FAQ’s

EEA Course FAQ’s

What should I bring to class?

Environmental Education Associates provides all course materials, including course manuals, handouts, specimens and electronic media, where applicable.

You may want to bring a pen and note paper. We will supply pens and highlighters for those attending an initial training course. Those attending courses that are “hands-on” should be prepared for manual labor and should be outfitted appropriately with long pants and work boots. Environmental Education Associates will provide any additional safety equipment, including safety glasses and hard hats as determined by the circumstances.

Asbestos Training FAQs

I heard that there are special circumstances for asbestos. What exactly are they?

If you are being trained for the first time, you will need to bring your New York State Drivers License. If you are being trained by Environmental Education Associates and you are not a resident of New York State, you will need to contact the New York State Department of Motor Vehicles to obtain a New York ID number.

What if I just need an asbestos refresher?

If you have already received training, you’ll need to bring a copy of your 2832 (DOSH Form) along with a current government issued picture identification card.

What is the New York State Department of Health Asbestos Safety Training Program?

Workers involved in asbestos abatement must first receive appropriate training from a New York State Department of Health accredited asbestos safety training provider prior to being certified through the New York State Department of Labor Asbestos Licensing and Certification Unit.

The Department of Health has regulatory oversight of New York State accredited asbestos safety training providers. Part of the Bureau of Occupational Health, the Asbestos Safety Training Program regulates specific training courses in nine disciplines that involve the handling, evaluation, sampling and removal of asbestos containing materials.

How do I become certified to work with asbestos in New York?

In New York State, certification is a two-step process. To work with asbestos you must:

  1. Attend training in one of nine disciplines at a New York State Department of Health accredited asbestos safety training provider and then;
  2. Apply for a certificate through the New York State Department of Labor Asbestos Licensing and Certification Unit.

Also, when engaged in asbestos work activities you must be working for a New York State Department of Labor licensed asbestos contractor.

What if I took training or am certified/licensed in another state?

You need to read and complete the Asbestos Safety Training Equivalency/Reciprocity Application (DOH-4353). This application is for out of state trainees who seek a determination that their training is substantially equivalent to that required by 10 NYCRR, Part 73. If approved, out-of-state applicants will need to complete a New York State refresher course.

How often do I need to train or do I need to complete refresher training?

Asbestos workers must keep their training current by completing annual refresher training. Training is specific to each discipline and valid for one calendar year regardless of the expiration date on your New York State Department of Labor certificate or “hard card”. Once your training expires, you are in a grace period and cannot be actively engaged in asbestos work. You have a one-year grace period after your training expires in which to complete refresher training. Once your grace period expires (exactly two calendar years from the date of your last training course completion date), you are no longer eligible to complete refresher training and must repeat an initial course of training.

Are asbestos companies and contractors required to be licensed?

Yes, asbestos companies and contractors must be licensed through the New York State Department of Labor Asbestos Licensing and Certification Unit.

My New York asbestos certification has expired or will expire soon, what can I do to keep my certification?

You must complete annual refresher training at a New York State Department of Health accredited asbestos safety training provider. After completing training, you must renew your certification with the Department of Labor Asbestos Licensing and Certification Unit.

I am an asbestos investigator in New York City and I am licensed through the New York City Department of Environmental Protection. Do I need a certificate from New York State?

Yes, you need to be certified with the New York State Department of Labor, Asbestos Control Bureau, Asbestos Licensing and Certification Unit, if you are working anywhere in New York State (memorandum for New York City Asbestos Work).

In addition, New York City Department of Environmental Protection certified asbestos investigators, like all disciplines, must complete annual refresher training, regardless of the expiration date of their New York City Department of Environmental Protection or New York State Department of Labor certifications. This policy is outlined in the Asbestos Safety Training Program Memorandum 2009-01.

What are the different disciplines or types of certificates for asbestos workers?

There are nine separate and distinct disciplines in New York State. Each has a specific set of training requirements.

