Case studies of Building Management Grouping for Lead-Based Paint Testing
Tri-Tech Building Hygiene Services Is Less Always More? Two Case Studies in Building Management Grouping (BMG) for Lead-Based Paint InspectionsFor multi-family housing testing for lead-based paint (LBP), the HUD protocol prescribesa statistical random sampling of units based on a published schedule. This samplingmethod requires units of similar painting and maintenance history to be grouped together.The sampled units are used to project the LBP present in the untested units. It is commonfor lead paint testing firms to competitively bid on doing the bare minimum requiredunits, treating all the units the same. Building owners are often reluctant to discloseknowledge of atypical units during bidding, correctly believing it will increase theirtesting costs. While the building owners may wish to do the bare minimum to minimizecostly lead paint testing fees, they should be warned of the long-term disadvantages, asthese two case studies illustrate below: Apartment Complex constructed in 1968Tri-Tech was retained to perform a Lead-Based Paint Inspection and Risk Assessment ofa two-story two-building apartment complex constructed in the 1968. The buildingcontained a total of 110 units subjected to lead clearance testing. Based on the age, aminimum of 26 units is required to be tested for LBP. The owner had only owned thebuilding for about one year and did not have good historical information about thepainting and maintenance history but believed all the units were similar. However, afterrandom selection of the units was performed and the inspection was started, it waslearned from on-site personnel that two units had been nearly gutted and re-drywalleddue to a leak from an adjacent boiler, which had caused flooding and severe mold impact.These units were not scheduled to have been tested. By setting aside these units andtesting them separately for the remaining original painted components, Tri-Tech was ableto identify these as lead-free units that would have otherwise been projected to containLBP based on the results of the typical unit testing.In addition, one unit was inspected and found to be dissimilar. The carpet was heavilystained and had not been replaced in many years and much more LBP was found on theliving space walls, unlike the other atypical units. It was inferred that this was the on-siteresidence for maintenance or management personnel and was painted separately from thenormal tenant turnover painting program. By setting this unit aside as a separate BMG,the owner obtained the benefit of not having this anomalous unit cause the remaining 82untested units to be managed as having LBP in the Living Room, Dining Room, MasterBedroom or Hall. It should be noted that one anomalous unit does not necessarily affectthe determination for untested units, but in this case there were already a few additionalanomalous and apparently random occurrences from LBP that, combined with thisfinding, would have made a substantial difference in the LBP determination.
Tri-Tech Building Hygiene Services Apartment Building constructed in 1921Tri-Tech was retained to perform a Lead-Based Paint (LBP) Inspection and RiskAssessment of a four-story apartment complex constructed in the 1921. The buildingcontained a total of 91 units. Of these, 75 contained bedrooms and were subjected to leadclearance testing. The owner reported that all of the units had a generally similar paintingand maintenance history except that one unit had newer vinyl windows but had onlyowned the building for about 10 years. The City Building Department incorrectlyreported the building age as 1955 and this was thought to be a possible date of majorrenovation. The specific renovation history of the rental units was unknown. Based on theage of the building, it was judged likely that some wall/ceiling replacement and unitreconfiguration had occurred. Since it is not uncommon for a few units to be damagedand gutted due to water, fire or vandalism damage over time, is the practice of Tri-Techto have an allowance budgeted for the discovery of atypical units that may not have beenknown to the Owner but would be recognizable to an experienced building inspector.Tri-Tech proceeded with the lead testing of the minimum prescribed 39 of the 75 totalunits. During unit testing activities, it was discovered that the two northernmost wings onthe Fourth Floor were dissimilar from the other units. These units were characterized asdifferent from the others by the presence of LBP on the Kitchen walls and ceilings andthe interior (non-window) walls and ceilings of the Bathroom and LBP on baseboard inthe Master Bedroom. LBP was not found to occur at these locations in the other typicalunits. The LBP was also generally less intact than the other typical units. It appeared thatthese two wings were omitted from renovation at one point or were otherwise manageddifferently. Therefore, these atypical units were tested as a separate BMG. In doing so,the building owner obtained the following benefits: • The 23 untested typical units could be managed as having no LBP on the Kitchen walls or ceilings or the Bathroom interior walls and ceilings or on the Master Bedroom baseboard. Had the bare minimum been done, these components would all have been listed as positive for LBP. • Having a separate set of atypical units known to have more LBP with a higher rate of damage assists the owner in making decisions about leasing to young couples or tenants with very young children and can direct maintenance personnel to monitor these units more closely.