EvilCorporations.com • Docket No. TSCA-04-2024-6109(b) • 24 min read

They Were Only Fined $31,800 After Renting Houses Containing Lead Paint

A South Carolina property management company leased seven pre-1978 homes to families without disclosing known or potential lead paint hazards and performed renovation work without the required federal certification. The penalty: less than the monthly rent on the properties they manage.

Seven Homes. Seven Failures. One Inspection.

On November 7, 2023, an EPA inspector walked into Copper Roof Property Management’s office at 1240 Winnowing Way, Suite 102, Mount Pleasant, South Carolina. What the records showed confirmed what the agency suspected: a systematic absence of every required lead-paint disclosure document across every rental transaction reviewed.

• 704 A Martin Lane, Charleston, SC 29407: Built 1975. Lease signed October 1, 2023. No lead warning statement, no disclosure, no pamphlet, no signed receipt from the tenant.
• 4729 Marlboro Place, North Charleston, SC 29405: Built 1941. Lease signed August 1, 2023. Same complete absence of required documentation.
• 6212 Murray Drive, Hanahan, SC 29410: Built 1977. Lease signed August 1, 2023. No lead hazard information provided to the incoming tenant.
• 704 B Martin Lane, Charleston, SC 29407: Built 1975. Lease signed July 1, 2023. Another tenant moved into a pre-1978 home without a single required disclosure document.
• 862 Lolandra Avenue, Charleston, SC 29407: Built 1933. Lease signed July 1, 2023. A home over 90 years old, potentially containing decades of accumulated lead paint, rented without disclosure.
• 4923 Victoria Avenue, North Charleston, SC 29405: Built 1958. Lease signed June 15, 2023. A 65-year-old structure rented without any lead paint hazard warning.
• 805 Castle Avenue, Charleston, SC 29407: Built 1940. Lease signed June 1, 2023. This property was also the site of renovation work performed without EPA certification in October 2022.

The law triggering these obligations is not obscure. The Residential Lead-Based Paint Hazard Reduction Act of 1992 and EPA regulations at 40 C.F.R. Part 745 require landlords of pre-1978 housing to complete five specific steps before any lease is signed:

• Provide the tenant with the EPA’s “Protect Your Family From Lead in Your Home” pamphlet before any lease obligation begins.
• Include a federally mandated Lead Warning Statement in every lease contract, reading explicitly that pre-1978 housing may contain lead-based paint and that exposure is especially harmful to young children and pregnant women.
• Disclose any known lead-based paint or hazards in writing, or state in writing that none are known.
• List any records or reports related to lead hazards that have been provided to the tenant.
• Obtain signatures from the landlord, the tenant, and any agents certifying compliance with all the above steps.

Copper Roof’s records demonstrated failure on all five counts, across all seven properties.

Renovation Work, No Certification, No Lead Pamphlet Provided

Beyond the leasing violations, the EPA found that Copper Roof was performing paid renovation work on pre-1978 homes without the federal certification that is required specifically because renovations disturb painted surfaces and create lead dust.

• 805 Castle Avenue, Charleston, SC: Renovation work performed on or about October 3, 2022. This is the same property where a lease was later signed on June 1, 2023, without lead disclosures.
• 1523 A Theresa Drive, Charleston, SC 29412: Renovation work performed on or about March 2, 2022.
• At the time of both renovations, Copper Roof had not obtained EPA firm certification as required under 40 C.F.R. §§ 745.81(a)(2)(ii) and 745.89(a)(1). Firm certification requires companies to demonstrate their renovators have been trained in lead-safe work practices.
• Copper Roof also had no records showing the property owners were given the EPA-approved “Renovate Right” pamphlet, which is required to be delivered no more than 60 days before renovation begins and must be acknowledged in writing by the owner at least 7 days before work starts.

Renovating a pre-1978 home without certification means the people doing the work may have had no training in containing lead dust, properly disposing of debris, or protecting occupants of neighboring units. Lead dust created during window replacement, surface scraping, or wall removal does not stay in the room where the work happens.

The Timeline: From Renovation to Inspection

What This Actually Cost the People Who Lived There

The legal documents in this case deal in paperwork: missing signatures, absent pamphlets, unchecked boxes. The language is clinical. It does not describe what happens inside the body of a two-year-old who ingests lead dust from a 90-year-old window sill that was never disclosed, never tested, and never properly contained during a renovation performed by a company that was not certified to do the work.

