In a letter dated 4/20/2010, the EPA announced that it does not intend to take enforcement actions against firms who applied for the required firm certification before April 22, 2010 and are just waiting for their paperwork.  

The RRP Rule requires that firms be certified with the EPA before offering or performing work that falls under the rule.  This fact is clearly stated in the rule and further explained in the FAQ section of the EPA website.   The rule also says that the EPA has up to 90 days to process firm applications.  Apparently, even though many businesses will be required to follow the RRP rule in its entirety, the EPA can decide which part(s) of the rule they will follow, or not.  In the letter, the EPA justifies not following the requirements of the RRP Rule in regards to the firm certification requirement as follows:

"The certification requirement is important to making sure that firms are protecting children and other residents while renovations are ongoing, but EPA does not wish to disrupt ongoing renovations for those firms that submitted applications on time."

The letter indicates that EPA expects to review all firm applications filed by April 22^nd by June, although they did not specify by when in June.  

The letter also makes it clear that the EPA will be enforcing the work practices and training requirements.

Click here to see which companies in your area are on the EPA's certified firms list  

On another note, the EPA did announce that the opt-out provision would be phased out and that it is proposing to add third party dust wipe testing.  The change in the rule regarding the opt-out will become effective 60 days after publication in the Federal Register.  Click here for more on the opt-out and the proposed dust-wipe testing.