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Lead-Based Paint Policy for University Apartment Housing

Effective Date: October 1, 2007 

Policy Statement

It is the policy of Columbia University to comply with all applicable federal, state and city legislation and regulations pertaining to the hazards of lead-based paint.  This policy covers residential buildings managed by University Apartment Housing (UAH) located in New York City.  This policy addresses the following issues as they relate to lead-based paint:  communication, inspection, worker certification and methods, remediation, clean-up and record keeping.  The policy focuses on residential buildings built before 1978 and, in particular, multi-family buildings where children under 6 years old are expected to reside.   

Reason(s) for the Policy The reason for this policy is to prevent exposure to lead-based paint hazards.  Lead-based paint was generally banned in New York City residential buildings in 1960 and in the United States in 1978 because of its known health hazards.  Subsequent federal, state and local legislation required owners of residential properties  to implement notification,  monitoring and remediation practices with regard to lead-based paint hazards.

Consistent with this legislation, the fundamental purpose of this policy is to ensure that: 1) residents, personnel, and contractors are aware of potential hazards from lead-based paint; 2) lead-based paint hazards are identified, monitored and/or remediated, as necessary and 3) workers use lead-safe work practices.

Primary Guidance to Which This Policy Responds

This policy complies with and is modeled after New York City Local Law 1 of 2004 and the federal Residential Lead-Based Paint Hazard Reduction Act of 1992 (Title X) and will be adjusted to comply with any future amendments to these laws or any new regulation that is enacted.

Responsible University Office & Officer

Columbia University Facilities is responsible for the maintenance of this policy and for responding to questions and concerns related to lead-based paint in residential spaces.  The Assistant Vice President for Residential Operations is the responsible officer.  Questions related to a specific building should be directed to the appropriate Director for Residential Services. 

Revision History

This policy has been in place, as it is currently structured, since August 2004 when New York City Local Law 1 of 2004 became effective.  Earlier, legislation such as New York City Local Law 38 of 1999, guided University policy related to lead-based paint hazards.  

Who is Governed by this Policy

University employees and contractors who perform and/or supervise repair or renovation work and/or communicate about lead-based paint issues in University Apartment Housing  and UAH leasing staff must comply with this policy.  In addition, residents living in UAH are required by law to comply with this policy.

Who Should Know This Policy

Senior Executive Officers, Vice Presidents, Directors, Project Managers, Senior Administrative Officers, UAH staff, Building and Grounds Personnel, and contractors or anyone that manages, supervises, leases, or otherwise does work in UAH must be familiar with this policy.

Exclusions & Special Situations

Buildings built after 1978 and buildings that have been certified as being lead free are excluded from this policy since they are presumed or known not to have lead-based paint.  Emergency work in an interior residential space is also excluded from some of the requirements of this policy.  Columbia University's Office of Environmental Health & Radiation Safety oversees academic, administrative and residence hall buildings with regard to lead-based paint issues and accordingly those buildings are not covered by this policy. This policy applies only to interior work and renovations in UAH and exterior work is generally excluded. 

Policy Text

The management of lead-based paint hazards in residential buildings operated by UAH is guided by existing federal and local legislation.  This summary is intended to be an outline and cannot cover all of the important and relevant information governing the policy and lead-based paint legislation.  Web site links to agencies that monitor compliance with this legislation and include more detailed information can be found below.

New York City Local Law 1 covers all pre-1960 multiple dwellings.  The law also places certain responsibilities on owners in post-1960 to pre-1978 buildings where the owner knows there is lead-based paint.

Local Law 1 requires that owners:

  • Send annual notifications to all occupants as well as to occupants upon lease-up, lease renewal, and agreement to lease or commencement of occupancy inquiring if there are children under 6 years of age residing in the unit.  Owners must include a notice about owner responsibilities under the law with each lease and must provide a pamphlet informing occupants about lead.  Owners must physically inspect units whose occupants do not respond to determine if there is a child under 6 residing in the unit.
  • Investigate units where children under 6 reside as well as common areas in the property to find peeling paint and lead-based paint hazards on chewable surfaces, deteriorated sub surfaces, and friction and impact surfaces.  This investigation must be conducted at least annually, or more often if the owner knows about a condition that may cause a lead hazard, or the occupant complains about such a condition.
  • Remediate lead hazards, using safe work practices and trained workers.
  • Make apartments lead safe on turnover.
  • Use safe work practices for all repairs and renovations performed in a unit where a child under 6 resides and in the common areas of buildings with such units.

Local Law 1 requires that occupants:

  • Respond to inquiries from the owner regarding the presence of children under 6 who are residing in the apartment
  • Promptly reporting any potential lead paint hazards such as peeling paint.
  • Facilitate annual inspections of their apartments.

Federal law requires that landlords disclose the presence of known lead-based paint and/or lead-based paint hazards in residential housing constructed before the phase-out of residential lead-based paint use in 1978. Landlords must also provide any available records or reports pertaining to the presence of lead-based paint and provide renters with the pamphlet developed by the United States Environmental Protection Agency, Housing and Urban Development and Consumer Product Safety Commission titled, Protect Your Family from Lead in Your Home.

Web site links:

Lead Related Links:  Columbia University Office of Environmental Health & Radiation Safety/Environmental Health & Safety

Lead Paint Law Compliance:  NYC Department of Housing Preservation & Development

Lead in Paint, Dust and Soil:  U. S. Environmental Protection Agency

 

Responsibilities

Director for Residential Services - follows up on inspections, necessary repairs and clearance in occupied apartments and common area renovations

Director of Housing Construction Programs  - ensures compliance with policy on apartment turnovers.

Director of Leasing Services - ensures that procedures are in place to give initial notice upon lease up and renewal to determine if child will reside in unit along with pamphlet regarding lead-based paint hazards.

Manager of Code Compliance - ensures annual notices and follow ups are prepared and distributed to residents.  Informs Directors and inspectors as needed where monitoring is necessary.

Definitions

Lead-Based Paint Hazard - any condition that causes exposure to lead from lead-contaminated dust, from lead based paint that is peeling, or from lead-based paint that is present on chewable surfaces, deteriorated surfaces, friction surfaces, or impact surfaces that could result in adverse human health effects.

Contacts

Poliy: Mark Kerman, 212-854-9301; mk17@columbia.edu

Building Specific Questions: Appropriate Director for Residential Services, 212-854-9301

Compliance: Diana Suarez, 212-854-9331; dsd1@columbia.edu

Appendix

Sample of annual notice to residents:  http://www.nyc.gov/html/hpd/downloads/pdf/annual-notice-lead-window-guards-english-2007.pdf