Signature Block Nursing Home Enquiry Made Easy

Signature block nursing home enquiry

great thank you hi everyone my name is clay lloyd i work at hud as a community planning development specialist and i wanted to welcome everyone to the meeting today we're excited to have you uh we're excited to have our grantee participants uh be able to get involved and engage with some hud experts on lead based paint regulations before this meeting this webinar starts i just wanted to mention one item of housekeeping which is an update on our problem-solving clinic the 2020 problem-solving clinic has now been uh officially cancelled and we've set up a 2021 problem-solving clinic uh for march of 2021 in chicago so the update one more time is the 2020 problem solving clinic with abundance of caution uh has now been canceled and we're focusing now on the 2021 problem solving clinic on the same month at the same location and to go along with that uh update we just want to point out that the way that we're hoping to best engage and support you guys is through these webinar series for 2020. so if you haven't already if you found this webinar uh through an email please go to the hud exchange website uh where you can get updates on both the problem solving clinic and future webinar theories that we're going to be posting throughout the year also if you have any other questions regarding the problem solving clinic you can always email hud drsi's email address which is grsi policy unit at hud.gov and with that i'll send it over to chris thanks clay we're glad everybody's here with us today my name is chris richmond i've i work for icf and i have been working in the community development world for over 20 years now and my very first project when i came to icf was helping to implement the lead safe housing role back in 1999 so i'm going to be manning the q a box that's the one that nicole told you about if you have any questions about the content you want to go to that top blue area on your screen and click on that q a and type in your question and we're going to try to answer them today if not somebody i'll get back to you after this session about that today i am joined uh by clay lloyd you just heard clay clay stationed in the washington dc hud office he works in disaster recovery and special issues division and he works in the cg cdbg dr policy for the division and then i'm also joined by karen griego karen works for hud's office of lead safe hazard control and healthy homes as a healthy homes representative so karen has spent over two decades with the department working with housing and health stakeholders to realize the office's mission which is to help all americans but especially children and other vulnerable populations in low-income households reach their full potential by making homes safe and healthy so we're getting a lot of really good information today from both clay and karen just to let everybody know what we're going to be trying to accomplish today we want to make sure the goal one of the goals is that you actually understand the harmful effects of lead to children and adults that you are actually going to be gaining an understanding of the federal lead paint regulations and how they apply to disaster recovery rehab programs we're going to look a little bit at some of the documentation and help you be able to assess the quality of that documentation and lastly we'll identify a couple resources for use and reference and i know clay had mentioned an email address for cdbg dr and that's actually listed on the last slide so if you missed that it is listed on the last slide at the end of this session so with that i'm going to turn it back over to clay clay you want to go over the first couple slides for us great yeah if you could move to the next slide that'd be awesome okay great so uh once again my name is clay lloyd i work at hud i work in the disaster recovery and special issues division on the disaster recovery cdbgdr grants you can go to the next slide here okay here we go i'm sorry i'm having trouble moving to the next slide there we go great so uh the idea behind this webinar series is uh to help our disaster recovery grantees the participants on the line hear a little bit more about lead paint lead paint disclosure and the documentation required for the types of programs you might be setting up and running and we're hoping that this will allow you to increase your understanding of what you need to do your compliance with the requirements documentation they might need in hand the types of programs that we want you to keep in the back of your mind are housing rehabilitation buyouts both the demolition and the relocation side those are all dealing with houses that might have been built prior to 1978 which may contain lead pace paint and therefore would make you uh subject to these uh lead based housing regulations you can go to the next slide great so the other reason why we brought it up is that in some of our conversations with our grantees we found that compliance with the regulations and requirements wasn't complete and so in order to get out of non-compliance we're hoping that we provide you an example of how to go through and make sure that not only that you're doing the proper work but you may already be doing it and you just didn't properly document that you've already done it so we want you to keep those two in the back your mind just to make sure that as you execute these programs properly you also are able to document and tell the story of how you met compliance for lead-based paint regulations