**Ten Effective Strategies for Preventing Childhood Lead Poisoning
Through Code Enforcement**

**Revised April 25, 2002**

# [Introduction]{.underline}  

Code enforcers can play a critical role in fighting childhood lead
poisoning, due to the strong link between poor housing conditions and
the increased risk of lead exposure. By including lead among the hazards
they address and focusing on effective enforcement of housing code
standards in communities at highest risk, code enforcers can
significantly increase the identification and control of lead hazards
and prevent the needless poisoning of children. 

This report briefly reviews the status of childhood lead poisoning and
makes the case for incorporating lead safety explicitly into code
enforcement. The report then outlines ten strategies for maximizing lead
poisoning prevention through code enforcement (listed below), citing
programs where work to incorporate these strategies is underway. 

**[Strategies:]{.underline} **

**1. Require owners to secure a license for rental property.**

**2. Conduct routine, periodic inspections. **

**3. Enforce chipping and peeling paint violations. **

**4. Include lead-based paint and dust hazards as prosecutable offenses
in housing codes. **

**5. Train and require code enforcers to conduct visual inspections for
potential lead hazards in all pre-1978 housing and, where appropriate,
sample household dust. **

**6. Ban unsafe work practices, and require property owners to conduct
repair work in a lead-safe manner and to undergo post-work clearance
testing to ensure the absence of hazards. **

**7. Develop self-sustaining, effective enforcement programs. **

**8. Target intensive enforcement efforts to high-risk units and
neighborhoods and to recalcitrant landlords. **

**9. Use lead hazard data gathered by code enforcers to prevent lead
poisoning and neighborhood decay. **

**10. Collaborate with agencies working on environmental health and
housing issues.**

##  

## [Current Status of Childhood Lead Poisoning ]{.underline} 

Lead poisoning remains the foremost environmental health threat to
children in the United States, with deteriorating lead-based paint and
lead-contaminated dust in and around housing responsible for most
poisonings. Almost one million American children continue to suffer from
elevated blood lead levels, resulting in reduced IQ, learning
disabilities and behavioral problems.  

Although lead poisoning affects children of all races and socioeconomic
levels, the disease is concentrated primarily in economically distressed
communities, where privately owned, poorly maintained, older housing
poses the greatest risk. Low-income children are eight times more likely
to be lead-poisoned than children from well-to-do families and
African-American children are at five times higher risk than white
children.\[[^1]\] Families who rent are more likely than homeowners to
live in a high-risk housing unit.\[[^2]\]  

An estimated twenty-seven percent of housing units in the U.S. have
significant lead-based paint hazards.\[[^3]\] The vast majority of these
were constructed before 1978, when the use of lead in residential paints
was banned.\[[^4]\] Lead-contaminated household dust is the most common
source of exposure. Lead dust is generated by deteriorating lead-based
paint or created by friction or impact of lead-painted surfaces (e.g.,
doors and windows). Lead dust hazards also may be created during
renovations or repairs if workers fail to employ lead-safe work
practices. Children ingest lead dust through normal activities such as
crawling on the floor and putting hands, toys or other objects in their
mouths.  

## Why Incorporate Lead Hazard Control into Code Enforcement?  

Lead poisoning can be prevented entirely by controlling sources of
exposure, the most common of which is deteriorating lead-based paint in
poorly maintained housing. The link between the level of housing
maintenance and the potential for lead exposure puts code enforcers in a
unique position to prevent needless poisonings.  

Effective enforcement of housing code standards provides a necessary and
important foundation for lead hazard reduction. By compelling compliance
with a broad array of health and safety standards, code enforcers
already reduce the likelihood of lead hazards. For example, addressing
moisture problems and water leaks removes an underlying cause of paint
deterioration.  

However, by failing to focus directly on lead hazards, code enforcers
lose numerous *additional* opportunities to prevent children from being
poisoned. For example, deteriorating paint is a code violation in most
jurisdictions, but may be viewed as an eyesore rather than a potentially
serious health hazard and therefore is inconsistently cited as a
violation. During the course of routine enforcement in older properties,
code officials should focus on deteriorating paint and potential lead
dust hazards, as well as the causes that underlie them. 

