LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
1
11/01/07
TABLE OF CONTENTS
NYU EHS LEAD MANAGEMENT MANUAL
1.0 EHS Lead Safety Policy
2.0 EHS Lead SOPs - Lead-Based Paint Program Management Responsibilities 2.1 Residential Buildings
2.2 Academic Buildings
3.0 EHS Lead SOPs for Office of Construction Management (OCM) 4.0 EHS Lead SOPs for Cooper Square Realty (CSR)
4.1 EHS Lead SOPs Overview of Requirements for Cooper Square Realty 4.1.1. Lead Program Procedures for Leasing Manager (CSR) 4.1.2 Lead Program Procedures for Property Manager (CSR) 4.1.3 Documentation Requirements for Leasing Managers 4.1.4 Documentation Requirements for Lead Abatement and/or
Assessments 5.0 Lead Consultant Requirements 6.0 Lead Contractor Requirements 7.0 NYC Local Law 1 (NYC LL1)
7.1 NYC LL1 – Section Analysis
7.2 NYC LL1 – Guide to Safe Work Practices 8.0 US EPA Lead Laws & Guidance
8.1 USEPA Lead Pamphlet (in English) 8.2 USEPA Lead Pamphlet (in Spanish) 9.0 DOH Order to Abate Procedures
10.0 Attachments
A. USEPA Lead-Based Disclosure Form
B. USEPA Pamphlet Protect Your Family From Lead in Your Home C. NYC Lead Poisoning Prevention Law Information for Tenants D. Filing Requirements for Abatement
E. NYC DOHMH – Notice of Commencement Form for Work Disturbing 100 Square Feet of Lead Paint or 2 or More Windows F. EPA Notification of Lead-Based Paint Abatement Activities G. Access Inspection Report for Child Under 6 Years Old
H. DOHMH (NYC)– Annual Notice “Protect Your Child From Lead & Window Falls
I. Letter to Tenant – Notification Post-Assessment (XRF) J. Letter to Tenant – Notification Post-Abatement
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
2
RESIDENTIAL BUILDINGS
1. Contractor/Consultant Qualifications - Qualify Lead Abatement Contractors and Lead Consultants. Obtain current firm licenses, resumes and certifications of key employees, list of projects of similar scope for last 3 years, 5 references from clients with projects of similar scope, current insurance certificate, list of lead-related regulatory violations, a statement from contractor regarding default or of owner removing contractor from any lead project in last 3 years. Request a Dun & Bradstreet Report for contractors (can get on-line at www.dnb.com). Review submittals annually.
2. Lead Paint Notifications
a. Ensure that all apartments constructed prior to 1978 that NYU owns or leases complies with tenant notification requirements under EPA and Local Law 1 (see Cooper Realty SOPs for more details). Forms must be signed by tenants, reports provided to tenants, and informational
pamphlets provided.
b. Periodically audit lease files to ascertain level of compliance with BOTH EPA and LL1 notification laws. Check files for copies of NYC and EPA properly completed and signed notification forms, and copies of all reports. Check spreadsheets to see what reports should be in files. 3. Lead Paint Inspections
a. Annuals –
i. On March 1 of every year, get a list of apartments with children under 6 from Cooper Square. This will include all those who returned forms and indicated a child, as well as all those apartments that Cooper Square had to visually check to see if a child occupies the unit. Verify with Cooper Square that these are all the units with children under 6. For subleases, Faculty Housing will have a cover letter to the agreement indicating the subtenant must go to Cooper Square office before moving in to get
documentation and give contact information.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
3
11/01/07
RESIDENTIAL BUILDINGS
iv. children under 6. Review Annual Inspection Reports and develop list of all those that require some level of remediation. Ensure that reports are written in a way that can be understood by the tenants who will be reading them, and check for accuracy (make sure summary reflects attached data).
v. Develop Scopes of Work, in conjunction with lead inspector, to provide to Cooper Square. Cooper Square contracts with the inspector to perform the work.
b. Turnovers Inspections
-i. Obtain a list of turnover apartments from Cooper Square and OCM.
ii. Determine from OCM what renovations are planned for apartment turnovers.
iii. Set up project file for each turnover, and obtain a file code from EHS Director. This file will include the turnover inspection documents as well as abatement documents.
iv. OCM contracts with the consultant to conduct inspections. v. Ensure that lead inspections are performed, and that
recommendations are made for making the apartment lead-safe. This includes making recommendations for: remediation of LBP hazards and defects; making bare floors, window sills and window wells smooth and cleanable; and removing or providing permanent covering of all LBP on friction surfaces (windows, doors, etc.). vi. Check inspection report for findings, ensure that it is signed by a
certified lead inspector, and place copy of report in EHS file. Copies of inspection reports must be provided to OCM, Cooper Square Property Manager and Lease Manager.
