operations and maintenance plan for lead-based …...2017/05/19 · operations and maintenance plan...

Operations and Maintenance Plan

for Lead-Based Paint

Former Pioneer Press Building 345 Cedar Street St. Paul, Minnesota

Prepared for

Dougherty Mortgage LLC

And Pioneer Apartments, LLLP Warning: This document may not be reproduced or excerpted from in substantial part without the expressed written permission of Braun Intertec Corporation. Braun Intertec Corporation 11001 Hampshire Avenue South Bloomington, MN 55438 Project B1702158.03 May 19, 2017

Table of Contents

Description Page Operations and Maintenance Plan ................................................................................................................ 1 for Lead-Based Paint ..................................................................................................................................... 1 A. Introduction ...................................................................................................................................... 2

A.1. Purpose ................................................................................................................................ 2 A.2. Background .......................................................................................................................... 2

B. Objectives and Elements of the O&M Program ............................................................................... 2 C. Notifications ..................................................................................................................................... 2

C.1. Elements of notification ...................................................................................................... 3 C.2. Methods OF Notification ..................................................................................................... 3 C.3. Required information .......................................................................................................... 3 C.4. Short Term Worker Acknowledgment ................................................................................ 4

D. Labels and Signs ................................................................................................................................ 4 E. Training ............................................................................................................................................. 4

E.1. Training for O&M Coordinator ............................................................................................ 4 E.2. Training for Maintenance Employees ................................................................................. 5 E.3. Training for Abatement Contractors ................................................................................... 5 E.4. Medical Surveillance and Employee Protection Program ................................................... 5

F. Maintenance and Renovation Permit System .................................................................................. 6 F.1. O&M Coordinator Permit Issuance Procedure ................................................................... 6 F.2. Special Work practices for renovation and remodeling ...................................................... 6

G. Periodic Surveillance - Reinspection ................................................................................................ 7 H. Emergency Response Procedures .................................................................................................... 7 I. Certification ...................................................................................................................................... 7

List of Appendices Appendix A: Lead-Based Paint Guidance for HUD Field Staff Appendix B: Lead-Based Paint Summary Table Appendix C: Example Notification Letter and Form Appendix D: Example Worker Acknowledgment Form Appendix E: Example Documentation of Training Form Appendix F: Renovate Right Brochure Appendix G: Example Maintenance and Work Permit System Form Appendix H: Example Periodic Surveillance Form

Former Pioneer Press Building – Lead Based Paint O&M Plan (May 19, 2017)

A. Introduction

A.1. Purpose

Braun Intertec Corporation was retained by Dougherty Mortgage LLC, to develop a Lead-Based Paint

Operation and Maintenance (O&M) Program Manual for the property located at 345 Cedar Street in St. Paul,

Minnesota (the Property). The purpose of the O&M Program Manual is to outline procedures to effectively

maintain and manage lead-based paint (LBP) in place until it must be removed due to a scheduled

renovation or demolition, or its condition warrants removal. Included in Appendix A is the Lead-Based Paint

Guidance for Owners and HUD Field Staff, prepared by U.S. Department of Housing and Urban Development

(HUD), which provides additional information for property owners about LBP compliance.

A.2. Background

The Property is occupied by an eight-story office structure with a full basement, penthouse, and elevator

equipment room on the roof. It was constructed in 1955 and encompasses approximately 162,000 total

square feet. The building is constructed of brick, concrete and steel. The typical interior finishes included

sheetrock/joint compound, plaster, floor tile, carpeting, lay-in ceiling panels, ceiling tiles, and vinyl sheet

flooring. There is an elevator shaft located in the west central area of the building and connects the

basement to the eighth floor. There are mechanical/duct rooms on the northeast and southeast corners

of each floor, and main vertical pipe chases centered on the north perimeter wall, south perimeter wall,

and central area just north of the elevator shafts. The exterior of the structure has concrete and brick

walls with a rubber membrane roof system. There is a single-story maintenance garage

(fleet maintenance building) to the west of the office building that has concrete block interior walls,

brick and mortar exterior walls and a rubber membrane roof system.

Braun Intertec completed a Pre-Renovation Hazardous Building Materials Inspection and Lead-Based

Paint Inspection Report dated April 13, 2017 (2017 Inspection). Based on the 2017 Inspection,

the identified LBP-coated components included interior components: plaster, ceramic and concrete

walls; plaster columns; plaster, and wood ceilings; concrete floors and stair risers; metal valves; wood

window casing; metal pipes. LBP was identified on the following components located on the exterior of

the buildings: metal garage door lintel, jambs, and guards; metal access door and door lintel; metal

decorative gate; and parking lot striping on asphalt. A summary table of the identified LBP components is

included in Appendix B.

Lead-Based Paint O&M Program Manual Project B1702158.03 May 19, 2017 Page 2

B. Objectives and Elements of the O&M Program

The objective of the O&M Program is to minimize the potential for lead exposure to anyone at the Property.

The specific elements of the O&M Program are as follows:

Notification practices and procedures

Training for the O&M Coordinator and key maintenance personnel

Maintenance and Renovation permit system

Special work practices for maintenance activities

Special work practices for renovations

Emergency response procedures

Periodic surveillance program

Recordkeeping

For purposes of implementing this O&M Program, only qualified personnel will perform LBP abatement-

related work activities. Adequate training will be provided to key maintenance personnel who will be

responsible for monitoring the building condition and be able to effectively identify areas of potential

hazards. In addition, an individual will be assigned the role of O&M Coordinator. This person will be

responsible for, and trained to, implement the O&M Program and assure that guidelines and provisions of

the program are met. All abatement activities will be conducted in accordance with all applicable federal,

state and local regulatory requirements.

C. Notifications

Notification is a key element of the O&M Program. Building occupants in units or areas where a renovation

and/or repair project is planned that will involve the disturbance of LBP will be notified in advance of work of

the potential hazards and the precautions that will be taken.

Employees and outside vendors who are aware of the presence of LBP are less likely to disturb the materials.

Therefore, notification is considered a key element of the O&M Program.


C.1. Elements of notification

The elements of notification include:

Notification of employees and outside vendors.

Notification of building occupants, when appropriate or required.

The notification serves two purposes:

1. It alerts affected parties to potential hazards in the buildings; and

2. It provides basic information on avoiding related hazards.

C.2. Methods OF Notification

Notification of occupants and other affected individuals may be accomplished in the following ways:

Distributing a notice or letter.

Holding awareness training for all maintenance personnel.

Issuance of a permit system to all outside contractors.

C.3. Required information

The following information should be available to notified individuals:

What has been done to protect occupants.

Types and locations of LBP hazards at the Property.

How individuals can avoid disturbing LBP.

How maintenance personnel are dealing with assumed LBP to prevent lead dust.

What will be done periodically and over the long-term to protect the health and safety of the

building occupants?

Name and telephone number of the person responsible for LBP related activities.

An example notification letter is included in Appendix C. Documentation of individuals notified should be

kept on file. An example notification form used to document each individual notified is also included in

Appendix C. This format or a similar format will be utilized as part of this O&M Program.


C.4. Short Term Worker Acknowledgment

Documentation of notification should be completed to outside vendors (such as a plumber or electrician)

who conduct activities which may disturb LBP within the facility. An example format to use for this

documentation is included in Appendix D. This format or a similar format will be utilized as part of this

O&M Program.

D. Labels and Signs

All outside licensed abatement contractors and/or certified renovators involved with a renovation and/or

repair project that involves the disturbance of LBP within the facility, must post signs at the entrance and the

perimeter of the regulated area of the project. All signs and postings of the project must be in accordance

with the OSHA Standards and all other applicable regulations.

E. Training

The O&M Coordinator shall ensure that initial and on-going training requirements in the O&M Program

are met. The O&M Coordinator shall maintain all employee training records for thirty years beyond the

employee’s last date of employment. An example format for documentation of training is included in

Appendix E. This format or a similar format will be used as part of this O&M Plan.

E.1. Training for O&M Coordinator

The O&M Coordinator is responsible for overseeing all O&M activities. He/she must be familiar with

appropriate procedures for operations and maintenance activities involving lead-based paint and

lead hazards.

The O&M Coordinator shall complete an initial course of training in lead hazards. The course should address

the following areas at a minimum:

History and uses of lead.

Health effects of lead.

Legal and liability considerations related to lead.

Criteria for hazards assessment of lead hazard screens.

Building assessment results.


Personal protective equipment for lead-based paint.

Regulatory requirements pertinent to lead-based paint.

Requirements for record keeping and report preparation concerning lead-based paint

operations and maintenance activities.

E.2. Training for Maintenance Employees

All maintenance employees shall attend an awareness course on lead hazards. At a minimum, training

should cover:

Information regarding lead and its various uses and forms.

Information on the health effects associated with lead and medical surveillance

requirements.

Locations of LBP.

Guidance for recognition of damage, or deterioration of LBP.

Use of work permit system.

Emergency situations.

Contact person(s) for questions regarding LBP.

Additional training is required if maintenance personnel will conduct LBP abatement activities. It must be

noted that the awareness training is not sufficient for employees to conduct LBP abatement activities.

E.3. Training for Abatement Contractors

All outside contractors and their workers performing abatement work shall be licensed and certified to

perform the specified abatement work by the State of Minnesota.

E.4. Medical Surveillance and Employee Protection Program

It is assumed that maintenance personnel at the Property will not be involved in LBP abatement activities.

Therefore no medical surveillance program is required.


