Lead-based paint inspector

Marianna Koval, J.D., licensed lead-based paint inspector/risk assessor. Lead Safe Home, Inc., Brooklyn... 

According to the NAHB survey, an EPA-certified lead-based paint inspector confirmed the presence of lead-based paint in all of the properties considered for this survey. Previous inspection reports were consulted if the inspections conformed to the HUD guidelines for lead-based paint inspections. Properties used in this survey included a single-family home in Illinois, two singlefamily homes and a duplex in Connecticut, and an apartment above a storefront in Wisconsin. 

Another commonly cited reason for not supporting the use of test kits by certified renovators was the lack of any sampling protocol in the regulation. A related concern was that the training in sampling techniques and protocols in the lead-based paint inspector course could not be shortened to fit within the 8-hour renovator course and still retain all of the necessary information. EPA wishes to make it clear that the 8-hour renovator course will not train renovators in how to select components for sampling because the certified renovator must use a test kit on each component affected by the renovation. The only exception to this is when the components make up an integrated whole, such as the individual stair treads and risers in a staircase. 

Another study, sponsored by HUD, on the use of sodium sulfide to detect lead in paint is being carried out at NIST. The objectives of this study include (1) investigating additional candidate procedures for carrying out a field chemical test and (2) determining estimates of the precision and accuracy of a potential candidate alternative procedure and a swab spot test procedure, when carried out by trained lead-based paint inspectors. 

Final regulations promulgated under paragraph (1) shall contain specific requirements for the accreditation of lead-based paint activities training programs for workers, supervisors, inspectors and planners, and other individuals involved in lead-based paint activities, including, but not limited to, each of the following ... 

It seems that the inspector noticed the repair work your crews were doing and became concerned. As a trained, experienced inspector, he knew the house was likely to contain lead-based paint. He decides a risk assessment is in order. (See Table 1.1 for an example of available statistics for a risk assessment.) The inspector told the homeowners about his concern for the family,... 

List names of individuals who have responsibility for lead-based paint. Include owner, property manager (if applicable), maintenance supervisor and staff (if applicable), and others. Include any training in lead hazard control work (by inspector, supervisor, worker, etc.) that has been completed. Use additional pages, if... 

In keeping with the 2006 Proposal and the 2007 Supplemental Proposal, this final rule exempts renovations that affect only components that a certified inspector or risk assessor has determined are free of paint or other surface coatings that contain lead equal to or in excess of l.Omg/cm or 0.5% by weight. These standards are from the definition of lead-based paint in Title X and in EPA s implementing regulations. Nearly all of the commenters that expressed an opinion on this topic favored this... 

Some commenters expressed confusion over the mechanics of this exception. The certified inspector or risk assessor determines whether components contain lead-based paint, while the renovation firm is responsible for determining which components will be affected by the renovation. A renovation firm may rely on the report of a past inspection or risk assessment that addresses the components that will be disturbed by the renovation. 

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