EPA Alleged Three Lead-Safety Failures at a Memphis Renovation

The inspection started with waste in the open

On May 13, 2026, an EPA inspector entered a renovation worksite on Carr Avenue in Memphis. The property had been built before 1978, placing it within the federal definition of target housing for the renovation rules at issue.

According to the consent agreement, the inspector observed collected renovation waste that was not stored under containment, inside an enclosure, or behind a barrier capable of keeping dust and debris in the work area and preventing access to it.

EPA requested the contractor’s compliance records that same day. The order says Classic Renovation & Design was unable to provide documentation showing that it had obtained the required firm certification or supplied the property owner with an EPA-approved lead-hazard information pamphlet before beginning the renovation.

Those details became the basis for three alleged violations under the Toxic Substances Control Act and EPA’s residential renovation rules.

Three safeguards were supposed to operate at different stages

The requirements are not interchangeable paperwork. Each applies at a different point in a renovation involving older housing.

1. Firm certificationA compensated renovation firm must apply for and obtain EPA certification before performing, offering, or claiming to perform covered renovations.
2. Owner informationThe firm must provide the owner with the approved lead-hazard pamphlet no more than 60 days before work and obtain an acknowledgment or qualifying proof of mailing.
3. Waste containmentAt the end of each workday and at the end of the project, collected waste must be secured to prevent dust and debris from leaving the work area or being accessed.

EPA alleged that Classic Renovation & Design failed at each point: authorization before the work, hazard information for the owner, and physical control of waste during or after the work.

What EPA documented, and what it alleged

The distinction matters. The waste condition was described as an inspector observation, while the three violations were EPA allegations settled without a hearing on the facts. The company agreed not to contest those allegations for this proceeding, but it did not admit them.

The risk is clear, but the record does not document exposure

Renovation can disturb painted doors, walls, windows, ceilings, and other surfaces. Federal rules apply additional safeguards to covered pre-1978 housing because renovation dust and debris can create a lead-related hazard when lead-based paint is present.

The alleged pamphlet failure meant the owner did not receive the specific hazard information EPA requires before covered work, according to the agency. The reported containment failure concerned a physical route by which renovation dust or debris could leave the work area or become accessible.

But the order does not say that the property contained lead-based paint. It does not report environmental testing, identify residents, document dust leaving the site, or establish that a child, worker, owner, or neighbor was exposed. Any claim of actual lead exposure or health damage would go beyond the available evidence.

The settlement imposed a penalty without a factual admission

The company consented to the penalty and conditions in the agreement. It waived any right to contest the alleged violations and waived an appeal of the final order. The agreement also counts as an enforcement action when EPA considers the company’s compliance history in a future case.

The settlement does not operate as an admission of the factual allegations. Classic Renovation & Design expressly neither admitted nor denied them. The final order approved and incorporated the agreement, making its obligations binding, but did not independently decide the disputed facts after a trial or evidentiary hearing.

The company’s documented position

• It acknowledged EPA’s jurisdiction over the matter.
• It neither admitted nor denied the factual allegations.
• It accepted the civil penalty and waived its rights to contest the allegations or appeal.
• It certified, to the best of its knowledge, that it was currently complying with the relevant renovation requirements.

From inspection to binding order

The order closes only this defined penalty case

Full compliance with the agreement resolves the company’s federal civil-penalty liability only for the facts and violations specifically alleged in the order. It does not excuse future noncompliance or restrict EPA from pursuing other lawful remedies in circumstances covered by the agreement.

The penalty is therefore one part of the outcome. The order also creates a public enforcement record, binds the company and its successors to the settlement, and preserves the agency’s ability to enforce the payment and compliance terms.

What the available record leaves unanswered

• Whether lead-based paint was present at the property.
• How long the waste remained unsecured or whether dust or debris traveled beyond the work area.
• Whether any residents, workers, or neighbors came into contact with the renovation waste.
• What specific corrective steps produced the company’s certification of current compliance.