F. Maintenance and Renovation Permit System

F.1. O&M Coordinator Permit Issuance Procedure

Minimizing inadvertent disruption of LBP during maintenance and/or renovation is the responsibility of the

O&M Coordinator. It may be prudent to initiate a permitting system, where all work orders or requests are

approved by the O&M Coordinator either verbally or using written forms. This permit system is an effective

way of controlling disruption to LBP during maintenance and renovation activities.

The permit system should require that all requests for activities that may disturb LBP be submitted for

authorization to proceed. The O&M Coordinator should physically inspect the area to make sure no LBP is

present in the work area prior to giving authorization to proceed.

The O&M Coordinator will assess the situation to determine whether or not the maintenance activity can

proceed without disturbing the LBP or if the activity will need to be modified to avoid disturbance or be

deferred until the LBP in the area can be properly removed or abated by a licensed contractor.

Contractors/vendors conducting work which will involve disturbance of any of the identified or suspected

LBP components should comply with the new U.S. Environmental Protection Agency (EPA) Renovation,

Repair, and Maintenance Program Rule (40 CFR Part 745) (RRP Rule). This rule requires contractor

certification, tenant notifications, lead-safe work practices, clearance verification and record keeping.

A copy of the EPA’s Renovate Right brochure is included in Appendix F and provides information about

the EPA RRP Rule.

Example formats for written documentation of the permit system are included in Appendix G.

F.2. Special Work practices for renovation and remodeling

Building renovation, remodeling or building system replacement can be a cause for disturbance of LBP.

Activities such as moving walls, adding rooms, or replacing ceilings or floors may result in the disturbance of

LBP. All areas shall be evaluated prior to renovation or remodeling to determine if LBP will be disturbed.


G. Periodic Surveillance - Reinspection

Periodic surveillance is recommended from the date the O&M Program begins. Identified or assumed LBP

should be inspected whenever an apartment is vacated and/or when personnel access an apartment for

maintenance purposes in an area with LBP.

This periodic inspection should be conducted by the O&M Coordinator or by an individual that has the

proper training. The purpose of the periodic surveillance is to ensure that changes in material condition are

documented. If maintenance personnel note a change, the change will be documented. An example format

for this documentation is included in Appendix H. The form includes space to document material location,

visual inspection, condition change, the type of change and recommendations for response actions.

H. Emergency Response Procedures

An emergency response situation is not likely to occur due to the presence of the identified LBP at the

Property. However, lead dust can occur during maintenance or renovation projects (see Section 6.2).

It is recommended that one or more local LBP abatement contractors are identified that are capable of

responding on short notice.

I. Certification

THIS LEAD-BASED PAINT OPERATIONS AND MAINTENANCE PROGRAM WILL BE IMPLEMENTED UPON

EXECUTION BY THE UNDERSIGNED.

Dated this __________ day of ________, 201__

As Certified By:

Entity Name

Address (City, State, Zip)

Signature

Print Name & Title

Appendix A

Lead-Based Paint Guidance for HUD Field Staff

Lead-Based Paint Guidance

for Owners and HUD Field Staff

Table Content

Introduction ………………………………………….……………………………… iii

I Instructions for Owners ...........................................................………. 1 A. Owner Communication with Contractor........................................… 1

1. Scheduling Inspections.......................................................… 1

2. Reporting...........................................................................… 2

3. Appeal Process………………………………………….........… 3 B. Owner Communication with Residents………………………………. 4

1. Pre-Inspection……………………………………………………. 4 2. Post-Inspection…………………………………………………… 4

C. Owner Communication with HUD................................................… 5 1. Pre-Inspection……………………………..................………… 5 2. Post Inspection...................................................................… 5

D. Owner Compliance Responsibilities.........................................…… 5

1. Determining Applicable Compliance....................................… 5

2. Calculating level of Assistance…............................…………. 6

3. Determining Course of Action (Lead Hazard Control Plan).… 6

4. Requesting HUD Assistance in Funding the LHCP….......….. 6

5. Documentation of Compliance............................................…. 7

II Instructions for Project Managers (PM)................................................ 7 A. PM Monitoring/Responsibilities.................................................…..…. 7

1. Monitoring Pre-Inspection Activities…..................................... 7 2. Monitoring Owner’s Actions..................................................... 7 3. Monitoring LBP Inspection Results in REMS......................….. 8

B. PM Analysis........................................................................................ 8

1. Processing Owner’s Request for Funding............................... 8

2. Verifying Owner’s Calculation of Level of Assistance…........... 8

3. Compliance/Clearance Reports............................................... 9

III Special Instructions for Contract Administrators (CA)........................ 9

IV Frequently Asked Questions….............................................................. 10

V Attachments..…………………………………………………………………. 11

Appendix A

Appendix B

Appendix C

Compliance with the Lead Safe Housing Regulation is our objective.

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Lead-Based Paint Compliance Instructions for Owners and HUD Field Staff

Introduction

The Lead Safe Housing Rule contained in 24 CFR 35 became effective September 15, 2000. This document summarizes the rule’s requirements for various multifamily housing programs and properties receiving Section 8 and other rental assistance constructed before 1978. The multifamily programs covered by the new rule are: (1) new applications for mortgage insurance (currently in development); (2) HUD-owned and Mortgagee-In-Possession (MIP) properties; and (3) properties receiving project-based rental assistance. Properties with units receiving no more than $5,000 of project-based rental assistance annually have different requirements than properties with units receiving more than $5,000 annually. To ensure the rule’s effective implementation, HUD has developed a transition plan with a three-part strategy. The goals of the transition plan are to: (1) establish transition periods during which geographic areas lacking capacity to comply with the rule can build that capacity and focus their resources on the housing stock with the greatest need; (2) provide training assistance to jurisdictions that need help building capacity; and (3) supply funding to reduce the costs of complying with the rule. The Office of Healthy Homes and Lead Hazard Control (OHHLHC) is assisting the local municipalities in building capacity to comply with items 1 and 2. In working with the industry, Multifamily Housing is funding a volunteer lead-based paint inspection program to assist Owners in complying with item 3. This program requires the Real Estate Assessment Center (REAC) to contract for the Inspection/Risk Assessment (IRA). Similar to the physical inspection process, REAC will manage the IRA with a contractor selected by the Department. The contractor will conduct the IRA and report the findings to the Hub/PCs, the Owner, the OHHLHC and Headquarters. REAC contacted all Owners with properties receiving Section 8 and other forms of rental assistance provided to the tenants (Loan Management Set-Asides, Section 221(d)(3) with Below Market Interest Rates, and Section 236 with Rent Supplement Assistance) to ascertain whether or not they were interested in participating in the program. HUD provided the listing of Owners who expressed interest in the program to the contractor and the contractor contacted each Owner to schedule the IRA. The IRAs started June 4, 2001, and HUD will submit the first reports to the Owners, Hub/PCs, the OHHLHC and Headquarters during the first week of August of this year. REAC and the OHHLHC developed the IRA as a protocol to comply with the Environmental Protection Agency standards. The Multifamily Housing Project Manager (PM) will perform follow-up and monitoring activities of the Owners participating in the Lead-Based Paint (LBP) inspection program. Each segment of the inspection process will consist of some PM involvement. Item II, page 8 of these instructions provides the procedures for Hub/PC staff monitoring (Project Managers).

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I Instructions for Owners

A. Owner Communication with Contractor

1. Scheduling Inspections Initial Notice: The REAC contractor(s) will contact the owner by telephone to negotiate a date for the LBP inspection and obtain ownership information i.e., on-site property manager, contact person, property address, and ownership entity. The negotiated date must be at least 30 calendar days from the date REAC contacted the owner. The owner is required to provide preliminary notification of the inspection to residents at least 15 days prior to the inspection date. (For further discussion of resident notification instructions see the section on Owner Communication with Residents on page 4). During scheduling of the inspection, the contractor will ascertain if the owner has submitted a Transfer of Physical Assets (TPA) application. If this has occurred, the contractor must determine the status of the application before scheduling the IRA. If HUD approves the TPA before the projected date of the IRA, the contractor must obtain the new Owner’s approval to conduct the IRA. If a TPA approval occurs after the projected date, the contractor may schedule the IRA. If the Owner pays off the loan and/or opts-out of the Section 8 contract and the tenants use Section 8 certificates or vouchers, the contractor will still conduct the IRA.

Second Notice: The REAC contractor is required to send a second notice to the Owner by certified mail 15 calendar days before the scheduled IRA date to confirm the date and any required and/or requested ownership information. The contractor will include in this notice a checklist entitled, “Information for the Residents on Lead-Based Paint Inspection/Risk Assessment” for distribution to each resident at least five days prior to the inspection. (See Appendix A).

Similar to the Physical Inspections conducted by the REAC protocol, the contractor will not inspect all of the units in the project. Based on the construction date of the property, the contractor will inspect a pre-determined number of units. The contractor will provide the number of units to the Owner 15 days prior to the scheduled inspection. Neither the Owner nor the tenants will know which units will be inspected until the date of the IRA.

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2. Reporting After completing the inspections for a property, the contractor will submit the results electronically to REAC within 10 business days. REAC will review the results using a checklist developed in conjunction with the OHHLHC. REAC will review the results to determine if the report is acceptable. After REAC accepts the report, it will mail only the summary report of the results to the Owner and the OHHLHC. The Hub/PC will receive an electronic copy. To receive a copy of the entire report, the Owner must send a written request to: Anthony Carey, Deputy Project Manager ATTENTION: Lead-Based Paint 1280 Maryland Avenue, SW, Suite 800 Washington, DC 20024-2135 The inspection report will identify whether there is NO LEAD PAINT or LEAD PAINT and/or LEAD PAINT HAZARDS on the property. If there is LEAD PAINT, the report will identify the location, level of hazard, and acceptable or optional ways of mitigating the hazards.

