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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