6. Building material reuse stores sometimes accept older materials which have been coated with lead-based paint and could pose a lead poisoning hazard. In particular, older windows and doors are likely to contain lead-based paint, and this paint can present very high risks due to friction and impacts causing the paint to deteriorate and generate lead dust. How can employees of these stores and their customers manage lead hazards associated with these older building materials?
7. When a certified renovator uses an EPA-recognized lead test kit or performs paint chip sampling to determine the presence of lead, can the results be grouped? For instance, may the certified renovator test just one window sill in a room if all will be affected?
11. If a certified renovator using an EPA-recognized lead test kit or paint chip sampling determines that the components that will be affected by a renovation are free of lead-based paint, can a firm that does not have RRP certification do the actual renovation work? What record-keeping requirements would apply?
15. My firm is not RRP-certified and does not employ an RRP-certified renovator. If we are asked to perform a renovation in a pre-1978 home, we first test the home for the presence of lead using an EPArecognized lead test kit. If lead is present, we decline the job. If lead is determined not to be present, we accept and proceed normally. Can we perform these lead tests without being a certified renovator?
16. I am an EPA-certified lead risk assessor. Can I use an EPA-recognized lead test kit (e.g. 3M LeadCheckTM, D-Lead®, etc.) when assessing whether or not a pre-1978 home contains lead-based paint for purposes of the RRP Rule?
General Information about the Lead Renovation, Repair, and Painting (RRP) Rule
15. I am a renovation firm and I have contracted for a renovation in a pre-1978 home to begin on or after April 22, 2010. None of my people have taken the lead-safe certified renovator training yet. I found out the Certified Renovator classes near me are all full until after April 22, 2010. What should I do?
19. Will a renovator working for a firm that has submitted a certification application to EPA but has not received its certification be allowed to work on pre-1978 properties assuming compliance with all other requirement of the RRP Rule?
Renovations Covered by the RRP Rule
1. How is window repair or maintenance, as distinct from removal, treated under the RRP Rule? Would the rule apply to a job that replaced parts or components of a window, such as broken or failed glass, hardware, or balance systems, where some components might be painted, but the frame of the window would remain?
8. My firm repairs windows in which the glass has been cracked or broken by removing and replacing the sash. For casement windows, we unscrew and remove the hinges on the old window, pull out the old sash, and install the new sash. For double-hung windows, we release the jambliner, pull out the sash with the damaged glass, and install the new sash. We may disturb paint on the hinges and screws, but do not otherwise disturb a painted surface. Is this work subject to the RRP Rule?
9. I am removing aluminum siding from a pre-1978 home. The aluminum siding was nailed over the top of painted wood siding that tested positive for lead. The underlying painted surface is greater than twenty square feet. Must I comply with the Rule when removing the aluminum siding?
10. Does the RRP rule apply to simple painting activities that occur when rental properties turn over? Approximately half of the rental units in the country get new tenants each year. This means a large number of properties are being repeated.
Definition of "Renovation"
2. What is a “whole house gut rehabilitation project” for RRP purposes? What RRP requirements, if any, apply during a whole house gut-rehabilitation project? If target housing has, at some point after 1978, been gut-rehabbed, would the RRP Rule apply to subsequent renovations on the property?
5. When a home or an apartment unit is repainted in preparation for a new tenant, is the painting activity always considered a “renovation” for purposes of the pre-renovation education requirements even if no surface preparation activity is performed prior to painting?
7. If I am painting a wall on which there are multiple coats of latex paint over the old lead-based paint and the paint is not peeling down to the lead paint level must I comply with the new regulations?
8. Does the RRP Rule apply to demolishing and disposing of: • An entire pre-1978 home or building? • An entire, non-attached free-standing structure on the same property such as a garage, shed, or gazebo? • An attached but segregated section of pre-1978 home or building such as a sunroom, addition, two-story porch, or garage attached by a breezeway?
10. My firm was hired to scrape and repaint siding on a pre-1978 home. The siding is relatively new and was installed after 1978, but was nailed over top of the old lead-based exterior paint. Does the RRP Rule apply?
15. When installing a roof, my firm does not create dust by directly sanding or cutting painted surfaces, but we do hammer the unpainted side of the lumber from above. Does the RRP Rule apply to this work?
