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HUD Lead-Based Paint Regulations & New

Healthy Housing OpportunitiesMay 2016

Presented byKaren Griego

U.S. Department of Housing & UrbanDevelopment (HUD)

Office of Healthy Homes & Lead Hazard Control

Community Planning and Development

Why is Lead-Based Paint a Concern?

• Estimated 535,000 young children have blood-lead levels at or above *CDC reference value of 5µ/dl

• Irreversible health effects

• Brain and nervous system damage

• Reduced intelligence

• Learning disabilitiesChildhood lead poisoning is

“a major, preventable environmental health problem.”CDC, 1997

*Centers for Disease Control and Prevention


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Who is most at risk?

• Children under the age of six

• Pregnant women

• Workers


Lead-Based Paint is STILL a Concern…Really?

• “Despite progress, lead poisoning remains one of the top childhood environmental health problems today.”

President’s Task Force on Environmental Health Risks and Safety Risks to Children

• CDC estimates 538,000 children less than 6 have harmful levels of lead in their bodies; lead poisoning affects 1 in 38 children ages 1-5


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Lead-Based Paint is STILL a Concern…Really?

• HUD’s American Healthy Homes Survey: Lead and Arsenic Findings:

• 37.1 million(~35%) homes have lead-based paint

• Of which 23.2 million (~22%) have 1 or more lead hazards

• Of homes with lbp, 34 million (93%) are pre 1978

• Estimated 3.6 million homes with children <6 have 1 or more lbp hazards including 1.1 million low-income children


HUD’s Mission Statement

• HUD’s mission is to create strong, sustainable, inclusive communities and quality affordable homes for all.


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Provide a Broad Overview of LSHR & Opportunities for improving resident health using housing as a platform

Objective


Major Accomplishments

The percentage of children <6 who are lead poisoned have been reduced from about 8% to just over 1% in a decade

Childhood Lead

Poisoning Reductions


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• 1.0 mg/cm2 lead on surface

• 0.5% (5,000 ppm) lead in dry weight of paint film

• 1.0 mg/cm2 lead on surface

• 0.5% (5,000 ppm) lead in dry weight of paint film

Lead-Based Paint (LBP)

• Condition which causes exposure to lead that would result in adverse human effects from:

• Dust-lead

• Soil-lead

• Lead-based paint on deteriorated, chewable, friction, or impact surfaces

• Condition which causes exposure to lead that would result in adverse human effects from:

• Dust-lead

• Soil-lead

• Lead-based paint on deteriorated, chewable, friction, or impact surfaces

Lead-Based Paint Hazard


Purpose of Lead Regulations

• To protect children in Federally assisted target housing through primary prevention

– DO NO HARM


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2012 HUD Guidelines• Guidelines for the Evaluation and Control of

Lead-Based Paint Hazards in Housing second edition published 2012– Support HUD’s vision to reduce hazards in housing

in a cost-effective manner while protecting health

– Apply to lead hazard evaluation and control IN ALL FEDERALLY ASSOCIATED HOUSING

– Complement regulations issued by HUD, EPA, OSHA, CDC

– http://portal.hud.gov/hudportal/HUD?src=/program_offices/healthy_homes/lbp/hudguidelines


Federal AuthorityResidential Lead-Based Paint Hazard

Reduction Act of 1992

24 CFR Part 35

• Lead Disclosure Rule (LDR, Subpart A)

• Lead Safe Housing Rule (LSHR, Subparts B-R)

EPA Renovation, Repair & Painting (RRP)Community Planning and Development

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Subparts of HUD Lead Regulations• A - Lead Disclosure Rule• B - General Requirements & Definitions• C - Disposition by Federal Agency Other than HUD• D – Project-Based Assistance by Federal Agency Other than