4. Lead Abatement
a. Abatement Required by Annual Inspection Report
i. EHS must review annual inspection reports to determine which apartments require abatement. Request a file code from EHS Director for each apartment, or apartment grouping, requiring abatement, and set up project file, and assign EHS Project Manager.
ii. Request abatement Scope of Work from consultant. EHS will identify the scope of work with certified lead inspector and send to Cooper Square.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
4
RESIDENTIAL BUILDINGS
iv. Review bids and obtain schedule to do the work from Cooper Square. Note: NYC DOHMH project filings are required for projects >100 square feet, or for removal of 2 windows. Filing must be done 10 days prior to start of work. US EPA requires abatement contractor to give 5-day notice of abatement on any project.
v. EHS should notify contractor and consultant that they will be doing the project, and when it will commence. Provide them with the appropriate Lead Abatement/Lead Consultant Contract. EHS must coordinate work with Cooper Square Property Manager. vi. Confirm schedule with Cooper Square, and confirm that tenant will
NOT be present during abatement.
vii. Obtain copies of regulatory filings from Contractor and maintain in project file. Obtain waste disposal information from Contractor – for small projects where lead waste can be readily double bagged, and is not drummed, contractor is responsible for disposing – request lined landfill. For large projects where paint-strip waste is in one or more drums, EHS will do disposal as RCRA waste. viii. Give contractor and consultant notice to proceed, and review final
schedule.
ix. EHS Project Manager should selectively visit abatement projects, with priority given to large projects. Project Manager should look for the following:
• Lead Warning Sign posted;
• Means of decontamination for workers;
• Workers’ lead certification cards present for all workers and at least one supervisor;
• MSDSs for materials present at job site; • Review paint stripper used, if applicable;
• Make sure 3rd party monitor is present, is maintaining daily log book, and has checked the work area for proper
protection;
• Look for any evidence of tracking outside work site. x. At conclusion of the work, consultant should contact EHS and
confirm that work has passed the visual inspection and lead
clearance wipe tests have been taken. Consultant is responsible for verifying that the Scope of Work has been completed.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
5
11/01/07
RESIDENTIAL BUILDINGS
xii. Get copies of lead clearance results from consultant and compare with criteria:
• Floors – 40 g/sq.ft.
• Window sills - 250 g/sq.ft. • Window Wells – 400 g/sq.ft.
xiii. Consultant should notify contractor of clearance, and observe final teardown of containment and removal of all contractor materials from site.
xiv. EHS to notify Cooper Square that project is complete.
xv. Ensure that Cooper Square provides tenant with clearance results. LL1 requires that test results be provided (Note – LL1 does not stipulate a time frame for notification). See attachment A for sample cover letter for Cooper Square.
xvi. Obtain final closeout documents from consultant. Make sure Cooper Square gets copy of final report. Remind Project Manager at Cooper Square that Lease Manager needs a copy, and that information should be added to report-tracking spreadsheet. xvii. Ensure the project file has the following information:
• Consultant Contracts • Contractor Contracts
• Lead Paint Inspection report – signed by certified inspector; copy of license;
• Scope of Work for Abatement;
• U.S. EPA and NYC DOHMH Project Notification forms, if >100 sq. ft, or removal of 2 windows;
• Copy of letter to tenant providing occupants with the lead dust clearance test results;
• Copy of Consultant’s daily logs;
• Final report, including close-out information:
1. Name, address telephone number of the person or entity who performed the work;
2. Start date and completion date of the work; 3. Copies of licenses and training certificates for the
personnel who performed the abatement work, as well as the firm license;
4. Copies of licenses and training certificates of the personnel who conducted the dust clearance testing; 5. Location and description of the work performed in
each room;
6. Invoices for payment of lead-abatement work;
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
6
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 must have copy of chain-of-custody record attached. Clearance must meet the following:
a. Floors: 40 g/sq.ft.
b. Window sills: 250 g/sq.ft. c. Window wells: 400 g/sq.ft.
8. Final Report signed by certified lead inspector/risk assessor.
9. Checklist completed when occupants are allowed temporary access to a work area.
b. Abatement Required for Turnovers
i. OCM is provided list of turnover from Cooper Square. They review renovation needs, and submit a request to EHS Director for a lead paint inspection. EHS director assigns EHS Project
Manager, and assigns file code for project.
ii. Project Manager sets up file. OCM contracts with consultant to do lead paint inspection, and provides EHS copy of contract. Scope of work is discussed by OCM, EHS & consultant.
iii. Inspection report provided to EHS for review. Must be signed by lead inspector/risk assessor, and copy of certification provided. iv. Copy of report must be provided to Cooper Square for lease files.
v. OCM should obtain abatement Scope of Work from consultant. Review with EHS, OCM & consultant.
vi. OCM, with assistance from Cooper Square for access, to conduct bid walkthroughs with qualified lead abatement contractors, review bids and select contractor. Provide contracts to contractor and consultant.
vii. OCM, contractor and consultant shall develop abatement schedule and provide to EHS and Cooper Square.
viii. Provide copy of contracts to EHS (Note: EHS should provide standard lead abatement requirements to be included in the contract).
ix. Contractor shall do NYC and EPA project filings, and provide copies to OCM and EHS.
x. OCM to arrange with Cooper Square regarding access.
xi. OCM to notify EHS when work is to start. EHS shall selectively conduct site visits and check for issues, as described in preceding section.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
7
11/01/07
xii. Consultant/OCM must notify EHS of any changes to the project scope
xiii. Consultant shall notify EHS when project is complete, and provide clearance results for review. See criteria in previous section. xiv. EHS should verify with consultant that the Scope has been
completed. Any changes require approval from OCM and EHS. xv. Cooper Square should be notified when project is complete. xvi. EHS must obtain final closeout documents, as described in prior
section. Cooper Square must be provided with a final report. Cooper Square needs to keep a copy in the lease files for future tenant disclosure.
