The RRP Rule Extended Deadlines have Passed….Watch out for Enforcement!

The RRP Rule Extended Deadlines have Officially Passed!  Do NOT Be One of the Contractors who Gets Fined by the EPA

By Scott von Gonten, CGA, CGP, CR, CDST

Well, both of EPA’s Renovation, Repair, and Painting Rule (RRP Rule) Extended Deadlines have now officially passed and the EPA can now actively fine contractors and contracting companies for violations…and they will. 

What deadlines have passed?  How long do you have to worry about getting caught and fined?  What should you be doing?  What can you do to protect yourself from being fined? 

“Certified Renovator” Training Deadline:  All contractors and sub-contractors (persons) had until December 31, 2010 to successfully complete the 8-hour “Certified Renovator” Training, which is valid for five years.  All persons working on Pre-1978 target housing or child-occupied facilities must either be a Certified Renovator or be trained by a Certified Renovator, and follow Lead-Safe Work Practices, unless it has been proved that there is no lead-based paint present.

“Certified Firm” Approval Deadline:  All contracting companies (firms) had until October 1, 2010 to receive an approval of their “Certified Firm” application from the EPA, which is valid for five years.  Any companies that are, or have been, working on Pre-1978 target housing or child-occupied facilities, without being an approved Certified Firm, as listed on the EPA’s website, are in violation of the RRP Rule and could be fined up to $37,500.00 per violation per day.

Remember, these extended deadlines did not delay following the RRP Rule’s Lead-Safe Work Practices on the jobsites, which went into enforcement on April 22, 2010.  Now that these two “extended deadlines” have passed, the EPA has the green light to begin fining contracting firms and contractors for RRP Rule violations. 

Remember, the EPA RRP Rule program is self-funded through fines and fees, so the EPA is motivated to find violators and has 3 years after the renovation projects are completed to audit your records!  Think about it:  If we can pull public records of permits, what access does the EPA have?

Here are some questions for you to carefully consider:

  • Did you send your “Certified Firm Application” to the EPA, along with the required payment, and receive your approval already?
  • Did you and your Project Managers successfully complete an EPA-approved 8-Hour Certified Renovator Training Course already?
  • Have you been very carefully following ALL of the Lead-Safe Work Practices, required by the RRP Rule, on all of your renovation projects, in target housing and child-occupied facilities, which were originally built before 1978?
  • Have you been training your co-workers in Lead-Safe Work Practices and keeping the proper training documentation?
  • Are ALL of your Sub-Contractors already approved as Certified Firms?
  • Have you been delivering the Renovate Right Pamphlets to the necessary people BEFORE starting your renovations?
  • Have you been testing ALL of the components in your Pre-1978 projects for Lead-Based Paint?
  • Have you been keeping all of the required renovation records to protect yourself from 3 Years of EPA audits? 
  • Have you been providing the necessary people your completed Post Renovation Reports, within the required time frame, AFTER your renovations are completed?


These are very important questions, ALL of which must be answered with a “YES,” in order for you to be compliant with the EPA’s RRP Rule. If you answered “NO” to ANY of these questions you are exposed to HUGE liability and are risking your business, as well as the safety of yourself, your clients, and your co-workers.

What You can do to Minimize Your Risk of EPA RRP Rule Violations

Complete Your Certified Renovator 8-Hour Training Class:

Although the EPA’s extended deadline of December 31, 2010, for individual contractors and project managers to successfully complete an EPA-accredited 8-Hour Certified Renovator Training class has passed, it is crucial for you to take the training right away.

If you have not yet completed the Certified Renovator Training class, please call (713) 213-1205, or go to to register for a class as soon as possible.

Complete Your “Certified Firm” Application:

Although the EPA’s extended deadline of October 1, 2010, for contracting companies to have received approval as “Certified Firms” from the EPA has passed, it is essential that you process your application as soon as humanly possible.

If you have not completed and mailed your Certified Firm Application, please call (713) 213-1205, or go to to get the link directly to the appropriate EPA web page.   

The EPA keeps an updated list of all approved Certified Firms on the website so consumers can make sure their contractor is following the law.  You can check the status of your application approval on that web site.

Call for the Real Facts about the RRP Rule

There is so much confusion about the RRP Rule.  If you need factual information about the RRP Rule from a contractor’s perspective, please call (713) 213-1205, or go to  For the sake of your own, your co-workers’, your clients’, and your business’ health and prosperity, call at any time for RRP Rule clarification or helpful suggestions.  We are here to help.

About the Author
Scott von Gonten, CGA, CGP, CR, CDST, provides Consulting Services as well as the most accurate, effective, and memorable Certified Renovator Training and Certified Dust Sampling Technician Training available. ConserveIQ is partnering with the National Center for Healthy Housing, an EPA-accredited training provider, to present Certified Renovator and Certified Dust Sampling Technician training Nationwide. Scott is a Principal Instructor for NCHH, a Certified Renovator, a Certified Dust Sampling Technician, a Certified Graduate Associate, and a Certified Green Professional. He is also a member of the NAHB Society of Honored Associates, the Faculty of the NAHB University of Housing, the Boards of Directors for the National Association of Home Builders and the Texas Association of Builders, as well as many other boards, councils, and committees at the national, state, and local levels. You can contact him at or (713) 213-1205. Take the "ConserveIQ Quiz" at