Lead-Safe RRP Rule: EPA Enforcement Update Spring 2013

Recently, our office participated in an EPA regional conference call regarding RRP enforcement and compliance, and we would like to share what we learned with you.

In EPA Region 10, which encompasses Washington, Oregon, Alaska, Idaho and 271 Native Tribes, there have now been 17 lead-based paint disclosure violations regarding leases and rental property, with three being settled. Many landlords are unaware that they need to provide new tenants the EPA lead disclosure pamphlet and this is one of the most common violations nationwide.

Another area they covered was a situation that we receive a number of calls and questions about: the General Contractor/Subcontractor relationship. They clarified that if a General Contractor is subbing out work to Sub Contractors, both the General Contractor and Sub Contractors need to have their Lead Safe Firm Certification with the EPA or EPA-Authorized State (depending on where the work is being done). In one EPA Region 10 case, a subcontractor was not certified but the GC was, and after the initial investigation, they fined both the general contractor & sub for being non-compliant. Even if the subcontractor is Firm Certified, but fails to use a Certified Renovator on the job or their workers don't follow RRP practices, the GC could still be liable for fines. Ultimately, the GC is responsible for hiring certified subs AND making sure they are using RRP workers on the job site.

We also learned that there has been a recent push within EPA Region 10 to refer lead violation cases to the EPA Criminal Investigation Division (CID) if an EPA inspector receives a complaint that they feel is worthy of passing on to CID. This allows the EPA to take enforcement actions beyond civil fines, and could mean jail time for those found to be in violation.

Lastly, don't be surprised if you receive a call from your regional EPA office. In a new effort to get the word out about the RRP Rule and lead-safe practices, EPA representatives have been hitting the phones and contacting relevant businesses in their region to make sure they are aware of the rule's requirements, and are taking proper action. Some of these calls have turned into actual data requests for previous projects, so always make sure you are keeping up with your record-keeping for RRP jobs.

Become a Lead Safe Certified Firm - Options for Applying With the EPA

For renovators, painters, contractors, and other professionals who need to comply with the Lead Safe Renovation, Repair, and Painting (RRP) Rule, attending the required 8-hour training course is only the first step. If you run your own company, even if you're just a sole-proprietor, you must also register your company with the Environmental Protection Agency (EPA), or an EPA-Authorized State, and receive a Lead-Safe Firm Certificate. The fee for the EPA Firm Certification is $300 for lead-safe renovation, repair, and painting activities, and it is valid for five years.

You have two options to register to become a Lead Safe Certified Firm:

1. Apply online through EPA's website at http://www2.epa.gov/lead/epa-lead-safe-certification-program and pay via credit card. For further instructions on completing the online application, check out our blog post here.

2. Download and mail in a hard-copy of the application to the EPA with a check. You can get the application and instructions at www.EPAFirmApplication.com.

If you perform work in an EPA-Authorized State, be sure to read our previous post on the local state requirements that you must comply with in lieu of the federal Lead RRP program.

Kansas Safety Training Center Joins GreenEDU Training Network

Haysville, KS -- This month Kansas Safety Training Center, Inc. joined Green Education Services' network of environmental and construction safety training providers. The partnership will help to increase access to OHSA safety and lead paint training in Kansas. Kansas Safety Training Center was established in 2010 to bring founder Rex Smith's industry expertise into the classroom.

Current courses available include the Lead Renovator Certification (RRP), Lead Worker, Lead Worker Refresher, Lead Supervisor, and Lead Supervisor Refresher located in Haysville, Kansas.

More About Kansas Safety Training Center
Kansas Safety Training - operating under the expertise of Rex Smith - offers Asbestos, Lead, and OSHA training courses. Rex has many years of hands-on experience working on buildings that contain hazardous materials and implementing OSHA-regulated work safety practices. By having this first-hand experience, Rex is fully aware how important Asbestos, Lead, and OSHA training is in order for his clients to succeed in protecting themselves, their families, and their customers. It is this in-the-field experience - along with his marketing and management skills - that has given Rex the ability to deliver exceptional environmental safety training.

