EPA Lead-Safe Certified Firm Logo Use Guidelines

Guidelines for use of the Certified Firm Logo provided by EPA must be followed to avoid fines.   Reading and understanding the following information can help make sure you are in compliance if you plan to use the firm logo on your vehicles, signage and or any marketing you do.

What is the Lead-Safe Certified Firm Logo?

The Lead-Safe Certified Firm Logo identifies a firm as certified under the Renovation, Repair, and Painting (RRP) Rule. The colors used to make the two-color logo are Pantone 362C (green) and Pantone 660C (blue). The font is Helvetica.

What are the guidelines for using the Logo?

The Logo must be reproduced so that all of its components are legible and includes your firm's certification number. The Logo must not be altered or distorted in any way.

You MAY --

• Use the Logo to identify your firm as an RRP-certified firm. Firms that are not RRP-certified may not use the Logo.
• Use the Logo in brochures, advertisements, Web sites, proposals, bills, signs, uniforms, vehicles and other materials promoting or identifying your firm.
• Use the Logo on documents or other materials in black and white or color (two-color or four-color versions are available).

You MAY NOT --

• Use the Logo in any manner that would imply EPA endorsement of a company, its products or services.
• Reduce the Logo to a size smaller than one inch wide by 0.687 inches in height.
• Allow a firm that is not RRP-certified (including your subcontractors) to use the Logo.

EPA will monitor the use of all Logos. If necessary, EPA will address failure to comply with these Logo Guidelines. To report a non-compliant use of the Logo, please contact EPA at 1-800-424-LEAD.

EPA will e-mail information regarding your custom Logo to the e-mail address listed on your firm certification application.

For further questions regarding your EPA Lead-Safe Certified firm Logo, please send an email to: EPARRPFirmLogo@battelle.org or send a fax to: (202) 566-0470. In your email/fax please include your EPA Firm Certification number (e.g., NAT-12345-1), Application ID (e.g., 12345), firm name, and firm mailing address.

EPA Lead-Safe Certified Firm Logo - Information for Training Providers

Accredited training providers may use the Logo on their site and marketing materials as long as it is used as a tool to guide renovators through the firm certification process (i.e., explain the difference between firm certification and individual training). Training providers may inform students that only certified firms will be provided a customized Logo exclusively for their use to advertise their businesses once their firm has been certified. Training providers may distribute the Logo only to principal instructors affiliated with the accredited provider, and only for the purpose of training as described above. Training providers may NOT distribute the Logo to unaffiliated entities. Upon request, EPA will provide to accredited training provider the Logo for their use. Requests can be made to the National Lead Information Center at 1-800-424-LEAD.

Principal instructors that advertise, provide training, and use the Logo must do so under the name of the accredited training provider for whom they work. They may also state that the organization that employs them, if different from the accredited training provider, is assisting with the training.

Information for Press and Marketing Entities

Press and other marketing entities may use the logo on their site and marketing materials provided it does not include a certification number. They may NOT:

• Distribute or provide a downloadable version of the logo
• Indicate association, endorsement or approval from EPA
• Imply lead-safe certification from EPA or any EPA-authorized state.

Upon request, EPA will provide the logo for use.

Note: The information shown above is from the EPA web site.   EPA has already and may again revise these guidelines.  Use this link to find the most recent info at the EPA web site.

Contact Information for EPA and EPA Regional Offices

The organized links below will bring you to specific web pages for the EPA main office as well as the 10 EPA regional offices around the country. This information can be used by Certified Renovators and Certified Firms to contact EPA regarding questions about the RRP Rule and to report RRP Violations.

The information on and the format of each page varies.   Some of the information found on the various pages may include:

• Contact information
• Office address locations
• Links to access  FAQ databases and to ask questions
• Policy information
• Forms for reporting violations
• Employee directories
• Media contacts
• Ability to report web site issues
• TTY Numbers for the Hearing Impaired
• Individual state environmental agency contact information

EPA Contact information:

EPA Main Contact Page

EPA Staff Directory by name and location

Region 1 - Boston

Region 2 - New York City

Region 3 - Philadelphia

Region 4 - Atlanta

Region 5 - Chicago

Region 6 - Dallas

Region 7 - Kansas City

Region 8 - Denver

Region 9 - San Francisco

Region 10 - Seattle

Directions to EPA Offices:

Get directions to EPA headquarters

Get directions to regional offices

What You Don’t Know About Respirators and Probably Would Rather Not Know

On December 2nd I attended an RRP/OSHA Respiratory and Worker Protection Workshop put on by The Contractor Coaching Partnership and Safety Trainers.   The workshop was really helpful for me.  It helped me tie together some of my open questions and concerns regarding OSHA requirements and compliance as they relate to RRP related work activities for employees.

