On June 22, 2018 the Schubert Center submitted comments on the Ohio Department of Health’s new Lead-Safe Rental Registry Rules. In the letter we raised several concerns regarding the proposed rules. The critical issue is that while lead contamination is mostly invisible the proposed rules do not require lead testing, but will accept a visual inspection of the property. We recommended that lead inspections for inclusion on the registry must require dust sample testing for the presence of lead. We also recommended that language be included in the rules to ensure that the implementation and maintenance of the registry is monitored for quality assurance purposes.
The Ohio Department of Health released its revised proposed rules on the Ohio Lead-Safe Rental Registry with a significant change in its policy for ensuring lead-safe rental housing for children and families. The new proposed rule on “post-maintenance dust sampling” replaces a mere visual inspection (“cleaning verification”) of dust wipe sampling with the best practice of a laboratory analysis (“clearance examination) of the dust wipe samples. In practice, this means assuring that lead inspections more effectively ensure lead safe housing, which is a critical step to ensuring the integrity of a voluntary, lead-safe rental registry. A big thank you to all the organizations and individuals that joined the sign on letter to ODH calling for the clearance examination! Please consider letting ODH know of your support of this change as they are taking comments on this new version until September 29, 2018. The new rules and guidance for submitting comments can be found at: https://www.odh.ohio.gov/rules/drafts/3701-81. Feel free to contact Gabriella Celeste at firstname.lastname@example.org if you have any questions or suggestions.