Guide · EPA & state Lead-Safe (RRP) firm certification

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FEDERAL VS. STATE FILING

EPA-Administered vs. State-Run RRP Programs: Which Applies to You?

Fifteen states run their own RRP program, and firms there certify with the state agency. Every other state, Washington D.C., and the U.S. territories are EPA-administered, so firms there certify with the EPA through the federal Central Data Exchange (CDX) system. The 15 state-run states are Alabama, Delaware, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oklahoma, Oregon, Rhode Island, Utah, Vermont, Washington, and Wisconsin. If your state is not on that list, you certify with the EPA.

Find your state on one of those two lists and you know where to file. The rule itself is the same federal standard everywhere (it comes from the Toxic Substances Control Act), but the agency you apply to, the fee, the form, and the renewal cycle change depending on which list you land on. If your work is in an EPA-administered state, or in North Carolina, Wisconsin, Delaware, or Washington, you can start your filing at LeadSafeFiling.com and we will prepare and submit it for you.

The one fact that decides where you file

The RRP Rule is federal. The EPA wrote it under the Toxic Substances Control Act, and it applies in all 50 states. What changes from state to state is who issues your firm certification and who enforces the rule.

The EPA lets a state take over administration of the rule if the state adopts a program at least as protective as the federal one. When a state does that and the EPA signs off, it becomes an authorized or state-run program, and firms working there certify with the state instead of the EPA. States that have not taken that step are EPA-administered: the EPA processes applications, issues certifications, and handles enforcement through its regional offices.

Most of the country is EPA-administered. Only 15 states run their own program, so the default answer for most contractors is that you certify with the EPA. This is a separate question from individual renovator training: either way, your firm still needs at least one Certified Renovator, a person who completed an accredited 8-hour course. Firm certification is the company credential, and this page is about where that company credential gets filed.

EPA-administered vs. state-run at a glance

Here is the practical difference between the two paths, side by side:

  • Who issues it: EPA-administered states file with the EPA; state-run states file with the state agency.
  • Where you apply: EPA-administered states use the federal CDX system; state-run states use the state's own process or portal.
  • Government fee: the EPA firm fee is $300; state fees vary by program.
  • Term: EPA certification lasts five years; state terms range from annual (North Carolina) to four or five years.
  • Coverage: one EPA certification covers your firm across every EPA-administered state; a state certification covers only that state.
  • Safety standard: identical, because an authorized state program must be at least as protective as the federal RRP Rule.

The 15 state-run RRP programs

These states are authorized by the EPA to administer the RRP Rule themselves. If your firm performs covered work in one of them, you apply to the state agency, pay the state's fee, and follow the state's renewal schedule. The federal CDX system does not apply to you for that state.

The full list of authorized state-run RRP programs:

  • Alabama
  • Delaware
  • Georgia
  • Iowa
  • Kansas
  • Massachusetts
  • Mississippi
  • North Carolina
  • Oklahoma
  • Oregon
  • Rhode Island
  • Utah
  • Vermont
  • Washington
  • Wisconsin

EPA-administered states (everyone else)

If your state is not one of the 15 above, your firm certifies with the EPA. That includes large states like California, Florida, New York, Texas, Pennsylvania, Ohio, Illinois, Michigan, New Jersey, and Virginia, plus Washington D.C. and the U.S. territories. In every one of these jurisdictions the path is the same: an application through the EPA Central Data Exchange (CDX) system, the $300 federal fee, and a five-year certification term.

One EPA certification covers your firm in any EPA-administered state, not just the state where you are based. A firm certified with the EPA can legally perform covered RRP work across the entire EPA-administered group without filing again at each state line.

Quick markers of the EPA-administered path:

  • You apply through the EPA CDX system, not a state portal
  • The EPA firm certification fee is $300
  • Certification is valid for five years before renewal
  • One EPA certification covers your firm across all EPA-administered states

State-run does not mean a harder or weaker certification

A state-run program is not a tougher credential than the EPA one, and it is not a lesser one. To earn EPA authorization, a state program must be at least as protective as the federal RRP Rule, so the core safety requirements (the lead-safe work practices, the containment and cleanup methods, the recordkeeping) match the federal standard. What differs is administrative: the form, the fee amount, the processing office, and how long the certification lasts before renewal.

Those administrative differences are real. North Carolina certifications renew every year, Wisconsin runs on a four-year cycle, and Delaware and Washington run up to five years, while the EPA term is a flat five years. Fees also vary by state. The certification is equally valid either way; it is issued by a different authority and kept current on a different calendar.

