Document G5z1yE2194oRROzgxaeo4e1wm

ft E A ~ United States ~., Environmental Protectior , Agency Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 6/17/2024 Toxic Substance Control Act 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: Servant Remodeling ^ 11550 Plano Road, Suite 126 Dallas, TX 75243 6ame Dallas 469.583.1831 Rob Jackson rob@servantremodeling.com I I Owner 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 Rob Jackson Servant Remodeling Inspector Inspector Owner EPA Lead Inspector Signature/Date Supervisor Signature/Date Stan Lancaster / Date RALPH LANCASTER Digitally signed by RALPH LANCASTER Date: 2024.07.31 10:58:51 -05'00' Troy Stuckey / Date Digitally signed by H H STUCKEY Date: 2024.07.31 13:33:18 STUCKEY -05'00' 6ENFORM-019-R8.2 (02/12/2020) 1 Servant Remodeling Inspection Date 03/17/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTION The focus of the inspection was to evaluate compliance to the Toxic Substances Control Act (TSCA) Lead Base Paint (LBP) Renovation Repair and Paint (RRP) Rule. The company was inspected based on neutral scheme targeting effort to identify companies potentially doing renovation and repair work on older homes in the DFW area. Servant Remodeling was identified as a company that has performed or intends to perform renovations on target housing. This inspection was not conducted based any specific information that was received by Wsuch as a complaint. FACILITY DESCRIPTION Servant Remodeling a general contractor that performs renovations. The company has a small storefront location at the address listed above. The inspection was conducted at this facility and no active construction was observed. Section II - OBSERVATIONS On the morning of June 17, 2024, EPA inspectors Angela Hays, Kiera Hancock and Stan Lancaster visited the offices of Servant Remodeling to conduct an RRP inspection. The door was locked, but Mr. Jackson answered and explained that he normally only meets people at that location by appointment and that he was on his way out and couldn't meet with inspectors at that time. The inspection was then planned to take place at that location later in the evening at 5:30 to accommodate Mr. Jackson's schedule. Upon arrival at 5:30PM, the inspectors presented their credentials to Mr. Jackson. The inspectors again informed Mr. Jackson of the purpose of the TSCA inspection, presented their credentials, and obtained his signature on the Notice of Inspection Document (Appendix 1). Mr. Jackson stated that Servant was aware of and believed that they were compliant with the requirement of the RRP Rule. He stated that the company was registered and that his son, Robert Jackson, is a certified renovator and acts as their project manager. Mr. Jackson stated that they worked on 20 to 25 projects a year and estimated that 20 to 25 percent were pre 1978 homes. At the time of inspection, Mr. Jackson did not have access to the lead based paint records but agreed to send them within the next few days as follow-up to the inspection. In an email on July 5, 2024, Mr. Jackson provided the requested information to the EPA inspectors. The information showed that Servant Remodeling had obtained EPA firm certification on February 27, 2020, and that Robert Jackson had obtained his renovators certification on June 14, 2021. Mr. Jackson also provided forms that show the company considers the age of each home and if lead safe procedures are 2 Servant Remodeling Inspection Date 03/17/2024 necessary in that home. Mr. Jackson also provided signed acknowledgements from the homeowners that they had been provided the Lead Based Paint Pamphlets. Section III - AREAS OF CONCERN No areas of concern were noted. Section IV - FOLLOW UP As of the date of this inspection report, Servant Remodeling has provided the requested information. No additional information is necessary at this time. Section V - LIST OF APPENDICES Appendix 1 - NOI Appendix 2 - Inspection Checklist 3 Servant Remodeling Inspection Date 03/17/2024 Appendix 1 Notice of Inspection 4 ,&EPA 1 1 ::':" 1f1!J~c: ';. 'fonr1w111,.,t P,,,1~r.,on United States ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 Notice of Inspection Office of Enforcement and Compliance Assurance ] . Investigation Identification 3. Facility Name -ziJIII ~ 1-1 I Date II Inspection ~umber Daily Seq. Number pe,-y4,t/ ,!l t---11 11 I I I , 2. Inspector's Address 4.Facil ity Address ~ ! /26/ i=t.m S'r . /lScJ ~/a.,,,,d I <fJ:r,1Ia5 rt< 75270 I D~/c;s1 TX' :For internal EPA Use. Copies may be provided to the recipient as acknowledgment ofthis nqtice. --- Reason for Inspection !Zol __5b;fe ;5",,2lj3 121,, Under the authority of Section 11 of the Toxic Substances Control Act For the purpose of inspecting (including taking samples, photographs, statements and other inspection activities) an 1 estilblishment, facility or other premises in which chemical substances or mixtures, articles containing same are : manufactured, processed, stored or held before or after their distribution in commerce (including records, files, papers, I processes, control and facilities) and any conveya nces being used to transport chemical substance, mixtures or articles 1 containing same in connection with their distribution in commerce (including records, files, papers, processes, controls and facilities) bearing on whether the requirements of the Act are applicable to the chemical substances, mixtures or articles, within, or associated with, such premise or conveyance have been complied with. Ci In addition, this inspection extends to (check appropriate blocks): DA. Financial Data DB. Sales Data D C. Pricing Data DD. Personnel Data D E. Research Data The nature and extent of inspection of such data specified in A through Eabove is as follows: Inspector's Recipient's I j ISignature:;;L::=:=;z=::::;;r-=~=== = = = = ==it-Si_g_na_t.