Presentation on theme: "What Risk Assessors and Lead Inspectors need to know to be compliant with the 2012 HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards."— Presentation transcript:
What Risk Assessors and Lead Inspectors need to know to be compliant with the 2012 HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing NEW REVISED HUD GUIDELINES
RISK ASSESSMENT REPORT FORMAT New and Required Elements 1 – “Executive Summary” at beginning of the report. 2 - “Purpose of the Risk Assessment” that includes the following: Definition of Risk Assessment Explain why the risk assessment was performed 3 – Floor plan that includes the following: Windows and doors Room numbers and descriptions (room 5 / bedroom) Dust wipe locations (optional) 4 – Site plan that includes the following: Outline of structure on the site Location of outbuilding such as garages, sheds, etc. Location of fences, driveways, etc. Location of bare soil areas and where soil sampling occurred Directional marquee showing North 5 – Performance Characteristics Sheet must be included in Risk Assessment 6 – Statement of Disclosure Rule must be in report 7 – Visual Assessment is given greater emphasis in revised guidelines
NEW HUD RULES FOR PAINT EVALUATION 1 – “FAIR” Eliminated ……. Use only “intact” or “deteriorated” 2 – ceramic tile and porcelain bathtubs need not be tested 3 – hairline cracks and nail holes in plaster not considered deteriorated paint 4 – paint chip sampling is not recommended on broad scale 5 – mildew not considered paint deterioration 6 – chalking is deterioration per EPA but not required to be corrected per HUD 7 – Performance Characteristic Sheet must be followed or Risk Assessment report deemed invalid
NEW HUD RULES FOR DUST WIPES 1 - Spike samples no longer required 2 - Blank samples – one per single family or 1 per 20 in multi-family 3 - Trough samples not required by HUD but still required by Michigan regulations 4 - Sampling priority for dust wipes Child’s play room Kitchen Child’s bedroom Bathroom used by child Living room where child spends time 5 - Floor Sample from inside the principle entryway of a dwelling unit that has direct access to the outside.
NEW HUD RULES FOR SOIL SAMPLING 1 -Bare Soil of any size in a child’s play area shall be sampled 2 -Garden Soil has no EPA or HUD standards but should not exceed 400 ppm Collect garden soil 3-4” deep 3 - Soil in drip line/foundation of nonresidential outbuilding should be tested if the following conditions are present: Building is a substantial and permanent structure such as a garage Building is known to be built before 1978 Evidence that the walls or roof have been painted It is free standing and not structurally connected or part of a residential dwelling The bare soil is accessible to young children 4 - Multi-family soil sampling in Play areas 10 units or less than select 2 areas to sample More than 10 units select 3 areas to sample If more than 5 buildings in complex select 5 buildings for play-areas
MODEL RISK ASSESSMENT / LEAD INSPECTION TEMPLATE (1.0) LETTER TO OWNER The purpose of the lead inspection/risk assessment was to determine the existence of lead- based paint and lead based paint hazards at the subject property and to determine the location, type, and severity of existing or potential health hazards associated with exposures to lead. This report can help Owners develop a plan for eliminating any lead-based paint hazards that were found and aid in establishing an ongoing lead-based paint maintenance and re-evaluation program, if needed. As part of the assessment, a visual survey of the property and structure was conducted, dust wipe sampling was performed on interior surfaces, and soil samples were collected. In addition, on-site paint testing using a x-ray fluorescence (XRF) analyzer was performed. The following report details the results of the investigation. The Executive Summary details all of the lead paint hazards, soil hazards and dust wipe hazards found during this investigation. Please consult the appendix for additional information on how to interpret XRF results, definition of terms, measurement standards, site and floor plan, etc. A copy of this report must be provided to each new lessee (tenant) or purchaser of this property under Federal law (24 CFR part 35 and 40 CFR part 745) before they become obligated under a lease or sales contract. The complete report must also be provided to purchasers and made available to tenants. Landlords (lessors) and sellers are also required to distribute an educational pamphlet approved by the U.S. Environmental Protection Agency (EPA), entitled “Protect Your Family from Lead in Your Home”, and include standard warning language in their leases or sales contracts to ensure that parents have the information they need to protect their children from lead-based paint hazards. For more information regarding your obligations under federal lead-based paint regulations, contact LEAD (5323). Sincerely, Risk Assessor P-_____ Company name and phone number
EXECUTIVE SUMMARY (2.0) Executive Summary – The purpose of the Executive Summary is to summarize where the lead hazards were found at this property. For each identified paint, soil or dust hazard a recommended corrective action is also provided. The two types of corrective actions are 1 – abatement which is a permanent long term solution or 2 – interim control which is a shorter term solution. For example, painting the exterior of the house is an interim control as paint will need to be re-applied after a few years, however, applying vinyl siding is an abatement measure as it is considered permanent. All identified lead based paint and lead based paint hazards should always be properly addressed by professionally certified lead workers and firms.
