Respondent failed to: (1) to provide the owners with the EPA-approved lead hazard information pamphlet and receive a written acknowledgement or certificate of mailing before each renovation; (2) retain all records documenting compliance with the work practice standards of 40 C.F.R. 745.85, including documentation that a certified renovator performed or directed workers to perform tasks described by 40 C.F.R. 745.85(a); (3) obtain firm certification from EPA under 40 C.F.R. 745.89, prior to performing renovations; (4) ensure that a certified renovator was assigned to each renovation performed by the firm and discharged all of the certified renovator responsibilities.