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Georgia Department of Community Affairs
Housing R R & P Issues
Lead-Based Paint & (Asbestos) Compliance
Georgia Environmental Protection DivisionLead-Based Paint & Asbestos Program
December 3, 2009
September 29, 2009
Brief Overview • Lead & (Asbestos)Compliance– Summary– Applications– Common Situations
• Shared Goals– Adequate Housing– Reasonable Risks– Government Compliance
September 29, 2009
Lead’s Harmful Health Effects
Hearing Damage
Brain Damage – Reduced IQ &
Learning Problems
Speech and Language Problems
Slowed Growth and Poor
Coordination & Motor Skill
Development
Kidney Damage
Hyperactivity and Violent or
Aggressive Behavior
Children Under 6 Years &Pregnant Mothers
September 29, 2009
Lead’s Harmful Health Effects
Adults
HH EE AA LL TT HH EE FF FF EE CC TT SS OO FF LL EE AA DD EE XX PP OO SS UU RR EE II NN AA DD UU LL TT SS
Brain Disorders
Memory Problems
Nerve Problems
High Blood Pressure
Kidney Problems
Digestive Problems
Reproductive Problems
Slower Reflexes
Weakness in Fingers, Wrists and/or Ankles
September 29, 2009
How Widespread is Lead in Housing?
Year House Was Built Percent of Houses with Lead-Based
Paint
Before 1940 87 percent
1940-1959 69 percent
1960-1978 24 percent
September 29, 2009
Sources
September 29, 2009
September 29, 2009
Lead-based paint is a possible hazard if it DISTURBED or….
PEELING
CHIPPING CRACKING
CHALKING
September 29, 2009
Role of Fund Managing Professionals
• Evaluate Properties• Choose Most
Economical & Safe Method to Comply
• Provide Guidance to the Involved Parties
September 29, 2009
Special Lead-Based Paint Regulations for….
ALL Target Housing…
Built Before 1978 .
• Most Private Housing,
• Public Housing, Housing Receiving Federal Assistance, and
• Federally Owned
Housing
Child-Occupied Child-Occupied FacilitiesFacilities……
Built Before 1978 . . .
•Visited by the Same Child Age Visited by the Same Child Age 6 or Under 6 or Under •Visits at Least 2 Different Visits at Least 2 Different Days Days Within the Same Week andWithin the Same Week and•Each Day’s Visit Lasts at Least Each Day’s Visit Lasts at Least 3 Hours and3 Hours and•Combined Weekly Visits Last Combined Weekly Visits Last at Least 6 Hoursat Least 6 Hours
•Includes: Day Cares, Schools, After School Facilities
September 29, 2009
Lead Testing
Certified Lead Inspector– Paint chip sample
Analysis– XRF
Certified Renovator– Lead Check Swab
September 29, 2009
Abatement versus Renovation
Abatement• Hazard Elimination
– A child has an Elevated blood Lead Level– Housing Receiving Federal $$ Above
Trigger Limits
Interim Controls
Renovation, Repair, or Painting
September 29, 2009
Interim Controls
• Keep Paint Intact
• Avoid Dust Generation
• Thoroughly Clean
• Install Barriers to Sources of Lead
September 29, 2009
What to Watch for….Lead Abatement Contractor Qualifications
•Certified Lead Abatement Firm–Ask for Certificate from Georgia EPD–Check Expiration Date
•Certified Individual–Works for Certified Lead Abatement Firm–Ask for Certificate from Georgia EPD–Check date of last training---Lasts for 2 Years–Check photo---May be on certificate
September 29, 2009
Basics of New Lead RRP Rule
Effective April 22, 2010
Applies to pre-1978–Target Housing–Child-Occupied Facilities
Triggers–Compensation–Area of Paint Disturbance
40 CFR 745.80-745.91
April 22, 2008 Federal Register
September 29, 2009
Effective Dates of RuleJune 22, 2008
– Effective date of rule– States and tribes can begin applying for authorization.
