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EPA Reaches Settlement with Two N.H. Companies for Failure to Disclose Lead Paint Information or Follow Lead-Safe Work Practices at Residential Property in Manchester

Contact Information: 
Emily Bender (

BOSTON – The U.S. EPA finalized a settlement agreement with two N.H. companies for their alleged failure to follow lead-safe work practices and provide proper lead paint disclosure to tenants at a residential property in Manchester, N.H. The agreement ensures that Brady Sullivan Millworks II, LLC and Brady Sullivan Millworks IV, LLC (Brady Sullivan) of Manchester, N.H will comply with federal rules ensuring lead-safe work practices and proper disclosure of information pertaining to lead paint, thus protecting the health of building occupants.

Under the terms of the agreement, Brady Sullivan will pay a penalty of $90,461 for its violations of the federal Real Estate Notification and Disclosure (Disclosure) and Renovation, Repair and Painting (RRP) Rules and will certify that it is currently in compliance with these Rules. These violations occurred at a four-story, historical mill building known as "The Lofts at Mill West" or "Mill West" located at 195 McGregor Street in Manchester.

In May 2015, EPA performed a series of inspections at 195 McGregor Street following the referral of a complaint about lead dust in the building resulting from sandblasting occurring on a lower, unoccupied floor received by the N.H. Dept. of Health and Human Services (NH DHHS). During the inspections, EPA observed dust and chipping paint throughout the interior common areas of the building (areas to which tenants continued to have access during renovation activities). At the time of the inspections, building residents included vulnerable populations like children and at least one pregnant woman. As part of the joint EPA and NH investigations, NH DHHS conducted dust-wipe sampling which confirmed levels of lead in the dust and in paint chips well above acceptable health-protective standards. Additional testing showed that there was dust containing levels of lead above the regulatory limit in numerous residential units on the third and fourth floors of the McGregor Street building. These inspections were part of an initiative by EPA to focus attention on high risk communities with the goal of reducing lead poisoning through education and compliance with federal lead laws.

The City of Manchester ordered a halt to sandblasting activities on May 11, 2015, because the subcontractor, Environmental Compliance Specialists, Inc. (ECSI), had not obtained the required permit from the City. On June 19, 2015, EPA issued a unilateral order to Brady Sullivan to clean up lead dust and chipping lead paint on the third and fourth floors of the building and in common areas throughout the property. EPA closely monitored these cleanup activities and expects a final cleanup report and certification from Brady Sullivan shortly.

In August and September of 2016, EPA issued complaints against both Brady Sullivan and ECSI citing them for numerous federal lead paint violations. While this settlement resolves EPA's action against Brady Sullivan, EPA's action against ECSI is ongoing. ECSI filed for Chapter 7 bankruptcy in late 2016.

Lead poisoning of infants and children can cause lowered intelligence, reading and learning disabilities, impaired hearing, reduced attention span, hyperactivity and behavior problems. Adults with high lead levels can suffer difficulties during pregnancy, high blood pressure, nerve disorders, memory problems and muscle and joint pain.

EPA's RRP Rule is designed to prevent children's exposure to lead-based paint and/or lead-based paint hazards resulting from renovation, repair and painting projects in pre-1978 residences, schools and other buildings where children are present. If lead painted surfaces are to be disturbed at a job site, the Rule requires individual renovators to complete an initial 8-hour accredited training course and the company or firm that they work for to be certified by EPA. These baseline requirements are critical to ensuring that companies take responsibility for their employees by following proper lead safe work practices including containing and managing lead dust and chips created during such projects. Further, the Rule requires that specific records be created and maintained in order to document compliance with the law.

The purpose of the Disclosure Rule is to ensure that prospective tenants have enough information about lead-based paint in general and known lead-based paint hazards in specific housing to make an informed decision about whether to lease a particular property. The Disclosure Rule requires owners/managers of rental properties to provide prospective renters both with general information about lead-based paint risks and to provide specific information on whether or not there is known lead-based paint in a rental unit prior to the individual signing a lease. By fully disclosing the required information, individuals can make an informed decision about whether to lease a particular property.

Please visit these EPA websites for additional federal lead paint information: