General contracting company, Schryer Thompson Construction, Inc, engages in renovation of residential properties, in addition to other commercial and industrial work. The complaint alleges that Schryer Thompson failed to obtain initial firm certification from EPA. It also alleges that the company failed to keep adequate records of: lead testing, pre-renovation notification, certified renovator assigned to projects, certified renovator performed training, certified renovator performed or directed all tasks, post-renovation cleaning verification, certified renovator training certificate, and certification from certified renovator. It also alleges that the company failed to assign a certified renovator to certain projects and failed to ensure that all workers on certain projects were certified renovators or trained by certified renovators. These failures resulted in 45 alleged violations of the Toxic Substances Control Act. The case originated from a neutral targeting scheme.