CONSOLIDATE CHILDHOOD LEAD POISONING PREVENTION AND CODE ENFORCEMENT ACTIVITIES
DESCRIPTION OF THE STRATEGY
Co-locating the childhood lead poisoning prevention program (CLPPP) and the public agency responsible for housing and sanitation code enforcement is an option for local governments to facilitate collaboration between traditionally separate activities. An even stronger consolidation extends to the CLPPP authority to cite violations of the housing code’s provisions related to deteriorated paint and lead hazards and trigger enforcement proceedings. In some instances, it may be preferable for the agencies to physically move closer or even share an office suite, but for other local governments, simply increasing collaboration can have significant results.
BENEFITS
Immediate/Direct Results: Co-locating CLPPPs with code enforcement agencies will expedite responses to the lead hazards by the code enforcement authority, helping CLPPPs bridge the gap between these functions that exists in many jurisdictions. When CLPPPs share code enforcement authority, or can influence its actions, they can readily ensure that owners of homes with deteriorated paint or other lead hazards identified by the CLPPP will be required to fix the hazards. Public Health Benefits: Improved code enforcement is the cornerstone of primary prevention. CLPPP staff will be able to effectively prioritize enforcement to benefit the highest risk children and housing. As a result of increased awareness of lead hazards among code enforcement staff, routine code enforcement practices can evolve to recognize violations that may have previously been considered low priority, triggering violation notices that may not have been generated in the absence of an EBL child. Other Indirect/Collateral Benefits: Improved code enforcement will lead to growth in the number of leadsafe or lead-free homes.
SCOPE OF POTENTIAL IMPACT
City- or County-Wide
PRIMARY ACTORS
Health Department Housing Code or Inspection Agency
KEY PARTNERS
City/County Prosecutors
CRITICAL ELEMENTS
Staff requirements: Staff requirements depend upon agency responsibilities and resources. Where enforcement authority coexists, more staff is likely to lead to more citations. Other resource requirements: Field staff expected to evaluate houses for lead hazards will need training, certification, and possibly an XRF device. Institutional capacity required: To the extent that code enforcement authority is shared or delegated, legislative, regulatory, or executive agency action may be needed. Substantive cross-agency coordination and/or resource sharing require upper management support. Cost considerations: Lab analysis costs ($50 per home on average), training, and prosecution resources associated with an incremental increase in the number of inspection staff and inspections performed. Certification costs for public employees are waived in some jurisdictions. Timing issues: Can be implemented whenever administrative and management arrangements have been completed.
Centers for Disease Control and Prevention
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Building Blocks for Primary Prevention: Protecting Children from Lead-Based Paint Hazards Using Code Enforcement and Other Systems CONSOLIDATE CHILDHOOD LEAD POISONING PREVENTION AND CODE ENFORCEMENT ACTIVITIES
Feasibility of Implementation: High with management support.
POTENTIAL OBSTACLES/BARRIERS
The housing code enforcement agency may be reluctant to delegate authority to or share it with the CLPPP staff because they will not trust that the staff will follow the procedures properly. Staff may also be concerned about overwhelming the legal system needed to complete the enforcement process. If the housing code enforcement has been lax in the past, suddenly adding lead hazard enforcement will be controversial with property owners.
ADDITIONAL RESOURCES
N/A
ILLUSTRATION OF STRATEGY IN PRACTICE When the city and the county consolidated operations in the mid-1970s, the health department and the county hospital became part of a quasi-governmental corporation. The county delegated responsibility for housing code enforcement to the health department and subsequently established an Environmental Court to prosecute housing code violations and related issues. The CLPPP issues citations for houses where it finds deteriorated paint or lead hazards, often as a result of an environmental investigation of a lead poisoned child. Between January 2000 and July 2003, the CLPPP issued more than 200 citations and pursued those cases in the Environmental Court to get the hazards resolved.
Jurisdiction or Target Area: Marion County / Indianapolis Primary Actor: Childhood Lead Poisoning Prevention Program, Housing Division, Marion County Health Department, Marion County Health and Hospital Corporation (includes Indianapolis). Secondary Actor(s): N/A Staffing utilized: Six FTE staff trained and licensed as risk assessors conduct the inspections, manage the enforcement process, and re-inspect some properties as needed. Other resources utilized: The close cooperation of the inspectors with other CLPPP staff enhances the overall effectiveness of the program. The Environmental Court streamlines the process and ensures that the hazards are addressed. Factors essential to implementation: The agency responsible for housing code enforcement must be willing to cooperate with the CLPPP staff and have a streamlined process to enforce code citations. Limitations/challenges/problems encountered: Staff must follow specific procedures and be prepared for the delays as property owners must be notified and prodded with orders and fines to address the problem. Magnitude of Impact/Potential Impact: Between January 2000 and July 2003, the CLPPP issued more than 200 citations and managed those citations in the Environmental Court to get the hazards resolved. Potential for replication: Very high
Centers for Disease Control and Prevention
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Building Blocks for Primary Prevention: Protecting Children from Lead-Based Paint Hazards Using Code Enforcement and Other Systems CONSOLIDATE CHILDHOOD LEAD POISONING PREVENTION AND CODE ENFORCEMENT ACTIVITIES
Contact for Specific Information Dave McCormick Director, CLPPP 317-221-2171 dmccormi@hhcorp.org References for additional information 1. See www.mchd.com/newlead.htm for a description of CLPPP program. 2. See www.mchd.com/newlead.htm for a copy of the Residential Housing Code.
Centers for Disease Control and Prevention
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