Lead Paint Safety and Public Housing

Transcription

1 Lead Paint Safety and Public Housing EPA and HUD Lead Rules Fall 2015

2 Project Funding This project was supported by Grant Number , funded by the U.S. Environmental Protection Agency (US EPA) and the State of Connecticut Department of Public Health. Its contents are solely the responsibility of the authors and do not necessarily represent the official views of the US EPA or the State of Connecticut Department of Public Health.

3 - Introduction - Lead 101

4 Connecticut Overview Department of Public Health Lead, Radon and Healthy Homes Program Kimberly Ploszaj, Epidemiologist (one of three staff that cover the state) Provide oversight technical assistance to 73 local health departments Monitor trends of lead exposure Provide funding for primary prevention Auditing and compliance checks of licensed lead practitioners

5 Connecticut Overview Local Health Departments 73 local health departments and health districts covering 169 towns statewide Director of Health, sanitarians, community health staff

6 Connecticut Overview Responsibilities relating to lead poisoned child: Respond to all blood lead levels 5 µg/dl Conduct comprehensive lead inspections when a child has (2) venous blood lead levels between greater than 90 days apart or (1) venous blood lead level 20 μg/dl Gather data on the child/family to assist in determining source of lead poisoning/exposure

7 Common Sources of Lead Environmental Paint Dust Soil Water Non-Environmental Ayurvedics (plant-based) Imported food, spices Occupations Hobbies Children s jewelry, toys

8 Lead in Paint Pre-1978 Housing may contain lead-based paint 74% of homes built prior to 1980 contain some lead paint Pre-1950 housing stock has an even higher probability of containing lead paint In CT, 35% of housing stock is pre-1950

9 Lead in Dust Is a very fine dust that comes from deteriorated lead paint Commonly found on window sills or friction surfaces Use wet cleaning and lead-safe work practices to minimize dust hazards

10 Lead in Soil May contain paint chips or lead dust from old paint that has fallen off the outside of a house Can be tracked into home by shoes and pets

11 Lead in Water Can leach into drinking water from lead pipes, solder, or fixtures in older homes (rarely a high risk factor) Lead solder was banned from use in plumbing in million household private wells not regulated

12 Non-Environmental Lead can also be found in: Ceramic dishes Crystal Food cans Water pipes Solder/fittings Ethnic cosmetics Home remedies

13 Occupational/Hobbies Lead can also be found in jobs/hobbies: Jobs: Painters Remodelers Plumbers Mechanics Bridge workers Salvage workers Hobbies Making jewelry, ceramics/pottery, and stained glass, Making sinkers and bullets

14 How Does a Child Get Lead Poisoned? Lead poisoning usually happens when children ingest (eat) and inhale dust that has lead in it Children may also eat chips of lead paint or soil that has lead in it

15 Common Sources of Lead Poisoning in CT Children are most commonly exposed to lead from lead-based paint hazards Lead-based paint hazards defective painted surfaces friction and chewable surfaces lead contaminated dust on interior floors and surfaces lead contaminated soil and water

16 Common Sources of Lead Poisoning in CT Children are less frequently poisoned from herbal or ethnic remedies, imported cosmetics, and other miscellaneous lead-contaminated products and foods

17 Common Sources of Lead Poisoning in CT

18 Lead Testing Requirements for Children in Connecticut

19 Mandatory Lead Testing in CT All children, at about ages one and two, should be tested for lead poisoning Pediatricians typically obtain a capillary sample (finger stick) If the capillary test result is 5 μg/dl, the child must have a confirmatory venous test Testing children for lead poisoning in CT is the LAW

20 Medical Testing of Children

21 Lead Surveillance Data

22 Percentage and number of children <6 years of age with a blood lead level 5µg/dL (2013)

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26 Percentage of housing style among inspected units

27 Type of Lead Hazards Identified

28 A Lead Story

29 What happens when things go wrong: Children poisoned Three children under age 6 were living in single-family rental unit in public housing Routine testing showed that 3 children had high lead levels Two children had to be hospitalized for chelation therapy Children required medical case management to ensure no further exposures Long-term effects on children: unknown

30 What happens when things go wrong: Poisoning caused by defective paint House required a comprehensive lead inspection to identify any and all lead hazards Defective lead paint indoors and on window exteriors High lead dust levels on floors, windowsills, and window wells High levels of lead in soil Family immediately relocated to lead-safe housing Local health department issued lead abatement orders

31 What happens when things go wrong: A preventable tragedy This situation was completely preventable Living room HUD Housing Inspection Form Lead-Based Paint 1.9 Are all painted surfaces free of deteriorated paint? Unit should have failed housing inspection because of defective paint Kitchen Bathroom Other room Exterior 2.9 Are all painted surfaces free of deteriorated paint? 3.9 Are all painted surfaces free of deteriorated paint? 4.9 Are all painted surfaces free of deteriorated paint? 6.6 Are all painted surfaces free of deteriorated paint?

