2
Why do we care?
• Harmful to the body• Stored in organs and bones• Long-lasting physical and neurological
problems• Children under 6 yrs. and unborn babies
most vulnerable
4
Where is it?
• Toys, fishing equipment, blinds, crayons, water, pottery, lead crystal, solder
• Pre-1978 homes• Higher percentage in pre-1950 homes
5
Lead-based paint hazards in a pre-1978 home
• Dust and paint chips• Deteriorated painted / varnished surfaces• Friction surfaces• Impact Surfaces• Chewable surfaces• Soil
6
Lead-based paint regs
• New regulations published in 1999• Section 1012 of the Residential Lead-Based
Paint Hazard Reduction Act of 1992• a.k.a Title X Subpart J• 24 CFR Part 35
7
Applicability
• If you are doing rehab on a pre-1978 home, and broken painted surfaces exist, or if the work you are doing will break paint, you must address all potential lead hazards, including soil.
8
Purpose
• To reduce the threat of childhood lead poisoning in housing owned, assisted, or transferred by the Federal Government.
9
Exemptions
• House built after 1-1-78 • Housing exclusively for elderly (unless
children under 6 could be present for prolonged periods of time )
• SROs, efficiency apts, dorms, military barracks
• Certified lead-free property
10
Exemptions
• Property where LBP was removed and clearance was achieved
• Unoccupied units that will remain vacant until it is demolished
• Non-residential property • Rehab where a painted surface will not be
disturbed
11
Exemptions
• Rehab where only a “de minimis” amount of paint is disturbed
• Emergency repair actions needed to safeguard against imminent danger or further structural damage
• Emergency housing (e.g. homeless) assistance that lasts less than 100 days per year
• NOTE: All exemptions must be documented
13
Disclosure
• Pamphlet: Protect Your Family From Lead in Your Home−http://www.hud.gov/offices/lead/outreach/
• Owners and tenants
14
Disclosure
• Evaluation of lead-based paint• Forms
−Owners and renters
• Sample forms:−http://www.hud.gov/offices/lead/disclosurerule/
index.cfm
15
Inspection
• Inspect the home to determine needed rehab
• Important to identify all repairs needed
16
Evaluation
• < $5,000 per unit −Test paint or presume LBP
• >$5,000 per unit−Test paint or presume LBP−Risk assessment
17
Evaluation
• When do you presume lead?−Property is in poor condition−Rehab job is small−You have reason to believe lead exists
Pre-1950 building Similar units in the neighborhood
−Work needs to begin immediately
18
Pre-Rehab
• Develop estimate• Allocate costs to rehab or LBP• Treatment method based on cost of non-
lead rehab• Determine treatment method
ALWAYS:−Lead-safe work practices by trained personnel−Occupant Protection Plan By Contractor
20
Standard Treatments
• Stabilize all deteriorated paint (interior and exterior)
• Create smooth cleanable horizontal surfaces
• Correct dust generating conditions−Friction surfaces−Impact surfaces
• Treat bare soil−To make LBP contaminated soil inaccessible
21
Interim Controls
• Acceptable way to reduce exposure to LBP hazards, although not permanent
• Paint stabilization• Treatment of friction & impact surfaces• Treatment of chewable surfaces• Lead-contaminated dust control (24 CFR
35.1330)• Lead-contaminated soil control
22
Abatement
• Permanent elimination of lead-based paint hazards
• Remove lead-based paint and its dust• Permanently encapsulate or enclose the
LBP• Replace components that have LBP
24
Lead Safe Work Practices
• Occupant Protection Plan• Done by Contractor• Must include:
−No entry into worksite−Temporary relocation if necessary−Protect contents of home from LBP contamination
25
Temporary Relocation
• Necessary when:−Can’t use kitchen or bath due to rehab work−Can’t close off work area from balance of living
area−Children may be exposed to LBP dust
• NOT necessary when:−Work done in an 8-hour period−Possible to secure worksite−Waiver -- for elderly occupants
26
Lead Safe Work Practices
• Worksite Preparation and Containment• Prohibited methods• Worksite Cleanup• One-day training for workers• Not required for de minimis levels of work• 24 CFR 35.140; 35.1350; 35.1345
27
Worksite Preparation
• Prevent LBP and dust from leaving worksite• Minimize spread of dust, paint chips, soil and
debris• 6 mil plastic on floors and over doors• Warning signs regarding LBP hazard
reduction activities
28
Prohibited Methods of Abatement
• Some methods of paint removal are prohibited because they increase the lead hazard−Open flame burning or torching−Machine sanding or grinding−Abrasive blasting−Paint stripping in poorly ventilated space
• 24 CFR 35.140
29
Cleanup and Clearance
• ALL worksites must be cleaned and pass a clearance test that assures the area has been properly cleaned of lead-based paint.
• Clearance Report−Documents results of clearance test−To UGLG, owner, and occupant
• Clearance test NOT done by contractor
30
ALWAYS
• Notifications to owner/occupant [24 CFR 35.125]−HUD pamphlet−Evaluations, work to be done, clearance reports
• Lead-safe work practices
• Clearance [24 CFR 35.1340]−Work site−Entire Unit
31
Determining Level of Rehab Assistance
• 24 CFR 35.915• Per unit amount of rehab “hard” costs• Federal Funds Only• NOT lead paint related costs• Not “soft” costs
32
Determining Level of Rehab Assistance
• Total Rehab Cost Estimate• Subtract identified LBP costs
−Cost of work damaging a painted surface−Cost of work addressing deteriorated paint−Cost of other work components with potential for
LBP impact
• = Level of rehab assistance
• Cost Allocation Document to show how level of rehab was determined
33
Getting the work done
• Treatment method is based on the amount of non-lead rehabilitation costs per unit
−< $5,000
−$5,000 - $25,000
−> $25,000
34
< $5,000
• Do no harm (to the occupant) • Test paint or Presume• Rehab as usual with Lead Safe Work
Practices• Use Standard Treatments on broken or
deteriorated painted surfaces• Clear the worksite
35
> $5,000 - $25,000
• Must Control Lead Hazards
• Test Paint and Do Risk Assessment−Interim Controls
- or-• Presume LBP
−Standard Treatments
• Clear Unit
36
> $25,000
• Test Paint and Do Risk Assessment−Abate LBP Hazards−Interim Controls Allowed on Exterior Surfaces not
otherwise disturbed-or-
• Presume LBP −Abate all applicable surfaces
• Clear Unit
37
Clearance/Notification
• ALWAYS Do this!
• Methods and standards per EPA at 40 CFR 745.227(e)
• Must be done by certified clearance inspector
• NOT done by contractor who did the work
• Copy of report to owner and occupant
• 24 CFR 35.930
38
Clearance
• < $5,000 non-lead rehab• Worksite only• Not necessary if work is de minimis
• > $5,000• Clear entire house
39
Clearance
• Occupants allowed back on site ONLY after clearance has been achieved
• Don’t pay contractor until clearance has been achieved
41
Recordkeeping Requirements
• In each rehab project file:
−Documentation of receipt of HUD booklet−Inspection−Risk assessment−Worker certifications−Temporary relocation claims and calculations−Clearance documents
42
Resources
• HUD Office of Healthy Homes and Lead Hazard Control −www.hud.gov/offices/lead
• Environmental Protection Agency (EPA)−www.epa.gov/lead
• Occupational Safety and Health Organization (OSHA)−www.osha.gov
Top Related