Renovator training renovation workers

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. 

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. 

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... 

In addition, to some extent, OJT is continuous and certified renovators will likely need to continue to provide training to workers based on the activities that they will be expected to perform on a particular job. A certified renovator would not need to provide OJT to the same worker on consecutive jobs if the worker is performing the same work, but if the nature of the work varies, or if the firm hires a new employee, relevant OJT would have to be provided for the work to be performed. EPA believes that the continuous nature of OJT obviates the need for a refresher training requirement in the rule and will serve as an incentive for firms to have their permanent employees trained as certified renovators. EPA also believes that refresher training per se is not practical, given that OJT will be specific to the job in question. 

This final rule also requires firms performing renovations to retain documentation of compliance with the work practices and other requirements of the rule. Specifically, the firm must document that a certified renovator was assigned to the project, that the certified renovator provided on-the-job training for workers used on the project, that the certified renovator performed or directed workers who performed the tasks required by this final rule, and that the certified renovator performed the post-renovation cleaning verification. This documentation must... 

Further, performing abatement is a highly specialized skill that workers and supervisors must learn in training courses accredited by EPA or authorized states, territories, or tribes. In contrast, EPA is not interested in teaching persons how to be painters, plumbers, or carpenters. Rather, EPA s objective is to ensure that persons who already know how to perform renovations perform their typical work in a lead-safe manner. 

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. 

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. 

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. 

Because EPA is not requiring any additional education or work experience requirements, or a third-party examination similar to that taken by inspector, risk assessor, or supervisor candidates, EPA believes that there is little value in requiring candidates to apply to EPA to receive their renovator or dust sampling technician certification. Currently, the only certified discipline without prerequisites in education or experience, or a third-party examination, is the abatement worker. When candidates for worker certification apply to EPA, EPA verifies that the copy of the training course certificate submitted with the application is from an accredited training provider. Without requiring renovators or dust sampling technicians to apply to EPA for certification, EPA will still receive course completion information from course providers. With this information, EPA will have a complete list of certified renovators and will be able to check to see if a particular course completion certificate... 

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... 

Under this final rule the certified renovator or a worker trained by and under the direction of the certified renovator is required to ensure that all personnel, tools, and other items including waste are free of dust and debris when leaving the work area. The certified renovator or a worker trained by and under the direction of the certified renovator must also contain waste to prevent releases of dust and debris before the waste is removed from the work area for storage or disposal. If a chute is used to remove waste from the work area, it must be covered. At the conclusion of each work day and at the conclusion of the... 

The 2006 Proposal also included a requirement that renovation firms maintain documentation of compliance with the renovator and worker training requirements and the work practice requirements. This documentation would have had to include signed and dated descriptions of how activities performed by the certified renovator were conducted in compHance with the proposed requirements. To demonstrate how these recordkeeping requirements might be met, EPA prepared and placed into the docket a draft recordkeeping checklist. 

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