5. Elevated Blood Leads (EBLs)
a. Cooper Square must notify EHS if they are informed about any EBLs. The EHS Director must be informed of any EBL situation.
b. EHS should get levels, and compare with criteria for environmental intervention – any single test greater than or equal to 20 g/dL, or two blood tests between 15 and 19 g/dL. Doctors are to report these cases directly to NYC DOHMH.
c. If levels meet the criteria, EHS must arrange for a risk assessment to be performed by a licensed risk assessor, and must include interviews with the tenants as part of the assessment. Levels that are lower, but above the detection limit should be reviewed by EHS Director to determine level of investigation (i.e., apartment inspection or full-blown risk assessment). For any confirmed EBLs, EHS personnel should visit apartment with the lead risk assessor.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
8 Introduction
Lead based paint (LBP) abatement is not required by regulations for non-residential buildings. The OSHA Lead in Construction standard (29 CFR 1926.26) requires that construction/renovation/demolition contractors follow the standard of assessment and protection of employees. OCM and FCM may have projects requiring LBP investigation and abatement in non-residential facilities.
5. Contractor/Consultant Qualifications - Qualify Lead Abatement Contractors and Lead Consultants. Obtain current firm licenses, resumes and certifications of key employees, list of projects of similar scope for last 3 years, 5 references from clients with projects of similar scope, current insurance certificate, list of lead-related regulatory violations, a statement from contractor regarding default or of owner removing contractor from any lead project in last 3 years. Request a Dun & Bradstreet Report for contractors (can get on-line at www.dnb.com). Review submittals annually.
6. Lead Paint Inspections
a. Construction Project Inspections
i. OCM will choose a consultant from the approved list qualified by EHS.
ii. Set up project file for each project, and obtain a file code from EHS Director. Review previous projects to see if any lead surveys or abatement was conducted. Send this information to the OCM PM.
iii. OCM contracts with the consultant to conduct inspections. iv. Ensure that lead inspections are performed, and that
recommendations are made for abatement of LBP, if necessary, based on the construction scope.
v. Check inspection report for findings, ensure that it is signed by a certified lead inspector, and place copy of report in EHS file. Copies of inspection reports must be provided to OCM. b. Facilities Projects
i. FCM is responsible for informing EHS of tasks that may disturb LBP.
ii. EHS will choose a consultant from the approved list.
iii. Set up project file for each project, and obtain a file code from EHS Director. Review previous projects to see if any lead surveys or abatement was conducted. Send this information to the FCM PM.
iv. EHS contracts with the consultant to conduct inspections.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
9
11/01/07
v. Ensure that lead inspections are performed, and that
recommendations are made for abatement, if necessary, of LBP based on the Facilities scope.
vi. Check inspection report for findings, ensure that it is signed by a certified lead inspector, and place copy of report in EHS file. Copies of inspection reports must be provided to FCM. 7. Lead Abatement
a. Abatement Required for Construction Projects
xvii. OCM should obtain abatement Scope of Work from consultant. Review with EHS, OCM & consultant.
xviii. OCM conducts bid walkthroughs with qualified lead abatement contractors, reviews bids and selects contractor. Provide contracts to contractor and consultant.
xix. OCM, FCM building manager, contractor and consultant shall develop abatement schedule and provide to EHS.
xx. Provide copy of contracts to EHS (Note: EHS should provide standard lead abatement requirements to be included in the contract).
xxi. Contractor shall do NYC and EPA project filings, and provide copies to OCM and EHS.
xxii. OCM to arrange with FCM building manager.
xxiii. OCM to notify EHS when work is to start. EHS shall selectively conduct site visits and check for issues, as described in preceding section.
xxiv. Consultant/OCM must notify EHS of any changes to the project scope
xxv. Consultant shall notify EHS when project is complete, and provide clearance results for review.
xxvi. EHS should verify with consultant that the Scope has been completed. Any changes require approval from OCM and EHS. xxvii. FCM building manager should be notified by OCM when project is
complete.
xii. Ensure the project file has the following information: • Consultant Contracts
• Contractor Contracts
• Lead Paint Inspection report – signed by certified inspector; copy of license;
• Scope of Work for Abatement;
• U.S. EPA and NYC DOHMH Project Notification forms, if >100 sq. ft, or removal of 2 windows;
• Copy of Consultant’s daily logs;
ACADEMIC BUILDINGS
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
10
10. Name, address telephone number of the person or entity who performed the work;
11. Start date and completion date of the work; 12. Copies of licenses and training certificates for the
personnel who performed the abatement work, as well as the firm license;
13. Copies of licenses and training certificates of the personnel who conducted the dust clearance testing; 14. Location and description of the work performed in
each room;
15. Invoices for payment of lead-abatement work; 16. Results of lead-contaminated dust clearance tests
from 3rd Party lab (include New York State lab certification number - must be certified for lead). Results must have copy of chain-of-custody record attached. Clearance must meet the following:
a. Floors: 40 g/sq.ft.
b. Window sills: 250 g/sq.ft. c. Window wells: 400 g/sq.ft.
