SF Apartment : April 2018
MASTERS OF DISASTER
Get Ahead Of Lead
by Karen Cohn
Between July 2015 and June 2017, the Department of Public Health Childhood Lead Prevention Program (CLPP) helped 615 households with young children identify and eliminate lead hazards. Lead is a systemic poison that affects children’s brain development, behavior and growth. San Francisco’s lead hazards primarily come from lead paint manufactured and sold before 1979; unfortunately, 83 percent of San Francisco homes were built during this time period.
The older the property, the more likely there is significant lead content in the less recent paint layers. Lead paint becomes a hazard to children whenever it is deteriorated, damaged or disturbed because these activities generate lead dust. The lead dust ends up being deposited onto building surfaces and areas of uncovered soil. Young children explore their environment and touch those lead-contaminated surfaces and areas of uncovered soil. Later, they put unwashed hands in their mouths. This is the typical pathway of children’s lead exposure.
The DPH would like to thank property owners for their cooperation in protecting children from lead poisoning by keeping lead-painted surfaces in good condition, keeping soil covered and replacing lead-painted components where feasible. Equally importantly, thank you for only using U.S. Environmental Protection Agency (EPA) or California Department of Public Health (CDPH) lead-certified contractors to do repairs and renovations on the residential properties that you own.
Lead Exposure in San Francisco
Lead-exposed children have been identified in almost every census tract in San Francisco, and more frequently in neighborhoods built before 1950 when higher lead content in paint was most frequent. These neighborhoods include the Haight, the Mission, Bernal Heights, the Bayview and North Beach. We also find more children from lower-income households due to mandatory blood lead testing for this population.
San Francisco health and building codes create the presumption that all residences built before 1979 have lead-based paint history. Property owners may hire CDPH-certified lead inspector/assessors to seek to rebut this presumption. CLPP inspectors are CDPH-certified lead inspector/assessors. As such, they regularly inspect and identify lead hazards from damaged and deteriorating paint conditions on window trims and sills, doors and door frames, baseboards, banisters, interior and exterior walls, foyer and porch floors, as well as uncovered soil in yards.
CLPP inspections most commonly find the following lead hazards in the homes of San Francisco children: paint or stain in damaged or deteriorating condition; lead dust on interior or exterior surfaces; and lead contamination in soil. Let’s take a look at each of these hazards in a little more detail.
Older paints, varnishes and stains are presumed to be lead-based coatings. These coatings are identified as lead hazards when observed to be in poor condition. In the 615 homes CLPP inspected, inspectors found a total of 359 damaged surfaces cited as lead hazards. The majority (66.3 percent) of the hazards were at interior windows, doors and walls.
Inspectors measure lead in dust using dust wipes sent for laboratory analysis. In the 615 homes CLPP inspected, a total of 329 lead dust measurements had lead concentration considered to be a lead hazard. An astounding 95.1 percent of those dust samples were collected from inside the child’s living space.
Inspectors also measure lead in soil, taking composite samples sent for laboratory analysis. In the 615 homes CLPP inspected, only 77 homes had yards with uncovered soil, and therefore only 77 were sampled. Thirty-seven homes, or 48 percent of the soil samples from those yards, had lead concentration considered to be a lead hazard.
The CLPP inspector cited the identified lead hazards in a Notice of Violation to the property owner, ordering the hazards to be fixed by CDPH-certified Lead in Construction Supervisor and Workers. The property owner was also directed to hire a CDPH-certified Lead Inspector/Assessor to provide clearance testing at project completion, for submittal to CLPP.
Just as lead can be found throughout the city, so, too, can lead hazard violations.
The San Francisco Health Code defines lead hazards as a prohibited public health nuisance. Property owners should understand that a Notice of Violation from CLPP does not indicate that a lead-poisoned child is in residence. The health director’s code enforcement authority to cite lead hazards does not require that children who spend time at that property prove they have been exposed to lead. CLPP must only prove that lead hazards are present to issue a violation. The health director’s authority is used both to proactively prevent lead exposure to young children and to ensure that children who have already been tested and found to be lead-exposed do not have prohibited lead hazards in the homes and other places where they spend time.
Staying Out of Trouble
Always disclose to tenants that older buildings have lead-based paint, which needs to be maintained in good condition. This is required by federal law, along with providing your tenants with the USEPA brochure “Protect Your Family from Lead in Your Home.”
Encourage tenants to report changes in paint or soil conditions, so that you can act promptly. Periodically inspect paint conditions and stabilize any paint that has been damaged. The goal is to prevent the creation of lead dust or paint chips.
When asking for bids on rehabs, repairs, and remodeling work, ensure that your contractors know how to comply with the San Francisco Building Code lead-safe work requirements when disturbing paint in pre-1979 buildings. The goal is to prevent the creation of new lead dust hazards, which are the most costly problems to correct. Only hire those knowledgeable about how to avoid creating lead hazards during rehab, repair and remodeling work. Ask for proof of their USEPA Lead Certificate or CDPH Lead Supervisor or Worker Certificate.
Cover bare soil with strong weed cloth and one of the following: sod, bark, stones, six inches of clean soil with plantings, or other fill material. The goal is to prevent children from touching uncovered lead-contaminated soil.
In addition, the San Francisco Department of Public Health is proposing changes to two lead hazard definitions: “lead-contaminated dust” and “lead-contaminated soil.” The largest impact under the proposed change is that more properties could receive NOVs to correct lead dust hazards, particularly lead hazards found on exterior porches or in uncovered soil.
For example, currently dust on interior floors is considered at hazard at 40 micrograms per square foot and dust on interior sills is a hazard at 250 micrograms per square foot. Those numbers would drop to 10 micrograms and 100 micrograms, respectively, if the proposed changes are accepted.
The rationale for this proposal is that the San Francisco Health Code is out of date with three other state and federal authorities. The California Health and Safety Code definition of lead dust on exterior window sills and other exterior horizontal surfaces was updated to 100 micrograms per square foot (versus the current S.F. standard of 800). The California Office of Environmental Health Hazard Assessment modeling found lead exposure of young children occurred with daily contact with soil with 80 parts per million of lead (versus the current S.F. standard of 440 parts per million). Finally, U.S. Housing and Urban Development Agency Lead Hazard Control lowered lead dust standards for funding grantees. Therefore, we incorporated all these changes into an ordinance that, if passed, will amend San Francisco Health Code.
Please contact our program with your questions, to order lead prevention educational materials, or to ask for outreach presentations for your property managers and tenants. Program Coordinator Haroon Ahmad can be reached at Haroon.Ahmad@sfdph.org or 415-252-3956. Senior Lead Inspector Karen Yu can be reached at Karen.Yu@sfdph.org or 415-252-3957. To order educational materials, reach out to Sherrie Valdez at Sherrie.Valdez@sfdph.org or 415-252-3839.
Karen Cohn is the program manager for the Children’s Environmental Health Promotion Program at the San Francisco Department of Public Health.