This paper highlights innovative, prevention-based strategies
to advance lead safety on a broad scale for consideration
by cities applying for Lead Hazard Control grants and community-based
partnering organizations. HUD solicits applicants for this
program each spring.
Over the past eight years, HUD has awarded more than $400
million in grants to help cities and states control lead hazards
in low-income housing. More than 200 communities have benefited
from these funds. In designing and carrying out Lead Hazard
Control grant programs, grantees have taken different approaches
across the country, which have evolved over time. Initially, most grantees undertook extensive lead hazard
control interventions in a relatively few properties. Exclusive
use of certified abatement contractors and selection of strategies
that permanently abated most lead hazards typically resulted
in a high unit cost and a correspondingly low number of units
treated, with little or no impact on lead safety in other
properties in high risk communities. Over the course of the program, HUD has taken steps to reduce
the average per unit cost of lead hazard control, relax requirements
for the use of certified contractors, and require grantees
to develop genuine partnerships with community-based organizations.
Many local grantees have developed innovative and cost-effective
approaches to increase the impact of their HUD grants and
the number of children protected from lead poisoning. Meanwhile,
research and evaluation studies have shed new light on sources
and pathways of lead exposure in the home environment and
confirmed the effectiveness of a range of hazard control strategies. This paper draws on local grantees’ experience, the
results of recent research, and opportunities to leverage
HUD’s new lead safety regulations to identify strategies
to increase the benefits of HUD’s Lead Hazard Control
grants and build capacity in high-risk communities. The Alliance
expresses appreciation to all those HUD grantees and community-based
organizations whose innovative programs and ideas have inspired
this paper. The Alliance hopes that cities, counties, and
states applying for HUD funds will consider this menu of strategies
and integrate these into grant proposals and program design
as appropriate.
Experience by multiple HUD Lead Hazard Control grantees has
highlighted a number of innovative ways to broaden program
impact and benefits. Some of these are basic common sense
and already in broad use. Others are novel and may have special
application in particular high risk communities. Grant proposals
and projects can be designed to incorporate some or all of
these strategies. Of course, the specifics of the situation
must dictate program design.
Target High Risk Neighborhoods
For maximum impact, resources need to be focused on neighborhoods
at high risk. Most cities have at least limited data on elevated
blood lead prevalence rates. Where these data are not available,
proxy data on housing age, poverty, neighborhood distress,
and other factors are available from the Census and other
sources. While HUD Lead Hazard Control grant funds can be
directed to low-income, high-risk properties in virtually
every community, some grantees are finding that addressing
lead hazards at the neighborhood level instead of
at the individual property level opens the door to
new opportunities and suggests new prevention-based strategies.
For example, concentrating investments in a few high-risk
blocks can build a nucleus of lead-safe housing and help to
reduce exposures from external sources. Of course, first attention
should be given to investments to protect children at highest
risk and ensuring that properties that are made lead-safe
are occupied by families with young children so that the health
benefits are fully realized. Screen High-Risk Housing (in Addition to Screening
Children)
Up to this point, lead poisoning “prevention”
in many communities has meant screening children through blood
lead tests and reacting to those identified as poisoned (sometimes
effectively, sometimes not). Screening high-risk housing on
a broad scale to identify lead hazards can complement blood
lead testing (or help to fill the void in communities lacking
effective health screening). Since comprehensive information
about lead hazards and the location of lead-based paint is
not required to identify high risk properties, the formal
“lead inspection” and “risk assessment”
protocols are not appropriate or cost-effective for initial,
broad-scale screening. Lower cost, more limited screening
tools can be used to set priorities and identify properties
for in-depth investigation. A visual inspection for deteriorated
paint and obvious signs of deferred maintenance provides a
quick and easy first cut. For properties with deteriorated
paint and deferred maintenance, limited dust and paint chip
samples can be collected for laboratory analysis. In most
communities, such initial screens can be done for as low as
$50 per property. Negative results obviously cannot be interpreted
to guarantee that a property is lead-safe. Make More Properties Lead-Safe, Instead of Fully
Abating a Few Units
The hazard control strategy selected should always match the
specifics of the situation. Instead of being automatic or
routine, complete abatement should be reserved for high-risk
properties with extensive and severe lead hazards. Over the
past few years, most HUD grantees have redirected their programs
along these lines. In most properties, hazards can be effectively
controlled by renovating windows, re-hanging doors, and safely
repairing deteriorated paint; correcting the underlying causes
of paint deterioration (usually water damage and moisture);
and doing a thorough cleaning using the proper techniques
for lead dust removal at the end of the job. Clearance dust
testing must be done in all units as a quality control to
ensure that lead dust hazards are not left behind, as will
soon be required for HUD-funded rehab and paint repair projects
in pre-1978 properties. Use Workers with Basic Training in Lead Safety for
Low-Level Interventions
Most cities receiving HUD lead hazard control grants use lead
abatement contractors for all work, even relatively simple,
small-scale projects. Because the number of certified abatement
contractors is limited in many areas, complete reliance on
certified contractors can increase cost and limit output.
