Must refresher course completion certificates for lead-based paint abatement certification bear an expiration date?
No. The requirement that a completion certificate include an expiration date only applies to “interim certifications.” Refresher course completion certificates do not expire in the Federal program. Specifically, 40 CFR 745.225(e)(4) and (e)(5)(vi), in describing requirements for refresher courses, refer back to 40 CFR 745.225(c), the requirements for initial course programs. However, 40 CFR 745.225(c)(8)(iv), which states that course completion certificates must bear the interim certification expiration date, does not apply to refresher course completion certificates. “Interim certification,” as that term is defined in 40 CFR 745.223, describes the status of a person who has successfully completed a training course but who has not yet received formal certification from EPA. The term is not applicable to persons who have already been certified. Accordingly, there is no interim certification date to display on a refresher course completion certificate. Moreover, 40 CFR 745.226(e) states that a certified person must be re-certified by EPA every three years, or every five years, if the person’s initial course included a proficiency test. Unlike the interim certification, which allows a person to work for up to six months before being fully certified, a certification of a person who has already been certified will expire on the applicable anniversary date (three or five years), unless they have taken the refresher course and been re-certified prior to the expiration of their current certification. There is no provision allowing this deadline to be extended (or shortened) based on the completion date of a refresher course. Imprinting a refresher course completion certificate with an expiration date six months from the date the certificate is issued could mislead certified individuals into thinking that they have six months from the date they complete their refresher course to become re-certified regardless of when their certification expires. This is incorrect and may cause a person’s certification to lapse. In addition, such an expiration date could also be misleading because it implies that a certified person must take a refresher course no more than six months before his or her current certification expires. EPA has no such requirement. On the contrary, EPA recommends that refresher training be taken more than 18 months before an individual’s current certification expires.