(a) Summary Report and Findings: HUD will provide a summary report to

the Owner. (The actual report is over thirty pages and will be available to the Owner upon request). The Hub/PC, and the OHHLHC will receive a copy of the entire report. The entire report will consist of the following elements:

(i) A summary statement that specifies if the property contains lead

hazards with an identification of the particular location. (ii) Property information and description. (iii) A summary of each identified lead hazard and a lead hazard

management category (i.e., high, moderate or low). (iv) A summary statement of the dust sample results averaged by

each component sampled (i.e., floors, windowsills, window troughs), room type, and the average compared to the applicable standard level to determine if the results are project-wide.

(v) A summary statement of the overall condition of each building by address and evaluated samples.

(vi) A summary statement listing the individual tested units and the total number of tested units.

(vii) The total number of separate tests performed for each homogeneous component/substrate pair and the total number of positive or negative lead results.

(viii) The lead classification result, positive or negative for each identified homogeneous component/substrate pair in the inspected property.

(ix) High priority locations that received a detailed examination and environmental sampling during the risk assessment.

(x) A tabular listing of all testing combinations classified as lead-based paint.

(xi) A tabular listing of all lead-based paint hazards. (xii) Actions required of the owner. (xiii) Owner(s) name or representative present during the

inspection/risk assessment.

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(b) Clearance Reports: The Owner of property with identified Lead-Based Paint (LBP) and/or Lead Paint Hazards (LPH) must submit a Lead Hazard Control Plan (LHCP). A clearance technician that has been certified by the unit of local government to review and approve the work will issue a clearance report once the Owner completes reduction activities (See Post-Inspection, page 5). Reduction activities include paint stabilization, maintenance, rehabilitation, interim controls or abatement. A clearance examination will follow these activities. In addition to the requirements described in the rule, individual states and localities may have additional or more stringent requirements.

As with the other notification requirements, the Owner must notify the residents upon clearance report issuance. The Owner must post the clearance report in a visible, accessible site on the property or distribute it to each individual unit. The Owner must provide access to a file of all IRA reports in the project office during normal business hours for at least one year after all related LBP activity is complete for review by the tenants and potential tenants.

3. Appeal Process If the Owner disagrees with the IRA, the Owner may appeal. To appeal, the Owner is required to request a re-evaluation of the IRA review within 15 calendar days of receiving the results. The request must be in writing and forwarded to:

Director, Real Estate Assessment Center

ATTENTION: Lead-Based Paint

1280 Maryland Avenue, SW, Suite 800

Washington, DC 20024-2135

The re-evaluation may include an analysis of the information the inspector collected, a complete re-inspection of a sample of the property, or a laboratory analysis of the paint chip samples. If the paint chips samples are used as part of the re-evaluation, the Owner must repair the damage. If the Owner disagrees with the re-evaluation results, the Owner may contract for another inspection with a contractor at the Owner’s expense. If the Owner contracts for another IRA, the Owner may not charge the costs to the project as an expense. Handbook 4350.1 only permits the use of project funds for testing. The Owner should be advised that the inspection must comply with the

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standards provided in the regulations or the Departments’ protocol. The Owner must submit this inspection to REAC at the above address within 30 business days from the Owner’s notification to REAC to contract for another inspection. The contractor must certify that the inspection meets regulations or the Department’s protocol. If REAC’s review of the Owner’s inspection concludes that the property is not contaminated, HUD may reimburse the Owner the expense of contracting for the inspection.

B. Owner Communication with Residents

Although the Owner may request an appeal of the IRA report, the Owner must post all information regarding the IRA process in a visible, accessible site on the property or distribute it to each individual unit. 1. Pre-Inspection As provided in Item I, Scheduling Inspection, the Owner must notify residents at least 15 days prior to the inspection date. The exact units that the contractor will

inspect are unknown until the day of the inspection. The Owner must notify all residents of the units that the contractor will inspect prior to the start of the IRA. Notices may be posted in each building. They must be accessible, located in three conspicuous places, and may be placed under the door of the units to receive the IRA. 2. Post-Inspection Once the Owner receives the results of the inspection/risk assessment from REAC, the Owner must provide the results to residents within 15 calendar days. The results must be posted in a visible, accessible site on the property or distributed to each individual unit (as described above). If the evaluation report identifies LBP and/or LPH and the Owner does not request an appeal, the Owner must coordinate with the PM to develop a Lead Hazard Control Plan (LHCP). The LHCP takes a strategic approach to addressing the lead hazards in the property and prioritizes the highest risk units, such as those with pregnant women or children under six years of age for lead hazard control work, and presents a plan to address lead hazards in other units and common areas over a period of time. The Owner must notify the residents when he/she will correct the deficiencies and post the inspection results. The Owner must post the LHCP within 30 days of completion. (See Determining Course of Action LHCP on page 6).

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C. Owner Communication with HUD 1. Pre-Inspection Prior to the inspection, the Owner will receive the form HUD-90057 “Certification of Notification to Residents/Tenants.” After the Owner notifies the residents of

the inspection date, the Owner must sign the form and fax to HUD prior to the date of the inspection. (See Appendix B).

2. Post-Inspection

Once the Owner receives the IRA results, the Owner must notify the residents and complete the form HUD-90056 “Notification of Results” (See Appendix C). The Owner must fax this form to HUD within 10 business days of receiving the IRA results. HUD will use this form to confirm Owner compliance with resident notification requirements. If IRA determines that the property has lead, the Owner shall develop a Lead Hazard Control Plan (LHCP) and correct the deficiencies noted in the results. (See Determining Course of Action LHCP on page 6). The Owner must certify to the PM that he/she has corrected the deficiencies. The certification must be on the mortgagor/Owner letterhead and signed by the mortgagor/Owner. The Office of Multifamily Housing will provide a standard Certificate in a separate memorandum.

D. Owner Compliance Responsibilities The Owner must calculate the level of assistance for the project to determine compliance requirements. 1. Determining Applicable Compliance Properties with the following characteristics are applicable for an IRA:

(a) Properties receiving project-based assistance less than or equal to $5,000 annually per unit are covered under 24 CFR Part 35.720. These properties are subject to the regulation effective September 15, 2000. The Owner must perform a visual assessment, perform paint stabilization, and ongoing lead-based paint maintenance is required.

(b) Properties receiving project-based assistance of more than $5,000

annually per unit are covered under 24 CFR Part 35.715. For these properties, the Owner must conduct a risk assessment on or before September 17, 2001, for existing multifamily projects constructed prior to 1960. Properties constructed after 1959 but before 1978 must have risk assessments completed by September 15, 2003.

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(c) All Owners of multifamily properties covered by the new rule, regardless of construction date, must perform interim controls and clearance of any LBP hazards identified in the inspection results.

2. Calculating Level of Assistance All owners are required to determine the applicable compliance using the following calculation:

To calculate the annual per unit assistance: Take the total assistance to the project for one month. Multiply by 12 to get annual assistance. Then divide by the total assisted units. Example: ($102,422 X 12 = $1,229,062 ÷ 248 units = $4,956) Perform this calculation for the same month every year.

3. Determining Course of Action (Lead Hazard Control Plan) If the contractors finds lead hazards on the property and if the Owner does not dispute the results, the Owner must initiate the process of developing a Lead Hazard Control Plan (LHCP). The LHCP should outline how the Owner intends to comply with HUD’s LBP hazard guidelines. An example of a LHCP can be found in appendix 8.2 of the HUD guidelines. Units where children reside under six years of age require treatment within 90 days of the IRA report date. Units without children under six years of age will have 12 months of the IRA report date to comply with the regulation.

The LHCP responds to the inspection results and information the Owner provides by to the risk assessor. A LHCP will consist of the following at a minimum:

• Introduction

• Risk Assessment Results

• Modifications planned for the buildings

• Lead Hazard Control in units with children (under six years of age)

• Lead Hazard Control in units not occupied by children (under six years of age)

• Worker training and protection

• Record keeping

• Funding sources for work not completed by project staff

• Timelines

4. Requesting HUD Assistance in Funding the LHCP

HUD’s funding of the inspection/risk assessment does not cover the completion of the Owner’s LHCP. The Department may at the Owner’s request review the property’s reserve accounts and where appropriate permit the release of excess funds.

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5. Documenting Compliance

The Owner/Agent must be able to provide documentation of compliance with HUD’s requirements including:

(a) Reduction of hazard activity (b) Clearance examination (must be performed by an individual that has

been certified by the local unit of government) to conduct compliance inspections to ensure that the worksite is free of dust-lead hazards, visible dust, debris, and deteriorated paint).

(c) Clearance Report (must be retained for a minimum of 3 years) (d) Certification that the property is free of lead-based paint and/or lead

hazards (must be retained for a minimum of 3 years)

II Instructions for Project Managers (PM)

A. PM Monitoring/Responsibilities

1. Monitoring Pre-Inspection Activities - LBP Scheduler

The PM must monitor properties scheduled for inspection. HUD has created a temporary scheduler for use on the HUD intranet at hudweb1.hud.gov/po/reac/products/prdlead.cfm1. The scheduler will list the property name, scheduled date and time, and the name of the IRA. To activate the web search for properties, type in the Property ID Number, REMS Number, the FHA Number, or the Section 8 Contract ID Number. The system will take only the active contract numbers for the FHA and Contract ID. Please note that the Office of Multifamily Housing is enhancing this process and will integrate the scheduling functionality in to REMS.