HUD• F – HUD-Owned Single Family Sold With a HUD-Insured

Mortgage• G – Multifamily Mortgage Insurance• H – HUD Project-Based Assistance• I – HUD-Owned Multifamily Property• J – Rehabilitation Assistance• K – Acquisition, Leasing, Support Services, or Operation• L – Public Housing• M – Tenant-Based Rental Assistance for units to be occupied

by children under 6 years of ageCommunity Planning and Development

Commonalities

• *Provision of Pamphlet

• *Visual assessment or evaluation (testing by certified/accredited Risk Assessors/Inspectors)

• *Paint Stabilization, Interim Controls and/or Hazard Abatement

• *Clearance evaluation

• Notice to Occupants– Ongoing maintenance

– Response to EIBLL childCommunity Planning and Development

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EPA Dust Standards

• Lead in dust (clearance/risk assessment)

– Floors 40 mg/ft2

– Interior window sills 250 mg/ft2

– Troughs 400 mg/ft2 (clearance only)

• Lead in bare soil (risk assessment)

– Play areas 400 mg/g

– Other soils 1,200 mg/gCommunity Planning and Development

Interim Controls

• Training requirements for personnel

• Includes occupant protection and clearance

• Activities include

– Paint stabilization

– Friction or impact surfaces

– Chewable surfaces

– Dust-lead hazard control

– Soil-lead hazard control


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Paint Stabilization• Type of Interim Control• Includes:

– Substrate repair– Surface preparation methods– New paint

• Lead Safe Work Practices if over de minimis

• Clearance required over de minimis


Abatement• Certified personnel• Abatement of Lead-Based Paint or Lead-Based

Paint Hazards (depending on the Subpart requirement)

• Methods include:– Component replacement – Paint removal– Encapsulation (flow-on product; relies on adhesion;

20-year life)– Enclosure (mechanically fastened; 20-year life) – Paving or removal soil

• Clearance follows abatement24 CFR 35.1325


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Lead Safe Work Practices• Specifically required for:

– Ongoing LBP Maintenance– Paint stabilization– Rehab (<$5,000)– Standard treatments

• Prohibited methods• Occupant protection and worksite preparation• Specialized cleaning• Control dust generated with wet methods• Contain dust and debris• Proper clean-up and pass clearance• Required above de minimis levels


MF Mortgage Insurance• Property Built Before 1960

– Disclosure– Protect Your Family Pamphlet

– Risk Assessment (+notice to occupants)

– Treatment of all hazards by RRP certified firm & workers w/ lead safe work practices

– Clearance (+notice to occupants)

• Property Built after 1959/before 1978

– Disclosure – Protect Your Family Pamphlet

– Ongoing maintenance (using RRP and LSWP)

– Clearance (+notice to occupants


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Multifamily Mortgage Insurance

• Properties Undergoing Conversion or Major Rehab– Disclosure (Protect Your Family Pamphlet)

– Lead Inspection & Risk Assessment (+ noticing)

– Interim Control w/ LSWP and RRP Firm & Workers

– Clearance (+noticing)

– Ongoing Maintenance

– Environmental Intervention Blood Lead Level (EIBLL)


Project Based Rental Assistance

• Up to and including $5,000

– Disclosure + pamphlet

– Visual Assessment

– Paint Stabilization using LSWP & RRP Firm/Workers

– Clearance (+ noticing)


– EIBLL


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Project Based Rental Assistance

• Projects > $5,000

– Disclosure

– Risk Assessment (+ noticing)

– Interim Control of hazards with LSWP, RRP Firm & Workers (within 90 days if child <6; within 12 mosother units and common areas)

– Clearance (+ noticing)


– EIBLL


HUD-Owned & Mortgagee-in Possession MF Properties

• Disclosure (Protect Your Family Pamphlet)

• Lead Inspection & Risk Assessment (+ noticing)

• Interim Controls with LSWP, RRP Firm & Workers

• Clearance (+ noticing)

• Ongoing maintenance

• EIBLL


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HUD’s LSHRand

EPA’s Renovation, Repair, and Painting (RRP) Rule


EPA’s RRP Rule• California does not have an EPA RRP

accreditation program (defer to EPA) – Contractors become an EPA Certified

Renovator through an EPA approved training provider.