32 What happens when things go wrong: Consequences Three children were poisoned, possibly with lifelong health, behavior, and learning consequences, because of an inadequate housing inspection

33 Leslie Balch

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35 Public Health Interested in prevention Not waiting for the condition to happen Mission: To "fulfill society's interest in assuring conditions in which people can be healthy Make it as easy as possible to be healthy, rather than hard to be healthy Importance of the condition Identify the risks Collaborate with partners Communication Policy development Referrals Assessment Enforcement

36 Health Impact of Lead Children. Effects brain development Decreased intelligence, reading and learning difficulties, behavioral problems, and hyperactivity Workers and other adults High blood pressure Loss of sex drive and/or capability being researched Physical fatigue Pregnant women Damage to the fetus 1-4

37 Blood Lead in Children Effects many systems-even at low levels Results in behavioral problems and intellectual impairment Associated with measurable detrimental effects on cognitive, behavioral, and social-emotional developmental outcomes Effects of lead toxicity are believed to be irreversible Contributes to social disparities Health, educational achievement and future quality of life Impacts Behavior, earning potential

38 Blood Lead Levels Decreasing Policies, laws and enforcement 1990s Unleaded gasoline 1978 Lead out of paint Remediation and abatement laws Safe practices Universal lead screening Level of concern lowered No safe blood lead level in children has been identified Blood lead concentrations are inversely associated with children's IQ scores Associated declines in IQ are greater at lower concentrations than at higher concentrations

39 Risk at Home Approximately 70 percent of lead poisoning cases are attributed to lead-based paint hazards in the home Ingestion through normal hand-to-mouth activity Delayed maintenance Deteriorated paint and the lead dust it creates Interior and in soil Repair activities Without proper safeguards to control and post-work cleaning Presence during repairs/renovations

40 Percentage of Homes Containing Lead- Based Paint Source: American Healthy Homes Survey: Lead and Arsenic Findings. April 2011.

41 Children at Highest Risk In poorly maintained older homes In homes with lead-painted surfaces disrupted without proper safeguards to control, contain, and clean up of lead dust In substandard housing From low-income communities and communities of color

42 Traditional Approach to Prevention Focus on individual behavior Tenants, owners, managers, real estate agents Assuming received, understand, and will use information Elevated blood lead as the indicator for lead hazard After the fact assessment, education, protective measures, and enforcement.

43 Trending Toward a housing based approach Making exposure hard (Primary prevention) Improve, preserve and provide affordable housing Better coordinate of activities Maximize available resources Primary versus secondary prevention Let s stop using kids to detect lead hazards in the home!

44 Studies Show Blood lead screening and cleaning alone without removal of lead hazard not effective in decreasing blood lead levels Screening Law Necessary for surveillance Education Surviving in poverty may trump continuing efforts Even with retention of information, not significant impact on blood leads

45 Lead Hazards The mere presence of lead paint alone is not a dangerous problem Hazards Non-intact lead-based paint Chipping, chalking, cracked, flaking, peeling Lead-dust Cleaning verification Soil-lead hazards Poor maintenance Improper renovation/repair

46 Reducing Exposure Risk Identify pre-1978 dwellings Delayed maintenance Deteriorated paint Lead dust Interior and in soil Improper repair activities Maintaining unit to prevent health hazards from arising Fixing dangerous problems before and during occupancy in a timely manner

47 ROI (Return on Investment) Lead poisoning prevention strong return for every dollar invested Prior to exposure Cost implications Avoid delays associated with relocation or phased project Abatement vs. remediation Avoid complaints, lawsuits and fines Opportunity Vacant unit After inspection, before occupancy

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49 EPA and HUD EPA s and HUD s Real Estate Notification and Disclosure Rule mandates that property owners reveal information about lead-based paint and hazards to prospective buyers and renters. EPA s Lead-Based Paint Activities Certification and Accreditation Program oversees the development of capacity to perform lead-based paint inspections, risk assessments, and abatement. HUD s Lead Safe Housing Rule governs how lead safety must be addressed in all federally assisted housing. EPA s Standards on Lead Dust define what is a dangerous level of lead in paint, bare soil, and interior dust. EPA s Renovation, Repair and Painting Rule requires contractors and workers who work in older homes and child-occupied facilities to take simple, low-cost precautions to avoid creating and spreading lead debris and dust.

