Another area they covered was a situation that we receive a number of calls and questions about: the General Contractor/Subcontractor relationship. They clarified that if a General Contractor is subbing out work to Sub Contractors, both the General Contractor and Sub Contractors need to have their Lead Safe Firm Certification with the EPA or EPA-Authorized State (depending on where the work is being done). In one EPA Region 10 case, a subcontractor was not certified but the GC was, and after the initial investigation, they fined both the general contractor & sub for being non-compliant. Even if the subcontractor is Firm Certified, but fails to use a Certified Renovator on the job or their workers don't follow RRP practices, the GC could still be liable for fines. Ultimately, the GC is responsible for hiring certified subs AND making sure they are using RRP workers on the job site.
We also learned that there has been a recent push within EPA Region 10 to refer lead violation cases to the EPA Criminal Investigation Division (CID) if an EPA inspector receives a complaint that they feel is worthy of passing on to CID. This allows the EPA to take enforcement actions beyond civil fines, and could mean jail time for those found to be in violation.