  1. Allied Trades – Any person performing any limited or special tasks in preparation for, or ancillary to, an asbestos project, such as a carpenter, electrician, plumber or similar occupation, or any other person who may potentially disturb friable or non-friable asbestos during the course of any employment.
  2. Operations and Maintenance – Any person who performs operations, maintenance and repair activities which may disturb minor quantities of ACM, PACM or asbestos material. Operation and maintenance certification permits the holder to perform OSHA Class III asbestos work only on minor asbestos projects. These minor asbestos projects must be associated with repairs required in the performance of emergency or routine maintenance activity, and is not intended solely as asbestos abatement. Such work may not exceed minor quantities of ACM to be disturbed within a single glovebag or a single negative pressure tent enclosure.
  3. Asbestos Handler (Worker) – Any person who removes, encapsulates, encloses, repairs or disturbs friable or non-friable asbestos, or who handles asbestos material in any manner which may result in the release of asbestos fiber.
  4. Contractor/Supervisor – Any person who performs supervision of persons (other than authorized visitors) permitted to enter the restricted area and regulated abatement work area. The supervisor is also responsible for performing the duties of the OSHA competent person for the asbestos project, consistent with current OSHA regulations.
  5. Inspector – Any person who performs the limited tasks involved in the asbestos survey, identification and assessment of the condition of asbestos and asbestos material and the recording and reporting thereof, or who is involved in the collection of bulk samples of asbestos material or suspected asbestos material for laboratory analysis.
  6. Management Planner – Any person who assesses the hazard posed by the presence of asbestos or asbestos containing material and/or who recommends appropriate response actions and a schedule for such response actions.
  7. Asbestos Project Air Sampling Technician – Any person who performs project air sampling.
  8. Project Monitor – Any person other than the asbestos abatement contractor’s supervisor, who oversees the scope, timing, phasing and/or remediation methods to be utilized on and the completeness of any asbestos project.
  9. Project Designer – Any person who plans the scope, timing, phasing and remediation methods to be utilized on any asbestos project.

What is the Asbestos Hazard Emergency Response Act (AHERA)?

AHERA, a provision of the Toxic Substances Control Act, became law in 1986. AHERA requires local education agencies to inspect their schools for asbestos-containing building material and prepare management plans to prevent or reduce asbestos hazards. Public school districts and non-profit private schools (collectively called local education agencies) are subject to AHERA’s requirements. This includes charter schools and schools affiliated with religious institutions.

The New York State Department of Health Asbestos Safety Training Program performs AHERA compliance audits and assistance at schools in New York State on behalf of the U.S. Environmental Protection Agency.

Lead Renovator Training FAQs

Why do I need to complete this training?

The new EPA rules state that any contractor participating on renovation projects on buildings or spaces that were built before 1978 must get certified under the guidelines of the Renovation, Repair, and Painting (RRP) Rule or they will face fines of $37,500 per day that they are working in a qualified space.

2. Do I have to become a certified Renovator if I am already a certified abatement supervisor?

Yes. As a certified abatement supervisor, you will be required to take a half day (4-hour) “refresher” course. This is also true for 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 Lead Based Paint Training Program,” prepared by HUD and NARI; or other courses previously approved by HUD for this purpose after consultation with EPA.

What do I have to do to become a certified Renovator?

A person can become a certified renovator by either:

  • Successfully completing an accredited renovator training course, or
  • 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.

Other than training, what else do I need in order to be in compliance?

In addition to training, your firm must become an accredited Renovation Firm by applying to the US Environmental Protection Agency (EPA). The registration fee is $300, separate from the training fee, and accreditation is valid for 5 years. You must have both the training certificate and the firm certificate present on all qualifying job sites.

EXCEPTIONS: EPA has the authority to authorize states, tribes and territories to administer their own RRP program that would operate in lieu of the EPA regulations. Currently the following states have been authorized by EPA and may have different compliance requirements from the federal program: Alabama, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oregon, Rhode Island, Utah, Washington, and Wisconsin.

Contractors who attend training and perform work in the following states are required to register with the state in lieu of the EPA: Alabama, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oregon, Rhode Island, Utah, Washington, and Wisconsin.

What are the responsibilities of a firm?

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.

When does the rule go into effect?

As of April 2010, all renovations must be performed by certified firms in accordance with the work practice standards and associated record keeping requirements. We suggest that you submit your Renovation Firm application to EPA or EPA-Authorized State at least 8 weeks in advance of the date you would need the certification.

How long is the accreditation good for?

EPA-Accredited 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.

The following states have exceptions:
Alabama, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oregon, Rhode Island, Utah, Washington, and Wisconsin.

Do all of my workers have to go through this training?

If you work on HUD or other government projects, you MAY need to have all workers certified. If this applies to you, please contact your Client or local jurisdiction to see what their requirements are. If your project is not HUD or government, there is only one certified Renovator required at your company but you must give on the job training to other persons performing renovation activities. In addition, you are required to maintain records of this training. Remember: 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.

Is it true that work performed under this rule does not require 3rd party clearance examination?

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.  See the Lead Sampling FAQ below.

Who is responsible for enforcing the rule?

