January 26, 2015

CDBG Small Cities

What is Triggered under HUD Regulations?

HUDProjects costing less than $25,000When a contract specifies lead remediation

What is Triggered under HUD Regulations?

HUDProjects costing less than $25,000When a contract specifies lead remediation

Lead Safe Work Practices

Scenario 1:A project costs $22,000There are 3 children ages 9, 4 and 1 in residence

The property has not been tested for lead paint

Many areas at the property have defective paintWhat are your next steps?

Answer:Testing of the painted surfaces for lead are not

required since the funding is less than $25,000All defective surfaces are presumed lead-based

paintAll defective surfaces must be remediated by a

certified EPA RRP firmThe RRP firm must employee workers/supervisor

who have completed a HUD approved lead-safe work practice course

At the completion of the job, a DPH licensed lead consultant contractor must complete clearance dust wipes

Sample RRP Certificate

HUD’s Lead Safe Housing RuleHUD’s Lead Safe Housing Rule (LSHR) is

found at 24 CFR Part 35, Subparts B through M

Generally applies to work performed in target housing units receiving:HUD housing assistanceRehabilitation assistanceAcquisition assistance

Under the LSHR, the program participant (person accepting funding) becomes responsible for compliance with federal laws

HUD’s Lead Safe Housing RuleRenovation firms must be a certified EPA RRP

firmAll workers and supervisors must complete a

HUD approved lead-safe work practice course The EPA RRP certified renovator course is an

acceptable lead-safe work practice courseRenovators must hand out “Protect Your Family

from Lead in Your Home” brochureRenovators should hand out “Renovate Right”

brochureClearance dust wipes must be completed at the

end of a job where children reside by a DPH licensed lead consultant contractor

Protect Your Family brochure

EPA Renovate Right brochure

What is Required?

What do the HUD/DPH Requirements Trigger?

DPHChild under the age of 6 in residence

Blood lead level of 20µg/dL or two venous blood lead levels 15-19µg/dL taken three months apart

Defective lead-based paint has been identified (a local code enforcement official or a CT licensed lead professional)

Other child occupied units in the same dwelling with identified defective lead-based paint

HUDProjects costing more than $25,000When a contract specifies lead abatement

What do the HUD/DPH Requirements Trigger?

DPHChild under the age of 6 in residence

Blood lead level of 20µg/dL or two venous blood lead levels 15-19µg/dL taken three months apart

Defective lead-based paint has been identified (a local code enforcement official or a CT licensed lead professional)

Other child occupied units in the same dwelling with identified defective lead-based paint

HUDProjects costing more than $25,000When a contract specifies lead abatement

Lead Abatement

Scenario 2:

A project costs $39,000There are 2 children ages 7 and 2 in residence

The defective paint has been tested for lead and is positive

What are your next steps?

Answer:Because a child <6 years of age resides at the property

and there is defective lead paint, a comprehensive lead inspection is required

The comprehensive lead inspection will identify all lead painted surfaces and lead contaminated dust, water, and soil

All defective and chewable leaded surfaces must be abated

All intact leaded surfaces must be placed on a management plan

At the completion of the job, a DPH licensed lead consultant contractor must complete clearance dust wipes

Questions