Respondent failed to comply with all the requirements of the Renovation, Repair and Painting (RRP) Rule as follows:
40 C.F.R. ?? 745.81(a)(2)(ii) and 745.89(a) - Failure of a firm that performs, offers, or claims to perform renovations or dust sampling for compensation to obtain initial certification; and 40 C.F.R. ? 745.84(a)(1) - Failure of a firm, no more than sixty (60) days before beginning renovation activities in any residential dwelling unit of target housing, to provide the owner of the unit with the EPA pamphlet titled Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools.