RRP refresher certificate expiration: dates and deadlines

How long does each certificate last?

For a federal initial course completed on or after April 1, 2011, EPA says the certificate expires 5 years from course completion. Older certificates followed earlier dates: courses completed by March 31, 2010 expired on March 31, 2016, and courses completed between April 1, 2010 and March 31, 2011 expired 6 years after completion.

A refresher with hands-on training gives 5 years from the date of training. A refresher without hands-on training, such as an online course, gives 3 years. Section 745.90(a)(4) adds a limit: a person who takes the refresher without hands-on training must take a hands-on refresher the next time.

EPA describes this as hands-on learning every other time. Read the date on the actual certificate, and ask the accredited training provider if anything on it is unclear.

• Initial course: 8 hours, including 2 hours of hands-on learning.
• Refresher: 4 hours.
• Refresher with hands-on training: certified for 5 years.
• Refresher without hands-on training: certified for 3 years.
• After a refresher without hands-on training, the next one must include it.
• Expired: the 8-hour initial course must be taken again.

Worked examples

Dana completes the initial course on May 14, 2022. That certificate expires May 14, 2027. Dana books a hands-on refresher on April 3, 2027. EPA states the new certification lasts 5 years from the date of training, so plan around April 3, 2032, and confirm against the new certificate.

Luis has the same May 14, 2027 date but takes an online refresher on April 3, 2027. That certification lasts 3 years, so plan around April 3, 2030. Luis's next refresher must include hands-on training.

Sam misses the May 14, 2027 date and calls on May 20. EPA says the 8-hour course must be taken again to regain certification. Until Sam is certified again, the firm needs a different certified renovator assigned to any covered job. EPA measures a refresher's term from the date of training, so a course taken early can also pull the next expiration forward.

What happens if a certificate expires mid-job?

Section 745.89(d) makes the firm responsible for ensuring that a certified renovator is assigned to each renovation and carries out the duties in section 745.90. A certificate that expires while work is under way raises the question of who is filling that role from that date on. Assign another certified renovator, record the change and the date, and do not let a job continue with no one qualified in the role.

If you find a past job where the assigned renovator's certificate had already lapsed, do not edit the old record. Keep the original, note what you found, and ask your lawyer how to proceed. Add the check to your pre-start list so that it cannot repeat.

Set reminders that leave room to book a class

Classes fill up and travel takes planning, so choose reminders well before the date. A practical pattern is 180, 90, and 30 days. Check the planned job calendar too: a certificate that expires on July 1 is a problem for a job scheduled to run through July 10, even if it is valid on the start date.

Keep each person's initial certificate and most recent refresher certificate together. Section 745.90(b)(7) requires copies of both at the work site, so do not delete the old one when the new one arrives. Keep superseded certificates too, since the copy that applies to an older job may be needed for the record of that job. RRP Central keeps crew certificates connected to job records and sends due-date reminders; confirm the date against the certificate itself.

Questions contractors ask

Is firm certification the same deadline? No. A firm certification is separate and lasts up to 5 years. EPA's firm page says a complete recertification application is timely when it is submitted 90 days or more before expiration. A late application can leave the firm unable to do covered work until EPA approves it.

Do on-the-job trained workers need a refresher? EPA's inspection manual says workers trained on the job do not need to become certified and no refresher is required. The firm still needs records of their training.

Is an online refresher allowed? EPA allows accredited alternative training, and it describes the 3-year refresher without hands-on training. Use an accredited provider, which you can find with EPA's training search.

Does an EPA certificate work in every state? No. EPA says authorized states and Tribes run their own programs, and a certificate from EPA covers areas without an authorized program. Check the program before you schedule work across a state line.