50 HEALTH

51 Subsidized Housing

52 Think Protection Good maintenance is important to keep lead-based paint intact Distribute maintenance guide Remodel and renovate safely Lead paint is rarely a hazard Dust during painting Cleaning Post work and ongoing Where kids play Resources for blood-lead screening

53 Need To Collaborate Working with same families, but don t know it Health becomes involved after exposure Realized there s a lot we don t know Still learning Lead Based Paint Owner Certificate Cleaning Verification Willingness to inform authorities

54 Attempts to Collaborate Successes and failures Lists Policy development Referrals Purpose of information Maximizing resources Cross reference involvements Reduce duplication Know enforcement authorities Share findings and areas of expertise Once know can optimize Marry statistics with programs Pre 1978 units with children Conditions found Safe practices used Referred for enforcement Inspected for complaints Safe housing available

55 Collaborate to Reduce Exposure Reduce or eliminate exposure risk factors before elevated blood lead detected Communicate Assess Based on information Plan Who, what, where and when Implement Evaluate Revise

56 Collaboration Who s on First? Players Property owner Real estate Housing Health Occupant/Community Identify resources and authority Interagency referrals Established and types of communications Delivering communications and educational outreach Engage occupants Increase awareness of potential hazards

57 Interagency Communication Agencies Authority Regulations Policies and procedures Inspection Relocation Information/data Referrals Lead safe maintenance and monitoring Importance to community help and equity Regulations and consequences Info and training options Owners, contractors, community members Develop and evaluate collaborative policy Based on maximizing available resources/knowledge/data What more is needed

58 Integration of Activities Identify properties/areas/communities of concern Property/landlord history Lead hazard evaluation Lead hazard controls Strengthen regulatory infrastructure Lead safe work practices Painters, renovators, code inspectors, realtors, property owners and managers Cleaning verification Inspection and complaint response

59 To Do List Identify and remove sources of exposure to lead Before children are harmed Educate about lead hazards in housing and responsibilities. Property owners, tenants, real estate professionals, and building contractors Enforce regulations and policies Increase the amount of safe and effective abatement performed. Assure that homeowners, contractors, and others comply with applicable requirements. Assure tenants are informed and understand Implications of lead, importance of screening, cleaning and reporting changes in condition.

60 Protecting and Preserving Safer housing market to protect our residents Education Lead hazard control Remediation of existing hazards Maintenance to prevent hazards from arising Monitoring Compliance

61 Together We Can Make it Happen!

62 LEAD SAFE RENOVATION U.S. ENVIRONMENTAL PROTECTION AGENCY

63 Part 745 Lead-Based Paint Poisoning Prevention in Certain Residential Structures Overview Safe Work Practices Recordkeeping & Enforcement Compliance Assistance U.S. ENVIRONMENTAL PROTECTION AGENCY

64 OVERVIEW In general, anyone who is paid to perform work that disturbs paint in housing built before 1978 must comply with the lead paint law, including: Painters, Home improvement contractors, Renovators and remodelers Carpenters, Finish workers, Landlords, property managers, Maintenance staff, Electricians and plumbers and Window replacement firms RRP U.S. ENVIRONMENTAL PROTECTION AGENCY

65 OVERVIEW Landlords, property managers, Maintenance staff, Electricians and plumbers and Window replacement firms A property management company performs most of the clerical functions of the business, and hires plumbers, electricians, carpenters, etc., for its renovation needs. Does the property management company need firm certification to comply with the Renovation A property management company acts as an agent for the landlord and has the same responsibilities as the landlord under the RRP Rule. Therefore, if the property management company uses its own employees to do the work, the property management company must be a certified firm and one of the employees must be a certified renovator. If the property management company hires a renovation firm to perform the renovation, the property management company does not need firm or renovator certification, but the firm the property management company hires must be certified and must perform the renovation using a certified renovator that directs and provides on-the-job training to any workers that are not certified renovators. U.S. ENVIRONMENTAL PROTECTION AGENCY

