Are You Ready for EPA's Renovator Rule?
Do I have to become a certified Renovator if I am already a certified abatement supervisor?
What do I have to do to become a certified Renovator?
Where can I find this training?
Other than training, what else do I need in order to be in compliance?
What are the fees associated with accreditation?
What are the responsibilities of a firm?
When does the rule go into effect?
How long is the accreditation good for?
Do all of my workers have to go through this training?
Do I have to give out the lead pamphlet 7 days prior to beginning renovation activities?
Who is responsible for enforcing the rule?
What is the legal status of this guide?
Is painting considered renovation if no surface preparation activity occurs?
What if I renovate my own home?
Is a renovation performed by a landlord or employees of a property management firm considered a compensated renovation under EPA's lead program rules?
Is it true that work performed under this rule does not require 3rd party clearance examination?
Q: Do I have to become a certified Renovator if I am already a certified abatement supervisor?
A: Yes. As a certified abatement supervisor, you will be required to take a half day (4-hour) "refresher" course. This is also true of those who have completed the lead abatement worker, or any recognized "Lead Safe Work Practices" courses, including the lead based paint maintenance training program "Work Smart, Work Wet and Work Clean to Work Lead Safe," prepared by NATA for EPA and HUD; "The Remodelers and Renovators Led Based Paint Training Program," prepared by HUD and NARI; or other courses previously approved by HUD for this purpose after consultation with EPA.
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Q: What do I have to do to become a certified Renovator?
A: A person can become a certified renovator by either:
1.successfully completing an accredited renovator training course, or
2.successfully completing an accredited refresher renovator training course, if the individual previously completed an accredited abatement worker or supervisor course, or has completed an EPA, HUD, or EPA/HUD model renovation training course (commonly known as Lead Safe Work Practices). Proof of prior training must be submitted and verified by the training provider.
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Q: Where can I find this training?
A: Environmental Education Associates has been accredited by the USEPA to offer training throughout the nation at our fixed locations as well as off-site locations. You can sign up for one of our scheduled courses on-line, or call our training department. If you would like to set up a new course at one of our locations or at a different location, call our Training Coordinator, Lynn Burlingham at 888-436-8338 ext 211.
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Q: Other than training, what else do I need in order to be in compliance?
A: In addition to training, your firm must become an accredited Renovation Firm by applying to USEPA.
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Q: What are the fees associated with accreditation?
A: There are 2 certification options from the USEPA. Renovation Firm Certification is $300 and a combined Lead-based Paint Activities and Renovation Firm Certification is $550. There is no fee for individual certification; individuals are certified by the trainer, not the USEPA. Please note that EPA Certification fees do not include any training fees.
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Q: What are the responsibilities of a firm?
A: In addition to obtaining a Renovation Firm License, firms performing renovations must ensure that:
All persons performing renovation activities are certified renovators or have received on-the-job training by a certified renovator;
A certified renovator is assigned to each renovation performed by the firm; and
All renovations are performed in accordance with applicable work practice standards
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Q: When does the rule go into effect?
A: Firms may apply for certification beginning October 2009 and must be certified by April 2010. After April 2010, all renovations must be performed by certified firms in accordance with the work practice standards and associated recordkeeping requirements. We suggest that you submit your Renovation Firm application to EPA at least 8 weeks in advance of the date you would need the certification.
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Q: How long is the accreditation good for?
A: Firms will have to re-apply for re-certification every 5 years. To maintain individual certification, a person must go through an accredited refresher course every 5 years.
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Q: Do all of my workers have to go through this training?
A: No, but the certified Renovator must give on the job training to other persons performing renovation activities and maintain records of this training. Remember that a certified Renovator must be assigned to each renovation project, so you will likely need more than one certified Renovator if you have multiple jobs going on simultaneously.
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Q: Is it true that work performed under this rule does not require 3rd party clearance examination?
A: Yes, after the renovation is complete, the firm must clean the work area. The certified Renovator must verify the cleanliness of the work area using a procedure involving disposable cleaning cloths. However, you may request that a clearance be performed by a certified professional.
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Q: Who is responsible for enforcing the rule?
A: At this point, USEPA is the enforcing agency. States and tribes may (in the future) become authorized to implement this rule. The rule contains procedures for the authorization of states, territories, and tribes to administer and enforce these standards and regulations in lieu of a federal program.
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Q: What is the legal status of this guide?
A: This guide was prepared pursuant to section 212 of SBREFA. EPA has tried to help explain in this guide what you must do to comply with the Toxic Substances Control Act (TSCA) and EPA's lead regulations. However, this guide has no legal effect and does not create any legal rights. Compliance with the procedures described in this guide does not establish compliance with the rule or establish a presumption or inference of compliance. The legal requirements that apply to renovation work are governed by EPA's 2008 Lead Rule, which governs if there is any inconsistency between the rule and the information in this guide.
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Q: Is painting considered renovation if no surface preparation activity occurs?
A: No. If the surface to be painted is not disturbed by sanding, scraping, or other activities that may cause dust, the work is not considered renovation and EPA's lead program requirements do not apply. However, painting projects that involve surface preparation that disturbs paint, such as sanding and scraping, would be covered.
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Q: What if I renovate my own home?
A: EPA's lead program rules apply only to renovations performed for compensation; therefore, if you work on your own home, the rules do not apply. EPA encourages homeowners to use lead-safe work practices, nonetheless, in order to protect themselves, their families, and the value of their homes.
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Q: Is a renovation performed by a landlord or employees of a property management firm considered a compensated renovation under EPA's lead program rules?
A: Yes. The receipt of rent payments or salaries derived from rent payments is considered compensation under EPA's lead program. Therefore, renovation activities performed by landlords or employees of landlords are covered.
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Q: Do I have to give out the lead pamphlet 7 days prior to beginning renovation activities?
A: The 7-day advance delivery requirement applies only when you deliver the lead pamphlet by mail; otherwise, you may deliver the pamphlet anytime before the renovation begins as long as the renovation begins within 60 days of the date that the pamphlet is delivered. For example, if your renovation is to begin May 30, you may deliver the pamphlet in person anytime between April 1 and start of the project on May 30, or you may deliver the pamphlet by mail anytime between April 1 and May 23.