EPA-Authorized States for the Lead Renovation, Repair, & Painting (RRP) Program

In an effort to enforce more stringent lead-safe programs, the Environmental Protection Agency (EPA) has authorized 12 individual states so far to control the RRP Lead-Safe Renovation Program in lieu of the federal program.  If you are doing renovation, repair, or painting work on pre-1978 homes in any of the states listed below, you must be in compliance with the state-specific requirements. We've compiled the most up-to-date information available on each EPA-Authorized State below:

• Alabama: Individuals performing RRP work in Alabama must register with the University of Alabama's Division of Environmental and Industrial Programs Alabama Individual App. The annual fee is $100. In addition, Renovators must work under an Alabama-certified contractor Alabama Contractor App. This annual fee is $300, paid to the Alabama Department of Public Health. View Alabama Lead Certification Classes.

• Georgia: Individuals performing RRP work in Georgia must register with the Georgia EPD (GA Renovator Application). The fee is $150, and it is valid for 3 years. In addition, Renovators must work under a Georgia-certified firm (GA Firm Application). The fee for firms is $125 for 1 year, or $300 for 3 years. View Georgia Lead Certification Classes.

• Iowa: Individuals performing RRP work in Iowa must register with the Iowa Department of Public Health. This fee is $60 every year. Renovators must also work under an Iowa-certified firm. There is no fee for the firm certificate at this time. View Iowa Lead Certification Classes.

• Kansas: Individuals performing RRP work in Kansas must register with the Kansas Department of Health and Environment Kansas Individual App. There is no fee at this time. In addition, Renovators must work under a Kansas-certified renovation firm Kansas Firm App. This fee is $200 for the initial firm certificate, with a renewal cost of $100 every five years. View Kansas Lead Certification Classes.

• Massachusetts: Individuals and firms performing RRP work in Massachusetts must register with the Massachusetts DLS (MA Renovator Application). The fee is $375, and it is valid for 5 years. View Massachusetts Lead Certification Classes.

• Mississippi: Firms must be certified to perform RRP work in Mississippi. The annual fee is $350 paid to the Mississippi Department of Environmental Quality Mississippi Firm App. Individuals performing RRP work in Mississippi must also register with the Mississippi Department of Environmental Quality Mississippi Individual App. The annual fee is $75, unless you are the 1st or 2nd Certified Renovator associated with the Certified Firm you are working for. If you are the 1st or 2nd Renovator, you are exempt from this fee. 

• North Carolina: Individuals must register with the NC Dept. of Health and Human Services (NC Individual Application). Contractors must also register to become a Certified Renovation Firm (NC Firm Application), and there is a yearly $300 fee. View North Carolina Lead Certification Classes.

• Oklahoma: Contractors must register to become a Certified Renovation Firm. The registration fee is $300 per company. View Oklahoma Lead Certification Classes.

• Oregon: Firms must be certified to perform RRP work in Oregon. The fee is $250 paid to the Oregon Health Authority Oregon Firm App and it is valid for five years. If you are a contractor registered with Oregon CCB (Construction Contractors Board) and you already have a contractor's license, the fee to become a certified firm is $50 Oregon CCB Firm App. View Oregon Lead Certification Classes.

• Rhode Island: Individuals performing RRP work in Rhode Island must register with the Rhode Island Department of Health Rhode Island Individual App. The fee is $40 and is valid for five years. Renovators must work under a Rhode Island-certified Lead Hazard Control Firm Rhode Island Firm App. This fee is also $40 and is valid for five years.

• Utah: Individuals performing RRP work in Utah must register with the Utah Department of Environmental Quality Utah Individual App. The annual fee is $200. In addition, Renovators must work under a Utah-certified firm Utah Firm App, with the annual fee being $250. You must also be a citizen of the U.S. to apply as an individual lead renovator in Utah Utah Citizenship App. View Utah Lead Certification Classes.

• Washington: Renovation firms must register with the Washington Dept. of Commerce and pay a $25 fee, which is valid for 5 years (WA Firm Application). Individuals who would like to perform RRP activities in Washington state but were certified by the EPA or other authorized state can do so by registering and paying a $25 fee, which is valid for 5 years (WA Individual Reciprocity Application). View Washington Lead Certification Classes.

• Wisconsin: Renovation firms must register with the Wisconsin Dept. of Health Services and pay a $75 fee, which is valid for 2 years (WI Firm Application). Individuals who would like to perform RRP activities in Wisconsin but were certified by the EPA or other authorized state can do so by registering and paying DHS a $50 fee every two years, (WI Individual Application). View Wisconsin Lead Certification Classes.

