May I as a training provider issue a certificate without a picture to a trainee who has successfully completed the course but objects to having his or her picture taken (or objects to possessing a photograph of him/herself) on religious grounds?

Yes.  Training providers may provide a person who objects to having his or her picture taken because of sincerely held religious beliefs with the equivalent of a certificate without a picture.  Specifically, the training provider may provide an “Acknowledgement of Completion” that the person has successfully completed the training (containing all the information that a certificate would except for a picture).  EPA recommends that training providers include the phrase “photo exception” in the normal place for a picture.  Further, training providers should use special coding when assigning Part 5 of the unique certificate number.  See for example, R-I-56789-10-E0025.  Part 5 (“E0025” in the example) represents the unique number assigned by the trainer.  The number is sequential and will always begin with the letter E.  The first number E0001 should be assigned to the first “photo exception” student completing training in a given calendar year.  is More general information about creating unique identification numbers is included in the Instructions for Accredited Training Providers.

EPA further recommends that training providers document the trainee’s objection by having the trainee sign a statement containing the following: “My refusal to be photographed is grounded upon a sincerely held religious belief. I understand that if challenged, I may be found in noncompliance unless I can demonstrate the sincerity of my religious beliefs.”  Training providers should submit a copy of this statement to EPA in lieu of a photograph.  For anyone who can demonstrate that his or her refusal to be photographed is grounded upon a sincerely held religious belief this acknowledgement will be treated as the equivalent of a certificate. 

NOTE: Training providers may now use CDX to submit post-training notifications to EPA that contain the above-described numbering protocol.

Question Number: 23002-32128

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