17. My firm installs replacement doors. We simply remove the hinge bolts, take away the old door, unscrew and remove the hinges, and install the new door and hinges. We may disturb paint on the hinges and bolts but do not otherwise disturb a painted surface. Is this work subject to the RRP Rule?
18. My firm has been hired to replace windows in a home built before 1978. The existing windows are milfinish (ie: not painted) aluminum. We plan to use the "insert" method of replacement where we remove the existing sash and attach the new window's frames inside the old frames. Because we will not disturb a painted surface (our work remains inside the mil finished aluminum), is this activity subject to the RRP ruling?
Minor Repair and Maintenance Activities
4. If I am insulating a multi-family building, does the standard for interiors of six square feet or less of disrupted painted surface, or the standard for exteriors of 20 square feet or less of disrupted painted surface apply to the whole building or can it be applied to each separate unit?
5. Does the minor maintenance exception mean that if I drill one-inch holes in a painted surface to blow insulation into an enclosed wall cavity, I could drill 864 holes in the interior or 2880 holes on the exterior before I had to comply with the RRP Rule? Or does it mean that the work is covered by the RRP Rule once I insulate more than 6 square feet of interior wall area (basically one hole) or more than 20 square feet of exterior wall area?
6. If an electrician or plumber, working in a different room from the contained renovation project, needs to drill or cut a hole six square feet or less in size to chase a wire or pipe, does the RRP rule apply to that work?
9. My company installs new or replacement seamless gutters. We install the gutters using self-tapping 3/16” to ¼” screws and the cumulative size of the total number of holes is only a couple of square inches. If the job does not involve sanding, scraping, repainting, repair, replacement or reconditioning of the fascia surface, is it covered by the RRP Rule?
12. As a floor covering installer I use an undercut saw to remove a small amount of wood at the bottom of baseboards and door casings. I am only disturbing the paint in the 1/8 inch cut of the blade. How do I calculate the area of the paint that is affected for purposes of the minor repair and maintenance provision?
13. When replacing an old wood door and frame with a new steel entry door and frame, how do I determine whether the job qualifies as a minor repair and maintenance activity? Do I calculate the amount of painted surface disrupted using the standard for interior renovations (six square feet or less in the room where the door is located) or for exterior renovations (20 square feet or less)?
14. My firm removes and replaces garage doors. The garage doors are typically made up of multiple panels, each of which has an exterior painted surface area of less than 20 square feet. Aggregated, the exterior painted surface area of all the panels exceeds 20 square feet. If we disturb the paint on just one of the door panels, is that activity subject to the RRP Rule?
15. Please provide guidance on how the Agency will interpret the term “minor repair and maintenance activities.” Is the replacement of a window measuring less than six square feet considered minor repair and maintenance? If I use a torch to burn off less than 20 square feet of paint on exterior fixtures, is that considered minor repair and maintenance? What does EPA mean by demolition? How is the size of the disrupted surface calculated? If I sand five square feet of paint on one wall on one day, and five square feet on a different wall in the same room on the next day, are both projects considered minor repair and maintenance?
Renovations for Compensation
2. My non-profit home repair organization performs renovations using mostly volunteers. We do some painting and scraping but we do mostly roof repair and interior work (bathrooms, kitchens, etc.). Obviously, we want to be in compliance with the law and we want our volunteers, staff and homeowners to be safe. Equally, we want to make sure that we are able to continue to offer this valuable service to our community. Is my organization’s work covered by the RRP Rule?
3. How will the RRP Rule affect the work of non-profit or not-for-profit groups? Will the rule apply, for example, to church groups who, as part of their missionary work, are making improvements for low income residents?
5. When repainting rental housing, if the landlord supplies the paint and materials, and the tenant does the labor without receiving money, credit toward rent, or other compensation, does the RRP Rule apply?
6. My local community has formed a “Long Term Recovery Committee” to assist in the rebuilding and recovery efforts following a natural disaster. The committee, which is a coalition of member agencies from the faith community, nonprofit agencies, government programs, businesses and individual donors, gathers monetary and material donations and provides assistance to families with unmet needs via volunteer work crews and/or contracted skilled labor. Are the rebuilding and recovery efforts organized by this committee subject to the RRP Rule?
7. I have a for-profit business where I purchase residential properties and renovate them. I initially try to rent the property, but if I can’t find tenants, then I try to sell the property. I pay for and perform all of the work myself, and keep all profits from the sale or lease. Is this type of renovation work on pre-1978 properties covered by the Renovation Repair and Painting (RRP) Rule?
