A contractor in Lafayette, Indiana walked into a pre-1978 home knowing a toddler with an elevated blood lead level lived there, ripped out the windows anyway, scattered paint chips and toxic dust across the floors and the yard, and left without a single safety measure in place.
Filed: June 6, 2024 | EPA Region 5 | Lafayette, IndianaA Child Was Already Poisoned. He Kept Going Anyway.
On or around January 16 through January 31, 2022, JLG Property Investments, LLC — doing business as JLG Contracting and Renovation, LLC, owned by Jordan Glick — performed window replacement work inside a single-family residence at 1520 Central Avenue, Lafayette, Indiana. The house was built in 1930. Any contractor with even a passing familiarity with federal law knows that pre-1978 housing is “target housing” under EPA regulations, meaning it is presumed to contain lead-based paint and is subject to strict safety rules before anyone touches a painted surface.
The Indiana Department of Health filed a tip with the EPA on February 3, 2022. That complaint included a detail that transforms this story from a paperwork violation into something much darker: a child under the age of six, with an already-elevated blood lead level, lived in the home. The EPA’s complaint states that Glick was aware of both facts — that the renovation would disturb lead paint, and that a poisoned child lived in the house — before the work began. He sent his crew in anyway.
The Indiana Department of Health provided 16 photographs as evidence. Those images documented paint chips, dust, and debris scattered across the interior of the residence and on the ground outside. This was the aftermath of a renovation conducted with zero containment, zero cleanup protocol, and zero certified personnel. The family — including that child — went home to that.
— EPA Complaint, Paragraph 36
Seven Ways He Broke the Law in One Job
Federal regulations under the EPA’s Renovation, Repair, and Painting (RRP) Rule exist precisely because Congress determined in 1992 that up to 3,000,000 children under age six were being poisoned by lead dust stirred up during home renovations. The rules require firms to be certified, workers to be trained, tenants and owners to receive written hazard warnings before work starts, and detailed records to be kept. JLG violated every single one of these requirements in a single job.
Maximum Penalty Exposure Per Violation — $48,512 Each
The Non-Financial Ledger: What Money Doesn’t Cover
Public Health Environmental JusticeThe family living at 1520 Central Avenue was a tenant household. They did not own the property. They had no power to choose who came to renovate it. They had no ability to demand that the contractor be certified. Under the law, the contractor — JLG — was required to hand them an EPA pamphlet called “Renovate Right” before a single window frame was touched, so they could understand the risks and take precautions. That pamphlet was never delivered. The occupant never received written notice. The tenant family never had the chance to prepare, to leave, to cover their furniture, to keep their child out of the room. That choice was taken from them.
The child in this story already had elevated blood lead levels before the renovation began. This is an extraordinarily important detail. Elevated blood lead levels in a young child are not a temporary condition that clears up with fresh air. Lead damages the developing brain at the cellular level. According to Congress’s own findings, codified in the statute the EPA is enforcing here, lead poisoning in children causes intelligence deficiencies, reading and learning disabilities, impaired hearing, reduced attention span, hyperactivity, and behavior problems. In severe cases, it causes seizures, coma, and death. Every additional dose of lead dust that child breathed or ingested after JLG’s crew tore out those windows compounded an injury that was already in progress. There is no undo. There is no refund.
The EPA’s own policy document — the Consolidated Enforcement Response and Penalty Policy that governs how penalties are calculated — describes a specific category of violation it labels “egregious.” The definition is precise: an egregious violation is one where a firm or renovator failed to follow any work practice standard, including containment, cleanup, or post-cleanup verification, or used prohibited or restricted practices which resulted in a paint, dust, or soil lead hazard in target housing where a pregnant woman or child under 6 resided. What happened at 1520 Central Avenue matches that definition exactly. The EPA’s policy explicitly states that in egregious situations, the agency reserves the right to seek a penalty that might exceed the respondent’s ability to pay, might cause bankruptcy, and might result in the respondent’s inability to continue in business. That is not a threat buried in fine print. That is the agency’s own language applied to situations like this one.
There are also the photographs. The Indiana Department of Health submitted 16 images to the EPA documenting the aftermath inside and outside the residence: paint chips, dust, and debris. Sixteen photographs of the aftermath of someone else’s negligence left behind in a family’s living space. That family had to come home to that. The child who already carried too much lead in their bloodstream lived in that. The images do not appear in this complaint as a footnote — they were submitted as formal evidence of harm. The government of the United States looked at those photographs and decided this warranted federal enforcement. That threshold matters. Regulatory agencies receive thousands of tips annually. This one rose to a civil administrative complaint under a federal toxic substances law. That tells you something about what those 16 photographs showed.
Legal Receipts: Straight From the Government’s Mouth
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; and the ingestion of household dust containing lead from deteriorating or abraded lead-based paint is the most common cause of lead poisoning in children.
— EPA Complaint, Paragraph 4, citing the Residential Lead-Based Paint Hazard Reduction Act of 1992According to the information in the tip/complaint, Respondent completed the renovation without utilizing any lead safe work practices. The tip/complaint also suggested a child under the age of six years and with an elevated blood lead level lived at the home. The tip/complaint stated that Respondent was aware both that the renovation would involve lead paint and that a child with an elevated blood lead level lived at the home where renovation was planned.