the couple of reasons for this and why we're focusing on lead is to uh is for the health of our occupants rehab workers and beneficiaries from the program and we also want to make sure that we're avoiding any legal issues that might come up from not following these regulations and with that i'd love to hand it off to karen uh who is our hud expert on wednesday okay i think i'm good now appreciate that anyhow uh welcome to our webinar and we really do thank you for your time and attention um to this topic today and we realized that it isn't sometimes an easy regulation to get through so i hope to provide you with enough information and resources with which you can move forth and either be thinking about your policies and procedures that you have in place presently or be thinking about ways and how or where you might need to plug some gaps or completely change a particular procedure or what have you so please keep in mind those policies and procedures that you follow during this webinar and our discussion to basically point out or pick out some of the areas within your lead-based paint regulatory requirements in your policies and procedure that may need to be modified or upgraded if you will so let's start off with the signing problem uh most of you are at least cursory aware that lead is a naturally occurring element in the crest of our earth it's fairly ubiquitous within our our urban and in some cases uh rural environments can be found in the air in the soil in water and inside our homes in the past as you know we have used leaded gasoline and it is being manufactured still it can be found in certain industrial facilities in lead mines and the outputs of those activities in our homes we have lead-based paint in some cases in pre-1978 properties can be found in a variety of other products like ceramics the solder in in our plumbing in batteries in our cars in ammunition and even in some cosmetics especially some that are imported from out of the country we are most interested in protecting children and the reason why we're so adamant about protecting children under six is because they have most of the they ingest and inhale lead paint at a greater rate than perhaps most human or adults do although there are health effects on from exposure to lead by adults as well however as i mentioned children under six are population that we are most concerned and interested in protecting as you know children under six spend an awful lot of time crawling around on the floor and putting things in their mouths including their hands and if their hands are playing in contaminated soil or contaminated dust on windowsills and other horizontal surfaces that lead dust in large or small quantities gets directly ingested and into that child's body now several years ago the centers for disease control and prevention changed their what we call trigger level of blood lead level and the cdc now recommends and hud has incorporated that recommendation or trigger level into its lead safe housing rule that children when they have a level level of five micrograms per deciliter or higher that is a trigger for some kind of a action reaction or response so as i mentioned everyone's basically at risk of lead in their environment if it's inhaled or ingested and as i mentioned children under six are the primary target because kids absorb more lead than us adults do and their brains and nervous systems are the most sensitive to the effects it is a neurotoxin lead and it is completely preventable an elevated blood level is some of you may or may not realize that elevated blood level levels in pregnant women can also pass to the baby and that exposure can be detrimental to that developing baby we also concern with workers such as construction workers folks doing rehabilitation in the jobs that we pay for and elsewhere and in certain industrial fields they are and could be exposing their families and young children at home when they do not take certain precautions with changing their clothes or washing up so basically they take home the lead on their clothing and other items and expose their family and children to those dangers okay so the federal lead regulations that we're going to focus on today are huds and epas now you notice some orange arrows on the slides and those arrows represent where hud and epa's regulations kind of intersect for instance the lead disclosure rule hud and epa basically have the same rule and we both enforce that lead disclosure rule jointly now as far as the lead safe housing rule is concerned many subparts of hud's regulations at 24cfr 35 incorporate elements of epa's lead-based pain activities rule and the renovation repair and painting rule you'll notice a little caption at the bottom of this on this slide identifying some recent changes in epa's rule that went into effect in january of this year and i will go over what that change means and how it may impact at least some of your programs presently so again these are the three federal led regulations that we'll be spending our time today discussing first being the lead disclosure rule if you've bought sold or rented a pre-1978 house or apartment built unit since march of 1996 you probably should have or maybe you did hopefully executed a disclosure and that is receipt of inform informational pamphlet as well as acknowledgement of receipt of that pamphlet and any known uh lead-based paint on that particular property so disclosure's been around for a long time similarly the hud led safe housing rule applies also to 19 pre-1978 housing units and that's been around