In July of 2012, the U.S. Department of Housing and Urban Development (HUD) released the second edition of the “Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing.” Anyone who printed the new Risk Assessment forms off the HUD Website knows this was a long time coming. It was almost second nature to scratch out the previous edition of lead dust and lead soil hazard levels and write in the current ones.
HUD has also released updated guidance for all grant programs under the Office of Healthy Homes and Lead Hazard Control (OHHLHC) regarding conducting lead-based paint inspections and risk assessments. This guidance was released after the Office conducted over 50 onsite visits to grantees, which accounted for approximately 20 percent of their active portfolio. As a lead risk assessor who provides these services for a HUD funded grant program, I have looked through these documents to see what, as a consultant, I could take away from this information.
According to Michelle Miller, Programs Division Director for OHHLHC, major issues were noted with the lead inspections and risk assessments themselves. “In many cases, only partial or limited lead-based paint inspections and risk assessments were being conducted,” remarked Miller. This issue became increasingly important with the OHHLHC’s clarification on window replacement. “The OHHLHC recognizes that windows are costly. Our grant programs were not intended to be a window replacement program; rather, OHHLHC grants were intended to perform lead hazard control/ interim control of all lead-based paint hazards on a property. For windows, testing of only a single window representing a testing combination for an entire property (interior and exterior) is not permitted.” Not properly testing window combinations can create repeated site visits, should the Grantee program you work with want it done properly. There is also the chance, the Grantee program can lose funding for improper inspections, which is a no-win situation for everyone involved.
If you have a client who is receiving funding from HUD, you may unknowingly be making mistakes or omissions on your reports.
Additionally, another major find from the onsite visits were “Lead-based paint inspection and risk assessment reports not properly documented in accordance with Chapters 5 and 7 of the HUD Guidelines.” Going forward, OHHLHC will be requiring photographic evidence of the lead hazards to justify the replacement of more than 5 windows per house. The OHHLHC also outlined its policy on lead-based paint and other surface coatings to be included in their hazard programs and which are not, including unpainted ceramic bathroom tile and porcelain bathtubs.
These new guidelines may not apply to your typical residential lead-based paint inspection and risk assessment, however if you have a client who is receiving funding from HUD, you may unknowingly be making mistakes or omissions on your reports. For the official memorandums and guidance, please visit www.hud.gov.