If an Owner is involved in a TPA, the PM must record this information into

the Project Action screen of REMS and send an e-mail immediately to

REAC (Eraina McCoy, GTR and [email protected]) and a copy to

Headquarters staff (Diana Reid and Kimberly Sanford). This includes a

Modified TPA.

2. Monitoring Owner’s Actions

The PM must confirm the dates of all resident notifications to assure compliance with HUD’s tenant notification requirements. Once the Owner faxes a signed copy of the form HUD-90057, “Certification of Notification to Residents/Tenants,” to the PM, the PM will document the information in REMS and maintain the hard copy in the Owner’s file. See Appendix B.

1 This website is a temporary system for retrieving information on inspections for LBP. It will have NO input capability.

http://hudweb.hud.gov/po/reac/products/prdlead.cfm

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In addition to the above, the PM must confirm that the Owner/Agent properly provided the form HUD-90056, “Notification of Results to Residents.” (See Appendix C). Once the PM receives and verifies this information, the PM will document the information in REMS and maintain the hard copy in the Owner’s file. Once the PM receives the signed form HUD-90056, “Notification of Results,” he/she will confirm that the Owner properly notified residents and enter the information into REMS. If the Owner disputes the results and requests a risk assessment review, the PM will record status of the appeal process in REMS.

3. Monitoring LBP Inspection Results in REMS Once REAC receives the results, the PM will receive a summary report through REMS. The Office of Multifamily Housing has not yet modified REMS so that the inspection results are viewable. In the interim, PMs can access LBP inspection results at hudweb1.hud.gov/po/reac/products/prdlead.cfm. If an inspector identifies LBP and/or LPH, the Owner must contact the PM to develop a Lead Hazard Control Plan (LHCP) (see page 6) for compliance. Once completed, the Owner must provide certification of remediation to the PM. If the certification is acceptable, the PM will record this into REMS. If the certification is unacceptable, the PM must notify the owner to resolve any remaining deficiencies. If the Owner refuses to comply after this notification, the PM must document the non-compliance in REMS. If the Owner continues to be in noncompliance, the PM must enter a flag into the APPS System (HUD-2530) and notify the local LBP agency. The PM should forward the project to the Departmental Enforcement Center (DEC) for enforcement action as an elective referral.

B. PM Analysis 1. Processing Owner’s Request for Funding Approval

The PM must receive the Owner LHCP (See page 6) including funding sources. Prior to approving the LHCP and funding, the PM will review the PASS and FASS reviews to determine if there are other project issues that should be factored into this decision. If the plan requires tenants to be temporarily relocated, the PM must review the relocation plan and comment where appropriate.

2. Verifying Owner's Calculation of Level of Assistance

The PM must understand the procedure used to calculate the level of assistance. (See Calculating Level of Assistance on page 6). The calculation determines the LBP compliance requirements. Properties with units receiving no more than $5,000 of project-based rental assistance annually have different requirements than properties with units receiving more than $5,000 annually.


9

3. Compliance/Clearance Reports Owners must document clearance of LBP hazards in report format and retain a copy of the report on the property for the tenants and potential tenants to review for at least three years. In addition to project information (i.e., address, specific location, etc.), the report must state the areas covered on the property (i.e., units, common areas, etc.), and must contain two basic parts: (1) information on the clearance examination; and (2) information on the work performed prior to the clearance examination.

III Special Instructions for Performance Based Contract Administrators

(PBCAs)

The Contract Administration Oversight Monitor (CAOM) should closely monitor all inspections on properties monitored by PBCAs. CAOMs can obtain this information from the temporary scheduler until REMS is enhanced. The temporary scheduler can be accessed using the HUD intranet at hudweb1.hud.gov/po/reac/products/prdlead.cfm. The scheduler will list the property name, scheduled date and time, and the name of the inspector/risk assessor. To activate the web search for properties, you must type in the Property ID Number, REMS Number, the FHA Number, or the Section 8 Contract ID Number. The system will take only the active contract numbers for the FHA and Contract ID. The CAOM will receive information from the PM regarding the LBP Hazard clearances. CAOM should inform the PBCAs of the scheduled inspection dates so that CAs can perform their monitoring duties.


10

IV FREQUENTLY ASKED QUESTIONS

Q/A 1. How will the field office be notified of scheduled inspections? A. The schedules and other information will be posted weekly for each Hub and

Program Center on the intranet web site which can be accessed at: hudweb1.hud.gov/po/reac/products/prdlead.cfm

2. If there are questions, comments, or complaints from the PM, how are they

handled? A. Lead-Based Paint questions should be directed to HUD’s Office of Healthy

Homes and Lead Hazard Controls at (202) 755-1785, extension 104. Policy questions should be directed to HUD’s Office of Asset Management to Margaret Keels at (202) 708-3944, extension 2672 or Diana Reid at (202) 708-2654, extension 2199. Lead-Based Paint inspection questions should be directed to the Technical Service Support Center at (877) 406-9220.

2. When an inspection is completed, how will the PM receive the results? A. The results will be in a summary format and will be posted on the interim

website. 4. If there is a need for the contractor to cancel an inspection, how is it

handled? A. If the contractor must cancel an inspection, the contractor must notify the

GTR at REAC and the Owner as soon as possible. 5. How many Owners have responded to this program? A. The initial group of properties (constructed prior to 1960) to be inspected

before September 17, 2001, is approximately 460 properties. The total number of properties over the three-year period is estimated at 3,500.

6. What is the estimated number of properties the contractor is expected to

inspect within a given timeframe? A. It is estimated that the contractor will complete approximately 50 properties

per week, starting in May 2001.

11

Attachments

Appendix A Information for the Residents

Appendix B Certification of Notification to

Residents/Tenants

Appendix C Notice of Results

12

Important Information for All Residents:

Lead-Based Paint Inspection/Risk Assessment

The following information is provided to residents by the Owner of this property. It concerns an inspection that will be conducted to determine whether lead-based paint hazards exist on the property. Please read carefully. NOTIFICATION TO RESIDENTS Fifteen days before the inspection/risk assessment is performed, the Owner must deliver a notice of the inspection to each resident. The notice must include the date(s) inspectors will be on the property. The Owner/Agent must ensure that all dwelling units of the property are available for the inspection/assessment. RESIDENT RESPONSIBILITY Residents are expected to cooperate by allowing the inspector access to the unit to perform the tests necessary to determine whether lead hazards exist. Residents must notify the Owner/Agent of any special circumstances that will delay or prevent the inspector/risk assessor from performing the inspection. OWNER/AGENT REPRESENTATIVE A representative of the Owner/Agent must accompany the contractor during the inspection/risk assessment to ensure that the inspector can access the units. This procedure will also provide the Owner/Agent’s representative with the opportunity to become more familiar with safe work practices concerning lead-based paint. INSPECTION/RISK ASSESSMENT PROCESS When the inspector/risk assessor arrives at the property, he or she will:

1. Meet with the Owner/Agent representative who will accompany him or her during the inspection. 2. Verify the resident notification. 3. Request the list of rental units to identify which units will be sampled. 4. Identify common areas, such as hallways, and develop a plan to sample those common areas. The sampling method for lead inspection is different from the sampling method used by the U.S. Department of Housing and Urban Development (HUD) for physical inspections. Although both methods use random samples, the number of units included in the lead inspection is greater than the number used for HUD physical inspections. The inspection time in a unit for the lead risk assessment is longer and can range from 1 to 3 hours. The inspector/risk assessor will use an x-ray fluorescence (XRF) analyzer to obtain the reading for the level of lead in the paint. On some surfaces where the XRF cannot obtain a conclusive reading (for example, a curved hand railing), the inspector/risk assessor may have to take a paint sample for further analysis. The Owner will be responsible for repair of the surface. REPORT A summary of the inspection/risk assessment results will be reported to the residents of the property. A copy of the full report will be available for review upon request. Appeals of the inspection/risk assessment results, if any, will extend the timeframe for releasing the report to the residents.

Información importante para todos los residentes:

Inspección y evaluación de riesgo de pintura con plomo

La siguiente información es suministrada a los residentes por el dueño de esta propiedad. Se refiere a una inspección que se efectuará para determinar si en la propiedad hay peligros de pintura con plomo. Por favor léala cuidadosamente. NOTIFICACIÓN A LOS RESIDENTES El Dueño/Agente debe notificar a los residentes mediante un aviso colocado en un sitio visible de la propiedad una vez que el dueño haya sido notificado de la fecha de la inspección. Quince días antes de la inspección/evaluación de riesgo el Dueño debe entregar un aviso de la inspección a cada residente. El aviso debe incluir la(s) fecha(s) en que los inspectores visitarán la propiedad. El Dueño/Agente debe asegurar que todas las unidades de vivienda de la propiedad estén disponibles para la inspección/evaluación. RESPONSABILIDAD DE LOS RESIDENTES Se espera que los residente cooperen permitiendo el acceso del inspector a la unidad a fin de realizar las pruebas necesarias para determinar si hay riesgo causado por el plomo. Los residentes deben notificar al Dueño/Agente de cualquier circunstancia especial que pueda demorar o impedir al inspector/evaluador de riesgo efectuar la inspección. REPRESENTANTE DEL DUEÑO/AGENTE Un representante del Dueño/Agente debe acompañar al inspector durante la inspección/evaluación de riesgo para asegurar que tenga acceso a las unidades. Este procedimiento también dará al representante del Dueño/ Agente la oportunidad de familiarizarse más con prácticas de seguridad en el trabajo relacionadas con la pintura con plomo. PROCEDIMIENTO DE INSPECCIÓN/EVALUACIÓN DE RIESGO Cuando el inspector/evaluador de riesgo llegue a la propiedad:

