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Voluntary Compliance – A Pre-Enforcement Framework for Healthy Housing Dale Hagen

Voluntary Compliance – A Pre-Enforcement Framework for Healthy Housing Dale Hagen Alameda County Healthy Homes Department. Basics of Voluntary Compliance. Assessment and Documentation Owner Notification and Engagement Technical Advisement Compliance Monitoring. Why Try Voluntary Compliance.

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Voluntary Compliance – A Pre-Enforcement Framework for Healthy Housing Dale Hagen

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  1. Voluntary Compliance – A Pre-Enforcement Framework for Healthy Housing Dale Hagen Alameda County Healthy Homes Department

  2. Basics of Voluntary Compliance • Assessment and Documentation • Owner Notification and Engagement • Technical Advisement • Compliance Monitoring

  3. Why Try Voluntary Compliance • To get something done when • Enforcement is not an option • Enforcement is not the first option • Enforcement is not the best option

  4. Why Try Voluntary Compliance • Give owners a chance to fix problems • Engage both parties-Tenants and Owners • Due diligence before reaching for enforcement help • Document Patterns of Behavior and Non-Responsiveness

  5. Why Try Voluntary Compliance • Document the need and extent of the problem - Type of Problem - Geographic Area • Gather information on impact of problem on families and vulnerable populations

  6. Voluntary Compliance in Alameda County Programs • Lead Poisoned Children • Unsafe Renovations (Lead) • Advancing Safe and Healthy Housing for Children and Families (ASHHI) • Mold

  7. Lead

  8. Voluntary Compliance:How We Got Started • Alameda County Lead Poisoning Prevention Program • Public Health Nursing • Environmental Health Specialists • Outreach and Education Team • Housing Professionals • Enforcement through Environmental Health

  9. Voluntary Compliance:How We Got Started • Case Review Working Group • Interdisciplinary Meetings • Technical Assistance • Compliance Monitoring

  10. Technical Advisement andCompliance Monitoring • Notify and establish deadlines • Assigned Housing Specialist • Persistent follow-up • Interdisciplinary Review

  11. Impact-Lead Hazards • Initially: • Enforcement referrals limited • Lengthy process • 2000 Median: 224 days to closure • 2011-14 Median: 88 days to closure • Enforcement referrals ~1-2 per year

  12. Next Step: Expansion of EBL Response • Based on resources available • Triage by level of presumed hazard • Voluntary compliance model • Owner notification w/deadlines • Technical advisement • Compliance monitoring • Interdisciplinary Team review

  13. EBL Response-Triaged

  14. Voluntary Compliance Elements • Intake and Assessment • On-Site Assessment • Owner Engagement • Technical Advisement and Compliance Monitoring • Enforcement Referral • Where available and appropriate

  15. Owner Engagement • Notification • Connect to Health and Codes • Promote Urgency or Deadline • Offer Assistance

  16. Voluntary Compliance-What Will You Do? TRIAGE: • Engagement Criteria • What will you respond to? • Response Criteria • How will you respond (level of resources) • Closure Criteria • How will you know when you are done?

  17. Developing Criteria: Engagement Criteria and Level of Response • Available Resources and Services • Severity • Extent • Immediacy • Vulnerable Populations • Lead: Children, child-care, school, EBL • Mold: Asthmatic or respiratory distress

  18. What Will You Do? Response Options • Advice • Notification and Technical Assistance • Site Assessment and Documentation • Compliance Monitoring • Enforcement Referrals

  19. Assessment Criteria • Visual or Testing? • Lead: • EBL 15+: Environmental Test • EBL 7-14: Home Visit Visual-Presume • Unsafe Renovation: Visual-Presume • Mold: Visual

  20. Unsafe Renovation (Lead)

  21. Review-Voluntary Compliance Elements • Intake and Assessment • On-Site Assessment • Owner Engagement • Technical Advisement and Compliance Monitoring • Enforcement Referral • Where available and appropriate

  22. Initial Inquiry/Complaint • Intake • Gather information • Provide advice, response options • Assess • Active • Severity • Research • Phone calls-renovator and owner • Site Visit?

  23. Site Assessment

  24. Owner Notification Why we are involved & • lead safety codes • Assessment Findings • Problem/Health Impact • Requirements / Consequences • Offer of Assistance • Timeframe for response

  25. Standards: State Law EPA RRP (where applicable)

  26. Work Practices Improvement

  27. Closure Time Periods FY 10 FY 12 # of incidents 59 77 Closed within: 30 days 31% 34% 60 days 37% 53% 90 days 49% 73%

  28. Advancing Safe and Healthy Housing for Families and Children • Assessment • Family Interview • Basic Environmental Treatment • Owner Notification and Engagement • Letter • Scheduled Appointment • Follow-up for 3 months • Enforcement Support-Oakland HH Pilot

  29. Standards: HHRS 29 Hazards

  30. Housing Health and Safety Assessment Report • Assessment date, type and disclaimer • Verify/Correct by qualified person • HHD available for consultation

  31. Housing Health and Safety Assessment Report • Deficiency • Location • Health Risk • Recommended Correction

  32. Oakland Healthy Homes Pilot Project • Oakland • Building Services • Housing Assistance Center • Alameda County • Healthy Homes • Asthma Start • Place Matters • Community/Tenant Groups • Also: Legal Aid, Vector Control, Health Care

  33. Results Project % w/owner Owner $ repairs Avg./unit HUD FY09 HH 26% $1,115 ASHHI 49% $ 680

  34. Further Evaluation • Most serious repairs addressed? • Type, extent and severity of unaddressed items? • Longer term impact? • Resources required.

  35. Mold • Phone Consults • Gathering Information • Referral to building department • Advice about effective complaint • Moisture, water intrusion, water leak • Don’t say “mold”

  36. Standards: Public Health Department Statements

  37. Gather Information Mold Calls July 2012-June 2013

  38. Mold • Next Steps-

  39. Challenges and Barriers • Managing Expectations • You can’t make everyone happy • People hear what they want to hear • Be clear to yourself about what you will do • Deliver clear messages about expectations • Provide referrals to enforcement agencies

  40. Challenges and Barriers • Larger Conflicts • Maintain fair and neutral stance • Referral to: • Mediation • Legal Aid • Tenant or Rental Owner organizations

  41. Measures of Efficacy • Anecdotal • Median Days to Closure • Compliance at: • Initial Visit • 2nd Visit • Owner Contribution - %, $ • Year over year changes in compliance • Compliance difference when RRP certified?

  42. Works Better With: • Commitment to the process • Interdisciplinary Collaboration • Willingness to start without all the answers • Housing/Health/Outreach expertise/partners • Link corrective actions to existing standards

  43. Works Better With: • Standard Process • Good Documentation • Referral Network • Resources

  44. Skills • Listening, Communicating and Educating • Mediation • Housing Assessment • Health Connection • Develop collaborative relationships

  45. Review-Voluntary Compliance Model • Triaged Response • On-Site Assessment • Owner Engagement • Technical Advisement and Compliance Monitoring • Enforcement Referral • Where available and appropriate

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