Owner Update “Question of The Month”

Q. What are the HQS requirements regarding paint?

A: In addition to spring flowers, spring brings building maintenance, including paint repair. TMHA's HQS (Housing Quality Standards) inspector checks interior and exterior painted surfaces for compliance with LBP regulations (24 CFR Part 35).

1. Applicability: unit(s) must comply with the LBP regulation IF both of the following apply:

    the unit was built before 1978,

    AND the tenant family has children under age 6 and/or a pregnant mother.

2. The LBP regulations assume that pre-'78 housing will likely contain LBP on the interior
    and/or exterior where it was commonly used, especially for things like windows and
     trim. The most important concept to remember is:

**intact lead-based paint is not a hazard.**

That means that if the painted surfaces are not chipping, pealing, checkering, chalking, but are sound and intact, they will not be cited by our HQS inspector. Therefore, the best practice in dealing with LBP is good maintenance so that paint will not be cited.

3. If paint IS cited, you the owner will be required to repair the deteriorated surface using "LBP safe work practices."

LBP safe work practices are "beefed up" methods of paint repair designed to protect both the tenant family and the workers. They consist of:

Containing/isolating work areas with 6 mil plastic sheeting on the interior to contain lead dust released by sanding. On exteriors use sheeting at the foundation to collect paint chips so as not to contaminate foundation soil. Workers should use respirators or masks designed for LBP work.

Wet Sanding/Scraping. Work wet to avoid releasing dust into the air by using wet-sanding equipment, wet-dry sand paper, wet sanding sponges

Use safe chemical stripper either on site, or remove doors, etc. and strip off site.

Scrape with an infrared or coil-type heat gun with temps. below 1,100 degrees F.

Vacuum work areas with a HEPA filter-equipped vacuum to safely remove dust and to prep. the area for clearance testing. NOTE - TMHA HAS A HEPA-VAC AVAILABLE WHICH CAN BE BORROWED FREE OF CHARGE.

Complete the job by cleaning area with powered phosphate dishwasher detergent or TSP to remove remaining dust.

4. Unit clearance: after paint has been repaired, the unit must pass a clearance test by a certified LBP inspector. In our area, Farsight Management is generally used. The unit is in HQS non-compliance until it has passed this clearance test.

Clearance test: consists of a visual check to see that the repaired painted surfaces are properly intact, and that no paint chips from scraping are in evidence. For interior clearances, a number of floor, wall, and window trough wipe samples are taken and tested for lead dust.

5. Owner's Certification: owner certifies to TMHA that the paint has been repaired using safe work practices.

6. Training: Cuyahoga Community College offers one-day periodic trainings in Lead-Safe Work Practices for a reasonable fee. TMHA passes on notice of these trainings in this newsletter.

For more information, contact Samantha Kaplan at 216-987-2932 or via e-mail at Samantha.kaplan@tric.edu or at the website www.corporatecollege.com

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