How to confirm which program applies to you

Your program is driven by where the work physically happens, not where your business is registered. A contractor based in an EPA-administered state who takes a job across the line in a state-run state generally needs that state's certification for that job, and the reverse holds too. Firms that operate across multiple states sometimes carry an EPA certification plus one or more state certifications.

To confirm your situation:

  • Check whether each state you work in appears on the 15-state list above. If it does, that state runs its own program; if it does not, it is EPA-administered.
  • Map it to where you actually perform covered work, not just your home office address.
  • If you cross between an EPA-administered state and a state-run state, expect to carry certification on both sides.
  • Confirm you even need certification: it is triggered by paid renovation, repair, or painting that disturbs more than 6 square feet of interior paint, more than 20 square feet of exterior paint, or any window, in housing or child-occupied facilities built before 1978.

What this means for filing, and where LeadSafeFiling.com fits

LeadSafeFiling.com prepares and files firm certification for the EPA-administered path (all EPA states, filed through the CDX system) and for four of the state-run programs directly: North Carolina, Wisconsin, Delaware, and Washington. Pricing is a flat $129 service fee plus the government filing fee, itemized separately and never marked up. All-in totals are $429 for EPA-administered states, $429 for North Carolina, $429 for Delaware, $379 for Wisconsin, and $154 for Washington.

The other 11 state-run programs (Alabama, Georgia, Iowa, Kansas, Massachusetts, Mississippi, Oklahoma, Oregon, Rhode Island, Utah, and Vermont) are administered directly by those states, so firms there file with the state agency. If your work is in an EPA-administered state or in North Carolina, Wisconsin, Delaware, or Washington, you can start your filing at LeadSafeFiling.com and have it prepared, submitted, and tracked to issuance. No Social Security number is ever required.

Getting this right matters: a firm must be certified before it advertises for or performs covered work, and federal penalties for the RRP Rule reach up to $37,500 per violation, per day. Identifying your correct program is the first step, and filing in the right place is the second. Start your filing at LeadSafeFiling.com and we will handle the paperwork on the path that applies to you.

Frequently asked questions

Which states run their own RRP program instead of the EPA?

Fifteen states run their own EPA-authorized RRP program: Alabama, Delaware, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oklahoma, Oregon, Rhode Island, Utah, Vermont, Washington, and Wisconsin. Firms in those states certify with the state agency rather than the EPA.

Do I certify with the EPA or with my state?

If your state is one of the 15 authorized state-run programs, you certify with that state. If it is not on that list, you certify with the EPA through the federal CDX system. The decision follows where you perform the work, so a firm working in multiple states may need both.

How do I know if my state is authorized for RRP?

Check the list of 15 authorized states: Alabama, Delaware, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oklahoma, Oregon, Rhode Island, Utah, Vermont, Washington, and Wisconsin. If your state appears, it runs its own program. If not, the EPA administers RRP there.

What is an EPA-administered state?

An EPA-administered state is one where the EPA runs the RRP program directly: it processes firm certification applications, issues the certifications, and handles enforcement. Most states are EPA-administered. Firms apply through the EPA CDX system, the fee is $300, and certification lasts five years.

Is Texas, California, Florida, or New York EPA-administered or state-run?

All four are EPA-administered. None of them appears on the list of 15 authorized states, so firms in Texas, California, Florida, and New York certify with the EPA through the CDX system for a $300 federal fee and a five-year term.

If I am certified with the EPA, can I work in any EPA-administered state?

Yes. One EPA firm certification covers your firm across all EPA-administered states, not just the one where you are based. You would only need a separate state certification if your work takes you into one of the 15 state-run programs.

Is the certification different in state-run programs?

The safety standard is the same, because an authorized state program must be at least as protective as the federal RRP Rule. What differs is administrative: the issuing agency, the fee amount, the application form, and the renewal cycle. The credential is equally valid either way.

Does my firm still need a Certified Renovator either way?

Yes. Firm certification is the company credential and is separate from the individual Certified Renovator credential, which requires an accredited 8-hour course. Both EPA-administered and state-run programs expect your firm to have a Certified Renovator available for covered jobs.

Can LeadSafeFiling.com file in any of the state-run states?

LeadSafeFiling.com files the EPA-administered path plus four state-run programs directly: North Carolina, Wisconsin, Delaware, and Washington. The other 11 authorized states administer their own programs, where firms file with the state agency. You can start a filing for the EPA path or for NC, WI, DE, or WA at LeadSafeFiling.com.

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