EPA Lead Renovator

As of April 22, 2010, the EPA has mandated that contractors who perform renovation, repairs and painting must train and re-certify in lead-safe work practices before renovating certain projects.

There are 5 steps to ensure you are in compliance:

  1. Get registered for an EPA-approved lead certification course
  2. Submit an application to EPA on behalf of your company
  3. Complete the training in a public or private workshop
  4. Pass the 25-question certification exam given in class
  5. Receive approval from EPA
  6. With these five steps completed, you’re in the clear!

If you work around lead, or could potentially take on a project that would involve working around lead, it’s critical to your business that your employees attend the EPA lead renovator certification course. Failure to comply with EPA certification requirements will result in fines of $37,500 per day that you are working in the field on a qualifying project.

CS Consulting is the only approved EPA Provider in Wyoming and offers the new EPA lead certification, conducting initial training in Lead Paint Safety for Renovation, Repair and Painting and certifying renovators to perform lead-safe work.

CS Consulting’s EPA Lead Renovator course costs $300 per person.

EPA Requirements

Common renovation activities like sanding, cutting and demolition can create hazardous lead dust and chips by disturbing lead-based paint, which can be harmful to adults and children.

To protect against this risk, on April 22, 2008, EPA issued the Renovation, Repair and Painting Rule. It requires that firms performing renovation, repair and painting projects that disturb lead-based paint in pre-1978 homes, child-care facilities and schools be certified by EPA and that they use certified renovators who are trained by EPA-approved training providers to follow lead-safe work practices. Individuals can become certified renovators by taking an eight-hour training course from an EPA-approved training provider. Learn how to become an EPA certified firm and where to take a training course near you.

Contractors must use lead-safe work practices and follow these simple procedures:

The rule requires that contractors performing renovation, repair and painting projects that disturb lead-based paint provide to owners and occupants of child care facilities and to parents and guardians of children under age six that attend child care facilities built prior to 1978 the lead hazard information pamphlet Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools (PDF) (10 pp, 7.0MB). | en español (PDF) (11 pp, 2.1MB)

The rule affects paid renovators who work in pre-1978 housing and child-occupied facilities, including:

  • Renovation contractors
  • Maintenance workers in multi-family housing
  • Painters and other specialty trades.

Under the rule, child-occupied facilities are defined as residential, public or commercial buildings where children under age six are present on a regular basis. The requirements apply to renovation, repair or painting activities. The rule generally does not apply to minor maintenance or repair activities where less than six square feet of lead-based paint is disturbed in a room or where less than 20 square feet of lead-based paint is disturbed on the exterior, but this does not include window replacement, demolition or prohibited practices.

Read EPA’s Lead Renovation, Repair and Painting rule.

EPA Authorized State Programs

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. When a state, tribe or territory becomes authorized, contractors and training providers working in these areas and consumers living there should contact the appropriate state, tribal or territorial program office. Currently the following states have been authorized by EPA (note: in following these links you will be leaving the EPA web site): Alabama, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oregon, Rhode Island, Utah, Washington, and Wisconsin.

Information for Contractors

As a contractor, you play an important role in helping prevent lead exposure. Ordinary renovation and maintenance activities can create dust that contains lead. By following the lead-safe work practices, you can prevent lead hazards.

NOTE: Contractors and training providers working in Alabama, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oregon, Rhode Island, Utah, Washington or Wisconsin must contact the state to find out more about its training and certification requirements. These states are authorized to administer their own RRP programs in lieu of the federal program. In following the above links, you will leave the EPA web site.

Contractors who perform renovation, repairs, and painting jobs in pre-1978 housing and child-occupied facilities must, before beginning work, provide owners, tenants and child-care facilities with a copy of EPA’s lead hazard information pamphlet Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools (PDF) (10 pp, 7.0MB) | en español (PDF) (11 pp, 2.1MB). Contractors must document compliance with this requirement; EPA’s pre-renovation disclosure form (PDF) (1 pp, 53K) may be used for this purpose.

