EvilCorporations.com • Corporate Accountability Project • Public Health & Housing
Marchant Property Management, LLC · EPA Enforcement · 2024–2026
A South Carolina Landlord Renovated Pre-1978 Tenant Housing Without Lead Paint Certification or Tenant Warnings
Marchant Property Management performed renovations on lead-era housing while uncertified and without notifying tenants of lead hazards, putting renters at direct risk of exposure.
TL;DR
Marchant Property Management, LLC, a Taylors, South Carolina rental company, renovated a pre-1978 home at 17 Arthur Avenue, Greenville, without first obtaining required EPA lead-safe certification. The firm also failed to give the tenant the legally required “Renovate Right” lead hazard pamphlet before work began. Pre-1978 homes contain lead-based paint, which causes irreversible brain damage in children and serious health harm in adults when disturbed during renovation. This is not a paperwork failure. This is a landlord choosing profit over the safety of the people living in their property. The EPA fined Marchant $3,800 under the Toxic Substances Control Act in 2026.
Tenants deserve to know when lead hazards may be disturbed in their homes. Demand that your landlord be certified and follow lead-safe renovation rules.
$3,800
EPA civil penalty assessed
Pre-1978
Age of renovated housing (lead-paint era)
0
Lead hazard pamphlets provided to tenants
2
Federal violations cited by EPA
The Violations: What Marchant Did
Core Violations
What the EPA found
| 01 | Marchant Property Management performed paid renovation work at a pre-1978 home on 17 Arthur Avenue, Greenville, South Carolina, without holding EPA firm certification, which is required by federal law before any certified renovation firm can work on lead-era housing for compensation. | high |
| 02 | Marchant failed to provide the adult tenant at the property with the EPA-required “Renovate Right” lead hazard pamphlet within 60 days before renovation began. This pamphlet exists specifically to inform tenants of lead paint dangers so they can protect themselves and their children. | high |
| 03 | Marchant did not obtain a written acknowledgement from the tenant confirming receipt of the lead hazard pamphlet, nor did the company certify that a pamphlet was delivered and that a signature could not be obtained, nor did it obtain a certificate of mailing at least seven days before renovation. All three methods exist as alternatives; Marchant used none of them. | high |
| 04 | The renovation at 17 Arthur Avenue began on or about April 28, 2024. Federal certification and tenant notification requirements applied well before that date. Marchant’s failure was not accidental; it reflects a structural decision to begin work without completing legally required safety steps. | med |
| 05 | EPA Region 4 conducted a business inspection on June 5, 2024, and requested Marchant’s compliance records. Marchant submitted those records on July 17, 2024. The records themselves confirmed the violations. | med |
Public Health and Safety
Why lead paint rules exist
| 01 | Lead paint in homes built before 1978 is safe when undisturbed. Renovation, including sanding, scraping, cutting, and window repair, releases lead dust and chips that can be inhaled or ingested by occupants, especially children under six. | high |
| 02 | Lead poisoning in children causes permanent neurological damage, including reduced IQ, learning disabilities, and behavioral disorders. There is no safe level of lead exposure for children. The tenant at 17 Arthur Avenue had no documented warning that renovation activities would disturb lead-painted surfaces in their home. | high |
| 03 | EPA certification for renovation firms requires training in lead-safe work practices, including containment, cleanup, and disposal of lead debris. Marchant performed renovation work without this certification, meaning there is no documented evidence that federally required lead-safe practices were followed. | high |
| 04 | The Renovation, Repair, and Painting (RRP) Rule under TSCA exists precisely because landlords and contractors historically failed to protect tenants during renovation of older housing. Marchant’s violations reproduce the exact pattern of neglect the federal rule was designed to prevent. | med |
Corporate Accountability Failures
How the system responded
| 01 | The total civil penalty assessed against Marchant is $3,800. This penalty covers two separate federal violations, including operating without certification and failing to notify a tenant of lead hazards. Three thousand eight hundred dollars is the entirety of the consequence for exposing a tenant in a pre-1978 home to potential lead contamination. | high |
| 02 | Marchant neither admitted nor denied the factual findings, a standard settlement posture that allows the company to resolve federal violations without a public admission of wrongdoing. The company’s president, Hunter W. Hughey, signed the agreement on February 5, 2026. | med |
| 03 | The CAFO covers only the specific violations at 17 Arthur Avenue during the April 2024 renovation. EPA retains the right to pursue any additional violations. The settlement does not review or remediate any health harm that may have occurred to the tenant during the uncertified renovation. | med |
| 04 | Penalties under TSCA are not tax-deductible, but the base penalty of $3,800 represents a minimal financial consequence for a property management company. The fine does not require Marchant to remediate the property, compensate the tenant, or undergo auditing of any other properties in its portfolio. | med |
Tenant and Renter Rights
Who bears the risk
| 01 | The tenant living at 17 Arthur Avenue, Greenville, was never given the federally mandated “Renovate Right” pamphlet, which informs renters of lead paint risks, how to protect themselves and children during renovation, and their rights under federal law. The tenant’s consent and awareness were never sought. | high |
| 02 | Renters in older housing are disproportionately lower-income people and people of color, populations that already bear the largest burden of lead poisoning in the United States. Landlords who skip lead-safe renovation rules do not absorb the cost of their noncompliance. Tenants and their children do. | high |
| 03 | The Renovation, Repair, and Painting Rule requires written tenant acknowledgement before renovation begins. This is not a formality. It is a documented record that the tenant received safety information and had the opportunity to prepare. Marchant bypassed this protection entirely. | high |
Timeline of Events
Pre-1978
The property at 17 Arthur Avenue, Greenville, SC 29605 is constructed. Under federal law, all housing built before 1978 is classified as “target housing” subject to lead paint safety rules during renovation.
