Renovator training certified

States must require contractors to be trained, certified, and licensed according to certain standards in order to abate (remove or otherwise control) lead paint. Specific types of contractors who do renovation and remodeling will also have to be trained and certified. If any state does not yet have a training and certification program in place by September 1998, the EPA will set up a program for that state by September 1999, out of its regional office. 

It is important to note that OJT is not as portable as certified renovator training nor is it intended to be. Certified renovators... 

EPA does not believe that work experience requirements are necessary because previous experience in the construction or renovation industry would do litde to help an individual understand or perform the work practices, which are not standard practice in the industry. Consequently, there is no relevant work experience for EPA to require. In addition, the work practices required by this final rule are sufficiently straightforward that EPA does not believe it is necessary to require work experience in addition to certified renovator training. 

Under this final rule, individuals who successfully completed an accredited abatement worker or supervisor course, and individuals who successfully completed either HUD, EPA, or the joint EPA/HUD model renovation training courses may take an accredited refresher renovation training course in lieu of the initial renovation training to become a certified renovator. In addition, individuals who have successfully completed an... 

Commenters raised concerns and had suggestions regarding how certified renovator training should be conducted in three broad areas course length course content and format and training of non-English speaking renovators. 

One commenter asked about the availability of the cleaning verification card, specifically, who would produce them, where would they be available, and how often do they need to be replaced. EPA intends to produce the cleaning verification cards and to make them available at accredited renovator training courses and on request from the National Lead Information Center. Several commenters argued that a third party should perform cleaning verification (or visual inspection, in the case of exterior jobs) rather than the certified renovator. 

Contractor certification and training rules were first put into effect in 1998. Those initial rules required lead paint professionals to be certified and trained and imposed an accreditation program for training programs, individual certifications for renovators, and specific work practice standards. ... 

Beginning April 22, 2010, federal law requires that contractors performing renovation, repair, and painting projects that disturb more than six square feet of paint in homes, childcare facilities, and schools built before 1978 must be certified and trained to follow specific work practices to prevent lead contamination. Contractors working with lead are required to be in a lead-safe certified company. Many houses and apartments built before 1978 have paint that contains lead (called lead-based paint). Lead from paint, chips, and dust can pose serious health hazards if not taken care of properly. 

Renovations must be performed by certified firms. The certification requirements for renovation firms are identical to the certification requirements for firms that perform lead-based paint activities, except that renovation firm certification lasts for 5 years instead of 3 years. A firm that wishes to become certified to perform renovations must submit an appUcation, along with the correct amount of fees, attesting that it will assign a certified renovator to each renovation that it performs, that it will use only certified or properly trained individuals to perform renovations, and that it will follow the work practice standards and recordkeeping requirements in this regulation. 

The certified renovator or a worker trained and directed by a certified renovator must, at the conclusion of each work day, store any collected lead-based paint waste from renovation activities under containment, in an enclosure, or behind a barrier that prevents release of dust and debris and prevents access to the waste. In addition, the certified renovator or a worker under the direction of the certified renovator transporting lead-based paint waste from a worksite must contain the waste to prevent identifiable releases. 

At a minimum, the program requirements must include accredited training for renovators and procedures and requirements for recertification. State, territorial, and tribal programs applying for authorization are also required to include work practice standards for renovations that ensure that renovations are conducted only by certified renovators or renovation firms and that renovations are conducted using work practices at least as protective as those of the Federal program. 

This final rule exempts renovations that affect only components that a certified renovator, using a test kit recognized by EPA, determines are free of lead-based paint. EPA has deleted the regulatory thresholds for lead-based paint from this definition because they unnecessarily complicate the exception. A certified renovator is a person who has taken an accredited course in work practices. This training will include how to properly use the EPA-approved test kits. This final rule also establishes the process EPA will use to recognize test kits. 

Another commonly cited reason for not supporting the use of test kits by certified renovators was the lack of any sampling protocol in the regulation. A related concern was that the training in sampling techniques and protocols in the lead-based paint inspector course could not be shortened to fit within the 8-hour renovator course and still retain all of the necessary information. EPA wishes to make it clear that the 8-hour renovator course will not train renovators in how to select components for sampling because the certified renovator must use a test kit on each component affected by the renovation. The only exception to this is when the components make up an integrated whole, such as the individual stair treads and risers in a staircase. 

In addition, the rule requires that all persons performing renovation work either be certified renovators or receive on-the-job training (OJT) from and perform key tasks under the direction of a certified renovator. To become a certified renovator, a person must successfully complete an accredited renovator course. EPA renovator certification allows the certified individual to perform renovations in any state, territory, or Indian tribal area that does not have a renovation program authorized under 40 CFR, Part 745, Subpart Q. These requirements are discussed in greater detail in the following sections. 

Under this final rule, EPA is establishing new individual certification disciplines for renovators and dust sampling technicians. All renovation activities covered by this final rule must be performed by certified renovators, or by renovation workers who receive on-the-job training in the work practices from a certified renovator. 

Today s work practices are lead-safe work practices. The work practice standards listed in 745.85(a) are the same tasks that the other workers will be directed in and trained to do by the certified renovator (except for cleaning verification). In addition, the term lead-safe work practices has different meanings in different contexts, and this change is to make clear that the work practices required by this final rule are the work practices required in 745.85(a). 

Workers need not be trained in work practices that do not pertain to the renovations they will be performing. If the certified renovator will be the one posting warning signs, establishing containment, and cleaning the work area after the renovation, it is not necessary for the certified renovator to provide instruction on these tasks to any workers who will be used elsewhere on the project. Similarly, workers hired to perform only exterior projects need not receive training in how to clean an interior work area after a renovation. 

Some commenters agreed that OJT by a certified renovator is sufficient for training workers. One commenter stated that as long as a specific person is designated to oversee the job, there is no need for all workers onsite to have formal training. The commenter noted the similarity between this approach and OSHA s competent person standard. EPA agrees that there are some similarities between the approach in this final rule and OSHA s competent person standard. 

However, the majority of commenters had concerns about the use of OJT to train workers. Many argued that OJT is insufficient for providing workers with the necessary skills and thought renovation workers should receive formal Lead-Safe Work Practices (LSWP) training such as a 1-day course equivalent to that required for certified renovators. Some of these commenters also thought that workers should be certified or licensed. 

Several commenters thought that workers would not receive adequate OJT because the certified renovator was not qualified to train others. They noted that the certified renovators are renovators, not professional trainers, and do not necessarily have the skills necessary for teaching others. 

After consideration of these commenters concerns, EPA has concluded that OJT is sufficient for training some renovation employees. The work practice standards of this final rule are not complex or difficult to institute, and those activities critical to ensuring the lead-safe outcome of the project are either conducted by certified renovators or directed by certified renovators. The remainder of the project is often just the renovation itself, and EPA was careful when developing these final work practices to minimize the effect on the way typical renovations are conducted. With the exception of the prohibition of certain unsafe practices, renovation methods are unaffected by this rule. For example, the work practices of this final rule do not affect the method a firm would employ to replace a window. 

A certified renovator should be able to demonstrate to other firm employees work practices, such as how to work within containment and how to move into and out of containment without spreading lead dust and debris. EPA does not believe a professional trainer is needed to train renovation workers, who will be directed by a certified renovator if they will be performing any... 

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