Federal EPA Lead Notification
7. Provide copies of all lead reports for inspections, testing, abatement and clearance – include apartment-specific reports and common area reports – to Leasing
Manager.
8. Maintain a Report Database for each building, by year. Include the following:
a. apartment number;
b. whether there is a child under 6;
c. the date of the apartment inspection;
d. when the report was received from consultant;
e. when the report was sent to the tenant;
f. whether abatement was required;
g. when abatement was done;
h. date of dust clearance report;
i. date results sent to tenants;
j. date copies of inspection & clearance reports delivered to leasing manager.
New York City Local Law 1 – Lead Paint Law
7. Annual Inquiry – On February 16 of every year, check the Welcome Link web link for lead paint notification status for each building managed. Obtain the summary report for each building. Get lists of apartments with children under 6, and apartments that had no notification return. Cooper Square must check all apartments with no returns for evidence of children under 6.
8. Annual Inspections – Contact approved lead inspector to conduct lead inspections for all apartments with children under 6 and all common areas, and make
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arrangements for access. Even if an inspection was previously done, you still must inspect to see if conditions have changed. Cooper Square shall contract
directly with the lead inspector – Use EHS approved consultant only.
9. Inspection Reports – Provide copies of reports to tenants. Get copies of all inspection reports to Cooper Square Leasing Manager.
10. Abatement Action Design - Contact EHS to determine which apartments require abatement, based on inspection reports.
11. Apartment Turnovers – get list of vacancies to NYU OCM and to NYU EHS to coordinate lead inspections and abatement planning.
COOPER SQUARE REALTY LEAD-BASED PAINT PROGRAM PROCEDURES FOR PROPERTY MANAGERS
12. Lead Paint Abatement – EHS or OCM will contract with the lead abatement firm. Cooper Square shall:
a. coordinate access to areas to obtain bids from approved lead abatement contractors;
b. coordinate with EHS to develop schedule for abatement, including tenant relocation, if necessary – note – if more than 100 square feet of area is abated, then 10-day notice must be given to NYC DOHMH, and 5-day notice to Federal EPA. Notices will be done by lead abatement contractor;
c. provide access to contractors/consultants to do required lead work;
d. notify EHS if ANY change in scheduling is required;
e. be responsible for all communication with tenants;
f. provide tenants with abatement dust clearance sample results;
g. provide leasing manager with copy of abatement final report.
13. Tenant contact – if a tenant notifies you that a child under 6 now lives in the apartment, or has concerns about peeling paint, check records to determine if an inspection had been done in the past year. Inform EHS of complaint and arrange for an inspection as soon as possible, if required. Get copies of report to EHS and to lease manager for file.
14. Lead Based Paint Record Tracking - Cooper Square must update the spreadsheet with annual inspections and construction information on surveys and remediation results, as well as, when information is received and given to tenant. These updates should be done at least monthly and sent to EHS.
YOU MUST COMPLY WITH ALL OF THESE REQUIREMENTS.
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COOPER SQUARE REALTY LEAD-BASED PAINT PROGRAM DOCUMENTATION REQUIREMENTS FOR LEASING MANAGERS
The following is documentation needed for Lead Investigation or Annual Assessments
PROCEDURES FOR LEASING MANAGER WHO IS RESPONSIBLE CHECK IF
COMPLETED PER PROJECT (FINAL REPORT)
EPA REQUIREMENTS
To be completed at Lease Signing/Lease Renewal (note: this also applies to subleases or any lease that is for a period greater than 100 days):
1. Provide the EPA “Lead-Based Paint Disclosure Form”
(Attachment A or link below)
http://epa.gov/oppt/lead/pubs/lesr_eng.pdf (English) http://epa.gov/oppt/lead/pubs/spanless.pdf (Spanish)
Cooper Square Realty (for NYU)
2. Provide a copy of the EPA Pamphlet Protect Your Family from Lead in Your Home (Attachment B or link below)
http://epa.gov/oppt/lead/pubs/leadpdfe.pdf (English) http://epa.gov/oppt/lead/pubs/leadpdfs.pdf (Spanish)
Cooper Square Realty (for NYU)
3. Provides copies of ALL reports for inspections, testing, abatement and clearance – include apartment –specific and common area reports.
Cooper Square Realty (for NYU)
4. Reports to provide include:
• A) Initial XRF Report Assessment
• B) Lead Abatement Reports (if initial assessment warrants abatement – i.e. poor condition)
• C) Annual Visual Assessment Report (if 4A was performed then every year after 4C must be performed and include past reports to tenant.
