EPA has issued a "grace" period, but with limitations!
To avoid facing stiff fines (up to $32,000 per violation), you must be signed up for a class by Sept 30, 2010 and complete the training by Dec 31, 2010.
Using Sub-Contractors ? Or are you a sub-contractor??
Question
My firm acts as a general contractor - we subcontract the entire renovation job to other companies rather than using our own employees. Under the Renovation, Repair, and Painting (RRP) Rule, does my firm need to have a certified renovator at the job site?
Answer Yes.
Beginning April 22, 2010, no firm may perform, offer, or claim to perform renovations covered by the RRP Rule without certification from EPA. A general contractor that subcontracts the entire renovation job to other firms must be certified as a firm for two reasons. First, the contractual agreement between the general contractor and the subcontractor is based on the general contractor's offer to renovate the property of a third party for compensation. The RRP Rule requires a contractor that makes such an offer to be certified as a firm. Second, once the offer is accepted, the general contractor is obligated to perform a renovation in accordance with the terms of the contract, whether written or oral. Even if the general contractor chooses to fulfill its obligation to perform the renovation by hiring subcontractors, the general contractor is performing a renovation for purposes of the RRP rule and must comply with all the requirements of the rule that apply to firms performing renovations.
EPA Cites Company $784,380 for Failing to Warn Residents of Lead-Based Paint Exposures Jun 20, 2010
The U.S. Environmental Protection Agency recently filed a complaint and proposed a $784,380 penalty against Hanson’s Window and Construction Inc. of Madison Heights, Mich., for violations of the 1998 federal rule for failure to warn residents of potential lead-based paint exposures.
EPA alleges that in May 2005, Hanson, a window installation firm, failed to provide home owners and tenants of 271 residential properties in Lansing, East Lansing, Haslett, Charlotte, Onondaga, Williamston, Holt, Stockbridge, Mason, Leslie, and Warren with required information warning residents that their construction activities could expose residents to lead. The citation is based in part on information that two children living in renovated Michigan homes had tested positive for elevated blood lead levels.
The Pre-Renovation Lead Information Rule requires that renovators provide homeowners, tenants, and owners of child-occupied facilities with the “Renovate Right” pamphlet and obtain written confirmation that they have received it. The purpose of the rule is to protect families during renovations in housing built before 1978.