RRP Refresher Requirements for EPA Lead Certified Renovators

April 20th, 2013 - New York, NY

EPA Certified Renovators,

For those of you not following the calendar too closely, April 20, 2013 marks the three-year anniversary of the Environmental Protection Agency's implementation of the Renovation, Repair and Painting (RRP) Program Final Rule. Three years of RRP! So to the federal government, all of the RRP training providers, and the various contractors, renovators and painters who have taken the RRP class and are committed to lead-safe renovation practices, we at Green Education Services want to say thank you for doing your part!

As an industry, we have certainly learned a lot about this rule in the last three years. We have learned that rules and regulations can be subject to change, like in October 2011 with vertical containment requirements being written into the Rule and the Opt-Out Provision being written out; we have learned that implementing a federal regulation and keeping it consistent across the country is in itself, a very difficult endeavor; and despite all this, we have learned that the RRP Rule is here to stay, as lead poisoning is still a problem that is far from being resolved, and at the heart of this Rule is the health and safety of our children.

Environmental rules and regulations should not be viewed as a burden or as a necessary part of doing business. Not to be overly dramatic about it, but I always remind my RRP students that compliance with the RRP Rule is not meant to cause them grief, or make their businesses lose money, or in general, make their lives more difficult. Truly at the core of all of these environmental rules and regulations is the health and safety of everyone involved in the project, from the contractor and his workers to the customers and their kids. If we focus on the good that is being accomplished by following the RRP Rule, it is easier to deal with some of the difficulties staying compliant with new regulations.

Part of staying compliant with the RRP Rule is attending an RRP Refresher Course and re-registering your company with the EPA or EPA-Authorized State before your certification expires. The RRP Refresher Course will provide EPA Certified Renovators with a review of the RRP Rule requirements, covering topics such as containment, prohibited work practices, and personal protective equipment. Two important hands-on activities, testing for lead-based paint and the cleaning verification procedure, will also be reviewed.

The initial RRP certificate is valid for five years with the EPA, and the date that you attend a refresher training course will be your new renewal date going forward.

Also, keep in mind that some EPA Authorized States running their own RRP Program, such as Georgia and Wisconsin, only validate RRP certificates for three and four years, respectively, so refresher courses will be needed a little earlier in those areas. You can verify your expiration dates by checking right on your actual certificate you received in class and on the EPA or Authorized State firm certificate.

For more information or to sign up for an RRP Refresher Course, you can call our office at 1-800-355-1751, or register online at www.greenedu.com. As always, Green Education Services is here to meet your environmental safety training needs!

GreenEDU Announces Partnership with Astar Abatement for Asbestos Training in West Virginia

Charleston, WV -- A new partnership was recently announced between Green Education Services and Astar Abatement, Inc. with the goal of increasing access to lead paint safety and asbestos training in West Virginia.

Astar Abatement, based in Charleston, WV has been practicing in the field and providing training for almost two decades in the environmental safety and remediation industry. The company specializes in asbestos abatement training with emphasis on real-world applicability for its students so that they are prepared on the job site to perform the asbestos abatement work safely and efficiently. Astar provides asbestos refresher courses as well, which are required to renew an asbestos license, including Asbestos Worker Refresher, Asbestos Supervisor Refresher, and Asbestos Inspector Refresher training.

Astar also holds lead-safe renovator training in Charleston, which is required by the Environmental Protection Agency (EPA) for any contractor disturbing paint in pre-1978 houses. These courses comply with the Renovation, Repair, and Painting (RRP) Rule enacted by the EPA in April 2010.

More About Astar Abatement Inc.
Backed by almost two decades of experience and an excellent safety record, you can be sure that Astar Abatement, Inc will provide the dependable environmental remediation services that you need at an affordable rate. To ensure that we maintain our reputation for excellence, our experienced and knowledgeable team stays up to date on regulatory requirements, as well as changes and updates. Our mission is strongly focused on providing you with dependable and reliable services that meet or exceed your needs and regulatory requirements.

Lead Paint Safety Training In Michigan Highlighted With New Partnership

Atlanta, MI -- Green Education Services is excited to announce a new addition to its network of lead safety trainers through its recent partnership with QUAT, Inc.

QUAT, Inc. specializes in Lead Abatement and RRP Lead Renovator training for the initial and refresher certifications for contractors throughout Michigan. Based in Atlanta, MI the company has been training construction and remediation professionals for over two decades, bringing heightened awareness to its community on the dangerous effects of lead paint poisoning, specifically when dust is created by renovations and lead abatement work.

Courses provided by QUAT, Inc. in Michigan currently include the Lead Safe Renovator Certification, Lead Renovator Refresher, Lead Abatement Worker, Lead Abatement Supervisor, and Lead Supervisor Refresher Training.

