Requirements for Firm and Personnel Lead Renovator RRP Certification

Both of these Certifications are required for any firm participating in mitigation work for any program credentialing through Sublynk.

Summary

The Renovation, Repair, and Painting (RRP) Rule is a regulation under the Environmental Protection Agency (EPA) designed to protect the public from lead-based paint hazards during renovations, repairs, and painting activities. To comply with this rule, firms and individual renovators must obtain certification and follow specific procedures when working on buildings constructed before 1978. This article explains the certification requirements for both firms and personnel (lead renovators) under the RRP rule.

Company Certification Requirements

All firms, including sole proprietorships, performing renovations, repairs, or painting work that disturbs lead-based paint in homes, child care facilities, or schools built before 1978 must be certified under the RRP rule. This applies to both general contractors and subcontractors.

Steps for Firm Certification:

1. Submit an Application:
   1. Firms must apply to the EPA (or the state agency, if the state has an EPA-authorized RRP program), and can do so via this link.
   2. Submit the application online through the EPA's e-certification system or via mail.
2. Pay the Certification Fee:
   1. A fee is required when submitting the application. Fees very but typically range from $300 to $550, depending on the state or region.
3. Receive EPA Certification:
   1. Once approved, the EPA (or state agency) will issue a certification that is valid for five years.
   2. The firm must ensure they renew their certification before it expires.

Personnel Lead Renovator Certification Requirements

In addition to firm certification, the RRP Rule requires that individual renovators (also known as Lead-Safe Certified Renovators) be trained to manage lead-based paint hazards. This is satisfied by members of your organization completing an 8-hour EPA accredited lead renovator course, as well as passing an exam. This requirement is NOT satisfied by your firm certification.

Steps for Lead Renovator Certification:

1. Complete an EPA Accredited Training Course:
   1. Renovators must attend an EPA-accredited lead-safe training course that covers topics like safe work practices, lead containment, and cleanup procedures.
   2. Training typically takes 8 hours, including both classroom instruction and hands-on exercises.
2. Pass the Certification Exam:
   1. Upon course completion, renovators must pass a certification exam that tests their understanding of lead-safe practices.
3. Receive Lead Renovator Certification:
   1. After passing the exam, renovators receive an official Lead Renovator Certification.
   2. This certification is valid for 5 years.
4. Performing Lead-Safe Work:
   1. Certified renovators must be present on the job site or be easily reachable when lead-safe work is being performed.
   2. They are responsible for training non-certified workers on-site and ensuring that lead-safe practices are being followed.
5. Refresher Training:
   1. To maintain certification, renovators must complete an EPA-accredited refresher course before their certification expires. The refresher course is typically 4 hours long.

Where to find an accredited trainer

EPA accredited trainer search tool - https://cdxapps.epa.gov/ocspp-oppt-lead/training-search

States that run an EPA approved accreditation program:

Contractors in these states should follow the link provided to obtain more information about the specific RRP requirements and procedures in their state or tribe.

• Alabama
• Delaware
• Georgia
• Iowa
• Kansas
• Massachusetts
• Mississippi
• North Carolina
• Oklahoma
• Oregon
• Rhode Island
• Utah
• Vermont
• Washington
• Wisconsin
• Minnesota Chippewa Tribe - Bois Forte (Nett Lake)

Penalties for Non-Compliance

Firms and renovators that fail to comply with the RRP rule, including the failure to become certified or follow lead-safe practices, may face significant penalties. The EPA can impose fines of up to $48,762 per violation per day for non-compliance. It's essential that both firms and renovators maintain certification and properly implement lead-safe work procedures to avoid legal and financial repercussions.

Conclusion

Obtaining RRP certification is critical for both firms and individual personnel involved in renovation, repair, and painting projects on properties built before 1978. Following the EPA's certification and lead-safe work practices ensures that workers, residents, and the environment are protected from the dangers of lead-based paint exposure.

For more information on the application process and training providers, visit the EPA's RRP Program page or your state's specific lead certification resources.