66 OVERVIEW Firms performing maintenance, repairs or renovations that disturb Lead Based Paint (LBP) in homes or Child Occupied Facilities (COFs) built before 1978 must: Have their firm certified by EPA Use certified renovators who are trained by EPA-approved training providers Follow lead-safe work practices U.S. ENVIRONMENTAL PROTECTION AGENCY

67 Why 1978? Structures built before 1978 may contain lead paint If you do not handle lead paint safely: you, the residents, their neighbors, your co-workers, and your own family can become lead poisoned This training will teach you how to work lead-safe U.S. ENVIRONMENTAL PROTECTION AGENCY

68 OVERVIEW Approximately 38 Million Homes in the U.S. Contain Lead U.S. ENVIRONMENTAL PROTECTION AGENCY

69 OVERVIEW?? What is a renovation? A renovation is a modification of any existing structure, or portion thereof, that disturbs a painted surface, unless the activity is performed as part of an abatement. Examples include: repair of painted surfaces such as doors or windows by sanding or scraping removing building components weatherization projects involving insulation and/or weather-stripping renovations that convert a building, or part of a building into target housing or a child-occupied facility, are covered U.S. ENVIRONMENTAL PROTECTION AGENCY

70 What s the connection between lead poisoning and renovation? When renovation, repair, or painting jobs disturb lead paint, the paint often turns into lead dust If people breathe or swallow lead dust, they can become lead poisoned Lead poisoning can harm you, your family, your co-workers, the residents of the home, and their neighbors 9

71 What harm does lead poisoning do? In young children In adults Lead can cause serious problems with blood pressure, sexual function, digestion, and other illnesses Lead can cause serious, permanent problems with learning, behavior, and health

72 OVERVIEW EPA guidebook: Steps to Lead Safe Renovation, Repair and Painting

73 OVERVIEW Contractors performing renovations that disturb paint must be EPA certified U.S. ENVIRONMENTAL PROTECTION AGENCY

74 OVERVIEW CERTIFICATION - ACCREDITATION Certification of Firms

75 OVERVIEW How to get certified - individuals Persons who successfully complete an 8-hour accredited renovator training course become certified renovators EPA maintains a database of accredited renovator training courses on its website, or you can call the National Lead Information Center for assistance at LEAD A 4-hour accredited renovator refresher training course is required every 5 years to maintain your certification U.S. ENVIRONMENTAL PROTECTION AGENCY

76 OVERVIEW 4/16/2014 U.S. ENVIRONMENTAL PROTECTION AGENCY 18

77 OVERVIEW Renovators must provide building owners and occupants pre-renovation notification Renovations in common areas 60 days before renovation FIRM gives owner pamphlet and gets written acknowledgement OR gets certificate of mailing 7 days >start AND FIRM Notifies each affected unit Written notice to each unit OR post informational signs Post pamphlet (or how to obtain a copy) FIRM prepares written statement describing steps taken Notify if revisions to scope, location and/or dates U.S. ENVIRONMENTAL PROTECTION AGENCY

78 Safe Work Practices EPA Work Practice Standards Perform or direct work to ensure the work practices are followed Be physically present at the work site: When warning signs are posted, while containment is established, and during final work area cleaning Be available, either on-site or by telephone, at all other times Provide on the job training to uncertified workers (not allowed by HUD) When requested, use a test kit to determine if LBP is not present (not allowed by HUD) Perform cleaning verification (not allowed by HUD) Prepare required records U.S. ENVIRONMENTAL PROTECTION AGENCY

79 HUD Work Practice Standards All workers must be certified HUD does not allow the use of an EPA approved lead test swab HUD requires clearance dust wipes tests be be collected at the end of the work by a certified lead inspector/risk assessor U.S. ENVIRONMENTAL PROTECTION AGENCY

80 Safe Work Practices General Work Practice Standards Post signs defining the work area Ensure that all personnel, tools, and other items including waste are free of dust and debris when leaving the work area Waste must be sealed in bags or plastic sheeting, dispose of waste in accordance with Federal, State, and Local requirements U.S. ENVIRONMENTAL PROTECTION AGENCY

