A homeowner is acting as their own general contractor and hires multiple companies to do the work. Would each business be required to follow the Lead Renovation Repair and Painting (RRP) Rule and assign certified renovators to supervise their portion of the work including separate containment?

While the homeowner may be performing the role of general contractor by hiring firms and organizing their work, the homeowner is not performing, offering or claiming to perform a renovation and therefore does not need to be a certified firm. The firms hired by the homeowner to perform renovation tasks are responsible for complying with all aspects of the RRP Rule that are applicable to their work, including firm certification. The RRP Rule does not prohibit firms from reaching agreement on which will supply the certified renovator who is responsible for ensuring compliance with the RRP Rule and who directs and trains non-certified workers. However, all firms share liability for ensuring compliance with the RRP Rule.

Question Number: 23002-20939

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