1. How does a firm or renovator document or confirm the age of the structure? Is a signed statement by the occupant sufficient? Can publicly available information such as tax records, etc. be sufficient?
3. I understand that the RRP Rule does not apply to housing for the elderly. Does this term refer to specific built houses in 55+ communities or does it refer to all residential homes with this demographic living there?
5. I am a contractor a couple years from retirement and I am closing down my business. I do not plan to become certified under the RRP Rule. My understanding is that I can continue working on homes built after 1978?
6. Older hotels built before 1978 are knocking down walls, combining two hotel rooms, and making their units two-room or even three-room suites. My understanding has been that single hotel rooms are considered zero-bedroom dwellings. Does the RRP Rule apply when one-room units are converted to two-room suites?
13. My firm plans on doing renovation work on a storage building which is detached from, but a part of, an apartment complex. The apartment complex was constructed prior to 1978 and would be considered target housing. The storage building, however, was constructed after 1978. Will our work on the storage building be covered under the RRP Rule?
15. Does zoning affect the target housing determination? For example, would a pre-1978 house that is zoned for commercial or office use, but used for residential purposes be considered target housing?
16. How would RRP classify a pre-1978 property that is used for both residential and non-residential purposes? For example, would RRP apply to renovations in a pre-1978 house that is partially used as a residence and partially used as a legitimate commercial business?
5. A child’s consecutive visits to a particular building (such as a hospital) can technically qualify that building as a child-occupied facility, even if the visits were an isolated or rare event. How long does such a building remain a child-occupied facility?
Testing Painted Components
1. Is a lead-based paint inspection, performed by a certified inspector or risk assessor, that includes a written determination that various building components are free of paint or other surface coatings containing lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm2) or 0.5% by weight sufficient to determine compliance with requirements of the RRP rule?
2. I am an owner/agent for an apartment community built prior to 1978. In 2004, testing of a random sample of units was completed by a certified testing firm. The results were negative for lead paint but positive for lead dust. With the positive lead dust result, are we required to comply with the RRP Rule?
5. If a property is tested by a certified renovator, inspector, or risk assessor and found to be free of leadbased paint, does any testing need to be done again if work is done on the property several years later?
6. I’m a certified renovator using an EPA-recognized lead test kit to determine whether or not I have to follow the Renovation Repair and Painting (RRP) Rule work practices. What components must test negative for lead-based paint in order to qualify for the exclusion in 40 CFR 745.82(a)(2)?
1. A home sustained flooding as a result of a hurricane. Once the flood water recedes, my firm must make the necessary renovations including tearing out wet drywall before mold begins to grow. How do the record keeping requirements apply to an emergency renovation? How should my firm fill out the record keeping checklist if not all of the requirements are followed?
5. My company only does emergency renovation work. According to your guidelines emergency projects are exempt from the warning sign, containment, waste handling, training, and certification requirements to the extent necessary to respond to the emergency. Emergency renovations are NOT exempt from the cleaning and cleaning verification requirements. Does this mean that my firm does not need to be certified and my company doesn't need a certified renovator? Does this also mean that my employees would only have to be trained on cleaning and cleaning verification guidelines?
3. My firm performs renovations in large apartment complexes that often consist of several separate buildings. If a renovation is to be performed in a common area in one building, are we required to provide pre-renovation education to all tenants in all buildings?
4. When multiple contractors are involved in a single renovation, must every contractor provide prerenovation education? Can a certified firm assign its responsibility to a property management company?
7. EPA’s pamphlet titled Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools is currently not published in a Braille format. If working in target housing occupied by persons who are blind, how should a firm comply with the pre-renovation information distribution requirements?
8. My firm is going to perform renovations in a school during the students’ summer break. During the regular school year, the work area would fall under the definition of a child-occupied facility. However, no children under age six will be present during this multiple month break period. Do we still have to comply with the pre-renovation education requirements? If so, how should the information be distributed?
9. If a project disturbs six square feet or less of interior surface or twenty square feet or less of exterior surface, is it necessary for a firm to comply with the pre-renovation education requirements, such as distributing the pamphlet?
10. I regularly perform renovations and repairs to common areas in a large apartment complex. Must I provide separate notice to the tenants for each one of these activities or is there any way to avoid such duplication?
