Lead

Details on Certification Requirements for Firms

On this page you will find:

What kinds of firms need to be certified?

  • Any firm that is paid to perform work that disturbs lead paint or conducts lead dust sampling in housing or child-occupied facilities built before 1978 must be certified.
  • This may include residential rental property owners/managers, maintenance staff, general contractors, renovators and remodelers, and special trade contractors including painters, plumbers, carpenters, electricians, and kitchen and bath specialists.
  • EPA has defined the term "firm" to mean a company, partnership, corporation, sole proprietorship or individual doing business, association, or other business entity; a Federal, State, Tribal, or local government agency; or a nonprofit organization.

Top of page

Should a self-employed renovator or dust sampling technician also be certified as a firm?

Yes. All firms, including sole proprietorships, must be certified. In addition, firms must ensure that all persons performing renovation activities on behalf of the firm are properly trained, and certified as required.

Top of page

How does my firm become certified?

A firm that wishes to become certified to perform renovations or conduct dust sampling must submit an application, along with the correct amount of fees, attesting that it will:

  • Assign a Certified Renovator to each renovation that it performs,
  • Use only certified or properly trained individuals to perform renovations, and
  • Follow the work practice standards and recordkeeping requirements in the regulation.

EPA will certify any firm that meets these requirements unless we determine that the environmental compliance history of the firm, its principals, or its key employees demonstrates an unwillingness or inability to maintain compliance with environmental statutes or regulations.

EPA has up to 90 days after receiving a complete application for firm certification to approve or disapprove the application.

Top of page

If my information changes, do I have to file another certification application?

A firm must amend its certification within 90 days whenever a change occurs to information included in its most recent application. Examples of amendments include a change in the firm's name without transfer of ownership, or a change of address or other contact information.

If a firm fails to amend its certification within 90 days of the date the change occurrs, it will not be authorized to perform renovations until its certification has been amended.

To amend its certification, a firm must submit an application, noting on the form that it is submitted as an amendment. The firm must complete the sections of the application pertaining to the new information, and sign and date the form. The amendment must include the correct amount of fees.

Amending a certification will not affect the validity of the existing certification or extend the certification expiration date. EPA will issue the firm a new certificate if necessary to reflect information included in the amendment.

Firm certifications are not transferable. If the firm is sold, the new owner must submit a new initial application for certification.

Top of page

How does my firm maintain its certification?

A certified firm maintains its certification by submitting a complete and timely "Application for Firms," noting that it is an application for re-certification, and paying the required re-certification fee.

You must apply for a re-certification at least 90 days before the firm's current certification expires.

If a complete application, including the proper fee, is postmarked 90 days or more before the date the firm's current certification expires, the application will be considered timely and sufficient. In that case, the firm's existing certification will remain in effect until its expiration date or until EPA has made a final decision to approve the re-certification application, or not, whichever occurs later. The expiration date for the firm's re-certification will be 5 years from the date the existing certification expired, regardless of when the re-certification is approved.

However, in cases where a complete application is postmarked less than 90 days before the date the current certification expires, if EPA does not approve the re-certification application before the existing application expires, the firm's certification expires. In this case, the recertification application will be regarded as a new certification, and the expiration date will be 5 years from when this new certification is issued. The firm will not be able to conduct renovations until EPA approves this new certification application.

Similarly, if the firm submits an incomplete application for re-certification and EPA does not receive all of the required information and fees before the date the firm's current certification expires, or if the firm does not submit its application until after its certification expired, EPA will not approve the firm's re-certification application. Again, the recertification application will be regarded as a new certification, and the expiration date will be 5 years from when this new certification is issued. The firm will not be able to conduct renovations until EPA approves this new certification application.

If EPA does not approve the application, the Agency will provide the applicant with the reasons for not approving the re-certification application. Any fees submitted by the applicant will not be refunded, but the firm can submit a new application for certification, along with the correct amount of fees, at any time.

Top of page