What the $3,800 Doesn’t Cover

There is a family living at 17 Arthur Avenue in Greenville, South Carolina. The EPA’s documents do not name them. The settlement does not describe them. They appear in this story only as the implied consequence of a box left unchecked on a form that was never filled out. But they were there when the work started around April 28, 2024, and they had no idea that the dust being kicked up around them might be laced with lead.

Lead paint was banned from residential use in 1978 because it destroys the developing brain. It lowers IQ. It causes attention disorders, impulse control problems, and lifelong learning disabilities. There is no safe level of exposure for a child under six. There is no treatment that reverses the damage once it is done. The pamphlet that Marchant failed to deliver exists specifically because the federal government decided, decades ago, that people living in old housing deserve to know this before a contractor starts sanding walls in their home.

The pamphlet is called “Renovate Right.” It is a few pages long. Handing it over costs nothing. Getting a signature costs nothing. Being certified to do lead-safe renovation work costs a few hundred dollars and requires a training course. These are not burdensome requirements. They are a baseline minimum, the absolute floor of what it looks like to give a damn about the people whose home you are tearing apart for money.

Marchant Property Management didn’t bother. They were not certified. They did not provide the pamphlet. They did not get an acknowledgment. They did not send it by mail. They did not do a single thing the law required them to do to protect the people inside that house. And when the EPA showed up at their office on East Lee Road in Taylors to check the records, the records confirmed it.

The family at 17 Arthur Avenue may never know this happened. They were not parties to this settlement. They did not receive any portion of the $3,800. They received no notification that the renovation near their children was conducted by an uncertified company that never warned them about the hazard. The settlement is between Marchant and the federal government. The tenants are background scenery.

That is the non-financial ledger: the anxiety a parent might feel if they ever found out; the pediatric blood test that may or may not have been ordered; the developmental milestone that may or may not have been missed. The settlement document is silent on all of it. The only number that mattered to resolve this case was $3,800, and Marchant had thirty days to pay it.

What the Documents Actually Say

Every finding below comes directly from the signed Consent Agreement and Final Order, Docket No. TSCA-04-2026-6100(b), filed with EPA Region 4 on February 25, 2026.

“Respondent had performed, offered, or claimed to perform the renovation at the Property for compensation, and that at the time Respondent performed, offered, or claimed to perform the renovation at the Property, Respondent had not obtained ‘firm certification’ as required by 40 C.F.R. §§ 745.81(a)(2)(ii) and 745.89(a)(1).” — EPA Findings of Facts, Paragraph 19, Docket No. TSCA-04-2026-6100(b)

• This confirms that Marchant was taking money for renovation work in a building that likely contained lead paint, without ever obtaining the federal certification that exists specifically for this scenario. Certification is not optional; it is a legal prerequisite.
• The EPA discovered this through Marchant’s own submitted records, meaning the company’s paperwork confirmed the violation without the EPA needing to prove deception.

“Within 60 days before beginning renovation activities at the Property, Respondent failed to either: (i) obtain from the adult occupant of the Property, a written acknowledgment that the adult occupant received the EPA-approved pamphlet, or to certify in writing that a pamphlet had been delivered to the dwelling and that Respondent had been unsuccessful in obtaining a written acknowledgement from an adult occupant; or (ii) obtain a certificate of mailing at least seven days prior to the renovation of the Property.” — EPA Findings of Facts, Paragraph 20, Docket No. TSCA-04-2026-6100(b)

• Federal law gives firms three ways to comply with the pamphlet requirement: get a signature, certify in writing that you tried and failed to get a signature, or prove you mailed it. Marchant did none of the three. The law did not ask them to choose one hard option; it offered them an easy fallback and a second fallback. They bypassed all of them.
• The 60-day window means Marchant had nearly two months of lead time to deliver a piece of paper. They let all of it pass without action.