Local housing and building departments often view lead poisoning as a
problem to be dealt with by health officials.\[[^5]\] However, housing
departments actually are in a better position than health departments to
*prevent* children from becoming poisoned, because their mandate is to
ensure that housing conditions do not deteriorate to a point where lead
hazards are likely to exist. Housing and building officials also are
optimally positioned to ensure that work that disturbs painted surfaces
is performed in a lead-safe manner. Health departments, on the other
hand, typically become involved in lead-safe housing issues only after a
child has been poisoned, when the opportunity for primary prevention is
lost.  

The benefits of incorporating lead safety into code enforcement are
significant. Advancing primary prevention by identifying, controlling
and avoiding the creation of hazards is critically important.
Incorporating lead safety into code enforcement also can help to
pinpoint individual properties containing lead hazards as well as
identify lead "hot-spots" and neighborhoods with older housing in danger
of decline. Information gathered during the course of code enforcement
should be made publicly available to enable code enforcers and community
groups to focus their efforts on high-risk areas. This information also
can be used to create a registry of lead-safe housing to enable families
with young children to steer clear of lead hazards. 

In addition to protecting children from lead hazards, code officials
will strengthen their enforcement cases and gain greater leverage in
compelling compliance. Code officials also can use the presence of lead
hazards to aid in prioritizing enforcement efforts, requiring immediate
corrective action in situations imminently threatening a child. 

Finally, addressing lead hazards makes good economic sense. In addition
to the harm suffered by children, lead poisoning imposes significant
burdens upon society, including the costs associated with medical
screening and treatment, lead hazard identification and control, special
education and juvenile delinquency. Many of the lead hazard control
measures available to code enforcers are relatively low-cost,
particularly when compared to the potential economic and social benefits
of preventing the disease. For example, basic training in lead hazard
identification is available at low cost, and inspectors can integrate
this training easily into routine inspections. 

## Strategies for Maximizing Lead Poisoning Prevention Through Code Enforcement  

Code enforcers can take advantage of a number of strategies to
incorporate lead safety into their enforcement programs. Some approaches
described below augment the effectiveness of code enforcement generally,
thereby reducing lead hazards by improving housing maintenance (e.g.,
periodic inspection programs). Other approaches deal with lead hazards
more directly and comprehensively (e.g., training inspectors to identify
lead hazards). Ideally, code enforcement ensures compliance with basic
maintenance standards and also explicitly integrates lead hazard control
measures. This section describes strategies for minimizing and
eliminating lead hazards through code enforcement and offers examples of
programs implementing these approaches. 

**    1.  Require owners to secure a license for rental property.**

Concealed ownership can hamper enforcement by code officials as well as
effective action by tenants. Requiring owners to obtain a license by
registering their properties can thwart attempts by owners to shield
themselves from responsibility for lead or other health and safety
hazards. In New Jersey, for example, owners are required to register
buildings containing three or more units. In addition, they must
designate a local agent for receiving service of process and pay a
ten-dollar registration fee. Owners who fail to comply are subject to
fines and are precluded from evicting tenants for any reason, including
nonpayment of rent.\[[^6]\]

The state uses the information it gathers through the registration
program to enforce its housing and construction codes. The registration
program has worked to identify and locate recalcitrant individuals
responsible for significantly deteriorated properties (which often
contain lead hazards). While many rental registration programs have not
proven effective, New Jersey's program illustrates that when coupled
with real enforcement power and meaningful penalties, rental licensing
can work to hold property owners accountable for lead and other hazards
in housing.\[[^7]\]

**2. Conduct routine, periodic inspections.** 

Code enforcement systems triggered solely by tenant complaints, although
widely used throughout the country, are highly ineffective and costly.
Often, this approach contributes to the decline of housing conditions
since tenants may not complain until physical conditions are fairly
severe. Some tenants (such as recent immigrants) are reluctant to report
problems no matter how grave, so many substandard units remain outside
the system entirely. Complaint-based programs also fail to encourage
broad scale preventive maintenance since they are reactive, not
proactive, and ad hoc, not systematic. 

In contrast, systematic, periodic inspection programs ensure that the
entire universe of substandard units complies with basic health and
safety standards. Periodic inspections can prevent lead hazards by
promoting routine preventive maintenance. These programs also can foster
a more cooperative relationship between property owners and code
enforcers than complaint-based systems, which are inherently
adversarial. Of course, periodic inspection programs also must
accommodate complaint-based inspections. 

Proactive programs are rare, but a couple of examples demonstrate their
effectiveness. New Jersey's Hotel and Multiple Dwelling Law requires
inspections every five years of all residential buildings containing
three or more units. The state conducts initial inspections in
approximately 200,000 units per year, and reinspects about 110,000 of
those.\[[^8]\] Ninety-seven percent of the 9000 cases that proceed to
enforcement annually end in compliance.\[[^9]\] Los Angeles adopted a
program in 1998 to require inspections to be conducted at least once
every three years in buildings with two or more units.\[[^10]\] Although
staffing levels, technical problems and re-inspections have inhibited
the city's ability to meet this requirement, additional staff has been
approved and the pace of new inspections has increased. It is estimated
that all of the approximately 800,000 units subject to the program will
be inspected by 2004.\[[^11]\] 

> **3.** **Enforce chipping and peeling paint violations.** 

Deteriorating paint (regardless of its lead content) is a code violation
in most jurisdictions, but usually is viewed as an eyesore rather than a
potentially serious health hazard. Perhaps the single greatest step code
enforcers can take to prevent childhood lead poisoning is to
consistently cite chipping and peeling paint violations. Deteriorating
lead-based paint and associated lead-contaminated dust must be viewed as
potentially serious health hazards and dealt with accordingly. Not only
must paint deterioration be corrected in a lead-safe manner, its
underlying causes (e.g., excessive moisture) must be identified and
addressed to prevent the development of future hazards. 

**    4.  Include lead-based paint and dust hazards as prosecutable
offenses in housing codes.**

In order to provide the clearest legal basis for housing code officials
to address lead hazards, housing codes should state explicitly that
deteriorating lead-based paint, lead-contaminated dust and lead-laden
bare soil are prosecutable offenses. Otherwise, enforcement officials
seeking to address lead hazards will need to establish that they
constitute a nuisance or other catch-all violation contained in the
code. Specifically referencing lead hazards in the housing code also may
increase the attention enforcement officials devote to them and will put
property owners on notice that such hazards are illegal.  

Ideally, housing codes would incorporate the Environmental Protection
Agency (EPA) standards for lead dust on floors and interior window
sills, recently set at 40 µg/square foot and 250 µg/square foot,
respectively.\[[^12]\] Incorporating these standards would provide code
enforcers with a bright-line test for code compliance based upon dust
testing results and would ensure that lead levels in household dust
remain within safe limits. Including numerical standards also would draw
attention to lead-contaminated dust as the primary pathway of exposure.
Lead dust standards would comprise *additional* code requirements;
compliance with them should not constitute a defense to other code
violations. 

Although the EPA standards currently apply only to properties receiving
federal assistance, some jurisdictions are revising their codes to
explicitly include lead-based paint hazards as code violations. For
example, the recently revised Manchester, Connecticut Property
Maintenance Code (PMC), modeled on BOCA's 1996 National PMC, requires
that lead-based paint be free from peeling, chipping and flaking, or be
removed or covered.\[[^13]\]  

Legislation denoting lead hazards as distinct prosecutable offenses
should provide that the remedies associated with those hazards are
cumulative. For example, a lead hazard may violate basic provisions
prohibiting deteriorating paint, in addition to specific provisions
banning lead hazards and establishing dust lead standards. To maximize
compliance and enforcement, penalties for each violation should be
cumulative. 

> **5.  Train and require code enforcers to conduct visual inspections
> for potential lead hazards in all pre-1978 housing and, where
> appropriate, sample household dust.**

Code inspectors should routinely inspect for lead safety by performing a
visual check for deteriorating paint in pre-1978 housing. In addition,
lead dust testing is critical to verify the effectiveness of lead hazard
control measures, to confirm that apparently well-maintained premises do
not in fact contain lead hazards and to complement visual inspections. 

Some jurisdictions are moving to require lead hazard assessment during
the course of routine code enforcement. For example, proposed
legislation in New Jersey would require multi-family housing to be
visually inspected for lead hazards every five years. If the inspector
identifies potential hazards, the owner has the option of performing a
more thorough investigation to determine whether lead-based paint is
actually present or conducting lead hazard control work, which may
consist of abatement or interim controls.\[[^14]\] This forward-thinking
legislation holds great promise for visible lead hazards to be routinely
identified.

