Document 6bN8v0qOGO5RL904Q4w2waYQo

DownloadSearchable PDFRandom document
ft E A ~ United States .._..,~ Environmental Protectior ,,. Agency Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date: Media Program: Regulatory Program(s) 12/11/2024 Toxic Substance Control Act Section 1018 (Disclosure Rule) & Renovation Repair and Paint (RRP) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Moses Tucker Partners Offices 200 River Market Ave., Suite 501 Ft. Smith AR 72201 Same 501.376.6555 David Cole dcole@mosestucker.com I I CPA - Controller FRS Number: N/A Identification/Permit Number: N/A Media Identifier Number: N/A NAICS: SIC: Personnel participating in inspection: Angela Hays EPA Region 6 Stan Lancaster EPA Region 6 David Cole, CPA Moses Tucker Brandy Snyder Moses Tucker Jennifer Lester Alex Greene EPA Lead Inspector Signature/Date Moses Tucker Moses Tucker RALPH u19,..,11y s1gnea oy KALl-'H LANCASTER LANCAST~R ~t;~.;~2-~2.~i1 Stan Lancaster Inspector Inspector Controller Director of Property Accounting and Human Resources Principal & COO Property Manager Date Supervisor Signature/Date Stuckey, Troy g~;::~b:!~;2~~7~~~~~:ib, Troy Stuckey Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Moses Tucker Partners Inspection Date 12/11/2024 PURPOSE OF THE INSPECTION The purpose of this inspection was to evaluate compliance with the lead-based paint (LBP) regulations of the Toxic Substances Control Act (TSCA). Moses Tucker Partners is subject to both Section 1018 (Disclosure Rule) and the Renovation Repair and Paint (RRP) rule of TSCA. The investigation of this facility was selected based on a complaint that was received from a citizen. The citizen alleged that Moses Tucker Partners failed to disclose the presence of lead their lease of a pre-1978 dwellings (target housing) and did not provide the EPA pamphlet upon signing of the lease. As a property management company, Tucker Moses is also subject to the RRP rule thus the inspection will also look at their maintenance and renovation activities as it pertains to the RRP Rule. FACILITY DESCRIPTION Tucker Moses offices is located at 200 River Market Avenue, Suite 500 in Little Rock, Arkansas. The inspection took place at this location and not include any site visits to their properties. Tucker Moses manages several properties in Little Rock, five (5) of which were in buildings that have original build dates prior to 1978. These five (5) properties were identified during the inspection and were the focus of our discussions. According to Moses Tucker staff, these buildings had been remodeled prior the initial occupancy of tenants and no pre-1978 properties have received renovations or other work that would trigger the requirements of the RRP in the past 5 years. Section II - OBSERVATIONS On 12/10/2024 EPA inspectors Stan Lancaster and Angela Hays arrived at the Moses Tucker Partners offices located on River Market Avenue to conduct an inspection. At this time, Alex Greene met with the inspectors. The inspectors presented their credentials, and the purpose of our visit was explained. Mr. Greene asked the inspectors if they could return on the following morning to conduct the inspection in order to have time to gather the appropriate individuals to better address our concerns. The inspectors agreed to return the next morning. On 12/11/2024 at approximately 9:00 AM, EPA inspectors again visited the Moses Tucker Partners offices where they were met by Mr. Greene, Property Manager; David Cole, Controller; Brandy Snyder, Director of Property Accounting and HR; and Jennifer Lester, Principal and COO. The inspectors presented their credentials and explained to the individuals from Moses Tucker the purpose of the EPA inspection was to perform a compliance inspection with regards to lead-based paint (LBP), specifically Section 1018 of TSCA and the RRP Rule. The inspectors also explained that the inspection was being conducted a response to a citizen complaint as discussed above. Moses Tucker Partners Inspection Date 12/11/2024 Renovation Repair and Paint The inspectors briefly reviewed the requirements of the RRP and discussed the ages of their properties and any renovation activities that had been performed within the last 5 years. Moses Tucker identified five properties that they managed that were built prior to 1978 and thus would be subject to the TSCA LBP regulations. The five buildings discussed were Main Street Lofts located at 524 Main Street; Mulberry located at 315 Main Street; The Paint Factory located at 1300 E. 