April 28, 2024
Marchant Property Management begins renovation activities at 17 Arthur Avenue. The firm has not obtained EPA certification to perform renovations on lead-era housing. No lead hazard pamphlet has been provided to the tenant.
June 5, 2024
An EPA inspector conducts an inspection at Marchant’s place of business at 4 East Lee Road, Taylors, SC. The EPA requests Marchant’s compliance records.
July 17, 2024
Marchant submits records to EPA. The records themselves confirm the violations: no certification, no tenant notification documentation.
February 5, 2026
Marchant president Hunter W. Hughey signs the Consent Agreement and Final Order. The company agrees to pay a $3,800 civil penalty, neither admitting nor denying the factual findings.
2026
The EPA Regional Judicial Officer ratifies the CAFO. The case is closed. The tenant at 17 Arthur Avenue receives no remediation, compensation, or documented follow-up under the terms of this agreement.
Direct Quotes from the Legal Record
QUOTE 1
Operating without EPA certification
Core Violations
“Respondent had performed, offered, or claimed to perform the renovation at the Property for compensation, and that at the time Respondent performed, offered, or claimed to perform the renovation at the Property, Respondent had not obtained ‘firm certification’ as required by 40 C.F.R. §§ 745.81(a)(2)(ii) and 745.89(a)(1).”
💡 This confirms Marchant was operating outside the law from the start of the renovation. The company performed paid work on lead-era housing without the federal license required to do so safely.
QUOTE 2
No tenant notification of lead hazards
Tenant and Renter Rights
“Respondent failed to either: (i) obtain from the adult occupant of the Property, a written acknowledgment that the adult occupant received the EPA-approved pamphlet, or to certify in writing that a pamphlet had been delivered to the dwelling.”
💡 Three separate paths exist for documenting tenant notification. Marchant used none of them. The tenant had no documented knowledge that lead paint disturbance was occurring in their home.
QUOTE 3
Definition of what triggers the rules
Public Health and Safety
“The term ‘renovation’ is defined at 40 C.F.R. § 745.83, to mean, in part, the modification of any existing structure or portion thereof, that results in the disturbance of painted surfaces.”
💡 Any work that disturbs painted surfaces in a pre-1978 home triggers these rules. This is not a technical loophole. Marchant’s activity clearly met this definition, and the firm still failed to comply.
QUOTE 4
What the pamphlet requirement protects against
Public Health and Safety
“Firms performing renovations are required to provide the adult occupant of any residential unit of target housing with the EPA-approved pamphlet identified in Paragraph 8 no more than 60 days prior to beginning the renovation.”
💡 This 60-day window exists so tenants have time to prepare, ask questions, arrange for children to stay elsewhere, and understand the risks. Marchant gave the tenant none of that opportunity.
QUOTE 5
The settlement does not cover health remediation
Corporate Accountability Failures
“Full payment of the civil penalty, as provided in Section VII (Terms of Payment), shall not in any case affect the right of the EPA or the United States to pursue appropriate injunctive or other equitable relief or criminal sanctions for any violations of law.”
💡 The $3,800 payment closes this specific case, but does not prevent further enforcement or remediate any harm to the tenant. The person who lived through this renovation has no recourse under this agreement.
QUOTE 6
The company acknowledges this enforcement action counts against future compliance history
Corporate Accountability Failures
“Respondent acknowledges that this CAFO constitutes an enforcement action for purposes of considering Respondent’s compliance history in any subsequent enforcement actions.”
💡 If Marchant violates lead-safe renovation rules again, this settlement will be used against them. This is the only lasting accountability mechanism in the agreement.
