EPA Fines Property Manager $359K Over Lead Paint Disclosure Violations at Connecticut Mill

EPA Settles with Konover Over Cargill Falls Mill Lead Disclosure Violations

The U.S. Environmental Protection Agency has reached a settlement with Konover Residential Corporation over alleged violations of federal lead paint disclosure rules at the historic Cargill Falls Mill mixed-use complex in Putnam, Connecticut. The agency said Konover failed to provide the required lead warning statement and available records to tenants of 11 apartments, even though children were living in those units.

The violations, identified after tenant complaints triggered an EPA inspection, violated both the Toxic Substances Control Act and the Residential Lead-Based Paint Hazard Reduction Act. Under the settlement, Konover agrees to pay a $359,069 penalty and to maintain full compliance going forward. The property, built before 1978, falls under the lead disclosure rule that applies to all pre-1978 housing.

Konover, a subsidiary of the Simon Konover Company, managed the residential units at Cargill Falls Mill at the time of the violations. The complex, owned by Historic Cargill Falls Mill, LLC, was converted into residential and commercial space around 2017. The settlement requires Konover to give every future tenant an EPA-approved lead hazard pamphlet, include the mandatory Lead Warning Statement in each lease, and disclose any known lead-based paint hazards—or clearly indicate that no such records exist.

What the Settlement Means for the Property Management Industry

A Six-Figure Signal to the Multifamily Sector

The $359,069 penalty is more than a nuisance fee; it reflects the EPA's calculation that non-compliance can carry a significant financial sting. For property management firms operating older portfolios, the settlement underscores that the per-unit cost of disclosure lapses can quickly escalate. With 11 units involved, the penalty works out to roughly $32,640 per unit, a figure that will focus attention on compliance budgets and vetting processes.

The Risk Calculation for Older Properties

Cargill Falls Mill’s conversion in 2017 makes it a cautionary example for developers of historic reuse projects. Pre-existing lead paint is common in such properties, and the EPA’s disclosure rule is a strict-liability framework: if the building was built before 1978, the obligations kick in regardless of renovation history. The alleged violations—omitting the warning statement and not providing records—are among the simplest to commit if lease templates or internal checklists are not updated. The presence of children in the affected units likely amplified the agency’s enforcement posture, as protecting young children from lead exposure remains a stated EPA priority.

Tenant Complaints as an Enforcement Catalyst

The inspection was triggered by resident complaints, a pattern that gives tenants a direct avenue to prompt federal scrutiny. This dynamic increases the reputational and operational risk for property managers: a single complaint can lead to a site visit, record review, and potential penalties. For firms managing multiple older properties, the settlement is a reminder that compliance gaps are discoverable not only through agency sweeps but also through tenant-initiated reports.

Key Compliance Steps for Landlords and Property Managers

Property managers and landlords with pre-1978 residential units can take several specific steps to avoid similar enforcement actions:

• Audit lease documents immediately. Confirm every current and future lease includes the exact Lead Warning Statement required by federal law. Missing this statement was a core violation in the Konover case.
• Distribute EPA-approved pamphlets. Provide the current Protect Your Family from Lead in Your Home pamphlet to all tenants at lease signing and obtain written acknowledgment.
• Disclose all known lead information—or state there is none. Gather any past lead inspection reports, risk assessments, or paint test results for the property. For each unit, either hand over those records or sign a statement that no such records are available. Failure to do either was the second major violation identified.
• Verify compliance in historic or renovated properties. Even a gut renovation does not exempt a pre-1978 building from the disclosure rule unless the renovation has been certified lead-free by a licensed risk assessor—a rare outcome. Assume the rule applies unless you have formal documentation of lead removal.
• Calculate the cost of non-compliance. Konover’s penalty of roughly $32,640 per unit provides a concrete benchmark. Factoring that into risk management decisions can justify spending on compliance software, legal review, and staff training.