EPA RRP enforcement report

For the past three years, the Environmental Protection Agency (EPA) has quietly but aggressively ramped up enforcement of the Lead Renovation, Repair, and Painting (RRP) Rule across the United States. The agency’s current enforcement strategy is clear: they aren’t just targeting giant corporations anymore. They are actively showing up at local job sites and auditing regional contractor networks.

To help you keep your business protected and compliant, we are breaking down recent, real enforcement actions from the past few years—anonymized to show you exactly what EPA inspectors are looking for right now.

Case Study 1: The Active Job Site Surprise Inspection

  • The Penalty: $18,715 civil penalty
  • The Scenario: A commercial contracting firm was managing a multi-unit residential renovation on a historic pre-1978 property in New Hampshire. EPA inspectors conducted an unannounced, on-site physical inspection while work was actively underway.
  • The Violations: Inspectors physically observed multiple field violations. The crew failed to post lead-hazard warning signs around the work zone, failed to cover the floors with mandatory plastic sheeting, and failed to contain active renovation dust and debris. To make matters worse, when inspectors asked to see compliance documentation on-site, the supervisor could not produce them.

Case Study 2: The Franchise Subcontractor Audit

  • The Penalty: Widespread audits and multi-thousand dollar settlements
  • The Scenario: The EPA recently issued a formal Enforcement Alert after launching a targeted regional sweep auditing painting and restoration franchise networks. Instead of just inspecting jobs, they audited corporate records to see how jobs were being awarded.
  • The Violations: The sweep caught multiple regional operations for a systemic failure to hire certified firms. The primary businesses were handing off jobs on pre-1978 homes to uncertified subcontractors. Additionally, they failed to provide the mandatory “Renovate Right” pamphlets to property owners before starting work and failed to retain RRP compliance records.

The Big Takeaways for Your Crew

1. The “Subcontractor Trap” is Real

If your company signs the primary contract for a pre-1978 residential or child-occupied property, you carry the ultimate legal liability. You cannot hand off a project to an uncertified sub and assume the risk goes with them. If they violate RRP guidelines, the EPA holds the primary contractor responsible.

2. Physical Containment is Being Watched

As seen in the New Hampshire job site case, the EPA is actively looking for dirty jobs. If an inspector drives past your project and sees open windows, bare floors, or a lack of warning signs on a historic building, they have every right to walk onto the site.

3. Recordkeeping is 50% of the Law

You can do the cleanest, safest lead containment work in the world, but if you cannot prove you handed out the “Renovate Right” booklet, or if you lose your certified renovator records before the mandatory 3-year retention window closes, you are technically in violation.

Need to Get Your Team Certified?

Don’t wait for an unexpected visit from the EPA to find out if your paperwork and field practices are up to par. Project Safety Services provides comprehensive, EPA-approved Lead RRP training and compliance auditing to keep your business safe, certified, and profitable. Contact us today to schedule your crew’s next certification or refresher course.

Relevant Links:

Click here to register your firm!

Click here to learn more about the EPA RRP Program.

Click here to register for an EPA RRP Initial or Refresher Certification.