RRP Compliance Monitoring EPA performs inspections: – “For cause” (such as inspections based on tips and complaints) – Neutral scheme inspections, which have been targeted based on specific criteria Inspections for RRP take place for training providers as well as renovators RRP Overview & Enforcement 1

Enforcement Process EPA takes enforcement actions as appropriate and in accordance with our Enforcement Response and Penalty Policy (ERPP) – Civil Administrative Complaints – Notices of Noncompliance – Civil Judicial Referrals – Criminal Proceedings ERPP may be found at: RRP Overview & Enforcement 2

RRP Compliance Required if Building is Target Housing. Painted surfaces are removed or disturbed. Work is done for Compensation. 08/08/2013RRP Overview & Enforcement 3

4 Recordkeeping and Enforcement Documents demonstrating compliance with the rule must be retained for 3 years following the completion of a renovation EPA may suspend, revoke, or modify a firm’s certification if firm is found to be in non-compliance Non-compliant contractors may be liable for civil penalties of up to $37,500 for each violation Contractors who knowingly or willfully violate this regulation may be subject to criminal sanctions under TSCA Section 16. 4

RRP Certification Business certified as “firm”- App and fee to EPA. Job performed or supervised by “Certified Renovator”. Certified Renovator- completes 8 hour class offered by authorized RRP trainer. 08/08/2013 5

REMINDER- RRP Requires: When the final invoice for the renovation is delivered, or within 30 days of completion, if earlier, the renovation firm provide information demonstrating compliance with the training and work practice requirement to: the owner of the building and, if different, to the occupants of the renovated housing or the operator of the child-occupied facility 08/08/2013 6

October 2011RRP Overview 7