Lead based paint (LBP) is a surface coating that contains a certain amount of lead that is found in residential properties, school buildings, commercial buildings, industrial work sites, and many other places. Having LBP within a building does not mean that there is an immediate risk. While lead can cause a variety of serious health problems, it is only a problem when the painted surfaces are deteriorated or disturbed and reduced to a dust that can be either inhaled or ingested. Small children, pregnant women, and workers are most at risk of exposure to lead. In order to determine whether lead may be a problem or required by law to be inspected in any given building, there are different services that may be helpful:
- Lead Based Paint Inspections or Limited Paint Testing
- Lead Risk Assessments or Lead Combination Inspection/Risk Assessment
- Lead Clearance Testing
- Elevated Blood Lead Level Environmental Investigations
Lead Based Paint Inspections / Limited Paint Testing
A lead based paint inspection is a surface by surface investigation to determine the presence and location of lead based paint on pre-1978 residential properties or child occupied facilities and providing a report that explains the result of the investigation. A lead based paint inspection involves operating a hand held device known as a X-Ray fluorescence analyzer or (XRF) and taking non-destructive samples of all painted building materials. The paint is analyzed for lead concentrations and compared to the EPA threshold for lead based paint which is 1.0 mg/cm2. If an XRF cannot be used for some reason, a paint chip sample would be collected using a destructive method and sent to a NLLAP approved laboratory for analysis and compared to the EPA threshold for lead based paint which is 0.5% lead by weight. Any surface coating or that contains lead equal to or greater than 1mg/cm2 or 0.5% by weight is considered to be lead based paint (LBP). These surfaces must be carefully monitored for deterioration. If these surfaces are to be disturbed than all workers must follow appropriate regulations to ensure that building occupants are not exposed. There are different types of lead paint testing services that ETC offers as detailed below:
Lead Based Paint Inspections
Lead based paint inspections performed in single family housing would require all painted surfaces on a property to be analyzed and recorded. In child occupied facilities only areas to the extent defined for child use would usually be tested for lead based paint unless the entire building owner requests otherwise. In multi-family housing (depending on the age and number of units) only a percentage of the units, common areas, and building exteriors would be tested and recorded. Federal, state, and local laws may require lead based paint inspections for certain properties.
Limited Paint Testing
Limited paint testing is a service offered to building owners or renovation contractors which allows the lead inspector to only test a limited area, room, or certain building components for the EPA Renovation, Repair, and Painting Rule (RRP). This regulation is designed to ensure that building occupants are not exposed to unsafe levels of lead dust and that renovation contractors follow lead safe work practice standards. Because all surfaces would not need to be tested this type of testing is usually cheaper than a full lead based paint inspection.
Lead Risk Assessments or Lead Combination Inspection/Risk Assessment
A lead risk assessment involves identifying exposures to lead or potential exposures to lead from deteriorated lead based paint, elevated surface dust levels, lead contaminated soil, and sometimes from drinking water. A risk assessment involves interviewing the occupants, assessing the building condition, identifying different types of paint hazards or potential paint hazards, collection of dust samples from certain surfaces, collection of soil, and sometimes water sampling. Abatement (long term) and interim controls (short term) recommendations are described in the report for each identified lead based paint hazard. Paint samples would be analyzed by XRF and dust, soil, and water would be analyzed in a laboratory. Dust samples are collected and calculated by the sampled surface area and compared to EPA thresholds which are 40 ug/ft for floors, 250 ug/ft2 for window sills and 400 ug/ft2 for window troughs. Soil samples are measured in parts per million (PPM) and compared to EPA thresholds of 400 ppm for gardens and children’s play areas and 1200 ppm for other bare soil areas of a property. Water sampling is compared to the EPA drinking water system threshold of 15 parts per billion (PPB).
Lead Risk Assessments
Risk assessments identify hazards associated with lead and these hazards usually require actions to be taken to correct the identified issues. Lead risk assessments may be required by federal, state, or local law. If the amount of any federal funding used for a residential renovation or rehabilitation project exceeds $5000.00 a risk assessment would be required by federal law. City of Detroit rental property ordinance requires lead risk assessments for rental properties. Day care licensing in Michigan also requires lead risk assessments.
This is a combination lead based paint inspection and lead risk assessment. Lead combinations may be required by federal, state, or local law. If the amount of any federal funding used for a residential renovation or rehabilitation project exceeds $5000.00 a risk assessment and paint inspection would be required by federal law. City of Detroit rental property ordinance requires lead risk assessments for rental properties.
Lead Clearance Examinations
Lead clearances are required in the state of Michigan following all lead hazard control activities. The purpose of a clearance examination is to ensure that occupants or employees are not exposed to lead after lead based paint has been disturbed, lead dust has been removed, or soil has been treated for lead contamination. There are three steps to performing a clearance examination. First step: A lead inspector or risk assessor reviews the work that was performed by making sure that all corrections have been made properly by the hired contractor. Second step: A lead inspector or risk assessor visually reviews all work areas for dust, debris, or residue to ensure that proper cleaning was performed adequately. Third step: Dust samples are collected on interior surfaces, calculated by the sampled surface area, and compared to EPA thresholds which are 40 ug/ft2 for floors, 250 ug/ft2 for window sills and 400 ug/ft2 for window troughs.
Elevated Blood Lead Level Environmental Investigations
Elevated blood lead level environmental investigations are performed in response to a person that has an elevated blood lead level (EBL). An accredited EBL investigator is required by Michigan law to perform a combination lead based paint inspection and risk assessment on the property of the person with the EBL. An EBL investigation also includes a thorough interview with to determine all possible exposures to lead not only from lead based paint hazards in the residence but also from cosmetics, foods, medicines, hobbies, work place exposures, personal property, and many other potential sources of lead. An EBL investigation may not be limited to one address but also multiple addresses including schools, work sites, or other residences that a person with an EBL may be exposed to lead.
ETC’s diverse group of building inspectors have over 150 years of experience inspecting buildings throughout the State of Michigan and OHIO. ETC owns more than 10 Niton XLP 300A handheld devices and uses Accurate Analytical laboratory usually for analysis of dust, soil, paint chips, and lead or cadmium air samples. We have performed thousands of lead building inspections to assist our clients in complying with EPA, HUD, and OSHA regulatory requirements.