EPA Region 7 discovered through a records request that Winkler Renovations LLC, a Missouri corporation, failed to comply with the regulatory requirements of 40 C.F.R. Part 745, Subpart E, Lead-Based Paint Repair, Renovation, and Painting Rule (the ?RRP Rule?), which addresses lead-based paint hazards created by renovation, repair, and painting activities that disturb lead-based paint in target housing and child occupied facilities built before 1978.
Winkler Renovations LLC violated three separate requirements of the RRP Rule. First, the firm performed renovation work covered by the RRP Rule on target housing built in 1928, 1932, and 1950 without obtaining firm certification. Certification demonstrates that the firm acknowledges its responsibility to use appropriately trained and certified employees and to follow lead-safe work practices during renovation. Second, the firm failed to retain records necessary to demonstrate its compliance with the RRP Rule. Failure to maintain complete records of compliance with the regulatory requirements prevents the EPA from verifying that the required lead-safe work practices were followed on completed renovations. Finally, the firm also did not obtain either a written acknowledgement from the owners of the properties that they had received copies of the Renovate Right pamphlet or a certificate of mailing at least 7 days prior to the renovation. Owners who do not have the benefit of the information contained in the Renovate Right pamphlet