1. Se reunirá con el representante del Dueño/Agente que le acompañará durante la evaluación. 2. Verificará la notificación a los residentes. 3. Solicitará la lista de unidades de alquiler para identificar las unidades que serán inspeccionadas. 4. Identificará áreas comunes como pasillos y desarrollará un plan para tomar muestras de esas áreas. El método de muestreo para inspección de plomo es diferente al utilizado por el Departamento de Vivienda y Desarrollo Urbano (HUD) para las inspecciones físicas. Aunque ambos usan muestras tomadas al azar, la cantidad de unidades incluidas en la inspección de plomo es mayor que el número usado para las inspecciones físicas del HUD. El tiempo de inspección en una unidad para la evaluación de riesgo de plomo es mayor, y puede llevar de 1 a 3 horas. El inspector/evaluador de riesgo utilizará un analizador de fluorescencia de rayos equis (XRF) para obtener la medición del nivel de plomo en la pintura. En algunas superficies donde el XRF no puede obtener una medición precisa (como pasamanos curvos), el inspector/evaluador podría tener que tomar una muestra de la pintura para mayor análisis. El propietario será responsable de la reparación de la superficie. INFORME A los residentes de la propiedad se les proporcionará un resumen de los resultados de la inspección/ evaluación. Una copia del informe completo estará a disposición de quienes soliciten examinarlo. Las apelaciones de los resultados de la evaluación, si las hubiere, extenderán el plazo para dar a conocer el informe a los residentes.

Certification of Notification to Residents/Tenants U.S. Department of Housing and Urban Development OMB Approval No. 2502-XXXX Office of Housing – Federal Housing Commissioner (Exp. 02/29/2004) Public Reporting Burden for this collection is estimated to average 5 minutes per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. This collection is authorized under 24 CFR 35 to insure notification in multifamily housing. This form is completed by the owner of the project to indicated proper advance notice to residents/tenants informing them of the pending inspection for lead-based paint. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Reports Management Officer, U.S. Department of Housing and Urban Development, 451 7th Street SW Washington, DC 20410-3600 and to the Office of Management and Budget, Paperwork Reduction Project (2502-XXXX), Washington, DC 20503. Do not send this completed form to either of the above addresses.

Name of property: _________________________________________________

Project Number: __________________________________________________

Date of Inspection/Risk Assessment: __________________________________

Owner of property: ________________________________________________

As owner/agent of the above property, I certify that the residents/tenants of the above-mentioned property were given preliminary notice of the pending Lead-Based Paint inspection by either posting the notice in three conspicuous places, and/or hand delivered to each resident. I further certify that at least five days prior to the scheduled inspection, each resident will receive a copy of the “Information for the Residents, Lead-Based Paint Inspection/Risk Assessment. This notification conforms with the owner agreement previously signed and referenced in 24 CFR 35. ”

Print Name: ____________________________________________________ (Owner/Agent) Signature:______________________________________________________

(Owner/Agent) Date: ________________ Contact Phone Number: ____________________

This certification of notification must be signed and returned by fax prior to the inspection date to: U.S. Department of Housing and Urban Development

Your local Program Center - Project Manager

Notification of Results U.S. Department of Housing and Urban Development OMB Approval No. 2502-XXXX Office of Housing – Federal Housing Commissioner (Exp. 02/29/2004) Public Reporting Burden for this collection is estimated to average 5 minutes per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. This collection is authorized under 24 CFR 35 to insure notification in multifamily housing. This form is completed by the owner of the project to indicated proper advance notice to residents/tenants informing them of the pending results of the inspection for lead-based paint. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Reports Management Officer, U.S. Department of Housing and Urban Development, 451 7th Street SW Washington, DC 20410-3600 and to the Office of Management and Budget, Paperwork Reduction Project (2502-XXXX), Washington, DC 20503. Do not send this completed form to either of the above addresses.

Name of property: __________________________________________

Project Number: ____________________________________________ Date Results Received: _______________________________________

Pursuant to 24 CFR 35.125, Subparts D, and F through M, occupants of multifamily housing properties covered by the rule must be notified of lead-based paint evaluation results and hazard reduction activities (including clearance examinations). If lead-based paint or lead-based paint hazards are presumed to exist, notification must be made to each occupant on the property.

I/we ______________________________________(owner (s)) certify that the occupants of the above-mentioned property were notified of the lead-based paint inspection results within 15 days of receiving the report. I further certify that the summary of the results was posted in a visible/accessible site for occupants to review.

Signature: ___________________________________________________ (owner) Date: _______________ Contact Phone Number: ____________________

Please fax this certification to HUD within 15 days after posting to: U.S. Department of Housing and Urban Development

Your local Program Center - Project Manager

Appendix B

Lead-Based Paint Summary Table

Lead-Based Paint Summary

Project No.: B1702158.03

Project Name: Former Pioneer Press

Address: 345 Cedar Street

St. Paul, Minnesota

Component Side Substrate Color Condition

MAIN BUILDING BASEMENT BOILER FLOOR A CONCRETE RED POORMAIN BUILDING BASEMENT BOILER VALVE D METAL GREEN INTACTMAIN BUILDING BASEMENT BATH NORTH WALLS A CERAMIC GREEN INTACTMAIN BUILDING BASEMENT WEST ROOM WALL D CONCRETE RED INTACTMAIN BUILDING BASEMENT WEST ROOM FLOOR C CONCRETE RED INTACTMAIN BUILDING BASEMENT MID EAST WALL D CONCRETE ORANGE INTACTMAIN BUILDING BASEMENT STAIR CENTER WALL A PLASTER YELLOW INTACTMAIN BUILDING BASEMENT SOUTH EAST WALL B PLASTER BEIGE POORMAIN BUILDING BASEMENT WELL ROOM PIPE B METAL GREEN POORMAIN BUILDING BASEMENT WELL ROOM RISER B CONCRETE RED POORMAIN BUILDING FIRST North Office Area WALL A PLASTER BEIGE INTACTMAIN BUILDING THIRD BATHROOM WALL A CERAMIC GREEN INTACTMAIN BUILDING SECOND NORTH OFFICES WALL D PLASTER BEIGE INTACTMAIN BUILDING ALL FLOORS NORTH STAIRWELL WALL B PLASTER BEIGE INTACTMAIN BUILDING FOURTH BATH WALL A CERAMIC GREEN INTACTMAIN BUILDING FOURTH SOUTH OFFICES WINDOW CASING A WOOD BROWN INTACTMAIN BUILDING FIFTH NORTH OFFICES WALL D PLASTER BEIGE INTACTMAIN BUILDING FIFTH ELE LOBBY WALL D PLASTER BEIGE INTACTMAIN BUILDING FIFTH BATHROOM WALL ALL CERAMIC GREEN INTACTMAIN BUILDING 6th BATHROOM WALL ALL CERAMIC GREEN INTACTMAIN BUILDING 7th NORTH WALL C PLASTER BEIGE INTACTMAIN BUILDING 7th NORTH WALL B PLASTER BEIGE INTACTMAIN BUILDING 7th NORTH WALL D PLASTER BEIGE INTACTMAIN BUILDING 7th SOUTHEAST WALL A PLASTER BEIGE INTACTMAIN BUILDING 7th SOUTHEAST WALL B PLASTER BEIGE INTACTMAIN BUILDING 7th SOUTHEAST WALL C PLASTER BEIGE INTACTMAIN BUILDING 7th THROUGHOUT COLUMN ALL PLASTER BEIGE INTACTMAIN BUILDING 7th SOUTHWEST WALL B PLASTER BEIGE INTACTMAIN BUILDING 7th SOUTHWEST WALL C PLASTER BEIGE INTACTMAIN BUILDING 7th SOUTH MECH WALL D CONCRETE BLOCK BEIGE INTACTMAIN BUILDING 7th BATHROOM WALL A CERAMIC GREEN INTACT

Location

SF=Square Feet, LF=Linear Feet,Lead Based Paint

1 of 2

Lead-Based Paint Summary

Project No.: B1702158.03

Project Name: Former Pioneer Press

Address: 345 Cedar Street

St. Paul, Minnesota

Component Side Substrate Color ConditionLocation

MAIN BUILDING 8th NORTH WINDOW CASING A WOOD BROWN FAIRMAIN BUILDING 8th NORTH WALL C PLASTER GREEN INTACTMAIN BUILDING 8th NORTH WALL D PLASTER BLUE INTACTMAIN BUILDING 8th NORTH WALL D PLASTER BLUE INTACTMAIN BUILDING 8th SOUTH CEILING A PLASTER BEIGE INTACTMAIN BUILDING 8th SOUTH CEILING A WOOD BEIGE INTACTMAIN BUILDING 8th SOUTH CEILING A WOOD BEIGE INTACTMAIN BUILDING 8th SOUTH WALL B PLASTER BEIGE INTACTMAIN BUILDING 8th SOUTH WALL B PLASTER RED INTACTMAIN BUILDING 8th BATH WALL A CERAMIC GREEN INTACTMAIN BUILDING 8th BATH WALL A CERAMIC GREEN INTACTMAIN BUILDING FIRST EXTERIOR GARAGE LINTEL B METAL BROWN INTACTMAIN BUILDING FIRST EXTERIOR GARAGE JAMB B METAL BROWN POORMAIN BUILDING FIRST EXTERIOR GARAGE GUARD B METAL BROWN POORMAIN BUILDING FIRST EXTERIOR DOOR B METAL BROWN POORMAIN BUILDING FIRST EXTERIOR DOOR LINTEL B METAL BROWN POORMAIN BUILDING FIRST EXTERIOR GATE B METAL BROWN INTACTMAIN BUILDING FIRST EXTERIOR STRIPPING C METAL BROWN POORFLEET BUILDING FIRST UPPER GARAGE RISER B CONCRETE YELLOW INTACTMAIN BUILDING SECOND SOUTH OFFICE WALL B PLASTER BEIGE INTACTMAIN BUILDING SECOND SOUTH OFFICE WALL B PLASTER BEIGE INTACTMAIN BUILDING SECOND BATHROOM SOUTH WALL C CERAMIC GREEN INTACTMAIN BUILDING SECOND SKYWAY WALL A PLASTER GREEN INTACT