Consider 862 Lolandra Avenue in Charleston. Built in 1933. That structure stood through the New Deal, World War II, and every decade of American life since. By the time a family signed a lease there on July 1, 2023, the home was 90 years old. According to federal law, the landlord was required to disclose whether they knew of any lead paint hazards, hand over an EPA pamphlet explaining the risks, and get a signature confirming the family had received that information. None of that happened. A family moved into a 90-year-old home without knowing what they might be exposing themselves or their children to.

The same story played out six more times across Charleston and North Charleston between June and October 2023. Seven families, seven sets of neighbors, and any visitors or children spending time in those homes were denied the basic right to make an informed decision about where they were living. The law does not require that lead paint be present. It requires disclosure of what is known. Copper Roof denied tenants even that. The company did not even put in writing that it did not know about any hazards. The required “no knowledge” statement was absent alongside the required positive disclosure. Tenants were given nothing.

For renovation workers, the picture is different but no less serious. At both 805 Castle Avenue and 1523 A Theresa Drive, Copper Roof performed paid renovation work without the EPA certification that signals a company has trained its workers in lead-safe practices. Renovation disturbs painted surfaces. Sanding, scraping, cutting, and demolition create lead dust that settles on floors, in vents, in carpet fibers, on counters, and in the lungs of workers who are in the room. The federal certification program exists because the industry itself had a well-documented history of workers and residents being poisoned by renovation dust. Copper Roof bypassed that system entirely.

Lead has no safe level of exposure for children. The CDC acknowledges there is no blood lead level that has been proven to be without harmful effects. Developmental damage, reduced IQ, behavioral problems, and learning disabilities linked to lead exposure are permanent. They do not resolve when the family moves out. They do not disappear when the EPA closes a case. The $31,800 penalty paid by Copper Roof Property Management does not fund a single blood test, does not pay for a single developmental evaluation, and does not reach any family that may have been harmed.

The people who signed those leases trusted that a professional property management company was handling their housing legally and transparently. That trust was misplaced. They were not told what they had a legal right to know. And the federal settlement that closed this case was paid to the United States Treasury, not to them.

Straight From the Document: What the EPA Found and What Copper Roof Agreed To

Every quote below is taken verbatim from Docket No. TSCA-04-2024-6109(b), the Consent Agreement and Final Order signed August 19, 2024.

“The records provided by Respondent to the inspector failed to demonstrate that prior to entering into the leases referenced in Paragraph 34, Respondent had: [a] Included as an attachment or within the contracts to lease target housing the appropriate Lead Warning Statement… [b] Included… a statement by the lessor disclosing the presence of known lead-based paint and/or lead-based paint hazards… [c] Included… a statement by the lessee affirming receipt of the information… [d] Included… a statement by the agents… [and e] Included… the signatures of the lessors, agents, and lessees.”

• This quote documents that every single required disclosure element was absent from every single lease reviewed. This is not one missed checkbox; it is a complete failure to implement the federal lead disclosure framework across the company’s rental operations.
• The five items listed (a through e) correspond to five separate regulatory requirements under 40 C.F.R. § 745.113(b). Each one is an independently enforceable violation. With seven properties affected, the EPA identified up to 35 individual leasing violations in total.

“The records provided by Respondent showed that at the time that the renovation work was being performed at the Properties, Respondent had not obtained ‘firm certification’ as required by 40 C.F.R. §§ 745.81(a)(2)(ii) and 745.89(a)(1).”

• This is an admission by Copper Roof’s own submitted records that the company knew it lacked the required federal certification and performed paid renovation work anyway on pre-1978 properties.
• Firm certification under 40 C.F.R. § 745.89 requires companies to apply to the EPA and demonstrate that their workers have completed accredited lead-safe renovation training. Performing this work without certification means there is no verified record that any worker on those jobs knew how to contain lead dust.

“Respondent: a. admits that the EPA has jurisdiction over the subject matter alleged in this CAFO; b. neither admits nor denies the factual allegations set forth in Section IV (Findings of Facts) of this CAFO; c. consents to the assessment of a civil penalty as stated below… e. waives any right to contest the allegations set forth in Section V (Alleged Violations)… f. waives its rights to appeal the Final Order.”