6th Street; Dem Lofts located at 615 main Street; and Tuff Nut located on River Market Avenue. They stated that within the past 5 years that they had not performed renovation work or other activities at these properties that would have triggered the requirements of the RRP (no work greater than 6 square feet interior or 20 square feet exterior). The Moses Tucker team stated that they could not with certainty provide the exact dates that these buildings were renovated and turned into lofts or apartments but believed it was at least 15 years ago. The facility was also unable to provide any information as to how the buildings were renovated at that time but felt like it was a total tear down and reconstruction of the interior space. They could not say with any certainty if the remodel had been done in conjunction with lead abatement or if the properties had been assessed to determine the presence of LBP. They asked for time to explore these questions in depth and determine the answer to these questions. The inspectors agreed to give the facility time to do so. According to a letter provided by Moses Tucker and other correspondence, they have contracted an environmental firm to conduct a lead assessment at the five properties in question. The lead assessment is anticipated to be concluded and available by MidFebruary, 2025. If the lead assessment shows the presence of LBP at their pre-1978 properties, they will need to comply with any future renovations in accordance with the RRP Rule. This would require that any remodel or renovation activities disturbing greater than 6 square feet interior or 20 square feet exterior of painted surface is required to be performed by a company that is lead safe certified, have a lead certified renovator assigned to the project and follow work safe practices required by the RRP. 1018 Disclosure Rule The EPA inspectors requested leases for each of the 5 pre-1978 buildings. They reviewed two leases from Tuff Nut Lofts, one lease from Arkansas Democratic Lofts, three leases from Mulberry Flats, four leases from Main Street Lofts and one from the paint factory (AKA 12 Star Flats). The leases reviewed represented approximately 10% of the leases at each property. The inspectors noted that none of the leases reviewed addressed LBP. The leases did not contain a lead addendum, the lead warning statements and no acknowledgment of the receipt of the lead hazards pamphlet. All leases were consistent between properties. It was explained to Moses Tucker that all leases for target housing should contain this information, every tenant should be receiving a pamphlet and sign an acknowledgment of receipt. Additionally, information Moses Tucker obtains relating to lead in these properties, will also need to be disclosed in the leases and made available to the tenants. On January 22, 2025, Moses Tucker provided a lead addendum that they indicated has been incorporated into their leases and will be used moving forward. The lead assessment that is currently being conducted will Moses Tucker Partners Inspection Date 12/11/2024 need to be mentioned in this addendum and made available to tenants. Moses Tucker has indicated that they will comply with this requirement. CONCLUSION The inspection lasted approximately an hour and ended with a short discussion of the areas of concern that were identified during the inspection. Moses Tucker agreed to do a full review of their pre-1978 properties and alter their leases to comply with the requirement of the Disclosure Rule. Moses Tucker also agreed to share the requested information pertaining to lead at the target housing that was mentioned in this report. Section III - AREAS OF CONCERN The following areas of concern were noted and discussed during the inspection: 1. Moses Tucker failed to provide tenants with the lead hazard information pamphlet. 2. Moses Tucker failed to include the lead addendum in the leases of pre-1978 properties. 3. Moses Tucker failed to provide statement of known lead-based paint hazards or no knowledge of such hazards as part of the lease. 4. Moses Tucker failed to provide a statement from the Lessee affirming receipt of lead-based paint information. 