While the New Jersey legislation does not require dust testing, other
jurisdictions have taken that step. In Manchester, Connecticut, the
Property Maintenance Code requires code officials to collect dust wipe
samples when inspecting units with deteriorating paint that house a
child under age six. The samples are to be sent to the health
department, which orders abatement if appropriate.\[[^15]\] While these
measures have the potential to significantly increase the detection and
safe repair of lead hazards, adherence to date unfortunately has been
somewhat inconsistent.\[[^16]\]

The Department of Housing and Urban Development (HUD) currently offers a
one-hour, on-line lead-based paint visual assessment training course,
available at
[www.hud.gov/lea/training/visualassessment/h00100.htm](http://www.hud.gov/lea/training/visualassessment/h00100.htm).
This course is designed for experienced housing inspectors and provides
basic information on lead poisoning and how to identify and safely
repair deteriorated paint.  

EPA also has developed a one-day "lead sampling technician" training
course to teach participants how to collect samples for lead in dust. A
list of trained sampling technician training providers who will provide
free training (subsidized by HUD) is available at
[www.leadsafehousing.org/html/sampling_technician.htm](http://www.leadsafehousing.org/html/sampling_technician.htm).
Housing code inspectors should take advantage of these readily
available, free training opportunities to strengthen their knowledge of
lead hazards and their ability to detect them.  

Some jurisdictions are undertaking to train code officials independent
of the HUD-sponsored training. For example, in Manchester, Connecticut,
the city's Lead Abatement Project provides training for code inspectors
in lead poisoning prevention. The training includes basic information on
the causes and effects of lead poisoning; background on applicable
local, state and federal laws; hazard identification; collection of dust
wipe samples; and lead-safe work practices.\[[^17]\] Statewide,
Connecticut has subsidized lead inspection training for approximately
400 health and housing code enforcers. The state also has cut costs and
reduced administrative hurdles by lifting certification requirements for
trained, state employed code enforcers performing inspections in their
official capacity.\[[^18]\] 

> **6.  Ban unsafe work practices, and require property owners to
> conduct repair work in a lead-safe manner and to undergo post-work
> clearance testing to ensure the absence of hazards.**

Once code violations are identified, it is critical that repair work be
done in a safe manner to avoid creating additional hazards. Unless
testing proves that painted surfaces are not lead-based, lead-safe work
practices should be required as a matter of course in pre-1978 housing.
Property owners should be required to have their units independently
tested following repair work ordered by a health or code enforcement
agency to ensure that repairs do not leave lead dust hazards
behind.\[[^19]\] These measures become increasingly important as the age
of the housing increases, because the paint in older housing is likely
to contain higher concentrations of lead and the odds of the unit
containing lead-based paint increase with age.\[[^20]\] 

The City of New Orleans' recently enacted Lead Paint Poisoning
Prevention and Control Act follows this model. The act bans unsafe paint
removal practices during work on the interior or exterior of pre-1978
buildings or on steel structures. Paint on those structures is presumed
to contain lead unless tests establish otherwise. The act mandates the
use of containment barriers for exterior work and requires property
owners or their contractors to notify tenants, neighbors and the city
before work begins. The Department of Health is authorized (but not
required) to conduct dust sampling, and can issue notices of violation
and stop work orders, or in lieu of penalties, can require first-time
violators to complete training in lead-safe work practices.\[[^21]\]  

HUD's lead-safe housing regulation also prohibits unsafe methods of
paint removal in federally-assisted housing, including dry sanding or
scraping, open flame burning, operating a heat gun above 1100 degrees,
machine sanding without a HEPA attachment, and stripping in poorly
ventilated areas using hazardous volatile strippers.\[[^22]\] The HUD
regulation requires persons undertaking maintenance and lead hazard
control measures to follow lead-safe work practices, and mandates
clearance testing (visual assessment followed by dust testing) after
virtually all work that repairs or disturbs painted surfaces in pre-1978
federally assisted housing.\[[^23]\]  

EPA has been contemplating regulations that would cover renovation and
remodeling for many years. To this end, the agency has developed a model
training course that focuses on containing, minimizing and cleaning up
lead hazards during renovation and remodeling. The training course is
available at <http://www.epa.gov/lead/rrmodel.htm>. HUD has adapted
EPA's model renovation and remodeling course to facilitate compliance
with its lead-safe housing regulation. The student manual for the
HUD-adapted course is available at
[www.hud.gov/offices/lead](http://www.hud.gov/offices/lead).  