=u=re===;.::=r-====*====:;.qc::=====,l Name ,._5/,'-M I Name 7 I -[?!] '!:_Titl-"=l'z.e:'.:==.~/~ffe~0A==-o,_:J:<-===::.lll_ot,e r /4:fidlnue[ &~ 0'= = = J E ,e lf'Aforni l710-3(Rl!v. -!/16) l lnspecto1 Copy 2-F~ciiity,; ''FY Servant Remodeling Inspection Date 03/17/2024 Appendix 2 Inspection Checklist 5 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 EPA Inspector Name EPA Inspector Telephone EPA Inspector Email Inspection Date Inspection Type: Inspection Location Companv Name Address Contact Name Contact Telephone Contact Email Manager Name Manager Telephone Manager Email EPA Firm Certification Number Inspection Checklist ) /.,,_,,,,_ L-,,i ,,,- A~. U , - - 1 /r,/ ~~7 007--( f l 1/7-/ 2-C/ :,P.5<:J~,A - ':): 5'0 Rl<Z-P tJ/,),_ ~) Firm Information 'Serv... ,..., -1- F--t -"'> .I ( , .,,, . It <5"0 ?t...___J, fLJJ R,,h , _ ; i r- '\t ..-r / S"... rlP /:;, C. l/LIJ ?"%~ lx~t, / '-/61 J1 1 I $ 5I f c) r-/)k/1? u.rv.. ~ .~.,,,,., ,1,. 1-,~ . C,{)vYI,_ / l "" - / r-., / _; 7 ~ c,./ /::_ J O v'\.. - C?A,~ ~-.-1- /-'l,,:.,.._, ,, - - .AAJ..~..,) ,5 n,~M le r1.e:.-'--' Introduction & Purpose Permission to enter granted Permission to enter document signed Facility/operator provided copy ofentry document Copy of Lead Base Paint Pamphlet provided 2,p- z.,, F/o) 0/,,,- / pr Zf)-V,~ - Y-N-N/A Comments The items identified in this inspection have the potential to incur civil penalties in the 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: _1.__o-~----...J...A..-?..K.......>...P--tl-<'- Email: >eI"~.,., 1- ,(-+<ork(, / , ~~ Date - - - Page 1 of 6 Facility/Company Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ 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 # Reg Ref Question I 40 CFR 745.87(c) Did the company pennit entrv for inspection? Comments Y-N-N/A r 2 40 CFR 745.87(c) Did the company provide requested infonnation and/Jorecords ~drril g ~ \-' after the inspection? w, I ( prov,~ e,,,... - Comments 3 40 CFR 745.87(c) Is this company a licensed real estate brokerage firm? If so, provide state licensing number in comments. N./J- Comments 4 40 CFR 745.87(c) Does this company manage target housing? Mft Comments ~..1- 5 40 CFR 745.87(c) How many target housing~ ' 7 - H do~this company manage? zo /..,r Comments 6 40 CFR 745.87(c) Are children under the age of 6 years living in any of these properties? Comments 7 40 CFR 745.87(c) Are pregnant women living in these properties? Comments 8 40 CFR 745.87(c) Has renovation/repair/painting work been perfonned on these properties? y' Comments 9 40 CFR 745.87(c) Which properties had RRP work perfonned and when? See List Comments 10 40 C.F.R. Did the renovator or property manager provide the owner of the unit with r 745.84(a)(l) the EPA-approved lead hazard infonnation pamphlet? - Comments ~ rl L,..,In, J,.,,c!-f Ow41 ..f u r , I / ~ / '< W,w v,: 11 40 C.F.R. Did the renovator or property manager provide the adult occupant'ofthe 745.84(a)(2) unit (if not the owner) with the EPA-approved lead hazard infonnation pamphlet? Comments 12 40 C.F.R. In Common Areas, did the renovator or property manager provide the 745.84(b)( I) owner of the multi-family housing with the EPA-approved lead haz.ard infonnation/pamphlet or to post infonnational si!!Ils? Nk Comments 13 40 C.F.R. ln Common Areas, did the renovator or property manager notify in 745.84(b)(2) Vfr 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 infonnational signs? Comments 14 40 C.F.R. In renovation in Child-Occupied Facilities, did the renovator or property 745.84(c)(1)(1) manager provide the owner of the building in which the child-occupied facility is located with the EPA-approved lead hazard infonnation pamphlet? Comments Page 2 of 6 Facility/Company Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ 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 15 40 C.F.R. 745.84(c)( I )(ii) In renovation in Child-Occupied Facility, did the renovator or property manager provide an adult representative of the child-occupied facility with the pamphlet, if the owner is not the operator ofthe child-occupied facility? Comments 16 40C.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 infonnation describing the general nature and locations of the renovation and the anticipated completion date, by mailing or hand-delivering the pamphlet and renovation infonnation, or by posting infonnational signs describing the general nature and locations ofthe 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 ofthe pamphlet or infonnation on how interested parents or guardians can review a copy of the pamphlet or obtain a copy from the renovation finn 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 finn post (1). signs clearly defining the work area and warning occupants and other persons not involved in renovation activities to remain outside ofthe 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 Did the finn establish and maintain records and make those records 745.84(a)(l )(i) available during the inspection? Comments 19 40 CFR Did the finn receive written acknowledgement from the owner for receipt 745.84(a)(l)(i) ofa lead education pamphlet? Comments 20 40 CFR Did the finn receive written acknowledgement from an adult occupant, 745.84(a)(2)(i) of/for a lead education pamphlet? Comments 21 40 C.F.R. Did the finn provide the adult occupant of the unit (ifnot the owner) with 745.84(a)(2) the EPA-approved lead hazard infonnation pamphlet? Comments 22 40C.F.R. Did the renovator provide the owner ofthe multi-family housing with the 745.84(b)(l) EPA-approved lead hazard infonnation/pamphlet or to post infonnational signs? Comments Page 3 of6 Facility/Company Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ 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. Did the renovator notify in writing, or ensure written notification of, each 745.84(b)(2) unit of the multi-family housing and make the pamphlet available upon request prior to the start of the renovation, or to post infonnational signs? Comments 24 40 C.F.R. Did the renovator provide the owner ofthe building in which the child- 745.84(c)( I)(i) occupied facility is located with the EPA-approved lead hazard infonnation pamphlet? Comments 25 40 C.F.R. Did the renovator or owner provide an adult representative of the child- 745.84(c)( I )(ii) occupied facility with the pamphlet, if the owner is not the operator ofthe child-occupied facility? Comments 26 40 C.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 pamphlet and renovation infonnation, or by posting infonnational signs describing the general nature and locations ofthe renovation and the anticipated completion date, posted in areas where they can be seen by parents or guardians ofthe children frequenting the child-occupied facility, and accompanied by a posted copy of the pamphlet or infonnation on how interested parents or guardians can review a copy of the pamphlet or obtain a copy from the renovation finn at no cost to the parents or guardians? Comments 27 40C.F.R. 745.85 (I) 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 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. During the renovation did the renovator obtain, from the owner, a written 745.84(a)(I) 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 ofmailing at least 7 days prior to the renovation? Comments 29 40 C.F.R. During the renovation did the renovator obtain, from the adult occupant, a 745.84(a)(2) 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 ofmailing at least 7 days prior to the renovation? Comments Page 4 of 6 Facility/Company Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ .ft 0 U.S. EPA Lead Renovation/Repair/Painting Compliance Checklist- Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 7S202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION 30 40 C.F.R. 745.84(b)( 1)(i) 40 C.F.R. 745.84(b)(1) During the renovation in Common Areas, did the renovator obtain, from the owner, a written acknowledgment that the owner had received the 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 performed to notify all occupants ofthe intended renovation activities and offer to provide the pamphlet? Comments 32 40 C.F.R. 745.84(b)(4) During the renovation in Common Areas, did the renovator notify, in writing, the owners and occupants ofthe scope, locations or expected starting and ending dates ofthe planned renovation activities, before the renovator initiated work beyond that which was described in the original notice? Comments 33 40 C.F.R. 745.84(c)( I )(i) During renovation in a Child-Occupied Facility, did the renovator obtain, 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 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)(l)(ii) from an adult representative of the child-occupied facility, ifthe operator of the child-occupied facility is not the owner ofthe 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? Comments 36 40 C.F.R. 745.84(d)(l) During all renovations, did the renovator include a statement recording the owner or occupant's name and acknowledgement ofreceipt of the pamphlet prior to the start of the renovation, the address ofthe unit undergoing renovation, the signature of the owner or occupant as applicable, and the date of si!!Ilature? Comments 37 40 C.F.R. 745.84(d)(2) and (3) During all renovations, did the renovator provide written 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 ofthe contract or agreement or lease or pamphlet? Page 5 of 6 Facility/Company Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ 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 records necessary to demonstrate compliance with the residential property renovation for a period of3 years following completion of the renovation activities? Comments 39 40 C.F.R. 745.225 During all Renovations, did the renovator, or property manager (i) implement a program to maintain and make available to EPA upon request, records for a period of 3 years and 6 months? Comments 40 40 C.F.R 745.225, In Target Housing and Child-occupied Facilities, did the owner, 745.226, 745.227, renovator, or property manager establish, maintain, provide, copy, or permit access to records or reports? 40 C.F.R. 745.235 - ' (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 o"r 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: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __