RISK ASSESSORS AND LEAD INSPECTORS STATISTICAL UPDATE August

RISK ASSESSORS AND LEAD INSPECTORS STATISTICAL UPDATE August 2, 2012 Lead Workshop Healthy Homes Section

TOP 5 • TOP 5 CITATIONS • TOP 5 NONS • Failed to submit monthly report • Failed to take correct number of dust wipes • Failed to provide copy of report to homeowner • Failed to take dust wipes from required locations • Failed to test all required surfaces • Conclusions section not near front of report • No table of contents • Hazards not prioritized • Missing property descriptors such as homeowner’s phone number • XRF quality control data missing such as calibration shots, serial number, etc

STATISTICS • 55% of the cases originated from Detroit • 50% of the cases were complaint based • 50% of the cases had NO CITATIONS § Down from 79% last year • 50% of the cases had Citations § Average of 2 citations per case up from 1. 2 last year § Average fine $568 per citation up from $303 last year • Reflects changes made to the Penalty Matrix system • 17% of the cases involved Home Inspectors performing an uncertified lead inspection 2012 Lead Workshop Healthy Homes Section 3

THE DETROIT INITIATIVE • Numerous complaints from landlords - “City of Detroit won’t accept the Risk Assessment that I paid for. ” • In response the City of Detroit has assigned a full time inspector to review every risk assessment for compliance with the Detroit lead ordinance • Severely non-compliant risk assessments are forwarded to me for auditing. • Aggressively addressing deficient risk assessments and applying citations as appropriate o Paint chip samples only is common and often very deficient • Working with the Detroiters Working for Environmental Justice to improve the list that is provided to landlords seeking a Risk Assessor • 2012 Lead Workshop Healthy Homes Section 4

WHAT THE HOMEOWNER WANTS TO KNOW “Do I have lead in my house? ” “Where is it? ” “What do I do now? How do I get rid of it? ”

CONCLUSIONS = UPFRONT AND COMPLETE DO’S DON’T 1. Clearly explain where lead was found 1. Don’t just reference other sections of the report 2. Connect the conclusions to other areas of the report. “See XRF shot #55”. 2. Don’t use canned language that doesn’t apply to the specific case 3. Make it readable – narrative is usually best. 3. Don’t assume that the reader understands “industry jargon” i. e. ug/ft 2 4. Include an explanation page on how to interpret XRF results 4. Don’t mix lead hazards with non-lead hazards 5. Keep reports as short and simple as 5. Don’t bury the conclusions in the report. possible yet providing the relevant They should be the front and center information. OSHA requirements, RRP show piece of the report. regulations, etc. are usually not relevant to the report 2012 Lead Workshop Healthy Homes Section 6

COMPLIANCE ASSISTANCE • Available to any certified RA / LI who would like some tips or review of procedures / reports on an informal basis. • Very helpful for new RA / LI who are just getting started • Why wait for an audit to discover issues • Enhances and extends classroom training by providing hands on training/review 2012 Lead Workshop Healthy Homes Section 7

“SURVEY SAYS” Responses are from communities using CDBG funds • 78% contract for RA/LI services • 67% contract for clearances • 11% contract for spec writing • 64% of RA/LI are reviewed by rehab specialist • 7% of RA/LI are reviewed by supervisor or manager • 68% who review RA/LI have received formal training • 79% satisfied or very satisfied with clearance report turn around time • What improvements are needed to RA/LI? – 21% better explanation of conclusions – 21% XRF table needs improving – 24% recommendation section better description of abatement / interim control options needed to assist in spec writing – 28% better description of the location, type and severity of hazards • Do contractors complain about RA/LI reports? – 86% few comments by contractors • 75% satisfied or very satisfied with overall performance of RA/LI

STEVE M. SMITHS@MICHIGAN. GOV (616) 240 -3926 August 2, 2012 Lead Workshop Healthy Homes Section