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Enforcement

Brady Sullivan Millworks II, LLC and Brady Sullivan Millworks IV, LLC Information Sheet

Overview of Company and Location

Brady Sullivan Millworks II, LLC and Brady Sullivan Millworks IV, LLC (the Company) is located in Manchester, New Hampshire.  The Complaint involves the lease of, and renovation activities conducted at, property constructed prior to 1978, located in Manchester, New Hampshire. 

Violations 

The Complaint addresses alleged violation of the Toxic Substances Control Act (TSCA, the Residential Lead-Based Paint Hazard Reduction Act, the Renovation, Repair and Painting Rule (RRP Rule), 40 C.F.R. Part 745, Subpart E, and the Lead-based Paint Disclosure Rule, 40 C.F.R. Part 745, Subpart F.  In the Complaint, the United States alleges that the Company failed to comply with the requirement to:

  • Provide prospective tenants records or reports pertaining to lead-based paint or lead-based paint hazards.
  • Obtain initial firm certification.
  • Ensure that a certified renovator is assigned to a renovation, and discharges all of the duties charged to a certified renovator.
  • Retain records.

Pollutant Reductions 

This enforcement action is expected to contribute to a significant reduction in lead exposure by increasing compliance with the rules and increasing awareness of the rules’ requirements among the public and regulated community.

Health and Environmental Effects

Lead exposure affects the nervous system and can cause a range of health effects, from behavioral problems and learning disabilities, to seizures and death. Children six years old and younger are most at risk. If not detected early, children with high levels of lead in their bodies can suffer from:

  • Damage to the brain and nervous system
  • Behavior and learning problems, such as hyperactivity
  • Slowed growth
  • Hearing problems
  • Headaches
  • Anemia
  • In rare cases of acute lead poisoning from ingestion of lead, seizures, coma and even death.

Lead can accumulate in our bodies over time, where it is stored in bones along with calcium. During pregnancy, lead is released from bones as maternal calcium is used to help form the bones of the fetus. This is particularly true if a woman does not have enough dietary calcium. Lead can also be easily circulated from the mother's blood stream through the placenta to the fetus. Mothers with high levels of lead in their bodies can expose their developing fetuses, resulting in serious and developmental problems including:

  • Miscarriages,
  • Premature births or low birth weight,
  • Brain damage, decreased mental abilities and learning difficulties, and/or
  • Reduced growth in young children.

Civil Penalty

The Complaint proposes that the Company pay a civil penalty of $139,171.