since september of 2000. we did make amendments as i mentioned before to reduce the trigger level of an elevated blood lead level basically from 20 micrograms per deciliter to 5 to match cdc's response level finally we'll be talking about epa's renovation repair and painting rule this rule applies to all pre-1978 residential housing and including child occupied facilities such as schools and day cares regardless of the source of funding basically and this rule became effective in 2010 so again that's this rule has been around for a while as well so i'd like to to think of the lead safe housing rule in a series of steps disclosure rule is set aside and i'll tell you why in just a minute but essentially the steps involved in compliance in the compliance process of the lead safe housing rule involves evaluating lead-based paint on the property either through a visual assessment in some cases a lead-based paint risk assessment and paint testing or a lead-based paint inspection naturally following that evaluation if there is lead-based paint and lead-based paint hazards then we figure out well how are we going to treat those hazards either through some kind of paint stabilization for a small job maybe some temporary means to control those hazards such as interim control methods or in larger jobs we're talking about hazard abatement so basically eliminating all of those hazards on a more permanent basis and in all cases we're requiring a clearance and again we'll go into some more details on each of these steps coming right up and lastly there are a couple of points it within and at the end of all of these steps where there's a notification requirement to the tenants and we'll take a look at what that what that means and how to perform that so let's dive into the lead disclosure rule as i mentioned before this rule applies to almost all pre-1978 housing for sale and for lease or rental um the owner or lessor provides this pamphlet protect your family from lead in your home there's also provision of a warning statement either in the sales contract or the leasing lease agreement or rental agreement the owner lessor well the property owner is required to disclose any and all known information about lead-based pain and one thing i want you to note and keep in mind and you might want to take a take a little pen to paper at this point is that when we get into the paint evaluations and clearance and so forth property owners are going to get copies of notification of the results of paint testing and of clearance and the type of work performed the owner in that in those cases of those pre-1978 properties will be required to disclose that information when or if they decide to sell or lease that property to other people in the future and in all cases disclosure again when property is being sold or rented disclosure must be completed before any contract is signed occasionally when epa and hud folks in my division go out and perform enforcement or audit work or monitoring we see lots of times old outdated obsolete notifications such as this and similar kinds of material in the in project files or in the sales contract files leasing contract files if you have these if you are using these please discard them they are obsolete now this is a basic albeit small and difficult to read i just want you to know that there are two different kinds of disclosure forms one is for leasing and one is for sale and the reason for the difference is for a property that is for sale the buyer is afforded an option to get that unit or home tested and we'll talk a little bit more about that as we move forward however if again if the property is being assisted with disaster recovery funds for rehabilitation in the future that property owner sells that property or leases that property out they are on the hook for providing known information about lead-based paint to those prospective buyers and lessers lessees pardon me okay so let's go ahead and dive on into the led safe housing rule so you notice that disclosure of known lead-based paint that we talked about previously said nothing about the requirement to test or abate or treat right it's basically a requirement that pre-19 property owners of pre-1978 housing disclose what they know about lead-based paint to the prospective buyer or lessee now the let's say housing rule on the other hand provides for a much stronger or more protective approach to primary prevention and that is protecting children in assisted target housing from number one either obtaining or somehow being exposed to lead and lead-based paint hazards such as dust and soil and paint chips and performing work on those units in a lead-safe fashion by credentialed and trained professionals okay now as as much as it is important to understand the steps to complying with the lead safe housing role it's also very valuable to thoroughly understand the exemptions or when do you not have to comply with the lead safe housing rule again every decision you make every every step you take in the lead safe housing rule requires some form of documentation right so for instance if and when hud monitors your grant program and particularly rehab files files or properties that you have used disaster recovery funds to rehabilitate we're going to be looking for some kind of documentation in your files that demonstrate that you have made a conscious decision and taken means and measures to decide whether or not the lead safe housing rule applies so let's go over what those exemptions are if the property is constructed after january 1 1978 well that