April 22, 2009 – Providers of renovator and/or dust sampling technician
training may apply for accreditation.
October 22, 2009– Renovation firms may begin applying for certification.
April 22, 2010– Rule fully implemented. Training providers must be
accredited, renovation firms/renovators/dust sampling technicians must be certified, and work practices must be followed.
September 29, 2009
Scope of RRP Rule
Trigger Quantities
– Equal to or Over 6 square feet interior in any room
– Equal to or Over 20 square feet exterior
– Window removal
– Partial Demolition
September 29, 2009
RRP Rule Renovation means…
• Modification of any existing structure, or portion thereof that results in the disturbance of painted surfaces unless that activity is performed as part of an abatement activity.
September 29, 2009
RRP Rule Renovation includes…• Removal, modification, or repair of painted
surfaces or painted components• Removal of building components• Weatherization projects• Interim controls that disturb painted surfaces• Converting a building or part of a building into
target housing or a child-occupied facility.• Excludes Minor Repair and Maintenance
Activities or tested lead free surfaces
September 29, 2009
What to Watch for….Renovation Contractor Qualifications
•Certified Renovation Firm–Ask for Copy of EPA Certificate –Check Expiration Date—5 Years
•Certified Renovator–Works for Certified Renovation Firm–Ask for Copy of Accredited Training Certificate –Check date of last training---Lasts for 5 Years–Check photo---Must be on certificate
September 29, 2009
What to Watch for….
Pre-Renovation Notification
•Contractor Pre-Renovation Notification Rules –New Renovate Right Pamphlet must be used
–Child-Occupied Facilities must also be notified now
–Signed form for owner and occupant
–Option to post signs in common areas
September 29, 2009
Lead Safe Work PracticesWhat to Watch for….
September 29, 2009
Inadequate Collection / Improper DisposalInadequate Collection / Improper Disposal
What to Watch for….
September 29, 2009
What to Watch for….
Post-Renovation
•No visible dust, debris, or residue in or below the work area
•Ask about Post-Clearance Inspection
September 29, 2009
HUD Title X HUD Title X Disclosure Disclosure RequirementsRequirements
September 29, 2009
Avoiding The Problems
• Determine If LBP Will Be Disturbed
• Decide What Job Will Be Needed
• Use Qualified Persons
• Follow Lead Safe Work Practices
• Collect & Dispose Waste Properly
• Follow The Applicable Rules
Asbestos Containing Materials (ACMs)
ACM Issues Most Common to
D C A Projects• Avoid Asbestos Hazards
• Avoid Project Interference
• Ensure Government Compliance
September 29, 2009
ACM Definitions
> 1% Asbestos Content
Friable Attached
Non-Friable Detached
September 29, 2009
Popcorn Ceilings, Walls, Other
Examples of ACM Materials
September 29, 2009
Floor Tile & Mastic (FTM)Examples of ACM Materials
September 29, 2009
September 29, 2009
What to Watch for…. Asbestos Inspector and Contractor Qualifications• Accredited Asbestos Inspector
– Ask for Training Certificate– Check Training Expiration Date- Needed Every Year
• Asbestos Contractor– Must be Georgia Licensed Contractor– Ask for Training Certificate– Check Expiration Date of Training—Needed Every Year– Check Expiration Date of License-Needed Every Three
Years
September 29, 2009
Thoroughly InspectWhat to Watch for….
September 29, 2009
Properly Collect & Dispose ALL ACM Waste
In a landfill permitted by EPD for acceptance of asbestos containing waste
Listings Available on Georgia EPD Website.
What to Watch for….
September 29, 2009
Bottom Line
• Find It Before Disturbed
• Plan For It Up Front
– Budget– Schedule
• Chose Other Property
September 29, 2009
Georgia Environmental Protection DivisionLead-Based Paint and Asbestos Program4244 International Parkway, Suite 104Atlanta, GA 30354
Phone: 404-363-7026 Fax: 404-362-2563www.gaepd.org/Land
Mindy Crean, Program Manager
Contact Us
