EPA RRP fines and penalties: what a violation can cost

What counts as a violation

Section 745.87 lists three kinds. Failing to comply with any part of the RRP rule violates TSCA section 409. Failing to create, keep, or give access to the required records violates TSCA sections 15 and 409. Refusing entry or an inspection is also a violation.

Each missed requirement can be a separate count. A single job can produce several: no firm certification, no certified renovator assigned, no pamphlet receipt, no cleaning verification record. Section 745.87(e) also says lead-based paint is assumed to be present at covered renovations.

• Doing covered work without firm certification.
• No certified renovator assigned to the job.
• Pamphlet not delivered, or no proof of delivery.
• Work practices not followed.
• Required records missing or not kept for 3 years.
• Refusing an inspection or access to records.

The maximum civil penalty

TSCA section 16(a) sets the civil penalty, and federal law adjusts it for inflation. The table in 40 CFR 19.4 lists $49,772 per violation for penalties assessed on or after January 8, 2025. The statute says each day a violation continues counts as a separate violation.

There was no 2026 increase. In April 2026, the Office of Management and Budget told agencies not to apply a 2026 inflation adjustment and to keep using the 2025 levels. Check 40 CFR 19.4 again in January, because the figure can change each year.

These are maximums. The actual amount depends on the facts of each case. A case with several violations across several jobs can add up quickly.

Criminal penalties

TSCA section 16(b) covers knowing or willful violations. On conviction, a person can be fined up to $50,000 for each day of violation, jailed for up to one year, or both. It applies only to violations that are knowing or willful.

How EPA decides the amount

TSCA section 16(a)(2)(B) tells EPA what to weigh: the nature, circumstances, extent, and gravity of the violation, and, for the violator, ability to pay, the effect on the business, past violations, and degree of culpability. EPA can also settle for less.

In practice, the facts that help are the ones you can show: a certified firm, a named renovator, a signed pamphlet receipt, photos of containment, and a cleaning verification record. Our inspection guide explains how to get those ready.

Why records matter as much as the work

A crew can do every step right and the firm can still be cited if it cannot show it. Section 745.86 requires the firm to keep its records for 3 years after the job is complete. A lost binder or a phone that was wiped can turn a clean job into a records violation.

Keep each job's records in one place and check them before the job closes. Our recordkeeping requirements guide lists every document.

Questions contractors ask

Can a homeowner report me? Yes. EPA and state programs accept tips and complaints from the public.

Do state programs have their own fines? Yes. Authorized state and Tribal programs enforce their own rules and set their own penalties. Check the program for your work location.

Should I talk to a lawyer? If you get a notice from EPA or a state program, yes. This guide is general information, not legal advice.