RESPONDENT FAILED TO COMPLY WITH ALL REQUIREMENTS OF THE RENOVATION, REPAIR AND PAINTING RULE BY FAILING TO OBTAIN AN INITIAL FIRM CERTIFICATION FROM EPA, PROVIDE OWNERS WITH AN EPA-APPROVED LEAD HAZARD INFORMATION PAMPHLET PRIOR TO BEGINNING RENNOVATION WORK, ASSIGN A CERTIFIED RENOVATOR TO THE JOBS, AND RETAIN RECORDS NECESSARY TO DEMONSTRATE COMPLIANACE WITH RRP.