Thursday, October 19, 2017

Can I Use My Lead Renovator (RRP) Certification to Work in Another State?

Since the EPA's Lead Renovation, Repair, and Painting (RRP) Rule was passed in 2010, the EPA has granted several states permission to run their own lead-safe renovation program in lieu of the EPA's federal program. These EPA-Authorized state programs are either equal to or more stringent than the EPA federal requirements. If you perform RRP work in multiple states, it is important to be aware of the nuances of these EPA-authorized states and how it may impact your training requirements, company registration, and work practices.

We'll touch on the work practice differences in a later article - today we will focus on the Registration and Training requirements. These are the terms we'll be using to discuss the requirements:

  • Firm Certification: This is a certification that denotes your company is a Lead-safe Firm and is licensed to perform RRP work. In order to receive this certification, you must submit an application and required fees to the proper enforcement body. This is required even if you are a sole proprietor.
  • Lead Renovator Training: The 1-day training class required for at least one employee at the company who will be supervising the RRP work (does not have to be owner). This also involves refresher training to maintain the certification.
  • Individual Registration: Refers to an application submitted to enforcing body after an individual completes the Lead Renovator training class.

EPA-Run State Requirements

First, if you only work in the 36 EPA-run states, you're in luck - all you need to do is apply for your Firm Certification with the EPA ($300) and have at least one employee who will be supervising the work take the 1-day Lead Renovator training class.  The EPA does not require an Individual Registration after the class.

  • These EPA-run States include: Alaska, Arizona, Arkansas, California, Colorado, Connecticut, Florida, Hawaii, Idaho, Illinois, Indiana, Kentucky, Louisiana, Maine, Maryland, Michigan, Minnesota, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Dakota, Ohio, Pennsylvania, South Carolina, South Dakota, Tennessee, Texas, Vermont, Virginia, West Virginia, Wyoming
So for example, if you only perform work in New York, New Jersey, and Pennsylvania, you are fully covered under one single EPA Firm Certification, and would just need to make sure at least one employee on any of your jobsites has taken the Lead Renovator course. 

EPA-Authorized State a.k.a. "Special State" Requirements

Next we have the 14 "Special States" as we like to call them, that are authorized by the EPA to enforce their own lead-safe renovation program for RRP work.
  • These EPA-Authorized States include: Alabama, Delaware, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oklahoma, Oregon, Rhode Island, Utah, Washington, and Wisconsin.
Each of these 14 states require a unique application for your Firm Certification, and some of them also require an Individual Registration application for those who take the Lead Renovator class. To view these specific requirements, check out our EPA-Authorized state chart

Firm & Individual Registration Reciprocity

Among the "Special States" and with the EPA, there is no reciprocity for the Firm Certification. 

If you work in both an EPA-run states AND a "Special State" it is important to make sure you have submitted the Firm Certification application to the EPA (which will cover you in any of the 36 states above), as well as to each Special State you work in. 

If your state requires an Individual Registration, there is no reciprocity for these applications either and must be submitted for each applicable state that requires it where you'll be working.

For example, if you work in Florida, South Carolina, Georgia, and Alabama (ie. 2 EPA states, 2 special states) the paperwork requirements would be:
  • Firm Certification: Submit company applications to EPA, Georgia, and Alabama
  • Individual Registration: Submit individual application to Georgia and Alabama

Training Reciprocity 

While there may not be reciprocity the firm and individual registrations, most states do accept reciprocity for the Lead Renovator training course.

NOTE: With the information below, we are assuming you have a valid training certificate - ie. not expired! Refresher training is required by EPA every 5 years (3 if completed online, which is an option every-other renewal period). Renewal periods vary among the "Special States" - you can view the details in the Authorized States chart.

36 EPA States
As we mentioned before, if you work in any of the EPA-run states, you will just need to take the Lead Renovator training course with any accredited training provider in any state. This includes training providers who are accredited through one of the 14 "Special States" - EPA is okay with that since the class is likely the same or even more stringent curriculum than what is taught in the EPA class. So for example, if you have taken the Lead Renovator class with a trainer in Georgia (Special State), you do not need to take the class again in order to work in Florida or South Carolina (EPA states).

14 "Special States"
Below we will break down the 14 "Special States" into 3 categories based on their RRP training reciprocity-friendliness: No-Go's, A Bit Extra, and Good-to-Go.

These states require that you attend training with a training provider that they have specifically approved. There is no reciprocity with non-approved training provider courses from other states. The No-Go states are:
  • Alabama
  • Georgia
  • Oklahoma
The one glimmer of hope here is that some training providers are approved in multiple states. For example, our training partner Seagull Environmental is approved in several special states including Georgia and Alabama, so you can take their RRP class at any of their locations and it will still be accepted by GA and AL. In these states, before registering for your training class we recommend contacting the lead program in the state(s) where you'll be working to confirm if the trainer is on their approved list.

A Bit Extra
These states accept reciprocity for the RRP training course if you attended out-of-state, but have additional requirements to be aware of. They include:
  • Iowa - Iowa recognizes the 8-hour initial training from all EPA and EPA-Authorized state training providers. In order for this cert to be recognized in Iowa, however, the student must have received an 80% or better on the course final exam. Contact the Iowa DPH, Bureau of Lead Poisoning Prevention at 1-800-972-2026 for a reciprocity application.
  • Kansas - Kansas recognizes the 8-hour initial training from EPA Accredited training providers. If taken from a trainer who is not approved in KS, student must pass a free online quiz after class to obtain KS certification. Individual Registration must be submitted within 1 year of taking your training class, and then they will send you info on registering for the quiz.
  • Mississippi - Mississippi recognizes training from EPA and EPA-authorized state accredited training providers but the training must have been completed within the past 3 years. 
  • Utah - Utah recognizes training from EPA and EPA-authorized state accredited trainers, however if the trainer is not accredited with Utah a $30 fee is required to verify the validity of your training certificate. This will be requested when you submit your individual registration with the state.
  • Washington - Washington recognizes the 8-hour initial training from EPA and EPA-authorized state accredited training providers. There is a $25 fee and reciprocity application.
  • Wisconsin - Wisconsin recognizes recognizes the 8-hour initial training from EPA accredited training providers if completed in the past 4 years; a $25 additional fee is required for the reciprocity section located on normal individual app

Lastly, we have the "Special States" that accept any training completed with an EPA or EPA-Authorized state training provider. Just don't forget your applicable Company and Individual paperwork! These friendly states are:
  • Delaware
  • Massachusetts
  • North Carolina
  • Oregon
  • Rhode Island
  • (And any of the 36 EPA-run states)

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