RESPONDENT FAILED TO COMPLY WITH ALL REQUIREMENTS OF RENOVATION, REPAIR, AND PAINTING (RRP) RULE BY FAILING TO OBTAIN INITIAL FIRM CERTIFICATION FROM EPA PRIOR TO BEGINNING WORK, FAILING TO HAND OUT THE RENOVATE RIGHT PAMPHLET TO THE HOME OWNER AND ADULT OCCUPANT PRIOR TO WORK STARTING, FAILING TO ASSIGN A CERTIFIED RENOVATOR, AND FAILING TO RETAIN RECORDS NEEDED TO DEMONSTRATE COMPLIANCE.