january 26, 2015 cdbg small cities. what is triggered under hud regulations? hud projects costing...
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January 26, 2015
CDBG Small Cities
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What is Triggered under HUD Regulations?
HUDProjects costing less than $25,000When a contract specifies lead remediation
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What is Triggered under HUD Regulations?
HUDProjects costing less than $25,000When a contract specifies lead remediation
Lead Safe Work Practices
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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?
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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
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Sample RRP Certificate
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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
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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
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Protect Your Family brochure
EPA Renovate Right brochure
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What is Required?
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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
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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
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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?
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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
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Questions