RESPONDENT FAILED TO DISCLOSE A KNOWN LEAD BASED PAINT HAZARD TO LESSEES OF HOUSING, FAILED TO PROVIDE THEM RECORDS OR REPORTS PERTAINING TO THAT HAZARD, AND FAILED TO PROVIDE THE LEAD BASED PAINT INFORMATION PAMPHLET. THESE FAILURES VIOLATE SECTION 409 OF THE TOXIC SUBSTANCES CONTROL ACT AND 40 CFR SECTION 745.