SF=Square Feet, LF=Linear Feet,Lead Based Paint

2 of 2

Appendix C

Example Notification Letter and Form

Disclosure of Information on Lead-Based Paint and/or Lead-Based Paint Hazards

Lead Warning StatementHousing built before 1978 may contain lead-based paint. Lead from paint, paint chips, and dust can posehealth hazards if not managed properly. Lead exposure is especially harmful to young children and pregnantwomen. Before renting pre-1978 housing, lessors must disclose the presence of known lead-based paint and/orlead-based paint hazards in the dwelling. Lessees must also receive a federally approved pamphlet on lead poisoning prevention.

Lessor’s Disclosure

(a) Presence of lead-based paint and/or lead-based paint hazards (check (i) or (ii) below):

(i) ______ Known lead-based paint and/or lead-based paint hazards are present in the housing(explain).

_______________________________________________________________________________________

_______________________________________________________________________________________

(ii) _____ Lessor has no knowledge of lead-based paint and/or lead-based paint hazards in thehousing.

(b) Records and reports available to the lessor (check (i) or (ii) below):

(i) ______ Lessor has provided the lessee with all available records and reports pertaining tolead-based paint and/or lead-based paint hazards in the housing (list documentsbelow).

_______________________________________________________________________________________

_______________________________________________________________________________________

(ii) _____ Lessor has no reports or records pertaining to lead-based paint and/or lead-basedpaint hazards in the housing.

Lessee’s Acknowledgment (initial)

(c) ________ Lessee has received copies of all information listed above.

(d) ________ Lessee has received the pamphlet Protect Your Family from Lead in Your Home.

Agent’s Acknowledgment (initial)

(e) ________ Agent has informed the lessor of the lessor’s obligations under 42 U.S.C. 4852(d) andis aware of his/her responsibility to ensure compliance.

Certification of AccuracyThe following parties have reviewed the information above and certify, to the best of their knowledge, thatthe information they have provided is true and accurate.

__________________________________________________ __________________________________________________Lessor Date Lessor Date

__________________________________________________ __________________________________________________Lessee Date Lessee Date

__________________________________________________ __________________________________________________Agent Date Agent Date

EXAMPLE NOTIFICATION

MEMO

To: ____________________________

From: Management

RE: The Presence of Lead-Based Paint

This letter is to inform you of the presence of lead-based paint (LBP) at Former Pioneer Press Building

located at 345 Cedar Street in St. Paul, Minnesota.

To help safe-guard residents against accidental lead dust releases, we are implementing an Operation and

Maintenance Program which will be directed by (Name) the O&M Coordinator. As part of the program, we

will be implementing specific procedures to be followed when working in areas where LBP exist, and will

conduct periodic inspections to monitor the condition of these surfaces.

It is important that all persons take precautions to avoid disturbing the remaining LBP in the facility. Any

materials known or suspected to be LBP should not be cut, abraded, or otherwise damaged. If damage to

LBP occurs, the O&M Coordinator should be notified immediately.

Please review the attached information regarding location, types of LBP, contact (O&M Coordinator) at

(phone number). Thank you for your attention and cooperation in this matter.

Appendix D

Example Worker Acknowledgment Form

EMPLOYEE/SHORT TERM WORKER

NOTIFICATION FORM

BUILDING NAME:

BUILDING ADDRESS:

DATE OF NOTIFICATION:

On the above date, employees/short term workers and or contractors (circle one) were notified of the

following:

Location of Lead-Based Paint (LBP).

Planned LBP abatement activities

Name, address and phone number or ext. of the O & M Coordinator

The notification was made by:

(Type of notification, memo, newsletter, etc.)

_Notification attached

_Submitted to O & M Coordinator, Date:

Signature of person completing form Date

SHORT TERM WORKER ACKNOWLEDGMENT

I have been informed of the location(s) of the lead-based paint (LBP) in this facility and have reviewed

the management plan, including the operations and maintenance plan. I understand that LBP may be

present within existing structures. I further understand that if I find encounter or suspect LBP, I must

cease work and contact the building administration staff. I am knowledgeable of the appropriate

procedures to work around or near LBP.

Name Date

Signature Date

Company Name

Address Phone

City State

O & M Coordinator

Date submitted

Appendix E

Example Documentation of Training Form

DOCUMENTATION OF TRAINING

Date of Training:

Instructor:

Organization:

Topics:

General Overview of Problems and Definitions

Health Effects

Locations of Lead-Based Paint

Recognition of Damage

Use of Work Permit System

Emergency Procedures

Contact Person for Questions

ATTENDEES SIGNATURE

Appendix F

Renovate Right Brochure

1-800-424-LEAD (5323)www.epa.gov/getleadsafe

EPA-740-K-10-001April 2010

Important lead hazard information for families, child care providers and schools.

CERTIFIED FIRM

LEAD-SAFE

The Lead-Safe CerTified Guide To

RenovateRIght

iT’S The Law!Federal law requires contractors that disturb painted surfaces in homes, child care facilities and schools, built before 1978 to be certified and follow specific work practices to prevent lead contamination. Always ask to see your contractor’s certification.

Federal law requires that individuals receive certain information before renovating more than six square feet of painted surfaces in a room for interior projects or more than twenty square feet of painted surfaces for exterior projects or window replacement or demolition in housing, child care facilities and schools built before 1978.

• Homeowners and tenants: renovators must give you this pamphlet before starting work.

• Child care facilities, including preschools and kindergarten classrooms, and the families of children under six years of age that attend those facilities: renovators must provide a copy of this pamphlet to child care facilities and general renovation information to families whose children attend those facilities.

who ShouLd read ThiS PamPhLeT?

This pamphlet is for you if you:

• Reside in a home built before 1978.

• Own or operate a child care facility, including preschools and kindergarten classrooms, built before 1978, or

• Have a child under six years of age who attends a child care facility built before 1978.

You will learn:

• Basic facts about lead and your health.

• How to choose a contractor, if you are a property owner.

• What tenants, and parents/guardians of a child in a child care facility or school should consider.

• How to prepare for the renovation or repair job.

• What to look for during the job and after the job is done.

• Where to get more information about lead.

This pamphlet is not for:

• abatement projects. Abatement is a set of activities aimed specifically at eliminating lead or lead hazards. EPA has regulations for certification and training of abatement professionals. If your goal is to eliminate lead or lead hazards, contact the National Lead Information Center at 1-800-424-LeaD (5323) for more information.

• “Do-it-yourself” projects. If you plan to do renovation work yourself, this document is a good start, but you will need more information to complete the work safely. Call the National Lead Information Center at 1-800-424-LeaD (5323) and ask for more information on how to work safely in a home with lead-based paint.

• Contractor education. Contractors who want information about working safely with lead should contact the National Lead Information Center at 1-800-424-LeaD (5323) for information about courses and resources on lead-safe work practices.

1

renovaTinG, rePairinG, or PainTinG?

• Is your home, your building, or the child care facility or school your children attend being renovated, repaired, or painted?

• Was your home, your building, or the child care facility or school where your children under six years of age attend built before 1978?

If the answer to these questions is YES, there are a few important things you need to know about lead-based paint.

This pamphlet provides basic facts about lead and information about lead safety when work is being done in your home, your building or the child care facility or school your children attend.

The facts about Lead

• Lead can affect children’s brains and developing nervous systems, causing reduced IQ, learning disabilities, and behavioral problems. Lead is also harmful to adults.

• Lead in dust is the most common way people are exposed to lead. People can also get lead in their bodies from lead in soil or paint chips. Lead dust is often invisible.

• Lead-based paint was used in more than 38 million homes until it was banned for residential use in 1978.

• Projects that disturb painted surfaces can create dust and endanger you and your family. Don’t let this happen to you. Follow the practices described in this pamphlet to protect you and your family.

2 3

Lead and Your heaLTh

Lead is especially dangerous to children under six years of age. Lead can affect children’s brains and developing nervous systems, causing:

• Reduced IQ and learning disabilities.

• Behavior problems.

even children who appear healthy can have dangerous levels of lead in their bodies.

Lead is also harmful to adults. In adults, low levels of lead can pose many dangers, including:

• High blood pressure and hypertension.

• Pregnant women exposed to lead can transfer lead to their fetuses. Lead gets into the body when it is swallowed or inhaled.

• People, especially children, can swallow lead dust as they eat, play, and do other normal hand-to-mouth activities.

• People may also breathe in lead dust or fumes if they disturb lead-based paint. People who sand, scrape, burn, brush or blast or otherwise disturb lead-based paint risk unsafe exposure to lead.

what should i do if i am concerned about my family’s exposure to lead?

