David Gillis was the manager of Home Free Lead Inspections (HFLI), a Maryland limited liability company accredited as a lead paint inspection contractor by the Maryland Department of Environment (MDE).

In December 2017, MDE received a complaint regarding ongoing renovations at a property in Baltimore, Maryland. An MDE inspector responded to the site and was told by workers that the property was lead-free. After further investigation, the inspector discovered the property was inspected by HFLI several months prior and tested positive for lead-based paint. The inspector conducted his own inspection of the property, however, and discovered lead-based paint.

As a result, from approximately February 2018 through and including September 2018, MDE conducted oversight inspections of many properties certified by HFLI as lead-free. The inspections revealed that Gillis, on behalf of HFLI, performed inspections at properties without following the proper lead-based paint testing protocols and accepted methodologies, as required by Maryland's Lead-Based Paint program and regulations. The inspections further revealed that properties were certified by Gillis and HFLI as lead-free but in fact, the properties contained lead-based paint.

In September 2018, with federal funding provided by EPA, MDE hired an environmental contractor (the Contractor) to reinspect properties that had been inspected and certified as leadfree by HFLI. From September 2018 through November 2019, the Contractor conducted 219 inspections and identified 129 properties (59%) as failing for containing lead-based paint.

The investigation revealed that Gillis and HFLI knowingly failed and caused others to fail to follow the required testing protocols. Among other things, Gillis failed to test and caused others to fail to test for the presence of lead-based paint in all required areas. Similarly, Gillis failed to document and caused others to fail to document the presence of lead-based paint, and instead, certified properties as lead-free when, in fact, they contained lead-based paint. As a result, Gillis issued and caused others to issue false lead-free certificates.

• Toxic Substances Control Act (TSCA)