5. Moses Tucker failed to include the "Lead Warning Statement" (provided below) in leases for pre-1978 properties. Lead Warning Statement: "Housing built before 1978 may contain lead-based paint. Lead from paint, paint chips, and dust can pose health hazards if not managed properly. Lead exposure is especially harmful to young children and pregnant women. Before renting pre-1978 housing, lessors must disclose the presence of known lead-based paint and/or lead-based paint hazards in the dwelling. Lessees must also receive a federally approved pamphlet on lead poisoning prevention." Section IV - FOLLOW UP Moses Tucker committed to researching their pre-1978 properties, document information regarding lead-based paint in these properties and have this information available to tenants. Moses Tucker also agreed to modify their lease documents to comply with the requirements of the Disclosure Rule and indicating the availability of any LBP information. To date, Moses Tucker has provided a copy the proposed lead addendum for their properties, a letter from Hight Environmental with a cost estimate to perform lead assessment at the properties identified in this report as well as other information. The LBP assessment is anticipated to be complete by February 17, 2025 and shared with EPA as soon as possible. Moses Tucker has been cooperative and responsive throughout this investigation. Section V - LIST OF APPENDICES Appendix 1 - Notice of Inspection Appendix 2 - Receipt of Samples and Documents Appendix 3 - RRP checklist Moses Tucker Partners Inspection Date 12/11/2024 Appendix 1 Notice of Inspection $EPA Uni ted St dtCs Ervrro nment.sl ~>n,)tec :ron l\g ~n,:::y U tsited States ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 - ~ ~ ---------- - - - - - - - - - - - - - - - - -- - Notice of Inspection Office of Enforcement and Compliance Assurance ,I --- I i Date !lu# I I 11-c1!LJ l Investigation identification Inspection Number ol DaUy Seq. N~mber 11 ol '. 3 Facility Name J??a5e5 fu<!_lar /Jar1+iu.s: I 2. Inspector's Address 4. Facility Address dtJt) 1-tv/YlarJa,f ftVL 5,,,1 It!- 11 I i. i-f/-1.t k1e- ArL 7~:?6i For Internal EPA Use. Copies may be provided to the recipient as acknowledgment of this notice. "1Ji J I I ! .. Jj ---- -- i Reason for Inspection !Under the authori ty of Section 11 of the Toxic Substances Control Act 1 For the purpose of inspecting (including taking samples, photographs, statements and other inspection activities) an I establishment, facility or other premises in which chemical substances or mixtures, articles containing same are f manufactured, processed, stored or held before or after their distribution in commerce (including records, files, pap,?.rs, processes, control and facilities) and any conveyances being used to transport chem ical substance, mixtures or articles co~~a_ining sa,:ne in connection with th_eir distribution in commerc'. (including record _s, files, papers, processes, con?o ls and . fac1l1t1es) bearmg on whether the requirements of the Act are applicable to the chemical substances, mixtures or articles, ,1 within, or associated with, such premise or conveyance have been complied with. I - 1 In addition, this inspection extends to (check appropriate blocks): 1 D A. Financial Data - D D. Personnel Data D B. Sales Data [J E. Research Data O C. Pricing Data The nature and extent of inspection of such data specified in A through E above is as follows: I I ; I Inspector's Signature EPA Form 7740-3 (Rev. 2/16) !- in,pect c-r Copy 2 Fd cility Copy Moses Tucker Partners Inspection Date 12/11/2024 Appendix 2 Receipt of Samples and Documents oEPA United S tate!'. Environm t-: ntal ProtectinrAgency United States ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 - - - -- - - -- - - - -- - -- - - - Receipt for Samples and Documents Office of Enforcement and Compliance Assurance Date IJg~ J/-c2L/ 1. Investigation Identification - Inspection No. Daily Seq. No. 11 tJJ 11 ol I 3. Inspector Address I I I I ! r internal EPA use. Copies of this form may be provided to recIpIent bstances and/or mixtures described below collected in connection r ! 2. Company Name ' II /YltJ5ts /tJcJu,,- f'artil.,./_f&- 4. Company Address Idi? //..iv. lllPrKd-Av.i 51;-/-e__5o(J LJ.f/J.t tq('fl ,k.. '1~o.L as acknowledgment of the documents and samples of chemical with the ad1rnnistration and enforcement of the Toxic Substances ~~- Ji Cont1ol I ~ t-. No. 11 J - -- - - -- - - --- - - - - - - Receipt of Document(s) and/or Sample(s) Described is Hereby Acknowledged: - -- -- - - Description ----- : I F; ve, { 5) t,fft..3 o-1- /U,6e_5 - 1),Jf Nvf- ~ fa,r11 (i) P'7!1 L4+5 II (-;J>} m/1 ,,.,., <lJ,rA A .1.- I';;) IJ1 ,Jhn- ,., .l Ii I I I I I I ii I - ----- ! .