About QUAT, Inc.
At QUAT, Inc, teaching the safe and legal methods of lead abatement and its effects on children and families has been our mission since 1993. We pride ourselves on delivering a quality training experience for contractors, their employees, and other business owners throughout the state of Michigan. Our mission continues to be focused on training individuals in the safe practices of handling this hazardous material and on ensuring the proper certifications for all work activities.

EPA Compliance Series Part 2: Paperwork for RRP Job Site

This is the second installment of our RRP Compliance Series, as we take an in-depth look at the most important parts of performing of a lead-safe renovation job in compliance with the Environmental Protection Agency's (EPA) Renovation Repair & Painting (RRP) Rule.

Recently, I attended a Healthy Housing Conference in Philadelphia and had the chance to hear the EPA discuss enforcement of the RRP Rule firsthand. They admitted it is difficult to catch a Renovation Firm in the act of being non-compliant, considering most renovations, repairs, and painting projects do not last longer than a couple days, if that. What is not difficult for the EPA, however, is auditing renovation firms for their paperwork. Keep in mind, every time you complete a renovation project under the RRP Rule, you must keep the required records for 3 years.

As we cover in our lead-safe renovator training courses, here are the six documents needed for every RRP project:

1. Your Certificates: Individual and Firm: If you haven't filed your company (firm) with the EPA, but yet you are still working in pre-1978 residential homes, you are breaking the RRP Rule and are considered to be non-compliant, which carries a maximum fine of $37,500 per violation, per day! You can process your firm application online OR send in a hard copy application, which you can access here: EPA Firm Application. Your choice! Keep in mind, the EPA asks that you give them 90 days to process your firm application, but it has been taking much less time recently, according to our past students.

2. Renovate Right Pamphlet: Handing out the EPA's pre-renovation education pamphlet is one of your main responsibilities as an EPA Lead Renovator. The purpose of this pamphlet is educating your client about the potential risks that arise when a disturbance of lead-paint is created through renovations, repairs, or prep-work for painting. You can find this pamphlet many places, like Green Education Services' on-line store,  in your RRP manual in Appendix # 3, or from the EPA's website.

3. Proof of Renovate Right Pamphlet Receipt: Now that you handed out the Renovate Right pamphlet prior to beginning your RRP Project, maintain this proof with either your customer's signature or by sending the pamphlet by certified mail. Also, if you purchase the pamphlets from our store, we include carbon copy disclosure forms that the tenant can sign. You can review the ins-and-outs of this process in Module # 3 of your manual, but in regards to when the Renovate Right pamphlet should be handed out, there are three time-frames that you must know:

• Do not hand out the pamphlet more than 60 days before beginning the renovation 
• You may distribute the pamphlet by certified mail, as long as you do not mail it less than 7 days before beginning the renovation 
• You must distribute the Renovate Right pamphlet at least 24 hours before the job begins, and if you miss the 7 day window with certified mail, you must obtain the owner’s written acknowledgement when you physically hand it to them 

EPA's Sample Pre-Renovation Form Confirmation of Receipt of Pamphlet.

4. Test Kit Results: If you are working in a pre-1978 residential home, the EPA wants you to show proof that you ran a test for lead-based paint prior to beginning your work. Your other option is to presume that lead-based paint is present and to use Lead Safe Work Practices based on the age of the home. You can find the Test Kit Results forms in Appendix # 6 of your RRP manual.

5. Training Non-Certified Workers: There needs to be at least one EPA Certified Renovator on each RRP Project, and that person can provide on-the-job training to the other workers. The Steps Guide, which you will use to train these workers, can be found in Appendix # 5 of your manual. The Non-Certified Worker training documents you will fill out after this training can be found in Appendix # 6. You can also review all of the RRP Hands-On Activities so you are up to speed with lead-safe work practices, which is essential to being compliant with the RRP Rule.

6. Post-Renovation Report (Record-Keeping Checklist): When your RRP Project is completed, you need to fill out this Post-Renovation Report which sums up exactly what you did during your renovation work. This form can be found in Module # 6 of your RRP manual, or on the EPA website here. Please note, the last thing that you will check off before you sign this post-renovation document is this: I certify under penalty of law that the above information is true and complete, so make sure your RRP documentation is!

If you have any further questions about the required documentation for RRP Projects, you can call our office at 1-800-355-1751, and we will be glad to assist you!

