Renovator training work practice standards

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. ... 

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. 

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. 

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). 

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. 

Some commenters questioned the need for firm certification, while others, including industry representatives, supported it. The agency believes that firm certification is necessary for several reasons. First, certification is an important tool for the agency s enforcement program. To become certified, a firm acknowledges its responsibility to use appropriately trained and certified employees and follow the work practice standards set forth in the final rule. This is especially important under this final rule, since the certified renovator is not required to perform or be present during all of the renovation activities. Under these circumstances, it is important for the firm to acknowledge... 

This final rule incorporates work practice standards generally derived from the HUD Guidelines, EPA s draft technical specifications for renovations, and the model training curriculum entitled Lead Safety for Remodeling, Repair, and Painting. ... 

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. 

One state commenter disagreed with EPA s proposed approach and requested that EPA authorize state, territorial, or tribal programs that incorporate only the training, certification, accreditation, and work practices of this final rnle becanse TSCA section 404 allows states to administer and enforce the standards, regulations, or other reqnirements established under TSCA section 402 or TSCA section 406, or both. EPA agrees with this commenter s reading of TSCA. Therefore, this final rule provides for the authorization of state, territorial, or tribal programs that inclnde either the pre-renovation edncation... 

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