Shawn, We applied for designation as an EPA Renovation Firm early March. With the EPA backlog, I don't anticipate receiving the EPA Firm Certification prior to 22 April. Since that designation is more a registration paper-work drill as opposed to a certification, can we operate based on the fact we have applied alone? I am our newly trained Certified Renovator. Thanks, Tim
According to the EPA RRP rule, you cannot offer, sell or do work on pre 78 target housing for compensation unless you or your business is a certified firm. That said, my EPA contacts have told me the government may decide to allow you to work as long as you have a certified renovator on staff and your application has been received by the EPA, even if they have not sent you confirmation of firm certification. So, because this is not yet the case, you should assume you are taking a great risk if you work without being a certified firm. Fines are $37,500 for each violation. Watch for updates on the rule between now and April 22nd to see if the EPA grants any temporary amendment to the rule. If I hear of any, I will post that info on my website.
I hope this helps.