Is it a crackdown or just a friendly invitation? In its latest efforts to enforce the federal lead-based paint Renovation, Repair and Painting (RRP) Rule, the Environmental Protection Agency (EPA) sent over 200 letters to New Haven, Ct. area remodeling and painting contractors, property management companies and landlords, where, according to an EPA statement, public health records indicate a high rate of childhood lead exposure. The letter invited participants to an information session "to provide an overview of the RRP Rule requirements, and introduce an expedited settlement offer for one violation of the RRP Rule." But the letter also notifies participants that the agency will be inspecting a number of them in June 2014 - all part of the agency's expanding "compliance assistance and enforcement initiative."
The press release does not give any details about the "expedited settlement offer" but it is likely a version of settlements made under the "Lead-based Paint Expedited Settlement Agreement (ESA) Pilot Program," in which contractors accepted reduced penalties for easily determined, minor violations, such as incomplete record keeping and failing to hand-out information pamphlets, in exchange for waiving the right to an appeal and accepting the conditions of the settlement without a hearing. ESA settlements were used extensively in a crackdown on Northeast contractors for allegedly violating the RRP rule in 2012, as well as in a recent and larger crackdown in February of this year. (Here is one example of an ESA settlement.)
Tell us what you think: Did you receive a letter and attend the information session last night (April 16)? How would you feel if you had?
