Eliminating Childhood Lead Poisoning in New York State by 2010
V. Proposed Strategies for New York State
Focus Area Three: Primary Prevention
The third component of the strategic plan will generate new emphasis on primary prevention. These efforts will focus on protecting children from exposure to lead through a variety of methods that involve the work of government agencies, community leaders and community members. All opportunities for primary prevention for lead poisoning must be explored.
Goal 1: Environmental lead hazards are identified before children are exposed.
Objective 1: To incorporate lead hazard identification into all DOH programs with a home visitation component.
- New York State Department of Health (DOH), in cooperation with local health departments, will identify all programs that include visits to the home. These may include the DOH Healthy Neighborhoods Program (HNP), Community Health Worker Program, local health department home visiting nurses, and the Healthy Families New York (HFNY) home visiting program sponsored by the NYS Office of Children and Family Services (OCFS) in collaboration with NYSDOH. DOH staff will work with these programs to identify opportunities for their home visitors to provide educational information regarding lead, lead hazards, and screening for lead during these visits. Initially these efforts will focus on the areas in NYS at highest risk.
- Staff performing home visits in appropriate programs will receive basic training on lead poisoning and visual lead hazard identification. Where feasible, staff will complete the HUD visual assessment on-line training program to increase knowledge and basic skills for identifying and categorizing potential lead hazards.
- Where feasible, home visitation programs should incorporate a basic visual assessment of the conditions of the dwelling in home visits. Chipping or peeling paint, excessive dust, structural problems, or other visible potential lead hazards will be identified and categorized according to the HUD training program. Where feasible, home visiting staff should provide educational materials to residents, and make referrals for appropriate follow-up as needed.
- NYSDOH will work with local communities to develop referral mechanisms to facilitate timely and coordinated communication, education, and more intensive follow-up as needed related to potential lead hazards identified. Referral mechanisms will be developed and implemented through a collaborative effort of home visiting staff, local health department childhood lead poisoning prevention programs, and local code enforcement. Mechanisms may be based on the current Healthy Neighborhoods Program, and may incorporate those programs where they exist.
Objective 2: To expand the Healthy Neighborhood Program to additional high-risk target areas
- With funds from the state's Maternal Child Health Block Grant (MCHBG), funding to the DOH Healthy Neighborhood Program (HNP) will be increased to add programs in high-risk communities that are not currently served by HNP.
- An evaluation of the HNP will be conducted to assess the number of dwellings that have been impacted by the program. Also assessed will be the number of homes where lead hazards are identified, as well as those who have been corrected during a follow up visit. Approximately 25% of all homes with lead hazards identified during the initial home visit will receive a follow up visit six months later to determine what efforts to control or eliminate the lead hazards were taken. In addition, the number of children who receive lead screening based on a HNP intervention will be assessed.
- The program will work to identify other environmental lead sources that may impact target populations (such as playgrounds, urban dust, and bridges), and coordinate appropriate state and local agencies to address lead hazards that are identified.
Objective 3: To develop a lead hazard identification component for visual environmental inspection programs within other state agencies.
- DOH will meet with representatives of agencies represented on the Lead Poisoning Prevention Advisory Council to identify areas of training for other agency staff to visually assess potential lead based paint hazards. Currently, several of these agencies also have staff performing site visits to homes and other settings where children spend significant time, such as child care and foster care. The possibility of developing a program similar to that used by DOH (described above under Objective 1) will be explored. This integration of lead safety into other agencies programs would help broaden the impact of the primary prevention program.
- DOH will work with representatives from other state agencies to form a workgroup to identify current state housing regulations that could be enforced to assure that housing is maintained in a lead-safe condition
- DOH will work with other state agencies to establish a continuing education program. This program will provide continuing education to staff from programs that perform home visits, such as Code Enforcement Officials, Fire Investigators, Office of Children and Family Services child welfare investigators and Healthy Families New York home visiting program, as well as community based agencies that also perform home visitation. Currently, the HNP has a referral mechanism with these local agencies. This referral mechanism can be expanded to include other home visitation programs.
- The DOH will work with other agencies to identify programs that currently exist, for example the Small Business Consulting Services, Welfare to Work programs, and specific trades training from the Department of Labor where an educational component regarding lead could be included.
- DOH will include the regulations from all the agencies relating to housing on the DOH web site. In addition, information for individuals, contractors and local regulators will be included pertaining to how to comply with these regulations utilizing lead safe work practices.