-,, I' _J i I I I I I I I - I Optional: Duplicate or Split Samples: Requested and Provided 1-lnsp0ctor Copy 2-Facility C\>pv Appendix 3 RRP Checklist Moses Tucker Partners Inspection Date 12/11/2024 ft - U.S. EPA - - - - Com an Name - Address Contact Name Contact Tele hone - Contact Email - EPA Firm Certification Number Lead Renovation/Repair/Painting Compliance Checklist - Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION -- Y - N - NIA Comments - Permission to enter document sioned Facility/operator provided copy of entry document y Copy of Lead Base Paint Pamphlet rovided /V 1 Ucu/1d ul~ .,,. b~vaL ~vroo I enmfv-- A/,,t}'( Frcz~d~ The items identified in this inspection have the potential to incur civil penalties in dr'e amount identified . Your firm has - 90 days in which to submit proof that the items identified have been corrected. These deficiencies are of a serious nature -- and if left uncorrected could result in formal enforcement action. Your response should be submitted to: Copy of inspection checklist and on-site report sent to: - Print Name: - - - - ~ - ~ - - - --- Email: - - -- - - - - - - -- Page 1 of 6 Date - - -- --- Facility/Company Name: _ _____;,,;.._V_l O_,~,~d_' 5~ rz~=u_cK~t6~v)2~ .. - - - - - - - - - - U.S. EPA Lead Renovation/Repair/Painting Compliance Checklist- Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION .,.- # Reg Ref Question 1 40 CFR 745.87(c) Did the company pennit entry for inspection? Comments Y-N-N/A y I 2 40 CFR 745.87(c) Did the company provide requested information and/or records during or V after the inspection? I - ,., Comments .) 40 CFR 745.87(c) Is this company a licensed real estate brokerage firm ? If so, provide state - licensing number in comments. Comments - 4 40 CFR 745.87(c) Does this company manage target housing? y - Comments 5 40 CFR 745.87(c) How many target housing properties does this company manage? Comments 6 40 CFR 745.87(c) Are children under the age of 6 years living in any of these properties? , ei"'-,\oA, --r~v Comments 7 40 CFR 745 .87(c) Are pregnant women living in these properties? Comments '1?> v - 8 40 CFR 745.87(c) Has renovation/repair/painting \Jv'..Ork been performed on these properties? Ye s Comments {\,41JJ... --h, r:L, rl"\--, , P ,~ I- u Y~ " Ar..lkv! 1, 9 40 CFR 745.87(c) Which properties had RRP work performed and when? See List -r ,,,,-f,7) Comments 10 40 C.F.R. 745.84(a)(l) the EPA-approved lead hazard information pamphlet? Did the renovator or property manager provide the owner of the unit with ;I Comments 11 40 C.F.R. Did the renovator or property manager provide the adult occupant of the 745.84(a)(2) pamphlet? unit (if not the owner) with the EPA-approved lead hazard information IV - Comments 12 40 C.F.R. In Common Areas, did the renovator or property manager provide the - 745.84(b)(l) owner of the multi -family housing with the EPA-approved lead hazard tl/1 information/pamphlet or to post informational signs? Comments 13 40 C.F.R. In Common Areas, did the renovator or property manager notify in 745.84(b)(2) writing, or ensure written notification of, each unit of the multi-family housing and make the pamphlet available upon request prior to the start of the renovation, or to post informational signs? rf/t Comments 14 40C.F.R. In renovation in Child-Occupied Facilities, did the renovator or property 745 .84(C)(1 )(i) manager provide the owner of the building in which the child-occupied Comments facility is located with the EPA-approved lead hazard information pamphlet? -- Page 2 of 6 --- Facility/Company Name: _____t_tlfu_s;..~.,-c>~~-;_- u___ c_(_:.C~.4~~-1/_L _ _ _ _ _ _ _ _ _ __ !{vk ft e U.S. EPA Lead Renovation/Repair/Painting Compliance Checklist - Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION 15 40 C.F.R. In renovation in Child-Occupied Facility, did the renovator or property 745.84(C)(1 )(ii) manager provide an adult representative of the child-occupied facility with the pamphlet, if the owner is not the operator of the child-occupied f facility? Comments - 16 40 C.F.R. In renovation in a Child-Occupied Facility did the renovator or property 745.84(c)(2) manager provide the parents and/or guardians of children using the child- - occupied facility with the pamphlet and information describing the general nature and locations of the renovation and the anticipated completion date, by mailing or hand-delivering the pamphlet and renovation information, or by posting informational signs describing the - wA general nature and locations of the renovation and the anticipated completion date, posted in areas where they can be seen by parents or guardians of the children frequenting the child-occupied