2.5 Background Information Collection for Risk Assessments

2.5 Background Information Collection for Risk Assessments

A lead risk assessment is not a paint survey alone. Under 40 CFR 745.227(d)(3), the certified risk assessor must collect background information about:

1. The physical characteristics of the residential dwelling or child-occupied facility; and
2. Occupant use patterns that may cause lead-based paint exposure to one or more children under age 6.

Those facts are not optional narrative. They determine where dust and soil samples are collected, which deteriorated components are highest priority, and what control options are realistic for the household. The same background package must appear in the final report under 40 CFR 745.227(d)(11)(xv).

Why Background Collection Matters on the Exam and in the Field

Physical-Characteristic Checklist

Collect and document at least:

• Construction date (pre-1978 target housing / COF status)
• Building type (single-family, multi-family unit, common areas, child-occupied facility rooms)
• Recent renovation, remodeling, or repainting history and whether work used lead-safe practices
• Prior lead inspection, risk assessment, or hazard-screen reports (and whether hazards were controlled)
• Known or presumed lead-based paint locations from owner records or previous XRF/chip data
• Maintenance practices (unit turnover painting, window operation, HVAC filtration, housekeeping frequency)
• Site features affecting soil pathways (bare play areas, dripline soil, gardens, sandboxes)

Occupant-Use Interview Topics

Interview the owner, adult occupant, or facility operator about:

• Ages and primary rooms used by children under 6
• Presence of pregnant occupants
• Where children play indoors and outdoors
• Window/door operation habits (friction dust generation)
• Observed chewing/mouthing of painted surfaces (window sills, railings, stair edges)
• Pets that track soil indoors
• Any elevated blood lead level (EBLL) findings or public-health case management involvement
• Cleaning routines and whether HEPA/wet cleaning is used

Exam distinction: Lead inspectors focus on presence/location of LBP. Risk assessors must connect building conditions to who is exposed and how. Background interviews are the bridge.

Turning Background Data into a Sampling Plan

Example workflow:

1. Interview identifies a 2-year-old whose primary spaces are the living room, bedroom, and rear patio play area.
2. Visual assessment concentrates on deteriorated paint and friction surfaces in those rooms.
3. Dust wipes prioritize living-room and bedroom floors plus accessible window sills in those rooms.
4. Soil sampling prioritizes the bare patio play area (400 ppm play-area hazard threshold) and dripline soil if bare.
5. Report narrative cites the interview findings when prioritizing immediate specialized cleaning and play-area soil cover.

Multi-Family and Child-Occupied Facilities

In multi-family housing and COFs, background collection expands to:

• Common-area use by children (lobbies, corridors, playrooms)
• Unit turnover and vacancy status
• Building-wide maintenance contracts
• Prior building-wide inspections or hazard-control programs

Common areas where children under 6 contact dust must be considered for dust sampling during full risk assessments and, when required, during lead hazard screens.

Documentation Standard

Retain interview notes, owner questionnaires, prior reports, floor plans annotated with child-use rooms, and photographs supporting occupancy claims. Incomplete background files are a frequent audit finding and can invalidate the usefulness of an otherwise complete laboratory package.

Sample Owner/Occupant Questionnaire (Field Template)

Use a consistent questionnaire so interviews are reproducible across assessors:

1. Year built / major additions?
2. Any known lead inspection or risk assessment reports on file?
3. Dates and rooms of renovation, window replacement, or sanding in the last 12 months?
4. Ages of children who live in or regularly visit the unit?
5. Primary indoor play rooms and outdoor play locations?
6. Do children chew painted surfaces (sills, railings, stair edges)?
7. Any pregnant occupants?
8. Any child with elevated blood lead level or public-health case management?
9. Cleaning methods used (dry sweeping, vacuum type, wet mopping)?
10. Pets with outdoor access that track soil indoors?

Attach the completed questionnaire to the project file and summarize key answers in the report narrative required by 40 CFR 745.227(d)(11)(xv).

Common Field Failures to Avoid

• Sampling the formal living room while the toddler actually lives in a basement playroom
• Ignoring vacant units' future occupancy plans in HUD-assisted turnovers
• Failing to ask about occupational take-home dust from battery/recycling/construction work
• Collecting excellent laboratory data but omitting background narrative from the report

Background collection is scored on exams because it separates paint surveyors from true risk assessors who evaluate exposure pathways.