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CDBG Lead-Based Paint Requirements. For Grant Administrators. Why do we care?. Harmful to the body Stored in organs and bones Long-lasting physical and neurological problems Children under 6 yrs. and unborn babies most vulnerable. Where is it?.

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Cdbg lead based paint requirements

CDBG Lead-Based Paint Requirements

For Grant Administrators

Why do we care
Why do we care?

  • Harmful to the body

  • Stored in organs and bones

  • Long-lasting physical and neurological problems

  • Children under 6 yrs. and unborn babies most vulnerable

Where is it
Where is it?

  • Toys, fishing equipment, blinds, crayons, water, pottery, lead crystal, solder

  • Pre-1978 homes

  • Higher percentage in pre-1950 homes

Lead based paint hazards in a pre 1978 home
Lead-based paint hazards in a pre-1978 home

  • Dust and paint chips

  • Deteriorated painted / varnished surfaces

  • Friction surfaces

  • Impact Surfaces

  • Chewable surfaces

  • Soil

Lead based paint regs
Lead-based paint regs

  • New regulations published in 1999

  • Section 1012 of the Residential Lead-Based Paint Hazard Reduction Act of 1992

  • a.k.a Title X Subpart J

  • 24 CFR Part 35


  • If you are doing rehab on a pre-1978 home, and broken painted surfaces exist, or if the work you are doing will break paint, you must address all potential lead hazards, including soil.


  • To reduce the threat of childhood lead poisoning in housing owned, assisted, or transferred by the Federal Government.


  • House built after 1-1-78

  • Housing exclusively for elderly (unless children under 6 could be present for prolonged periods of time )

  • SROs, efficiency apts, dorms, military barracks

  • Certified lead-free property


  • Property where LBP was removed and clearance was achieved

  • Unoccupied units that will remain vacant until it is demolished

  • Non-residential property

  • Rehab where a painted surface will not be disturbed


  • Rehab where only a “de minimis” amount of paint is disturbed

  • Emergency repair actions needed to safeguard against imminent danger or further structural damage

  • Emergency housing (e.g. homeless) assistance that lasts less than 100 days per year

  • NOTE: All exemptions must be documented

What you need to do:




Address the Hazard




  • Pamphlet: Protect Your Family From Lead in Your Home


  • Owners and tenants


  • Evaluation of lead-based paint

  • Forms

    • Owners and renters

  • Sample forms:



  • Inspect the home to determine needed rehab

  • Important to identify all repairs needed


  • < $5,000 per unit

    • Test paint or presume LBP

  • >$5,000 per unit

    • Test paint or presume LBP

    • Risk assessment


  • When do you presume lead?

    • Property is in poor condition

    • Rehab job is small

    • You have reason to believe lead exists

      • Pre-1950 building

      • Similar units in the neighborhood

    • Work needs to begin immediately

Pre rehab

  • Develop estimate

  • Allocate costs to rehab or LBP

  • Treatment method based on cost of non-lead rehab

  • Determine treatment method


    • Lead-safe work practices by trained personnel

    • Occupant Protection Plan By Contractor

Terms to know

  • Standard Treatments

  • Interim Controls

  • Abatement

  • Lead Safe Work Practices

Standard treatments
Standard Treatments

  • Stabilize all deteriorated paint (interior and exterior)

  • Create smooth cleanable horizontal surfaces

  • Correct dust generating conditions

    • Friction surfaces

    • Impact surfaces

  • Treat bare soil

    • To make LBP contaminated soil inaccessible

Interim controls
Interim Controls

  • Acceptable way to reduce exposure to LBP hazards, although not permanent

  • Paint stabilization

  • Treatment of friction & impact surfaces

  • Treatment of chewable surfaces

  • Lead-contaminated dust control (24 CFR 35.1330)

  • Lead-contaminated soil control


  • Permanent elimination of lead-based paint hazards

  • Remove lead-based paint and its dust

  • Permanently encapsulate or enclose the LBP

  • Replace components that have LBP


  • Remove or permanently cover lead-contaminated soil

  • If ordered by enforcement agency

Lead safe work practices
Lead Safe Work Practices

  • Occupant Protection Plan

  • Done by Contractor

  • Must include:

    • No entry into worksite

    • Temporary relocation if necessary

    • Protect contents of home from LBP contamination

Temporary relocation
Temporary Relocation

  • Necessary when:

