The United States Environmental Protection Agency (“EPA”) and Strategic Management Partners d/b/a Sienna Heights Apartments (“SMP”) entered into a May 3rd Consent Agreement and Final Order (“CAFO”) addressing an alleged violation of Section 409 of the Toxic Substances Control Act and 40 C.F.R. Part 745, Subpart F (Residential Lead-Based Paint Hazard Reduction Act of 1992). See Docket No. TSCA-04-2016-2531(b).

SMP is described as a lessor (as defined at 40 C.F.R. § 745.103) of the Sienna Heights Apartments (“apartments”).

The apartments are characterized as residential housing located in Norcross, Georgia. The residential units in the apartments are described as “target housing” as defined at 40 C.F.R. § 745.103.

EPA is stated to have obtained information on or about May 31, 2016 relating to a lease of Apartment #153 indicating SMP violated Section 409 of the Toxic Substances Control Act and 40 C.F.R. Part 745, Subpart F. The specific violation is described as SMP failing to:

. . . include, as an attachment or within a contract to lease target housing, the signatures of the lessors, agents, and lessee certifying to the accuracy of their statements, to the best of their knowledge, as well as dates of said signatures, pursuant to 40 C.F. R. § 745.113(b)(6).

A civil penalty of $198 is assessed.

A copy of the CAFO can be downloaded here.