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Common Pitfalls in Multi-Family Lead Assessments: Criteria and Best Practices

Learn about the common pitfalls in multi-family lead assessments and the specific criteria set by HUD for combining multiple units and buildings into a single assessment population. This guide covers key factors such as construction dates, maintenance and ownership history, and the importance of random and targeted inspections. Understand how to effectively identify and document hazards like dust and deteriorated paint. Explore the nuances of clearance testing and discover why traditional sampling methods may not yield representative results.

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Common Pitfalls in Multi-Family Lead Assessments: Criteria and Best Practices

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  1. Multi-Family Pitfalls Common Problems in Multi-Family Lead Assessments

  2. Grouping Units & Buildings HUD’s Criteria For Combining Multiple Units and/or Buildings into a Single Population Include: • Construction Date & Style • Paint History • “Could tenants ever paint their own units prior to 1978?” • Maintenance History • Ownership History

  3. Determining Tested Units • Random (Inspections & Risk Assessments): Most common method, relies solely on probability/math • Targeted (Risk Assessments only): Requires reliable data on every unit for 7 selection criteria • Worst Case (Risk Assessments only): Requires physical access to every unit in the population Documentation of the Selection Process is Critical! (See Accompanying Charts for Examples) Having owners clean selected units before a Risk Assessment is not considered a ‘representative sample’!

  4. Determining Hazards • Dust Hazards • Averaged by component per unit • If one unit has a hazard they all do. • Deteriorated Paint Hazards • Very little interpretive guidance from HUD • Presence of Lead-Based Paint is determined by percentage of the whole using HUD’s flow chart • Logical to follow the same chart and percentages to determine Deteriorated Paint Hazards (i.e. >2.5%) • Generally, all Common Areas should be tested, and the results of those tests stand alone. How are these hazards documented in our reports?

  5. Clearance Testing If the property contains under 40 units, most cost effective method is to clear all units. • Tested units must be randomly selected after work is complete • HUD guidelines state that contractor can’t know what units will be tested • Can’t simply use the same units that were tested in the Risk Assessment • Must review all selected units based on the hazards described in the multi-family Risk Assessment • Clearance testing relies on representative sampling for the entire property, so if one unit fails, all untested units fail with it • After failed results, future clearance testing cannot use the same units • HUD guidelines state that contractor can’t know what units will be tested • Must use and document new random selection process

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