Transmittal of the Interim Final Lead-Based Paint Consolidated Enforcement Response and Penalty Policy
This memorandum, dated 19 August 2010, is from the U.S. EPA, Office of Enforcement and Compliance Assurance. The memorandum transmits the Interim Final Lead-Based Paint Consolidated Enforcement Response and Penalty Policy (LBP Consolidated ERPP) for civil administrative enforcement actions taken pursuant to Section 16 of the Toxic Substances Control Act (TSCA). This Policy sets forth guidance for Agency officials to use in determining the appropriate enforcement response and penalty amounts for violations of Section 409 of TSCA resulting from failure or refusal to comply with provisions of the Pre-Renovation Education Rule (PRE Rule); Renovation, Repair and Painting Rule (RRP Rule); and Lead-Based Paint Activates, Certification and Training Rule (LBP Activities Rule).
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