Lead Paint Assessment and Survey

Lead Paint is a significant environmental issues facing urban and suburban property owners. If a property or structure has been exposed to lead paint, Lead Assessment of the site will determine whether lead paint abatement is necessary.

Lead Assessment and Federal Regulation

The federal government defines “lead-based paint”, or lead paint, as any “paint, surface coating that contains lead equal to or exceeding one milligram per square centimeter (1.0 mg/cm2) or 0.5% by weight. Most (if not all) states have adopted this definition of “lead-based paint, and enforce regulations associated with defined activities conducted in housing constructed prior to 1978, such as the permanent removal (abatement) of an identified lead-based paint hazard.

Two basic testing procedures exist for lead-based that although similar provide different information. Lead-based paint inspections survey the range of painted surfaces in a complex to determine where lead-based paint may be present. The second testing procedure is a lead-based paint hazard or risk assessment. In this procedure, only deteriorated and damaged painted surfaces are tested and dust wipe samples are collected. This information assists the risk assessor determine if there are any lead hazards. Many property owners decided to get a combination of both tests to develop a response action and reduce possible exposure hazards.

Pre-school classroom. Brooklyn, N.Y.

Lead-based paint and related lead hazards are among the top ten environmental contaminant concerns for children. Specific testing and abatement can greatly reduce or eliminate the potential exposure risks. In many cases, it’s also required by law.

Lead Assessment and Lead Paint Surveys

Lead is a highly toxic metal that has been used in a wide variety of applications. When incidentally consumed through inhalation or ingestion, lead is stored in human blood, tissues, and the bone marrow. Lead has been shown to be associated with organ damage, nerve damage, and other health risks. In children lead has been shown to retard intellectual development and cause behavioral disorders. In addition, pregnant women and their unborn children are particularly susceptible to lead poisoning.

Lead paint is by far the largest source of lead exposure. Although the production of lead paint was banned in 1978, many structures built prior to 1978 still contain vast quantities of lead paint. Typically, the highest concentration of lead in paint are found in the older, heavier, oil-based paints found on window sill, panes, and jambs, radiators, and wooden trim. In addition, lead paint was extensively used on exterior wood trim and doors. Lead paint that is peeling, chipping, flaking, chalking, or otherwise damaged is readily accessible to children for consumption. These conditions represent a significant health hazard.

During the last decade, many federal and state regulations have been enacted that require specific inspection, risk assessment, monitoring, and abatement protocols. Federated Environmental closely follows the lead paint regulations to ensure that each of its clients are in compliance with federal, state, and local regulations and the risks have been responsibly managed. For example, in order for borrowers to qualify for HUD insurance for loans related to multifamily complexes, a professional lead paint assessment of the property must be performed. After the lead paint assessment has been completed, the “high risk” surfaces (chewable, accessible, and in poor condition) must be abated or managed in accordance with HUD guidelines. Multifamily complexes constructed prior to 1978 are required to have a lead-based paint survey completed in accordance with the US Code of Federal Regulations, Title 24 (Housing and Urban Development); Part 200 (Introduction); Subpart O (Lead-Containing Paint Poisoning Prevention); Section .820 (Multifamily Insurance and Coinsurance).

The specific inspection protocols requires inspection of ten (10) units for projects with twenty (20) or more units, and six (6) units for projects with fewer than (20) units. In addition, representative sampling of common areas include non-dwelling facilities commonly used by children under the age of seven, as well as a representative sample of accessible painted exterior surfaces.

Federated Environmental’s lead-based paint services include Lead-Based Paint Hazard Assessments, Operations & Maintenance Planning, Abatement Specifications Development, Abatement Oversight, Monitoring, and Clearance Testing.

Lead Assessment of Lead Paint Hazards

Federated Environmental’s generally completes lead assessments in accordance with Lead-Based Paint Interim Guidelines for Hazard Identification and Abatement in Public and Indian Housing and the HUD Multifamily Protocol. However, all of the lead-based paint surveys conducted by Federated Environmental includes the following elements:

Federated Environmental incorporates the requirements of Department of Housing & Urban Development’s Notice of Funding Availability and Lead-Based Paint Risk Assessment, Federal Register, Volume 57, Number 125, June 29, 1992.
All accessible painted surfaces on the property are inspected by a Lead Paint Inspector. All of the painted surfaces will be inspected for peeling, chipping, flaking, chalking, and any other damage that would facilitate its removal by a child.
Trained and certified personnel use a state-of-the-art portable field analyzer [Spectrum Analyzer X-Ray Fluorescence Units (XRF)] to assess the quantity, condition, and location of lead-based paint inside and outside of the building(s). Strict quality control protocols are used including, but not limited to, laboratory sample collection, testing equipment validation, and specific sample testing documentation.
Federated Environmental will use the services of an accredited laboratory to test paint samples for total lead content, if needed. Paint samples are analyzed for total lead content using Flame Atomic Absorption Spectrometry (most cases).
If needed and desired, Federated Environmental will conduct an assessment of other areas on the property which may possess a lead hazard. These areas may include lead-containing dust and soil. Older playground equipment on a multifamily property may have lead-based paint. For potential lead-containing dust concerns, Federated Environmental will collect dust wipe samples for total lead analysis.
Federated Environmental will issue a comprehensive report at the completion of the inspection which includes, in detail, the presence, condition, and quantity of lead-based paint on the property. In addition, Federated Environmental will provide recommendations on the most effective means to bring the property into compliance with federal, state, and local regulations.

Operations & Maintenance Planning

Under certain circumstance, lead-based paint does not represent a significant environmental risk in its present location and condition. However, controls must be instituted to ensure that the lead-based paint is not disturbed or damaged, causing an unnecessary potential risk to children and pregnant women. Federated Environmental can develop a site-specific Operations & Maintenance Plan which describes the location and condition of the paint, and how the paint should be managed during routine maintenance and repair activities. An Operations & Maintenance Plan establishes a guideline for on-site property managers to use in order to reduce exposure risks. In addition, it provides a level of comfort that the paint is being is being properly managed on a day-to-day basis. The Operations & Maintenance Plan contains the following interim controls and risk-reducing items:

Lead Hazard training of the property management and maintenance staff.
Recommendations and protocols on worker protection requirements and mandated OSHA regulations for personnel safety.
Establishment of baseline worker health data and a medical surveillance program.
An easy-to-use Recordkeeping System.

The Operations & Maintenance Plan provided by Federated Environmental will be site specific, and is developed based on information and observations made only after a comprehensive inspection of the property and a review of on-site maintenance staff practices. This integrated approach serves to eliminate or reduce risks, be cost-effective, and be easily assimilated into the overall management of the property.

Lead Paint Abatement Specifications Development

When the condition of lead paint is so poor that abatement is the only viable alternative for managing the paint, Federated Environmental can provide a site-specific abatement plan designed to thoroughly manage the problem at the least possible cost. In order to assist and facilitate the abatement process, Federated Environmental provides the following services:

Provide cost quotations and estimates for the full range of lead hazard abatement strategies.
Assist in the review of the strategies in order to determine which abatement method is both the most cost effective and the best given the site specific conditions.
Develop the specifications package for abatement contractors to use in order to provide quotes for the completion of the work. The overall success of the abatement project relies on clear communication of what the abatement scope of work is to include and not include. This is particularly important in managing the overall cost of the project.

Federated Environmental has extensive experience in assisting multifamily property managers in handling their lead paint concerns. Effective management of the lead paint problem, accompanied by appropriate documentation makes coordinating and communicating with federal and state regulators that much simpler.

Abatement Oversight, Monitoring, and Clearance Testing

Although Federated Environmental is not a lead paint abatement contractor, under many circumstances our clients request that we oversee and monitor the abatement process to ensure that the work is “done right.” Usually, lead paint abatement contract work is completed in a proper manner, but clients like the level of comfort that their interests are being represented while the work is being completed. The project oversight process includes the following elements:

A review of the contractor’s insurance to ensure that the contractor possesses all of the necessary insurance needed to complete the work.
A review of the abatement strategy specifications to ensure that the work is being completed according to plan.
A physical reinspection of the work at the completion. The follow-up inspection typically includes the collection of “dust wipe” samples to ensure that no unacceptable lead dust remains.

All of these services are provided to ensure that the lead assessment is conducted properly, and that lead hazards have been properly addressed and that the property is in compliance with all applicable federal, state and local regulations.