HUD’s current NOFA allows uncertified contractors to
perform minor paint stabilization and dust control. In addition,
HUD’s policy guidance 94-09 (available at www.hud.gov/lea/94_09.pdf)
explains how regular, non-certified contractors with “basic
training” in lead safety can be used for various hazard
control measures, including window replacement. This approach
reduces barriers to entry for community contractors and workers,
expanding employment and economic opportunities in distressed
communities. Section 3 even allows HUD funds to be used in
creative ways to help build the capacity of contractors employing
low-income community residents. Make Lead-Safe Painting and Remodeling the Norm
Because lead paint is a prevailing reality in distressed housing,
all painters and remodelers need to understand the dangers
of lead dust and know how to take basic precautions. The changes
needed to make work practices lead-safe are modest, easy to
integrate into standard procedures, and can be learned in
one day of training. EPA and several states are now developing
one-day courses to train painters and remodelers how to control,
contain, and clean up lead dust. HUD’s approval of these
courses as meeting its requirements for CDBG- and HOME-financed
rehab and paint repair projects provides an easy way to assure
that training courses convey the critical information. At
very low cost, HUD grantees could offer no-cost or low-cost
training in lead-safe practices to painters, remodelers, maintenance
workers, homeowners, and landlords. Additionally, funds could
be used for volume purchases of tools and equipment to control
lead dust hazards, including high quality vacuum cleaners,
cleaning supplies, poly sheeting, mops and buckets, and other
supplies. Training courses and equipment lease and loan could
be housed in an appropriate community-based organization with
experience in lead poisoning prevention. Help Property Owners Who Want to Make Their Properties
Lead-Safe
Some HUD grantees provide free or low-cost training, technical
assistance, advice, and supplies to homeowners as well as
responsible rental property owners. For example, grantees
could periodically offer at no charge a one-day HUD-approved
lead-safe practices course to homeowners and landlords. To
make this even more attractive, trainees could be given a
stipend to offset time and expenses, and child care could
be provided, if necessary. Among other things, such free training
offers the opportunity to establish a common ground and constructive
working relationship with landlords who welcome such assistance
and want to integrate lead safety into their operations. Another
approach is for a community-based organization to hire a retired
contractor to provide lead safety technical assistance, advice,
and mentoring to landlords and their maintenance staff. Lead
Hazard Control grants can also be used to fund free specification
writing, bulk purchase of supplies, or even stipends to cover
the additional cost of lead-safe turnover treatments to ensure
continuing lead safety in properties occupied by a family
with a young child. Leverage Existing Programs to the Maximum
It is vital that HUD’s Lead Hazard Control grant funds
not be viewed in a vacuum. Rather, these funds offer the opportunity
to fill critical gaps to advance lead safety. For example,
some HUD grantees are using Lead Hazard Control grant funds
in tandem with intensified code enforcement in high risk neighborhoods.
