1. Renovators must use lead-safe work practices in work exempt from the RRP

• Disturbs between 2 and 6 ft2 of paint per room, the LSHR’s de minimis threshold and the RRP’s minor repair and maintenance activities threshold, respectively.

Note: Window replacement, window sash replacement, and demolition of

painted surface areas disturb more paint than the LSHR’s de minimis threshold.

• Disturbs more than 10% of a component type with a small surface area (such as window sills, baseboards, and trim).

Note: The square foot and percent thresholds above apply to all work performed

• Is in target housing where the owner-occupant signs a statement under the RRP Rule that lead safe work practices are not required.

Note: HUD does not allow any owner, whether an owner-occupant or landlord, to

2. Not using HUD’s 3 additional prohibited work practices:

• Heat guns that char the paint even if operating at below 1100 degrees F.

• Dry sanding or dry scraping, except dry scraping in conjunction with heat guns or within 1 ft of electrical outlets.

• Paint stripping using a volatile stripper in a poorly ventilated space.

c. Taking additional measures to protect occupants during longer interior hazard reduction activities: Temporarily relocating the occupant before and during longer interior hazard reduction activities to a suitable, decent, safe, and similarly accessible dwelling unit that does not have lead-based paint hazards. Temporary relocation is not required for shorter projects, where:

• The work is contained, completed in one period of 8-daytime hours, and does not create other safety, health or environmental hazards; or

• The work is completed within 5 calendar days, after each work day, the worksite and the area within 10 feet of the containment area are cleaned of visible dust and debris, and occupants have safe access to sleeping areas, and bathroom and kitchen facilities.

On jobs covered by the HUD LSHR, the certified renovation firm and the certified renovator should know other requirements for the designated party that may affect their role on the project.

a. NOTICE OF EVALUATION OR PRESUMPTION: This notice informs the occupants that paint has been evaluated to determine if it is LBP or that paint has been presumed to be LBP. The designated party must notify the occupants within 15 calendar days of receiving the evaluation report or making the presumption. The renovator should ask the client if he/she has made this notice. The owner may provide a copy of this notice to the renovator so the renovator knows where LBP is located.

b. NOTICE OF HAZARD REDUCTION ACTIVITY: This notice describes the hazard reduction work that was completed and gives the contact for occupants to get more information. The designated party must notify the occupants within 15 calendar days of completion the hazard reduction work. The renovator may be given a copy of this notice, or may be asked to prepare or distribute the notice for the owner at part of the renovator’s work for the owner.

generally requires that identified LBP hazards be treated. Treatments may include

LBP hazard abatement, interim controls or ongoing LBP maintenance. Renovators should inquire if their contract with the owner requires them to perform lead hazard treatment tasks listed below. If so, all workers and supervisors must have the proper training and qualifications. Generally, interim controls include the following activities,which are required if the amount of work is above HUD’s de minimis threshold; for work below the de minimis threshold, any deteriorated paint must be repaired, but the work need not be done using lead-safe work practices, although HUD strongly encourages their use:

a. Deteriorated LBP must be stabilized. This means that physical defects in the substrate of a paint surface or component that is causing the deterioration of the surface or component must also be repaired.

b. Friction surfaces that are abraded must be treated if there are lead dust hazards nearby.

c. Friction points must be either eliminated or treated so the LBP is not subject to abrasion.

d. Impact surfaces must be treated if the paint on an impact surface is damaged or otherwise deteriorated and the damage is caused by impact from a related building component (such as a door knob that knocks the wall or a door that rubs against its door frame).

e. LBP must be protected from impact.

f. Chewable LBP surfaces must be made inaccessible for chewing by children of less than six years of age if there is evidence that such a child has chewed on the painted surface.

g. Horizontal surfaces that are rough, pitted, or porous must be covered with a smooth,cleanable covering or coating.

hazards. An environmental intervention blood lead level is a reading in a child under 6

years old of 20 micrograms per deciliter of blood (20 μg/dL), or two readings of 15 to 19 μg/dL at least 3 months apart. For certain types of HUD assistance (tenant-based rental assistance, project-based rental assistance, public housing, and HUD-owned (multifamily housing), the owner or designated party may ask the renovator to perform work in the unit to address specific lead hazards identified by an environmental investigation risk assessment. All persons participating in such work should have appropriate training and qualifications.

(1) A clearance examination includes a visual assessment at the end of the renovation work for deteriorated paint, dust, debris, paint chips or other residue; sampling of dust on interior floors, window sills and window troughs; submitting the dust samples to a laboratory for analysis for lead; interpreting the lab results, and preparing a clearance report. EPA also allows a clearance examination to be used instead of the post-cleaning verification, if the clearance examination is required by federal, state or local regulations or by the contract. The unit – or, where work is contained, just the work area and an area just outside the containment – must pass clearance, and must not have any remaining lead hazards. If clearance fails at either the visual assessment step or the dust testing step, cleaning has to be redone in the failed part of the work area. The failed part of the work area is the specific area that was tested, as well as any areas that were not tested, and any other areas that are being represented by the sampled area. For example:

• Just one bedroom was tested, because it was to represent all bedrooms in the housing unit; it failed. Therefore, all of the bedrooms in the unit have to be recleaned and re-cleared.

• In a large multifamily apartment building, if a percentage of units are tested in accordance with the HUD Guidelines, if any fail, all of the units except those that passed clearance have to be re-cleaned and re-cleared. (If there are patterns of just certain component types failing, just those component types need to be recleaned and re-cleared in the failed and untested units.)

(2) The person conducting the clearance examination must be both:

• A certified lead-based paint inspector, risk assessor, clearance examiner, or dust sampling technician, depending on the type of activity being performed. (Either the State or the EPA certifies this person, depending on whether or not the State the housing is in is authorized by EPA to certify people in the lead discipline.)

• Independent of the organization performing hazard reduction or maintenance activities. There is one exception, which is that designated party may use a qualified in-house employee to conduct clearance even if other in-house employees did the renovation work, but an in-house employee may not do both renovation and clearance.

1. Ask the property owner if the property or the family receives any type of housing

Note: You should be able to explain to the owner that there will be information

2. If you have any questions about the Federal or State lead-based paint

• State Housing Agency

• State Community Development Agency, Corporation or Authority

• State Housing Finance Agency

• City or County Housing Authority

• City or County Community Development Agency

• USDA Service Center - Rural Housing Programs

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