New Bern, North Carolina recently enacted an ordinance that imposes
permitting requirements to ensure adherence to lead-safe work practices
during repairs that will disturb painted surfaces. The city's permitting
authority refers applicants to the health department, which oversees the
lead safety requirements and recommends to the city whether a permit
should be granted. Workers must be trained in lead-safe work practices
and the unit must pass a clearance test that includes a visual
assessment as well as dust sampling. The health department's
environmental health section has trained numerous contractors in
lead-safe work practices, and provides clearance testing.\[[^24]\]  

In Massachusetts, property owners must hire licensed contractors to
perform mandated lead hazard control work, unless they choose to
undertake the work themselves. Property owners are authorized to perform
low- and moderate-risk lead hazard control activities, which include
encapsulation as well as removal and replacement of windows and
woodwork, but only after completing a training course in lead-safe work
practices and passing an exam.\[[^25]\] During the first year this
option was made available, about 2000 owners completed the
training.\[[^26]\] Work performed by owners must be checked by a
licensed inspector to ensure that no hazards have been left
behind.\[[^27]\]  

In Battle Creek, Michigan, a proposed code provision requires lead
clearance exams after painted surfaces are disturbed during the course
of paid renovations in pre-1978 housing.\[[^28]\]  

Manchester, Connecticut's Property Maintenance Code requires inspectors
to attach lead hazard warnings to repair orders.\[[^29]\] This low-cost,
easy-to-implement measure has the potential to prevent needless
poisonings brought about by unsafe work practices. 

Enforcement officials also could provide information to help property
owners locate workers trained in lead safety. A HUD-sponsored listing of
lead-trained renovators, as well as certified abatement contractors is
available at [www.leadlisting.org](http://www.leadlisting.org/). In
addition, building departments should make lead safety information
available to property owners and contractors seeking remodeling permits.
In Sacramento County, California, for example, HUD pamphlets are on
display in the building permit department alerting remodelers to employ
lead-safe work practices.\[[^30]\] ** **

7.  **Develop self-sustaining, effective enforcement programs.**

Poorly designed enforcement systems can waste agency resources and limit
the impact of enforcement initiatives. For example, an audit of New York
City's code enforcement system found that inspectors repeatedly
documented violations, but failed to improve housing conditions because
they lacked adequate means to pressure landlords to undertake
repairs.\[[^31]\]

In contrast, in New Jersey, the state succeeds in securing compliance
with housing code requirements under its Hotel and Multiple Dwelling Law
in 8800 out of 9000 annual enforcement cases.\[[^32]\] Much of the
success in New Jersey is attributable to the law's efficient enforcement
provisions under which the state rarely needs to appear in court. Owners
who fail to appeal violation notices are presumed by law to be in
violation. The state reinspects noncomplying units 60 days after the
initial inspection, and again 30 days later if warranted. After the
second reinspection, the state can and has imposed penalties up to
\$5000 per day. The state can request the Superior Court to enter
judgment on outstanding penalties and execute on the judgment, usually
by imposing a lien on the rental receipts. If necessary, the state can
work to identify assets and pierce the corporate veil, if one exists,
using information obtained through the licensing and registration
process (see strategy number 1, above) and court-sanctioned
discovery.\[[^33]\] Streamlined enforcement provisions coupled with
significant penalties have enabled the state to attain compliance from
all but a small fraction of property owners.  

In many cases, lack of sufficient funding lies at the heart of
ineffective code enforcement programs. Programs that generate revenues
sufficient to cover their costs can avoid the vagaries of legislative
appropriations and minimize cuts in staff or resources that impede
enforcement efforts. New Jersey imposes a thirty-three dollar per unit
inspection fee every five years upon owners, and collects \$3 million
annually in penalties, enough to sustain its program.\[[^34]\] In Los
Angeles, a recently enacted housing ordinance imposes a \$12 annual fee
upon owners of rental properties with two or more units to cover the
cost of the city's systematic code inspection program.\[[^35]\]
Low-income tenants strongly supported passage of the ordinance,
including the monthly fee, which under the law can be passed on to
tenants. The fee is expected to generate \$7-8 million per
year.\[[^36]\]  

> **8. Target intensive enforcement efforts to high-risk units and
> neighborhoods and to recalcitrant landlords.** 

The ubiquitous presence of lead-based paint in the country's housing
requires that neighborhoods and properties most likely to poison
children receive priority attention. Older, poorly maintained distressed
and marginal housing pose the greatest risk for lead hazards. While
those units housing a young child present the most immediate threat of
lead poisoning, units not currently housing a child cannot be ignored. A
property with lead hazards that is not occupied by a family may poison a
future occupant's child.  