81 Safe Work Practices Prohibitive EPA Prohibited Work Practices Prohibited work practices Open flame burning or torching of lead-based paint Using heat gun >1100 o F Using machines without HEPA attachment (sanding, grinding, power planning, needle gun, abrasive blasting, or sandblasting) U.S. ENVIRONMENTAL PROTECTION AGENCY

82 Safe Work Practices Prohibitive HUD Prohibited Work Practices Prohibited work practices Open flame burning or torching of lead-based paint Using heat gun >1100 o F Heat guns that char paint, even if lower than 1100 F Use of power tools without shrouding and HEPA vacuum Dry scraping or sanding less than one foot from electrical outlets Use of volatile stripper in poorly ventilated space U.S. ENVIRONMENTAL PROTECTION AGENCY

83 Safe Work Practices Interior Work Practice Standards Remove or cover all objects from the work area Close and cover all ducts in the work area Close all windows, and cover all doors in the work area Cover the floor surface of the work area with plastic sheeting U.S. ENVIRONMENTAL PROTECTION AGENCY

84 Safe Work Practices Exterior Work Practice Standards Close all doors and windows within 20 feet of the renovation Cover the ground with plastic sheeting extending out from the edge of the structure a sufficient distance to collect falling paint debris U.S. ENVIRONMENTAL PROTECTION AGENCY

85 Safe Work Practices Exterior - Vertical Containment Work Practice Standards Vertical barrier of plastic sheeting over a rigid frame Required for exterior jobs close to property lines Can be used to minimize floor or ground contamination U.S. ENVIRONMENTAL PROTECTION AGENCY

86 Safe Work Practices Exterior Ground Cover Work Practice Standards Cover the ground with protective sheeting. If space permits, extend a minimum of 10 feet from the work area. Pay special attention and cover nearby vegetable gardens and children's play areas. Limit access, place signs. Establish a 20 foot perimeter around the work area if space permits. Erect a vertical containment. Vertical containment must be erected if renovations occur within 10 feet of the property line U.S. ENVIRONMENTAL PROTECTION AGENCY

87 Safe Work Practices Cleaning Work Practice Standards Pick up paint chips and debris Remove all protective sheeting Clean all objects and surfaces in and around the work area Clean walls with a HEPA-equipped vacuum or with a damp cloth _ HEPA Vacuum all remaining surfaces & objects with a HEPA-equipped vacuum, including furniture & fixtures (use beater-bar attachment for rugs & carpets) Wipe all remaining surfaces in the work area with a damp cloth Mop uncarpeted floors U.S. ENVIRONMENTAL PROTECTION AGENCY

88 Safe Work Practices Disposal Work Practice Standards What should I do with my waste? At the work site: Place waste in heavy duty plastic bag Gooseneck seal the bag HEPA vacuum the exterior of the waste bag before removing it from the work area Store waste in a secure area Carefully dispose of waste in accordance with Federal, State and Local regulations Always check local waste requirements U.S. ENVIRONMENTAL PROTECTION AGENCY

89 Safe Work Practices Disposal Work Practice Standards Waste Management During renovation, waste must be contained to prevent releases of dust & debris. At the end of each work day and at the end of the job, waste must be contained or enclosed to prevent release of dust & debris and to prevent access. When the firm transports waste, it must be contained to prevent releases of dust & debris. U.S. ENVIRONMENTAL PROTECTION AGENCY

90 Recordkeeping & Enforcement Documents demonstrating compliance with the rule (usually the project checklist ) must be provided to the owner/occupant within 30-days following the completion of a renovation, and retained for 3-years EPA may suspend, revoke, or modify an individual s or a firm s certification for noncompliance Non-compliant contractors may be liable for civil and/or criminal penalties of up to $37,500 for each violation U.S. ENVIRONMENTAL PROTECTION AGENCY

91 Maintain Records & Enforcement Record Keeping U.S. ENVIRONMENTAL PROTECTION AGENCY

92 Maintain Records & Enforcement Record Keeping To have records available at the work site of: Certifications for the Certified Firm and Certified Renovators To retain all records for at least 3 years after completion of the renovation. To keep records of: Training and certifications for all renovation personnel, and for certification of the firm Distribution of required information Communications with and certifications from owners and residents Work activities in compliance to the Rule Post-renovation reports U.S. ENVIRONMENTAL PROTECTION AGENCY

