EPA RRP Lead Certification: Firm, Training & Renewal (2026)

A state may not license painting or remodeling, but paid work can still be regulated by the federal Lead Renovation, Repair and Painting Rule. The RRP Rule applies to covered renovation in pre-1978 target housing and child-occupied facilities and requires certified firms, trained people, lead-safe work practices, occupant education, and records.

This guide covers the federal baseline as administered by EPA. Fifteen states and one Tribe run EPA-authorized RRP programs in place of the federal program, and those programs can have different forms, fees, and procedures.

When the rule applies

The rule generally covers a firm performing renovation for compensation when the work disturbs painted surfaces in:

target housing: most housing built before 1978, subject to regulatory exclusions; or
a child-occupied facility: a qualifying pre-1978 building or portion regularly visited by the same child under six.

“Firm” includes a sole proprietorship. Covered people can include contractors, landlords, property managers, and maintenance staff performing compensated renovation. A homeowner doing work in the owner’s own residence is generally outside the rule unless another covered use, such as rental housing or child care, applies.

The minor repair and maintenance limit

An activity can qualify as minor repair and maintenance when it disturbs no more than six square feet of painted surface per room for interior work or no more than 20 square feet for exterior work. Those areas are calculated under EPA’s rules and can be aggregated with related work.

The exception does not apply when the job uses a prohibited practice or involves window replacement or demolition of painted surface. Do not read the square-foot numbers as a blanket exemption for every small job.

Testing can also affect coverage. A certified renovator, certified lead inspector, or certified risk assessor may use an approved method to determine that affected components do not contain regulated lead-based paint. Keep the required documentation.

Firm certification and renovator training

Firm certification. The business must be certified by EPA or the authorized state or Tribal program. In EPA-administered areas, renovation firm certification currently costs $300 and is valid for five years. EPA advises applying for recertification at least 90 days before expiration to preserve continuity under its timeliness rules.

Certified renovator. The firm must assign a certified renovator to each covered renovation. Initial certification comes from an eight-hour course accredited by EPA or an authorized program, including two hours of hands-on learning. Other workers disturbing paint must either be certified renovators or receive documented on-the-job training from one.

Individual renovator certification is represented by the course-completion certificate, not by the firm’s certificate. A company needs both layers: a certified firm and the required trained personnel.

Core jobsite duties

give the required “Renovate Right” information and document delivery before work;
post warning signs and contain the work area;
avoid prohibited practices, including specified open-flame burning and uncontrolled machine sanding or grinding;
control, bag, and dispose of dust and debris properly;
clean the area using the required methods and complete cleaning verification; and
retain required records for three years.

The certified renovator has responsibilities that must be performed personally and others that can be directed. Use EPA’s current Small Entity Compliance Guide and course materials for the exact onsite requirements rather than relying on a short checklist.

RRP is not abatement

RRP governs renovation, repair, and painting where paint disturbance occurs during the work. Lead abatement is designed specifically to permanently eliminate lead-based-paint hazards and is regulated under a separate certification framework. RRP firm or renovator status does not, by itself, qualify a contractor to perform abatement.

Do not infer the correct program from the tools being used. The purpose and design of the project matter, along with any order from a housing or health authority.

Where to apply

EPA currently lists these 15 states as operating authorized RRP programs:

Alabama, Delaware, Georgia, Iowa, and Kansas;
Massachusetts, Mississippi, North Carolina, Oklahoma, and Oregon;
Rhode Island, Utah, Vermont, Washington, and Wisconsin.

The Minnesota Chippewa Tribe–Bois Forte also operates an authorized program. Contractors working in one of these areas apply to that program rather than EPA for the covered work. A firm operating across program boundaries may need more than one certification.

Renewal details that are easy to miss

EPA firm certification lasts five years. Renovator refresher training must be completed before the individual certificate expires. Under the federal program, a refresher course with hands-on training renews renovator certification for five years, while a qualifying online refresher without hands-on training renews it for three years. Authorized programs can set their own procedures, so verify the course with the authority governing the job.

If renovator certification expires before the refresher is completed, the individual generally must retake the initial course. Track firm and individual dates separately.

Enforcement and penalties

RRP obligations are enforceable under the Toxic Substances Control Act. Civil penalty maximums are adjusted for inflation, and an enforcement matter can involve multiple requirements. Actual penalties depend on the facts and statutory factors; avoid quoting an old fixed maximum as though it were the automatic fine for every job. Knowing or willful violations can also carry criminal consequences.

Official sources

Check the painting requirements for your state, then use EPA’s firm and training-provider searches or the authorized program’s directory before accepting covered work.