17. Final Report signed by certified lead inspector/risk assessor.
18. Checklist completed when occupants are allowed temporary access to a work area.
b. Abatement Required for Facilities Projects
i. EHS will have consultant develop the abatement Scope of Work from consultant. Review with FCM.
ii EHS conducts bid walkthroughs with qualified lead abatement contractors, reviews bids and selects contractor. Provide contracts to contractor and consultant.
iii. EHS, FCM building manager, contractor and consultant shall develop abatement schedule.
iv. EHS does work orders or contracts (based if emergency or project) and provides to FCM.
v. Contractor shall do NYC and EPA project filings, and provide copies to EHS.
vi. EHS shall conduct site visits and check for issues.
vii. Consultant shall notify EHS when project is complete, and provide clearance results for review.
viii. EHS should verify with consultant that the Scope has been completed.
ix. FCM building manager should be notified by EHS project is complete.
x. Ensure the project file has the information listed above.
ACADEMIC BUILDINGS
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
11
11/01/07
a. All waste generated from LBP abatement is RCRA hazardous waste and will be disposed of in accordance with Safety Policy 109.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
12
Purpose
To ensure that OCM follows proper procedures for lead abatement project management as required by The Department of Environmental Health & Safety.
Procedure
OCM Project Managers are responsible and must ensure that documentation of project is on-going and reviewed for completeness until project end.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
13
11/01/07
EH&S Director
Receives all notification of construction via “Asbestos/Lead Survey/Abatement Request Form” (Form A) by OCM PM as soon as project is known.
Will assign an EH&S PM to oversee the QA/QC of the possible abatement project. Send email notification to OCM PM of the name of the EH&S PM.
EH&S Project Manager (will follow in-house procedures in addition to below)
Receives project notification from EH&S Director
Immediately sets up project file and checks EH&S files of possible past projects or surveys that might be helpful information to OCM PM.
Notifies OCM PM of any past XRF assessments and/or abatement projects previously performed in the building or in the exact location.
Discusses scope of work with OCM PM.
Will receive a copy of the investigation report from consultant OR
Will receive an email from OCM PM that OCM PM has received an investigation report (this will help to ensure project is being made aware to EH&S).
If the above is the case, EH&S PM will send an email to EH&S Director to assign project code and complete the missed steps.
If assessment done and no lead is found, will receive report notification from EHS.
Complete Responsibility
If no previous assessment, OCM PM will schedule assessment. project, will be notified of bid walk-through date and time through OCM PM or consultant.
If lead abatement project, EHS will be notified of bid walk-through date and time through OCM PM or consultant.
If abatement project, will be provided Scope of Work for abatement by consultant. Will be notified of all meetings regarding lead project through OCM PM.
Will be notified of awarded contractor by OCM PM. Will be notified of abatement schedule by OCM PM.
Will receive copies of all filings and will notify EH&S via email, that filings have been received (this will help to ensure EH&S is kept informed).
Work must not be allowed to proceed without a copy of the stamped filings in EH&S office (this requires all parties cooperation). At least 24-hours prior to start.
Will be aware that consultant will post “Lead Work Area” in building location within regulatory timeframe.
Will be made aware by consultant of any changes to scope of work that might affect the health & safety of occupants or workers.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
15
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
16
OCM Project Manager
Will send an “Asbestos/Lead Survey/Abatement Request Form” (Form A), as soon as the project is official to the EH&S Director.
Will provide one set of drawings and scope of work to EH&S Director.
After discussions with EH&S PM, will assign a consultant to the project and request a survey investigation (if one has not been completed previously).
Will use the “Lead Survey and Consultant Agreement” (Appendix A) to initiate survey with consultant.
Will provide the consultant with one set of drawings of the project and the name of the EH&S PM assigned to the project for proper investigation.
If project is an apartment renovation, a lead survey is required. Will receive proposal for investigation to be provided by consultant. OCM PM will initiate investigation by signing consultant proposal. Will receive investigation report from consultant
Will send an email to EH&S PM that investigation report is received (this will help to ensure that EH&S is aware of project).
If abatement project, will request consultant set up a bid walk-through with contractors. Standing Walkthroughs will occur on Fridays
If abatement project, will request consultant to provide Scope of Work for abatement. Scope of Work will be attached to contract for both consultant and contractor
Will notify EH&S of bid walk-through date and time (either by OCM PM or Consultant but must ensure EH&S is aware). Standing Walkthroughs will be scheduled for Fridays Will notify EH&S of all meetings regarding asbestos project and any changes to
meetings, schedules, etc.
Will receive bids from abatement contractors.
Will award bid to abatement contractor and notify awarded contractor and EH&S of awarded contractor.
If work is 100SF or greater or involves the removal of 2 or more windows, EHS receive all filings from abatement contractor.
Will receive copies of all filings and will notify EH&S via email, that filings have been received (this will help to ensure EH&S is kept informed).
Complete Responsibility
A copy DOHMH Notice of the Commencement of Abatement (mentioned above) must be posted at the entrance to the building and at the entrance of the specific apartment where work will take place. This must be posted 24-96 hours before work begins.
Post a warning sign in one inch letters, next to the abatement area at least 24 hours
before work area preparation begins, that says: WARNING:LEAD PAINT
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
17
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
18
Complete ABATEMENT CONTRACTOR
Contractor must be “EPA Certified – Lead Safe Work Practices
Will be notified of abatement bid walk-through by OCM PM via consultant.