Commentary
Why does it matter that the home was built before 1978?
Homes built before 1978 were constructed before the federal ban on lead-based paint in residential housing. Millions of older rental homes still contain lead paint on walls, window frames, doors, and trim. The paint is not dangerous when intact, but renovation work: scraping, sanding, cutting, and demolishing surfaces, releases lead dust and debris into the living space. Tenants, especially children, breathe and ingest that dust. The result is lead poisoning, which causes irreversible brain damage in children. There is no treatment that reverses lead’s neurological effects. The pre-1978 threshold is not arbitrary. It marks the line at which federal law says a landlord must follow strict procedures before touching a painted surface.
What is EPA firm certification and why does Marchant need it?
Any company that performs renovation work for pay on pre-1978 housing must be certified by the EPA under the Renovation, Repair, and Painting Rule. Certification requires training in lead-safe work practices: containment of work areas, wet methods to suppress dust, proper cleanup, and safe disposal of lead debris. Marchant Property Management performed paid renovation work at 17 Arthur Avenue without this certification. That means no documented evidence exists that lead-safe practices were followed during the renovation. The tenant’s home may have been contaminated with lead dust, and there was no certified professional on the job to prevent it.
Who is most harmed when landlords skip lead-safe rules?
Children under six years old are the most vulnerable. Lead crosses the blood-brain barrier in developing brains, causing permanent cognitive damage at doses too small to cause visible symptoms. The damage is silent and irreversible. Renters in older, lower-cost housing: disproportionately lower-income families and communities of color in cities like Greenville, SC: bear the largest share of lead exposure risk in the United States. Landlords who skip certification and tenant notification do not absorb the cost of their noncompliance. The children who live in those homes do. The learning disabilities, behavioral disorders, and reduced life outcomes caused by lead poisoning are a direct result of a landlord choosing not to follow a rule that costs nothing but compliance and paperwork.
Is $3,800 an adequate penalty for this conduct?
No. Three thousand eight hundred dollars is the entire financial consequence for operating an uncertified renovation firm on lead-era tenant housing and denying a tenant their federally mandated right to lead hazard information. This penalty does not require Marchant to pay the tenant anything, test the property for lead contamination, remediate any lead hazards created during the renovation, or be audited for compliance at any other properties it manages. For a property management company, $3,800 is a rounding error. It is not a deterrent. It is the minimum cost of getting caught, and it does nothing to address the harm already done.
What should tenants in pre-1978 rental housing know?
Before any renovation begins in your home, your landlord or their contractor must: (1) be EPA-certified as a Renovation, Repair, and Painting firm; (2) provide you with the EPA pamphlet “Renovate Right” at least 60 days before work starts; and (3) obtain your written acknowledgement that you received the pamphlet, or document that they attempted to do so. If renovation begins and you have not received this pamphlet and documentation, the landlord is violating federal law. You can report violations to your EPA regional office. In South Carolina, that is EPA Region 4 in Atlanta. You may also have rights under state tenant protection law. Document everything.
Did Marchant admit to wrongdoing?
No. Under the terms of the Consent Agreement and Final Order, Marchant Property Management neither admits nor denies the factual allegations. This is standard in EPA administrative settlements. The company agreed to pay the fine and certified current compliance with lead-safe rules, but it did not acknowledge that it harmed anyone or violated a tenant’s rights. This posture, common in corporate enforcement settlements, allows companies to resolve regulatory violations without a public record of admitted fault. The EPA’s own factual findings are part of the public record, but Marchant’s signature on this document carries no admission of guilt.
Is this an isolated incident or a pattern?
This consent agreement covers only the single renovation at 17 Arthur Avenue in April 2024. The EPA’s inspection was triggered by a review of Marchant’s business records at its Taylors, SC office. The settlement does not require disclosure of how many other properties Marchant manages, how many other renovations it has performed, or whether lead-safe practices were followed at any other sites. The public record answers none of those questions. What the record does confirm is that at the one property the EPA examined, Marchant violated both core requirements of the federal lead-safe renovation program.
What can I do to prevent this from happening again?
If you rent in a pre-1978 home, ask your landlord or property management company for proof of EPA RRP firm certification before any renovation begins. Report uncertified renovation work to EPA Region 4 at (800) 241-1754 or online at epa.gov/enforcement. Contact your South Carolina state legislators and demand stronger tenant protections in older housing, including mandatory disclosure of lead test results before rental agreements are signed. Support organizations working on housing justice and environmental health in your community. Share this case publicly. The penalty against Marchant is a matter of public record. So is the fact that a tenant in Greenville was renovated around without ever being warned about lead paint. That tenant has a name. That child, if there was one in that home, has a future worth protecting.
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