The U.S. Environmental Protection Agency (EPA) recently revised its uniform guidance for EPA-credentialed inspectors who monitor compliance with the federal . For the regulated community, EPA has taken steps to bring many aspects of the firm certification and individual renovator training/certification processes online, seemingly to streamline compliance with the rule. EPA also regularly updates its online collection of on the Lead Program to clarify requirements for industry, including specific work practices that renovators must follow. This article recaps recent developments related to the implementation and enforcement of EPA鈥檚 Lead RRP rule.
EPA鈥檚 Lead RRP rule applies to all firms and individuals performing paid renovation, repair and painting projects that disturb lead-based paint in housing and child-occupied facilities (such as schools and day-care centers) built before 1978. This includes contractors, maintenance workers, painters and other specialty trades. to access EPA鈥檚 Web page and to sign up to receive Lead RRP updates from EPA.
What States Are Authorized To Run Their Own Renovation Programs?
To date, EPA has authorized 14 states to run their own renovation programs. Renovators and firms that only work within an authorized state(s) must be certified by each authorized state in which they do work, and would not be required to be certified by EPA. The authorized states are , , , , , , , , , , , , , .
If an individual renovator is certified by an authorized state they are also qualified to work in EPA-administered states, with no additional training. EPA certified renovators wishing to work in an authorized state should contact the state to determine if additional training/certification is necessary. Regardless of whether a firm is certified by an authorized state, if they do work in an EPA administered state they must be certified by EPA. to see the 鈥淔requently Asked Questions鈥 related to this topic.
Has EPA Issued Guidance for Inspectors Who Monitor Compliance with the Lead RRP Program?
EPA鈥檚 Office of Compliance has revised the . The RRP Inspection Manual establishes uniform guidance for EPA-credentialed inspectors who conduct inspections to monitor compliance with the RRP Rule. Compliance monitoring activities for the RRP Rule include work site inspections, records reviews of renovation firms, and auditing training provider courses that certify renovators.
How Do I Submit Applications Required by EPA鈥檚 Lead Renovation and Abatement Programs (e.g., Individual, Firm, Trainer)?
Effective immediately, all lead program applications must be submitted electronically rather than by mail. This applies to all , and applications required by EPA鈥檚 lead renovation and abatement programs. All applications, payments, updates and certificate replacement requests are done online using the Agency鈥檚 Central Data Exchange (CDX) system. Acceptable methods for payments online include credit card, debit card, or electronic check. Once submitted to EPA your application will be processed in two to three weeks. Upon completion, you will receive an email from lead.paint@epa.gov that includes your approval letter, certificate, and customized logo.
How Often Do Renovation Firms Need to Apply for Re-certification?
Firms that disturb painted surfaces in homes and child care facilities built before 1978 are subject to EPA鈥檚 Lead RRP rule and likely require EPA firm certification. These firm certifications expire every five years. Firms must apply for recertification to extend their certification an additional five years. Firms are encouraged to apply early, at least 90 days before their expiration, to ensure their application is processed before they expire. You won鈥檛 be penalized for applying early, just be sure to select 鈥渞e-certification鈥 and your new five-year certification won鈥檛 begin until your current certification expires. for information about applying for re-certification.
Where Can I Check the Status of My Firm鈥檚 Certification or Retrieve My Customized Lead Program Logo?
EPA's E-Enterprise site allows you to check the status of your firm certification application, download a copy of a recently issued certificate or retrieve your customized lead program logo. To access the site, you should go to , login in with your CDX user name and password, then go to the 鈥減rogress tracker鈥 section. From the 鈥減rogress tracker鈥 section you'll be able to see the status of your application and, if complete, download your certificate and customized program logo. The certificate and logo are available through the site for six months following issuance, after that you'll need to submit a .
Does My Training Course Completion Certificate Serve as My Individual Renovator Certification?
The training course completion certificate a renovator receives upon successful completion of an accredited renovator class serves as their individual certification. This document is very important because it鈥檚 needed to qualify for the refresher training, and a renovator must have a copy onsite at every renovation project they are assigned. A copy of the original is all that鈥檚 needed for these requirements, so remind your renovators to take several copies and keep the original in a secure place. If they can鈥檛 locate a copy of their certificate, they鈥檒l need to contact the trainer they took the course from and request a copy.
A renovator must take the four-hour refresher course before the expiration of their current training, or you will need to retake the 8-hour initial course to be certified again. Renovators must submit a copy of their current training course completion to the trainer to be eligible to take the refresher course. NOTE: Renovator refresher training can be done completely online with or without a hands-on component. Use to find trainers offering the option you are interested in.
Need More Information?
EPA maintains a list online of (FQ) regarding the Agency鈥檚 Lead Program. EPA recommends you check that first, then call the National Lead Information Center at 1-800-424-LEAD (5323) if you need more information. Here's an example from the FQ database. Can the required records and documentation be stored electronically rather than as paper copies? The answer is 鈥測es, the records can be stored electronically.鈥 Take a look at for more details.
Please contact Leah Pilconis, senior environmental advisor to 51风流 of America, at pilconisl@agc.org if you have additional questions.