US · Expiry & renewal tracking
Re-certify your EPA lead-safe firm before the certificate expires
A firm renovating pre-1978 target housing or child-occupied facilities for compensation needs EPA RRP certification, issued for at most 5 years and renewed every 5 years (40 CFR 745.89). Applying at least 90 days before expiry keeps the certificate in effect; otherwise the firm may not renovate until EPA approves it.
EPA's Renovation, Repair and Painting (RRP) rules apply to renovations performed for compensation in target housing and child-occupied facilities, unless an exception applies (40 CFR 745.82(a)). Target housing is housing built before 1978, except housing for the elderly or persons with disabilities and 0-bedroom dwellings, unless a child under 6 lives or is expected to live there (40 CFR 745.103). A child-occupied facility is a building, or part of one, built before 1978 and regularly visited by the same child under 6, such as a day care centre or preschool (40 CFR 745.83).
No firm may perform, offer or claim to perform such renovations without EPA certification under 40 CFR 745.89, unless an exception applies (40 CFR 745.81(a)(2)(ii)). These federal requirements apply in States and Tribal areas that do not have an EPA-authorized renovation program (40 CFR 745.81(a)). EPA issues the certificate with an expiration date not more than 5 years from approval (40 CFR 745.89(a)(2)(i)).
To keep its certification, a firm must be re-certified by EPA every 5 years. A re-certification application is timely if it is submitted electronically 90 days or more before the current certification expires; the current certification then stays in effect until it expires or until EPA decides, whichever is later. If the application is filed less than 90 days before expiry and EPA has not approved it by then, the certification expires and the firm may not do renovations until EPA approves it. A firm that is not re-certified before expiry must not perform renovations or dust sampling until it is certified anew. The new certificate expires 5 years after the current one (40 CFR 745.89(b)).
At a glance
| Rule | 40 CFR 745.89, EPA lead Renovation, Repair and Painting rule |
|---|---|
| Validity | Not more than 5 years; re-certification every 5 years |
| Timely renewal | Submitted electronically 90 days or more before expiry |
| New certificate | Expires 5 years after the current one |
| Changes to firm details | Amend the certification within 90 days |
| Records | Kept 3 years after each renovation is completed |
These federal requirements apply in States and Tribal areas without an EPA-authorized renovation program (40 CFR 745.81(a)).
Who is responsible?
The firm. It must make sure every person doing renovation work for it is a certified renovator or trained by one, that a certified renovator is assigned to each renovation, that the work practice standards, pre-renovation education and recordkeeping requirements are met (40 CFR 745.89(d)), and it must keep the records for 3 years after each renovation (40 CFR 745.86(a)).
If the deadline passes
If the firm is not re-certified before its certification expires, it must not perform renovations or dust sampling until it is certified anew (40 CFR 745.89(b)(1)(iii)). Failure to comply with the RRP rules is a violation of the Toxic Substances Control Act, and violators may be subject to civil and criminal sanctions for each violation (40 CFR 745.87).
Update the certification when firm details change
A firm must amend its certification within 90 days of a change to information in its most recent application. If it does not, it may not perform renovations or dust sampling until the certification is amended. Amending does not change the expiration date (40 CFR 745.89(c)).
Tracking it with ExpirySuite
- Add the firm certification with its expiration date.
- Add a second record dated 90 days before expiry for the application deadline, so you are reminded in time to file a timely re-certification application.
- Reminders arrive 60, 30, 14, 7 and 1 day before the due date and on the due date itself.
- Track each certified renovator's certificate as a separate document, because every renovation needs one assigned.
- Assign a responsible person (for example your compliance or office manager) so the right person gets the reminder.
- If a date passes, managers get overdue reminders 3, 7 and 14 days later.
- Upload the new certificate, or ask a colleague to send it through a secure upload link, valid for 14 days; no account is needed.
Frequently asked questions
- How long is an EPA RRP firm certification valid?
- Not more than 5 years from approval. The firm must be re-certified by EPA every 5 years (40 CFR 745.89(a)(2)(i) and (b)).
- When should a firm apply for re-certification?
- 90 days or more before the current certification expires. A complete, timely application keeps the current certification in effect until expiry or until EPA decides, whichever is later (40 CFR 745.89(b)(1)(i)).
- What if we apply less than 90 days before expiry?
- If EPA has not approved the application by the expiration date, the certification expires and the firm may not conduct renovations until EPA approves it (40 CFR 745.89(b)(1)(ii)).
- Which buildings are covered?
- Renovations for compensation in target housing (generally housing built before 1978) and child-occupied facilities built before 1978, unless an exception applies (40 CFR 745.82, 745.83 and 745.103).
Sources
- eCFR: 40 CFR 745.89, Firm certification
- eCFR: 40 CFR 745.81, Effective dates
- eCFR: 40 CFR 745.82, Applicability
- eCFR: 40 CFR 745.83, Definitions
- eCFR: 40 CFR 745.103, Definitions (target housing)
- eCFR: 40 CFR 745.86, Recordkeeping
- eCFR: 40 CFR 745.87, Enforcement and inspections
Last checked: Sep 30, 2026 · This page summarises official sources for general information and is not legal advice. Check the linked sources for current rules and fees.
Made for EPA lead-safe (RRP) firm certification (US)
A ready template for EPA lead-safe (RRP) firm certification (US) with sensible validity defaults, so you enter less and track more.
Reminders on time
Email alerts at 60, 30, 14, 7 and 1 day before each EPA lead-safe (RRP) firm certification (US) expires, plus overdue escalation to managers.
Assign an owner
Give each EPA lead-safe (RRP) firm certification (US) an owner and let employees update their own via a secure link — no login needed.