On April 1, 2011, Region 10 filed a Consent Agreement and Final Order (CAFO) resolving TSCA claims against College Works Painting (College Works). This CAFO resolves Region 10Âs claim that College Works violated the requirements of the Lead-Based Paint Pre-Renovation Education Rule (Pre-Renovation Rule), 40 C.F.R. §§ 745.84 and 745.86 and Section 409 of the Toxic Substances Control Act (TSCA), 15 U.S.C. § 2689. Specifically, Region 10 alleged that College Works failed to establish and maintain records necessary to demonstrate compliance with the regulations, prior to conducting renovations. The renovations took place at properties in Portland, McMinnville, and Hillsboro, Oregon. Under the terms of the CAFO, College Works of Irvine, California agreed to pay a penalty of $32,508. It also should be noted that the target housing units are located in potential environmental justice areas in Oregon.