• D) If new tenant or “turnover, refresher or custom”
then 4A would be performed and all past report information be given to new tenant
Cooper Square Realty (for NYU)
5. For renewals, provide copies of reports generated since last lease signing (see #4)
Cooper Square Realty (for NYU)
6. Maintain copies of notification forms in lease files Cooper Square Realty (for
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NYU) 7. For Sublease Agreements – subtenants must visit
Cooper Square Office before move in and receive required documentation (#1-4)
Letter to the Agreement provided by Faculty Housing 8. Subtenant Contact Information to provide to tenant file Cooper Square Realty (for
NYU)
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PROCEDURES FOR LEASING MANAGER WHO IS
RESPONSIBLE NEW YORK CITY LOCAL LAW 1 REQUIREMENTS
1. At Lease signing/lease renewal – provide NYC Brochure – NYC Lead Poisoning Prevention Law Information for Tenants
(Attachment C or link below)
http://home2.nyc.gov/html/doh/downloads/pdf/lead/lead-paint-fix-bro-abr.pdf
2. Annual Inquiry – Between Jan. 1 and Jan. 15 of every year, forms must be provided to all tenants inquiring if they have a child under 6 residing in unit. If tenants do not respond by Feb. 15, contact CSR Property Manager to ensure that apartments are checked for child occupancy before March 1.
Cooper Square Realty (for NYU)
3. Forms must be provided by one of the following methods:
• by first class mail, addressed to the occupant of the dwelling unit;
• by hand delivery to the occupant of the dwelling unit;
• by enclosure with the January rent bill, if such rent bill is delivered after December fifteenth but no later than January sixteenth; or
• by delivering form in conjunction with the annual notice required pursuant to rules of the Department of Health and Mental Hygiene pertaining to the installation of window guards.
Cooper Square Realty (for NYU)
4. Upon receipt of form tenant must respond to the “owner” by February 15 of that year, whether or not a child <6 years old resides in unit. If tenant does not respond by Feb 15, and owner does not otherwise have actual knowledge whether a child < 6 year of age lives in unit, then the following:
• the “owner” shall at reasonable times and upon reasonable notice inspect that occupant’s dwelling unit to ascertain the residency of a child < 6 years of age and,
• When necessary, conduct an investigation in order to make that determination.
• If, between February 16 and March1 of that year, “owner” has made reasonable attempts to gain access into unit to
determine if a child <6 years old resides in unit and was unable to gain access, the “owner” shall notify the Department of Health and Mental Hygiene of that circumstance.
Cooper Square Realty (for NYU)
COOPER SQUARE REALTY LEAD-BASED PAINT PROGRAM DOCUMENTATION REQUIREMENTS FOR ABATEMENT AND/OR
ASSESSMENTS
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Lead abatement projects (Projects which disturb > 2 SF of surface/room with peeling paint, or >
10% of small component such as window sill), we need to keep the following on record and need for the following to be included in all Lead Reports based on the following:
DOCUMENTATION NEEDED FOR LEAD ABATEMENT PROJECTS
WHO IS RESPONSIBLE CHECK IF
COMPLETED PER PROJECT (FINAL REPORT)
1. Name, address telephone number of the person or entity who performed the work
NYU to include in contract/work order
2. Start date and completion date of the work;
Consultant to include in Final Lead Abatement Report 3. Copies of licenses and
training certificates for the personnel who performed the abatement work, as well as the firm license;
Contractor to provide to Consultant and Consultant to include in Final Lead
Abatement Report 4. Copies of licenses and
training certificates of the personnel who conducted the dust clearance testing;
Consultant to include in Final Lead Abatement Report
5. Location and description of the work performed in each room;
Should be included in Detailed Scope; if not to include by Consultant
6. Invoices for payment of lead-abatement work;
Consultant and Contractor to provide copies of invoices to EHS; original invoices to Responsible Party (Department Requesting Work)
7. Results of lead-contaminated dust clearance tests from 3rd party lab (include New York State lab certification number – must be certified for lead). Results should have copy of chain-of-custody record attached.
Clearance must meet the following:
Consultant to include in Final Lead Abatement Report
a. Floors: 40ug/SF
b. Window sills: 250 ug/SF c. Window wells: 400ug/SF DOCUMENTATION NEEDED FOR LEAD ABATEMENT PROJECTS
WHO IS RESPONSIBLE CHECK IF
COMPLETED PER PROJECT (FINAL REPORT)
8. Final Report signed by Consultant to include in Final
LEAD PROGRAM MANUAL 9. Copy of letter to tenant
providing occupants with the lead dust clearance test results.
At present, Cooper Square Realty (CSR) to include in each tenant’s file. CSR to provide EHS with signed memo that EHS provides to CSR confirming letters have been sent (see Attachment 1) 10. Checklist completed when
occupants are allowed temporary access to a work area
Consultant to include in Final Lead Abatement Report if applicable (see Attachment 2) 11. If project is > 100SF or
involves removal of 2 or more windows, the project must be filed 10 days before project start with DOHMH. A copy of the filing should be maintained in the project file.
