Get Started At Least 90 Days Before Your Current Approval Expires!
It is time to start thinking about renewing your U.S. Environmental Protection Agency (EPA) Lead Renovation, Repair and Painting (LRRP) program certifications. Any construction firm – or you/your employees – are subject to this rule if you perform work for compensation that disturbs lead-based paint in homes, child-care facilities or schools (with kids six years or younger) built before 1978. Remember that renovation firm and renovator certifications both expire every five years. EPA is encouraging contractors to show that they are an “EPA Lead-Safe Certified Firm” by displaying the agency’s new logo. Under the Toxic Substances Control Act (TSCA), EPA may file an enforcement action against violators of the LRRP rule seeking penalties of up to $37,500 per violation, per day.
According to the EPA, “... no firm working in target housing or child-occupied facilities, where lead-based paint will be affected by the work, may perform, offer or claim to perform renovations without EPA Firm Certification 
In addition, firms must have at least one LRRP “Certified Renovator” assigned to each job site where lead-based paint is disturbed. The LRRP Certified Renovator is required to train all non-certified people at the job site in the use of lead-safe work practices. These requirements took effect on April 22, 2010. For complete details, see AGC’s Fact Sheet on EPA’s LRRP rule.
Do not wait! The re-certification process may take several months to complete. EPA has up to 90 days after receiving a complete application for firm certification to approve or disapprove the application. In addition, renovators must complete a renovator refresher course within five years of the date the individual completed the initial course – or the individual must re-take the initial 8-hour course to become certified again.
According to EPA, more than 135,000 renovation firms and roughly 493,000 individuals are currently certified – with a large percentage of these approvals occurring near the April 2010 compliance deadline. Thousands of contractors will need to enroll in refresher classes and renew their firm certifications in the coming months to stay in compliance. If you are one of them, start the process soon to avoid delays the risk of costly fines and penalties.
Re-certification Reminders
FIRMS: Remember that renovation firm certifications expire every five years. Be aware of your expiration date and submit your re-certification application at least 90 days before your firm's current certification expires, in accordance with EPA regulations. This will help ensure your re-certification is complete before your current certification expires. If you're not sure when your firm's certification expires, you can look it up online with EPA’s firm search tool. There is no penalty for applying for re-certification early. Your certification will be extended 5 years from the date of the current expiration regardless of how early you apply.
Firm certification involves the submission of an application and fee to EPA or to the state, if it has an EPA-authorized LLRP program, and paying a fee. Click here for information about applying for re-certification (or certification). Firms can apply for EPA LRRP certification or re-certification online to greatly reduce processing times (compared to paper applications). Follow this link to apply online.
RENOVATORS: Remember that renovator certifications also expire every five years. Once the re-certification course is completed, the renovator will be certified for five years from the date of course completion. Don't delay; if you don't take the 4-hour refresher course before the expiration, you'll have to retake the 8-hour initial course to be certified again.
EPA requires that everyone take certain sections of the EPA-approved certified renovator refresher course (as well as the initial certification) in person, due to the “hands-on” exercises that are a required part of the training. EPA is looking into the possibility of removing the current hands on training requirements for the refresher course to allow for more distance learning. If EPA follows that course, it will issue a proposal to get feedback on the idea. Renovators can use the EPA training search tool to find an EPA-accredited training provider (or a state-accredited provider, in the case of a state that EPA has authorized to administer its own LRRP program) in their area.
Authorized State Programs
EPA’s certifications are not necessarily accepted in all areas. EPA cannot compel authorized states or tribes to adopt programs identical to the Federal program or to establish reciprocity provisions. However, EPA continues to encourage states and tribes that may be considering establishing their own renovation programs to keep reciprocity in mind as they move forward.
As of October 2014, 14 states have their own LRRP programs (Alabama, Delaware, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oklahoma, Oregon, Rhode Island, Utah, Washington, and Wisconsin). If your firm is located in one of these states, you should contact them for information on their certification requirements. If you work outside of one of those states, your firm must be certified by EPA.
Lead Safe Certification Logo 
EPA is encouraging contractors who are certified under the LRRP rule to use a logo that highlights their firm as an “EPA Lead-Safe Certified Firm.” The agency has launched a new “Look for the Logo” campaign – telling customers seeking renovation work (particularly in pre-1978 target housing and child-occupied facilities) to check on whether their contractor is displaying the logo. For more information or to download the materials for free, click here.
If your firm is certified, you may want to promote your business by posting an EPA logo with your firm certification number on it on your website, brochures, advertisements, proposals, bills, signs, uniforms, vehicles and other materials. Firms can receive their custom Lead-Safe Certified Logo from EPA, via e-mail, approximately two weeks after they have been certified. For the Logo Use Guidelines, click here.
For more information on EPA’s LRRP rule, please see AGC’s Fact Sheet or contact AGC’s Leah Pilconis at pilconisl@agc.org.