I’ve been asked several times if contractors really need to have the RRP Training. Here is the answer from Gio Fanelli with ERT,. Gio is a licensed contractor and a certified trainer for the RRP Training. He is also a member of the Construction Guild. LINK
Q: Does a contractor need to have the RRP training if he works on pre-1978 homes but subs out all the demo work?
A: Yes, based on the fact that the company is working for compensation and must understand the law, recordkeeping requirements and what the subs must do on the project that they have ultimate responsibility for overall so short answer is yes. All contractor that work on pre-1978 target homes or child occupied facility must be “certified firm” and have one “certified renovator” on staff or on contract if not employed by them.
Q: In such a case does the contractor still need to notify the homeowner.
A: Yes, pre-education “Renovate Right Pamphlet” to the owner of the building, tenants and or occupants is a must and records of this need to be kept for 3 years.
Q: When does the contractor have to register with the EPA?
A: The contractor only needs to register with the EPA if he takes on a pre-1978 project. Yes – only pre-1978 (Dec 31, 1977 / pre Jan 1, 1978) built.
Q: If the contractor subs out all that work does he still need to register with the EPA?
A: Yes, because this is the way U.S. EPA gets funded to help them enforce the law so short answer is ‘yes’.