U.S. Department of Housing and Urban Development’s (HUD) 24 CFR 35 Subparts B thru R, is better known as the Lead Safe Housing Rule (LSHR). If you have chosen to be a Lead Safe Certified Firm and use a Certified Renovator, not only can you work on RRP projects, but also many HUD projects that contain lead based paint. In fact, when the Certified Renovator took their class, they also learned about HUD projects. As with EPA’s Renovation, Repair and Painting Rule, you can not disturb paint or stain in a pre-1978 target housing unless you are certified.
For the vast amount of painting contractors, it is not worth getting certification to only work on LSHR projects. This is especially true during economic hard times. Most painting contractors get certified to do RRP jobs and then when they run into a LSHR project they can take it.
LSHR VS RRP
If you are familiar with the EPA’s Renovation, Repair and Painting Rule many of the same type of compliance requirements will be done. However, there are some differences …
- The Certified Renovator can not do lead testing.
- There are 3 additional prohibited practices.
- Where EPA has a 6 sq ft exclusion, HUD’s is 2 sq ft.
- Clearance testing is required.
- The Certified Renovator is not usually responsible for compliance. The Designated Party is the responsible person.
- All workers must be Certified Renovators (unless the supervisor is abatement certified and has completed the 4 hour RRP refresher course).
There are some additional differences too, but minor things.
How To Tell If It’s A LSHR
Rule of Thumb: When someone contacts you specifically looking for a Lead Safe Certified Firm, many times, this can be a HUD project. Ask questions about any financial assistance.
The LSHR is required when the property if federally owned and/or receives federal assistance. The Lead Safe Certified Firm should ask if the property is federally owned, has a federal mortgage insurance or the project has received a loan or grant from the federal government.