POLICY RECOMMENDATIONS
PREVENTION RECOMMENDATIONS
Lead Safe Certificate
1. Mandate a Lead Safe Certificate for all rental units built before 1978. The mandatory, proactive
certificate should be established by the completion of third-party inspections.
• Consider allowing exemptions for:
o Fully renovated and/or majorly rehabbed rental units that have passed an initial clearance
examination.
o Rental units that are already required to be lead safe under federal law.
• Consider allowing exemptions during the initial Lead Safe Certificate cycle for:
o Rental units that have recently passed randomized lead dust wipe inspections conducted by the
Department of Building and Housing.
• The Lead Safe Certificate should attach to the land and transfer upon sale.
• The Lead Safe Certificate should be valid for two years.
• Adhere to the U.S. Housing and Urban Development (HUD) Sampling Standards for multi-unit
buildings. If one of the rental units in the applicable sample is found to have lead hazards, mandate
an inspection of all rental units.
2. Mandate clearance examinations by certified clearance technicians or certified lead risk assessors OR
risk assessments by certified lead risk assessors as acceptable inspections to earn a Lead Safe Certificate.
• If preferred by landlord or property owner, permit a risk assessment that finds a rental unit to be
“lead free” to earn a Lead Free status.
• A Lead Free status should be determined by administrative rule.
• If a property fails the clearance examination or risk assessment and requires remediation, a
subsequent clearance examination must be accompanied with a verification that remediations were
completed by a certified Renovation, Repair and Painting (RRP) contractor using lead safe work
practices.
Implementation of the Lead Safe Certificate
3. Roll out the Lead Safe Certificate in two parts.
• Ramp-Up (Year 1): The time period from the passage of the Lead Safe Certificate mandate to the
first phase of certification is one year. The ramp-up time allows for: 1) workforce development, 2)
resource development, 3) implementation preparation, and 4) grace period/incentive period for early
adopters (landlords who certify their rental units as lead safe during year 1).
• Phase-In (Years 2 and 3): After the Ramp-Up period, create a two-year certification cycle that is
phased in every quarter according to 8 rental inspection areas.

 o 8 rental inspection areas should be modelled on the existing Department of Building and
Housing rental inspection areas but determined by ZIP code. The 8 Lead Safe Certificate
inspection areas adapts the successful concept of the Department of Building and Housing
rental inspection areas, manages caseload (approximately 8,000 unit per quarter), distributes
costs to landlords over time, supports a viable, year-round workforce, and avoids legality
issues associated with targeted enforcement.
4. The Lead Safe Certificate mandate should target resources, as opposed to targeting enforcement.
• Resources should be targeted based on:
o High-risk areas (high-risk could be defined by address where screened/tested child lives
and/or properties identified as having lead hazards).
o Need of tenants (need could be defined by eligibility for other programs, like Home Energy
Assistance Program (HEAP)).
5. Incentivize early Lead Safe Certificate adoption by providing inspection vouchers to landlords or
property owners registering rental units with the Rental Registry during the Ramp-Up period.
• Vouchers should only be available for vetted inspectors, limited to a certain number per
company/inspector, and administered through a community-based program.
6. To support the ability to implement a high functioning Lead Safe Certificate system, increase the
appropriation for the Department of Building and Housing.
• The appropriation should support software to maintain a publicly accessible database with list of
Lead Safe homes.
• The appropriation should support increased enforcement of the Rental Registry, the implementation of
the new Lead Safe Certificate, and the tracking and enforcement of rental units that are noncompliant.
Enforcement and Evaluation of the Lead Safe Certificate
7. Lead with civil penalties, rather than criminal penalties, in both the new Lead Safe Certificate system
and the existing Rental Registry.
• Establish civil penalties for Lead Safe Certificate non-compliance, as opposed to the creation of new
criminal penalties.
• Add civil penalties to the existing criminal penalties for rental registry non-compliance.
• Prevent contributing to racial inequities by not creating additional criminal penalties.
8. Require regular monitoring, impact analysis, and public reporting on the Lead Safe Certificate and of
the Lead Safe Certificate system.
• An impact analysis should track metrics developed, in part, with Lead Safe Cleveland Coalition.
9. Create a position of Lead Safe Auditor to provide independent quality control of the Lead Safe
Certificate.
• The Lead Safe Auditor should be responsible for:
o Coordinating regular monitoring and reporting on the Lead Safe Certificate system;
o As needed, enhancing U.S. Environmental Protection Agency (EPA) and Ohio Revised Code
standards for inspections and remediation;
o Serving as a clearinghouse for certified and vetted inspectors and contractors;
o Recommending incentives and improvements for ongoing compliance.
• The Lead Safe Auditor could be housed in the Department of Building and Housing, serve in a crossdepartmental capacity, and/or be appointed by City Council.
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 10. Create a position of Lead Safe Ombudsperson to serve as a public-facing resource to members of the
community who are impacted by the Lead Safe Certificate system.
• The Lead Safe Ombudsperson should be responsible for:
o Representing the interests of the public by investigating complaints of noncompliance of the
Lead Safe Certificate standards;
o Resolving disputes between parties including: tenants, landlords, contractors, and inspectors.
o Recommending improvements in the Lead Safe Certificate procedures, policies, and practices.
• The Lead Safe Ombudsperson could be appointed by the City of Cleveland and/or housed in an
independent agency with authority and resources.
11. Include explicit language that triggers automatic policy reevaluation if certain impacts (see #8) are
identified.
• This recommendation is a version of Rochester’s “Korfmacher Compromise” to safeguard against
unintended consequences such as housing insecurity and homelessness.
Lead Safe Home Fund and Other Resources
12. Seed the Lead Safe Home Fund with a City of Cleveland appropriation.
• As conceptualized by the Lead Safe Cleveland Coalition, the Lead Safe Home Fund will:
o Prioritize resources by need but still make resources widely accessible;
o Fund a sliding scale of subsidies to support remediation work ranging from interim controls to
full abatement, inspection subsidies, training for inspectors and contractors, emergency
transitional housing support, and other direct services as needed by families and children;
o Be operated by an independent third party.
13. Revise the reestablished Department of Community Development paint program to allow interior
painting, in addition to exterior use.
• Coordinate the paint program with the Lead Safe Resource Center and require the necessary training
for any participant who intends to access the program to address lead hazards.
Intersections and Systems Change
14. Tenant protections should be increased.
• Include explicit language stating protections against retaliation for tenants who report landlord noncompliance with Lead Safe Certificate system.
• Add “Source of Income” as a protected class in local anti-discrimination law to advance equitable
housing choice and increased mobility.
• Establish a Right to Counsel program to provide representation for low-income families facing eviction.
15. Require all projects using City of Cleveland funding to be lead safe and/or to employ lead safe work
practices, as defined by administrative rule.
16. Require proof of the appropriate U.S. EPA-compliant RRP training as a part of applicable contractor
registration.
• Applicable contractors are those who are disturbing paint in rental units and day care centers built
before 1978.

