Module 9: Lead-Based Paint Requirements


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  • Right now we want to talk about the lead that is in the paint used on homes built prior to 1978. In the CDBG program, there are federal laws and regulations which require that potential lead based paint hazards be addressed if using CDBG funds for projects in residential units. (IF State has laws and regs mention that here too). If you leave this training and remember nothing else from this module, remember this: Lead-based paint is dangerous to our children and it’s found in homes built prior to 1978… the very homes you’re fixing with your CDBG money.
  • Why do we care about paint that has lead in it? Children exposed to lead hazards can develop long-lasting physical and neurological problems like Brain damage Behavior and learning disorders Exceptionally high levels of lead can even lead to death After the hazard is removed, the damage to the body isn’t… therefore it’s important to address lead hazards in our rehab work BEFORE children are poisoned.
  • Graph from an article in the “Washingtonian”   Shows violent crime from 1964 to 2004 and per-capita use of lead in gasoline between 1941 and 1986 Shows lead exposure paralleling violent crime with a lag of 23 years. The rate of violent crime is not declining as quickly as lead in gasoline, largely because lead hazards have not declined as quickly … just another reason why it’s important to address lead paint hazards
  • Where is this harmful stuff? mini-blinds Crayons Solder Fishing sinkers – did you bite them closed? … and We’ve recently heard of the high number of toys containing lead-based paint, and the harm that it’s doing to our children… LBP is also found in houses built prior to 1978 – with higher instances of lead hazards found in pre-1950 homes … and how many of the homes that you will be assisting - those with low-income families – are built before 1978?! That’s why your understanding of the dangers of LBP is important to the administration of your housing program
  • Because of this danger, the federal government has developed requirements for dealing with LBP in housing assisted with Federal funds to reduce the threat of childhood lead poisoning. It’s important for you to know about LBP if constituents complain about having to remove lead hazards in their home .
  • Where are those lead hazard in pre-1978 homes? Dust: normal cleaning of a house can circulate lead dust that has settled in carpeting. LBP dust is often found in window troughs – subject to breezes blowing LBP into the house Paint chips (including varnish) Paint hazards are also found on several different types of surfaces: Friction surface: Surface subject to abrasion or friction such as painted floors and friction surfaces on windows Impact surfaces: surface subject to damage by repeated impacts such as parts of door frames Chewable/Accessible surfaces : surface accessible for a young child to mouth or chew such as a window sill or door frame Soil: soil may contain high levels of lead-based paint as a result of chipping, peeling or dusting of exterior paint - may be from house or garage siding
  • The regulation that addresses hazards in pre-1978 homes is found at Section 1012 of the RLBPHRA It’s also known as Title 10 (not “X”) The lead-safe housing rule took effect on September 15, 2000 Different requirements about how you must deal with lead hazards depending on the nature of the federal assistance, the amount of federal assistance and the nature of the housing. Subpart “J” applies to rehab work done with CDBG funds  and is the topic of this presentation [If the state has state specific requirements then they should be inserted here and then in each following slide where applicable.]
  • As with many rules, this one has exceptions. Not all units are subject top the requirements of Title X [read slide] Housing for the elderly and handicapped must be housing that is specifically designed as senior/handicapped housing – not just a house where a senior citizen happens to live. FYI: It is possible that some housing units built after 1978 have lead-based paint due to the supply of LBP still in the pipeline. Just because the home was built in after 1-1-78 doesn’t guarantee that the unit is free of lead hazards.
  • Also exempt are: [read slide]
  • Your grant administrator must be sure that all owners and tenants who are receiving CDBG funds for a housing project and are living in units built prior to 1978 get this booklet. Recent estimates are that less than 10% of the population understands the importance of dealing with lead-based paint. EPA, HUD and CPSC developed a booklet entitled “Protect Your Family From Lead in Your Home”. Suggestion: To promote LBP safety, give the pamphlet to ALL applicants Show sample of booklet
  • Sometimes the lead work that is done on a house will require that the family is temporarily displaced – moved to a hotel or to the home of family or friends – during the rehab project. This temporary displacement is done to protect the family, and to let the hazard reduction be completed efficiently. [review slide] Temporary relocation is discussed in greater detail in the relocation module for grant administrators. Handout: Form to use when reimbursing the family for the cost of temporary relocation.
  • The treatment of units with lead hazards in CDBG funded rehab projects depends in part on how much federal money is spent on the rehab of that house. Your grant administrator will calculate the costs and prepare the appropriate documents for the work that needs to be done. As the local official, you need to know that if you’re spending federal funds on rehab, the lead hazards must be addressed, and that can get expensive .
  • After the work is finished, the contractor will clean the worksite or the entire unit. At this point the family still may not return to the home. Your grant administrator will arrange to have tests done to be sure the lead hazards have been adequately addressed. This is know as “clearance testing”. No payment may be made to the contractor until the work “clears” Occupants should only be allowed to go back to the worksite if clearance has been achieved. The occupants may complain to you… now you know why it’s important that they remain out of the house while the lead hazards are being addressed.
