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LEAD-BASED PAINT
EXAMPLES OF HQS INSPECTION REPORTING BY
GASTONIA HOUSING AUTHORITY
AND
COMPLIANCE BY OWNER

Socialserve.com gratefully acknowledges this contribution by the Gastonia Housing Authority
and reminds property providers that other Housing Authorities may have differing rules.

AS ALWAYS, PLEASE CHECK WITH YOUR LOCAL
HOUSING AUTHORITY FOR SPECIFIC COMPLIANCE INFORMATION

GENERAL LEAD-BASED PAINT INSPECTION CRITERIA

The Gastonia Housing Authority will continue to inspect housing units at initial occupancy and reexamination as in the past. The only difference will be in the identification and requirements for lead-based paint hazard reduction, clearance testing and notification that will take effect August 10, 2001.

Three conditions may exist where you must take action:

1. Chipped, peeling or cracked surfaces below 'de minimus' levels

You must stabilize painted surfaces before approval of tenancy (unoccupied) or within 30-days of notification (occupied). Stabilization involves removal of loose paint; repair of substrate; and an application of new coat of paint. Safe work practices are not required. Ongoing maintenance is required. Option - test paint.

2. Chipped, peeling or cracked surfaces above 'de minimus' levels

You must stabilize painted surfaces 1 before approval of tenancy (unoccupied) or within 30-days of notification (occupied). Stabilization, using safe work practices, involves removal of loose paint; repair of substrate; and an application of new coat of paint. Workers who, at a minimum, have OHSA Lead Hazard Communication Training must perform the work. A certified "Lead-Based Paint Abatement Supervisor" must supervise the work. You must perform a clearance test and notify the resident of clearance test results. Ongoing maintenance required. Option - test paint.

3. Child under the age of six with Environmental Intervention Blood Lead Level (EIBLL)

Gastonia Housing Authority must conduct a risk assessment within 15 days of notification and notify you of the results. You must perform paint stabilization 1 (interim controls or abatement) using safe work practices within 30 days of receiving the risk assessment report. This involves removal of loose paint; repair of the substrate; and an application of a new coat of paint. Workers who, at a minimum, have OSHA Lead Hazard Communication Training must perform the work. A certified "Lead-Based Paint Abatement Supervisor" must supervise the work. You must obtain a clearance examination and notify residents of the hazard reduction activities and clearance examination results. You must take the above action even if the child moves from your housing unit. Ongoing maintenance required. Option - test paint.

The following pages provide examples of how lead based paint failed items will be notated on the form HUD-52580, Inspection Checklist, Section 8 Tenant-Based Assistance, Rental Certificate Program, Rental Voucher Program.

EXAMPLE 1 - ITEMS 1 AND 2

Item 1 - Chipped, peeling or cracked surfaces below de minimus levels

On Page 1 of 6, Item No. 1.9, there is a notation for "PNT PEEL - WINDOW SILL (<10%); PNT PEEL-WALLS (< 2 SF)

This means that lead-based paint was found on less than 10% of the living room window sill and less than 2 SF on the walls.

In this case, because both surfaces contain less that the de minimus amount of lead-based paint, you would follow the "CHECKLIST FOR LEAD HAZARD REDUCTION ACTIVITIES CHIPPED, PEELING OR CRACKED SURFACES BELOW DE MINIMUS LEVELS" to ensure compliance with the lead-based paint regulation. (Please note that this is the same procedure that has been used prior to August 10, 2001).

If deteriorated lead-based paint greater than 10% had been found on living room window sill or greater than 2 SF had been found on the interior walls, the "CHECKLIST FOR LEAD HAZARD REDUCTION ACTIVITIES CHIPPED, PEELING OR CRACKED SURFACES ABOVE DE MINIMUS LEVELS" would be used. (Please note that this is a more stringent procedure than in effect prior to August 10, 2001).

Item 2 - Chipped, peeling or cracked surfaces above de minimus levels

On Page 4 of 6, Item No. 6.6, there is a notation for "PNT PEEL - WINDOW TRIM (>10%); PNT PEEL- EXT WALLS (> 20 SF)"

In this case, lead-based paint was found on more than 10% of the exterior window trim and more than 20 SF on the exterior walls.

Either one of these findings would require you to follow the "CHECKLIST FOR LEAD HAZARD REDUCTION ACTIVITIES CHIPPED, PEELING OR CRACKED SURFACES ABOVE DE MINIMUS LEVELS" to ensure compliance with the lead-based paint regulation. (Please note that this is a more stringent procedure than in effect prior to August 10, 2001).

EXAMPLE 2 - CHILD UNDER THE AGE OF 6 WITH ELEVATED INTERVENTION BLOOD LEAD LEVEL AND LEAD-BASED PAINT ABOVE THE DE MINIMUS LEVEL

On Page 4 of 6, Item No. 6.6, there is a notation for "1 CHILD UNDER AGE 6 HAS EIBLL; PNT PEEL - WINDOW TRIM (>10%); PNT PEEL-EXT. SURFC. (>20 SF)

In this case, the Gastonia Housing Authority has been notified by an agency (most likely the Gaston County Health Department that a child has been identified with an Elevated Intervention Blood Lead Level (EIBLL). In response, the Gastonia Housing Authority has conducted an inspection and found lead-based paint on more than 10% of the exterior window trim and more than 20 SF on the exterior walls (above the de minimus level.

When these two conditions are found to exist (child with EIBLL and lead-based paint above the de minimus lever), the Gastonia Housing Authority will cause a formal Risk Assessment to be performed (at our expense) to determine the condition of the lead-based paint and the course of action required by the owner of the property. We must do this within 15 days of being notified that a child with an EIBLL is living in the housing unit.

You, as the owner of the housing unit, must perform the hazard reduction actions outlined in the Risk Assessment with 30 days of receiving the Risk Assessment report.

After receipt of the Risk Assessment, you will follow the "CHECKLIST FOR LEAD HAZARD REDUCTION ACTIVITIES CHIPPED, PEELING OR CRACKED SURFACES ABOVE DE MINIMUS LEVELS" to ensure compliance with the lead-based paint regulation. (Please note that this is a more stringent procedure than in effect prior to August 10, 2001).

This inspection criteria was adopted by the Gastonia Housing Authority, Gastonia, NC directly from Federal law, State statutes and HUD regulations.
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