Some jurisdictions have employed targeting to aid in addressing problem
housing. In Manchester, Connecticut, code inspectors conduct cyclical
inspections in areas of the town determined to be most in need of
investment based on factors such as resident income levels, housing
condition and housing age. Inspectors initially examine exterior
conditions in these target areas and, if problems are detected, they
expand their efforts to building interiors. They also routinely inspect
building exteriors in neighborhoods in which they are working in
response to a complaint.\[[^37]\] 

Milwaukee, Wisconsin adopted a three-year pilot project that targets 800
units in two economically distressed areas of the City with
exceptionally high childhood lead poisoning rates. Three-quarters of the
housing units in each area are rental properties (determined to be more
susceptible to inadequate maintenance and deteriorating painted
surfaces), and more than 99% of the homes were built prior to 1950 and
therefore are highly likely to contain lead-based paint.\[[^38]\] Based
on extensive environmental sampling and research, the Milwaukee Health
Department conclusively documented lead-based paint on old windows as
their most significant hazard.\[[^39]\] 

During the first year of the program, owners of rental properties built
before 1950 must obtain a lead-based paint hazard control certificate
evidencing their property's compliance with the city's lead-safe housing
requirements, which include abatement for lead-painted windows. During
the second and third years of the program, owners must employ essential
maintenance practices in order to be re-certified as lead-safe. The
program makes funding available to owners to help offset the cost of the
lead hazard control work.\[[^40]\] 

One very effective targeting strategy is to undertake building-wide code
enforcement in multi-family buildings where one unit is found to contain
lead hazards or to house a poisoned child. This approach benefits all
building occupants as well as visiting children and future occupants of
the property. 

> **9. Use lead hazard data gathered by code enforcers to prevent lead
> poisoning and neighborhood decay.** 

Information gathered during the course of code enforcement itself can be
a valuable tool in improving housing conditions and preventing childhood
lead poisoning. For example, multiple code violations may indicate the
presence of lead hazards in individual properties, and may point to lead
"hot-spots" and neighborhoods in danger of decline if present on a broad
scale. Information gathered during code enforcement should be made
publicly available to enable code enforcers and community groups to
focus their efforts on high-risk areas and to track safe units.  

*a. Create a registry of lead-safe housing.* 

As enforcement officials determine units to be free of lead hazards, the
locations of these units should be compiled in a registry of lead-safe
housing. A registry can ease the identification of lead-safe housing by
the public and gauge progress on the part of governments in making
housing lead-safe. In creating a lead-safe housing registry, care must
be taken to ensure that the information does not become outdated and
misleading. If the registry includes units at which interim controls are
in place, users should be informed that a visual inspection, dust
testing and ongoing maintenance are necessary to ensure those units'
continuing safety.

Proposed legislation in New Jersey would require the state's Department
of Community Affairs to create a registry of lead-safe housing, which
will categorize housing as either lead-free (housing constructed after
1978 or housing containing no lead-based paint); lead-abated; or lead
hazard controlled (housing in which preventive maintenance practices and
interim controls are in place). If feasible, the information will be
made available on the internet.\[[^41]\]  

In Manchester, Connecticut, the Lead Abatement Project (LAP) (housed
within the town's Health Department), has created a registry of
lead-safe units and their owners. The registry includes
LAP-rehabilitated units in which lead hazards have been controlled and
conditions brought up to code.\[[^42]\] 

> *b.*   *Create constituencies of support for code enforcement programs
> by making housing information accessible to community groups. *

Community groups working to improve housing conditions can increase
their effectiveness significantly if they have ready access to current
information on housing characteristics and conditions. In Los Angeles,
for example, UCLA's Advanced Policy Institute has created Neighborhood
Knowledge Los Angeles, a freely accessible web site dedicated to
preventing housing and neighborhood deterioration by tracking multiple
data points for properties throughout the city.  

The web site compiles a wide breadth of information gathered from a
number of city agencies that indicates properties in danger of decline.
Code complaints, building permits, contract nuisance abatements
(city-sponsored repairs to address public safety hazards), tax
delinquencies and utility liens are noted for each property in the
database. Housing inspectors in the field enter information into
hand-held computers, enabling community groups to track code complaints,
inspections and improvements using "real time" information.  

