UNDERSTANDING THE ASBESTOS EXPIRATION DATE
According to the EPA, if the certified asbestos individual allows the certificate to expire one year beyond the last day of his or her training the asbestos certified individual shall no longer perform response actions associated with asbestos. This applies to all initials and each refresher courses. The individual may only perform response actions to asbestos while the certificate is current.
For the first year after it is expired, the law provides a one-year "grace period". Once the certificate reaches the second year past the last day of his or her last training the certificate becomes completely null and void. After the second year the individual is no longer able to gain entry to a refresher course for asbestos and must take the initial course discipline over again in order to become accredited/certified again.
During the "grace period" or the 365 days following the expiration date, the participant may refresh the certificate at any time by attending a one-day refresher course provided by an EPA or an authorized state approved training provider. The grace period anticipates the certified asbestos individual leaving the asbestos industry and then rejoining the asbestos abatement industry within the grace year period. Hence, the day after the 2 year date is met, that is two years and one day after the last date of training, the certificate becomes null and void and may no longer be used to achieve a refresher course or renewal accreditation. In order to rejoin the industry the participant must start over by taking the initial course again.
Here is an example. Any asbestos course completed on lets say, August 18, 2000 would be valid to perform asbestos response actions until August 18, 2001. The period from August 18, 2001 to August 18, 2002 would be considered the one-year grace period. After August 18, 2002 the accreditation certificate is rendered non-renewable.
Though few, the anomaly or deviation from this normal or common rule are where the states licensing requirements are the submittal of the applicants entire training history. That is the submittal to the state of every certificate the applicant has beginning with the initial course and each concurrent annual refresher leading to the most current refresher. In the case of these states, they will not provide licensing to an applicant that has used the grace period rule. That is to say that any asbestos certified individual that allows their certificate to lapse past the one year expiration date chances not being able to license in one of these states. You never know where that next big contract will be so keep your certificates current.
UNDERSTANDING THE LEAD-BASED PAINT EXPIRATION DATE
With the Lead-based Paint disciplines we consider three "expiration" dates. What follows describes each one.
Interim Period - 6 Month date set by EPA - According to EPA this sets the interim period for the licensee to work on until you get the license.
OSHA Annual - 1 Year set by OSHA - According to OSHA you must to have annual training if you use Personal Protective Equipment.
Sunset Date - 3 Years set by EPA - According to the EPA the cert only is good for 3 years for use in HUD or child occupied housing.
The Interim period is from the last day of the course to exactly six months after the last date of the training course. This time is designed as a period where the individual can work in Lead while waiting for your Federal or State license to arrive in the mail.
The OSHA Annual date meets the OSHA requirement for annual training if you wear a respirator.
The Sunset Date applies to the last possible date for refresher course eligibility.
UNDERSTANDING THE MOLD EXPIRATION DATE
With Mold, today most governments are busy working to nut and bolt together legislation to serve the needs of everyone involved with mold problem. The existing laws are mainly for damage liability caps for the insurance and real estate companies and landlord disclosure. Today, Texas and California have training and licensing requirements in place. Future regulations are currently proposed for remediation and consultant registration, conflict of interest rules, licensing and training requirements.
As for the expiration dates on OUR Mold certificates the are required to be refreshed annually.
To sum it all up, the difference between Lead-based Paint and Asbestos is this. With ASBESTOS certification you can only work for one year at a time. From the last day of the course forward for one year. At the end of that year you need your refresher course to continue working. If you don't refresh by the end of the first year you can't work but you have one year to get to a refresher course (the grace period). At the end of the second year the asbestos certificate is null and void and you have to start over.
With LEAD certification the certificate expires when the license expires (no grace period). You refresh before the license expires and apply for your next license before the first one expires. In order to continue working, when the license expires you should have already received your new license. We encourage you to get refreshed and apply early for your license. It's not like the Asbestos certificates where you have a one-year grace period after the expiration date on the certificate. With Lead certificates once you reach the license expiration date the validity of the certificate sunsets. Here is where it gets tricky. For those states WITHOUT Lead-based Paint programs you will need a Federal U. S. EPA license. For US EPA licensing information CLICK HERE. The Federal license expires every three years. For those states WITH Lead-based Paint programs CLICK HERE. State licensing expiration differs from state to state. You must stay on top of this particularly if you work in multiple states.
Were not done yet! Here is another confusing state. I mean confusing issue. It's state reciprocity. Reciprocity is a condition that only exists between some states, not all. Reciprocity is one state's willingness (by regulation) to accept a training certificate for licensing from a training provider approved by the US EPA or another state with approval authority, but is not approved specifically by that state's government. CLICK HERE for a short explanation of reciprocity.
Again whenever in doubt use the links above to contact the US EPA or the State(s) you plan to work in. When all else fails call us at 1-800-966-9933 . We can usually be of service in getting you back on the job.