Will be given Scope of Work at walkthrough and is responsible for all conditions within the Scope of Work, areas or quantities of lead, etc.
Will notify OCM PM of a realistic schedule to complete the work under regulatory and safe conditions.
Will provide bids to OCM PM by date requested.
If awarded bid, will begin regulatory filings process ASAP. If schedule not set, obtain projected start date and amend as necessary.
Will file with all appropriate agencies depending on the size of the project. If 100 SF or greater or removal of 2 or more windows – DOHMH filing is required.
Must provide the DOHMH Notice of Commencement Form 10 days prior to start of work.
Copy of the above-mentioned notice must be posted in work area 24-96 hours before work begins.
Fax or hand deliver the EPA Notice of Lead-Based Paint Abatement Activities 1 to 4
days before work starts.
Post Warning Sign: “Warning: Lead Work Area – POISON – No Smoking or Eating” in work area start.
Will provide OCM PM & EH&S PM of all copies of filings.
Work must not be allowed to proceed without a copy of the stamped filings in EH&S office (this requires all parties cooperation).
Any changes to the Scope of Work will be provided to OCM PM via change order and wait for approval from OCM PM.
Will protect all surfaces and fixed equipment from contractor’s operation. Assume full responsibility for damage which occurs while working on the project and shall reimburse NYU for necessary repairs or anything that is not within the Scope of Work.
HEPA vacuum to wet wipe and remove all objects (including drapes, furniture, and
carpets- organized through OCM) from the abatement area. If objects cannot be
removed, HEPA vacuum or wet wipe them and cover them with 2 layers of 6 mil plastic sheeting sealed with waterproof tape.
Cover all floors, windows and air vents in the abatement area with 2 layers of 6 mil
plastic sheeting sealed with waterproof tape.
Complete Responsibility
Cover doorways with two sheets of plastic. Tape one sheet of 6 mil plastic sheeting to
the top and one side of each doorway. Tape a second sheet to the top and other side of each doorway, to create a "S"-shaped entry.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
19
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
21
11/01/07
Complete CONSULTANT
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.
Complete Responsibility
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.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
22
FILING & POSTING INFORMATION: Regulatory
Agency Size of Project Filing Requirement No ApprovalNeeded
NYC
DOHMH Work Disturbing 100 SF ormore or Removal of 2 or more Windows DOHMH Notice of Commencement of Work 10 Calendar Days prior to start of work
EPA Same as Above EPA Notification of
Lead-Based Paint Abatement Activities
Fax or hand deliver 1 – 4 days prior to start of work
Post in Work Area
NYU
(contractor) Work Disturbing 100 SF ormore or Removal of 2 or more Windows DOHMH Notice of Commencement of Work 24-96 hours before work begins. NYU (contractor)
“Warning: Lead Work Area – POISON- No Smoking or Eating”
Start of Work
EH&S CONTACT LIST
NAME PHONE EMAIL
Stephanie Kung 8-1439 [email protected]
Melisa Puglisi 8-1438 [email protected]
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
23
11/01/07
Neha Prasad 8-1440 [email protected]
Zack Korenstein 2-8276 [email protected]
Joe Stern 8-1423 [email protected]
Lou Ortiz 8-1442 [email protected]
FORM A
ASBESTOS/LEAD SURVEY/ABATEMENT REQUEST FORM
Date: ________________________________ 1. PROJECT INFO:
TITLE OF PROJECT FCM PROJECT MANAGER
CONSULTANT : CONTACT & PHONE:
ARCHITECT/ENG. FIRM: CONTACT & PHONE
GENERAL CONTACTOR: CONTACT & PHONE
2. LOCATION OF PROJECT INFO: ADDRESS
AKA BLOCK # LOT #
APPROXIMATE AGE OF BUILDING (YEARS) HOW MANY FLOORS
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
24
Complete Set of Drawings (Plumbing, Mechanical & Electrical) & Specifications. Connections to existing pipe and areas that piping/conduit may pass through must be noted to determine if there is an impact with respect to asbestos
Requirements for re-insulation or fireproofing
4. Proposed project start date (date by which work zone is requested to be asbestos or lead free) :__________ 5. LIST OF OCCUPANTS (DEPARTMENTS) & SPACE UTILIZATION OF THE SURROUNDING AREA DEPARTMENT IN RENOVATION AREA CONTACT PERSON IN RENOVATION AREA
DEPARTMENT IN AREAS SURROUNDING THE ZONE CONTACT PERSON IN AREAS SURROUNDING THE ZONE
INSTRUCTIONS FOR ASBESTOS SURVEY/ABATEMENT REQUEST FORM
NOTE:
The Asbestos Abatement Report should be submitted to Environmental Services at least 6 weeks prior to the proposed project starting date (see section 4 on form) to avoid project start-up delay. The information requested will be used to file the appropriate New York City Department of Environmental Protection form: "Asbestos Inspection Report" or "Not an Asbestos Report". The following are general instructions for filling out the Asbestos Abatement Report.
