2. Does your business have a certified renovator (or equivalent under a delegated state or tribal authority) available to supervise projects covered by the RRP rule?
The distinction between being a certified firm (as asked in Q1) and having a certified renovator on staff is an important one.
“To become a certified firm means that the business sends in the required application and a $300 fee,” McCadden explains. “By doing so, they can do the work, but have also recognized their legal responsibilities related to the rule. A certified firm must use a certified renovator to supervise the RRP-related work the business performs. The certified renovator attends the required class to learn the work practices and documentation requirements of the rule to become ‘certified.'”
McCadden says he believes some remodelers are unclear on this distinction in the RRP rule, while others have taken the certified renovator classes, but are waiting to see if EPA begins enforcing the rule before spending more money on certifying the firm or buying necessary tools and supplies.