safe housing rule does not apply very simple most zero bedroom units or what we call sros and they could be dormitory rooms and the like unless there is a child under six living in that zero bedroom unit it is exempt from the lead safe housing rule housing exclusively designated for the elderly or persons with disabilities are exempt now put a note here by exclusively designated for these populations we are talking about um properties where there is some kind of legal uh requirement that only seniors may live there or folks with disabilities are allowed to reside in a particular property it isn't it does not apply this exemption does not apply to a single-family owner-occupied home that happens to be owned and occupied by an elderly person or a person with disabilities so please understand that distinction also exempt our properties found to be led free now in order to be be considered lead free thus exempt from the lead safe housing rule you must have had or the property owner must have a thorough lead-based paint inspection where all lead-based paint has been identified and either removed or it doesn't exist and if it was found initially and removed and the clearance of that rehabilitated property says no lead-based pain exists on that property then for future reference that property is thus lead-based paint free and not an elective housing rule does not apply and oh by the way lead-free properties are also exempt from the lead disclosure rule next an unoccupied residential pre-1978 property that is slated for demolition provided that it remains unoccupied until demolition occurs rehabilitation jobs that do not disturb any painted surfaces on that property are exempt how would we how would we know that if i were looking at a project file i would be looking at the specs i would be looking at pictures before and after probably if you take them my recommendation is you do so there it should be some uh record of decision and some records of the specifications for the rehabilitation work and thus we can actually tell from the rehab specifications whether or not paint would be disturbed potentially now last here on this list is the emergency actions and emergency actions that are necessary to protect life health and safety or protect from further damage to the structure are exempt as well now this exemption does not apply to rehabilitation or restoration of such damaged property okay so a couple of other exemptions to consider rehabilitation that doesn't disturb a painted surface and also lastly safe work practices are not required when maintenance for instance or hazard reduction activities don't disturb painted surfaces that total more than de minimis levels and i'm sure you're aware of when you're thinking in your mind how much is two square feet per interior space isn't very much okay and by the way these are small jobs less than five thousand dollars and we're going to talk about why that investment threshold makes a difference in how you address lead-based paint in a property so i mentioned uh at the beginning of the exemption uh discussion that we would like to see that you have actually deliberately decided whether or not the let's say housing rule applies to a particular project and the way you do that is by utilizing the resources that hud has available to you now you don't have to use this this form as it is but something like it might be helpful to to you to your project managers your rehab specialists etc and towards the end where we show you where all of the resources can be found it's very easily downloadable and can be made part of your policies and procedures karen i just wanted to give you a time check to let you know we have about 30 minutes left thank you sure so the lead safe housing rule is the one rule within the lead regulations federal led regulations that requires a lot of documentation as you might have guessed so we're talking about credentials certifications trainings of those folks that are performing abatement or interim controls testing those properties for hazards abatement reports clearance reports and the like and u.s program administrators are required to keep all of these documents and documentation available for at least three years we like to say that actual record keeping should be for the life of the building particularly for owners they should be told and educated on record keeping right for purposes of disclosure for purposes of future work that might be done on that at home if for instance all of the lead-based paint hasn't been removed as a as a result of your rehab project it's important that they understand and know where the lid based paint exists and be able to articulate it to the next buyers or renters okay this is a really quick snapshot of how the lead safe housing rule is sort of distributed if you will or codified and it basically follows certain kinds of activities right so whereas the general requirements and definitions as you might guess applies to all federally assisted activities there are other subparts within the regulation that only apply to certain kinds of activities and we are going to talk about subpart j that is our main focus of this discussion today is subpart j now as you can see there are other subparts that may apply to other types of programs or projects that you all are funding and ministering with your dr awards today we are going to stick to talking about subpart j it's possible that if we have enough interest and time in the future we can cover some of the other applicable subparts in future webinars okay i kind of led you