93 Common Violations & Enforcement Failure to Obtain Firm Certification - The United States alleges that Company X violated the Renovation, Repair, and Painting Rule by failing to obtain firm certification from EPA prior to performing, or offering to perform, renovation activities in housing constructed prior to 1978 Failure to Comply with Training Requirements - The United States alleges that Company X violated the Renovation, Repair, and Painting Rule by failing to obtain training course completion certification Failure to Establish and Maintain Records - The Unites States alleges that Company X violated the Renovation, Repair, and Painting Rule by failing to establish and maintain records certifying that a certified renovator was assigned to the project, provided on-the-job training to individuals used on the project, and directed these individuals performing the renovation to comply with the work practice standards required by the RRP rule U.S. ENVIRONMENTAL PROTECTION AGENCY

94 Common Violations & Enforcement Failure to Document Delivery of the Lead Hazard Information Pamphlet to the Property Owner - The United States alleges that Company X violated the Renovation, Repair, and Painting Rule by failing to document that it provided a copy of the Renovate Right pamphlet to the property owner prior to commencing renovation activities Failure to Ensure All Individuals Performing the Renovation Were Certified or Trained - The United States alleges that Company X violated the Renovation, Repair, and Painting Rule by failing to ensure that all of the individuals performing the renovation were certified by EPA or had been trained by a certified renovator U.S. ENVIRONMENTAL PROTECTION AGENCY

95 Common Violations & Enforcement Failure to Comply with Work Practice Standards. The United States alleges that Company X violated the Renovation, Repair, and Painting Rule by: (1) failing to post signs clearly defining the work area and warning occupants and other persons not involved in renovation activities to remain outside of the work area (2) failing to using prohibit the use of machines designed to remove paint or other surface coatings through high speed operation such as sanding, grinding, power planing, needle gun, abrasive blasting, or sandblasting without HEPA vacuum attachments, and (3) failing to contain waste from renovation activities to prevent releases of dust and debris before the waste is removed from the work area for storage or disposal U.S. ENVIRONMENTAL PROTECTION AGENCY

96 EPA Tips and Complaints. Information Resources - Web Links Tips & Complaints (TIPS) U.S. ENVIRONMENTAL PROTECTION AGENCY

97 U.S. ENVIRONMENTAL PROTECTION AGENCY

98 epa.gov/lead

99 James M. Bryson Regional Lead Coordinator USEPA Region 1 Bryson.jamesm@epa.gov Region 1 Main Lead Line: (ext. 1524) National Hot Line (LEAD) U.S. ENVIRONMENTAL PROTECTION AGENCY

100 Connecticut Children s Healthy Homes Program Funding Opportunities for Subsidized Housing

101 Objectives In This Presentation, Learn What We Do Where We Work Resources Where We Don t Work How Can we Work Together!

102 Quick Overview/Milestones Started in 2003 HUD/DOH Funded Grant Program $30.2 million since ,100 Units Lead

103 Variety of Housing

104 CCHHP Communities - Bridgeport - Danbury - East Haven - Enfield - Harford - Manchester - Meriden - New Britain - New Haven - Norwalk - Stamford - Torrington - Waterbury - West Haven - Winchester

105 Qualifications Lead Hazard Control 80% of Area Median Income (AMI) Fair Market Rent Child Under 6 in Residence (Owner) Pre-1978 Construction

106 **FREE**Home Assessments Assess your home for 29 hazards FREE Install smoke detectors FREE Install Carbon Monoxide Alarm FREE Provide a child safety kit FREE Referral to Energy Efficiency Programs you guessed it, FREE

107 Funding Available Lead Hazard Control Single Family $15,000 2 Units $23,000 3 Units $34,500 and up

108 A Short List of Other Hazards - Asbestos - Radon - Electrical - Mold & Moisture - Structural Collapse - Trip & Fall - Carbon Monoxide - Pests

109 Small Cities Awards 2015 $12 Million in Small Cities Grants to 22 Municipalities Roof Replacement, Heating Systems, Window Replacement, Lead Paint and Asbestos Removal, Code Upgrades.