Author: Gregory Jaskowiak, Certified Lead Renovator, is the Programs Manager and In-House Instructor at Green Education Services, specializing in lead paint safety training.

New Partnership Highlights Lead and Asbestos Training in Nevada and SoCal

Las Vegas, NV -- Green Education Services is excited to announce a new partnership with Enviro-Con Integrated Solutions, an environmental consulting and training company based in California and Nevada. The partnership will focus on bringing greater access to asbestos training and lead certification training to Las Vegas, NV and Southern California for contractors and environmental remediation workers.

Enviro-Con Integrated Solutions brings 28 years of experience in the environmental training industry, established in 1985. Its quality training programs were developed by working professionals with extensive real-world experience, allowing them to provide valuable insight while delivering the curriculum.

“We are excited to join forces with Enviro-Con, a staple in the Nevada and California training market for almost 30 years,” stated Green Education Services’ CEO Zachary Rose. “GreenEDU hopes to assist Enviro-Con with continued success and growth, connecting local construction and remediation industry professionals with the asbestos, OSHA, lead, and any other environmental training they may need.”

Enviro-Con’s upcoming schedule includes EPA Lead Renovator (RRP) Certification in Las Vega, NV and La Mirada, CA, as well as Asbestos Worker Refresher Training in Las Vegas, NV and La Mirada, CA.

About Enviro-Con Integrated Solutions, Ltd.
With offices in Southern California and Nevada, Enviro-Con Integrated Solutions, Ltd is a full environmental consulting and training company. Its professional staff has acquired significant hands-on experience on many types of environmental projects including asbestos, lead-based paint and microbial contamination issues, indoor air quality (IAQ), Phase I and Phase ll environmental assessments, and management of hazardous materials. Our professional qualifications come from the combined experience, capabilities, and knowledge of each professional in the firm. Our staff includes certified asbestos consultants, project managers, project designers, lead risk assessors, construction managers and other health safety professionals. Enviro-Con Integrated Solutions is EPA, Cal/OSHA and California Department of Public Health (CDPH) accredited for asbestos, lead-based paint, and OSHA training.

EPA Compliance Series Part 1: Necessary Equipment for a Lead Safe RRP Job

As you may already know, complying with the EPA's Lead Safe Renovation, Repair, and Painting (RRP) Rule goes beyond just attending the Renovator Training and certifying your company. How you actually perform the work is the most important part of compliance. In this blog series, we'll look at what implementation of RRP lead-safe practices looks like on a job site, beginning with the equipment necessary to properly perform the work. 

Without the right equipment, it is nearly impossible to comply with the regulations and standards established by the EPA's RRP Rule. In this breakdown, we will go step-by-step through a typical RRP project, and list for you the necessary materials and equipment needed to stay compliant with this rule. We will follow the Steps to Lead Safe Renovation, Repair and Painting guide found in Appendix 5 of your RRP training manual.

STEP 1 - Determine If the Job Involves Lead-Based Paint:
If a home or child-occupied facility was built before 1978, all surfaces affected by a renovation covered by the Renovation, Repair and Painting Rule must either be tested for lead-based paint or presumed to contain lead-based paint. Testing must include all affected surfaces coated with paint, shellac, varnish, stain, coating or even paint covered by wallpaper, if it will be disturbed during the renovation work. A report documenting the testing must describe the test used, the surfaces tested, and the results of the testing. Materials needed for this first step include:

• EPA-recognized test kits, such as LeadCheck swabs
• Utility knife
• Nitrile gloves
• Plastic bag for all waste created during the testing process
• Wet rag for clean-up

STEP 2 - Set Up the Job Safely:
When you work on a job with lead-based paint, you must contain the work area to prevent the escape of dust and debris. The goal of proper setup of the work area is to keep dust in the work area and non-workers out. Materials and equipment needed for this step of an RRP Project include:

• Warning signs
• Barrier tape, rope or fencing
• Cones
• Heavy duty plastic sheeting
• Masking, duct, or painter's tape
• Stapler
• Utility knife or scissors
• Rigid framing material if using vertical containment

STEP 3 - Protect Yourself and Your Workers:
Without the right personal protective equipment, workers may ingest or inhale lead from the job and may risk bringing lead from the worksite home to their families. The right personal protective equipment and good personal hygiene will help combat lead exposure. Personal protective equipment includes:

• Disposable coveralls
• Painter's hat
• Disposable N-100 rated respirator (at least)
• Disposable shoe covers
• Eye protection
• Work gloves

