EPA RRP Requirements in 2026: Firm Certification, Renovator Training, and State Programs

EPA's Renovation, Repair and Painting rule applies to covered renovation work in pre-1978 housing and child-occupied facilities. The rule is about lead-safe work practices when paint is disturbed. It is not the same thing as a general contractor license.

EPA's renovator training page says each firm must be certified, at least one certified renovator must be assigned to each covered job, and other workers involved in renovation activities must either also be certified renovators or be trained on the job by a certified renovator.

This is also why contractors get in trouble when they treat RRP like a single wallet card. The legal obligations sit at both the firm and worker level.

EPA's lead program FAQ says a firm may not perform, offer, or claim to perform covered renovations without certification. EPA also says sole proprietors still count as firms for this purpose.

Separately, a renovator becomes certified by completing an accredited renovator training course. EPA says the initial course is eight hours with hands-on instruction.

If you are a general contractor using subs, the EPA FAQ is explicit that all firms performing covered renovations remain responsible for compliance. That is broader than many shops assume.

Under EPA's federal training rules, renovator certification does expire. EPA says a renovator must take refresher training before expiration, and that an online refresher renews for three years while a hands-on refresher renews for five years.

If the renovator certification expires, EPA says the worker must take the full eight-hour course again to regain certification.

Firm approval is a different workflow. Under EPA's federal materials, firms apply through EPA's RRP firm certification process. But state-authorized programs can use their own forms, fees, and renewal handling, so you should not blindly carry federal timelines into a state-run program.

EPA's lead FAQ says that in EPA-authorized states and Tribal areas, contractors should check with the state or Tribal agency administering the program to learn the certification requirements in that jurisdiction. EPA also says it encourages those programs to accept federal or other state certifications, but that they are not required to do so.

That is the key reason we moved the state RRP detail pages on YourStanding to public requirement pages instead of indexable renewal pages. The same slug can represent very different realities depending on the state.

• California: CDPH says California's Lead-Related Construction program is not the same as EPA's model program, and out-of-state certificates are not automatically valid there.
• Massachusetts: Mass.gov says a licensed lead-safe renovation contractor must be used for covered renovation work.
• Oregon: Oregon says at least one owner or employee must complete the eight-hour RRP training and the CCB handles the certified lead-based paint renovation contractor license.
• Washington: Commerce says it administers the RRP program directly and that covered RRP certifications are valid up to five years.
• Wisconsin: DHS says it is authorized by EPA to administer and enforce Wisconsin's Lead-Safe Renovation Rule and that both company and individual certification are required.
• Pennsylvania: Pennsylvania's Department of Health says EPA enforces the RRP rule there, while Pennsylvania's own Labor & Industry certifications are for abatement work rather than ordinary renovation.

EPA's FAQ says firms must retain records needed to demonstrate compliance for three years after the renovation is completed. EPA also says certified renovators must have their initial course certificate and most recent refresher certificate available at the job site.

This is the operational takeaway: if your company performs covered work, you need more than a vague memory that someone on staff once took a class. You need the right firm approval, the right renovator training record, and the right project documentation.

Track state licenses separately from lead-safe renovation requirements