HUD Lead Paint Inspection & Risk Assessment 1 — Questions and Answers
Question 1: What is the difference between a lead-based paint inspection and a lead risk assessment?
- They are the same process with different names
- An inspection identifies the presence and location of LBP; a risk assessment identifies lead hazards and recommends corrective actions (Correct answer)
- An inspection is done before occupancy; a risk assessment is done only after a child has elevated blood lead
- A risk assessment only tests soil; an inspection only tests paint
Correct answer: An inspection identifies the presence and location of LBP; a risk assessment identifies lead hazards and recommends corrective actions
A lead-based paint inspection determines whether and where LBP is present; a risk assessment evaluates lead hazards (paint, dust, soil) and recommends how to address them.
A lead-based paint inspection is performed by a certified LBP inspector and determines whether LBP is present in the property and its exact location using XRF analysis and/or laboratory paint sampling. A lead risk assessment is performed by a certified risk assessor and evaluates whether lead-based paint hazards exist (including lead dust, lead soil, and deteriorated paint), determines the extent of those hazards, and recommends options for control or abatement. Risk assessment is typically the appropriate first step for addressing potential hazards in occupied housing.
Question 2: What device is used by certified lead inspectors to detect lead in paint without damaging the painted surface?
- Colorimetric test kit (sodium sulfide)
- X-ray fluorescence (XRF) analyzer (Correct answer)
- Gas chromatograph
- Atomic absorption spectrophotometer
Correct answer: X-ray fluorescence (XRF) analyzer
XRF analyzers are the primary non-destructive tool used by certified lead inspectors to measure lead content in painted surfaces in milligrams per square centimeter (mg/cm2).
X-ray fluorescence (XRF) analyzers are the standard tool for lead-based paint inspections. They measure lead concentration in painted surfaces non-destructively by emitting X-rays that cause lead atoms to fluoresce at a characteristic energy level. Results are given in mg/cm2. A reading of 1.0 mg/cm2 or greater is considered lead-based paint under HUD standards. Colorimetric test kits are less accurate and are not acceptable as the sole testing method for certified inspections.
Question 3: Under HUD's Lead Safe Housing Rule, what lead dust wipe clearance standard applies to floors after lead hazard reduction activities?
- 5 ug/ft2
- 10 ug/ft2 (Correct answer)
- 40 ug/ft2
- 100 ug/ft2
Correct answer: 10 ug/ft2
HUD's current clearance standard for floors after lead hazard reduction is 10 ug/ft2 (micrograms per square foot) of lead in dust wipe samples.
Under HUD's Lead Safe Housing Rule (24 CFR Part 35), clearance standards after lead hazard reduction are: floors: 10 ug/ft2; window sills: 100 ug/ft2; window wells (troughs): 400 ug/ft2. These measurements are taken from dust wipe samples analyzed by a certified laboratory. Units cannot be reoccupied after lead hazard reduction until clearance is achieved.
Question 4: Which of the following is considered a lead-based paint hazard under the Residential Lead-Based Paint Hazard Reduction Act?
- Intact, well-adhered lead-based paint on any surface
- Deteriorated lead-based paint, lead dust above clearance levels, and lead in bare soil above threshold levels (Correct answer)
- Any painted surface in a pre-1978 home regardless of condition
- Lead found only in paint chips but not in dust
Correct answer: Deteriorated lead-based paint, lead dust above clearance levels, and lead in bare soil above threshold levels
Lead hazards are specifically: deteriorated LBP, lead dust above clearance thresholds, and lead in bare soil above EPA action levels—not all lead paint regardless of condition.
Under Title X, lead-based paint hazards are defined as: (1) deteriorated lead-based paint (peeling, chipping, chalking, or cracking LBP or any LBP on a friction or impact surface); (2) lead-contaminated dust at or above applicable standards (10 ug/ft2 floors, 100 ug/ft2 window sills); and (3) lead-contaminated soil at or above action levels (400 ppm in play areas, 1,200 ppm for other bare soil). Intact, well-adhered LBP in good condition is not a hazard per se—it is managed in place.
Question 5: A risk assessment of a pre-1978 single-family rental home finds intact LBP on exterior window frames and lead dust levels below clearance standards. What response is appropriate?
- Immediate full abatement of all LBP in the property
- Interim controls—stabilize the paint, clean lead-contaminated surfaces, and establish an operations and maintenance plan (Correct answer)
- No action required since LBP is present but not at hazardous levels
- Complete repainting of the entire exterior
Correct answer: Interim controls—stabilize the paint, clean lead-contaminated surfaces, and establish an operations and maintenance plan
When LBP is intact and lead dust is below clearance levels, interim controls (stabilization, cleaning, O&M plan) are the appropriate response—full abatement is not required for non-hazardous conditions.
When a risk assessment finds intact LBP without current lead hazards (dust below clearance levels, no deteriorated paint), interim controls are the appropriate response. Interim controls include: paint stabilization (addressing deteriorated areas before they become hazards), lead dust cleaning, soil management, and implementing an operations and maintenance (O&M) plan for ongoing monitoring. Full abatement is not required unless hazards are confirmed.
Question 6: Under HUD's Lead Safe Housing Rule, what documentation must be provided to new occupants of federally assisted housing regarding lead-based paint?
- Only a verbal explanation of lead hazards
- Lead hazard disclosure form, LBP inspection or risk assessment report (if available), and the HUD/EPA pamphlet (Correct answer)
- Proof that the property has been fully abated
- Only the HUD/EPA pamphlet if the property predates 1950
Correct answer: Lead hazard disclosure form, LBP inspection or risk assessment report (if available), and the HUD/EPA pamphlet
Owners of federally assisted pre-1978 housing must provide new occupants with the disclosure form, any existing inspection/risk assessment reports, and the HUD/EPA lead hazard information pamphlet.
Under the Lead Disclosure Rule and HUD's Lead Safe Housing Rule, when a unit in pre-1978 target housing is rented, owners must provide to new occupants: (1) the EPA/HUD pamphlet 'Protect Your Family From Lead in Your Home'; (2) a lead hazard disclosure form signed by both parties; and (3) any existing records of LBP inspections, risk assessments, or lead hazard reduction activities. Verbal disclosure alone is never sufficient—written documentation is required.
HUD Lead Paint Inspection & Risk Assessment 1
What is the difference between a lead-based paint inspection and a lead risk assessment?