What $47,476 Does Not Cover

Imagine hiring someone to fix your windows. The house is old, you know that, but you trust the company with a name that sounds like it has been around for generations. You do not know that the paint on those window frames is laden with lead. You do not know because nobody told you. The contractor was supposed to hand you a pamphlet before they touched a single surface. They did not. Instead, workers showed up, started pulling and cutting and scraping, and old painted surfaces were disturbed. Dust went into the air. It settled on floors, on windowsills, on the places where small hands rest.

Lead dust does not smell like anything. You cannot see it against a white floor. Children do not know they are ingesting it. They crawl, they touch things, they put their hands in their mouths. The federal government has known since at least 1992 that lead poisoning causes intelligence deficiencies, reading and learning disabilities, impaired hearing, reduced attention span, hyperactivity, and behavior problems in children under six. Congress wrote that finding directly into law. It is not a fringe claim. It is statute. And yet Crawford & Brinkman, knowing full well they were working in homes built decades before 1978, sent their crews in without a certified renovator assigned, without on-the-job safety training documented, without post-cleaning verification performed, and without ever handing a single homeowner the basic information they were legally owed.

The families at those twelve Peoria addresses did not get a say in this. They hired a company to do a job and assumed the company was following the rules. That assumption was wrong. None of them will receive a penny of the $47,476 fine. That money goes to the federal government. The fine is, in legal terms, a penalty for paperwork failures and procedure violations. But what happened on the ground was not about paperwork. It was about whether a child living in a 1914 house on North Maryland Avenue was protected or not. Based on every record the EPA could find, the answer was not.

There is no way to measure what a child loses when their developing brain is quietly, incrementally damaged by lead exposure. There is no metric card for the IQ points that do not develop, the reading level that never quite catches up, the attention span that makes school feel impossible before age ten. These costs do not appear on any balance sheet. They appear in report cards, in behavioral referrals, in the exhausted faces of parents who cannot figure out why their kid is struggling, in a lifetime of outcomes that statistics will eventually capture but no individual family will ever be compensated for. The fine is paid to the EPA. The debt is paid by everyone else.

Directly From the Federal Order: No Paperwork, No Protection

These are verbatim quotes from EPA Consent Agreement and Final Order, Docket No. TSCA-05-2025-0014, filed March 27, 2025. The company neither admitted nor denied the facts but signed the agreement and waived all rights to contest or appeal.

“Congress found, among other things, that low-level lead poisoning is widespread among American children, afflicting as many as 3,000,000 children under the age of 6; at low levels, lead poisoning in children causes intelligence deficiencies, reading and learning disabilities, impaired hearing, reduced attention span, hyperactivity, and behavior problems.” Paragraph 9, CAFO, TSCA-05-2025-0014

“On twelve occasions from May 27, 2020, to October 18, 2022, Respondent performed or directed workers who performed window and door replacements at the properties described in the chart below.” Paragraph 33, CAFO, TSCA-05-2025-0014

“Respondent provided contracts for the renovations identified in paragraph 33, above, but did not provide any records necessary to demonstrate compliance with work practice standards in 40 C.F.R. § 745.85.” Paragraph 35, CAFO, TSCA-05-2025-0014

“For each renovation project described in paragraph 33, Respondent failed to provide the owner of the unit with the EPA approved lead hazard information pamphlet, in violation of 40 C.F.R. § 745.84(a)(1) and 15 U.S.C. § 2689.” Paragraph 38, CAFO, TSCA-05-2025-0014

“Respondent failed to provide documentation that a certified renovator was assigned; Respondent failed to provide documentation that the certified renovator performed on-the-job training for workers; Respondent failed to provide documentation that the certified renovator performed or directed workers to perform the work practice standards; Respondent failed to provide documentation that the certified renovator performed the post-cleaning verification.” Paragraph 39(a–d), CAFO, TSCA-05-2025-0014

“The Respondent failed to stop renovations or dust sampling if it did not obtain recertification under 40 CFR § 745.89(a), in violation of 40 C.F.R. § 745.89(b)(1)(iii) and 15 U.S.C. § 2689.” Paragraph 40, CAFO, TSCA-05-2025-0014

“This CAFO constitutes a ‘prior such violation’ as that term is used in EPA’s Interim Final Consolidated Enforcement Response and Penalty Policy.” The paper trail now follows them into every future contract dispute and enforcement action.

Who Pays When Contractors Skip the Rules

Public Health

The health consequences of uncontrolled lead exposure during home renovation are well-documented. Every regulatory failure in this case represents a direct, unremediated exposure pathway for families in aging Peoria housing stock.

• Congress established in federal law that as many as 3,000,000 children under age six were affected by lead poisoning at the time the Residential Lead-Based Paint Hazard Reduction Act of 1992 was passed. The renovations at issue here span 2020 to 2022, meaning this risk remains active and ongoing in communities across the country where similar violations occur.
• Window and door replacement in pre-1978 housing is one of the highest-risk renovation activities for generating lead dust. Cutting, scraping, and pulling old painted frames releases fine particles that settle into carpets, upholstery, and floor crevices. Without post-cleaning verification, there is no confirmation those surfaces were cleared before families returned to using the space.
• Children under six are the most vulnerable population because they spend more time on floors, engage in more hand-to-mouth contact, and absorb a higher percentage of ingested lead than adults. The homes at issue are residential. The presumption that children were present or visiting during the relevant period is reasonable and standard under federal renovation rules.
• The neurological harms associated with low-level lead exposure, including reading and learning disabilities, reduced attention span, and hyperactivity, are irreversible. There is no treatment that restores lead-damaged neural development. Prevention through regulated work practices is the only intervention that works, and those work practices were absent here at every documented job site.
• Workers employed by Crawford & Brinkman were also unprotected. Federal work practice standards exist partly to safeguard the people doing the renovation work itself. The absence of any documented on-the-job training means the workers handling lead-painted materials had no confirmed instruction in how to protect themselves from the dust they were generating.

Economic Inequality

The geography of lead exposure in American cities is not random. Older housing stock is concentrated in lower-income neighborhoods, and the families living in pre-1978 homes are disproportionately working class or economically vulnerable. The twelve addresses in this case are spread across Peoria neighborhoods with housing built as early as 1914.

• Families in older housing are the exact population federal lead safety regulations are designed to protect. They tend to have fewer resources to remediate lead hazards independently and less ability to pursue legal action if a contractor contaminates their home. The regulatory system is supposed to be the backstop. When contractors operate outside it for years, these families bear the risk with no recourse.
• The economic burden of childhood lead poisoning falls almost entirely on families and public systems. Developmental delays caused by lead exposure increase the demand for special education services, behavioral health support, and long-term academic interventions. These are costs absorbed by school districts, public health systems, and the families themselves, not by the contractor who created the exposure.
• The fine of $47,476 is paid to the federal government as a civil penalty. Not one dollar flows to the households at the twelve addresses where violations occurred. Those families received no notification through this enforcement process, no medical screening referral, and no remediation support. The enforcement mechanism treats their exposure as a regulatory paperwork matter, not a compensable harm.
• Homeowners who hired Crawford & Brinkman paid for professional work and received no disclosure that the company was operating without active certification or compliant safety practices. They exercised reasonable consumer trust in a licensed-appearing business and were not given the basic federally mandated information that would have allowed them to make an informed decision about how to protect their households during the work.
• This case establishes Crawford & Brinkman’s record as a “prior such violation” under EPA enforcement policy, meaning any future enforcement action against this company carries elevated penalty exposure. The deterrent is forward-looking. The families who lived through these twelve jobs are not part of that calculation.

The Fine in Context

Accountability Steps and Resistance Resources

Crawford Door Company of Peoria, Inc. is now on the federal enforcement record. The following individuals and bodies are the documented responsible parties and oversight mechanisms in this case.

Who Signed the Order

• Thomas Hoffman, President of Crawford Door Company of Peoria, Inc., signed the Consent Agreement on behalf of the company. His email, tom@crawfordandbrinkman.com, is listed in the federal order as the official contact for the Respondent.
• Michael D. Harris, Director of the Enforcement and Compliance Assurance Division, EPA Region 5, signed for the Complainant on March 24, 2025.
• Ann L. Coyle, Regional Judicial Officer, EPA Region 5, signed the Final Order on March 27, 2025, making it effective immediately upon filing.

Regulatory Watchlist

• EPA Region 5 Enforcement and Compliance Assurance Division: The body that investigated and prosecuted this case. If you know of similar violations in Illinois, Indiana, Michigan, Minnesota, Ohio, or Wisconsin, this is the reporting authority. Contact: R5lecab@epa.gov (listed in the order).
• EPA National Lead Program: Administers the Renovation, Repair and Painting (RRP) Rule under TSCA. Maintains a public database of certified renovators and firms. You can verify whether a contractor working in your pre-1978 home is actually certified before they start the job.
• Illinois EPA: Handles state-level environmental enforcement and may have jurisdiction over parallel state regulations affecting this type of work.
• Peoria City/County Health Department: The local authority for blood lead level screening and childhood lead poisoning follow-up in the areas where these violations occurred. They can connect affected families to testing resources.
• U.S. Department of Justice, Environment and Natural Resources Division: Authorized under 15 U.S.C. § 2615(a) to pursue civil action in federal court if Crawford & Brinkman fails to pay the assessed penalty or violates this order.

What You Can Do Right Now

• If you live in a pre-1978 home in Peoria or anywhere in the country, ask any contractor doing window, door, or surface work for their EPA firm certification number before they touch a wall. Look it up at epa.gov/lead. If they cannot produce it, they cannot legally do the work.
• If you or your child lived at one of the twelve addresses during 2020 to 2022, contact your local health department and request a blood lead level test. These tests are often covered by Medicaid and state children’s health programs. Early detection is the only intervention that matters once exposure has occurred.
• Share the twelve addresses from the federal order with neighborhood associations, tenant unions, and community health organizations in Peoria. The families at those addresses may not know this enforcement action exists. Grassroots notification is the only mechanism currently distributing this information at the local level.
• Report suspected lead safety violations directly to the EPA Region 5 complaint line. The investigation in this case began with an on-site inspection on March 22, 2023. Inspections begin when someone flags a concern. Document what you see, including contractor names, addresses, and dates of work, and submit to the EPA’s enforcement reporting channels.
• Connect with national lead poisoning prevention organizations such as the National Center for Healthy Housing and the Childhood Lead Poisoning Prevention Program, which operate mutual aid networks for affected families navigating the testing and treatment system without resources.