Failing to distribute to the owner a copy of the EPA's Renovate Right Pamphlet as required by 40 C.F.R. 745.84(a)(l )(i); 2) failing to retain records documenting compliance with the work practice requirements of 40 C.F.R. 745.85, 3) failing to obtain initial firm certification prior to the renovation at a target housing as required by 40 C.F.R 745.81(a)(2)(ii), and 4) failing to ensure certified renovators were assigned to the renovation or trained by one as required by 40 C.F.R. ? 745.89(d )(2) at one target housing property.