Does CDBG require a lead safe clearance test for homeowner rehab programs under $5,000? Our understanding is that clearance is not required if the disturbance of the paint surface is de minimis.
Date Published: May 2015
For housing rehabilitation work costing under $5,000 per unit, the "do no harm" approach is used. You are correct that clearance is not required when painted surface areas are below HUD's de minimis threshold (only).Note that when clearance is required, HUD's Lead Safe Housing Rule (LSHR) requires a clearance examination be done by an independent party instead of the certified renovator's cleaning verification procedure. HUD's LSHR regulations are found at 24 CFR Part 35. Subpart J addresses housing rehabilitation.