110 Other Programs Connecticut Housing Investment Fund Multi-Family Energy Conservation Loan Program Neighborhood Rebuilder Construction Loans Energize Connecticut Home Energy Solutions Income Eligible (HES-IE) 877- WISE USE ( )

111 Thank You! Chris Corcoran

112 Lead Paint Regulations and Lead Paint Evaluations Office of Lead Hazard Control and Healthy Homes November 10,

113 Regulations Lead Disclosure Rule (LDR) Subpart A of 24 CFR Part 35 Lead Safe Housing Rule (LSHR) Subpart B-R of 24 CFR Part 35 Renovation, Repair and Painting Rule (RRP) 2

114 Evaluations Visual Inspection Paint Testing Lead-Based Paint Inspection Risk Assessment Combination Inspection and Risk Assessment 3

115 LEAD BASED PAINT REQUIREMENTS Lead rules generally apply to properties built prior to 1978 Lead evaluation and treatment depends on; Level of Federal assistance Needs of the property 4

116 MAIN EXEMPTIONS Built after 1977 Inspection report says LBP free Single-room occupancy Designated for elderly or disabled (unless kids under 6 live there) 5

117 Disclosure Requirements Provide pamphlet Provide Warning statement Disclose KNOWN information 6

118 Lead Safe Housing Rule (LSHR) PURPOSE: To protect children in assisted target housing through primary prevention 7

119 Lead Safe Housing Rule Varying requirements based on Title X Type of assistance In some cases, amount of assistance 8

120 LSHR General Requirements Evaluate Act Clear Tell Visual Paint inspection Risk assessment* Lead Safe Work Practices Dust sampling 9

121 EPA Renovation Repair and Painting Rule (RRP) 10

122 . Renovation, Repair and Painting Rule Contractors that disturb lead-based paint in homes, child care facilities, and schools built before 1978 must be certified by the EPA or State Work must be supervised by Certified Renovator LSHR additional Requirements 11

123 RRP Owner Requirements If employees conduct renovation, repair, or painting activities in a pre-1978 residential building-must become a firm If not, then hire only a Lead-Safe Certified firm for building maintenance, repair, or painting Option for testing 12

124 Evaluations Determine if Exempt Comply with Regulations Lead Inspection (LI) Risk Assessment (RA) Combination (LIRA) Paint Testing Visual Clearance 13

125 Standards HUD Guidelines LI Chapter 7 RA Chapter 5 Clearance Chapter CFR 745 Your State 14

126 Lead Inspection Lead-based paint inspection means a surface-by-surface investigation to determine the presence of lead-based paint and the provision of a report explaining the results of the investigation. 15

127 Common Components Always Present Walls Ceilings Doors Door Casing Usually present Closet components Window Trim Cabinets Hallways 16

128 Compare Two Rooms Reasonable Inspection Bedroom 1 Walls A Bedroom 1 Walls B Bedroom 1 Walls C Bedroom 1 Walls D Bedroom 1 Ceiling Bedroom 1 Door Bedroom 1 Door Casing Bedroom 1 Closet Door Bedroom 1 Closet Shelf Bedroom 1 Closet Pole Bedroom 1 Window sill wall A Bedroom 1 Vent Bedroom 1 Baseboard Bad Inspection Bedroom 1 Wall A Bedroom 1 Wall B Bedroom 1 Wall C Bedroom 1 Wall D Bedroom 1 wall C Bedroom 1 wall D Bedroom 1 W. wall A 17

129 Inspection Quick Check Report Title Inspector License Executive Summary Disclosure Statement 18

130 Visual Inspection Complete HUD Free Online Visual Assessment training Review property for deteriorated paint All surfaces presumed to be LBP 19

131 Visual Assessment Routine building maintenance and unit turnover Determine completeness or stability of lead hazard control 20

132 Visual Assessment Identify Deteriorated Paint HUD s de minimis amounts Identify Type and Cause of Deterioration Repairing Deteriorated Paint No determination of Lead 21

133 Deteriorated Paint 22

134 Visual Report Summary Listing of areas inspected and locations of deteriorated paint See HUD Guidelines Chapter 5 for example forms See other forms in Handouts 23

135 Risk Assessment Risk assessment means (1) an on-site investigation to determine the existence, nature, severity, and location of leadbased paint hazards, and (2) the provision of a report. 24

136 Risk Assessment Activities Visual Assessment for Deteriorated Paint Limited Paint Testing of Deteriorated Paint Dust Testing of Floors and Window Sills Soil Testing if Bare Soil Report Identifying Lead Hazards and Control Options 25

137 UPCS Lead Base Paint (LBP) Disclosure Form and Inspection Report: Inspectors are required to request the LBP disclosure form and inspection report from the property representative for all properties, regardless of the type of resident population, for buildings constructed prior to