• Copper Roof paid $31,800 and walked away. The “neither admits nor denies” language is standard in EPA consent agreements and means the company closed the case without a public acknowledgment of wrongdoing, despite the factual record in the same document documenting the violations in detail.
• By waiving the right to appeal, Copper Roof ended any chance of a public hearing or further scrutiny of the facts. The case was over the moment the final order was signed on August 19, 2024, by Regional Judicial Officer Robin Allen.

“Respondent is assessed a civil penalty of THIRTY-ONE THOUSAND, EIGHT HUNDRED DOLLARS ($31,800) which shall be paid within thirty (30) days after the Effective Date of this CAFO.”

• $31,800 divided across seven properties equals approximately $4,543 per property. Each property had up to five disclosure violations. Per violation, the penalty averages roughly $909, a figure dramatically below the statutory maximum allowed under TSCA for knowing violations.
• The penalty does not go to affected tenants. It goes to the U.S. Treasury. The families who were denied disclosures receive no portion of this settlement.

“By executing this CAFO, certifies to the best of its knowledge that Respondent is currently in compliance with all relevant requirements of 40 C.F.R. Part 745, Subparts E and F, and the Act, and that all violations alleged herein, which are neither admitted nor denied, have been corrected.”

• Copper Roof certified compliance going forward, but the EPA’s verification of this compliance rests primarily on Copper Roof’s own self-reporting. The settlement includes no independent audit requirement, no third-party inspection, and no ongoing monitoring obligation specified in the document.
• The “neither admitted nor denied” framing sitting inside this compliance certification creates a logical tension the document never resolves: the company simultaneously says the violations are corrected and that it does not admit they occurred.

What the Law Required vs. What Tenants Actually Got

Public Health: Lead Is a Permanent Poison With No Minimum Safe Dose

Lead paint violations are not paperwork violations. They are public health violations. The disclosure requirements exist because lead exposure causes irreversible neurological damage, and the people most at risk are the least able to protect themselves.

• The CDC has established that there is no identified safe blood lead level in children. Even low levels are associated with cognitive impairment, reduced IQ, attention and behavioral disorders, and impaired academic performance. These effects do not reverse when exposure ends.
• Children under six are the highest-risk group because they absorb lead more efficiently than adults and because their brains and nervous systems are still developing. The Lead Warning Statement Copper Roof failed to include in its leases explicitly names young children as especially vulnerable. Tenants with young children moved into seven pre-1978 homes without that warning.
• Lead paint in pre-1978 homes deteriorates over time into dust and chips, which settle on floors where toddlers crawl, on surfaces they touch, and in soil around the exterior. The 1933-built property at 862 Lolandra Avenue and the 1940-built property at 805 Castle Avenue represent the highest-risk tier due to the volume of years lead paint was applied and the likelihood of deterioration.
• Renovation dust is one of the most acute lead exposure pathways. Sanding, scraping, and disturbing old painted surfaces sends fine lead particles airborne. The EPA’s Renovation, Repair, and Painting Rule (RRP Rule) exists specifically because renovation of pre-1978 housing caused documented spikes in children’s blood lead levels in surrounding homes. Copper Roof’s uncertified renovators may have created exactly these conditions at 805 Castle Avenue and 1523A Theresa Drive.
• Pregnant women are a second named high-risk group in the federal Lead Warning Statement Copper Roof omitted. Lead crosses the placental barrier and can harm fetal brain development. A pregnant woman who signed one of these leases would have had no federally mandated warning that the home she was entering carried this risk category.

Economic Inequality: Lead Poisoning Is a Housing Market Problem Concentrated on Lower-Income Renters

Pre-1978 rental housing is disproportionately occupied by lower-income tenants who have fewer options in the housing market. The lead disclosure rules exist in part because this population has the least power to negotiate for safer housing or walk away from a lease that lacks required documentation.

