[CLC-Discussion] Toxic Substances Control Act (TSCA), 15 U.S.C. § 2610

Charles B. Hernicz, Esq. chernicz at herniczlegal.com
Wed Jun 12 10:30:21 PDT 2024


Need someone versed in defense of claims from EPA for violations of TSCA "pertaining to renovations, repair, and painting of "target" properties constructed before 1978, where lead-based paint may be present, as set forth in 40 C.F.R. Part 745, Subpart E ("Residential Property Renovation" or "RRP").  EPA wants my client to participate in a show cause hearing with under threat of an admin hearing with fines of nearly $50k per violation.  To the best of the client's knowledge, there was no lead based paint present in any building it worked on performing concrete restoration and no evidence lead paint was present; this is purely a procedural issue for buildings that were built before 1978.  Help!

Chuck

NOTE! WE HAVE MOVED!  Please use new address below.

Charles B. Hernicz, Esq.
Board Certified in Construction Law by The Florida Bar
Hernicz Legal Services, P.L.
95102 Royal Palm Court
Fernandina Beach, FL  32034
Telephone: (561) 753-7511
Chernicz at HerniczLegal.com
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