Who must have firm certification?
If you are doing renovation activity that is covered under the lead RRP Rule, then you may need to have EPA Firm Certification. This is different than having the individual lead paint certification. This can be a bit confusing so let’s break it down. The EPA requires firms working for compensation in affected properties that will disturb lead-based paint to be certified. But, what is considered a firm? A firm is simply a company and the two words can be used interchangeably. Firms also include sole proprietorships in which there is only one person acting as both the owner and operator of the business.
Certification is required even if your company is not a legal entity, hold a contractor license, or even need a permit to do your work. It basically boils down to if you are working for compensation in these older affected properties, you need a lead safe firm certificate. If your company has many employees, not everyone has to apply for this. Only one certificate is needed for the business. Typically the owner or owners representative will submit an application for the company.
What if there are multiple companies working the same project that is covered under the scope of the rule? For instance, a project has a general contractor running the project and hired several subcontractors to do much of the work. Who needs to be certified? The EPA is very clear on this. All separate contacting companies would need to have the firm certificate. You may often see this referred to as a contractor lead license as part of a document, bid proposal or permit application.
How Contractors can get Lead Certification
Now that you know you need to get your firm certification to do your work, you may be asking yourself, just how do you get it? Well, it’s relatively easy process so don’t sweat it. The first thing to remember is that only one application is needed for the entire business. No matter how many employees, just submit one application. Please remember the requirement is one application per company and not per person. In this example, if one person owns three companies doing business affected by the rule, then the one person would submit three applications to the EPA. One application would be submitted for each separate business. Note that if you do work in a state authorized by the EPA to manage their own lead program, then you must submit the application to your state you are doing work in. Read on to find out details about state authorized programs and if they apply to you.
There are 3 easy steps to get your Lead Safe Firm Certificate
- Fill out the EPA application and submit $300.00 payment.
- Allow up to 90 days for the EPA to process your application.
- Receive your Certificate in your company name from the Environmental Protection Agency!
Renewing Your Certification
Your certification is valid for 5 years in most locations. It is important not to let your certificate expire. If it does, then you will be unable to continue doing work activity in these older properties until you re-certify. I highly recommend being proactive and submit your application early. As with the initial application, the EPA can take up to 90 days to process. Do you want your firm certificate to be valid and not expire while your new application is being reviewed? I’m guessing the answer is yes. Then you must be timely on this. You must submit your application at least 90 days before the certificate expiration date. It’s that easy. I would suggest simply marking the date on your calendar and letting it remind you prior to the time needed to resubmit. That way you won’t forget and you will be able to continue your work activity and be in compliance with the lead paint law.
What if I do work in a State Authorized Program
You might be asking yourself, what is a state authorized program. When the EPA first came out with this rule, they were hopeful states would adopt the rule and take over management of it. That didn’t happen to the level that was expected. However, at this time, there are 14 states that did. What does this mean? The EPA doesn’t regulate the Lead RRP Rule in these locations, the states do. Simply put, the EPA certification does not apply in state authorized programs. So, if you do work in on of these states, AL, DE, GA, IA, KS, MA, MS, NC, OK, OR, RI, UT, VT, WA, WI then you must apply directly to that program.
If you are a contractor doing work in one of the following locations, please visit the links provided to find out state specific requirements on the application process and lead safe work procedures.
Alabama: Alabama Department of Public Health
Delaware: Delaware Division of Public Health
Massachusetts: Massachusetts Labor and Workforce Development
Mississippi: Mississippi Department of Environmental Quality
North Carolina: North Carolina Health and Human Services
Oregon: Oregon Public Health
Rhode Island: Rhode Island Department of Health
Vermont: Vermont Department of Health
Washington: Washington Department of Commerce
Wisconsin: Wisconsin Department of Health Services
Minnesota Chippewa Tribe – Bois Forte (Nette Lake): Bois Forte Band of Chippewa
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