Federal law requires renovation firms (including sole proprietorships) to be certified and requires individuals to be trained in the use of lead-safe work practices. To become certified, renovation contractors must submit an application and fee payment to EPA or to the state if you work in one of the states authorized to run its own RRP programs. Individuals wishing to become certified renovators must take training from an EPA-accredited training provider.

EPA has up to 90 days after receiving a complete application for firm certification to approve or disapprove the application.

Please note that if you previously completed certain lead-safe work practice training prior to October 4, 2011, you may be eligible to take a four-hour refresher course instead of an eight-hour initial course from an accredited training provider to become certified. See a list of eligible courses.

Contractors who perform renovation, repairs and painting jobs should also:

  • Provide a copy of your EPA or state lead training certificate to your client.
  • Tell your client what lead-safe methods you will use to perform the job.
  • Learn the lead laws that apply to you regarding certification and lead-safe work practices.
  • Ask your client to share the results of any previously conducted lead tests.
  • Provide your client with references from at least three recent jobs involving homes built before 1978.
  • Keep records to demonstrate that you and your workers have been trained in lead-safe work practices and you follow lead-safe work practices on the job. To make recordkeeping easier, you may use the sample recordkeeping checklist (PDF) (1 pg, 141K) that EPA has developed to help contractors comply with the renovation recordkeeping requirements.

Read about how to comply with EPA’s rule in the EPA Small Entity Compliance Guide to Renovate Right (PDF) (32 pp, 5.5MB).

Contractors should also read the EPA Enforcement Alert newsletter titled Compliance with New Federal Lead-Based Paint Requirements (PDF) (4 pp, 120K).

Information for States and Tribes

EPA headquarters has developed guidance documents to assist states and tribes that are applying to EPA for authorization to manage their own lead renovation, repair and painting programs (PDF) (122 pp, 257K).

Information for Property Owners of Rental Housing, Child-Occupied Facilities

Property owners who renovate, repair, or prepare surfaces for painting in pre-1978 rental housing or space rented by child-care facilities must, before beginning work, provide tenants with a copy of EPA’s lead hazard information pamphlet Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools (PDF) (10 pp, 7.0MB) | en español (PDF) (11 pp, 2.1MB). Owners of these rental properties must document compliance with this requirement; EPA’s sample pre-renovation disclosure form (PDF) (1 pp, 53K) may be used for this purpose.

Property owners who perform these projects in pre-1978 rental housing or space rented by child-care facilities must be certified and must follow the lead-safe work practices required by EPA’s Renovation, Repair and Remodeling rule. To become certified, property owners must submit an application for firm certification (PDF) (9 pp, 642K) and fee payment to EPA. The Agency has up to 90 days after receiving a complete request for certification to approve or disapprove the application.

Property owners who perform renovation, repairs, and painting jobs in rental property should also:

  • Take training to learn how to perform lead-safe work practices.
  • Learn the lead laws that apply to you regarding certification and lead-safe work practices.
  • Keep records to demonstrate that you and your workers have been trained in lead-safe work practices and that you follow lead-safe work practices on the job. To make recordkeeping easier, you may use the sample recordkeeping checklist (PDF) (1 pg, 141K) that EPA has developed to help contractors comply with the renovation recordkeeping requirements.
  • Read about how to comply with EPA’s rule in the EPA Small Entity Compliance Guide to Renovate Right (PDF) (32 pp, 5.5MB).

Information for Homeowners Working at Home

If you are a homeowner performing renovation, repair, or painting work in your own home, EPA’s RRP rule does not cover your project. However, you have the ultimate responsibility for the safety of your family or children in your care. If you are living in a pre-1978 home and planning to do painting or repairs, please read a copy of EPA’s Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools (PDF) lead hazard information pamphlet (10 pp, 7.0MB). | en español (PDF) (11 pp, 2.1MB). You may also want to call the National Lead Information Center at 1-800-424-LEAD (5323) and ask for more information on how to work safely in a home with lead-based paint.

Information for Tenants and Families of Children under Age 6 in Child Care Facilities and Schools

As a tenant or a parent or guardian of children in a child care facility or school, you should know your rights when a renovation job is performed in your home, or in the child care facility or school that your child attends.

