“40 CFR 745.107(a)(1) requires that, when contracting to lease target housing, the lessor must provide the lessee or purchaser with EPA-approved lead hazard information and pamphlet.”

💡 This regulation exists to protect families from brain damage caused by lead exposure in older homes

“One child above the age of 6 resided at 407 Myrtle Street, Kalamazoo, Michigan 49007 during the lease term from October 10, 2020 to September 30, 2021.”

💡 A child spent an entire year in housing with undisclosed lead hazards during critical developmental years

“Respondents are Joshua Dipzinski, an individual with a place of business located in Kalamazoo, Michigan and Greg LLC, a limited liability company doing business in the State of Michigan. Respondent Joshua Dipzinski is the registered agent of Respondent Greg, LLC.”

💡 One person made the decision to skip safety warnings across nine separate rental properties

“Housing built before 1978 may contain lead-based paint. Lead from paint, paint chips, and dust can pose health hazards if not managed properly. Lead exposure is especially harmful to young children and pregnant women.”

💡 This is the exact warning that tenants never received before signing leases and moving their families in

“Respondents did not include a lead warning statement as an attachment or within the contract to lease target housing for the properties listed on lines 1-2 and 5-9 of Appendix A, in violation of 40 CFR 745.113(b)(1).”

💡 Every single lease contract violated federal law by omitting mandatory safety language

“Respondents did not include, as an attachment or within the contract to lease target housing, a statement disclosing the presence of known lead-based paint hazards in the target housing or the lack of knowledge of such presence for the properties listed on lines 3-4 of Appendix A in violation of 40 CFR 745.113(b)(2).”

💡 Tenants could not make informed decisions about their housing because they received no information about lead testing or hazards

“Complainant also considered EPA’s Section 1018 – Disclosure Rule Enforcement Response and Penalty Policy, dated December 2007.”

💡 Available EPA records show Greg LLC violated disclosure rules in 2005, indicating this is a pattern spanning 20 years

“Under 18 USC 3571(e), 15 USC 2615(a), and 40 CFR Part 19, the Administrator of the EPA may assess a civil administrative penalty of up to $22,263 for each violation of 42 USC 4852d and Section 409 of TSCA, 15 USC 2689, that occurred after November 2, 2015.”

💡 EPA could have fined up to $311,682 for 14 violations but settled for $5,000, making noncompliance financially attractive

“Respondents neither admits nor denies the actual allegations in this Consent Agreement and neither admits nor denies the factual allegations in this CAFO.”

💡 The landlord avoided public admission of endangering families while continuing rental operations

“This Consent Agreement and Final Order, as agreed to by the parties, shall become effective immediately upon filing with the Regional Hearing Clerk. DATED THIS 30th DAY OF September, 2025.”

💡 By the time EPA acted, any children exposed in 2020-2021 had already lived with potential brain damage for years

“Before renting pre-1978 housing, lessors must disclose the presence of known lead-based paint and lead-based paint hazards in the dwelling. Lessees must also receive a federally approved pamphlet on lead poisoning prevention.”

💡 The pamphlet explains how lead causes learning disabilities and behavioral problems that last a lifetime

“Respondents’ failure to include, as an attachment or within the contract to lease target housing, a statement disclosing the presence of known lead-based paint hazards in the target housing or the lack of knowledge of such presence or of known lead-based paint and/or lead-based paint hazards in the contract to lease target housing for the property listed on Line No. 4 in Appendix A, constitutes one violation of 40 CFR 745.113(b)(2).”

💡 The EPA carefully documented that every element of the disclosure process was skipped, not just one or two

“In determining the penalty amount, Complainant considered the nature, circumstances, extent and gravity of the violations and, with respect to Respondents, ability to pay, effect on ability to continue to do business, any history of such prior violations, the degree of culpability.”

💡 The low fine reflects the landlord’s financial claims rather than the severity of endangering children

“40 CFR 745.103 defines target housing as any housing constructed prior to 1978, except housing for the elderly or persons with disabilities (unless any child who is less than 6 years of age resides or is expected to reside in such housing) or any 0-bedroom dwelling.”

💡 All nine properties met this definition and required full disclosure, with no exceptions applicable

“This CAFO resolves only Respondents’ liability for federal civil penalties for the violations alleged. This CAFO does not affect Respondents’ responsibility to comply with the Lead Act and the Disclosure Rule and other applicable federal, state and local laws.”

💡 The EPA treated repeated endangerment of families as an administrative matter rather than a criminal act