facility, and - accompanied by a posted copy of the pamphlet or information on how interested parents or guardians can review a copy of the pamphlet or - obtain a copy from the renovation firm at no cost to the parents or guardians? Comments 17 40 C.F.R. 745.85 For all renovations, did the renovator or property management firm post (1). signs clearly defining the work area and warning occupants and other persons not involved in renovation activities to remain outside of the work area; to prepare, to the extent practicable, signs in the primary ~ language of the occupants; and/or to post signs before beginning the - renovation and make sure they remain in place and readable until the renovation and the post-renovation cleaning verification have been - completed? Comments 18 40 CFR 745 .84(a)(l )(i) Did the firm establish and maintain records and make those records available during the inspection? rJ Comments 19 40 CFR 745.84(a)(l )(i) of a lead education pamphlet? Did the firm receive written acknowledgement from the owner for receipt ,J Comments 20 40 CFR 745.84(a)(2)(i) Did the firm receive written acknowledgement from an adult occupant, of/for a lead education pamphlet? r1 Comments 21 40 C.F.R. 745.84(a)(2) the EPA-approved lead hazard information pamphlet? Did the firm provide the adult occupant of the unit (if not the owner) with r1' Comments 22 40 C.F.R. Did the renovator provide the owner of the multi-family housing with the 745 .84(b)(l) EPA-approved lead hazard information/pamphlet or to post informational r-1 signs? Comments Page 3 of 6 Facility/Company Name: _ _ __,MQ,--5~C~f_ _-_,_,_l_A_C-'-{'("'"~"- - - - - - - - - - - ' - ft 0 -- U.S. EPA Lead Renovation/Repair/Painting Compliance Checklist - Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE iV-LEAD HAZARD REDUCTION - 23 40 C.F.R. 745.84(b)(2) Did the renovator notify in writing, or ensure written notification of, each f l unit of the multi-family housing and make the pamphlet available upon request prior to the start of the renovation, or to post informational signs? Comments 24 40 C.F.R. 745 .84(C)(1 )(i) Did the renovator provide the owner of the building in which the childoccupied facility is located with the EPA-approved lead hazard \A\'\\L-~ J information pamphlet? Comments 25 40 C.F.R. Did the renovator or owner provide an adult representative of the child- - 745 .84(C)(1 )(ii) occupied facility with the pamphlet, if the owner is not the operator of the child-occupied facility? rJ Comments 26 40C.F.R. Did the renovator or owner provide the parents and/or guardians of 745.84(c)(2) children using the child-occupied facility with the pamphlet and information describing the general nature and locations of the renovation and the anticipated completion date, by mailing or hand-delivering the N - pamphlet and renovation information, or by posting informational signs describing.the general nature and locations of the renovation and the - anticipated completion date, posted in areas where they can be seen by parents or guardians of the children frequenting the child-occupied - facility, and accompanied by a posted copy of the pamphlet or information on how interestedparents or guardians can review a copy of the pa,mphlet or obtain a copy from the renovation firm at no cost to the parents or guardians? - Comments 27 40 C.F.R. 745.85 (1) Did the renovator or property management firms post signs clearly defining the work area and warning occupants and other persons not involved in renovation activities to remain outside of the work area; to - prepare, to the extent practicable, signs in the primary language of the rl occupants; and/or to post signs before beginning the renovation and make sure they remain in place and readable until the renovation and the post- renovation cleaning verification have been completed? Comments - 28 40 C.F.R. 745.84(a)(l) During the renovation did the renovator obtain, from the owner, a written rJ acknowledgment that the owner has received the pamphlet, pursuant to 40 C.F.R. 745.84(a)(l)(i) or failure to obtain a certificate of mailing at least 7 days prior to the renovation? Comments - 29 40 C.F.R. 745 .84(a)(2) During the renovation did the renovator obtain, from the adult occupant, a ~ written acknowledgment that the adult occupant has received the pamphlet, pursuant to 40 C.F.R. 745.84(a)(2)(i) or failure to obtain a certificate of mailing at least 7 days prior to the renovation? - Comments Page 4 of 6 Facility/Company Name: _ _ __,M~ D'-"">..Je...._S._' _-r_v_c,"'-'k-,'.,l;..:{..;;L:;___ _ _ _ _ _ __ -- I -- ft 0 - U.S. EPA Lead Renovation/Repair/Painting Compliance Checklist - Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION 30 40 C.F.R. 745 .84(b)(l)(i) 40 C.F .R. 745.84(b)(l) During the renovation in Common Areas, did the renovator obtain, from the owner, a written acknowledgment that the owner had received the I pamphlet, or that information signs had been posted, or they had obtained a certificate of mailing at least 7 days prior to the renovation? Comments 31 40 C.F.R. 745.84(b)(3) During the renovation in Common Areas, did the renovator prepare, sign, ~ and date a statement describing the steps perfonned to notify all occupants of the intended renovation activities and offer to provide the pamphlet? Comments 32 40 C.F.R. During the renovation in Common Areas, did the renovator notify, in 745.84(b )( 4) writing, the owners and occupants of the scope, locations or expected - J starting and ending dates of the planned renovation activities, before the - renovator initiated work beyond that which was described in the original notice? Comments 33 40 C.F.R. During renovation in a Child-Occupied Facility, did the renovator obtain, - 745 .84(C)( 1)(i) from the owner of the building, a written acknowledgment that the owner had received the pamphlet, or obtained a certificate of mailing at least 7 - rJf days prior to beginning the renovation? Comments - 34 40 C.F.R. During renovation in Child-Occupied Facility, did the renovator obtain - ~~ 745.84(C)(1 )(ii) from an adult representative of the child-occupied facility, if the operator of the child-occupied facility is not the owner of the building, a written acknowledgment that the operator had received the pamphlet, or obtained a certificate of mailing at least 7 days prior to beginning the renovation? Comments 35 40 C.F.R. 745.84(c)(3) During renovation in Child-Occupied Facility, did the renovator prepare, sign and date a statement describing the steps performed to notify all parents and guardians of the intended renovation activities and to provide the pamphlet? N'~ Comments 36 40 C.F.R. During all renovations, did the renovator include a statement recording 745 .84(d)(l) the owner or occupant's name and acknowledgement of receipt of the pamphlet prior to the start of the renovation, the address of the unit ~ undergoing renovation, the signature of the owner or occupant as applicable, and the date of signature? Comments - 37 40 C.F.R. During all renovations, did the renovator provide written - 745.84(d)(2) and (3) acknowledgment of receipt of the pamphlet on either a separate sheet or ~ as part of any written contract or service agreement for the renovation, - and written in the same language as the text of the contract or agreement or lease or pamphlet? Page 5 of 6 - Facility/Company Name: _ _ _ _ _ _ _ __,/,_;...!.a.O.:._S..=e::.-...S...__,t_-tA_. c._1_( e_(_L _ _ __ ft 0 U.S. EPA Lead Renovation/Repair/Painting Compliance Checklist - Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION Comments 38 40 C.F.R. 745.86 During all Renovations, did the renovator or property manager retain all Comments records necessary to demonstrate compliance with the residential property renovation for a period of 3 years following completion of the renovation activities? ~t~f: hfa [_ l {'.._,, (, 39 40 C.F.R. 745.225 ' (i) During all Renovations, did the renovator, or property manager implement a program to maintain and make available to EPA upon request, records for a period of 3 years and 6 months? I I.r d fJcJ rc011 Comments 40 40 C.F.R 745 .225, In Target Housing and Child-occupied Facilities, did the owner, ti 745 .226, 745 .227, 40 C.F.R. 745.235 renovator, or property manager establish, maintain, provide, copy, or perm it access to records or reports? (b) Comments Target Housing Major= one or more occupants under age 6 and/or pregnant woman Significant= no information about age of the youngest occupant, or one or more occupants between ages of 6 and 17 Minor= no occupants under age 18 Child Occupied Facility Major= one or more occupants under age 6 (by definition, a child-occupied facility is regularly visited by one or more children under 6) Minor= renovation activities were completed during a period when children did not access the facility (e.g., as summer vacation) and there is no continuity of enrollment (i.e., the same children are not returning after the break). Page 6 of 6 Facility/Company Name: - - - - - rM_ a_S,-e~5_ ..,...f-,..,.-_ (_A,_G_\!_.. -v _L_________ {