The site may be searched by zip code, census tract, council district,
address, or by specific criteria (e.g., properties with pending code
complaint cases). Any of the site's datasets may be viewed area-wide on
easy-to-read maps, allowing users to spot clusters of tax delinquencies,
code complaints, or other problems indicating pockets of potential
neighborhood decay.  

A wide range of users find the NKLA web site useful. Community groups
use the site to identify property owners in trouble and provide
proactive counseling services while their advice still may be effective.
Local non-profit developers locate properties headed toward abandonment
and acquire them before they deteriorate. Residents can determine
whether their landlords are complying with their obligations, and learn
about conditions in their neighborhoods. And city employees frequently
use the site to easily access data generated by other agencies, which
was not previously available to them.\[[^43]\] Code enforcement
personnel could use the information to target problem neighborhoods,
problem owners and neighborhoods in decline.  

> **10. Collaborate with agencies working on environmental health and
> housing issues.  **

Environmental, health and housing agencies can significantly advance the
fight against childhood lead poisoning by coordinating their efforts
with code enforcement programs. In Sacramento, California, the
Environmental Management Department (EMD) reached out to building and
housing code officials in an effort to encourage them to incorporate
lead safety into their programs. EMD conducted workshops for building
and housing code officials that provided basic information on childhood
lead poisoning and included a brainstorming session to generate ideas
for incorporating lead safety into code officials' existing scope of
work. As a result of the workshops, field inspectors provide written and
verbal information to occupants regarding potential lead hazards, and
permitting officials offer information regarding lead-safe renovations.
In addition, the Sacramento County Code Enforcement Unit, working with
the EMD, has included building and soil-related lead hazards among other
violations in recent repair orders issued to owners.\[[^44]\]  

Health and housing agencies also should share information on a
continuing, systematic basis. For example, health departments should
direct housing code authorities to properties and neighborhoods with
high incidences of lead poisoning. Conversely, when housing code
inspectors discover potential lead hazards they should notify health
authorities to test the blood lead levels of children potentially at
risk.  

[^1]: \[?\] U.S. Centers for Disease Control and Prevention, "Update:
    Blood Lead Levels -- U.S., 1991-1994," 46 [MMWR Morbidity &
    Mortality Weekly Report]{.underline} (1997) at 141-146.

[^2]: \[?\] U.S. Department of Housing and Urban Development, National
    Survey of Lead and Allergens in Housing, Final Report, Volume I:
    Analysis of Lead Hazards, Revision 6.0 (April 18, 2001),
    [www.hud.gov/lea/HUD_NSLAH_Vol1.pdf](http://www.hud.gov/lea/HUD_NSLAH_Vol1.pdf)
    at Table 3.1.

[^3]: \[?\] *Id.* at 3-2. These hazards include deteriorated lead-based
    paint, contaminated household dust and contaminated bare soil. *Id.*
    at 3-1 -- 3-2.

[^4]: \[?\] *Id.* at Table 3.1. 

[^5]: \[?\] Western Center on Law and Poverty, "Preventing Childhood
    Lead Poisoning: Identifying and Eliminating Local Barriers to
    Primary Prevention Strategies," (November 2001) at 8-9.

[^6]: \[?\] New Jersey Hotel and Multiple Dwelling Law, N.J.S.A.
    55:13A-12; presentation by William Connolly, Director, New Jersey
    Division of Codes and Standards at Expert Forum, *Maintaining
    Healthy Homes: Challenges and Strategies for Distressed and Marginal
    Communities,* Camden, New Jersey, December 7, 2000 ("Connolly,
    December 7, 2000"). For more information on New Jersey's program,
    see Alliance To End Childhood Lead Poisoning, "Holding Property
    Owners Accountable: New Jersey Multiple Dwelling Registration and
    Inspection Program," [Innovative Strategies for Addressing Lead
    Hazards in Distressed and Marginal Housing: A Collection of Best
    Practices]{.underline} "[AECLP Best Practices]{.underline}."

[^7]: \[?\] *Id.*

[^8]: \[?\] Connolly, December 7, 2000.

[^9]: \[?\] *Id.*

[^10]: \[?\] Los Angeles Housing Code, § 161.351.

[^11]: \[?\] Gary Bess Associates, Systematic Code Enforcement Program
    Evaluation, November 13, 2001 at 5-14; phone conversation with Tai
    Glenn, Senior Attorney, Housing Improvement Project, Legal Aid
    Foundation of Los Angeles, March 25, 2002.

[^12]: \[?\] 40 CFR § 745.65(b).