AN ACCOUNT NUMBER SHOULD BE PROVIDED AT THE TIME OF REQUEST
FORM SECTIONS:
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
25
11/01/07
COOPER SQUARE REALTY
LEAD-BASED PAINT STANDARD OPERATING PROCEDURES OVERVIEW OF REQUIREMENTS
1. Tenant Notifications
a. Federal EPA-Required Lead-Based Paint Notification – All Apartments Constructed Before 1978:
i. At lease signing/lease renewal, Cooper Square leasing must provide tenant with required form (see Attachment A for sample), properly completed, and obtain tenant signature on form to keep in lease file;
ii. Provide a copy of the EPA pamphlet Protect your Family from Lead in Your Home (see attachment B).
iii. Cooper Square Leasing must provide tenant with copies of all lead-based paint related reports for their specific apartment and
common areas of the building. This includes reports for all inspections, tests, paint abatement, and dust clearance tests that have ever been performed in the applicable apartment, and all common areas. NOTE: All reports must be provided, even if abatement has been done in the apartment/common area, until a location is certified as “Lead Free”.
iv. For Sublease Agreements – Faculty Housing will have a cover letter to the agreement indicating that subtenants must go to Cooper Square Office before moving in to receive required documentation and to get subtenant contact information.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
26
been provided to Faculty Housing. Water Street has provided disclosure information to Cooper Square Realty and they provide it to incoming tenants. This building is new and is lead free.
b. New York City Local Law 1 – Requirements for All Apartments Constructed Prior to 1978
i. Annual notification form and lease signing & renewal form -Between January 1 and January 15 of every year, and at lease signing/renewal, provide every tenant with a form inquiring if they have a child under 6 residing in the apartment (see Attachment H for sample form). If residents do not respond by February 15, apartments must be inspected to determine if a child resides there
COOPER SQUARE REALTY
LEAD-BASED PAINT STANDARD OPERATING PROCEDURES OVERVIEW OF REQUIREMENTS
ii. (to be done by Cooper Square personnel). This determination must be made between February 16 and March 1, or the Department of Health & Mental Hygiene must be notified of failure to access. iii. Provide tenant with a copy of the New York City Lead Information
Brochure (see Attachment C).
iv. Welcome Link - Annual notices are currently being done for Cooper Square by this service. Cooper Square Property Managers must check the web-site, which has a list of NYU buildings, and the apartments which have children under 6. The Welcome Link web-site summary reports also have a list of units that did not respond to the request, apartments that had conflicting information, and units returned as undeliverable. Between February 15 and March 1, Cooper Square must inspect those units that did not respond, or where information was conflicting, to determine if a child under 6 is present. Cooper Square personnel can perform this check. Once all sources have been checked, a list of units must be compiled and arrangements made for lead inspections.
iv. For Sublease Agreements – Faculty Housing will have a cover letter to the agreement indicating that subtenants must go to Cooper Square Office before moving in to receive required documentation and to get subtenant contact information.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
27
11/01/07
been provided to Faculty Housing. Water Street has provided disclosure information to Cooper Square Realty and they provide it to incoming tenants. This building is new and is lead free.
2. Lead-based Paint Inspections
a. Annual Inspections - For all apartments where a child under 6 resides, an inspection for lead-based paint must be performed by a licensed inspector. Cooper Square is responsible for contracting with a company approved by EHS to provide this service. Apartments from the Welcome Link data and
COOPER SQUARE REALTY
LEAD-BASED PAINT STANDARD OPERATING PROCEDURES OVERVIEW OF REQUIREMENTS
from lease/renewal signing where the required form indicates a child under 6 resides, must be inspected for lead. Also, those non-responsive b. Apartments that are checked by Cooper Square and found to have children
under 6 must also be inspected by the licensed inspector and a report generated for that apartment. Once a year, all common areas must be inspected, and a report generated to cover all common areas in a building. c. Special Requests for Inspections - Throughout the course of the year, if
Cooper Square receives a request from a tenant for a lead paint inspection (because they have had a baby, or if a child under 6 comes to live with them, or if they are concerned about peeling paint), Cooper Square must contract with a licensed inspector to perform the work. EHS must be notified, and a copy of the report must be provided to EHS, to the tenant, and to the Copper Square leasing manager for inclusion in her EPA notification files.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
28
e. Apartment turnovers – all apartments must be made “lead-safe” during turnover. A list of turnovers must be compiled by Cooper Square and provided to OCM and EHS to make arrangements for a licensed inspection and assessment of lead hazards. OCM contracts for the inspection and assessments. The Cooper Square leasing agent should make any prior inspection reports available to the licensed lead inspector prior to inspection. Even if prior inspections exist, a licensed lead
inspector must perform this inspection, to determine the condition of lead-based paint. Prior reports may provide information to assist the lead inspectors in the performance of their work. The licensed inspector will provide reports to OCM, EHS and Cooper Square. Cooper Square must provide a copy of the report to the leasing manager, for inclusion in her files for EPA notification for the new tenant. EHS will review the reports
COOPER SQUARE REALTY
LEAD-BASED PAINT STANDARD OPERATING PROCEDURES OVERVIEW OF REQUIREMENTS
and, in consultation with the certified inspector, determine if lead abatement work is necessary.
f. Report Tracking – Cooper Square must maintain a spreadsheet indicating what apartments have had lead paint inspections. A separate list should be maintained for each building, and reports should be tracked by year. Access to this list must be provided to the Cooper Square leasing agent, and to EHS. This spreadsheet should be updated at least monthly and a copy sent to EHS. The following should be included on the spreadsheet for each building:
i. apartment number; whether there is a child under 6; ii. the date of the apartment inspection;
iii. when the report was received from consultant; iv. when the report was sent to the tenant;
v. whether abatement was required; vi. when abatement was done; vii. date of dust clearance report; viii. date results sent to tenants;
ix. date copies of inspection & clearance reports delivered to leasing manager.
