It is time to start thinking about renewing your U.S. Environmental Protection Agency (EPA) Lead Renovation, Repair and Painting (LRRP) program certifications, as previously reported by AGC. All construction firms and their employees are subject to the LRRP rule, if they perform regulated renovation activities, such as work that disturbs lead-based paint in homes, child-care facilities or schools, with kids six years or younger, built before 1978.
Following are important updates for RRP contractors working in EPA administered jurisdictions. This includes all but 14 states that operate their own LRRP program (see “Authorized State” bullet below for more information). 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 – click here to download the materials at no charge. 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.
Change to Firm Application Process – Effective Sept. 15, 2015, EPA will no longer offer the option to submit firm certification applications by mail. After that date all firm applications, payments, updates and certificate replacement requests must be done online. The option to submit firm applications online has been available for some time; currently 85% of applications are submitted in this manner, according to EPA. Acceptable methods for payments online include credit card, debit card, or electronic check.
Renovator Training Expiration Extended – EPA has extended the training expiration date for many certified renovators. This was done so if the proposed changes of January 2015 are finalized, which would allow more distance learning options, many more renovators will be able to take advantage of those changes. Affected expiration dates are based on when the previous course was taken. Note: The extensions do not apply to firm certifications.
Firm Certification – Firm certifications expire after five years. This means that firm certifications have already begun to expire – please check your expiration date. EPA encourages firms to apply early, at least 90 days before their expiration, to ensure their application is processed before they expire. You won’t be penalized for applying early; just be sure to select “re-certification” and your new 5-year certification won’t begin until your current certification expires. Click here for information about applying for re-certification.
Note: EPA is concerned that some renovation firms have trained employees but the firm itself is not certified. All businesses providing regulated renovation activities must be certified (even sole proprietorships). Firm certification involves the submission of an application and fee to EPA.
Amending Your Application – A firm must amend its certification within 90 days of the date a change occurs to information included in their most recent application. If the firm fails to amend its certification within that period, the firm may not perform renovations or dust sampling until their certification is amended.
Authorized States – 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 AL, DE, GA, IA, KS, MA, MS, NC, OK, OR, RI, UT, WA and WI.
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. Click here to see the “frequent questions” related to this topic.
Frequent Question Database (FQ database) – EPA maintains an online database of Frequent Questions regarding its Lead Program. It is regularly updated, but if you cannot find the answer you are looking for, call the National Lead Information Center at 1-800-424-LEAD (5323).
Here's an example from the FQ database: I took my initial renovator training on May 1, 2010, and my training expiration was extended, will I get something that shows my expiration was extended? The answer: No, take a look at FQ 23002-36710 for more details!
For more information on EPA’s LRRP rule, please see AGC’s Fact Sheet or contact Leah Pilconis, senior environmental advisor to AGC, at pilconisl@agc.org.