Question: As a general contractor, we subcontract the entire renovation job to other companies rather than using our own employees. Under the Renovation, Repair, and Painting (RRP) Rule, does my firm need to have a certified renovator at the site?
Answer: Not necessarily. All firms performing renovations, including general contractors, must ensure that all individuals performing renovation activities on behalf of the firm are either certified renovators or have been trained by a certified renovator.
A firm acting as a general contractor may satisfy this requirement by hiring another certified firm that also takes responsibility for ensuring that all individuals performing the renovation activities are either certified renovators or have been trained by a certified renovator.
With respect to assigning a certified renovator who is responsible for any OJT and regularly directing other workers, a firm acting as a general contractor my satisfy this requirement by hiring another certified firm that in turn assigns a certified renovator to the job. However, this does not discharge the general contractor's liability to ensure compliance with the RRP Rule.