• RRP covers minor repair and maintenance activities that disturbs greater than 6 square feet of paint per room inside, or greater than 20 square feet on the exterior of a home or building.

Single Family Housing

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HUD’s LSHR and EPA’s RRP Rule

• Tenant-based rental assistance:

– RRP rule covers housing even if no child under 6 lives there

• Training and certification:

– (In CA) EPA- certification is needed for the renovation firm (including subs) and at least one supervisor or worker who is at the job or who is available when work is being done.


HUD’s LSHR and EPA’s RRP Rule• EPA: EPA certifies renovators and firms. (Some

states are authorized by EPA to do this for work in their state. There are none in Region IX.)Only certified renovator required to have classroom training.Workers may receive on-the-job training from the certified renovator.

• HUD: In addition - all workers and supervisors must have completed EPA-approved RRP lead safe work practices course; RRP course


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Historic Preservation

• LIMITED EXEMPTION

See

National Park Service Preservation Brief 37

HUD Guidelines – Chapter 18

Part 35 Subpart J: Interim control for exterior work on historic properties


Where Does Part 58 Fit In?

• Toxics Policy – 50.3(i)

(i) It is HUD policy that all properties that

are being proposed for use in HUD programs be free

of hazardous materials, contamination, toxic chemicals

and gases, and radioactive substances,

where a hazard could affect the health and safety of

occupants or conflict with the intended utilization of

the property.


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Renovate Right Brochure

http://www2.epa.gov/lead/materials-and-downloads-renovators-renovation-repair-and-painting

Lead Paint EPA RRP Fines

Individual fines can be as much as $37,500, but multiple violations can exceed this amount.


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HUD and EPA Resources• EPA RRP home page:

– www.epa.gov/lead/getleadsafe

• Hotline: Natl. Lead Info Ctr.: 800-424-LEAD

• OHHLHC RRP page:

– www.hud.gov/offices/lead/training/rrp/rrp.cfm

• OHHLHC Training Information home page:

– www.hud.gov/offices/lead/training/

• Hotline: [email protected]


HUD Lead Compliance Advisor Toolhttp://portalapps.hud.gov/CorvidRpt/HUDLBP/welcome.html

Public and Indian Housing

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HUD’s Healthy Homes Strategic Planhttp://www.hud.gov/offices/lead/library/hhi/hh_strategic_plan.pdf

• Recognizes housing as a platform to improve resident health through:

• Building a National Framework– Foster partnerships for implementing a healthy homes agenda

• Creating Healthy Housing through Key Research– Support strategic, focused research on links between housing and

health and cost-effective methods to address hazards

• Mainstreaming the Healthy Homes Approach– Promote the incorporation of healthy homes principles into

ongoing practices and programs

• Enabling Communities to Create and Sustain Healthy Homes Programs– Build sustainable local healthy homes programs


2016 NOFA Priorities(Applicants may earn up to 2 points for each

NOFA Priority)

• Increase Energy Efficiency and the Health and Safety of Homes

– Applicants certify existing HUD/DOE Better Buildings Challenge Partner (demonstrate development of a Showcase Project and track annual energy consumption)

– Commit to pursue comprehensive, industry-recognized green building standard and certification for green building

• And/OrCommunity Planning and Development

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2014 NOFA Priorities(Applicants may earn up to 2 points for

each NOFA Priority)• Certify project will incorporate renewable

energy technologies

– PV or Solar Thermal Electric, Landfill Gas, Wind Energy, Biomass, Combined Heat and Power, etc.

• Identify projects and activities that will comprehensively assess housing units for rehab, health and energy deficiencies and coordinate interventions across multiple disciplines and address risks based on assessment


Contact Information

Karen M. Griego

Healthy Homes Rep. Regions IX & X, NMOffice of Lead Hazard Control & Healthy HomesAlbuquerque Field Office500 Gold Ave SW, 7th Floor, Suite 7301P.O. Box 906Albuquerque, NM [email protected]

[email protected]


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Thanks for Attending!


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