EPA RRP Lead-Safe Firm Renewal Process

Why this matters

Any firm that performs renovation, repair, or painting work that disturbs more than six square feet of interior or twenty square feet of exterior painted surfaces in a pre-1978 residential property or child-occupied facility must be EPA Lead-Safe Certified per 40 CFR 745 Subpart E. Firm certification is separate from the individual Certified Renovator certification under 40 CFR 745.90. The firm certification runs on a five-year cycle. Missing the renewal means every dollar of revenue from RRP-covered work after expiration is in violation of the Toxic Substances Control Act (TSCA), and EPA penalties are inflation-adjusted under 40 CFR 19.4 and posted by the agency annually. Renewal is straightforward but easy to miss because there is no automatic reminder.

Coverage scope - confirm you actually need this

Per 40 CFR 745.83 and 745.85:

• Target housing - any pre-1978 residential dwelling unit, EXCEPT housing for the elderly or persons with disabilities (unless a child under six resides there) AND zero-bedroom dwellings.
• Child-occupied facility - building, OR portion of a building, constructed before 1978, visited regularly by the same child under six on at least two different days within any week, with each visit at least three hours and the combined weekly visits at least six hours and combined annual visits at least 60 hours. Daycares, kindergartens, preschools.

Work scope thresholds at 40 CFR 745.83 minor repair and maintenance exemption: disturbing six square feet or less per room of interior painted surface, twenty square feet or less of exterior painted surface, AND no window replacements OR demolition work. Above any threshold, full RRP applies.

Trade implications:

• Window replacement in any pre-1978 home triggers RRP regardless of square footage.
• HVAC service that requires drilling penetrations through painted exterior walls can trigger if the disturbance exceeds 20 square feet exterior.
• Electrical service installing a panel and pulling new circuits through painted walls almost always triggers if multiple penetrations.
• Plumbing repairs cutting drywall in older homes can trigger interior thresholds quickly.

If the work is in any pre-1978 structure, the safer default is to assume RRP applies.

Initial firm certification (recap)

Per 40 CFR 745.89(a): the firm submits an application via EPA's Central Data Exchange (CDX) including firm name, address, contact information, and a certification statement. EPA reviews. The firm certificate is issued for five years.

Renewal timing - the 90 day window

40 CFR 745.89(c): the firm must submit the renewal application within 90 days before the certification expires. Submit too early and EPA will reject; submit late and the firm is uncertified during the gap.

Calendar plan:

• 180 days before expiration: pull the firm certificate, confirm expiration date, calendar the 90-day-before-expiration date as renewal-eligible date.
• 90 days before expiration: submit renewal via CDX.
• 60 days before expiration: if no confirmation received, contact EPA's Lead Program at the EPA Region office covering the firm's state.
• Expiration date: confirm renewed certificate appears in EPA's Lead-Safe Firm search at epa.gov/lead.

Renewal application contents

40 CFR 745.89(c) renewal mirrors the initial application. Items to verify before submitting:

• Firm name exact match to the original certification (no DBA changes without separate amendment)
• Business address current
• Owner or principal contact current; if changed, file amendment separately under 745.89(d)
• Certification statement re-signed by an authorized officer
• Renewal fee per the EPA fee schedule

If the firm has changed its EIN, the firm is treated as a NEW firm and must re-apply rather than renew. Mergers, acquisitions, and entity conversions trigger this.

Certified Renovator individual recertification - related but separate

40 CFR 745.90 governs the individual Certified Renovator. The five-year refresher requirement was modified:

• Initial certification: 8-hour course from an EPA or state-accredited training provider.
• Recertification: 4-hour refresher course (with hands-on component) OR 4-hour refresher (without hands-on) if the initial course included hands-on training. The without-hands-on refresher requires a hands-on initial.

Each Certified Renovator must complete refresher training and obtain a new Renovator certification before the previous one expires. Track individually per renovator.

For the FIRM renewal, EPA does not require attaching individual renovator certificates - but if the firm has no Certified Renovator on staff at the time of renewal, the firm cannot legally perform RRP work and the renewal is functionally meaningless.

State-administered programs

EPA delegates RRP administration to several states with EPA-approved programs. Active state administrators (verify current list at epa.gov/lead):

• Alabama, Delaware, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oklahoma, Oregon, Rhode Island, Utah, Washington, Wisconsin

Firms operating in these states renew through the state agency, NOT EPA. Each state has its own portal, fee, and renewal timing rules; verify with the state lead program. A firm working in both delegated and EPA-administered states needs certification in EACH jurisdiction.

Records, signage, and customer-facing requirements

40 CFR 745.85 mandates for every covered job:

• Distribute the EPA "Renovate Right" pamphlet to the owner and occupants before work begins (acknowledgment required).
• Post warning signs at work area entrances during the project.
• Contain the work area with poly sheeting, plastic, or equivalent containment.
• Use lead-safe work practices: no open-flame burning, no heat-guns above 1100 F, no power sanding without HEPA, no power planing without HEPA.
• Conduct a cleaning verification at job completion using the lead-cleaning verification card.
• Provide cleaning verification results to the owner.

40 CFR 745.86 recordkeeping retention is THREE YEARS from completion of the renovation, including:

• Records demonstrating the firm followed lead-safe work practices
• Pre-renovation education documentation (pamphlet acknowledgment)
• Renovator certifications
• Subcontractor certifications
• Test kit results (if test-out applied)

References

• 40 CFR Part 745 Subpart E - Residential Property Renovation
• 40 CFR 745.83 - Definitions and minor maintenance threshold
• 40 CFR 745.85 - Work practice standards
• 40 CFR 745.86 - Recordkeeping requirements
• 40 CFR 745.89 - Firm certification
• 40 CFR 745.90 - Renovator certification
• Section 402 of Toxic Substances Control Act (15 USC 2682)
• EPA Lead-Safe Firm search at epa.gov/lead