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Lead-Based Paint: Paint Sampling, Paint Inspections, and Risk Assessments

Andy Trent, Project Leader

This Tech Tip, the eighth in a series, describes the differences between lead-based paint sampling, paint inspections, and risk assessments. All three procedures are used to determine the presence of lead-based paint.

Background

The EPA Regulation, Requirements for Lead-Based Paint Activities in Target Housing and Child-Occupied Facilities (40 CFR Part 745), takes effect September 1, 1999. This regulation requires that individuals and firms conducting lead-based paint inspections, risk assessments, and abatement activities have training, be certified, and follow work practice standards. It applies only to target housing and facilities occupied by children. Target housing is defined as housing constructed before 1978. Child-occupied facilities are portions of buildings constructed before 1978 that are regularly visited by children 6 years old and younger. Examples include daycare centers, preschools, and kindergarten classrooms. This definition eliminates many Forest Service facilities from the rule, although the rule covers all pre-1978 housing. A paint inspection or risk assessment is not required before renovation or abatement work on buildings that are not target housing or facilities occupied by children.

Paint Sampling

Taking paint samples is an easy, cheap way to determine if you have lead-based paint on a painted surface. All you have to do is remove a small paint chip from a surface and send the chip to a certified lab for analysis. The lab will report back to you with the amount of lead contained in the chip, usually within 24 to 48 hours. Lab costs have been falling recently, with some labs charging as little as $5 per sample.

Taking paint samples is a good method if you are trying to determine whether the building you are about to repaint or renovate has lead-based paint. The results may help you determine whether to contract the job or to use force-account personnel. However, if you have many buildings or surfaces to test, a paint inspection may be a better approach than taking paint samples.

Paint Inspection

A paint inspection is defined as a surface-by-surface investigation to determine the presence of lead-based paint and report its location. A paint inspection will provide answers to two questions:

• Is there lead-based paint on the structure?
• If lead-based paint is present, where is it located?

A paint inspection identifies the presence of lead-based paint, but does not determine whether the paint presents an immediate hazard. Dust and soil samples are not usually collected as part of a routine paint inspection.

If a paint inspection is conducted, it should be performed by a certified inspector or a certified risk assessor. The recommended method of paint inspection is by portable X-Ray Fluorescence (XRF) instruments. The cost will vary depending on the number of buildings, the number of surfaces to be tested, and the distance the inspector will need to travel to the site. Typically, you could expect costs to range from $400 to $500 dollars per day for the inspector, plus travel. The inspector should be able to take samples from several buildings in 1 day.

Risk Assessment

A risk assessment is an onsite investigation to discover if any lead-based paint hazards exist. A hazard is a condition that causes exposure to lead that would result in an adverse health outcome. The assessments also provide recommendations for reducing exposure to the lead hazards. Certified risk assessors must perform risk assessments.

Risk assessments go beyond simply assessing the condition of the paint, and take into account resident use patterns and management or maintenance practices that will affect the paint. Risk assessments also identify other potential sources of lead hazards, such as dust and soil.

The cost of a risk assessment will vary depending on the number and condition of the buildings being assessed. Estimates for risk assessments could range from as low as $250 to more than $1000 per building, depending on the conditions and locations of the buildings.

A risk assessment has four major components: onsite data collection, laboratory analytical procedures, evaluation of findings, and the final report.

Onsite Data Collection—The onsite data collection begins with an overall visual assessment of the site. The visual assessment should identify deteriorating painted surfaces, areas of visible dust accumulation, areas of bare soil, and painted surfaces at impact points (such as door jambs) that could create lead dust. After the visual assessment is completed, dust samples are collected from specific sites and sent to an accredited laboratory to determine the amount of lead. If deteriorating paint is observed or if the assessor believes a hazard exists, the paint will be analyzed by X-Ray Fluorescence or by taking paint samples. Soil samples may be taken in areas of bare soil in outdoor play areas, building foundations or drip lines, bare pathways, etc. Water samples may be taken, but are not required for a routine risk assessment.

Laboratory Analytical Procedures—Paint, dust, and soil samples are analyzed only by accredited laboratories.

Evaluation of Findings—The goal of risk assessment is to determine whether any lead-based paint hazards are present. If lead hazards are found, the risk assessor will identify acceptable options for controlling the hazards.

Final Report—The final report compiled by the risk assessor documents the findings of the risk assessment and identifies control methods.

Approaching a Project

If you plan on renovating or repainting a single building, your approach would be to take representative paint samples and determine the levels of lead that exist. If you are working with a number of buildings at the same site or near each other, it may be best to hire a paint inspector for the testing. The inspector should get the job done rather quickly at a reasonable cost, and should provide thorough results. If living quarters are involved, and especially if work will be done inside the building, it may be best to combine a paint inspection and a risk assessment. This will protect not only the construction workers, but also the building's occupants. The combination of a paint inspection and a risk assessment is especially important if children use the building. Remember, paint inspections and risk assessments are not required for repainting or renovation jobs in nontarget buildings. However, you must know if you are working with lead-based paint to comply with OSHA's Lead in Construction and RCRA's hazardous waste disposal rules.

How to Find Risk Assessors or Certified Paint Inspectors

A list of certified paint inspectors and risk assessors may be located over the Internet at http://www.leadlisting.org. This site, developed under the sponsorship of the Department of Housing and Urban Development, has a listing of some of the qualified lead service providers (lead inspectors, risk assessors, and abatement contractors) for each State. You may also obtain information by calling the National Lead Information Clearinghouse at 1-800-424-5323. Ask for the latest list of certified lead contractors in your area.

Hard copies of this document may be ordered from:

USDA Forest Service
Missoula Technology & Development Center
5785 Highway 10 West
Missoula, MT 59808-9361
Phone: (406) 329-3900
Fax: (406) 329-3719

For further technical information, contact Andy Trent at the address above.

Phone: (406) 329-3912
Fax: (406) 329-3719
Email: atrent@fs.fed.us

E-mail: wo_mtdc_webmaster@fs.fed.us	Technology & Development Center

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