Other grantees are using lead hazard control funds to provide
clearance testing in private Section 8 units and after rehab
projects funded by CDBG and HOME. Grantees can also explore
innovative partnerships with managed care organizations providing
health care to children covered by Medicaid and other children’s
health insurance programs, such as screening homes occupied
by families with young children for environmental hazards.
In addition, grantees can build the capacity of small local
contractors by providing training in trade skills and administration
as well as assistance with purchasing equipment and supplies. Educate Families for Prevention
In addition to training painters, remodelers, and landlords,
grant funds could also be used to provide critical information
to help parents protect their children from poisoning. It
is vital, however, that educating parents be viewed as one
of a constellation of prevention strategies rather than a
substitute for controlling lead hazards. Tenants need to be
educated about their legal rights and that property owners
have a legal duty to provide safe housing. Families also need
to be educated as “lead-smart consumers” to make
well-informed housing decisions. Some communities are developing
registries of lead-safe and/or hazardous properties to help
make critical information about lead-safe housing more easily
available to families. Another promising community-wide prevention
strategy is to educate pregnant women about lead safety even
before the child is born. Respond Rapidly to Lead-Poisoned Children
While HUD’s Lead Hazard Control grant funds are not
intended simply to treat properties occupied by a poisoned
child, these funds do provide a critical resource to rescue
children in extremis. Many communities have elected
to give properties housing a lead-poisoned child special consideration,
(e.g., higher priority for selection, more intensive interventions,
etc.). But flexible approaches are needed even for properties
that have poisoned a child. For example, if the cost of the
hazard control is prohibitive or the landlord is uncooperative,
paying to relocate the family to safe housing may be a more
effective strategy, with safeguards to ensure that the property
is not reoccupied until its lead-safe status has been documented.
If a child has been poisoned by lead hazards in a multi-family
property, other units in the property should also be investigated.
Forge Genuine Partnerships with Community-Based
Organizations
HUD’s NOFA requires government agencies applying for
Lead Hazard Control grant funds to partner with community
organizations. In the past, many local governments made half-hearted
efforts to include community-based organizations, including
local groups only after-the-fact, assigning them only limited
responsibilities, and sharing only token funds. To make lead
safety a reality in communities hardest hit by lead poisoning,
community groups committed to lead poisoning prevention need
to be included early in the process and given a meaningful
role. These organizations must be allocated sufficient funds
to hire staff, cover administrative costs, build non-governmental
capacity to deliver a variety of services and have trained
and credentialled personnel to continue the work after the
grant ends. Review and Revise Policies and Programs
HUD Lead Hazard Control grant proposals are greatly strengthened
by demonstrated and genuine local commitment to prevention.
Creation of a public/private task force to critically review
laws, regulations, policies, and subsidy and enforcement programs
is one clear way to demonstrate this commitment. In addition
to the relevant government agencies, leaders of community-based
organizations committed to lead poisoning prevention and affordable
housing should have full representation in this task force.
The task force should report regularly to the executive and
legislative branches of government, as well as to neighborhood
associations, on legislative, policy, and program changes
needed to protect the community’s children at highest
risk for lead poisoning.
The Alliance To End Childhood Lead Poisoning believes this
menu of innovative strategies developed by Lead Hazard Control
grantees and community-based organizations offers significant
opportunities for increasing protection to children still
at significant risk for lead poisoning. We hope that existing
HUD grantees as well as cities applying for their first Lead
Hazard Control grant will consider integrating these strategies
into their grant proposals as well as program design and implementation.
The Alliance expresses appreciation to all those in governmental
agencies, community-based organizations, universities, and
private industry working to find more effective ways to protect
children from lead hazards in their homes. We hope to expand
this paper to include other innovative and effective strategies
in the future. The Alliance takes full responsibility for
this paper. | 