October 21st, 2019

Tactical Thinking: Housing Codes and Lead Poisoning Prevention

by Sarah Goodwin and David Jacobs

When it comes to local efforts to prevent childhood lead poisoning, there seems to be one word on everyone’s mind these days: codes. Between our brand new Code Comparison Tool, several recipients of the 2019 Lead Poisoning Prevention Grants, and the highly attended webinar presented by the City of Dallas’ Bob Curry and our own Amanda Reddy, virtually every project we work on at NCHH has to do with improving local housing codes in some way. And that’s a good thing! Although today’s housing codes originated over a century ago in the sanitation movement to combat health problems such as cholera, tuberculosis, and typhoid, current codes typically refer housing-related lead problems to local health departments instead of using the code process to identify and correct such lead and other healthy homes problems. But thanks to established national models in places like Rochester (New York), Maryland, and Rhode Island, we’re seeing more and more local and state jurisdictions begin to weaponize their housing codes in the fight against lead poisoning.

The National Center for Healthy Housing (NCHH) was funded from June 2018 through May 2019 by the Michigan Department of Health and Human Services, under a Child Lead Exposure Elimination Innovations Grant, to work with four cities to improve their housing codes to prevent childhood lead poisoning. The Technical Assistance for Code Transformation Innovation Collaborative (TACTIC) met twice with city officials and community partners from Battle Creek, Grand Rapids, Detroit, and Flint and published five reports.

In each city report, we included a description of best practices from across the country, an analysis of the city’s present strengths, and recommendations for how they could improve their code language, staffing levels and training, enforcement practices, and community engagement to address lead hazards proactively. In the statewide report, we examined at the Michigan lead laws and regulations, creating recommendations for how each could be improved, as well as how the state could support local efforts.

Here are the links to each of the city reports:

And here is the Michigan report (which includes the city reports in the appendices).

While the specific recommendations were tailored to the situation in each city, our suggestions generally follow the model below:

  • Cities should require testing of deteriorated lead paint and dust as part of the rental permit to determine actual risk of lead hazards.
  • Housing code language should require remediation of deteriorated lead‐based paint using lead‐safe work practices and clearance dust testing in all rental units in which young children reside, are expected to reside, or could reside or visit.
  • Cities may need to increase the number of housing code inspectors to carry out this work.
  • Housing code compliance officers should be trained to collect paint and dust samples properly as part of code inspections instead of only doing so after a child has already been exposed.
  • Code violation notices should include deteriorated lead‐based paint and elevated dust lead levels.
  • Cities should involve the public in proposed changes to the code and seek comment from tenants, landlords, property owners, public health officials, and other members of the public. This includes working for the protection of tenants during the implementation of code changes.
  • There should be an effort to facilitate data sharing between the city and the county health department, and housing agencies.
  • Public education efforts should include the importance of deteriorated lead‐based paint and the contaminated dust and soil it generates.
  • Cities should evaluate the results of code changes by documenting changes in housing quality, compliance time, complaints, and childhood blood lead levels.
  • Cities should work with community‐based programs to expand capacity to educate landlords and residents.
  • To achieve these goals, cities may need to consider increasing funding and capacity for code compliance.

One of the most exciting parts of this project is discovering the various strengths and opportunities within each city. For example, Detroit is rolling out a requirement that all landlords obtain a lead inspection and risk assessment and remediate hazards; the program is being implemented one ZIP code at a time, and if compliance is achieved, the city could become a national model. In Grand Rapids, an engaged advisory committee led by the mayor is already considering our recommendations. In Battle Creek, we learned about a previous successful public education campaign that energized the community and how the local code inspectorate is already engaged in lead hazard assessment. And in Flint, the city has just begun their first ever HUD lead grant, giving them the opportunity to hire and train new code inspectors.

We’ll continue our work with these cities as they implement the recommendations – as well as repeating process with a new set of Michigan jurisdictions – with support from the State of Michigan. There’s a groundswell of movement toward using local housing codes to ensure healthy housing, and we’ve been excited to participate in Michigan’s effort over the past 12 months and into the future.


Sarah Goodwin, Policy Analyst, NCHHSarah Goodwin joined NCHH as a policy analyst in June 2017. She previously served NCHH as a policy intern, helping to establish and run the Find It, Fix It, Fund It lead action drive and its work groups. She holds a Bachelor of Arts degree in Interdisciplinary Studies: Communications, Legal Institutions, Economics, and Government from American University.




David Jacobs, Chief Scientist, NCHHDr. David Jacobs, former director of the Lead Poisoning Prevention Program at the U.S. Department of Housing and Urban Development, is the chief scientist for the National Center for Healthy Housing and an adjunct professor at the University of Illinois at Chicago School of Public Health

October 21st, 2019 | Posted By , | Posted in Blog, Codes, Lead Poisoning | Tagged , , , , , , , , , , , , ,