If your firm performs renovations in pre-1978 housing or child-occupied facilities for compensation, EPA requires both you and your firm to be certified. 40 CFR § 745.81(a)(2)(ii) is unambiguous: every renovation must be performed by a certified firm using certified renovators. There is no substitute, no grandfather clause, and no de minimis exception for "just a small kitchen." ECT went through both certification tracks in 2026 — individual Renovator in late April, firm in early May. Here is the timeline, the cost, and the EPA portals you'll actually use.
Two separate certifications, two separate processes
Most contractors conflate them. They're not the same.
- EPA Certified Renovator — an individual credential held by a person. Required for at least one person on every RRP job. Earned through an accredited 8-hour initial training course (4-hour refresher every 5 years thereafter). Governed by 40 CFR § 745.90.
- EPA Lead-Safe Certified Firm — a company credential held by the legal entity (LLC, corp, sole prop). Required for the firm to legally accept compensation for renovation work in target housing. Application-only — no exam. Governed by 40 CFR § 745.89.
You need both active to legally perform RRP work. Holding only one doesn't satisfy the rule. A firm can hold the firm cert and employ Certified Renovators; an individual can hold the Renovator cert and work for any certified firm. ECT runs both as the same person and the same entity — that's the small-business model.
The individual Renovator track — what to expect
I took the 8-hour initial course on 2026-04-29 at proActive Safety Services (an EPA-accredited training provider) at 2900 Jackson Ave in Ann Arbor. The fee was $250. Format: a full day in a classroom, morning lecture covering the regulation, afternoon hands-on lab where you set up containment, practice wet-wiping, perform the cleaning-verification card test, and document the whole flow. Pass-or-fail written exam at the end.
Bring a government-issued photo ID and a snack — there is no formal lunch break. The instructor was a working contractor with two decades in the field, which made the hands-on lab feel less theatrical and more like actual job-site practice. Pass rates are high (well over 90%) but the practical portion is the harder gate; the exam is open-book on the regulation but the lab requires you to physically perform each step.
EPA issues the certificate within 1-2 weeks. Mine arrived as a PDF by email and a hard card by mail. The cert is valid for 5 years and is portable — you carry it as an individual to any certified firm. Refresher course (half-day, ~$150) is required every 5 years to maintain.
To find an accredited trainer in your area, use the EPA accredited-training-program search at epa.gov/lead/find-training. Michigan has at least a dozen accredited providers; most offer the course monthly.
The firm track — what to expect
The firm certification is paperwork-only, no exam, no in-person component. You apply through EPA's online portal. ECT filed mid-April 2026; the cert issued on 2026-05-07. Total wait time: about 21 days, which is faster than the EPA-published estimate of 30-90 days.
What you submit:
- Firm legal name and federal EIN (no separate state cert number required, but EPA will verify the entity)
- Physical business address (P.O. boxes not accepted — must be a real address EPA can mail enforcement notices to)
- Name and EPA Renovator cert number of at least one Certified Renovator who will perform or supervise the work on every job
- Application fee: $300 for a small business (under $500K annual revenue). Larger firms pay tiered fees. Submit at EPA's firm-application portal.
- Acknowledgment that the firm will follow the work practice standards in 40 CFR § 745.85 and the recordkeeping requirements in 40 CFR § 745.86
EPA mails a wallet-sized certificate plus a PDF. The cert is valid for 5 years from issuance. Renewal is a similar online filing at the 5-year mark — no re-application from scratch, just an update to confirm the certified renovator on staff and the firm address.
Why the firm track matters more than the individual
Many GCs assume holding the individual Renovator cert is enough. It isn't. 40 CFR § 745.81(a)(2)(ii) applies to the firm that accepts compensation, not to the individual swinging the hammer. A firm without the firm cert violates the rule even if every employee on site holds a current Renovator cert. EPA enforcement actions in the past decade have specifically targeted firms operating with certified individuals but no firm certificate. Penalties can run up to $47,357 per violation per day under the Toxic Substances Control Act § 16(a).
The cost math
First-time setup, individual + firm together, runs about $550-700 all-in: $250 for the Renovator course, $300 for the firm application, plus the time cost of a full day in class and a few hours filling out the firm application. Renewals every 5 years cost roughly the same — $150 refresher course + ~$300 firm renewal — so the annualized cost across a 5-year window is about $130/yr for a small operation.
Compared to the labor cost of complying without certification (i.e., not at all, while absorbing the per-violation-per-day TSCA fine risk), the math is unambiguous: get certified.
If certification is more time than you have
General contractors who don't want to run their own lead-safe compliance program can subcontract the RRP portion to a certified firm. That's the model ECT runs: we hold the firm cert and the Renovator cert; you stay focused on your build. You're still required to verify your subcontractor's certs and retain proof for 3 years per 40 CFR § 745.86 — but the burden of the workflow shifts to the certified firm.
If your firm isn't certified and you have a pre-1978 job booked, the cheapest legal path forward is to subcontract. Reach out via the contact page or book directly through the booking calendar — flat $550 covers a full RRP day. If you want to get certified yourself instead, the EPA portals linked above are the only path; no third-party can shortcut it.