STEP 4 - Minimize the Dust:
As you work, your goal is to keep the dust down. Remember that as you scrape, drill, cut, open walls, etc., you are creating dust. You can keep dust down by using the right tools and following some simple practices that minimize and control the spread of dust. Remember - work wet, work safe, work clean! Equipment and materials used during this process include:

• Wet-dry sandpaper, sanding sponge
• Misting bottle or pump sprayer
• Heavy plastic sheeting
• Utility knife or scissors
• Masking tape, duct tape, or painters’ tape
• High Efficiency Particulate Air (HEPA) vacuum
• Heavy duty plastic bags
• Tack pads (large, sticky pads that help remove dust), paper towels, or disposable wipes

STEP 5 - Leave the Work Area Clean:
The work area should be left clean at the end of every day and must be cleaned thoroughly at the end of the job. The area must be completely free of dust and debris before it can be cleared by the Certified Renovator assigned to the project. Cleaning materials for an RRP Project include:

• Heavy-duty contractor bags
• HEPA vacuum with attachments and a powered beater bar
• Masking tape, duct tape, or painters tape
• Misting bottle or pump sprayer
• Disposable wet-cleaning wipes or hand towels
• General-purpose cleaner
• Mop and disposable mop heads
• Two buckets or one two-sided bucket with a wringer
• Shovel and rake
• Wet Mopping System
• Electrostatically charged dry cleaning cloths

STEP 6 - Control the Waste:
Waste from renovation activities must be contained to prevent releases of dust and debris before the waste is removed from the work area for storage or disposal. Collect and control all your waste. This includes dust, debris, paint chips, protective sheeting, HEPA filters, dirty water, cloths, mop heads, wipes, protective clothing, respirators, gloves, architectural components and other waste. Equipment and materials needed for this step include:

• Heavy-duty contractor bags
• HEPA vacuum to clean outside of waste bags
• Always check local requirements!

STEP 7 - Verify Work Completion with the Cleaning Verification Procedure or Dust Clearance Exams:
When your interior renovation work is complete, you have to do one of two clearance tests to ensure you cleaned up the job by the RRP standards - either a Cleaning Verification (CV) Procedure, or a Dust Clearance Examination performed by a Lead Inspector, Risk Assessor, or Dust Sampling Technician. As an EPA Certified Renovator, you are only allowed to perform a Cleaning Verification (CV) Procedure, in which you will check for dirt and dust by taking “swipes” of all windowsills, countertops and floors in the work area and checking them against your CV Card. The difference between this CV Procedure and a Dust Clearance Exam, is that for a Dust Clearance Exam, these “swipes” are sent to an accredited NLLAP laboratory. For exterior projects, when work areas have passed the visual inspection, the project is complete and the area may be turned over to the occupants. For conducting the Clearance Verification Procedure for interior projects, you will need:

• A flashlight
• CV card (provided in class)
• Wet, disposable cleaning clothes
• Cleaning materials if the renovation firm fails the Cleaning Verification Procedure

Keep in mind, this EPA RRP Rule applies to ALL activity that will disturb lead-based paint, whether you are a carpenter, an electrician, a plumber, a renovator, or the general contractor subbing out the actual work. If you do need training, or have additional questions on this topic, we are happy to help – send an email to contact@greenedu.com or give us a call at 1-800-355-1751.

Oklahoma Joins EPA-Authorized States for RRP Rule

Oklahoma, OK - As of Spring 2013, Oklahoma has been authorized by the Environmental Protection Agency (EPA) as the 13th state to run its own Lead Safe Renovation, Repair, and Painting program in lieu of the federal EPA program.

What this means for painters, renovators, and contractors who perform work in Oklahoma:

• If you are already an EPA Certified Renovator: Reciprocity will be granted to perform work in Oklahoma until your initial training certification expires. Refresher training must be taken with an Oklahoma-approved training provider, following the state curriculum requirements.
• If you are NOT already certified by the EPA or other EPA-authorized state: Candidates must attend an Oklahoma-approved training course, and register for Firm Certification with the state (Oklahoma RRP Firm Application). The fee is $300 and is valid for 5 years.

If you perform renovation, repair, or painting activities in Oklahoma on housing or residential buildings older than 1978, make sure you are complying with these new state requirements. For details on the EPA's RRP Rule, visit http://www.greenedu.com/epa-lead-rrp-overview or call Green Education Services at 646-564-3546.