Lead Paint Inspection and Risk Assessment Guide
XRF vs. paint chip sampling, HUD protocols, dust wipe standards, when inspections vs. risk assessments are required, and clearance testing.
Types of Lead Evaluations
Lead Inspection
A surface-by-surface investigation using XRF or paint chip sampling to determine whether lead-based paint is present on each painted surface in a building. The inspector tests every distinct painted surface and reports whether each is positive or negative for lead-based paint.
A lead inspection answers the question: “Where is the lead-based paint?” It does not assess condition, exposure risk, or recommend actions.
Lead Risk Assessment
A broader evaluation that includes everything in an inspection plus assessment of lead hazards from dust, soil, and water. A risk assessment identifies lead hazards that require intervention and recommends response actions (abatement, interim controls, or monitoring).
A risk assessment typically includes:
- Visual assessment of paint condition on all surfaces
- XRF or paint chip testing of deteriorated paint and impact/friction surfaces
- Dust wipe sampling on floors and window sills
- Soil sampling from bare soil areas (particularly near building perimeter, play areas, and drip lines)
- Assessment of water lead levels when relevant
- Written report with findings and recommended response actions
Lead Hazard Screen
A limited risk assessment that involves less sampling than a full risk assessment. If any lead hazard is found during a screen, a full risk assessment must be conducted. Lead hazard screens are less common in practice but are allowed under federal and Ohio regulations.
Sampling Methods
X-Ray Fluorescence (XRF)
XRF analyzers are portable instruments that measure lead content in paint by directing X-rays at the painted surface and measuring the fluorescent X-rays emitted by lead atoms. Results are reported in mg/cm2.
Advantages:
- Non-destructive (no paint removal needed)
- Rapid results (readings in seconds)
- Can test in place without removing components
- Preferred method for large-scale inspections
Limitations:
- Requires calibration and quality control procedures
- Substrate effects can influence readings (some substrates produce false positives or negatives)
- Readings near the 1.0 mg/cm2 threshold may be inconclusive and require additional testing
- XRF analyzers must meet EPA performance characteristic requirements
- Operators must understand instrument-specific performance and limitations
Lead-based paint threshold: 1.0 mg/cm2 or greater
Paint Chip (Laboratory) Sampling
Physical removal of a paint chip sample for laboratory analysis. The sample must include all layers of paint down to the substrate. Analysis is performed by an approved environmental lead analytical laboratory.
Advantages:
- Definitive results not subject to substrate interference
- Identifies lead content by weight percent
- Can analyze individual paint layers if needed
Limitations:
- Destructive (paint must be removed from the surface)
- Slower turnaround (depends on lab processing time)
- Requires careful sample collection to include all paint layers
- More expensive per sample than XRF
Lead-based paint threshold: 0.5% by weight (5,000 ppm) or greater
Dust Wipe Sampling
Surface dust samples collected by wiping a measured area with a pre-moistened wipe. Used during risk assessments to evaluate dust-lead hazards and during clearance testing after abatement or renovation. Analysis is performed by an approved laboratory.
Sampling areas: Floors, interior window sills, and window troughs
Current EPA action levels (effective January 12, 2026):
| Surface | Action Level |
|---|---|
| Floors | 5 ug/ft2 |
| Interior window sills | 40 ug/ft2 |
| Window troughs | 100 ug/ft2 |
Dust-lead reportable levels: As of the October 2024 EPA rule, any detectable level of lead in dust reported by an accredited laboratory is considered a reportable level for risk assessment purposes. This is a significant change from the previous numeric thresholds.
Important: Composite dust wipe samples are prohibited under Ohio law (OAC 3701-32-03). Each wipe must be analyzed individually.
Soil Sampling
Soil samples collected from bare soil areas around the building, particularly near the foundation (drip line), play areas, and high-traffic areas. Used during risk assessments to evaluate soil-lead hazards.
EPA soil-lead hazard standard: 400 ug/g (ppm) for play areas; previously 1,200 ug/g for the rest of the yard (under review - EPA’s October 2024 proposal may further lower these thresholds).
EPA residential soil screening level (CERCLA/RCRA sites): 200 ppm (lowered from 400 ppm in January 2024).
HUD Requirements
The U.S. Department of Housing and Urban Development (HUD) Lead Safe Housing Rule (24 CFR 35{target=“_blank”}) establishes requirements for lead-based paint evaluation and hazard control in federally assisted housing. The specific requirements depend on the type of federal assistance and the dollar amount of rehabilitation:
- Housing receiving up to $5,000 in federal rehab assistance: Paint stabilization and clearance
- $5,000 to $25,000: Risk assessment and interim controls
- Over $25,000: Risk assessment and abatement of all lead-based paint hazards
HUD requirements work alongside (not in place of) EPA and state regulations. When HUD and EPA/state standards conflict, Ohio law requires compliance with the more stringent standard (OAC 3701-32-03(B)).
Clearance Testing
Clearance testing is required after lead abatement to verify that lead hazards have been adequately controlled. In Ohio, clearance after abatement must be performed by a licensed lead inspector or lead risk assessor (not a clearance technician - clearance technicians can only perform clearance on non-abatement projects).
Clearance consists of:
- Visual assessment - the work area must be free of visible dust, debris, and paint chips
- Dust wipe sampling - samples collected from floors, window sills, and window troughs in the clearance area
- Comparison to action levels - results must be below EPA action levels
If clearance fails, additional cleaning must be performed and clearance testing repeated until results pass.
Resources
- EPA Lead Hazard Standards - Current dust-lead and soil-lead standards
- HUD Office of Lead Hazard Control and Healthy Homes - Lead Safe Housing Rule and enforcement resources
- HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards
- Ohio Lead Program Overview
- Ohio Lead Licensing and Certification
- Lead Standards Quick Reference
Frequently Asked Questions
What is the difference between a lead inspection and a lead risk assessment?
A lead inspection is a surface-by-surface investigation to determine whether lead-based paint is present. It answers a yes/no question for every painted surface. A lead risk assessment evaluates lead hazards from all sources (paint, dust, soil, water), assesses their condition and likelihood of causing exposure, and recommends response actions. A risk assessment typically includes a paint inspection, dust wipe sampling, and soil sampling.
When is a lead inspection required?
Lead inspections or risk assessments are commonly required in several situations: HUD-assisted housing transactions and programs, pre-renovation work in pre-1978 housing (to determine if RRP Rule applies), real estate transactions involving pre-1978 properties (disclosure requirements), child lead poisoning investigations, and abatement project design.
Can I use a home test kit for a lead inspection?
Under Ohio law (OAC 3701-32-03), chemical test kits are prohibited for lead inspections and risk assessments. Inspections must use either X-ray fluorescence (XRF) analysis or paint chip sampling analyzed by an approved laboratory. EPA-recognized lead test kits may be used by certified renovators under the RRP Rule to determine whether lead-based paint is present before renovation, but this is not the same as a lead inspection.