“Respondent: neither admits nor denies the factual allegations set forth in Section IV (Findings of Facts) of this CAFO; consents to the assessment of a civil penalty as stated below; waives any right to contest the allegations set forth in Section V (Alleged Violations) of this CAFO; and waives its rights to appeal the Final Order accompanying this CAFO.” — Stipulations, Paragraph 23, Docket No. TSCA-04-2026-6100(b)

• The legal structure of “neither admits nor denies” is a standard corporate shield. Marchant paid the fine and closed the case without ever being forced on record to confirm or deny that they endangered a family. The violation stands in the federal record, but Marchant’s liability was resolved without any public admission of wrongdoing.
• By waiving all appeal rights, Marchant permanently accepted this enforcement action as part of its compliance history, which the document specifies can be used against them in any future enforcement actions.

“To protect the interests of the United States, the rate of interest is set at the IRS standard underpayment rate, as any lower rate would fail to provide Respondent adequate incentive for timely payment.” — Terms of Payment, Paragraph 30(a), Docket No. TSCA-04-2026-6100(b)

• Read this carefully. The EPA’s own settlement document acknowledges that the financial structure of this penalty had to be engineered to give Marchant a reason to pay on time. The question of whether the penalty itself was large enough to deter future violations from Marchant or other property managers goes unaddressed entirely.
• The EPA was focused on ensuring collection of $3,800. The language reveals that the design goal was payment compliance, not behavioral deterrence.

The Damage This Case Represents

Public Health

The violations here are not paperwork infractions. They are failures of the exact system designed to prevent lead poisoning in children, a condition that is irreversible and disproportionately affects low-income renters.

• Lead-based paint is defined under TSCA as hazardous to children under six years of age. The law’s definition of “target housing” specifically calls out that pre-1978 homes are presumed to contain it unless proven otherwise. Marchant’s property at 17 Arthur Avenue was built before 1978 and was legally classified as target housing.
• Renovation activities, including the removal, modification, or repair of painted surfaces, sanding, scraping, and window repair, are all explicitly listed in the federal regulations as activities that generate lead-contaminated dust. Marchant performed this type of work without any of the safety protocols that limit dust exposure to occupants.
• The EPA pamphlet that was never delivered contains specific instructions for families on how to protect children during renovation: staying out of work areas, using wet mopping to control dust, and watching for renovation contractor lead-safe work practices. Without the pamphlet, the occupants of 17 Arthur Avenue had no reason to take any precautions.
• Because Marchant was not certified, there is no assurance that the renovation was conducted using lead-safe work practices at all. Certification training teaches contractors to contain dust, use wet methods, and clean up properly. The absence of certification means these standards may never have been applied.
• Lead poisoning from renovation dust is linked to permanent neurological damage, reduced IQ, behavioral disorders, and impaired academic performance. Children poisoned during early development carry those effects for life, with knock-on costs in special education, healthcare, and the criminal justice system that dwarf any fine Marchant will ever pay.

Economic Inequality

Lead paint violations concentrate in rental housing, and rental housing concentrates among people who cannot afford to buy. The Marchant case is a window into a structural dynamic where the families most likely to live in pre-1978 buildings are the least likely to have legal resources to fight back when those buildings are renovated unsafely.

• Pre-1978 rental housing in cities like Greenville, South Carolina is disproportionately occupied by lower-income families and families of color, communities that already face higher rates of lead poisoning due to older housing stock, and who have fewer options to demand relocation or remediation during a renovation.
• The EPA’s lead renovation rules exist precisely because the market does not protect renters. Landlords profit from renovation work (increasing property value, reducing maintenance costs), while tenants bear the health risk. The pamphlet and certification requirements are one of the few legal tools that shift any responsibility back onto the property manager.
• A $3,800 fine for a property management company operating in South Carolina represents a rounding error. For context, the EPA’s own maximum statutory penalty under TSCA Section 16 is $37,500 per violation per day. The settled amount is a fraction of a single day’s maximum exposure, and Marchant faced multiple violations.
• Tenants in this situation have no private right of action under TSCA. They cannot sue Marchant for these violations themselves. The only enforcement pathway is the EPA, which here concluded the matter for less than the cost of one month’s rent in many Greenville neighborhoods.
• By waiving all appeal rights and paying $3,800, Marchant effectively purchased a closed federal record. No trial. No jury. No public testimony. No day in court for the family at 17 Arthur Avenue.