12. The RRP Rule requires delivery of the “Renovate Right” pamphlet to the owner and occupants of target housing. My firm was hired to perform a renovation in a pre-1978 apartment building. Is delivery of the pamphlet to the property manager sufficient for purposes of delivery to the owner of the building?
18. In a typical co-operative apartment building, occupants do not own the individual units; rather they “own” an undifferentiated share in the entire building and then “rent” back a specific unit from the co-operative corporation. Similarly, in a typical condominium building, owners of individual units jointly own the common areas of the building. For purposes of the pre-renovation education requirements, who are the “owners” in such situations?
19. I am planning on sending the pamphlet via the United States Postal Service’s certificate of mailing delivery method to a tenant who occupies a unit scheduled to be renovated. Does the tenant’s name need to be addressed on the mailing, or is it acceptable to address the envelope to Attn: Tenant/Occupant?
20. Under the Pre-Renovation Education Rule, I have the option of using a certificate of mailing to notify the owner or occupant. What is the difference between a certificate of mailing and certified mail?
21. If a renovation is to be performed on a common area in a pre-1978 building that contains a mix of studio apartments (0-bedroom dwellings) and apartments with one or more bedrooms, what pre-renovation education requirements would apply?
23. When a unit is not occupied by its owner, 40 CFR 745.84(a)(2) states that the “Renovate Right” pamphlet must be provided to an adult occupant prior to beginning any covered renovation activities. What does EPA consider an “adult” for these purposes?
Work Practice Standards
1. When renovating the exterior of a high-rise building, does the requirement to close and seal doors and windows within 20 feet of the renovation include closing those openings two-plus floors above the floor where work is to be performed?
Containing the Work Area
11. Plastic can be a slip hazard in some jobs, such as handling granite counter tops. This creates a more immediate safety concern than protecting the floor from dust. Can’t I just clean the floor at the end of the job?
14. In Chapter Four of the EPA Certified Renovator Initial course, there is a PowerPoint slide showing plastic sheeting being taped to the floor at several corners, but not around the entire perimeter of the plastic. Must the plastic be "sealed" to the floor on all four edges by tape or just "secured or held" to the floor by tape at several locations?
16. My firm is replacing windows on the second floor of a 90-year-old home. The windows are built into a bay that projects out from a steeply pitched slate roof. When setting up exterior containment for this job, does the RRP Rule require me to install plastic on the roof under the windows?
17. When replacing an unpainted roof, sometimes sections of paint-covered lumber under the roof need to be removed as well. If my firm removed damaged lumber from only certain sections of the roof, does only this area need to be contained while we fix the lumber?
19. When I replace windows, I set up interior vertical containment barriers that extend from floor to ceiling and completely enclose the interior area in which I physically work. If these barriers are set up at a distance less than six feet from the perimeter of the work surface, must I still extend the containment on the floor beyond the vertical barrier to meet the six-foot requirement?
21. My firm removes and replaces windows from the exterior of a building or residence. To contain dust in the work area, we cover the entire interior surface of the window with impermeable plastic sheeting and affix the sheeting to the surrounding interior wall. This creates a pocket, accessible only from the exterior, from which the window is removed and replaced. All removal and replacement work is performed from the exterior, and we still apply the exterior containment measures as provided in the Rule. Does the interior containment method described meet the requirements under the Rule?
23. My firm replaces windows. Various obstacles make it difficult to set up the ten-foot exterior ground containment in a way that would enable our renovators to perform the work and still effectively contain dust. In these cases, we lay the ground containment, but also use vertical containment measures to completely enclose the area in which we work. Is this a permissible method of exterior containment? If the vertical containment is set up at a distance of less than ten feet from the work surface, must we still extend the ground containment beyond the vertical barrier to meet the ten-foot requirement?
24. Under the Renovation, Repair, and Painting (RRP) Rule, in exterior containment if a large tree or shrub is within the work area can the plastic be placed around the base and would the plant, however large, also need to be covered?
Prohibited and Restricted Practices
Waste from Renovations
Cleaning the Work Area
2. Under the RRP Rule, do paint chips and debris need to be removed from protective sheeting prior to misting, removing, folding and sealing the sheeting even if such chips and debris can be effectively contained by the sheeting or the sealed container the sheeting is contained in for disposal?
3. If a renovator uses the required practices to remove containment and clean a work area, then performs successful cleaning verification, can the balance of the project then be done using uncertified workers and without reference to the work practices required by the RRP Rule?