While at the workshop I found one thing the main instructor Darcy Cook of Safety Trainers said to be very important for contractors to be aware of.   Under the OSHA Lead in Construction Standard, contractors must assume their employees will be exposed to lead above OSHA’s established action level requiring the use of respirators until they actually conduct air monitoring testing to prove otherwise.

This means that respirators must be worn while doing RRP work until the testing is done and a written respirator plan is put in place that details when a respirator is required and when it is not.   Engineering controls can be used to limit the creation and or spread of lead dust while work is performed.  The requirement to wear the respirator or not all depends on the kind of work being done as well as how the work is performed. 

For example; the sanding of painted surfaces.  If dry hand sanding is done, a respirator will definitely be required.   If wet sanding is done a respirator may not be required.  If the sanding is being done using a sander attached to a functioning HEPA Vac that captures all sanding dust, a respirator is probably not required.   The previous sentence is qualified with “may” and “probably not” on purpose.  The only way to know if a respirator is required or not is to monitor the air for lead dust while the work is actually being performed.

The chart below is from the EPA Certified Renovator Manual.  The chart shows exposure levels of airborne leaded dust for some common renovation activities.   OSHA’s permissible exposure limit (PEL) for workers is 50 Micrograms per centimeter squared (50 µg/m3).   If exposed over the PEL, workers must wear respirators.  All three activities in the chart exceed the PEL.

So, under OSHA requirements, before allowing them to do RRP related work or even enter a contained work area, employees must first be sent to a physician to be sure they are healthy enough to wear a respirator. Then they must be fit tested by a professional and provided with a properly fitted respirator that protects them from worst case lead exposure scenarios based on the kind of work they do. They must also be trained how to select, use, clean and store a respirator.   And, they must wear the respirator until the air monitoring testing is done to identify when a respirator is required and when it is not depending on how the work is performed and what engineering controls are being used.

Although these OSHA requirements are not new, the majority of residential contractors are not aware of them.  Unfortunately, ignorance of the requirements will not be an excuse if OSHA inspects one of your projects and or one of your employees is poisoned by lead.   Perhaps it would have been helpful if EPA had included the above information in the required eight hour certified renovator training when showing the chart above.

Click here for more information about Personal Protection Equipment (PPE) required for RRP work

Click here for more about what you need to know about Respirators when doing EPA RRP work

Click here for OSHA standards for cleaning a respirator

EPA Decides RRP Trainers Can Use Either Test Kit at RRP Training Classes

Through my fellow NARI member contacts I have learned that on November 5, 2010, at their offices in Washington DC, the NAHB hosted a meeting with the EPA to discuss the RRP rule.   Several industry trade associations, including NARI, were in attendance at the meeting.  Also in attendance were representatives from Hybrivet Systems, Inc. and ESCA Tech, Inc. 

Hybrivet Systems, Inc. and ESCA Tech, Inc. are the manufacturers of the only two commercially available Lead Test Kits approved by EPA for use on RRP regulated renovations. Hybrivet Systems, Inc. manufactures and distributes the Lead Check test kit.  ESCA Tech, Inc. manufactures and distributes the D-Lead Test kit.  The D-Lead test kit was only recently approved for RRP use.  The Lead Check Kit has been approved since before the RRP rule came into effect on April 22, 2010.

At the meeting a representative from ESCA Tech, Inc asked the EPA when it was going to require that RRP training instructors demonstrate the proper use of both of the currently approved lead test kits at the EPA required Certified Renovator Training Classes.  EPA responded that they were not going to require training on both kits and instructors could decide which kit they would demonstrate at the training. 

I am an approved Certified Renovator Instructor for Massachusetts and EPA.  I and several other instructors had submitted this same question to EPA a few weeks back.   Although we still have not heard anything back from EPA, it is good that EPA has clarified this for instructors.  I hope the EPA will get this clarification out to all instructors soon.

Here is just one reason I will go with the Lead Check kits when I do RRP training.  Using the D-Lead kits will definitely take longer than using the Lead Check kits.  The certified renovator classes at eight hours long make for a long day and it is tough enough already for instructors to cover the subject matter in those eight hours.  Demonstrating and using the D-Lead kits would either cause the class to go past eight hours, or time spent on other topics would need to be cut back to keep the day at eight hours.  I know the students would rather not extend the day and I would prefer not to cut back on or eliminate any of the required subject matter.

Given the choice, I will definitely use the Lead Check Swabs in my training classes.  The main reasons for my decision, in addition to my concerns about the length of the training day, are ease of use and safety.  However, I suggest RRP certified renovator instructors decide for themselves which test kit they will use in their training classes. The same goes for renovators who plan to use test kits on RRP projects.   Both kits offer accurate testing, but both follow different protocol for testing and they both also have limitations or advantages depending on the surface or product to be tested. 

For more on the differences between the two EPA approved test kits see: Choosing Between EPA Approved Test Kits.

For written and video instructions for both test kits see: EPA Approved Lead Test Kit Instructions