LEAD PROGRAM MANUAL EHS LEAD-BASED PAINT PROGRAM MANAGEMENT RESPONSIBILITIES TABLE OF CONTENTS NYU EHS LEAD MANAGEMENT MANUAL

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1 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 Lead Program Procedures for Leasing Manager (CSR) Lead Program Procedures for Property Manager (CSR) Documentation Requirements for Leasing Managers 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 K. Use and Selection of Personal Protective Equipment Policy No

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 leadrelated 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 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. ii. Obtain an inspection schedule from Cooper Square. Ensure that all common areas are scheduled for inspection, as well as individual apartments. NOTE even if apartment was previously inspected, a new inspection must be done annually by a certified inspector. iii. Reports Obtain a file code from EHS Director for the annual inspections and keep hard copies on file. Make sure there are separate reports for each apartment, and a separate report for all common areas of the building. Reports must be signed by a certified lead inspector, and a copy of the license included in the report. Common area reports must be provided to all tenants with 2

3 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. iii. Advise Cooper Square Property Manager to conduct contractor walkthroughs with lead consultant and get bids from qualified lead contractors. 3

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 3 rd 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. xi. A minimum of three wipe tests must be collected from each room where work was done (floor, window sill & window well), and one from the floor of areas immediately adjacent to the work area. 4

5 RESIDENTIAL BUILDINGS xii. Get copies of lead clearance results from consultant and compare with criteria: Floors 40 g/sq.ft. Window sills 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; RESIDENTIAL BUILDINGS 5

6 7. Results of lead-contaminated dust clearance tests from 3 rd 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. RESIDENTIAL BUILDINGS 6

7 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. ACADEMIC BUILDINGS 7

8 Introduction Lead based paint (LBP) abatement is not required by regulations for non-residential buildings. The OSHA Lead in Construction standard (29 CFR ) 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 leadrelated 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 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. ACADEMIC BUILDINGS 8

9 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 Final report, including close-out information: 9

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 3 rd 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 4. Waste Disposal 10

11 a. All waste generated from LBP abatement is RCRA hazardous waste and will be disposed of in accordance with Safety Policy 109. STANDARD OPERATING PROCEDURE FOR LEAD ABATEMENT PROJECT PROCESS FOR THE OFFICE OF CONSTRUCTION MANAGEMENT 11

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. To ensure regulatory compliance and timely processing of project abatement, EH&S must be kept informed along all steps of the procedures listed below (but not limited to): 12

13 EH&S Director Receives all notification LEAD PROGRAM of construction MANUAL 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 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 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 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 , 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 Waste in disposed as 1) If Academic Building hazardous waste (EHS will provide drums, OCM to provide disposal costs); 2) if Residential mixed lead with construction debris can be disposed as C&D waste to a double-lined landfill; 3) if Residential and total lead waste 13 would fail TCLP waste will be disposed of as Hazardous Waste (see #1)

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16 OCM Project Manager LEAD PROGRAM MANUAL Will send an Asbestos/Lead Survey/Abatement Request Form (Form A), as soon as the project is official to the EH&S Director. Will PROGRAM provide one set MANAGEMENT of drawings and RESPONSIBILITIES 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 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 , 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 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 REMOVAL HAZARD DO NOT ENTER UNLESS AUTHORIZED 16

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18 Complete Complete ABATEMENT CONTRACTOR Contractor must be EPA Certified Lead Safe Work Practices LEAD PROGRAM MANUAL Will be notified of abatement bid walk-through by OCM PM via consultant. Will PROGRAM be given Scope MANAGEMENT of Work at walkthrough RESPONSIBILITIES 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 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. 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. 1. 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. 18

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21 Complete Complete CONSULTANT Will be contacted by OCM PM of possible lead project and name of EH&S PM assigned LEAD PROGRAM MANUAL to project. Will notify EH&S EHS of proposed LEAD-BASED OCM project PAINT (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. 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. 1. Take three dust wipe samples form each room or area where abatement work was done. 21