EXECUTIVE SUMMARY (2.1)Existing Lead-based paint hazards and Available Control Options The following items describe the existing lead-based paint hazards identified at XYZ street. They are listed in priority order i.e. what hazards should be addressed first. Each hazard also has corresponding options for corrective actions known as abatement (long term) and interim control (shorter term) solutions. The owner or owner’s representative must select the most appropriate and affordable solution to address each of the identified hazards. Please note that these hazards may become more severe over time and additional hazards may be created with changing conditions at this property. LOCATIONCOMPONENTLEVEL OF SEVERITY ABATEMENT OPTIONS Higher Initial Cost INTERIM CONTROL OPTIONS Lower Initial Cost Room #_____ DescriptionInsert description Describe
DUST WIPES (2.3) Table of Dust-lead Hazards and control options. The following table identifies all dust samples taken and identifies those samples that represent dust lead hazards. Control options are provided for each identified dust hazard. All dust hazards are considered “severe” and should be corrected immediately. Dust samples are collected from window sills, troughs and floors in rooms where young children might come into contact with dust. Samples were collected from areas most likely to be lead contaminated if lead-in-dust is present. These samples were collected in accordance with the requirements of ASTM Standard E Please refer to Appendix C– Dust Wipe Analytical Results for the laboratory reports. Testing data identified as a hazard indicates dust lead levels at or above the EPA and HUD allowable levels.
Sample # Room Location SurfaceLead Concentration in (ug/ft2) Hazard Y / N Abatement Control Option ETC
SOIL SAMPLES (2.4) Table of Soil lead hazards and control options. The following table identifies all soil samples collected and identifies those samples that represent soil hazards. Control options are provided for each identified soil hazard. All soil hazards are considered “severe” and should be corrected immediately. Soil samples were collected at this residence in accordance with the requirements of ASTM Standard E The samples were collected from bare soil areas only. Please refer to Appendix D– Soil Sample Analytical Data for the detailed analytical reports. Testing data identified as a hazard indicates soil lead levels at or above the EPA and HUD allowable levels. Sample # Sample LocationLead level (ppm) Hazard Y / N Abatement Control Options
POTENTIAL HAZARDS (2.6) Table of Potential Lead Hazards and Possible Control Options The following table lists potential lead-based paint hazards identified at the time of inspection. These potential hazards could become lead-paint hazards over time and additional hazards could develop with changing conditions such as from a renovation activity. A control option is provided for each potential lead hazard. Lead safe work practices must be used if any of these surfaces are disturbed. LocationComponentAbatement OptionInterim Control Option
PROJECT LIMITATIONS (2.7) Project limitations, difficulties and excluded components A lead inspection requires testing of every unique painted surface. However, some surfaces could not be tested because of limitations such as inaccessible areas, windows not operable, clutter, unsafe building conditions, etc. All untested components should be assumed to contain lead-based paint. Lead safe work practices should always be used if those surfaces are disturbed. The following table lists those components and areas which the inspector was not able to test and the reason for which it was not tested. AREA / LOCATIONCOMPONENTREASON NOT TESTED
GENERAL PROPERTY DESCRIPTION (3.1) General Property Description Short Narrative – age of property, single family or rental, general condition, type of neighborhood, etc. Date of construction: Apparent building use: SF residential rental other _________ Setting: residential neighborhood mixed use other ________ Front Entry Faces: N E S W Design: 1 story 2 story duplex multi-family other Construction type: brick wood stucco other ___________________ Lot Type: small narrow large other ___________________ Roof: flat asphalt tile/slate other __________________ Foundation: crawl space stone cement slab Front lawn condition: good poor some bare areas other ____________ Back lawn condition: good poor some bare areas other ____________ Drip line condition: no bare soil some bare soil paint chips other ___ Exterior structural condition: OK house unsound other _____________________ Porch(s) front porch rear porch side porch(es) Interior structural condition: damaged walls/floors windows in poor condition doors in poor condition other _____________________ Overall building/site condition: poor marginal OK well maintained Garage none detached attached poor condition good condition other ________________________________
VISUAL PAINT CONDITION FORM (3.3) Paint Condition form (visual inspection of selected surfaces ) The purpose of the visual assessment is to locate potential exterior and interior lead- based paint hazards. A visual assessment is conducted in all rooms. The risk assessor also examines other exterior painted surfaces such as fences, garages, storage sheds and outbuildings that are part of the residential property and built before The risk assessor also examines the grounds to identify areas of bare soil. The result is a complete inventory of the location and approximate size of each potential lead based paint hazard. Building Component Paint Condition (intact or deteriorated) Area (sq/ft) Large or small area? Probable cause of deterioration Condition is common to all/most similar components Friction or impact surface Visible teeth marks? Y / N Siding soffits Exterior trim Exterior windows Exterior doors Porch railing/columns Porch floor Porch ceiling Exterior steps Interior doors Walls
CONTACT INFORMATION SHARE YOUR IDEAS STEVE M. SM ITH (616) TOWNSEND STREET LANSING, MI