I think this new program is comparable to the E-check system. WORTHLESS! Just another way for uncle sam to make a buck!

There is no established violation here. The RRP rule applies if no lead testing was done. If lead testing by a certified renovator (even acting independent of a certified firm) established that there was not lead present beyond the established threshold the rule does not apply, 40 CFR 745.82(a)(1). The contractor performing the work shown above was not a certified firm and so was not required to do the recordkeeping of 40 CFR 745.86. Certified renovators have no requirement to do recordkeeping.

Jonathan, you are misinformed. By law, firm certification is required for those businesses doing RRP regulated work. The fact that a certified firm is not involved on this project does not remove any documentation requirements. I suggest you either read the regulations or get the assistance you need to understand the RRP rule. You should know that EPA does not agree with your logic. The business owner is being prosecuted by EPA and has been assessed a $150,000.00 fine.

good its about time i have over $6000.00 dollars invested in lead safe equipment tools vacs ect..air scrubers-if you dont want to play ball get off the feild.-they should have done this years ago ,i begining to really like how clean this system is.

Shawn, you are correct that work which is done under the RRP rule must be done by a certified firm. My point is that I have not yet seen it established that this work does in fact fall under that rule. I have not seen anything that establishes that lead paint testing was NOT completed. 40 CFR 745 (the "RRP rule") is a very poorly written piece of legislation. It leaves a loophole by making no requirement for certified renovators to perform record keeping of tests. Lookup 40 CFR 745.82(a)(1) as referenced above. Furthermore, the rule does not apply if a certified renovator has performed a test determining that lead is not present. Such a test is not required to be recorded, though, unless a certified firm performs such a renovation. See 40 CFR 745.86. Record keeping is required of certified firms. No record keeping is required of certified firms. Therefore, if a non-certified firm performs work on "target housing" that a certified renovator has "determined [is] free of paint or other surface coatings that contain lead" (see 40 CFR 745.82), then there is no violation. As I said, there is no established violation. The EPA is prosecuting, but has it been established that there was in fact a violation? 
 
I am a certified renovator working working for a certified firm, and I have set up all of our record keeping and procedures for our lead renovations. Believe me, I am thoroughly familiar with the legislation and it drives me crazy how poorly it is written.