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Kansas City-based Titan Environmental Services Inc., accredited by the Environmental Protection Agency to offer training programs under the Residential Lead-Based Paint Hazard Reduction Act, failed to provide all hands-on training to participants in some of its lead-safe training courses, EPA said in announcing actions taken against the company.
The company, based in Kansas City, Mo., has agreed to pay a $10,878 civil penalty to settle a series of violations of the Residential Lead-Based Paint Hazard Reduction Act, including failures to provide required hands-on training to contractors and other renovation professionals who enrolled in some of its training courses.
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| This EPA guide provides information for contractors and homeowners on how to plan for and complete a home renovation, repair or painting project using lead-safe work practices in pre-1978 housing and child-occupied facilities. See Steps to Lead-Safe Renovation, Repair and Painting. |
The allegations involve courses conducted by the company in April 2010 and October 2010.
As part of its settlement with EPA’s Region 7 office, and in addition to paying the $10,878 civil penalty, EPA said the company has agreed to offer the federally-required hands-on training at no cost to trainees who were enrolled in the company’s classes where EPA found violations.
An EPA Region 7 office spokesman said the agency is urging any participants in the courses who did not receive all hands-on training to contact Titan Environmental Services to inquire about receiving the training at no cost.
“Part of the challenge is that we don’t know how exactly how many did not receive the hands-on training,” Christopher Whitley, the EPA spokesman, told Durability + Design. “We believe it was approximately 120, but it may have been more than that. So the way it’s been settled, they (Titan Environmental Services) have to provide training to anyone who took the class but did not receive the training.”
The company has also agreed to perform a supplemental environmental project in which it will spend at least $97,902 to fund lead-abatement activities at five residential properties in St. Joseph, Mo. The project will include window replacement and lead-based paint abatement, to be performed by entities licensed and/or certified by the state of Missouri.
EPA said the company must submit detailed work plans to EPA for approval before the abatement activities begin, and follow-up reports to the agency when those activities are completed, under terms of the settlement.
Whitley called the case against Titan Environmental Services “a bit unique,” in that the company was the only approved training provider under the Lead-Based Paint Hazard Reduction Act known to have failed to provide all the training required by the agency.
“Numerous firms are certified to provide the training,” Whitley said. “This is the first time this has occurred where a firm was certified and licensed to provide training, but did not provide all the training.”
Whitley said the “onus is on the trainee” who enrolled in the classes to contact Titan Environmental Services to receive the hands-on training.
Violations Found During Inspections
According to an administrative consent agreement and final order filed by EPA Region 7 in Kansas City, Kan., Titan Environmental Services’ violations of the Residential Lead-Based Paint Hazard Reduction Act were based on findings from three EPA inspections: a May 2010 recordkeeping inspection at the company’s Kansas City business office, an October 2010 inspection at a lead-based paint training course given by the company at a hotel in Osage Beach, Mo.; and an October 2010 follow-up recordkeeping inspection at the company’s business office.
EPA’s inspections found that, despite being accredited in August 2009 to offer training in the Renovator Initial Course—English, Titan Environmental Services:
• failed to properly notify EPA at least seven days in advance of offering training on at least six occasions during 2010;
• failed to properly notify EPA within 10 days after completions of training on at least 35 occasions during 2010;
• failed to maintain and make available to EPA necessary documents showing the education, work experience, training requirements or demonstrated experience for the principal instructor of a course offered in April 2010;
• failed to cover all required portions of hands-on training activities during training courses provided on at least four occasions in April 2010 and October 2010;
• failed to maintain and make available to EPA the necessary student assessment forms for training courses provided on at least two occasions in April 2010.
By agreeing to the settlement with EPA, Titan Environmental Services has certified that it is currently in compliance with the applicable federal regulations.
The Residential Lead-Based Paint Hazard Reduction Act of 1992, part of the Toxic Substances Control Act (TSCA), was designed to address the need to control exposure to lead-based paint hazards. The law directs EPA to regulate the accreditation of training programs offered to renovation professionals, including minimum requirements for training providers, training curriculum, training hours, hands-on training, trainee competency and proficiency, and requirements for training program quality control.
Common renovation activities like sanding, cutting and demolition can produce hazardous lead dust that can be harmful to adults and children, EPA said.
More information on EPA’s requirements for lead-abatement training providers and renovators: Information for Training Providers.
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