One of the largest apartment management companies in the United States sent workers into pre-1978 homes to sand, scrape, and disturb painted surfaces — work that can release lead dust — without federal certification, without trained personnel, and without telling the families living there that they were at risk.

The Landlord in Your Building

Greystar Real Estate Partners is one of the biggest residential property managers in the world. Their Southeast subsidiary, GREP Southeast, LLC, manages apartment communities across Georgia, Florida, North Carolina, and South Carolina. These are everyday rentals: buildings where working-class families, young people, and seniors live.

Many of those buildings were built before 1978. That year matters because federal law recognizes it as the cutoff for lead-based paint risk. Any home built before 1978 is legally classified as “target housing” — meaning it requires specific disclosures, warnings, and certified renovation practices before anyone picks up a scraper or a sander inside it.

Greystar knew this. They operate at a scale that demands compliance infrastructure. Instead, the EPA found that their workers entered dozens of apartments and performed renovation work that disturbs painted surfaces — the exact work that releases lead dust into the air families breathe — without certification, without training, and without warning the residents.

The Violations by the Numbers

The EPA documented two categories of misconduct: failures during the leasing process (not disclosing lead hazards to new tenants) and failures during renovation work (no certification, no trained workers, no resident warnings). The chart below maps the full scope.

The Non-Financial Ledger

The Families Who Were Never Warned

Between July 1, 2021, and July 31, 2022, Greystar sent workers into at least 17 apartment units in Clearwater, Florida; Fort Myers, Florida; and Greenville, South Carolina, to perform renovations in buildings constructed before 1978. These renovations involved the kinds of work that generate lead dust: modifying painted surfaces, repairing painted components, sanding, scraping, and disturbing walls and ceilings that may have accumulated decades of lead-based paint underneath newer coats.

None of the residents in those units received the EPA-required pamphlet — “Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools” — before the work began. That pamphlet exists for one reason: to give families the information they need to protect themselves and their children from lead exposure during and after renovation work. Lead dust does not stay in the walls. It settles on floors, on countertops, on toys. Children absorb it through their hands and mouths. There is no safe level of lead exposure for children under six.

At the Clearwater property alone — 19135 US Highway 19 North — Greystar performed renovations in at least ten units: I02, I10, F17, J14, B10, F36, G22, H17, F7, and others. In the Greenville property at 1 East Main Street, renovations occurred in at least six units: 1110, 1117, 1201, 1205, 1238, and 1466. Two more units at 2346 Winkler Avenue in Fort Myers were also impacted. The EPA found that for the first eleven of these renovation sites, Greystar failed to ensure that the individuals performing the work were either certified renovators or had been trained by a certified renovator.

Separate from the renovation violations, Greystar also failed 16 households at the lease-signing stage across Georgia, Florida, North Carolina, and South Carolina. These were new tenants moving into pre-1978 apartments who signed leases without receiving legally required lead hazard disclosures. Their leases did not include the required statement confirming they had received lead hazard information. They did not receive confirmation that Greystar, as the agent, had even informed the building owner of their legal obligations. These families moved into homes where the legal framework protecting them from lead exposure had been quietly skipped. They signed their names to contracts and received keys. Nobody told them what might be in the walls.

Legal Receipts: Straight From the Document

What the EPA Put in Writing

“The records submitted by Respondent failed to document that prior to performing the renovation work at the Properties, Respondent had: Obtained ‘firm certification’ as required by 40 C.F.R. §§ 745.81(a)(2)(ii) and 745.89(a)(1); Provided the owner or adult occupant of the target housing with an EPA-approved pamphlet as required by 40 C.F.R. § 745.84(a)(1); and Ensured that all individuals performing renovation activities on behalf of the firm were either certified renovators or had been trained by a certified renovator.”

— EPA Findings of Fact, Section IV, Paragraph 34

“The records submitted by Respondent to the EPA failed to document that prior to entering into the leases referenced in Paragraph 30, Respondent had: Included as an attachment or within the contract to lease target housing, a statement by the lessee affirming receipt of the information required by 40 C.F.R. § 745.113(b)(2) and 40 C.F.R. § 745.113(b)(3), and the lead hazard information pamphlet required by 15 U.S.C. § 2686.”

— EPA Findings of Fact, Section IV, Paragraph 31

“This CAFO constitutes an enforcement action for purposes of considering Respondent’s compliance history in any subsequent enforcement actions.”

— Stipulations, Section VI, Paragraph 39(b)

“The provisions of this CAFO shall apply to and be binding upon Respondent and its officers, directors, employees, agents, trustees, authorized representatives, successors, and assigns.”

— Effect of the CAFO, Section VIII, Paragraph 54

“Nothing herein shall be construed to limit the power of the EPA to undertake any action against Respondent or any person in response to conditions that may present an imminent hazard as provided under the Act.”

— Effect of the CAFO, Section VIII, Paragraph 52

A Fine That Barely Registers

The $140,200 (enough to cover two years of groceries for roughly 28 average American families, or about 1.4 years of median U.S. household income) penalty Greystar agreed to pay covers violations across four states, 33 total documented violation instances, and at least two full years of documented misconduct. The chart below maps the timeline of violations.

Societal Impact: Who Gets Hurt When Rules Are Skipped

Public Health: The Lead Problem Has No Cure

Lead is a neurotoxin. There is no antidote. Once a child absorbs lead — through inhaled dust, through hand-to-mouth contact with contaminated surfaces — the neurological damage is permanent. The CDC and EPA have both stated that no level of lead exposure is safe for children under six. Federal lead renovation rules exist precisely because the act of sanding, scraping, and disturbing old painted surfaces generates the invisible fine dust that families inhale and ingest without knowing it.

Greystar sent workers into at least 17 pre-1978 apartment units to do exactly this kind of work — surface disturbance renovations — without ensuring those workers knew lead-safe work practices. For the first eleven renovation sites the EPA specifically flagged (Clearwater and Greenville locations), the company failed to confirm workers were certified renovators or trained by a certified renovator. Uncertified workers routinely skip containment, fail to use HEPA vacuums, and do not clean work areas to the standard required to prevent lead dust from spreading into the rest of the living space.

The residents in those apartments were never given the “Renovate Right” pamphlet. They had no way of knowing they should take extra precautions, relocate children during the work, or clean surfaces more thoroughly afterward. The public health protection chain that federal law built for exactly these situations — old buildings, renovation work, families present — Greystar broke every link in it.

Economic Inequality: The Buildings Tell You Who Pays the Price

Pre-1978 housing is disproportionately concentrated in lower-income communities and communities of color. It is the housing stock that working-class renters occupy because it is older and cheaper. Greystar — a massive institutional landlord — manages these properties at scale. The tenants signing leases at addresses like 2346 Winkler Avenue in Fort Myers, 19135 US Highway 19 North in Clearwater, and 1 East Main Street in Greenville are not wealthy renters with a dozen housing options. They are people for whom this apartment, this lease, this unit is the one they could afford.

When Greystar skips lead disclosures at signing, those tenants move in without knowledge they are legally entitled to have. They cannot make an informed decision about whether to negotiate additional cleaning, request lead testing, or choose a different unit. The information asymmetry Greystar created by skipping required disclosures across 16 lease transactions across four states compounds the existing disadvantage already faced by renters in older, lower-cost housing.

The $140,200 (enough to pay a full year of rent for roughly 12 average American renter households) settlement Greystar paid to the EPA does not flow to the tenants who were denied disclosures. It does not fund medical screening for the children who lived in the renovated units. It goes to the federal government as a civil penalty. The families most harmed by these violations receive nothing from this settlement.

The “Cost of a Life” Metric

What Now?

Named in the Document

The settlement was signed on behalf of Greystar by Jamie Teabo, Senior Managing Director, Real Estate, East Territory, at 545 Peachtree Street NE, Suite 700, Atlanta, GA 30309. The settlement agreement explicitly states its terms bind “officers, directors, employees, agents, trustees, authorized representatives, successors, and assigns.” Any corporate restructuring or ownership change does not erase these obligations.

Watchlist: Who Has Jurisdiction

• EPA Region 4 — enforces TSCA lead renovation rules in GA, FL, NC, SC; this case remains on compliance record for future enforcement considerations
• EPA Office of Enforcement and Compliance Assurance — national oversight of Toxic Substances Control Act violations
• HUD (Department of Housing and Urban Development) — enforces lead disclosure requirements in federally assisted housing
• CFPB (Consumer Financial Protection Bureau) — tracks landlord practices affecting housing consumers
• State Attorneys General (GA, FL, NC, SC) — can pursue state-level consumer protection and housing code violations independently of federal EPA action
• State Health Departments — can conduct lead testing and blood-level screening in affected communities

What You Can Do Right Now

If you rent from Greystar and live in a pre-1978 building, you have the legal right to request lead disclosure records and renovation compliance documentation. If your landlord cannot produce them, contact your state’s housing authority and your local EPA regional office. Connect with local tenant unions and housing justice organizations — groups like tenant advocacy coalitions in Atlanta, Clearwater, Fort Myers, Greenville, and Raleigh are already fighting these exact battles. Mutual aid networks can help you navigate lead testing resources, legal aid referrals, and tenant rights clinics. Greystar counts on renters not knowing what they are entitled to. You knowing changes the math.