HUD Lead Paint Inspection & Risk Assessment 2 — Questions and Answers
Question 1: What is the HUD standard for lead content in paint that classifies it as 'lead-based paint'?
- 0.5 mg/cm2 or more, or 0.5% by weight
- 1.0 mg/cm2 or more, or 0.5% by weight (Correct answer)
- 2.0 mg/cm2 or more, or 1.0% by weight
- 0.1 mg/cm2 or more, or 0.06% by weight
Correct answer: 1.0 mg/cm2 or more, or 0.5% by weight
HUD defines lead-based paint as paint or surface coating with a lead content of 1.0 mg/cm2 or greater (by XRF), or 0.5% or greater by weight (by laboratory analysis).
Under 24 CFR Part 35, HUD defines lead-based paint as any paint or surface coating that contains lead equal to or exceeding 1.0 mg/cm2 as measured by XRF analysis, or 0.5% by weight as measured by laboratory analysis of paint chip samples. The EPA Consumer Product Safety Commission standard for hazardous lead paint in consumer products is 0.009% (90 ppm) for new products—much lower because it was designed for toys and children's products.
Question 2: What type of surface is considered a 'friction surface' in the context of lead-based paint hazards?
- Exterior masonry surfaces exposed to rain
- Surfaces subject to abrasion during normal operation, such as window channels and door edges (Correct answer)
- Painted floor surfaces in hallways
- Surfaces within 3 feet of the ground
Correct answer: Surfaces subject to abrasion during normal operation, such as window channels and door edges
Friction surfaces are those subject to abrasion during normal use (window channels, door edges, stair treads). Lead paint on friction surfaces automatically constitutes a lead hazard because use generates lead dust.
Friction surfaces are defined as surfaces subject to abrasion during normal operation, including window channels and sills, door edges and frames, stair treads, and floor surfaces. Lead-based paint on friction surfaces is automatically considered a lead-based paint hazard under HUD's Lead Safe Housing Rule because the friction action of opening/closing windows and doors generates fine lead dust. This dust settles on floors and window sills where children can be exposed. Lead paint on friction surfaces requires abatement or treatment as a hazard regardless of whether the paint appears intact.
Question 3: Under Title X, which years of construction define 'target housing' subject to lead-based paint requirements?
- Housing built before 1950
- Housing built before 1978 (Correct answer)
- Housing built before 1980
- Housing built before 1990
Correct answer: Housing built before 1978
Target housing is defined as residential dwellings built before 1978, the year the CPSC banned consumer use of lead-based paint in housing.
The Residential Lead-Based Paint Hazard Reduction Act (Title X) defines 'target housing' as any housing constructed prior to 1978. This year was chosen because the Consumer Product Safety Commission banned the use of lead-based paint in residential properties effective January 1, 1978. Pre-1978 housing is subject to lead disclosure requirements, lead-safe work practices, and HUD's Lead Safe Housing Rule for federally assisted properties.
Question 4: What must a certified lead abatement contractor do upon completing abatement work in a federally assisted property?
- Submit only a written report to HUD
- Arrange for clearance examination by a certified inspector or risk assessor and maintain all project records for 3 years (Correct answer)
- Self-certify that clearance standards have been met
- Contact the tenant to confirm satisfaction with the work
Correct answer: Arrange for clearance examination by a certified inspector or risk assessor and maintain all project records for 3 years
After abatement, a certified inspector or risk assessor (independent from the abatement contractor) must conduct the clearance examination. Project records must be retained for at least 3 years.
Under HUD's Lead Safe Housing Rule and EPA regulations, after lead abatement activities: (1) a clearance examination must be conducted by a certified lead inspector or risk assessor who is independent from the abatement contractor; (2) the clearance examination includes visual assessment and dust wipe sampling; (3) the unit cannot be reoccupied until clearance is achieved; and (4) the abatement contractor must maintain project records for at least 3 years. Self-certification of clearance is not permitted.
Question 5: Which category of federally assisted housing built before 1978 is EXEMPT from HUD's Lead Safe Housing Rule?
- Single-family homes receiving CDBG funds
- Housing specifically designated for elderly persons or persons with disabilities with no children under 6 (Correct answer)
- Multifamily properties with HUD-insured mortgages
- Section 8 Housing Choice Voucher units
Correct answer: Housing specifically designated for elderly persons or persons with disabilities with no children under 6
HUD's Lead Safe Housing Rule exempts housing specifically designated for elderly or persons with disabilities where no child under 6 resides or is expected to reside.
HUD's Lead Safe Housing Rule (24 CFR Part 35) contains exemptions. Federally assisted housing is exempt if it: is specifically designated for elderly persons or persons with disabilities (provided no child under 6 resides or is reasonably expected to reside there); is a studio/0-bedroom dwelling unit; has been found to be lead-based paint free by a certified inspector; or is emergency housing for fewer than 100 days. All other federally assisted pre-1978 housing is subject to the full rule.
Question 6: What is the purpose of a 'paint stabilization' activity under lead hazard interim controls?
- Removing all lead-based paint from the property
- Repairing deteriorated paint and applying a durable new coating to prevent further deterioration and dust generation (Correct answer)
- Encapsulating the entire painted surface with a thick sealant
- Testing painted surfaces to determine lead content
Correct answer: Repairing deteriorated paint and applying a durable new coating to prevent further deterioration and dust generation
Paint stabilization involves addressing the underlying cause of deterioration, repairing the deteriorated paint, and applying a new protective coating to stabilize the surface and prevent lead dust generation.
Paint stabilization is an interim control activity (not full abatement) that involves: (1) identifying and addressing the underlying cause of paint failure (moisture, substrate failure, impact damage); (2) preparing the surface using lead-safe work practices (wet scraping, HEPA vacuum); (3) repairing the damaged substrate if necessary; and (4) applying a new durable paint coating over the stabilized surface. This prevents the deteriorated paint from generating lead dust without full removal. Stabilization must be followed by clearance testing.
HUD Lead Paint Inspection & Risk Assessment 2
What is the HUD standard for lead content in paint that classifies it as 'lead-based paint'?