Information for Training Providers

Training Provider Application and Instructions (PDF) (13 pp, 1.1M) – Training providers applying for accreditation must submit a completed application and fee payment as described in the application instructions. The following list contains key information required in the application:

  • Training program’s name, address, and telephone number;
  • A list of courses that the training program is applying for accreditation;
  • Statement certifying that the training program meets the requirements established by 40 CFR 745.225(c);
  • Statement certifying the basis of the training curriculum (EPA approved or non-approved – if non-approved then include a course agenda and copies of the student and instructor manuals;
  • A description of the training facilities and hands-on equipment used during training;
  • A copy of the course test;
  • A description of the activities and procedures that will be used to assess the skills associated with the hand-on component of the course;
  • A copy of the quality control plan as required by 40 CFR 745.225(c)(9).

Instructions for Accredited Training Providers – This document provides EPA accredited renovator and dust sampling technician training providers instructions regarding:

  • Certificate requirements and numbering protocol
  • How to notify EPA of training activities
  • Eligibility requirements for refresher training
  • Instructions for digital photograph submission
  • Recordkeeping requirements
  • Amending training provider accreditation
  • Cleaning verification cards

Renovation, Repair and Painting Rule Courses – These courses were developed by the U.S. EPA, in collaboration with the U.S. Department of Housing and Urban Development (HUD), to train renovation, repair, and painting contractors and dust sampling technicians on how to comply with EPA’s Renovation, Repair, and Painting (RRP) rule, and HUD’s Lead Safe Housing rule. The Agency will not be developing a model Dust Sampling Technician refresher training at this time.

Cleaning Verification Cards. Trainers can obtain copies of the Cleaning Verification Cards by contacting the National Lead Information Center at 1-800-424-LEAD (5323).

NOTE: Contractors and training providers working in Alabama, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oregon, Rhode Island, Utah, Washington, or Wisconsin must contact the state to find out more about its training and certification requirements. These states are authorized to administer their own RRP programs in lieu of the federal program. In following the above links you will leave the EPA web site.

Information for Lead Test Kit Vendors

Lead Test Kits – Read about EPA-recognized lead test kits and the Agency’s effort to evaluate the effectiveness of lead test kits.

Information for Realtors and Property Management Firms

Realtors and property managers should make themselves aware of the requirements in the Lead Renovation, Repair and Painting (RRP) Rule. EPA is working closely with the National Association of Realtors to make realtors and property managers aware of the hazards of lead paint poisoning and ways to prevent it, and the association has developed a series of guidance videos aimed at realtors and property managers:

Also read EPA’s brochure about RRP for building managers (PDF) (2 pp, 607K).

Post-Disaster Renovations and Lead-Based Paint

EPA has issued a fact sheet describing how the RRP regulation applies to renovations and repairs due to natural disasters like floods or hurricanes. Read the fact sheet (PDF) (2 pp, 79K).

Related Notices, Final and Proposed Rules, and Background Information on EPA’s Lead Renovation, Repair and Painting Program Rule

Read EPA’s July 15, 2011, final Clearance Rule (PDF) (29 pp, 290KB). The rule makes minor amendments to the Lead Renovation, Repair and Painting (RRP) rule related to training requirements and additional requirements for renovation firms. The Agency is not imposing additional “clearance” requirements included in the proposed rule because the existing RRP work practices and cleaning protocols effectively reduce lead dust hazards.

Read EPA’s April 22, 2010, final Opt-Out Rule. The rule eliminates the “opt-out” provision that previously exempted a renovation firm from the training and work practice requirements of the Renovation, Repair and Painting (RRP) rule. The rule also requires renovation firms to provide a copy of the records demonstrating compliance to the owner and, if different, the occupant of the building being renovated.

Read EPA’s July 15, 2009, Federal Register notice announcing a final rule to make minor revisions to the Renovation, Repair and Painting Program Rule. Read summary information on the final rule relating to requirements for training providers to submit photos of trainees.

Read other information related to the Renovation, Repair and Painting Program Rule.