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 SCREENING + TESTING RECOMMENDATIONS
17. Establish a council for cross-system coordination of screening and testing that shares information and
data, coordinates services, and assesses gaps.
• This Council should:
o Establish best practices that allow for the efficient and effective coordination of services for
families who are at risk of or have been exposed to lead hazards;
o Establish information sharing agreements between organizational members;
o Partner with the Healthy Homes Advisory Council (HHAC) to implement screening and testing
recommendations.
• Include as statutory members representatives from sectors and organizations such as:
o At least one parent or caregiver living in the City of Cleveland
o At least one provider from an early childhood education setting
o Cleveland Department of Public Health
o Cleveland Metropolitan School District
o Catholic Charities
o Cleveland Transformation Alliance
o Charter School System
o Religious School System
o Cuyahoga County Invest in Children
o Cuyahoga County Board of Health Early Ages Healthy Stages Coalition
o Cleveland Department of Law
o Cuyahoga County Family and Children First Council
o Medicaid Managed Care Organizations operating in the City of Cleveland
o FQHCs operating in the City of Cleveland
o Head Start
o Other major healthcare institutions operating in the City of Cleveland
18. Require projects and programs operated by the City of Cleveland or supported with City of Cleveland
funding that primarily serve children ages 0-6 and pregnant women to provide a screening
(appropriately adapted HHAC or similar questionnaire), to offer a referral for testing, and to provide lead
poisoning prevention education.
• Lead poisoning prevention education – for families and providers - should be streamlined across all
projects and programs and reflect a consistent, unified message, appropriate for diverse audiences,
and developed in conjunction with the Lead Safe Cleveland Coalition.
• Lead poisoning prevention education should articulate the significance of coordination with a medical
home.
• Referrals should be to appropriate testing entities.
19. Instruct the Department of Public Health to re-focus screening and testing efforts to community
programs and organizations where children ages 0-6, particularly children ages 12-24 months, are likely
to be.
• Re-focus and, where appropriate, increase resources dedicated to Department of Public Health
screening and testing toward early childhood education settings in high-risk areas and other places
where children convene like libraries, recreation centers, and WIC offices.
20. Instruct the Department of Public Health to explore a pilot program that would provide on-site and/or
mobile screening, testing, and/or testing referrals, and report back to City Council the findings.
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Answer the questions: what would it take to create an effective mobile screening and testing
program? Would this approach contribute positively and appropriately to improving lead testing
rates across Cleveland?

