Need someone versed in defense of claims from EPA for violations of TSCA "pertaining to renovations, repair, and painting of "target" properties constructed before 1978, where lead-based paint may be present, as set forth in 40 C.F.R. Part 745, Subpart E ("Residential Property Renovation" or "RRP"). EPA wants my client to participate in a show cause hearing with under threat of an admin hearing with fines of nearly $50k per violation. To the best of the client's knowledge, there was no lead based paint present in any building it worked on performing concrete restoration and no evidence lead paint was present; this is purely a procedural issue for buildings that were built before 1978. Help!
Chuck
NOTE! WE HAVE MOVED! Please use new address below.
Charles B. Hernicz, Esq.
Board Certified in Construction Law by The Florida Bar
Hernicz Legal Services, P.L.
95102 Royal Palm Court
Fernandina Beach, FL 32034
Telephone: (561) 753-7511
Chernicz@HerniczLegal.com
Confidentiality Notice: This communication is covered by the Electronic Communications Privacy Act, 18 U.S.C. §§ 2510-2521. It is legally privileged (including attachments) and is intended only for the use of the individual(s) or entity(ies) to which it is addressed. It may contain information that is confidential, proprietary, privileged, and/or exempt from disclosure under applicable law. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is strictly prohibited. If you have received this communication in error, please notify us so that we may take the appropriate action and avoid troubling you further. If you are not the intended recipient(s), please destroy this message, and any attachments, and notify the sender by return e-mail. Thank you for your cooperation.
Need someone versed in defense of claims from EPA for violations of TSCA "pertaining to renovations, repair, and painting of "target" properties constructed before 1978, where lead-based paint may be present, as set forth in 40 C.F.R. Part 745, Subpart E ("Residential Property Renovation" or "RRP"). EPA wants my client to participate in a show cause hearing with under threat of an admin hearing with fines of nearly $50k per violation. To the best of the client's knowledge, there was no lead based paint present in any building it worked on performing concrete restoration and no evidence lead paint was present; this is purely a procedural issue for buildings that were built before 1978. Help!
Chuck
NOTE! WE HAVE MOVED! Please use new address below.
Charles B. Hernicz, Esq.
Board Certified in Construction Law by The Florida Bar
Hernicz Legal Services, P.L.
95102 Royal Palm Court
Fernandina Beach, FL 32034
Telephone: (561) 753-7511
Chernicz@HerniczLegal.com
Confidentiality Notice: This communication is covered by the Electronic Communications Privacy Act, 18 U.S.C. §§ 2510-2521. It is legally privileged (including attachments) and is intended only for the use of the individual(s) or entity(ies) to which it is addressed. It may contain information that is confidential, proprietary, privileged, and/or exempt from disclosure under applicable law. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is strictly prohibited. If you have received this communication in error, please notify us so that we may take the appropriate action and avoid troubling you further. If you are not the intended recipient(s), please destroy this message, and any attachments, and notify the sender by return e-mail. Thank you for your cooperation.