to to believe that there are levels of protection within subpart j the lead safe housing role and that goes by the amount of assistance that is provided to a particular project essentially what we're talking about is three different levels of protection so as you might imagine the greater the investment the greater the standard of care and as you can see from this reader's digest if you will summary if it's a very small job for instance less than or equal to five thousand dollars the type of lead evaluation that is required is basically paint testing the surfaces that you're going to disturb as a result of that rehab job now looking further if the hard costs of rehabilitation exceed 5 000 up to an over 25 i'm sorry up to 25 000 the requirement for evaluating lead hazards is basically paint testing so testing the surfaces to be disturbed and a lead-based paint risk assessment and i do have a slide that talks about the difference between a risk assessment and an inspection as we move forward so i just wanted to to give you this sort of uh very high level summary of number one the steps right so this is a sequential kind of of graph or chart as well as the requirement for hazard reduction options that might apply evaluation of lead hazards etc now a moment you've been waiting for i'm aware of the dr funds being used to reimburse property owners for work that they performed on their property's pre-application so they are actually asking for reimbursement of those costs and i also have to say that this is a tricky scenario here and this cpd notice 15-07 goes into quite a bit more detail than i have here but nonetheless that lead screening worksheet would probably come in pretty darn handy assessing whether or not the property itself is exempt or the activities that the owner might wish to have reimbursed may it just may be exempt from the lead safe housing rule and you would have to document that in other in other cases the property owner would need to provide you with the evaluation of lead-based paint um the kind of work that was done to remove the hazards and the lead-based paint and a clearance report i don't know about you but i haven't seen very many folks in the private world going that length unless their state or local governments require it so here's an example from the texas general land office their policy and procedure basically says that if a property owner is unable to provide evidence of abatement and third-party clearance they just simply do not reimburse now that is for the reimbursement portion now the prospective requirement is basically following the lead safe housing rule in other words the property owner is now coming to you as a dr administrator requesting or applying for funds to rehabilitate or restore the property the let's say housing rule obviously kicks in if it's a pre-1978 house and none of the other exemptions that we talked about previously apply okay so this is a busy slide what i do want you to remember and understand out of this is the difference between a lead-based paint inspection a risk assessment and a visual assessment now in our situation where paint testing or a risk assessment and paint testing is required of a pre-1978 proposed rehab project that risk assessment has to be performed by a certified and accredited lead-based paint risk assessor in some cases the risk assessor may also be credentialed in a lead-based paint inspection so what you need to know and take a note is when you're procuring qualified contractors or vendors to perform this evaluation be clear and be deliberate in how you write that request for proposal or request for assistance right there the vendor the vendors that you have available to you need to know what your expectation is with relation to a lead safe housing rule so a risk assessor a risk assessment identifies lead-based paint and lead-based paint hazards through sampling paint sampling is not paint chips paint sampling is the risk assessor uses his or her xrf that is a very specialized expensive machine to essentially test the surface all the way through to the substrate to identify whether or not there's lead-based paint in any of those layers of paint on that sample area the risk assessor also takes dust samples of floors windowsills the risk assessor also takes samples of bare soil on the property particularly around the drip line of the house if there's bare soil there and play areas now the report that is written and provided to the property owner and you as the dr administrator will identify lots of different things right so a chain of custody of all of the samples of dust and soil um a full list of areas and xrf samples and the results and also a summary that is your number one go-to area of the report is the summary the summary will tell you or should tell you where all the lead-based paint hazards exist on that property as well as various options to control or eliminate those hazards so that is the beauty of a risk assessment a lead-based paint inspection on the other hand is essentially a surface by surface test with the xrf on all painted surfaces inside and outside and other impertinences on the property like play equipment garages outbuildings and so forth they don't usually include sampling of dust or soil or water or anything else unless you specifically ask for it but as you remember recall from one of the prior sharks most of the time paint testing of surfaces to be disturbed by the rehab job as well as the normal risk assessment procedure that should be covered in uh in a report and that is the type of activity that you would be identifying when you go out for your request for proposal or press for bids for that vendor okay now one of the prior slides i mentioned that there are some new epa amendments to their lead regulations and that has to do with risk assessments and the level of lead in floors and sills and bare soil that exceed a certain threshold now what i want to say is that these epa dust hazard standards became effective on january 6 2020 for states that epa runs their programs there are other states like texas like california washington oregon and a variety host of other states where the epa has basically accepted regulations from those states to run their own accreditation and certification program and so the states in those cases basically do epa's job for them and uh provide for accreditation training and licensing of abatement super lead-based pain abatement supervisors workers risk assessors inspectors now for those states this best hazard standard does not become effective for two years or earlier when those states amend their state-led laws to incorporate these new standards so obviously it's important to know if you're in a conducting disaster recovery rehab jobs in an epa state or not these are the old epa dust standards that are at least for now still applies in those state-run lead programs and until and unless these the state-led laws uh amen are amended and adopt the new epa standard um that the old standards automatically expire january 6 of 22. so again know whether or not your state is an epa authorized state or a state-run program all right this is just a quick picture of one kind of xrf device and a lot of pictorial explanations on how the xrf works and things that i frankly i am not an expert on myself but basically know the the gist of how an xrf works so if you're interested in seeing how it works in in real life and or how it works um there are resources for you to fig to find that information now you might be asking yourselves well okay that's fine how do i locate a certified lead-based paint inspector or risk assessor and fortunately epa does have a way in means of identifying and finding risk assessor abatement contractors and those kinds of firms and this is the website that you can plug in and find who is who out there is certified and accredited to perform this type of work now it's in some cases it isn't an exhaustive list of folks that are certified and in some cases there's a lot more that are certified and either not on the list or not working and on the list so i just kind of put that notation out there for your information word of mouth is always good if if you live in a state where the state runs its own accreditation and training and accreditation program for abatement and risk assessor inspectors you would be able to to probably call the state health department to locate that list so i'm not going to read this regulation or the citation in the regulation but just understand and know that the hud led safe housing rule incorporates those portions of the epa regulations that we've been kind of discussing in this case the inspections and paid testing requirements all right now once evaluation has been performed on your rehab job and you have the results of that risk assessment you have the report in hand the requirement is to provide a notice to occupants now a notice to occupants assumes that the risk assessment itself wasn't provided now if it's an owner occupied property in most cases the risk assessor inspector will automatically give a copy or give the original report to the property owner in any case if it's an owner-occupied property owner must get that report for disclosure purposes in the future if it's a tenant occupied property in in other words the property is leased then this kind of notice evaluation notice is pertinent to that occupant again owner gets a copy of the full risk assessment report karen just want to give you a three minute warning i'm just gonna let you know we got about 10 minutes left thanks okay so just like there's a an opportunity to find through the epa's website who is eligible or who is qualified to provide those risk assessment activities for you there's also a way to look up um who is certified to provide renovation work right so it's good to know number one who in your community has a risk assessment qualification an abatement worker or supervisor qualification and now also a certified renovator we talked a little bit about renovation repair and painting rule applies to projects that are going to involve interim controls and this would be where you would look now again the three levels of protection for a small job less than or equal to five grand again we talked about pain testing of the surfaces to be disturbed and a renovator to perform paint stabilization basically they're using safe work practices to perform that work some containment there's paperwork administrative paperwork that that renovator should know about and be performing on their own again epa is the or the state if they're running the renovation repair and painting program would have to have those available in cases where they were audited now for an interim control job now those are hard hard costs of rehab above 5000 and up to including 25 grand we're talking about a little bit higher level of protection and work standards these are measures that are designed to reduce on a temporary basis exposure or likely exposure to lead-based paint hazards these could mean any kinds of repair jobs a repainting job it involves some temporary containment and specialized cleaning in order to pass clearance on the other hand if the hard costs of rehabilitation exceed 25 000 hazard abatement hazard abatement not entire abatement but hazard abatement so your risk assessment and pain testing will tell you where all those hazards are you hire an abatement contractor and abatement workers to perform that hazard abatement work now take a note on this particular format uh this is not a required format for any purposes other than your own record keeping and makes it easier for us monitors to go in and check to make sure that the contractor did their job by protecting the occupants belongings and they prepared the work site properly with containment for that particular job now the last step or one of the last steps in the process is clearance and this is third-party clearance typically it's going to be either the same person or same company that performed the risk assessment and pain testing at the beginning of the job they come back and perform a clearance and the clearance is going to include a visual assessment of where the work was done and how that contractor left the property hopefully clean so the visual assessment is accompanied by dust sampling and there are usually quite a few of those dust samples that are taken sent to the lab and hopefully a more or less 24 hour turnaround from the accredited lab and that risk assessor will generally either call the contractor or you the the property or the administrator of the program to let you know that the unit passed clearance or didn't so the lead-based paint hazard reduction portion of that rehab job isn't complete until that clearance is passed so those dust stack those dust levels um have to be below the thresholds that we kind of talked about previously however the epa those new dust samples are apply at this moment to risk assessment but aren't don't necessarily are not necessarily those for clearance at this point that is going to change pretty soon so although those new dust standards again apply to risk assessments the old death standards apply to clearance at this moment all right and at the end of that job the notification that is required to the occupants is something like this basically outlines and provides some summary information to the occupants about the lead hazard reduction activity that took place and that clearance was achieved and this format is available on the lateral compliance advisor that is a resource that i have a slide on in a minute so just to reiterate notification of residents is required following paint testing and the risk assessment within 15 days of receipt of that report and 15 days following the clearance again the owner of the property always gets the full lead-based paint testing and risk assessment report as well as the clearance report for disclosure purposes later on really quickly there are a couple of considerations um that are afforded to you in relation to historic preservation and fair housing so if the home that you are working on is eligible or put or on the national register of historic places you know that the state historic preservation offices don't really like you to change windows and doors and exterior components that may affect the historic significance of that home or property so in this case you're allowed to under the lead safe housing rules to conduct interim controls on the exterior instead of hazard abatement so if it makes sense repairing and eliminating the lead-based paint from existing windows is preferable to the shippo than replacement but if you do do replacement make sure your consultation is clear and they give and the shippo gives you no adverse effect if you're going to replace in kind so there's additional information on historic preservation in this brief 37 from the advisory council on historic preservation and also in the hud guidelines and by the way hud writes the operating standards and the how-to for purposes of risk assessment inspection abatement interim controls clarions etc for the industry this is what is taught in the classes in order for folks to get their certifications to do that kind of work um and hud writes those guidelines if i have a slide in here now as far as for housing what the fair housing rule is is that it's unlawful to discriminate in the terms conditions or privileges of sale or rental of a property based on all kinds of things including familial status so what we're talking about here is pr 378 property that a landlord won't rent to a family with children under six because of the age we do get that condition occurring quite frequently so that is an illegal action on the part of the owner or landlord okay quickly on the renovation repair and painting rule again this applies regardless of whether it's a federally assisted property or not this became effective in 2010 it applies to like i said pre-1978 residential properties as well as child care facilities and other child occupied facilities firms need to be certified by the epa or the state if they are running the rrp program they use you must use certified renovators that are trained and approved by approved training providers so there's a whole host of accredited training providers for the rrp class it's a one-day class and there's a hands-on component to it as well and i do believe a lot of states provide our training providers provide that training in spanish which is very helpful they are required also to provide this renovate right pamphlet to the occupants before the job starts if they're found in violation by epa or the authorized state high civil monetary penalties could be imposed all right so documentation requirements at a glance so evaluation our first step copy of the paint testing and risk assessment report that is the piece of documentation that supports and provides evidence that either there's lead-based paint hazards or there are not now as far as the next step treatment we're going to be looking at the bid specifications your rfps your rfqs to ensure that you are offering these jobs to qualified either renovators in the case of an interim controlled job that is over well small jobs five thousand dollars up to twenty five thousand dollars or if it's a large job that the hazard abatement work was performed by an abatement contractor and and abatement workers your bid documents should also contain information as far as compliance with for abatement and or interim controls depending on the job if you do not specify your expectations as far as credentials and certifications often we find the responses to those bids exclude the requirement we're also going to be looking at occupant protection and work site preparation and that would be evidence usually in the bid docs there could be pictures as well and to demonstrate clearance obviously we have a clearance report for hopefully not but a re-clearance identifying that all of the the lead dust was removed and don't exceed the thresholds set by epa and we see the results of those best samplings in those clearance reports and then naturally we have to look for evidence of did you notify the occupants of the risk assessment results and also of the work itself and when clearance was achieved so really quickly i referred to a little bit ago a reference to the liberal compliance advisor and this is it you'll notice that the there is a resources tab on here and when you click on the resources tab you'll see all kinds of stuff including the notification forms worksheets that i uh had examples of earlier as well as sample bid bid specs um the what else well you go in there and you'll you'll see there's a plethora of information and this is a link to the hud guidelines that i talked about a little bit earlier and if you're interested in taking a look at the complexities and what your lead and construction folks are learning and knowing and hopefully performing you can reference these hud guidelines and a few other links to resources that you will most likely be able to get more information samples examples and information on let's say housing room led disclosure rule etc okay i think we can if we do have time to take some questions sure karen that was a great job thank you um we do have time to just do a couple questions and the question that always comes in was about level of assistance and they wanted to explain um what was that level of assistance and was it just the project cost and what's they weren't quite sure when you showed that chart they had 000 5 to 25 over 25 like where did those numbers come from what does that actually mean gotcha so the hard costs of rehabilitation that i referenced include construction permits associated fees and other project costs regardless of source now on the other hand costs of site preparation occupant protection relocation interim controls abatement clearance waste handling all to be done in compliance with the lead safe housing rule those costs are not to be included in the hard costs of rehabilitation calculation there are examples of how to calculate hard cost of rehab in the regulation section 35.915 c is in cat now the lead row compliance advisor also has examples on calculating hard costs of rehabilitation when you follow the prompts on the rural compliance advisor you'll see you'll get to a point where there are some examples of calculating our cost of rehab great thank you we also got a question in about what if the project fails clearance do you they have to do more work if that happens perhaps so the clearance report will identify where and how clearance failed typically a unit fails clearance due to an inadequate containment of their work site or their work area and their cleaning techniques are below standard right so in other words they didn't clean well enough and the dust levels exceed clearance levels so the renovator or abatement contractor is then responsible to go back in and address all of those points of failed clearance and again the lead hazard control work is complete when that dwelling passes clearance and is safe to reoccupy great we we also got another question because they sometimes use cdbg for infrastructure and so they were asking do we only need to follow this rule for housing or is infrastructure or any other facilities covered under this rule are you able to talk about that that might be the last question we have for today yes ma'am good question so the lead safe housing rule applies to pre-1978 housing that you're assisting not facilities or infrastructure improvement or commercial buildings or other public facilities it's strictly limited to housing great thank you so we do recognize there were a ton of questions that came in and we were not able to get answers out to all of those so staff will be reviewing those and and we have your names we'll be getting back to you with answers about that and we will also be posting this webinar along with the transcript shortly so i want to thank everybody for joining us today sorry it ran over a little late but very helpful information thank you to clay and karen uh for your time and presenting this really important information to grantees today for us so thanks everybody and hopefully you can join