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Cleveland's Lead Safe Rental Law Step 4: Final Cleanup

Once all lead hazards have been identified and remediated (see previous posts), the last step before your Clearance Examination is to conduct a final cleanup of the rental unit. This isn’t just your average cleaning. It must be done thoroughly and with the proper equipment. The Clearance Examination involves the collection of dust samples. The lead concentration of these samples is measured in micrograms. If the final cleanup is not done properly, minute amounts of lead dust—not visible to the naked eye—can result in a failed Clearance Examination and spending hundreds of dollars to reclean and retake the exam.

The full description of this cleaning process can be found in Chapter 14 Section V of the HUD Guidelines for the Evaluation and Control of Lead Based Paint in Housing. If you want to pass your Clearance, read it thoroughly. I’m just going over the basic principles in this post.

The cleaning process, sometimes called a “HUD Cycle Clean” involves three basic steps:

1. Use a HEPA vacuum to clean all visible dust, paint chips, and any debris.

2. Wet wash (using a detergent) all surfaces, making sure to get into every corner or grooves in the surface.

3. Use a HEPA vacuum again on these surfaces to remove any unseen dust or paint chips.

There are some variations to this depending on the type of surface and how much dust was present to begin with. There’s a couple of good charts explaining this in the section of the HUD Guidelines noted above.

Some important things to keep in mind:

· In a prior post I talked about the process of repainting called “Paint Film Stabilization”. One of the steps is to make the surface smooth and cleanable. A rough surface with a lot of grooves can be much harder to clean, so it’s important not to ignore this step when repainting the property. If a surface is not smooth, take extra time to clean any grooves or pits in the surface that may trap leaded dust.

· Use a HEPA vacuum. If you don’t, you’ll fail the clearance. Again, lead is measured in micrograms. Only a vacuum with a HEPA filter can capture the lead particles. If you use a regular vacuum, lead can get through and blow back into the air and settle on surfaces where it will be picked up during Clearance dust sampling.

· Schedule your Clearance Examination within a day or two of final cleanup, especially if the unit is occupied. You don’t want to run the risk of a tenant tracking lead in from work or a friend’s house. If the unit’s vacant, try to keep workers out between final cleanup and Clearance, and require anyone who enters to wear shoe covers.

I can’t stress the importance of doing this final cleanup correctly. Even if you identify all the hazards and correctly remediate them, failure to complete this step will cost you hundreds. If you don’t own a HEPA vacuum and don’t wish to buy or rent one, or if you don’t have the time to do as thorough a job as necessary, any lead abatement firm and some RRP contractors offer this cleanup as a service. They typically charge by the room. It’s well worth it to make sure you’re ready to pass the Clearance Examination, which I’ll discuss in my next post.


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