The Lapsed Firm and Renovator Certificates
A 1958 apartment complex is owned by a management company that uses its own four-person maintenance staff for turnover work. The company's EPA renovation-firm certification expired four months ago. One maintenance employee took the initial 8-hour certified renovator course six years ago and has not taken a refresher. The other three employees have no RRP training. The company plans to replace 14 interior doors and paint six door frames in a vacant unit next week. The experienced employee says he can supervise by phone from another property because the work is straightforward. The state has no EPA-authorized renovation program. The property manager wants to know whether the crew can start and what records must be available if an inspector visits. The unit will be re-rented immediately.
1. Can the management company's maintenance crew legally perform this renovation next week? Identify every certification gap.
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No. There are at least two independent gaps.
First, the management company is the renovation firm, and its firm certification expired four months ago. A firm must be certified before it performs, offers, or holds itself out as performing renovations for compensation. The company must renew its firm certification before work begins.
Second, the experienced employee's individual certified renovator certificate is no longer valid. Initial renovator certification lasts five years. A refresher course must be taken within that five-year period to maintain certification. Because this employee let the certificate expire, he must retake the initial 8-hour certified renovator course, not simply a refresher. The other three employees do not each need individual renovator certification, but they may perform work only after being trained by a certified renovator and while working under the required supervision. The firm must have at least one properly certified renovator assigned to the job. Because the state has no authorized program, EPA administers the program and EPA credentials are required.
2. What does 'supervise by phone' fail to satisfy? Describe the certified renovator's required on-site duties.
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Phone supervision from another property does not satisfy the on-site duties that the Rule assigns to the certified renovator.
The certified renovator must be physically present at the work site at the start of the renovation and at the time warning signs are posted. The renovator also must perform the post-work cleaning verification personally; that cannot be delegated to an untrained worker or done by phone. The renovator must provide on-the-job training to non-certified workers on the required work practices and must be available by telephone when not physically present for other portions of the job. For this job, the renovator should be on site to set up containment, post signs, train the crew, and return to perform cleaning verification before the unit is released. A phone call cannot confirm that plastic sheeting is sealed, that prohibited practices are avoided, or that dust has been cleaned up properly.
3. List the records the firm should have ready, and explain why a signed acknowledgment from the tenant is not the only record needed.
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The firm should have ready, at minimum:
- Its current firm certification.
- The assigned certified renovator's current certification.
- Training records for the three non-certified maintenance employees.
- Proof that the Renovate Right pamphlet was delivered and the occupant acknowledgment, or documentation of an unsuccessful delivery attempt.
- Any EPA-recognized test kit results if components were tested.
- Records showing work practices used and the cleaning verification result.
- The required posting or notice information, if applicable.
A signed acknowledgment proves only that pre-renovation education occurred. It does not prove that the firm was certified, that the renovator was certified, that workers were trained, that containment was used, or that cleaning verification was performed. An inspector will look for the full record chain because RRP compliance depends on qualifications and work practices, not just paperwork signed by the tenant.