U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics

INTERPRETIVE GUIDANCE FOR THE FEDERAL PROGRAM
TSCA SECTIONS 402/403

FINAL 12/11/06

Q/A(20) Refresher Training from Authorized Program
"Certification"

Q: For initial certification, the Federal program allows individuals to obtain
their training through either the Federal program or a Federally authorized
State or Tribal Program. When applying for recertification in the Federal
program, what types of accreditation are acceptable for refresher courses?

A: For the refresher training requirement, an individual can take courses that are
accredited by either the Federal program or an EPA-authorized State or Tribal
program. While the regulatory language regarding recertification does not specify
whether "accredited refresher training course" includes courses accredited by
EPA-authorized States and Territories, this interpretation is consistent with the
approach taken for initial certification, wherein a valid certificate from an
authorized State or Tribal program (see 745.226(a)(1)(ii)) is considered equivalent
to a certificate issued by a Federally accredited training provider.


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