3. Lead-based Paint Hazard Abatement
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
29
11/01/07
painters to do painting, if painting is needed. No further testing, inspection or reporting is required until the annual inspections are performed, and a child under 6 resides there.
b. Turnovers w/abatement required: For all turnovers, apartments must be made “lead-safe” prior to occupancy by new tenant. This work shall be contracted for by OCM. This includes remediating LBP hazards and defects, making bare floors, window sills and window wells smooth and cleanable, and remove or provide permanent covering of all LBP on friction surfaces (windows, doors, etc.) Work to be done must be defined by the certified LBP inspector/risk assessor, and contracted for by OCM in consultation with EHS. Scheduling of the work must be coordinated with the assistance of Cooper Square. Cooper Square must assist in gaining
COOPER SQUARE REALTY
LEAD-BASED PAINT STANDARD OPERATING PROCEDURES OVERVIEW OF REQUIREMENTS
access for contractors to review the scope to prepare bids. Contractors, inspectors and EHS must determine the length of time required to abate c. hazards, test the areas, and provide clearance test results. Time estimates
must be provided to Cooper Square, and Cooper Square must handle all apartment access issues.
d. Turnover Abatement Reports: A report of the work must be submitted by the certified LBP inspector/risk assessor, and include documentation as required by EHS and LL1. Reports are to be submitted to OCM, EHS and Cooper Square Realty. A copy of the report must be provided to the Cooper Square leasing agent for inclusion in the EPA notification files. EHS must maintain a summary list of all abatement reports, and provide copies and updates of this list to Cooper Square Leasing on a regular basis (every time list is updated).
e. Abatement recommended in Annual Inspection Reports and Other Inspection Requests: Upon review of the inspection reports, EHS will compile a list of apartments where work is to be done, and identify the Scope of Work, in conjunction with the certified lead inspector/risk assessor. EHS will provide a copy of the list to Cooper Square.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
30
to be present in active abatement areas, and Cooper Square must handle any relocation issues.
f. Abatement Reports: A report of the work must be submitted by the certified LBP inspector/risk assessor, and include documentation as required by EHS and LL1. Reports are to be submitted to OCM, EHS and Cooper Square Realty. A copy of the report must be provided to the Cooper Square leasing agent for inclusion in the EPA notification files. EHS must maintain a summary list of all abatement reports. Cooper Square must provide the tenant with a copy of the lead clearance wipe test results as soon as practical following receipt of the inspector’s test report. EHS has provided a standard notification letter for this purpose – see Attachment E.
COOPER SQUARE REALTY
LEAD-BASED PAINT STANDARD OPERATING PROCEDURES OVERVIEW OF REQUIREMENTS
4. Tenant Complaints
a. Child with Elevated Blood Lead Levels: If any tenant contacts Cooper Square, either in writing or by telephone, and says that their child has been tested by a physician and found to have elevated levels of lead in the blood, Cooper Square should obtain the contact information and
immediately provide it to EHS. EHS will then contact the tenant to obtain the details, and determine if a lead-based paint risk assessment needs to be performed.
b. Peeling Paint: If tenant calls with a complaint regarding peeling paint, Cooper Square should check the list of areas that have been selected for lead paint abatement to determine if the area has already been scheduled for lead abatement. If so, advise the tenant that the area(s) is already on the list for scheduled abatements. If the area is not on the list, schedule inspections for apartments with children under 6 or pregnant women. c. Complaint-Related Reports - Cooper Square shall be responsible for
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
31
11/01/07
COOPER SQUARE REALTY LEAD-BASED PAINT PROGRAM PROCEDURES FOR LEASING MANAGER
Federal EPA Lead Notification
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 a copy of EPA Pamphlet Protect Your Family from Lead in Your Home. 2. Provide the “Lead-Based Paint Disclosure Form” (make sure form is properly
completed).
3. Provide copies of all lead reports for inspections, testing, abatement and clearance – include apartment-specific reports and common area reports.
4. Check Report Databases from EHS and Property Managers to make sure all required reports are provided to the tenant.
5. For renewals, provide copies of reports generated since last lease signing. 6. Maintain copies of notification forms in lease files.
7. For Sublease Agreements – Faculty Housing will have a cover letter to the agreement indicating that subtenants must go to Cooper Square Office before moving in to receive required documentation and to get subtenant contact information.
New York City Local Law 1 – Lead Paint Law
1. At Lease signing/lease renewal – provide New York City Brochure - NYC Lead Poisoning Prevention Law Information for Tenants.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
32
do not respond by February 15, contact Property Manager to ensure that apartments are checked for child occupancy before March 1.
3. Welcome Link – provides initial annual notification service. Check their web-link to get information on which apartments have children under 6, and which apartments had no response. Property managers must schedule inspections for all apartments with children under 6. Follow-up to get reports.