— EPA Complaint, Paragraph 36In January 2024, EPA requested that Respondent provide additional financial information so that a complete ability to pay analysis could be conducted. EPA requested full-year internal financial statements for the past two years including a profit and loss statement, balance sheet as of the beginning and end of the year, and a statement of cash flows. Despite repeated extensions for submittal, Respondent has not submitted this information and is no longer cooperative with the Complainant’s attempts to settle this matter.
— EPA Complaint, Paragraph 76Lead poisoning in children, including poisoning in-utero, causes intelligence quotient deficiencies, reading and learning disabilities, impaired hearing, reduced attention span, hyperactivity and behavior problems. In severe cases it may lead to seizures, coma, and death. In as many as 38 million homes in the United States, children’s health is endangered by lead-based paint and/or lead-based paint hazards. Lead in housing and child-occupied facilities remains the most important source of lead exposure for young children and pregnant women.
— EPA Consolidated Enforcement Response and Penalty Policy, Section 3.IV, Gravity-Based PenaltyAn example of an egregious situation would be where a firm or individual renovator failed to follow any work practice standard, including containment, cleanup, or post-cleanup verification, or used prohibited or restricted practices which resulted in a paint, dust, or soil lead hazard in target housing where a pregnant woman or child under 6 resided or in a child occupied facility.
— EPA Consolidated Enforcement Response and Penalty Policy, Section 3.V, Footnote 32— EPA Consolidated Enforcement Response and Penalty Policy, Section 3.V
Societal Impact: Who Pays When Contractors Dodge the Rules
Public Health: Lead Has No Safe Dose for a Child
The medical science on childhood lead poisoning is not contested. The CDC, Congress, and the EPA all agree: there is no known safe level of lead in a child’s blood. Lead is a neurotoxin. Once it enters a developing nervous system, the damage it causes is permanent. The violations committed by JLG did not just break regulatory rules — they created the precise conditions under which additional lead exposure would occur in a child who was already suffering from its effects. The renovation involved window replacement in a 1930s home. Older single-pane wooden windows are among the highest-risk lead-paint surfaces in pre-1978 housing because their edges are subject to repeated friction, which generates fine lead dust every time a window is opened or closed. Ripping them out without containment, without wet methods, without HEPA vacuuming, without protective coverings over floors and surfaces, generates enormous quantities of airborne and settleable lead dust. That dust disperses through the home. It settles on food preparation surfaces, on toys, on floors where toddlers crawl and play. Hand-to-mouth behavior — which is completely normal in children under six — then delivers that dust directly into the child’s body.
The EPA’s own penalty policy identifies children under six and pregnant women as the highest-priority protected populations under these regulations. The “extent” factor in the penalty calculation matrix is rated “Major” whenever the agency knows a child under six resides in the home. Major is the highest possible extent category, meaning the potential for harm is classified as “potential for serious damage to human health.” In this case, the EPA did not have to guess whether a child under six was present. It knew. The Indiana Department of Health’s tip stated it explicitly. The child already had elevated blood lead levels. JLG knew this too. The EPA complaint says so in paragraph 36. This was not a case of an uninformed contractor making a paperwork mistake. This was a contractor who possessed material knowledge of a child’s medical vulnerability and proceeded regardless.
Economic Inequality: Tenants Bear the Consequences That Owners and Contractors Skip
The household at 1520 Central Avenue was a tenant household. The owner of the property lived elsewhere — confirmed by Count 3 of the complaint, which notes that “the Residence was not occupied by the owner, but was occupied by a tenant.” This fact is not incidental. It sits at the center of why lead-paint regulations exist and who they are designed to protect. Homeowners who choose to renovate their own property have leverage: they hire the contractor, they set the schedule, they can demand certifications, they can refuse unsafe work. Renters have none of that. The landlord hires the contractor. The tenant lives with the result.
The Renovate Right pamphlet requirement exists specifically to give tenants information they otherwise would not have access to. It is the law’s mechanism for bridging the power gap between a contractor working on orders from a landlord and a family living in the space being renovated. JLG bypassed that mechanism entirely. Neither the owner nor the occupant received the pamphlet or written acknowledgment of its receipt. Both were legally required. Both were skipped. The family had no idea what their rights were, what risks they faced, or what they could demand. That is not an accident of circumstance. That is the predictable outcome when contractors calculate that the cost of compliance — getting certified, hiring trained workers, doing the paperwork — is more inconvenient than the probability of getting caught.
The economic inequality dimension extends further. The EPA’s penalty policy explicitly addresses the reality that many renovation contractors are small firms or sole proprietors. The policy says these smaller operators are assumed to have less familiarity with lead safety regulations than larger companies. That assumption is used to calibrate penalties, not to excuse violations. JLG is a limited-liability company — a legal structure that, by design, shields the personal assets of Jordan Glick from the financial consequences of the company’s conduct. The family in the house had no LLC protecting them from the health consequences of JLG’s choices. The asymmetry could not be more stark: the contractor has legal structures insulating him from financial harm; the tenant family has no corresponding insulation from the bodily harm he caused.
The “Cost of a Life” Metric
Timeline: From Renovation to Federal Complaint
The EPA provided all 102 pages of this legal complaint here for your reading pleasure: https://yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings/338DF534ADA5936785258B34005D80FD/$File/TSCA-05-2024-0012_Complaint_JLGPropertyInvestmentsLLC_LafayetteIN_102PGS.pdf
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