What about subs? Will subs need their own entity and certification of their own firm, along with the training?
I sure hope so.
Thanks for all the info.
From the EPA Frequently Asked Questions ....
Question
My firm performs renovations covered by the RRP rule, but solely in the capacity of a subcontractor. If the general contractor is a certified firm, does my firm also have to be certified, or can we just provide the
certified renovator?
Answer
All firms performing, offering, or claiming to perform renovations covered by the RRP rule must be certified. In this case, both the general contractor and subcontractor must become certified firms.
end of FAQ
The sub has to be a Lead Safe Certified Firm according to the above, but the sub doesn't have to have the 8 hour course and be a Certified Renovator. The GC can provide the Certified Renovator in theory.
However, you get into the IRS area, where a sub is an independent contractor and can't be told what or how to do the job. So in a way, the Certified Renovator can't tell the sub what to do. Although

, I guess it could be written up in a contract (with the sub) that certain EPA compliances have to be done. Starts getting gray.