4. Inspections – get copies of all inspection reports from Property Managers, and keep in leasing files.
5. Apartment Turnovers and Lead Abatement Reports – get copies of these reports from Property Managers and keep in leasing files.
COOPER SQUARE REALTY LEAD-BASED PAINT PROGRAM PROCEDURES FOR LEASING MANAGER
6. Tenant contact – if a tenant notifies you that a child under 6 now lives in the apartment, notify Property Manager to arrange for an inspection. Get copies of report for file.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
33
11/01/07
COOPER SQUARE REALTY LEAD-BASED PAINT PROGRAM PROCEDURES FOR PROPERTY MANAGERS
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.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
34
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.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
35
11/01/07
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)
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
36
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
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
37
11/01/07
PROCEDURES FOR LEASING MANAGER WHO IS
RESPONSIBLE CHECK IF COMPLETED PER PROJECT (FINAL REPORT) 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
(English)
http://nyc.gov/html/hpd/downloads/pdf/Fix-lead-paint-hazards-spanish.pdf
(Spanish)
Cooper Square Realty (for NYU)
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
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
38
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)
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
39
11/01/07
certified lead inspector/risk assessor
Lead Abatement Report 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
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
40
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.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
41
11/01/07
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.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
42
CONSULTANT
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.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
43
11/01/07
ASBESTOS/LEAD SURVEY AND CONSULTI NG AGREEMENT
BY AND BETWEEN
NEW YORK UNIVERSITY / NYU HOSPITALS CENTER OWNER
-AND
_____________________ CONSULTANT
---LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
44 PROJECT
DATED AS OF
____________
NEW YORK UNIVERSITY ("Owner") WORK ORDER
("Consultant")
SCOPE OF PROJECT
Consultant shall continuously monitor, inspect, observe and record the removal of lead-based paint ("LBP"), approximately less than _________________________at
__________________________ by _______________________("Contractor").
Consultant acknowledges that it is familiar with the conditions and scope of the project and with the project site and that any failure to have familiarized itself therewith shall not relieve Consultant of its obligations hereunder. The principal purpose of Consultant's activities will be to assure that Contractor is fully complying with all applicable laws, rules, regulations, orders, notices or other requirements and to verify successful
completion of the work through visual inspection and testing as required by New York City Local Law 1 (NYC LL1). Consultant shall also apprise Owner daily of the
information obtained by reason of its monitoring, inspection, observation and recording activities. All questions shall have been, or shall be directed to the Owner's Department of Environmental Health & Safety for clarification.
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
45
11/01/07
Location:________________________________________________________________
2. TERMS AND CONDITIONS
a. Schedule
Consultant will commence its monitoring, inspection, observation and recording duties at the project site at __________________ on _____________________ (the
"commencement date). The phases of the work by Contractor shall be determined and approved by Owner prior to the commencement date. The continuous duties of
LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT
PROGRAM MANAGEMENT RESPONSIBILITIES
46
11/01/07
ABATEMENT CONTRACTOR
Will be notified of abatement bid walk-through by OCM PM via consultant.
Will be given Scope of Work at walkthrough and is responsible for all conditions within the Scope of Work, areas or quantities of lead, etc.
Will notify OCM PM of a realistic schedule to complete the work under regulatory and safe conditions.
Will provide bids to OCM PM by date requested.
If awarded bid, will begin regulatory filings process ASAP. If schedule not set, obtain projected start date and amend as necessary.
Will file with all appropriate agencies depending on the size of the project. If 100 SF or greater or removal of 2 or more windows – DOHMH filing is required.
Fax or hand deliver the DOHMH Notice of the Commencement of Abatement to the
Department of Environmental Protection 1 to 4 days before work starts.
Copy of the above-mentioned notice must be posted in work area 24-96 hours before work begins.
Must provide the DOHMH Notice of Commencement Form 10 days prior to start of work.
Will provide OCM PM & EH&S PM of all copies of filings.
Work must not be allowed to proceed without a copy of the stamped filings in EH&S office (this requires all parties cooperation).
Any changes to the Scope of Work will be provided to OCM PM via change order and wait for approval from OCM PM.
Will protect all surfaces and fixed equipment from contractor’s operation. Assume full responsibility for damage which occurs while working on the project and shall reimburse NYU for necessary repairs or anything that is not within the Scope of Work.
HEPA vacuum to wet wipe and remove all objects (including drapes, furniture, and
carpets- organized through OCM) from the abatement area. If objects cannot be removed, HEPA vacuum or wet wipe them and cover them with 2 layers of 6 mil plastic sheeting sealed with waterproof tape.
Cover all floors, windows and air vents in the abatement area with 2 layers of 6 mil
plastic sheeting sealed with waterproof tape.
Cover doorways with two sheets of plastic. Tape one sheet of 6 mil plastic sheeting to
the top and one side of each doorway. Tape a second sheet to the top and other side of each doorway, to create a "S"-shaped entry.
2. If the area to be abated is less than 6 square feet per room, cover floors with 2 layers of 6-mil plastic extending 6 feet in each direction. Steps 2 and 3 are only required for larger jobs.
For Department of Health ordered abatements, follow the "Directions for Lead Paint Abatement" which include accepted abatement methods attached to the
"Commissioner's Order to Abate."