Lead-Based Paint Inspection

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U.S. Department of Housing and Urban Development
Guidelines for the
Evaluation and Control
of Lead-Based Paint
Hazards in Housing
Chapter 7:
Lead-Based Paint Inspection

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Step-by-Step Summary

Lead-Based Paint Inspection:
How to Do It
Note: This 1997 Revision replaces Chapter 7 of the 1995 HUD Guidelines for the
Evaluation and Control of Lead-Based Paint Hazards in Housing
1. See Chapters 3, 5 and 16 for guidance on when a lead-based paint inspection is appropriate. A lead-based paint
inspection will determine:
• Whether lead-based paint is present in a house, dwelling unit, residential building, or housing development,
including common areas and exterior surfaces; and
• If present, which building components contain lead-based paint.
The U.S. Department of Housing and Urban Development (HUD) and the U.S. Environmental Protection Agency
(EPA) define an inspection as a surface-by-surface investigation to determine the presence of lead-based paint
(see 40 CFR part 745 and Title X of the 1992 Housing and Community Development Act). The sampling
protocols in this chapter fulfill that definition.
2. The client should hire a certified (licensed) lead-based paint inspector or risk assessor (see 40 CFR part 745).
Lists of inspectors and laboratories can be obtained by calling 1-888-LEADLIST or through the Internet at
www.leadlisting.org. Lists are also available through State agencies (call 1-800-LEAD-FYI for the appropriate
local contact). More than half of all States now require a license or certification to perform a lead-based paint
inspection. If the State does not yet have a certification law, an inspector or risk assessor certified under another
State's law should be used. By the fall of 1999, all lead-based paint inspections must be performed by a certified
lead-based paint inspector or risk assessor in accordance with 40 CFR part 745, section 227.
3. The inspector should use the HUD/EPA standard for lead-based paint of 1.0 mg/cm² or 0.5% by weight, as
defined by Title X of the 1992 Housing and Community Development Act. If the applicable standard in the
jurisdiction is different, the procedures in this chapter will need to be modified. For the purposes of the
HUD/EPA lead-based paint disclosure rule, 1.0 milligrams per square centimeter (mg/cm²) or 0.5% by weight are
the standards that must be used.
4. Obtain the XRF Performance Characteristic Sheet for the X-Ray Fluorescence (XRF) lead paint analyzer to be
used in the inspection. It will specify the ranges where XRF results are positive, negative or inconclusive, the
calibration check tolerances, and other important information. Contact the National Lead Information Center
Clearinghouse (1-800-424-LEAD) to obtain the appropriate XRF Performance Characteristic Sheet, or
download it from the Internet at www.hud.gov/lea/leahome.html. XRF Performance Characteristic Sheets have
been developed by HUD and EPA for most commercially available XRFs (see Addendum 3 of this chapter).
5. Report lead paint amounts in mg/cm² because this unit of measurement does not depend on the number of layers
of non-lead-based paint and can usually be obtained without damaging the painted surface. All measurements of