• Call your local health department for advice on reducing and eliminating exposures to lead inside and outside your home, child care facility or school.

• Always use lead-safe work practices when renovation or repair will disturb painted surfaces.

• A blood test is the only way to find out if you or a family member already has lead poisoning. Call your doctor or local health department to arrange for a blood test.

For more information about the health effects of exposure to lead, visit the EPA lead website at www.epa.gov/lead/pubs/leadinfo.htm or call 1-800-424-LeaD (5323).

There are other things you can do to protect your family every day.• Regularly clean floors, window sills, and other surfaces.

• Wash children’s hands, bottles, pacifiers, and toys often.

• Make sure children eat a healthy, nutritious diet consistent with the USDA's dietary guidelines, that helps protect children from the effects of lead.

• Wipe off shoes before entering house.

4

where doeS The Lead Come from?

dust is the main problem. The most common way to get lead in the body is from dust. Lead dust comes from deteriorating lead-based paint and lead-contaminated soil that gets tracked into your home. This dust may accumulate to unsafe levels. Then, normal hand to-mouth activities, like playing and eating (especially in young children), move that dust from surfaces like floors and window sills into the body.

home renovation creates dust.Common renovation activities like sanding, cutting, and demolition can create hazardous lead dust and chips.

Proper work practices protect you from the dust. The key to protecting yourself and your family during a renovation, repair or painting job is to use lead-safe work practices such as containing dust inside the work area, using dust-minimizing work methods, and conducting a careful cleanup, as described in this pamphlet.

other sources of lead. Remember, lead can also come from outside soil, your water, or household items (such as lead-glazed pottery and lead crystal). Contact the National Lead Information Center at 1-800-424-LeaD (5323) for more information on these sources.

5

10 20 30 40 50 60 70 80 90 100

Between1940 – 1960

Between1960 – 1978

Before 1940

24%

69%

87%

Percentage of Homes Likely to Contain Lead

Ag

e o

f H

om

es

CheCkinG Your home for Lead-BaSed PainT

older homes, child care facilities, and schools are more likely to contain lead-based paint. Homes may be single-family homes or apartments. They may be private, government-assisted, or public housing. Schools are preschools and kindergarten classrooms. They may be urban, suburban, or rural.

You have the following options:You may decide to assume your home, child care facility, or school contains lead. Especially in older homes and buildings, you may simply want to assume lead-based paint is present and follow the lead-safe work practices described in this brochure during the renovation, repair, or painting job.

You can hire a certified professional to check for lead-based paint. These professionals are certified risk assessors or inspectors, and can determine if your home has lead or lead hazards.

• A certified inspector or risk assessor can conduct an inspection telling you whether your home, or a portion of your home, has lead-based paint and where it is located. This will tell you the areas in your home where lead-safe work practices are needed.

• A certified risk assessor can conduct a risk assessment telling you if your home currently has any lead hazards from lead in paint, dust, or soil. The risk assessor can also tell you what actions to take to address any hazards.

• For help finding a certified risk assessor or inspector, call the National Lead Information Center at 1-800-424-LeaD (5323).

You may also have a certified renovator test the surfaces or components being disturbed for lead using a lead test kit. Test kits must be EPA-recognized and are available at hardware stores. They include detailed instructions for their use.

6

for ProPerTY ownerS

You have the ultimate responsibility for the safety of your family, tenants, or children in your care. This means properly preparing for the renovation and keeping persons out of the work area (see p. 8). It also means ensuring the contractor uses lead-safe work practices.

Federal law requires that contractors performing renovation, repair and painting projects that disturb painted surfaces in homes, child care facilities, and schools built before 1978 be certified and follow specific work practices to prevent lead contamination.

Make sure your contractor is certified, and can explain clearly the details of the job and how the contractor will minimize lead hazards during the work.

• You can verify that a contractor is certified by checking EPA’s website at epa.gov/getleadsafe or by calling the National Lead Information Center at 1-800-424-LeaD (5323). You can also ask to see a copy of the contractor’s firm certification.

• Ask if the contractor is trained to perform lead-safe work practices and to see a copy of their training certificate.

• Ask them what lead-safe methods they will use to set up and perform the job in your home, child care facility or school.

• Ask for references from at least three recent jobs involving homes built before 1978, and speak to each personally.

always make sure the contract is clear about how the work will be set up, performed, and cleaned.

• Share the results of any previous lead tests with the contractor.

• You should specify in the contract that they follow the work practices described on pages 9 and 10 of this brochure.

• The contract should specify which parts of your home are part of the work area and specify which lead-safe work practices will be used in those areas. Remember, your contractor should confine dust and debris to the work area and should minimize spreading that dust to other areas of the home.

• The contract should also specify that the contractor will clean the work area, verify that it was cleaned adequately, and re-clean it if necessary.

if you think a worker is not doing what he is supposed to do or is doing something that is unsafe, you should:• Direct the contractor to comply with regulatory and contract requirements.

• Call your local health or building department, or

• Call EPA's hotline 1-800-424-LeaD (5323).

If your property receives housing assistance from HUD (or a state or local agency that uses HUD funds), you must follow the requirements of HUD’s Lead-Safe Housing Rule and the ones described in this pamphlet.

7

for TenanTS and famiLieS of ChiLdren under Six YearS of aGe in ChiLd Care faCiLiTieS and SChooLS

You play an important role ensuring the ultimate safety of your family. This means properly preparing for the renovation and staying out of the work area (see p. 8).

Federal law requires that contractors performing renovation, repair and painting projects that disturb painted surfaces in homes built before 1978 and in child care facilities and schools built before 1978, that a child under six years of age visits regularly, to be certified and follow specific work practices to prevent lead contamination.

The law requires anyone hired to renovate, repair, or do painting preparation work on a property built before 1978 to follow the steps described on pages 9 and 10 unless the area where the work will be done contains no lead-based paint.

if you think a worker is not doing what he is supposed to do or is doing something that is unsafe, you should:• Contact your landlord.

• Call your local health or building department, or

• Call EPA's hotline 1-800-424-LeaD (5323).

If you are concerned about lead hazards left behind after the job is over, you can check the work yourself (see page 10).

8

PreParinG for a renovaTion

The work areas should not be accessible to occupants while the work occurs. The rooms or areas where work is being done may need to be blocked off or sealed with plastic sheeting to contain any dust that is generated. Therefore, the contained area may not be available to you until the work in that room or area is complete, cleaned thoroughly, and the containment has been removed. Because you may not have access to some areas during the renovation, you should plan accordingly.

You may need:• Alternative bedroom, bathroom, and kitchen arrangements if work is occurring in

those areas of your home.

• A safe place for pets because they too can be poisoned by lead and can track lead dust into other areas of the home.

• A separate pathway for the contractor from the work area to the outside in order to bring materials in and out of the home. Ideally, it should not be through the same entrance that your family uses.

• A place to store your furniture. All furniture and belongings may have to be moved from the work area while the work is being done. Items that can’t be moved, such as cabinets, should be wrapped in plastic.

• To turn off forced-air heating and air conditioning systems while the work is being done. This prevents dust from spreading through vents from the work area to the rest of your home. Consider how this may affect your living arrangements.

You may even want to move out of your home temporarily while all or part of the work is being done.

Child care facilities and schools may want to consider alternative accommodations for children and access to necessary facilities.

9

durinG The work

Federal law requires contractors that are hired to perform renovation, repair and painting projects in homes, child care facilities, and schools built before 1978 that disturb painted surfaces to be certified and follow specific work practices to prevent lead contamination.

The work practices the contractor must follow include these three simple procedures, described below:

1. Contain the work area. The area must be contained so that dust and debris do not escape from that area. Warning signs must be put up and plastic or other impermeable material and tape must be used as appropriate to:

• Cover the floors and any furniture that cannot be moved.

• Seal off doors and heating and cooling system vents.

These will help prevent dust or debris from getting outside the work area.

2. avoid renovation methods that generate large amounts of lead-contaminated dust. Some methods generate so much lead-contaminated dust that their use is prohibited. They are:

• Open flame burning or torching.

• Sanding, grinding, planing, needle gunning, or blasting with power tools and equipment not equipped with a shroud and HEPA vacuum attachment.

• Using a heat gun at temperatures greater than 1100°F.

There is no way to eliminate dust, but some renovation methods make less dust than others. Contractors may choose to use various methods to minimize dust generation, including using water to mist areas before sanding or scraping; scoring paint before separating components; and prying and pulling apart components instead of breaking them.

3. Clean up thoroughly. The work area should be cleaned up daily to keep it as clean as possible. When all the work is done, the area must be cleaned up using special cleaning methods before taking down any plastic that isolates the work area from the rest of the home. The special cleaning methods should include:

• Using a HEPA vacuum to clean up dust and debris on all surfaces, followed by

• Wet wiping and wet mopping with plenty of rinse water.

When the final cleaning is done, look around. There should be no dust, paint chips, or debris in the work area. If you see any dust, paint chips, or debris, the area must be re-cleaned.

10

for ProPerTY ownerS: afTer The work iS done

When all the work is finished, you will want to know if your home, child care facility, or school has been cleaned up properly. Here are some ways to check.

Ask about your contractor’s final cleanup check. Remember, lead dust is often invisible to the naked eye. It may still be present even if you cannot see it. The contractor must use disposable cleaning cloths to wipe the floor of the work area and compare them to a cleaning verification card to determine if the work area was adequately cleaned.

To order a cleaning verification card and detailed instructions visit the EPA lead website at www.epa.gov/lead or contact the National Lead Information Center at 1-800-424-LeaD (5323) or visit their website at www.epa.gov/lead/nlic.htm.