[^13]: \[?\] Manchester, Connecticut Property Maintenance Code, §
    7-305.4.

[^14]: \[?\] Assembly Substitute for Assembly No. 2399 \[2R\], sponsored
    by Assemblymen Collins and Kelly.

[^15]: \[?\] Town of Manchester Property Maintenance Code, § 7-305.4.2.

[^16]: \[?\] Heller, August 2, 2001.

[^17]: \[?\] Phone conversation with Sue Heller, Manchester Lead
    Abatement Project Administrator, August 2, 2001; *Basic Lead Hazard
    Evaluation & Control Training for Code Officials*, manual produced
    by Safe Homes Inc. for Manchester Lead Abatement Project.

[^18]: \[?\] Phone conversation with Al Bizetti, Connecticut Department
    of Public Health; Conn. Gen. Stat. § 20-479.

[^19]: \[?\] The federal Occupational Safety and Health Administration
    (OSHA) and state worker safety agencies administer standards to
    protect employees from lead exposure. However, local housing and
    health officials rarely make use of these requirements.

[^20]: \[?\] U.S. Department of Housing and Urban Development, National
    Survey of Lead and Allergens in Housing, Final Report, Volume I:
    Analysis of Lead Hazards, Revision 6.0 (April 18, 2001),
    [www.hud.gov/lea/HUD_NSLAH_Vol1.pdf](http://www.hud.gov/lea/HUD_NSLAH_Vol1.pdf)
    at Table 4.1, 4.6.

[^21]: \[?\] Code of the City of New Orleans, §§ 82-311 *et seq*. San
    Francisco also requires lead-safe work practices during exterior
    work on pre-1979 buildings.

[^22]: \[?\] 24 CFR § 35.140.

[^23]: \[?\] 24 CFR §§ 35.1330, 35.1335, 35.1340.

[^24]: \[?\] Phone conversation with Deborah Yarbrough, Craven County
    Health Department, August 8, 2001.

[^25]: \[?\] Massachusetts Department of Health web page,
    [www.state.ma.us/dph/clppp](http://www.state.ma.us/dph/clppp).

[^26]: \[?\] Phone conversation with Paul Hunter, Director,
    Massachusetts Childhood Lead Poisoning Prevention Program, July 18,
    2001.

[^27]: \[?\] Mass. Gen. L. ch. 111, § 197(d).

[^28]: \[?\] Battle Creek proposed Building and Housing Code, § 1460.235

[^29]: \[?\] Manchester Property Maintenance Code, § 7-305.4.

[^30]: \[?\] Phone conversation with Carol Good, Sacramento County
    Department of Environmental Management, August 22, 2001.

[^31]: \[?\] *City Limits*, "Burned Out," December 2000 at 14.

[^32]: \[?\] Connolly, December 7, 2000.

[^33]: \[?\] *Id.*

[^34]: \[?\] *Id.* The per-unit inspection fee decreases as the number
    of units increases.

[^35]: \[?\] Los Angeles Housing Code, § 161.352.

[^36]: \[?\] Phone conversation with Rod Field, Los Angeles Housing Law
    Project, December 10, 1998.

[^37]: \[?\] Heller, August 2, 2001.

[^38]: \[?\] The concentrations of lead in paint were highest before
    1950, however, lead was not banned from residential paints until
    1978.

[^39]: \[?\] "Targeting High-Risk Neighborhoods: The Milwaukee,
    Wisconsin Pilot Project for Lead-Based Paint Hazard Control," [AECLP
    Best Practices]{.underline}.

[^40]: \[?\] *Id.*

[^41]: \[?\] Assembly Substitute for Assembly No. 2399 \[2R\], sponsored
    by Assemblymen Collins and Kelly.

[^42]: \[?\] Manchester Connecticut health Department Lead Abatement
    Project, *Final Report -- Round 5, February 1, 1998 -- January 31,
    2001*, at 24.

[^43]: \[?\] "Early Warning Systems for Deteriorating Properties:
    Neighborhood Knowledge Los Angeles," [AECLP Best
    Practices]{.underline}; see also
    [http://nkla.ucla.edu](http://nkla.ucla.edu/).

[^44]: \[?\] Good, August 22, 2001 phone conversation and November 26,
    2001 email correspondence; Special Lead Project Period 3 Report.
    Lead hazards are not specifically included as prosecutable offenses
    in the housing code, so citing lead hazards as nuisance violations
    represents a significant step forward.