On April 7, 2022, EPA Region 6 issued a Consent Agreement and Final Order (CAFO) under its authority pursuant to the Toxic Substances Control Act to The O?Brien Group, Inc. (Respondent), located in Dallas Texas. The CAFO was issued in response to the Respondent's failure to meet the requirements of the Lead-Based Paint Renovation, Repair, and Painting (RRP) Rule involving fourteen properties; specifically:
1) Failure to obtain initial firm certification from EPA, 40 C.F.R. ? 745.89 and 40 C.F.R. ? 745.81(a)(2)(ii);
2) Failure to assign a certified renovator to each of the properties, 40 C.F.R. ? 745.89(d)(2);
3) Failure to provide the EPA pamphlet (Renovate Right) to the owners of each subject property before renovation activities, 40 C.F.R. ? 745.84(a)(1); and
4) Failure to prepare and retain records documenting compliance with the requirements of 40 C.F.R. ? 745.85 for each subject property, 40 C.F.R. ? 745.86(a) and 745.86(b)(6).
The CAFO requires the Respondent to return to compliance and pay a penalty of $17,709.