US EPA is the enforcing agency. In addition, EPA has the authority to authorize states, tribes and territories to administer their own RRP program that would operate in lieu of the EPA regulations. Currently the following states have been authorized by EPA and may have different compliance requirements from the federal program: Alabama, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oregon, Rhode Island, Utah, Washington, and Wisconsin.

What is the legal status of this guide?

This FAQ 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’2s 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.

Is painting considered renovation if no surface preparation activity occurs?

No. If the surface to be painted is not disturbed by sanding, scraping, window replacement, or other activities that may cause dust, the work is not considered renovation and the EPA’s or Authorized State’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.

What if I renovate my own home?

The RRP 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.

Is a renovation performed by a landlord or employees of a property management firm considered a compensated renovation under the RRP lead program rules?

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.

Do I have to give out the lead pamphlet 7 days prior to beginning renovation activities?

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.

Lead Dust Sampling FAQ’s

What’s the regulatory difference between dust testing and clearance?

The important difference is examined when the results are in. Dust wipe testing culminates in reporting the results to the owners and occupants, regardless of the values relative to the EPA hazard standards. Clearance, on the other hand, requires that the Renovator “pass” the EPA hazards standards of 40, 250 & 400 ug/f2 for the floors, sill and wells respectively.
The EPA explains that information on results of dust sampling testing is likely to improve landlords and occupants awareness of dust-lead hazards. Per EPA, “It will also greatly improve their ability to make further risk management decisions”. As such, the owner can’t hold the Renovator to the hazard standards unless they’ve specified such in their contract agreement.
DWT and clearance must be performed by someone who has passed the EPA Dust Sampling Technician certification.
How many samples should be submitted to the lab for clearance for a project in 5 rooms?
13 samples plus 1 blank for a renovation clearance Floor, Windowsill, Window Trough from each room (12, if each room has these) and outside work area sample (1) and a blank (1). 13 samples + 1 Blank
Can a Renovator clear his own projects? How?
Yes, a Renovator can conduct post renovation evaluation on his/her own projects but there needs to be sufficient training before the clearance can be done. The dust wipe testing needs to be performed by a person who has successfully completed the EPA Dust Sampling Technician certification, a one day course presented by an EPA accredited trainer. EPA certified Inspectors and Risk Assessors can also serve as this role.
How does the UNYSE Labs Lead Wipe Kit work?
The kit gives homeowners and contractors the ability to conduct wipe samplings after lead safe work practices that meet HUD & EPA requirements and regulations. The cost is $195 and everything that is needed for the sampling is included. These items include wipes, tubes, gloves, chain of custody, and other sampling forms; everything you need to perform your sampling quickly and efficiently. EEA also includes a UPS shipping box for easy, convenient, and reliable service. Once the sampling is received at the lab, the results will be analyzed and processed within 72 hours. Once your samples arrive a new kit will be mailed so you never miss an opportunity to perform a clearance. This kit and service is USEPA, NLLAP, and AIHA approved.
The UNYSE Labs “do it yourself” lead dust sampling kit is a must need item for all contractors and home renovators. This convenient kit makes sampling easy along with the knowledge that you can rest easy with the UNYSE Lab processing your results. The leader in environmental testing analysis throughout New York State.
Lead Renovator FAQ’s

Do I have to become a certified Renovator if I am already a certified abatement supervisor?

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.

What do I have to do to become a certified Renovator?

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.

Where can I find this training?

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.

Other than training, what else do I need in order to be in compliance?

In addition to training, your firm must become an accredited Renovation Firm by applying to USEPA.

What are the fees associated with accreditation?

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.

What are the responsibilities of a firm?

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

How long is the accreditation good for?

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.

Do all of my workers have to go through this training?

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.

Who is responsible for enforcing the rule?

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.

What is the legal status of this guide?

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.

Is painting considered renovation if no surface preparation activity occurs?

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.

What if I renovate my own home?

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.

Is a renovation performed by a landlord or employees of a property management firm considered a compensated renovation under EPA’s lead program rules?

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.

Do I have to give out the lead pamphlet 7 days prior to beginning renovation activities?

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.

What’s your refund policy, especially if I have to cancel a course I’ve registered in?

Environmental Education Associates reserves the right to cancel classes due to low enrollment in advance of the course start date. In order to avoid any inconvenience, pre-registration with full payment is the only way to be notified if a class is cancelled. In the event that class is cancelled, refunds will be issued. If a student cancels five business days prior to class start date, refunds will be issued. If student cancels in less than 5 business days, credit will be issued for the next available class. If a student does not cancel their registration, or begins a class and is unable to complete the entire class, the student is ineligible for a refund, and is responsible for the full tuition