You also may choose to have a lead-dust test. Lead-dust tests are wipe samples sent to a laboratory for analysis.

• You should specify in your contract that a lead-dust test will be done. In this case, make it clear who will do the testing.

• Testing should be done by a lead professional.

If you choose to do the testing, some EPA-recognized lead laboratories will send you a kit that allows you to collect samples and send them back to the lab for analysis.

Contact the National Lead Information Center at 1-800-424-LeaD (5323) for lists of qualified professionals and EPA-recognized lead labs.

If your home, child care facility, or school fails the dust test, the area should be re-cleaned and tested again.

Where the project is done by contract, it is a good idea to specify in the contract that the contractor is responsible for re-cleaning if the home, child care facility, or school fails the test.

11

You may need additional information on how to protect yourself and your children while a job is going on in your home, your building, or child care facility.

The National Lead Information Center at 1-800-424-LeaD (5323) or www.epa.gov/lead/nlic.htm can tell you how to contact your state, local, and/or tribal programs or get general information about lead poisoning prevention.

• State and tribal lead poisoning prevention or environmental protection programs can provide information about lead regulations and potential sources of financial aid for reducing lead hazards. If your state or local government has requirements more stringent than those described in this pamphlet, you must follow those requirements.

• Local building code officials can tell you the regulations that apply to the renovation work that you are planning.

• State, county, and local health departments can provide information about local programs, including assistance for lead-poisoned children and advice on ways to get your home checked for lead.

The National Lead Information Center can also provide a variety of resource materials, including the following guides to lead-safe work practices. Many of these materials are also available at www.epa.gov/lead/pubs/brochure.htm.

• Steps to Lead Safe Renovation, Repair and Painting.

• Protect Your Family from Lead in Your Home

• Lead in Your Home: A Parent’s Reference Guide

for addiTionaL informaTion

For the hearing impaired, call the Federal Information Relay Service at 1-800-877-8339 to access any of the phone numbers in this brochure.

1312

ePa regional officesEPA addresses residential lead hazards through several different regulations. EPA requires training and certification for conducting abatement and renovations, education about hazards associated with renovations, disclosure about known lead paint and lead hazards in housing, and sets lead-paint hazard standards.

Your Regional EPA Office can provide further information regarding lead safety and lead protection programs at epa.gov/lead.

Region 1 (Connecticut, Massachusetts, Maine, New Hampshire, Rhode Island, Vermont)Regional Lead ContactU.S. EPA Region 1Suite 1100One Congress StreetBoston, MA 02114-2023(888) 372-7341

Region 2 (New Jersey, New York, Puerto Rico, Virgin Islands)Regional Lead ContactU.S. EPA Region 22890 Woodbridge AvenueBuilding 205, Mail Stop 225Edison, NJ 08837-3679(732) 321-6671

Region 3 (Delaware, Maryland, Pennsylvania, Virginia, Washington, DC, West Virginia)Regional Lead ContactU.S. EPA Region 31650 Arch StreetPhiladelphia, PA 19103-2029(215) 814-5000

Region 4 (Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee)Regional Lead ContactU.S. EPA Region 461 Forsyth Street, SWAtlanta, GA 30303-8960(404) 562-9900

Region 5 (Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin)Regional Lead ContactU.S. EPA Region 577 West Jackson BoulevardChicago, IL 60604-3507(312) 886-6003

Region 6 (Arkansas, Louisiana, New Mexico, Oklahoma, Texas)Regional Lead ContactU.S. EPA Region 61445 Ross Avenue, 12th FloorDallas, TX 75202-2733(214) 665-6444

Region 7 (Iowa, Kansas, Missouri, Nebraska)Regional Lead ContactU.S. EPA Region 7901 N. 5th StreetKansas City, KS 66101(913) 551-7003

Region 8 (Colorado, Montana, North Dakota, South Dakota, Utah, Wyoming)Regional Lead ContactU.S. EPA Region 81595 Wynkoop StreetDenver, CO 80202(303) 312-6312

Region 9 (Arizona, California, Hawaii, Nevada)Regional Lead ContactU.S. Region 975 Hawthorne StreetSan Francisco, CA 94105(415) 947-8021

Region 10 (Alaska, Idaho, Oregon, Washington)Regional Lead ContactU.S. EPA Region 101200 Sixth AvenueSeattle, WA 98101-1128(206) 553-1200

ePa ConTaCTS oTher federaL aGenCieS

CPSC The Consumer Product Safety Commission (CPSC) protects the public from the unreasonable risk of injury or death from 15,000 types of consumer products under the agency’s jurisdiction. CPSC warns the public and private sectors to reduce exposure to lead and increase consumer awareness. Contact CPSC for further information regarding regulations and consumer product safety.

CPSC 4330 East West HighwayBethesda, MD 20814Hotline 1-(800) 638-2772 www.cpsc.gov

CdC Childhood Lead Poisoning Prevention BranchThe Centers for Disease Control and Prevention (CDC) assists state and local childhood lead poisoning prevention programs to provide a scientific basis for policy decisions, and to ensure that health issues are addressed in decisions about housing and the environment. Contact CDC Childhood Lead Poisoning Prevention Program for additional materials and links on the topic of lead.

CDC Childhood Lead Poisoning Prevention Branch4770 Buford Highway, MS F-40Atlanta, GA 30341(770) 488-3300www.cdc.gov/nceh/lead

hud office of healthy homes and Lead hazard ControlThe Department of Housing and Urban Development (HUD) provides funds to state and local governments to develop cost-effective ways to reduce lead-based paint hazards in America’s privately-owned low-income housing. In addition, the office enforces the rule on disclosure of known lead paint and lead hazards in housing, and HUD’s lead safety regulations in HUD-assisted housing, provides public outreach and technical assistance, and conducts technical studies to help protect children and their families from health and safety hazards in the home. Contact the HUD Office of Healthy Homes and Lead Hazard Control for information on lead regulations, outreach efforts, and lead hazard control research and outreach grant programs.

U.S. Department of housing and Urban DevelopmentOffice of Healthy Homes and Lead Hazard Control451 Seventh Street, SW, Room 8236Washington, DC 20410-3000HUD’s Lead Regulations Hotline(202) 402-7698www.hud.gov/offices/lead/

SamPLe Pre-renovaTion formThis sample form may be used by renovation firms to document compliance with the Federal pre-renovation education and renovation, repair, and painting regulations.

occupant ConfirmationPamphlet Receipt q I have received a copy of the lead hazard information pamphlet informing me of the

potential risk of the lead hazard exposure from renovation activity to be performed in my dwelling unit. I received this pamphlet before the work began.

Printed Name of Owner-occupant

Signature of Owner-occupant Signature Date

renovator’s Self Certification option (for tenant-occupied dwellings only)Instructions to Renovator: If the lead hazard information pamphlet was delivered but a tenant signature was not obtainable, you may check the appropriate box below.

q declined – I certify that I have made a good faith effort to deliver the lead hazard information pamphlet to the rental dwelling unit listed below at the date and time indicated and that the occupant declined to sign the confirmation of receipt. I further certify that I have left a copy of the pamphlet at the unit with the occupant.

q unavailable for signature – I certify that I have made a good faith effort to deliver the lead hazard information pamphlet to the rental dwelling unit listed below and that the occupant was unavailable to sign the confirmation of receipt. I further certify that I have left a copy of the pamphlet at the unit by sliding it under the door or by (fill in how pamphlet was left).

Printed Name of Person Certifying Delivery Attempted Delivery Date

Si gnature of Person Certifying Lead Pamphlet Delivery

Unit Address

note regarding mailing option — As an alternative to delivery in person, you may mail the lead hazard information pamphlet to the owner and/or tenant. Pamphlet must be mailed at least seven days before renovation. Mailing must be documented by a certificate of mailing from the post office.

Appendix G

Example Maintenance and Work Permit System Form

APPROVAL FORM FOR MAINTENANCE THAT MAY DISTURB LBP

The O&M Coordinator will evaluate each job request to determine how work should be completed.

AUTHORIZATION

___Granted

___Denied

Authorization is given to __________________________ to proceed with the following work:

WORK PRACTICES

The following work practices will be used to avoid or minimize disturbing LBP:

Authorizing Signature

Date:

Job Request Number:

JOB REQUEST FORM

FOR MAINTENANCE WORK THAT MAY DISTURB LEAD-BASED PAINT

For maintenance work which may directly or indirectly involve disturbing lead-based paint, submit this form

to the O&M Coordinator for approval. Authorization must be received before any work involving lead-based

paint can proceed.

DATE: ____________

BUILDING NAME AND ADDRESS:

Apartment Number(s) and or location description of work area:

Start Date Requested:

Anticipated Completion Date:

Description of Work:

Will lead-based paint be disturbed? __YES __NO. If yes, describe how the material might be affected:

Requester Signature:

Date:

Appendix H

Example Periodic Surveillance Form

PERIODIC SURVEILLANCE FORM

CHANGE IN CONDITION OF LBP

DATE:

TIME:

BUILDING NAME:

NUMBER:

BUILDING ADDRESS:

DESCRIPTION OF AREA:

Apartment Number(s) or Common Area

CONDITION ASSESSMENT:

LBP Type LBP Type

( ) Good ( ) Good

( ) Damaged ( ) Damaged

( ) Damaged Significantly ( ) Damaged Significantly

If damaged, describe nature and extent of problem:

Signed:

Date (Inspectors Name)

RETURN THIS FORM TO ,

O & M COORDINATOR.

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