The Arithmetic of Accountability

Required Process vs. What Marchant Actually Did

Federal law under 40 C.F.R. Part 745, Subpart E, prescribes a clear step-by-step process for any firm renovating pre-1978 housing. Every step below was required. Every step on the right shows what Marchant’s records confirmed actually happened.

Who Is Accountable and What You Can Do

The case is closed, but the company is still operating. Here is who to watch, who to report to, and how to fight back where you live.

Who Signed This Settlement

• Hunter W. Hughey, President of Marchant Property Management, LLC, signed the consent agreement on February 5, 2026, on behalf of the company. His contact information appears in the federal record: hunter@marchantpm.com, (864) 332-9066, 4 East Lee Road, Taylors, South Carolina 29687.
• Keriema S. Newman, Director of the Enforcement and Compliance Assurance Division, EPA Region 4, signed for the EPA. The order was also digitally signed by Kimberly Bingham on February 19, 2026.
• Regional Judicial Officer Dwana King issued the Final Order on February 19, 2026, ratifying the settlement under 40 C.F.R. §§ 22.4(b) and 22.18(b)(3).

Watchlist: Regulatory Bodies That Cover This

• EPA Region 4 (covers South Carolina): The office that brought this case. File renovation complaints at epa.gov/enforcement or call the Region 4 tip line. Case contact on record: Mathew Rouse, rouse.mathew@epa.gov, (404) 562-8522.
• EPA Lead Program (National): The EPA’s Office of Chemical Safety and Pollution Prevention enforces the Lead Renovation, Repair, and Painting (RRP) Rule nationally. Report violations at epa.gov/lead.
• South Carolina Department of Health and Environmental Control (DHEC): The state-level agency that may have authority over lead-paint housing conditions and tenant health complaints in South Carolina.
• South Carolina Attorney General: Tenant protection violations and consumer fraud complaints can be filed through the AG’s Consumer Protection Division if you believe a property management company misrepresented safe practices.
• HUD Office of Lead Hazard Control and Healthy Homes: Covers federally assisted housing. If any portion of Marchant’s properties involves HUD-assisted tenants or Section 8 vouchers, HUD has overlapping jurisdiction and separate enforcement authority.

Direct Actions for Renters and Community Members

• If you are a tenant in a pre-1978 rental in South Carolina and a contractor begins work in your unit, demand to see the contractor’s EPA RRP certification before they start. Ask them for the “Renovate Right” pamphlet in writing. Document your request by email or text.
• Contact a local legal aid organization immediately if a landlord refuses. In South Carolina, organizations such as the SC Legal Services network provide free legal assistance to low-income renters facing housing hazards.
• Request a lead inspection from your local health department, particularly if children under six live in the home and renovation work has occurred without the required warnings. Blood lead level testing for children is often covered under Medicaid and CHIP.
• File a complaint directly with EPA Region 4 if you believe a property management company in South Carolina, Georgia, Florida, Alabama, Mississippi, Tennessee, Kentucky, or North Carolina has violated lead-safe renovation rules. Complaints do result in inspections; this case is proof of that.
• Organize with neighbors in older rental buildings. Collective complaints from multiple tenants in the same building or managed by the same company carry more weight with regulators and make it harder for agencies to settle cases quietly.
• Share this federal enforcement record. Docket No. TSCA-04-2026-6100(b) is a public document. Marchant Property Management, LLC of Taylors, South Carolina, now has a permanent federal enforcement record for lead-paint violations. Future tenants deserve to know it exists.