If your firm is not Lead-Safe (RRP) certified and you advertise for or perform renovation, repair, or painting on pre-1978 housing or child-occupied facilities, the EPA can assess civil penalties under the federal Toxic Substances Control Act. The maximum civil penalty is $49,772 per violation, per day (40 CFR 19.4, adjustment effective January 8, 2025); EPA sets actual penalties case by case. The penalty applies to advertising and offering the work, not just performing it, and separate violations stack on the same job.
Updated September 2026 · Reviewed by Korey Sharp-Paar, Founder, Fast Filing Group LLC
The EPA publishes its enforcement cases. Published settlements with contractors have run from roughly $35,000 to $400,000, and one national retailer agreed to a $12.5 million penalty. Firm certification is a filing that costs $429 all in for EPA-administered states through LeadSafeFiling.com.
Civil penalties for operating without RRP certification are set under Section 16 of the federal Toxic Substances Control Act. The maximum civil penalty is $49,772 per violation, per day (40 CFR 19.4, adjustment effective January 8, 2025); EPA sets actual penalties case by case. The $37,500 figure often quoted elsewhere is an older amount from before later adjustments.
Two features of that maximum matter. First, it is per violation, so a single job can generate several separate violations at once: no firm certification, no certified renovator assigned, no records, no lead-safe work practices. Second, it is per day, so the clock runs for each day the violation continues. The EPA does not have to assess the maximum, and published settlements land well below it.
In practice the EPA negotiates settlements based on the number of violations, how long they continued, the size of the firm, and whether children were exposed. The maximum is the ceiling, not the typical outcome. Smaller contractors have settled in the tens of thousands of dollars, while large companies have paid six and seven figures.
These are published EPA and Department of Justice settlements:
Yes. This is the trap most contractors miss. Under the RRP Rule, on or after April 22, 2010, no firm may perform, offer, or claim to perform covered renovations in pre-1978 target housing or child-occupied facilities without firm certification. The words offer and claim carry real weight. You can be in violation before you ever pick up a tool.
In plain terms, running an ad, listing the service on your website, bidding a job, or telling a homeowner you do this work can each count as offering to perform regulated renovation. If your firm is not certified when you do any of that, you are exposed. The rule is written so that certification comes first, before the marketing and before the job. A firm must be certified before it advertises for or performs the work.
Yes. The federal penalty is assessed per violation, per day. A violation that persists for a week is not one penalty, it is potentially seven, and that is before you multiply by the number of distinct violations on the project.
Consider a single uncertified job that disturbs lead paint over several days. The firm has no certification, no certified renovator on site, no recordkeeping, and did not follow lead-safe work practices. Each of those is a separate violation, and each can accrue for every day it continues. EPA weighs these factors when it sets the actual penalty case by case.
Yes. The EPA runs a dedicated enforcement program for the Lead Renovation, Repair and Painting Rule, publishes settlement summaries, and has issued enforcement alerts that warn contractors directly. Cases come from routine inspections, tips, homeowner complaints, and, in several documented instances, from renovation work that aired on television.
Enforcement also reaches firms that assumed they were too small to notice. The agency has pursued sole proprietors and regional remodelers, not just national retailers. Lead exposure in homes with young children is a public health priority, and the RRP Rule is one of the EPA's primary tools to address it.
A federal penalty is the headline risk, but it is not the only one. An uncertified firm caught violating the RRP Rule can face consequences that outlast any single fine, and several of them cost more in the long run than the penalty itself.
Certification protects you on all of these fronts at once, and it is the one variable you fully control.
Firm certification is a single filing, and through LeadSafeFiling.com it costs $429 all in for EPA-administered states. That is a $129 preparation and filing fee plus the $300 government fee, and EPA certification lasts five years. The three state-run programs we file directly have their own government fees, with all-in totals of $429 in Delaware, $254 or $379 in Wisconsin (2-year or 4-year), and $154 in Washington.
No Social Security number is ever required to file, and you do not have to learn the EPA CDX system or the state portals. We prepare your firm certification application, submit it in EPA's CDX for you (state programs: prepared and guided through submission), track it to issuance, and deliver your certificate and Lead-Safe Certified Firm logo. Start your filing at LeadSafeFiling.com.
One distinction matters here. Firm certification is the company credential, and it is what we file. It is different from the individual Certified Renovator credential, which is a separate accredited 8-hour course that a person on your crew completes. Most firms need both: the firm certification to operate, and at least one certified renovator to run jobs.
The maximum civil penalty is $49,772 per violation, per day (40 CFR 19.4, adjustment effective January 8, 2025); EPA sets actual penalties case by case. Penalties apply to advertising and offering the work, not just performing it.
The statutory maximum is the ceiling, but real settlements have ranged from roughly $35,000 for small firms to $400,000, and one national retailer paid $12.5 million. The actual amount depends on the number of violations, how long they continued, and the firm's size.
Yes. The RRP Rule prohibits any firm from performing, offering, or claiming to perform covered renovations without certification. Running an ad, bidding a job, or listing the service can each count as offering the work, so you can be in violation before any work begins.
Yes. Penalties are assessed per violation, per day, so a violation that continues for several days multiplies, and separate violations on the same job stack on top of each other. EPA sets the actual amount case by case.
Yes. The EPA runs a dedicated RRP enforcement program, publishes settlement summaries, and issues enforcement alerts. It has pursued sole proprietors, regional remodelers, and national retailers, including cases triggered by renovation work shown on television.
Common violations include operating without firm certification, not assigning a certified renovator to a job, failing to follow lead-safe work practices, and not keeping the required records. Each is a separate violation that can be penalized per day.
It applies if your firm is paid to perform renovation, repair, or painting that disturbs more than 6 square feet of interior paint or more than 20 square feet of exterior paint, or windows, in housing or child-occupied facilities built before 1978.
Get your firm certified before you advertise for or perform the work, and keep at least one certified renovator on your crew. Firm certification is $429 all in for EPA-administered states through LeadSafeFiling.com and lasts five years.
No. Firm certification is the company credential and is what LeadSafeFiling.com files for you. The Certified Renovator credential is a separate accredited 8-hour course an individual on your crew takes. Most firms need both.
$429 all in for EPA-administered states ($129 service fee plus the $300 EPA fee). State-run programs range from $154 in Washington to $429 in Delaware, with Wisconsin at $254 (2-year) or $379 (4-year).
Ready to file? Select your state and start your certification →
See cost by state · file it yourself? · glossary
We prepare and file your EPA or state Lead-Safe firm certification. No SSN required; processing time is set by the issuing agency.
Start Your Filing