RRP Training Regulations


    A training program shall not provide, offer, or claim to provide accredited training courses without applying for and receiving accreditation from the state as required in this Rule. (Authorized states require certain wording to appear on all advertising.  In addition, it is illegal for you to make it appear that you are approved.  Only Seagull is approved.  Thus, you may offer the training, but somewhere in the offer, it must state that all courses are sponsored by Seagull.  Seagull requires that all solicitations be approved by Seagull in writing.)

    Training courses shall be evaluated for course administration, course length, curriculum, training methods, instructor’s qualifications, instructor’s teaching effectiveness, technical accuracy of written materials and instruction, examination, and training certificate. The evaluation shall be conducted in accordance with the requirements set forth in this Rule and any documented methodologies referenced herein. (In other words, you may be subjected to a surprise audit. Don’t worry!  Most providers are audited for course content.  Our content is the EPA model with a few state variations added.  The content cannot be wrong as long as you play it.  There will be additional auditing of your paperwork and records.  Good News!  Seagull maintains all records and archives.  This is why Seagull developed software that insures all recordkeeping.  As long as you follow the course checklist, you will do fine in an audit.  Refer all audit questions to Seagull.  This will not be a problem as our computers have teleconferencing capabilities for which we make very heavy use.)

    Training programs shall permit the EPA or authorized states to attend, evaluate and monitor any training course, take the course test and have access to records of training courses without charge or hindrance to the government for the purpose of evaluating compliance with the Rules. The government will perform periodic and unannounced on-site audits of training courses.  (See what happened to one of our competitors during one of these audits by clicking here.)

    The training manager (James F. Stump) shall designate a qualified principal instructor (possibly you) for each course who has:

  1. (i)Demonstrated experience, education, or training in teaching workers or adults; and

  1. (ii)Successfully completed a lead training course from an accredited training program specific to the discipline(s) in which the instructor intends to teach, with a minimum of sixteen (16) training hours  (Seagull can provide this training).

(iii) Demonstrated two (2) years of experience, education, or training in lead or asbestos abatement, painting, carpentry, renovation, remodeling, occupational safety and health, or industrial hygiene.

    The training program shall ensure the availability of, and provide adequate facilities for, the delivery of the lecture, course test, hands-on training, and assessment activities. This includes providing training equipment that reflects current work practices and maintaining or updating the equipment and facilities as needed.  (Much of this is handled by Seagull.)

    The training manager shall be responsible for ensuring that the instructors accurately teach the training course curriculum that was accredited by the Division. (The Seagull computer presentation system and Seagull participation and auditing all help insure this is followed.)

    For each training course offered, the training program shall conduct a hands-on skills assessment and a closed book course test at the completion of the training course. (Following the Seagull hands-on videos & checklists helps insure compliance.  The supplied hands-on materials and supplies are all numbered and color coded corresponding to the videos making compliance and great training simple.  The exam is given online and self grades allowing the student to review his right and wrong answers.  No need to worry about exam security.  Each exam is different.)

    For successful completion of the training course, each student shall attend at least ninety-five percent (95%) of the training course, successfully complete the hands-on skills assessment, and receive a passing score of seventy percent (70%) or greater on the course test. (Must be military and by-the-clock).

    Passing students shall be provided with a course completion certificate from the training program.  (Seagull handles this automatically.  The certificates are printed at your location on a Seagull printer.)

    The training manager is responsible for maintaining the validity and integrity of the hands-on skills assessment to ensure that it accurately evaluates the trainee’s performance of the work practices and procedures associated with the course topics contained in the course. (This is one reason Seagull insists that there is an operational connection to your classroom and hands-on area by Facetime, iChat or Skype connections.  Hands-on is generally achieved in the same room as training.  It is sized down since our classes are smaller.)

    The training manager is responsible for maintaining the validity and integrity of the course test to ensure that it accurately evaluates the trainees’ knowledge and retention of the course topics. (This is all handled online.)


    The course test shall be developed in accordance with the test blueprint.

(Previously provided to approving entity by Seagull.)

All course tests shall consist of a minimum of 25 multiple choice questions.

    The training manager shall develop and implement the quality control plan. The plan shall be used to maintain and improve the quality of the training program over time. This plan shall contain at least the following elements:

(i) Procedures for periodic revision of training materials and the course test to reflect innovations in the field; and

(ii) Procedures for the training manager’s annual review of the principal instructor’s competency.

    The training program shall ensure that the following quality control measures are met:

  1. (i)The instructor(s) shall follow the training curriculum which was accredited;

(This is handled by the videos and software)

  1. (ii)Each initial training course shall have a maximum of forty (40) students;

  1. (iii)A day of training shall be a minimum of eight (8) hours a day and at least six and one-half (6 1/2) hours of direct instruction, including classroom, hands-on training or field trips, except for the refresher renovator training course courses; (Cannot release students early, even in emergencies, If the student leaves early, they must complete, not only the curriculum, but the time requirements before certification.)