  • REMEMBER: most stringent parts of each regulation (Federal, state and local) applies.
  • Module 9: Lead-Based Paint Requirements

    1. 1. CDBG Lead-Based Paint Requirements For Local Officials
    2. 2. Why do we care? <ul><li>Harmful to the body </li></ul><ul><li>Stored in organs and bones </li></ul><ul><li>Long-lasting physical and neurological problems </li></ul><ul><li>Children under 6 yrs. and unborn babies most vulnerable </li></ul>
    3. 3.
    4. 4. Where is it? <ul><li>Toys, fishing equipment, blinds, crayons, water, pottery, lead crystal, solder </li></ul><ul><li>Pre-1978 homes </li></ul><ul><li>Higher percentage in pre-1950 homes </li></ul>
    5. 5. Purpose of LBP Requirements <ul><li>To reduce the threat of childhood lead poisoning in housing owned, assisted, or transferred by the Federal Government. </li></ul>
    6. 6. Lead-based paint hazards in a pre-1978 home <ul><li>Dust and paint chips </li></ul><ul><li>Deteriorated painted / varnished surfaces </li></ul><ul><li>Friction surfaces </li></ul><ul><li>Impact Surfaces </li></ul><ul><li>Chewable surfaces </li></ul><ul><li>Soil </li></ul>
    7. 7. Lead-based Paint Regulations <ul><li>Section 1012 of the Residential Lead-Based Paint Hazard Reduction Act of 1992 </li></ul><ul><li>a.k.a Title X </li></ul><ul><li>Regulations effective September 15, 2000 </li></ul><ul><ul><li>Subpart J </li></ul></ul>
    8. 8. Exemptions <ul><li>Housing units built after 1-1-78 (caution: LBP still in the supply line) </li></ul><ul><li>Housing for elderly (unless children are known to be present for prolonged periods of time </li></ul><ul><li>Non-residential property </li></ul><ul><li>Rehab where a painted surface will not be disturbed </li></ul><ul><li>Additional exemptions: SROs, efficiency units, dorms, military barracks </li></ul>
    9. 9. Exemptions continued <ul><li>Unoccupied unit that will remain vacant until it is demolished </li></ul><ul><li>Emergency repair actions needed to safeguard against imminent danger or further structural damage </li></ul><ul><li>Emergency housing (e.g. homeless) assistance that lasts less than 100 days per year </li></ul>
    10. 10. Notification <ul><li>Pamphlet: Protect Your Family From Lead in Your Home </li></ul><ul><ul><ul><li> / </li></ul></ul></ul><ul><li>Give to Owners and tenants </li></ul>
    11. 11. Temporary Relocation <ul><li>Necessary when: </li></ul><ul><ul><li>Can’t use kitchen or bath due to rehab work </li></ul></ul><ul><ul><li>Can’t close off work area from balance of living area </li></ul></ul><ul><ul><li>Children may be exposed to LBP dust </li></ul></ul><ul><li>NOT necessary when: </li></ul><ul><ul><li>Work done in an 8-hour period </li></ul></ul><ul><ul><li>Possible to secure worksite </li></ul></ul><ul><ul><li>Waiver signed where only elderly reside </li></ul></ul>
    12. 12. Treating LBP <ul><li>Three options for treatment </li></ul><ul><li>Based on dollar amount of non-lead rehab </li></ul><ul><ul><li>Less than $5,000 </li></ul></ul><ul><ul><li>Between $5,000 - $25,000 </li></ul></ul><ul><ul><li>More than $25,000 </li></ul></ul>
    13. 13. Clearance <ul><li>Occupants allowed back on site ONLY after clearance has been achieved </li></ul><ul><li>Don’t pay contractor until clearance has been achieved </li></ul>
    14. 14. State Requirements/Resources <ul><li>Insert any specific state requirements concerning lead-based paint hazards </li></ul>
    15. 15. Resources <ul><li>HUD Office of Healthy Homes and Lead Hazard Control </li></ul><ul><ul><li> </li></ul></ul><ul><li>Environmental Protection Agency (EPA) </li></ul><ul><ul><li> </li></ul></ul><ul><li>Occupational Safety and Health Organization (OSHA) </li></ul><ul><ul><li> </li></ul></ul>
    16. 16. Resources <ul><li>Guidance: </li></ul><ul><ul><li> </li></ul></ul><ul><li>For more information contact Connecticut Department of Public Health/ Lead Environmental Management Unit at </li></ul><ul><li>For more information also contact your local agency (Health/Housing) </li></ul>
    17. 17. Handouts <ul><li>Summary of Lead-Based Paint Requirements by Activity </li></ul><ul><li>Lead-Based Paint Requirements in CDBG-Assisted Housing Rehabilitation </li></ul><ul><li>Lead-Based Paint Rehabilitation Process </li></ul><ul><li>Guidance on HUD/EPA Abatement Letter </li></ul><ul><li>Temporary Relocation Reimbursement Form </li></ul>