Contractor to provide to Consultant and Consultant to include in Final Lead
Abatement Report
SPECIFIC TO TURNOVERS = (by definition: OCM turnovers & customs, CSR Refreshers)
12. Remediate all lead-based paint hazards and any underlying defects, when such underlying defects exist
CSR schedule with EHS Management of Lead Consultant & Contractor
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COOPER SQUARE REALTY LEAD-BASED PAINT PROGRAM DOCUMENTATION REQUIREMENTS FOR ABATEMENT AND/OR
ASSESSMENTS
DOCUMENTATION NEEDED FOR LEAD ABATEMENT PROJECTS
WHO IS RESPONSIBLE CHECK IF
COMPLETED PER PROJECT (FINAL REPORT)
13. Make all bare floors, window sills, and window wells in the dwelling unit smooth and cleanable
CSR schedule with EHS Management of Lead Consultant & Contractor 14. Provide for the removal or
permanent covering of all lead-based paint on all friction surfaces on all doors and door frames;
and
CSR schedule with EHS Management of Lead Consultant & Contractor
15. Provide for the removal or permanent covering of all lead-based paint on all friction surfaces on all windows, or provide for the installation of replacement window channels or slides on all lead-based painted friction surfaces on all windows. shall perform a lead-contaminated dust clearance test pursuant to this paragraph unless such person is a third party, who is independent of the owner and any individual or firm that performs the work upon turnover. Personnel performing
lead-contaminated dust clearance testing after completion of such work must be trained in accordance with
regulations issued by HUD, or successor rule, or under an equivalent program approved by HPD or DOHMH.
CSR schedule with EHS Management of Lead Consultant & Contractor
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COOPER SQUARE REALTY LEAD-BASED PAINT PROGRAM DOCUMENTATION REQUIREMENTS FOR ABATEMENT AND/OR
ASSESSMENTS
The following is documentation needed for Lead Investigation or Annual Assessments DOCUMENTATION NEEDED
FOR ANNUAL INVESTIGATION ONLY
WHO IS RESPONSIBLE CHECK IF
COMPLETED PER PROJECT (FINAL REPORT)
16. Name, address telephone number of the person or entity who performed the work
NYU to include in contract/work order
17. Start date and completion date of the work;
Consultant to include in Final Lead Assessment Report 18. Copies of licenses and
training certificates of the personnel who conducted the dust clearance testing;
Consultant to include in Final Lead Assessment Report
19. Location and description of the work performed in each room;
Should be included in Detailed Scope; if not to include by Consultant
20. Invoices for payment of lead-assessment work;
Consultant to provide copies of invoices to EHS; original to CSR (or Department Requesting Work) 21. Results of lead-XRF
samples
Consultant to include in Final Lead Assessment Report 22. Final Report signed by
certified lead
inspector/risk assessor
Consultant to include in Final Lead Assessment Report 23. Copy of letter to tenant
providing occupants with the lead XRF results.
At present, Cooper Square Realty (CSR) to include in each tenant’s file. CSR to provide EHS with signed memo that EHS provides to CSR confirming letters have been sent (see Attachment 1)
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Will be contacted by OCM PM of possible lead project and name of EH&S PM assigned to project.
Will notify EH&S of proposed OCM project (to help ensure that the start of the process is successful)
Will be provided with one set of drawings and request for investigation by the OCM PM.
Will provide OCM PM with the signed “ASBESTOS/LEAD AND CONSULTANT AGREEMENT” (Appendix A).
Will review construction drawings and provide OCM PM & EH&S PM with an investigation and investigation report.
Will provide OCM PM and EH&S PM of recommendations for remedial work.
If lead abatement project, will be requested by OCM PM to set up a bid walk-through with contractors.
If lead abatement project, will provide Scope of Work for abatement to OCM PM &
EH&S PM.
Will notify EH&S of bid walk-through date and time.
Will be notified of awarded abatement contractor and notify awarded contractor to start filings.
Based on contractor Scope of Work and schedule, will provide cost estimate for remedial work consulting and monitoring.
Will receive all filings from abatement contractor for signing process ASAP.
Work must not be allowed to proceed without a copy of the stamped filings in EH&S office (this requires all parties cooperation).
Will post all appropriate “Warning Lead Work Area” (Form B) within regulatory timeframes.
Will notify EH&S of any agency inspection or any deviation from proposed scope of work, accident, etc.
Has the authority through EH&S to stop work.
Will ensure that all filings and appropriate signs are posted prior to project start date.
Any changes to the Scope of Work will be provided to OCM PM, if changes affect the health & safety of occupants or worker, consultant will then notify EH&S.
Will ensure that the contractor is following Scope of Work.
Will be present and aware of operations during all abatement work.
Will notify OCM PM & EH&S PM when abatement project is completed.
Post-Abatement Walkthrough
Visually inspect the abated area and adjacent areas, to ensure that no dust or debris remains.
2. Take three dust wipe samples form each room or area where abatement work was done.
In each room or area, a sample must be taken from:
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ASBESTOS/LEAD SURVEY AND CONSULTI NG AGREEMENT
BY AND BETWEEN
NEW YORK UNIVERSITY / NYU HOSPITALS CENTER