Schubert Center Submits Comments on ODH’s Lead-Safe Rental Registry Rules

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.

Read our full comments.

Read the original call for comments from the Ohio Healthy Homes Network.

Update 9/4/2018

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! The Schubert Center provided comments on the revised proposed rules.

Read the Schubert Center’s comments.

Update 3/5/2019

The Ohio Department of Health Joint Committee on Agency Rule Review (JCARR) approved Rule # 3701-81: Lead Safe Rental Registry on March 4, 2019.