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1997 Revision 7-iii
Step-by-Step Summary
Lead-Based Paint Inspection:
How to Do It
Note: This 1997 Revision replaces Chapter 7 of the 1995 HUD Guidelines for the
Evaluation and Control of Lead-Based Paint Hazards in Housing
1. See Chapters 3, 5 and 16 for guidance on when a lead-based paint inspection is appropriate. A lead-based paint
inspection will determine:
• Whether lead-based paint is present in a house, dwelling unit, residential building, or housing development,
including common areas and exterior surfaces; and
• If present, which building components contain lead-based paint.
The U.S. Department of Housing and Urban Development (HUD) and the U.S. Environmental Protection Agency
(EPA) define an inspection as a surface-by-surface investigation to determine the presence of lead-based paint
(see 40 CFR part 745 and Title X of the 1992 Housing and Community Development Act). The sampling
protocols in this chapter fulfill that definition.
2. The client should hire a certified (licensed) lead-based paint inspector or risk assessor (see 40 CFR part 745).
Lists of inspectors and laboratories can be obtained by calling 1-888-LEADLIST or through the Internet at
www.leadlisting.org. Lists are also available through State agencies (call 1-800-LEAD-FYI for the appropriate
local contact). More than half of all States now require a license or certification to perform a lead-based paint
inspection. If the State does not yet have a certification law, an inspector or risk assessor certified under another
State's law should be used. By the fall of 1999, all lead-based paint inspections must be performed by a certified
lead-based paint inspector or risk assessor in accordance with 40 CFR part 745, section 227.
3. The inspector should use the HUD/EPA standard for lead-based paint of 1.0 mg/cm² or 0.5% by weight, as
defined by Title X of the 1992 Housing and Community Development Act. If the applicable standard in the
jurisdiction is different, the procedures in this chapter will need to be modified. For the purposes of the
HUD/EPA lead-based paint disclosure rule, 1.0 milligrams per square centimeter (mg/cm²) or 0.5% by weight are
the standards that must be used.
4. Obtain the XRF Performance Characteristic Sheet for the X-Ray Fluorescence (XRF) lead paint analyzer to be
used in the inspection. It will specify the ranges where XRF results are positive, negative or inconclusive, the
calibration check tolerances, and other important information. Contact the National Lead Information Center
Clearinghouse (1-800-424-LEAD) to obtain the appropriate XRF Performance Characteristic Sheet, or
download it from the Internet at www.hud.gov/lea/leahome.html. XRF Performance Characteristic Sheets have
been developed by HUD and EPA for most commercially available XRFs (see Addendum 3 of this chapter).
5. Report lead paint amounts in mg/cm² because this unit of measurement does not depend on the number of layers
of non-lead-based paint and can usually be obtained without damaging the painted surface. All measurements of
1997 Revision 7-iv
lead in paint should be in mg/cm², unless the surface area cannot be measured or if all paint cannot be removed
from the measured surface area. In such cases, concentrations may be reported in weight percent (%) or parts per
million by weight (ppm).
6. Follow the radiation safety procedures explained in this chapter, and as required by the U.S. Nuclear Regulatory
Commission and applicable State and local regulations when using XRF instruments.
7. Take at least three calibration check readings before beginning the inspection. Additional calibration check
readings should be made every 4 hours or after inspection work has been completed for the day, or according to
the manufacturer's instructions, whichever is most frequent. Calibration checks should always be done before the
instrument is turned off and again after it has been warmed up (calibration checks do not need to be done each
time an instrument enters an automatic "sleep" state while still powered on).
8. When conducting an inspection in a multifamily housing development or building, obtain a complete list of all
housing units, common areas, and exterior site areas. Determine which can be grouped together for inspection
purposes based on similarity of construction materials and common painting histories. In each group of similar
units, similar common areas, and similar exterior sites, determine the minimum number of each to be inspected
from the tables in this chapter. Random selection procedures are explained in this chapter.
9. For each unit, common area, and exterior site to be inspected, identify all testing combinations in each room
equivalent. A testing combination is characterized by the room equivalent, the component type, and the substrate.
A room equivalent is an identifiable part of a residence (e.g., room, house exterior, foyer, etc.). Painted surfaces
include any surface coated with paint, shellac, varnish, stain, paint covered by wallpaper, or any other coating.
Wallpaper should be assumed to cover paint unless building records or physical evidence indicates no paint is
present.
10. Take at least one individual XRF reading on each testing combination in each room equivalent. For walls, take at
least four readings (one reading on each wall) in each room equivalent. A different visible color does not by itself
result in a separate testing combination. It is not necessary to take multiple XRF readings on the same spot, as
was recommended in the 1990 Interim Guidelines for Public and Indian Housing.
11. Determine whether to correct the XRF readings for substrate interference by consulting the XRF Performance
Characteristic Sheet. If test results for a given substrate fall within the substrate correction range, take readings
on that bare substrate scraped completely clean of paint, as explained in this chapter.
12. Classify XRF results for each testing combination. Readings above the upper limit of the inconclusive range are
considered positive, while readings below the lower limit of the inconclusive range are considered negative.
Readings within the inconclusive range (including its boundary values) are classified as inconclusive. Some
instruments have a threshold value separating ranges of readings considered positive from readings considered
negative for a given substrate. Readings at or above the threshold are considered positive, while readings below
the threshold are considered negative.
13. In single-family housing inspections, all inconclusive readings must be confirmed in the laboratory, unless the
client wishes to assume that all inconclusive results are positive. Such an assumption may reduce the cost of an
inspection, but it will probably increase subsequent abatement, interim control, and maintenance costs, because
laboratory analysis often shows that testing combinations with inconclusive readings do not in fact contain leadbased
paint. Inconclusive readings cannot be assumed to be negative.

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14. In multifamily dwelling inspections, XRF readings are aggregated across units and room equivalents by
component type. Use the flowchart provided in this chapter (Figure 7.1) to make classifications of all testing
combinations or component types in the development as a whole, based on the percentages of positive, negative,
and inconclusive readings.
15. If the inspector collected paint-chip samples for analysis, they should be analyzed by a laboratory recognized
under the EPA's National Lead Laboratory Accreditation Program (NLLAP). Paint-chip samples are collected
when the overall results for a component type are inconclusive. They may be collected by a properly trained and
certified inspector, client, or third party, if permitted by State law. Paint-chip samples should contain all layers of
paint (not just peeled layers) and must always include the bottom layer. If results will be reported in mg/cm²,
including a small amount of substrate with the sample will not significantly bias results. Substrate material should
not, however, be included in samples reported in weight percent. Paint from 4 square inches (25 square
centimeters) should provide a sufficient quantity for laboratory analysis. Smaller surface areas may be used, if the
laboratory indicates that a smaller sample is acceptable. In all cases, the surface area sampled must be recorded.
16. The client or client's representative should evaluate the quality of the inspection using the procedures in this
chapter.
17. The inspector should write an inspection report indicating if and where lead-based paint is located in the unit or
the housing development (or building). The report should include a statement that the presence of lead-based
paint must be disclosed to potential new buyers (purchasers) and renters (lessees) prior to obligation under a sales
contract or lease, based on Federal law (see 24 CFR part 35, subpart H or 40 CFR part 745, subpart F). The
suggested language below may be used. The inspection report should contain detailed information on the
following:
• Who performed the inspection;
• Date(s);
• Inspector's certification number;
• All XRF readings;
• Classification of all surfaces into positive or negative (but not inconclusive) categories, based on XRF and
laboratory analyses;
• Specific information on the XRF and laboratory methodologies;
• Housing unit and sampling location identifiers;
• Results of any laboratory analyses; and
• Additional information described in Section IV of this chapter.
This chapter also contains language that may be used in an inspection report in the case where no lead-based paint has
been identified (see the suggested language below).

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