EPA issued the Renovation, Repair, and Painting (RRP) rule in 2008, and has amended it several times, most significantly in May 2010 and in July 2011. Listed below are changes to the RRP rule that are particularly relevant to training providers. For more detailed information and a more complete set of changes, please refer to the rule and amendments at http://epa.gov/lead/pubs/rrp.htm.
Documentation of personnel qualifications
• Training programs must submit names and documentation demonstrating qualifications of the education, training, and work experience of the training manager and any principal instructor(s) with their applications for accreditation and re-accreditation. (§745.225(b)(1)(iii) and (iv), §745.225(e)(5)(iii) and (iv), and §745.225(f)(3)(iii) and (iv))
Submission of training course materials
• Unless the training program uses EPA-recommended model training materials, a training provider must submit a copy of its training course materials with its application for accreditation for review by the Agency in order to become accredited. Note that training providers using material from authorized States or Indian Tribes must also submit those materials. (§745.225(b)(1)(vi))
Accreditation amendments
• Training providers must amend their accreditation application within 90 days of the date a change occurs, by submitting a signed application form, whenever there is a change to the information presented in their most recent accreditation or re-accreditation application. If the training provider does not amend its most recent accreditation application within 90 days of the date the change occurs, it must stop providing training until the accreditation application is amended. (§745.225(j)(1))
• EPA will now have a 30 day period to review accreditation amendment applications that include a new training program manager, new principal instructor, or new permanent training location. (§745.225(j)(3))
• Training providers must not provide training under a new training manager or offer courses taught by any new principal instructor until 30 days after an amendment application is submitted for the change, unless EPA approves the amendment earlier. However, new training managers or principal instructors already approved under another EPA training program accreditation may be used on an interim basis during the 30 day EPA review period. (§745.225(j)(3))
• Training providers may use new permanent training locations on an interim basis during the 30 day EPA review period. (§745.225(j)(3)(ii))
• No fee will be charged for accreditation amendments. (§745.238(c)(5))
Role of principal instructor
• Principal instructor(s) are primarily responsible for teaching the course materials and must be present to provide instruction (or oversight of portions of the course taught by guest instructors) for the course for which he has been designated the principal instructor. (§745.225(c)(3))
Training topics
• Renovator instruction must include procedures for collecting a paint chip sample and sending it to a laboratory recognized by EPA under section 405(b) of TSCA. (§745.225(d)(6)(v))
Hands-on training topics
• Renovator instruction must include hands-on training in using test kits, renovation methods that minimize creation of dust and lead-based paint hazards, interior and exterior containment and cleanup methods, and cleaning verification. (§745.225(d)(6))
• Dust sampling technician instruction must include hands-on training in dust sampling methodologies and report preparation. (§745.225(d)(7))
• All refresher courses (except project designer) must include hands-on training. (§745.225(e)(2))
E-learning
• Requirements for electronic learning (“E-learning”) and other alternative course delivery methods are now specifically included. Details are included in the regulation. Training providers must assign a unique identifier to each student. E-learning or other alternative delivery methods cannot be used for the hands-on training, the final course test, or the proficiency test, if one is given. (§745.225(c)(6)(viii))
Trainee photograph requirements
• Photographs on course completion certificates must be an accurate and recognizable image of the individual and not smaller than one square inch in size when reproduced on the certificate. (§745.225(c)(8)(vii))
Training provider recordkeeping
• For renovator and dust sampling technician refresher courses, training programs must maintain a copy of each trainee’s prior course completion certificate showing that each trainee was eligible to take the refresher course. (§745.225(i)(1)(viii))
• For all courses delivered in electronic format, training programs must maintain records of each student’s log-ins, launches, progress, and completion, and a copy of the electronic learning completion certificate for each student. (§745.225(i)(1)(ix))
• The recordkeeping period for records associated with renovator and dust sampling technician courses was increased. Records for renovator or dust sampling technician courses completed before April 22, 2010 must be kept until July 1, 2015. Records for renovator and dust sampling technician courses offered on or after April 22, 2010 must be kept for a minimum of 5 years. (§745.225(i)(2))
Doreen Cantor Paster
Associate Chief, Lead, Heavy Metals, & Inorganics Branch
Office of Chemical Safety and Pollution Prevention
U.S. Environmental Protection Agency (7404T)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Phone: 202-566-0486
Email: cantor.doreen@epa.gov