Frequent Questions About Training Provider Accreditation Under the RRP Rule
Find answers to question on topics including how accredited training providers must structure and administer Renovation, Repair and Painting (RRP) Rule courses, principal instructors, guest instructors, language-specific courses, disability accommodations, exam requirements, training managers and refresher certification timing.
Teaching Renovator Training Courses
Do all renovation course instructors need to be approved as principal instructors? For example, to reach a 6:1 student-to-instructor ratio with 18 people in the class, may we have one principal instructor who teaches the entire lecture and is assisted by two additional hands-on instructors (who are not approved as principal instructors)?
Every accredited training program must employ a qualified training manager, and it is the job of the training manager to designate a qualified principal instructor for each course. The principal instructor is responsible for the organization of the course and oversees the teaching of all course material. The training manager may designate expert guest instructors as needed to provide instruction specific to the lecture, hands-on activities, or work practice components of a course. In this case, where the principal instructor will teach the entire course, qualified guest instructors may assist with the hands-on aspects of the course material.
Question Number: 23002-15092
Is it permissible for a training provider to employ more than one training manager?
Yes. The RRP Rule requires that a training provider employ a training manager that meets the qualifications in 40 CFR 745.225(c)(1). EPA does not interpret this to be a limitation on the permissible number of training managers. Therefore, a training provider may employ more than one training manager so long as each person meets all qualifications in 40 CFR 745.225(c)(1). An accredited training provider wishing to add an additional training manager can do so by amending their accreditation. Applying for accreditation and amending an accreditation to add a training manager is done online using CDX. Note that if information included in your most recent application to EPA changes, you have 90 days to amend your accreditation. If an amendment is not submitted within 90 days, you may not provide training until your accreditation is amended.
Question Number: 23002-32491
Exams & Student Accommodations
If a student in a renovator training course is unable to read and understand English, may the exam be read to them in their native language?
No. Separate course accreditations are required for each renovation course a training provider offers that is in a language other than English. Courses presented in a language other than English must use instructor manuals, exams and other course materials in that language that have been reviewed by EPA as part of the accreditation process for the course.
Question Number: 23002-18403
May renovator training providers provide reasonable accommodations to people with disabilities?
Yes. However, to pass the course an individual must successfully complete the hands-on skills assessment and receive a passing score on the course test.
Question Number: 23002-19568
May the renovator training provider give the exam orally?
Yes. There is no requirement that the course test be conducted in writing. Each individual must successfully complete the hands-on skills assessment and receive a passing score on the course test to pass any course.
Question Number: 23002-19573
I'm an accredited training provider. Can the final course assessment to be administered in an "open book" format?
No. The training provider is responsible for maintaining the validity and integrity of the course test to ensure that it accurately evaluates the trainee’s knowledge and retention of the course topics. A course test administered in an "open book" format does not evaluate whether a student has sufficiently learned and retained the information in the course.
Question Number: 23002-35003
Refresher Course Certification
If a renovator takes the refresher course early (i.e., before their previous certification has expired), would the new certification period be valid from the date of training, or from the date that the previous certification expires?
Renovator refresher training and recertification is valid for five years from the date of training for a course that includes hands-on training and three years for a course that does not include hands-on training. Note that individuals who take the renovator refresher without hands-on training must, for their next refresher course, take a refresher course that includes hands-on training to maintain renovator certification.
Question Number: 23002-35002