LEAD TRAINING FAQS
LEAD RENOVATOR COURSE TRAINING FREQUENTLY ASKED QUESTIONS
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.
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.
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. 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.
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.
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.
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 FREQUENTLY ASKED QUESTIONS
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.