  1. (iv)Student At-Work time and instruction time shall not exceed twelve (12) hours in a twenty-four (24) -hour period;

  1. (v)All course requirements must be completed within a two-week period of the course start date;

  2. (vi)All instructors and students shall be fluent in the language in which the course is being taught  (In Seagull’s case, English Only.  If there is a question upon student arrival, Seagull has an online test available to determine the students ability to understand English which is given before the student and trainer invest their time).

  1. (vii)An interpreter shall not be used to teach or instruct training courses;

  1. (viii)Lead renovator initial training courses shall have at least one (1) principal instructor. (Seagull students must alway have immediate access to a Principal Instructor, but the instructor need not be in the classroom during computer portions of the class.)

  1. (ix)Instructor ratio for hands-on training skills assessment shall be no more than ten (10) students per instructor;

(x) All course materials shall be developed in the language for which the course is being taught; (English.)

  1. (xii)Students shall take a course test no more than two (2) times for each training course. After two (2) failures, the student shall retake the full course before being allowed to retest;

  1. (xiii)Instructors shall not review for the course test by reading questions from the test;  (Seagull’s review is presented by video.)

  1. (xiv)A training program shall provide course test security measures to prevent student access to the course test before and after the test. Training programs shall take measures to preclude cheating during the course test; and (The exam is given in the classrom, but online.)

(xv) For each training course, the training program shall verify, by photo identification, the identity of each person taking the training course.  (Very important!  Contractors tend to delegate their tasks.  Be sure you know who you are training.)

    At the conclusion of all training courses, the training program shall make available copies of the state rules and state certification applications to all course attendees.  (This will vary by state.  Inquire with Jim Stump, james.seagull@me.com,  for hand-out requirements where you train.)

Minimum Requirements for Training Program Notification and Recordkeeping.

Accredited training programs shall submit the following:

1. Notice of intention to conduct an accredited training course for lead accreditation and renovation certification purposes shall be submitted to the accrediting entity. (All authorized states and EPA.)  Notice for lead worker and renovator training courses shall be postmarked or received by the authorized state or EPA,  ten (10) working days before the training course start date. If the training course is canceled, the training program shall notify at least one (1) working day prior to the scheduled start date.  (Seagull is in an odd situation.  The rules were made thinking of periodic classes, not everyday or every week.  (This is handled by Seagull.)  

  1. 2.A course roster must be submitted to the Division no later than five (5) working days after the last day of training. The course roster must be provided on forms provided by or acceptable to the Division and must contain the name of every person who attended the training course, regardless of including whether the person was issued a training certificate or not.  (This is handled by Seagull from the student registration and the online exam.  All the onsite trainer or facilitator need do is insure that the student is registered on Seagull’s onsite computer by 10:00AM in the time zone where the training occurs.)

Beyond being profitable, Seagull has two goals:

  1. 1.Do a great job of training!

  2. 2.Obey all related training regulations.

No matter how well a trainer has trained, if a regulation is broken, the training and reputation of the trainer is ruined.  See our competitor (CLICK HERE).

Therefor, being a great trainer begins with training regulations, not the trainer’s knowledge of the subject to be trained:

Understanding RRP training regulations:

EPA creates regulations and then invites states to create their own that are at least as stringent as EPA’s.  Historically, some states do and some don’t.  Those that do tend to change the regulation making it more strict.

Generally, training providers must apply to EPA and each EPA authorized state where they intend their students to be able to legally work without repeating the course.  When approved by a state, the provider pledges that when that state is presented with a certificate of training for state certification, that the training followed their rules.  As an example, the EPA regulation requires training providers to issue and register individual certifications, but many states require the individual to, once trained, apply for to the state fro individual state certification.

Therefor, as a Seagull trainer, you must obey the most stringent rules of all of the authorized states on any subject.

While not perfect, the following rules are the minimum that Seagull and its trainers must follow to maintain our multi-state “approval or acceptance”.

The first thing one needs to understand is “approval or acceptance”.  A training provider is approved if they apply directly to a state or federal agency and receive “approval”.

There are EPA authorized states that have their own programs, but still accept EPA approved training, as long as it does not occur within their state boarders.

Thus, Seagull has not applied to every authorized state program.  But, for now, training in the states that we do, Seagull students are “accepted” in almost all states without re-training. 

Never say, “Seagull is approved in all 50 states”. Always say, “Accepted or approved in most states.”

Many EPA authorized states do not accept EPA approved training, but the good news is that EPA accepts all EPA authorized state training without the student having to apply to any state program or EPA for certification.  In other words, EPA accepts the authorized state training certioficate issued by Seagull as an individuals EPA  certification.  Here is the EPA regulation:

§745.90   Renovator certification and dust sampling technician certification.

  1. (a) Renovator certification and dust sampling technician certification.

    (1) To become a certified renovator or certified dust sampling technician, an individual must successfully complete the appropriate course accredited by EPA under §745.225 or by a State or Tribal program that is authorized under subpart Q of this part. The course completion certificate serves as proof of certification.

Thus, the most logical path is to issue authorized state certificates to gain universal acceptance.  For a long time, this has not been understood by our nations trainers.  Beginning in the third quarter of 2016, Seagull will no longer conduct EPA approved training favoring authorized state approved training.

The following is a merge of the most stringent authorized state regulations, it is by no means complete: