Describe the actions that will take place during the next year to evaluate and reduce the number of housing units containing lead-based paint hazards in order to increase the inventory of lead-safe housing available to extremely low-income, low-income, and moderate-income families.
Program Year 3 Action Plan Lead-based Paint response:
Based on the estimates provided in the Five-Year Consolidated Plan, approximately 745,000 to 911,000 or from 38 to 46 percent of all housing units in Alabama pose a lead-based paint hazard. An estimated 308,000 of the housing units with a potential lead-base paint hazard are occupied by extremely low-, low-, and moderate-income householders. Housing units occupied by those with less than 80.0 percent of the median family income where lead paint may be present are concentrated in the state’s most populous metropolitan counties. For the extremely low-income category, 30.5 percent of all dwellings estimated to contain lead-based paint were located in just two counties: Jefferson and Mobile. Likewise, in the low-income category, Jefferson and Mobile counties total 28.2 percent of the estimated housing units containing lead. Jefferson, Mobile, Madison, and Montgomery counties dominate in the moderate income group, comprising 40.0 percent of the state total.
Currently, Alabama’s CDBG program is the program most likely to be used for a project involving lead-based paint hazards. The State encourages all persons engaged in CDBG funded housing rehabilitation projects to presume lead is present if the house were constructed prior to 1979, therefore, no risk assessment or prior testing is required. The CDBG program has issued recommendations, rather than requirements, in order to maintain program flexibility. The Alabama CDBG program lead-based paint hazard recommendations are summarized below.
Prepare local housing rehabilitation policies and implement lead abatement requirements for units for which rehabilitation costs exceed $25,000.
Unless otherwise specified in an approved application, the local housing rehabilitation policies should specify that the standard treatment option per 24 CFR Part 35 et. al., will be used.
Have the housing rehabilitation inspector and a representative for all potential contractors take the University of Alabama course entitled “Lead Safe Work Practices for Renovators and Remodelers.” If the housing rehabilitation inspector will serve as a Lead Sampling Technician, then the inspector should take the University of Alabama course (or an equivalent course which has been approved by DHUD) entitled “Lead Sampling Technician Course”.
Determine if de minims levels are involved. If so, then safe work practices are not required and clearance testing is not required.
Provide the proper notices to occupants.
Determine what work (involving standard treatments and basic rehabilitation that will not impact painted surfaces) will need to be done and identify a plan to work room-by-room with the occupants. Outside construction work will need to be performed prior to any soil treatments. Treatment of any potentially contaminated soils will need to be done with either impermeable surface coverings or land use controls.
Avoid relocation of occupants, if at all possible, because of budgetary constraints. Sealing the work area and use of a 10’ containment area will likely be sufficient as long as access to the bath, kitchen and adequate sleeping areas are provided after work is completed on a daily basis. Note that the project will have to be completed within five days.
Perform clearance examination per procedures and use appropriate procurement practices to identify a qualified Accredited Inspector or Risk Assessor as per accreditation provided by Safe State. It should be noted that Safe State maintains a list of qualified firms that can provide these services.
Other than the above, typical procedures and housing standards, per the adopted rehabilitation policies, should be followed. Many of the standard treatments prescribed by 24 CFR Part 35 are already being used because they are necessary to correct code violations and to create safe and sanitary living spaces.
The overall goal of the recommendations listed above is to reduce lead-based paint hazards in CDBG funded housing rehabilitation projects over the next five years. The strategy has been broken into four parts listed below:
Coordinate state and local jurisdictions with public and private efforts to address and rectify the problem of reducing lead-based paint hazards and protecting young children from lead poisoning.
Integrate lead hazard evaluation and reduction activities into existing housing programs.
Develop technical capacity to ensure that the technical aspects of assessment and lead hazard reduction are managed properly.
Increase knowledge of lead safe practices among parents, property owners, and renovators of CDBG rehabilitated homes.