22 FILING & POSTING INFORMATION: Regulatory Agency Size of Project Filing Requirement NYC DOHMH Work Disturbing 100 SF or more or Removal of 2 or more Windows DOHMH Notice of Commencement of Work EPA Same as Above EPA Notification of Lead-Based Paint Abatement Activities NYU (contractor) NYU (contractor) Work Disturbing 100 SF or more or Removal of 2 or more Windows DOHMH Notice of Commencement of Work Warning: Lead Work Area POISON- No Smoking or Eating No Approval Needed 10 Calendar Days prior to start of work Fax or hand deliver 1 4 days prior to start of work Post in Work Area hours before work begins. Start of Work EH&S CONTACT LIST NAME PHONE Stephanie Kung Stephanie.kung@nyu.edu Melisa Puglisi Melisa.puglisi@nyu.edu Celeste Rufer Celeste.rufer@nyu.edu 22

23 Neha Prasad Zack Korenstein Joe Stern Lou Ortiz FORM A ASBESTOS/LEAD SURVEY/ABATEMENT REQUEST FORM TITLE OF PROJECT 1. PROJECT INFO: Date: FCM PROJECT MANAGER CONSULTANT : CONTACT & PHONE: ARCHITECT/ENG. FIRM: CONTACT & PHONE GENERAL CONTACTOR: CONTACT & PHONE ADDRESS AKA 2. LOCATION OF PROJECT INFO: BLOCK # LOT # APPROXIMATE AGE OF BUILDING (YEARS) HOW MANY FLOORS 3. SCOPE OF WORK (attach additional sheets as necessary) should include Job Description 23

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: 1. Please provide project title, contact name and numbers for: Project Manager, Consultant, Architectural/Engineering Firm, and General Contractor. 24

25 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 leadbased 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. v. NYU Leased Apartments Faulty Housing is in contact with the Building Owner to obtain lead-based paint information (inspection reports, confirmation of tenant notification information, etc.) and ensure that all lead-based paint reports are provided to the tenant at lease signing/renewal. Currently Peter Cooper Village/Stuyvesant Town and Waterside provide all the required disclosure directly to the affiliate tenant when they go to pick up their keys. Copies have 25

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. v. NYU Leased Apartments Faulty Housing is in contact with the Building Owner to obtain lead-based paint information (inspection reports, confirmation of tenant notification information, etc.) and ensure that all lead-based paint reports are provided to the tenant at lease signing/renewal. Currently Peter Cooper Village/Stuyvesant Town and Waterside provide all the required disclosure directly to the affiliate tenant when they go to pick up their keys. Copies have 26

27 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. d. Inspection Reports - The licensed inspector must provide all inspection reports to EHS and Cooper Square. Cooper Square must provide a copy of the report to the tenants. The Property Manager shall provide the tenants with copies of the most recent apartment-specific report, and a copy of the Common Area report. All tenants with children under 6 should receive copies of the most recent Common Area Inspection for their building. Cooper Square must provide a copy of the reports to the leasing manager, for inclusion in her files for EPA notification compliance (See Item 1 above). EHS will review the reports and, in consultation with the certified inspector, determine if lead abatement work is necessary. 27

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 leadbased 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 a. Turnovers w/no lead abatement required: for all apartments where LBP inspector/risk assessor has determined that there are no LBP hazards, and OCM in conjunction with the lead assessor has determined that no renovation work is required that may potentially impact lead, Cooper Square shall contract with a painting contractor to use LBP trained 28

29 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. Scheduling of the work must be done with Cooper Square. Cooper Square must assist in gaining access for contractors to review the scope to prepare bids. Contractors, inspectors and EHS must determine the length of time required to abate 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. Any pre-abatement notification shall be handled through Cooper Square Realty. Tenants are not allowed 29

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 providing copies of the reports to the tenant. Any reports generated from these activities must be provided to the leasing manager for inclusion in the notification files. The lead inspector should provide a copy of the report to EHS. 30

31 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. 2. Annual Inquiry Between January 1 and January 15 of every year, forms must be provided to all tenants inquiring if they have a child under 6 residing in unit. If tenants 31

32 do not respond by February 15, contact Property Manager to ensure that apartments are checked for child occupancy before March 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. YOU MUST COMPLY WITH ALL OF THESE REQUIREMENTS. 32

33 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 Annual Inspections Contact approved lead inspector to conduct lead inspections for all apartments with children under 6 and all common areas, and make 33