    • Can’t use kitchen or bath due to rehab work

    • Can’t close off work area from balance of living area

    • Children may be exposed to LBP dust

  • NOT necessary when:

    • Work done in an 8-hour period

    • Possible to secure worksite

    • Waiver -- for elderly occupants

Lead safe work practices1
Lead Safe Work Practices

  • Worksite Preparation and Containment

  • Prohibited methods

  • Worksite Cleanup

  • One-day training for workers

  • Not required for de minimis levels of work

  • 24 CFR 35.140; 35.1350; 35.1345

Worksite preparation
Worksite Preparation

  • Prevent LBP and dust from leaving worksite

  • Minimize spread of dust, paint chips, soil and debris

  • 6 milplastic on floors and over doors

  • Warning signs regarding LBP hazard reduction activities

Prohibited methods of abatement
Prohibited Methods of Abatement

  • Some methods of paint removal are prohibited because they increase the lead hazard

    • Open flame burning or torching

    • Machine sanding or grinding

    • Abrasive blasting

    • Paint stripping in poorly ventilated space

  • 24 CFR 35.140

Cleanup and clearance
Cleanup and Clearance

  • ALL worksites must be cleaned and pass a clearance test that assures the area has been properly cleaned of lead-based paint.

  • Clearance Report

    • Documents results of clearance test

    • To UGLG, owner, and occupant

  • Clearance test NOT done by contractor


  • Notifications to owner/occupant [24 CFR 35.125]

    • HUD pamphlet

    • Evaluations, work to be done, clearance reports

  • Lead-safe work practices

  • Clearance [24 CFR 35.1340]

    • Work site

    • Entire Unit

Determining level of rehab assistance
Determining Level of Rehab Assistance

  • 24 CFR 35.915

  • Per unit amount of rehab “hard” costs

  • Federal Funds Only

  • NOT lead paint related costs

  • Not “soft” costs

Determining level of rehab assistance1
Determining Level of Rehab Assistance

  • Total Rehab Cost Estimate

  • Subtract identified LBP costs

    • Cost of work damaging a painted surface

    • Cost of work addressing deteriorated paint

    • Cost of otherwork components with potential for LBP impact

  • = Level of rehab assistance

  • Cost Allocation Document to show how level of rehab was determined

Getting the work done
Getting the work done

  • Treatment method is based on the amount of non-lead rehabilitation costs per unit

    • < $5,000

    • $5,000 - $25,000

    • > $25,000

5 000
< $5,000

  • Do no harm (to the occupant)

  • Test paint or Presume

  • Rehab as usual with Lead Safe Work Practices

  • Use Standard Treatments on broken or deteriorated painted surfaces

  • Clear the worksite

5 000 25 000
> $5,000 - $25,000

  • Must Control Lead Hazards

  • Test Paint and Do Risk Assessment

    • Interim Controls

      - or-

  • Presume LBP

    • Standard Treatments

  • Clear Unit

25 000
> $25,000

  • Test Paint and Do Risk Assessment

    • Abate LBP Hazards

    • Interim Controls Allowed on Exterior Surfaces not otherwise disturbed


  • Presume LBP

    • Abate all applicable surfaces

  • Clear Unit

Clearance notification

  • ALWAYS Do this!

  • Methods and standards per EPA at 40 CFR 745.227(e)

  • Must be done by certified clearance inspector

  • NOT done by contractor who did the work

  • Copy of report to owner and occupant

  • 24 CFR 35.930


  • < $5,000 non-lead rehab

  • Worksite only

  • Not necessary if work is de minimis

  • > $5,000

  • Clear entire house


  • Occupants allowed back on site ONLY after clearance has been achieved

  • Don’t pay contractor until clearance has been achieved

State requirements resources
State Requirements/Resources

Insert State Specific Requirements

Recordkeeping requirements
Recordkeeping Requirements

  • In each rehab project file:

    • Documentation of receipt of HUD booklet

    • Inspection

    • Risk assessment

    • Worker certifications

    • Temporary relocation claims and calculations

    • Clearance documents


  • HUD Office of Healthy Homes and Lead Hazard Control


  • Environmental Protection Agency (EPA)


  • Occupational Safety and Health Organization (OSHA)



  • Guidance:



  • Summary of Lead-Based Paint Requirements by Activity

  • Lead-Based Paint Requirements in CDBG-Assisted Housing Rehabilitation

  • Lead-Based Paint Rehabilitation Process

  • Guidance on HUD/EPA Abatement Letter