Is there a delay in required compliance? The Wall Street
Journal and some industry media said yes. D.S. Berenson,
noted industry attorney, says no, lead safe work
practices are still required. According to attorney Berenson:
The law has not been changed or amended in any way.
On June 18, 2010 the EPA issued an internal “guidance”
memorandum to its Enforcement Division Directors.
This memorandum informs the EPA regional offices that
(i) contractors who have failed to register as Renovation
Firms with the EPA have until October 1 before they are
at risk of being fined for that violation; and (ii) individuals
who have failed to obtain licensure as Certified Renovators
with the EPA have until September 30 to sign up
for the training, which training must then be competed by
December 31.