8. My firm has signed a contract to replace the windows on a pre-1978 home. We have tested for the presence of lead based paint and found the results to be positive. However, the homeowner has already scraped and repainted their house but did not follow lead safe work practices. The result of their activity is paint chips scattered throughout the landscaping. How best should I proceed?
1. Typically, interior clearance is achieved by means of dust wipe sampling by a certified inspector or risk assessor using single surface dust wipes. This is required on all HUD jobs. EPA rules at 40 CFR 745.227(e)(8)(ii) allow for composite sampling in clearance testing. Under the RRP Rule, is composite sampling acceptable for clearance in lieu of cleaning verification?
Recordkeeping and Reporting Requirements
1. If a certified renovator is an employee of the certified firm, can the firm maintain all required records (those required of the firm and of the certified renovator); understanding that the certified renovator must also keep a copy of his certification as well as employee training records/documentation on the jobsite?
4. If a general contractor and one or more subcontractors are involved in a single renovation project, which persons or entities are responsible for preparing, retaining and making available the necessary records?
6. Under the RRP Rule, can the certified renovator comply with the rules by keeping records regarding his certification and employee training electronically, provided he can display them on a hand held device or laptop on the job site?
2. My firm acts as a general contractor – we subcontract the entire renovation job to other companies rather than using our own employees. Does my firm need to have a certified renovator at the job site?
4. A property management company performs most of the clerical functions of the business, and hires plumbers, electricians, carpenters, etc., for its renovation needs. Does the property management company need firm certification?
5. How will the RRP Rule affect the work of non-profit or not-for-profit groups? Will the rule apply, for example, to church groups who, as part of their missionary work, are making improvements for lowincome residents?
6. DOE provides weatherization grants to states, which in turn provide grants to non-profit sub-grantees. These sub-grantees fall into one of three categories: 1. The sub-grantee uses its own employees to perform all the weatherization services in the home, 2. The sub-grantee uses a combination of its own employees and contractors to perform weatherization services, or 3. The sub-grantee has no employees that perform weatherization services; instead, every service is performed by a hired contractor. Must these sub-grantees be RRP-certified firms?
14. If a property owner and a property management company have entered in to a consent agreement related to Section 1018 (lead hazard disclosure) that does not admit an actual violation, is the property management company required to acknowledge a lead-based paint violation when completing the application for firm certification?
15. If the demolition, cleanup, and cleaning verification portion of a renovation project is performed under the direction of a certified renovator using trained workers, can uncertified workers complete the job if further disturbances of painted surfaces will not occur? For example, a certified firm establishes containment and removes wall and ceiling board to the rough framing members. Cleaning and verification take place and containment is removed and properly disposed of. At that point, can non-certified firms perform electrical, plumbing, HVAC, or drywall work?
18. Can contractors submit their application to EPA before they complete the required training, or must the application be submitted after the training is complete? Is there a proof of training required by the EPA in order for the contractor's application to be approved?
19. Must maintenance workers at kindergartens and elementary schools become certified renovators if they perform renovations covered by the RRP Rule in the portions of the school that are child-occupied facilities? Are the schools or school systems then required to become certified renovation firms?
20. If a firm does business in several states, must they become certified in all states in which they manage a target property or is this requirement satisfied by certifying the firm in the state in which they are headquartered?
21. My non-profit organization receives grants to arrange for renovations in older housing, such as weatherization projects or general modernization. Typically, these grants come with eligibility conditions for properties and/or property owners and tenants, but specific properties or projects are not identified. My organization is responsible for locating eligible properties and recipients and hiring firms to perform the eligible renovations. Must my non-profit organization become an RRP-certified firm?
22. My non-profit organization applies for and receives grants to renovate older homes. We do not perform the renovations ourselves, we hire renovation contractors to perform them on our behalf. We identify the properties to be renovated and the specific projects in the grant application. If we are successful in obtaining the grant, the funding would obligate us to arrange for the renovation of the specific properties named in the grant application. Must my non-profit organization become an RRP-certified firm?
23. I am a facilities manager for a church with daycare and preschool programs. I recently became a certified renovator. If my staff and I do our own painting and remodeling work, do we need to be a certified firm?
28. My firm performs renovations covered by the RRP rule, but solely in the capacity of a subcontractor. If the general contractor is a certified firm, does my firm also have to be certified, or can we just provide the certified renovator?