138 UPCS A comment must be provided in the Property Information Comments field regarding resident population for elderly only. For the purpose of determining whether the LBP disclosure form and inspection report is applicable, the inspector must use the building construction year and not the date of complete rehabilitation or other renovations. 27

139 UPCS The inspector must randomly select five resident files to determine whether the required LBP disclosure form has been provided to and signed by the residents. All five files must contain evidence or the inspector must record NO. 28

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142 2012 Guidelines 2012 HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing 31

143 The Guidelines in one figure! 32

144 Two perspectives on changes Changes to HUD s Lead Safe Housing Rule (LSHR) as a result of EPA s Renovation, Repair and Painting (RRP) Rule Additional requirements for projects covered by both HUD s LSHR and the EPA s RRP Rule (most protective requirements apply) 33

145 Main changes to HUD LSHR projects to comply with EPA RRP Rule Tenant-based rental assistance: RRP rule covers housing even if no child under 6 lives there Training and certification: Renovation firm must be EPA- or Statecertified and at least one supervisor or worker who is at the job or who is available when work is being done On-the-job training for other workers. 34

146 Determination that LBP is present. EPA: Certified renovators use EPArecognized test kit to determine whether LBP is or is not present. HUD: EPA-recognized test kits may not be used to say paint is not LBP. Evaluation, paint testing or presumption by certified LBP inspector or risk assessor. Certified renovators may evaluate only if also certified as LBP inspector or risk assessor. 35

147 Training and Certification EPA: EPA (or approved state) certifies renovators and firms. Only certified renovator required to successfully complete RRP course. Workers may receive on-the-job training from the certified renovator. HUD: All workers and supervisors apart from the certified renovator must successfully complete RRP course or other HUD-approved lead safe work practices course. 36

148 Treating LBP hazards EPA: Most renovations in target housing performed in a lead-safe manner. HUD: OHHLHC grantee projects use interim controls, standard practices with ongoing maintenance, and abatement. 37

149 Clearance EPA: Clearance verification performed by RRP supervisor on site. HUD: Dust wipe samples collected by certified LBP Inspector or Risk Assessor analyzed at NLLAP certified laboratory. 38

150 Two perspectives on changes Changes to HUD Lead Safe Housing Rule (LSHR) as a result of EPA Renovation, Repair and Painting (RRP) Rule Additional requirements for projects covered by HUD s LSHR as well as the EPA s RRP Rule 39

151 Main changes to HUD LSHR projects from EPA RRP Rule Tenant-based rental assistance: RRP rule covers housing even if no child under 6 lives there Training and certification: EPA- or State-certification is needed for the renovation firm and at least one supervisor or worker who is at the job or who is available when work is being done. 40

152 Additional Requirements for projects covered by HUD s LSHR as well as the EPA s RRP Rule 41

153 EPA s RRP Rule EPA Lead in Renovation, Repair and Painting (RRP) Rule: EPA pamphlet for RRP Use certified renovation contractors when disturbing LBP: 42

154 Determination that LBP is present. EPA: Certified renovators use EPArecognized test kit to determine presence of LBP. HUD: EPA-recognized test kits may not be used to say paint is not LBP. Evaluation, paint testing or presumption by certified individual. Renovators may evaluate only if certified as LBP inspector or risk assessor. 43

155 Training and Certification EPA: EPA certifies renovators and firms. Only certified renovator required to have classroom training. Workers may receive on-the-job training from the certified renovator. HUD: All workers and supervisors must complete HUD-approved lead safe work practices course. 44

156 Treating LBP hazards EPA: Most renovations in target housing performed in a lead-safe manner. HUD: Depending on type and amount of HUD assistance, most lead hazards treated using interim controls, some with ongoing lead-based paint maintenance. 45

157 Prohibited Work Practices EPA: Prohibits 3 work practices: open flame burning or torching, heat guns above 1100 degrees F, power sanding, etc., without HEPA vacuum attachment. HUD: EPA s plus: heat guns that char paint, dry scraping farther than 1 ft. of electrical outlets, and use of volatile strippers in poorly ventilated space. 46

158 De minimis amounts EPA: 6 sq. ft. per interior space; 20 sq. ft. for exterior work. HUD: 2 sq. ft. per interior space; 20 sq. ft. for exterior work. 47

159 Useful Web Pages Lead Regulations Renovation, Repair and Painting 48