• Renters in the Charleston and North Charleston areas who are seeking affordable housing are more likely to encounter pre-1978 stock because older housing is generally priced lower. The seven properties span neighborhoods across Charleston, North Charleston, and Hanahan, representing accessible-price-tier rental markets.
• Tenants who were never given the EPA lead hazard pamphlet did not know they had the right to request records about lead paint testing or prior inspections. Without the required disclosure documents, they also could not make an informed decision to hire their own inspector before signing. The information asymmetry is entirely structural: the landlord knew the property’s age and history; the tenant knew only what the landlord chose to share.
• Medical costs associated with lead poisoning, including blood tests, specialist evaluations, cognitive assessments, and long-term educational support for affected children, fall on families, not on the property management company that failed to disclose. The $31,800 penalty paid by Copper Roof does not cover a single such cost.
• The settlement structure itself reflects the economic dynamic. Copper Roof signed a consent agreement that closed the federal civil penalty case. Tenants have no automatic standing under this enforcement action and receive no notification through the CAFO process that they may have been exposed to lead paint hazards without disclosure.

The Price the Government Put on Seven Families’ Right to Know

What Now: How Tenants, Neighbors, and Organizers Can Push Back

The EPA closed its case, but the obligation to protect people in pre-1978 rental housing does not close with it. Here is who is responsible for ongoing oversight and what you can do.

Leadership Named in This Case

• Jennifer Procter, Owner: Named in the Certificate of Service as the respondent’s contact. Email: jen@copperprop.com. Phone: 843-763-1130. Operating as Copper Roof Property Management, LLC, 1240 Winnowing Way, Suite 102, Mount Pleasant, South Carolina 29466.
• Keriema S. Newman: Director, Enforcement and Compliance Assurance Division, EPA Region 4. Signed the Consent Agreement on behalf of the EPA on August 16, 2024.
• Robin Allen: Regional Judicial Officer, EPA Region 4. Issued the Final Order on August 19, 2024.
• Yvonne Lawson, CDO, EPA Region 4: The EPA contact named for ongoing compliance. lawson.yvonne@epa.gov, 404-562-9205.

Watchlist: Regulatory Bodies With Jurisdiction

• EPA Region 4 (Atlanta): Primary enforcer. This case is now part of Copper Roof’s compliance history under 40 C.F.R. § 22.18. Any future violation should be reported at: epa.gov/enforcement/forms/report-environmental-violations or directly to lawson.yvonne@epa.gov.
• HUD (U.S. Department of Housing and Urban Development): HUD enforces the same Title X lead disclosure laws in federally assisted housing. If any of these properties receive housing assistance vouchers (Section 8/HCV), HUD has concurrent jurisdiction.
• South Carolina Department of Health and Environmental Control (DHEC): South Carolina’s state health authority can investigate lead hazards in rental housing. DHEC also maintains a childhood blood lead surveillance program.
• South Carolina Real Estate Commission: Property management companies operating in South Carolina are subject to real estate licensing requirements. License complaints can be filed if a licensee fails to meet legal disclosure obligations.
• DOJ (U.S. Department of Justice): Under Section 53 of this CAFO, EPA explicitly preserved its right to pursue injunctive or criminal sanctions independent of the civil penalty settlement. DOJ civil rights division handles housing discrimination enforcement.

What You Can Actually Do

• If you rent a pre-1978 home: You are legally entitled to a Lead Warning Statement in your lease, the EPA “Protect Your Family From Lead in Your Home” pamphlet, and a written disclosure of any known lead hazards. If these were missing from your lease, you may have grounds for a complaint to EPA Region 4 and your state housing authority. Document everything now.
• Request a lead risk assessment: Tenants can hire a certified lead risk assessor independently. The EPA’s National Lead Information Center at 1-800-424-LEAD can help locate certified assessors in your area. South Carolina also maintains a list through DHEC.
• Get your children tested: Blood lead testing is covered by Medicaid for children under 6 and is recommended by the CDC for children in pre-1978 housing. Your pediatrician can order this test. If results show elevated lead levels, document the housing conditions and consult a tenant’s rights attorney.
• Connect with local tenant organizing: Charleston-area tenant unions and housing justice organizations can help renters understand their rights and coordinate collective pressure on landlords. Mutual aid networks in North Charleston neighborhoods often have legal referrals and know the local housing court landscape.
• Report Copper Roof’s future conduct: The CAFO states this enforcement action will be considered in any future EPA action against this company. Future violations should be reported immediately and loudly. The EPA compliance reporting form is publicly accessible; so is the contact information for EPA Region 4’s enforcement division.
• Demand stronger penalties from your representatives: Contact your U.S. Representative and Senators and ask them why the EPA Region 4 office settled 35-plus lead paint disclosure violations affecting seven families for $31,800. TSCA authorizes penalties far higher. The agency chose not to use that authority here.