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

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 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 If the property contains under 40 units, most cost effective method is to clear all units.