Lead-Safe Certified Firm Logo
Renovator Certification and Training
5. The certified renovator is required to have proof of their certification at the work site. If the certified renovator provides on-the-job training to workers, does there need to be documentation of that training at the work site too?
6. Is the certified renovator assigned to a specific project responsible for the work practices of other contractors on the project if the certified renovator is an employee of the general contractor of the project?
7. What about a situation where the homeowner is acting as their own general contractor and hires multiple companies to do different portions of the work? In this situation, would each business participating be required to follow the rules and assign a separate certified renovator to supervise their portion of the work including separate containment?
9. Must maintenance workers at kindergartens and elementary schools become certified renovators if they perform renovations covered by the RRP Rule in the portions of the school that are child-occupied facilities? Are the schools or school systems then required to become certified renovation firms?
10. If a remodeling company that is a certified firm uses all contractual workers rather than employees, must each contractual worker be a certified renovator, or can the workers be trained on the job by a certified renovator employed by the firm?
13. May I as a training provider issue a certificate without a picture to a trainee who has successfully completed the course but objects to having his or her picture taken (or objects to possessing a photograph of him/herself) on religious grounds?
Authorized State and Tribal Programs
Training Provider Accreditation
1. Do all renovation course instructors need to be approved as principal instructors? For example, to reach a 6:1 student-to-instructor ratio with 18 people in the class, may we have one principal instructor who teaches the entire lecture and is assisted by two additional hands-on instructors (who are not approved as principal instructors)?
7. I’m a training provider and have been accredited for the renovator refresher course. If a renovator takes the refresher course early (i.e., before their previous certification has expired), would the new certification be valid for five years from the date of training, or five years from the date that the previous certification expires?
Enforcement and Inspections
2. If a property management company hires a certified firm to perform a renovation and the firm violates the RRP Rule, for example, by failing to distribute the necessary materials or keep proper records, which entity is subject to enforcement action, the property manager or the certified firm?
3. Does EPA’s announcement of June 18, 2010 modify the Lead Renovation Repair and Painting Rule’s requirements that contractors use lead-safe work practices when working in pre-1978 housing or child occupied facilities?
Information for Do-It-Yourselfers
20. If a person is the principal instructor or guest instructor for an initial or refresher course for one of the disciplines, can that person rely on his or her instruction of the course to fulfill the training requirement for certification in that discipline
23. The definition of “wipe sample” relies on two very specific American Society of Testing Materials (ASTM) standards. In referencing the ASTM standards, did EPA intend to prevent the use of EPA and HUD standards for wipe samples?
24. The definition of “soil sample” at 40 CFR §745.63 relies on certain American Society of Testing Materials (ASTM) standards. Did EPA intend to prevent the use of EPA and HUD standards for soil samples?
26. Do EPA’s current rules require inspectors, risk assessors, dust sampling technicians, or any individual who performs lead-based paint and/or lead dust sampling to document any visible lead-based paint deterioration on components and estimate the surface area of deteriorating paint during a lead evaluation?
30. Immediately following the completion of renovation activities, a company conducts a clearance examination which reveals dust levels above the clearance standard. Is removal of dust to address the failure of this clearance examination considered abatement?
33. If a homeowner wishes to perform lead abatement on his own home, but the home is visited on occasion by a child with elevated blood lead levels, is that homeowner subject to regulatory requirements (training, certification, work practice standards, etc.)
37. When individuals apply for certification in the Federal program under the provisions of 745.226(a)(1)(ii) by submitting a valid certification from an authorized State or Tribe, how long will the certification last?
38. If a person purchases a house and plans to conduct a lead abatement before moving his or her family into the house, is that person subject to regulatory requirements (training, certification, work practice standards, etc.) at 40 C.F.R. 745 Subpart L?
39. For initial certification, the Federal program allows individuals to obtain their training through either the Federal program or a Federally authorized State or Tribal Program. When applying for recertification in the Federal program, what types of accreditation are acceptable for refresher courses?
42. Must employees of Federal agencies who conduct lead-based paint activities be certified as individuals? Must their agencies be certified as firms? Must Federal agencies pay certification fees for individuals and firms?
46. Must self-employed or one-person businesses that perform lead-based paint activities, such as leadbased paint inspections, risk assessments, or abatements, be certified as firms in addition to being certified as individuals?