- The Interagency workgroup will focus on methods to increase enforcement of existing regulations, and to increase public education regarding the existence of these requirements. This increased enforcement will be emphasized on the DOH website for those who would be impacted for education and compliance assistance.
- The Interagency workgroup will assess and strengthen mechanisms to ensure communication between agencies and programs when lead hazards are identified (for example, to notify child care licensing agency when a lead hazard is identified in a child care setting).
Objective 4: Disseminate updates on potential lead hazards to support prevention efforts
- Disseminate information from Consumer Product Safety Commission (CPSC), Food and Drug Administration (FDA), and other states and agencies regarding unusual sources of lead hazards, to support comprehensive environmental investigations by local health department/district office environmental staff.
Goal 2: Enhance community knowledge regarding the identification and selection of lead hazard control methods that are safe, effective, and feasible.
Objective: DOH will support and provide educational programs that address the relatively simple, low-cost tools and measures that can contribute significantly to lead based paint safety.
- Utilizing HUD's lead-safety rule for federally assisted housing as a model, require that local CLPP staff perform outreach and education to the community regarding these practices. The outreach would include educational pamphlets, information on educational programs, and in home education from the HNP staff, Lead Resource Centers and Childhood Lead Poisoning Prevention staff. Utilizing the "work safe, work clean, work smart" principle, educate people to understand lead based paint, the hazards of lead based paint and methods of lead-safe work practices to bring housing to a lead-safe status.
- DOH, in cooperation with the local health departments, will participate and sponsor training sessions regarding lead, lead based paint hazards and lead-safe work practices. In addition, work with the local building, hardware and paint supply stores will be performed to assure that the stores staff are knowledgeable regarding lead based paint and lead-safe work practices. These training sessions for retail staff will also be effective at identifying "do-it-yourselfers" who may not live in targeted areas. With NYS having the highest number of housing units containing lead based paint in the nation, it is important that a variety of activities that result in the disturbance of lead-based paint be addressed and that workers be provided with education on performing the work in a lead-safe manner.
- NYSDOH will utilize their relationships with the Local Health Departments to identify opportunities to provide outreach in the community. The local health departments will also help to provide access to landlord associations, tool loan programs, parent groups and community advocacy groups that can assist in gaining access to the community members.
Goal 3: Assure that homeowners, contractors, and other appropriate parties subject to Federal disclosure requirements are complying with these requirements.
Objective: To ensure that current federal requirements are followed.
- NYSDOH will work with Department of Health and Human Services (DHHS) Region II to convene a New York State meeting of state and federal partners, including CDC, EPA, HUD, ATSDR, and others to address coordination of efforts for childhood lead poisoning prevention.
- Currently property owners and contractors are required to comply with the Federal Regulations regarding the disclosure of information under the Real Estate and Pre-Renovation Rules. To encourage compliance with these regulations, violators will be referred to the EPA Region 2 office for enforcement. In addition to these referrals, outreach to the community regarding compliance with these regulations will be performed.
- The NYSDOH will work with the Office of Children and Family Services and Division of Housing and Community Renewal to assure that all NYS-administered Section 8 housing is in compliance with the Lead-Based Paint in Federally Owned and Subsidized Housing rule, and to enhance the knowledge and skills needed by all Section 8 housing administrators to comply with the federal rule. This rule established primary prevention activities that are required in all housing subsidized by the federal government. Both of these agencies are represented on the Lead Poisoning Prevention Advisory Council.
Goal 4: Review and revise current DOH regulations and guidance for consistency with federal standards and guidelines.
Objective 1: To ensure that the DOH Regulations are consistent with federal requirements.
- Review Title 10 NYCRR Subpart 67-2 regarding changes for consistency with federal requirements.
- Receive and review public comment regarding suggested changes to Subpart 67-2.
Objective 2: To ensure that all DOH Guidance Document to field staff are consistent with federal requirements.
- Review the DOH Environmental Health Manual (EHM) Items for consistence with the Federal requirements and guidelines.
- Re-emphasize to the local health departments the benefit of clearance testing for lead dust in dwellings after lead hazard control activities.
- Provide training sessions to all local health department environmental lead staff regarding wipe samples for assessment of lead in dust. The training will include how, when, where and why to take dust samples, and how to interpret and apply dust sample results.
- Revise the EHM items regarding lead dust testing after lead hazard control activities have been completed.