Lead-safe renovation enforcement
EPA alleged that the Pennsylvania painting business renovated four pre-1978 homes without required firm certification, trained oversight, compliance records, or proof that owners received a federal lead-safety pamphlet.
The inspection began with contracts, not a reported injury
An EPA inspector examined nine contracts supplied by the painting business. Four pointed to renovations at homes constructed decades before the United States banned lead-based residential paint for consumer use in 1978.
The federal Renovation, Repair and Painting Rule treats most pre-1978 homes as target housing. When paid renovation work disturbs painted surfaces, the rule creates a chain of preventive requirements. Firms must be certified, qualified people must supervise or train workers, lead-safe practices and post-renovation cleaning must be documented, and owners must receive information about lead hazards.
The EPA consent agreement alleges that the CertaPro-branded business failed at each of those checkpoints at the four properties. The reviewed contracts did not indicate that a lead-free determination or emergency-renovation exception applied, according to the agency.
EPA said its inspector reviewed contracts during the July 2023 inspection, identified four properties as target housing, and used the missing certification and compliance documentation as the basis for four counts under the Toxic Substances Control Act and its regulations.
Four safeguards the EPA says were missing
The allegations cover more than a single expired form. Together, they describe the compliance system that is supposed to surround renovation work in older housing.
Firm certification
EPA alleged that the business had not obtained agency certification to perform renovations at the four target-housing properties.
Qualified oversight
The agency alleged that no certified renovator was assigned to each project and that workers were not certified renovators or trained by one.
Work and cleaning records
EPA alleged that the business failed to provide documentation showing required lead-safe work practices, worker training, and post-renovation cleaning verification.
Notice to property owners
The agency alleged that the business lacked either an owner’s written acknowledgment of the Renovate Right pamphlet or a timely certificate of mailing.
The four properties in the order
The homes were constructed between 1900 and 1962. The dates below are the contract dates listed by EPA for renovation activities performed in 2023.
| Property listed by EPA | Year built | Contract date |
|---|---|---|
| 400 Brook Drive, Spring City, Pennsylvania | 1962 | February 10, 2023 |
| 1033 S. New Street, West Chester, Pennsylvania | 1951 | April 26, 2023 |
| 1403 Manley Road, West Chester, Pennsylvania | 1959 | April 10, 2023 |
| 340 East Biddle Street, West Chester, Pennsylvania | 1900 | April 27, 2023 |
The EPA document labels its date column Date of Lease Contract while describing the reviewed records as painting contracts.
Why missing safeguards matter, and what the order does not prove
Lead-safe renovation rules are preventive. They are meant to control risks before a regulator has to document exposure or injury. Certification and training govern who performs the work. Practice and cleaning records provide a way to verify how the job was handled. The pamphlet requirement informs owners about the risks associated with disturbing old painted surfaces.
That preventive purpose does not turn every paperwork violation into proof of contamination. The order does not say that testing confirmed lead-based paint at any property. It does not document airborne or settled lead dust, identify occupants, report medical testing, or describe an injury.
Count III also requires careful reading. EPA alleged that the respondent failed to provide records demonstrating compliance with work-practice and cleaning requirements. Missing documentation does not, by itself, establish every physical condition at a job site. Count II separately alleges that the required certified renovator and trained-worker structure was not in place.
The parties entered a binding settlement, the final order ratified it, and the respondent agreed to pay $30,866.
The business violated four certification, training, recordkeeping, and notification requirements at four properties.
The presence of lead paint, actual exposure, injury, or property-specific contamination and cleanup needs.
The company accepted the penalty without admitting the allegations
The respondent admitted EPA’s jurisdiction for this proceeding but neither admitted nor denied the specific factual allegations. It agreed not to contest them, waived an appeal, and consented to the civil penalty.
The agreement identifies the respondent as Fabulous Painting by Fabio, doing business as CertaPro Painters of Downingtown and West Chester. Owner Fabio da Silva signed for the business on August 18, 2026. EPA Region 3 approved the agreement, and the agency’s Regional Judicial and Presiding Officer signed the final order filed on September 29, 2026.
The business also certified, after personal investigation and to the best of its knowledge and belief, that it was currently in compliance concerning the alleged violations. The order does not describe property-specific remediation, testing, or outreach to residents.
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The contract dates associated with the four renovations fall within this period.
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An authorized EPA inspector conducts the Renovation, Repair and Painting Rule inspection.
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The owner signs the consent agreement for the respondent.
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The final order is filed, making the agreement effective and requiring payment within 30 days.
The unresolved part is inside the homes
The administrative record provides a clear account of the alleged compliance failures and the financial settlement. It provides far less information about what happened at each work site.
Questions this order does not answer
- Whether any of the renovated surfaces contained lead-based paint.
- Whether renovation activities generated hazardous lead dust.
- Whether occupants received lead-safety information through any method not documented in the records EPA reviewed.
- Whether testing, cleaning, or other corrective work later occurred at the properties.
The penalty resolves the EPA’s civil claims for the specified alleged violations. It does not reconstruct conditions inside the four homes. The most concrete lesson in the order is narrower: a safety system built around certification, trained oversight, documented cleaning, and informed property owners cannot be verified when those protections are absent or unsupported by records.
We’d previously done another article about CertaPro for the exact same type of lead violations: https://evilcorporations.com/certapro-painters-lead-paint-violation-public-health/ clearly they don’t learn!
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