21. In partnership with the Lead Safe Cleveland Coalition, urge the State of Ohio to create a more
detailed, timely, and enforceable database on testing that includes city, county, and state records.

TREATMENT + INTERVENTION RECOMMENDATIONS
22. To more quickly process an anticipated increase in lead hazard control order case load, increase
appropriation for the Departments of Public Health and Law.
• Lead Safe Cleveland Coalition outreach in combination with the new Lead Safe Certificate system will
likely contribute to an uptick in lead hazard control orders.
23. Instruct the Department of Community Development to prioritize in Community Development Block
Grant (CDBG) program funding criteria to those projects that focus on or include lead poisoning
prevention.
24. Establish an action team, comprised of representatives from City of Cleveland-funded housing
providers, to support families who relocate as a result of lead poisoning or a lead hazard control order.
• The action team should establish a pool of available housing units for families facing relocation due to
lead poisoning;
• The action team should troubleshoot obstacles that emerge during emergency relocation;
• Based on its work, the action team could produce a set of recommendations to create a larger and
better relocation pipeline. For example, advocate for donated houses to support temporary relocation
of families.
25. Mandate that Certificates of Disclosure include the lead status of property.
• If there is a current, open lead hazard control order on a property it should be disclosed on the rental
registry as well as disclosed during applicable property transfers.
• Certificates of Disclosure could include copies of the lead hazard violations, both open and closed. This
is especially important if there were interim controls that require maintenance.
26. Mandate landlords to fully disclose to tenants when a rental unit is under a lead hazard control
order.
• Disclosure includes directly sending tenants copies of the lead hazard control order, inspections
reports, extensions, and notices that a property cannot be re-rented.
• Disclosure should also include pertinent information regarding the Lead Safe Resource Center and
action team.
27. In conjunction with the Lead Safe Cleveland Coalition, explore rent deposit and escrow tools for
future policy recommendations.
• Explore both an expanded version of the existing rent deposit program as well as alternatives, such
as declaring properties as worth zero rent while under a lead hazard control order.
• Include a study of:
o Benefits and challenges.
o Similar programs like the City of Detroit’s Rent Property Escrow Program.

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 EDUCATION + OUTREACH RECOMMENDATIONS
28. Create a Lead Safe Resource Center, in coordination the Lead Safe Home Fund, to serve as a “one
stop shop” for landlord training, vetted workforce directory, equipment rental, lead 101 information,
resources, hotline, and process navigation.
• Similar to the Lead Safe Home Fund, seed the Lead Safe Resource Center alongside with other public,
private, and philanthropic partners.
• To ensure transparency, the City should facilitate a competitive RFP process to select one or more
community-based organizations to serve as Resource Center.
• City will set metrics and monitor success in coordination with the Lead Safe Cleveland Coalition.
29. The Lead Safe Resource Center should provide subsidized, two-part training courses during Lead Safe
Certificate Ramp-Up and Phase-In periods.
• To access subsidized training courses, participants should be required to attend and pass a standard
in-class training and follow-up field training.
• Trainings opportunities should include clearance technician and risk assessor training, RRP contractor
training, and lead abatement contractor training.
• Consider funding other complementary, community-based workforce development programs for
inspectors, contractors, and trainers during Lead Safe Certificate Ramp-Up period.
30. Release an annual report to the community on City of Cleveland lead poisoning prevention related
efforts.
• Include updates, progress, and challenges on all prevention, screening + testing, treatment +
intervention, and education + outreach efforts across departments.
• Detail efforts such as: early intervention and other referrals, inspections results, lead hazard control
orders, remediation work, number of children who have tested positive for lead, number of rental units
that have passed clearance/risk assessment, number of rental units that have failed clearance/risk
assessment.
• Coordinate with the Lead Safe Cleveland Coalition to also measure and report community efforts.
31. Require organizations offering public housing or subsidized housing vouchers in the City of
Cleveland to annually report to the City the history and status of inspections and the status of their Lead
Safe Certificates.
• Subsidized housing providers include Cuyahoga Metropolitan Housing Authority (CMHA), EDEN, etc.
• Once fully implemented, advance the reporting system from annually to quarterly.
32. Require early childhood education providers, Cleveland Metropolitan School District (CMSD), and
private and religious school systems operating in the City of Cleveland to provide lead poisoning
prevention education to students and families.
• Lead poisoning prevention education should be streamlined across all projects and programs and
reflect consistent, unified messages to be developed in conjunction with the Lead Safe Cleveland
Coalition.
33. Starting when the Phase-In period ends, require landlords to disclose the Lead Safe Certificate status
to current tenants and any tenants with a new, renewed, or updated lease agreement; mandate a small
statutory damage penalty for non-compliance.

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