2.6 Lead Hazard Screen Protocol (40 CFR 745.227(c))

2.6 Lead Hazard Screen Protocol (40 CFR 745.227(c))

A lead hazard screen is a limited on-site evaluation used to decide whether a property is unlikely to have lead-based paint hazards or whether a full risk assessment is warranted. Under 40 CFR 745.227(c)(1), only a person certified as an EPA (or authorized-program) risk assessor may conduct a lead hazard screen.

Screen vs. Full Risk Assessment

Mandatory Screen Sequence

1. Background information — 745.227(c)(2)(i)

Collect the same style of building/occupant-use background required for risk assessments: physical characteristics and use patterns that may expose children under 6.

2. Visual inspection — 745.227(c)(2)(ii)

• Determine whether deteriorated paint is present
• Locate at least two dust sampling locations

3. Paint testing — 745.227(c)(2)(iii)

If deteriorated paint is present, test each surface that is in poor condition and has a distinct painting history, using documented methodologies (XRF and/or paint-chip laboratory analysis with QC).

4. Dust sampling — 745.227(c)(2)(iv)–(v)

Residential dwellings: collect two composite dust samples:

• One composite from floors
• One composite from windows in rooms, hallways, or stairwells where children under 6 are most likely to contact dust.

Multi-family dwellings and child-occupied facilities: in addition to the floor and window composites above, collect composite dust samples from common areas where children under 6 are most likely to contact dust.

All dust samples must use documented methodologies with adequate QC and must be analyzed by a recognized laboratory under 745.227(f) for quantifiable lead results.

Interpreting Screen Results

Because on/after January 12, 2026 a dust-lead hazard is any reportable level on floors/sills, screen dust detections are highly informative. Historically, many programs used conservative screen decision rules (for example recommending a full risk assessment when screen dust loadings were elevated relative to then-current numeric standards). Under the current rule, the regulatory text requires the screen report to include recommendations, if warranted, for a follow-up risk assessment and further actions. In practice:

• Reportable dust-lead on floor or window composites supports recommending a full risk assessment and interim cleaning discussion
• Multiple deteriorated LBP surfaces support expanding to full risk-assessment paint/dust/soil characterization
• "Clean" non-detect dust composites with no deteriorated LBP may support a conclusion that hazards are unlikely—but document limitations of the limited screen scope

Screen Report Contents — 745.227(c)(5)

The lead hazard screen report must include:

1. Information required in a risk assessment report under (d)(11)(i) through (d)(11)(xiv)
2. Background information collected under (c)(2)(i)
3. Exclude (d)(11)(xv) through (d)(11)(xviii) from the screen report template
4. Recommendations, if warranted, for a follow-up risk assessment and other appropriate actions

Exam trap: Do not claim that a hazard screen authorizes skipping certified-risk-assessor status, soil evaluation forever, or full report recommendations when a follow-up risk assessment is clearly warranted.

When Clients Choose a Screen

Screens are often selected for:

• Pre-purchase limited evaluations when parties want a fast indicator
• Portfolio triage before funding full risk assessments
• Situations where deteriorated paint and dust evidence are expected to be minimal

If the client needs prioritized interim-control vs. abatement options, encapsulant monitoring schedules, or comprehensive soil characterization, commission a full risk assessment instead of stopping at a screen.

Worked Screen Scenario

Property: 1952 single-family target housing; one 3-year-old resident. Screen actions:

1. Interview confirms child plays in living room and rear bedroom; chews living-room sill.
2. Visual inspection finds deteriorated paint on living-room sill and bedroom window trough area; selects those rooms plus hallway for dust locations.
3. XRF/paint-chip testing confirms LBP on the deteriorated sill.
4. Collects one floor composite (living room + bedroom + hallway floors) and one window composite (living-room and bedroom sills) using documented wipe methods and QC blanks.
5. NLLAP results show reportable lead on both composites.

Conclusion: Recommend a full risk assessment and discuss interim specialized cleaning / sill treatment options pending the fuller evaluation. The screen report cites 745.227(c)(5) follow-up recommendations and includes items (d)(11)(i)–(xiv) plus background notes.

Documentation Pitfalls

• Labeling a full risk assessment as a "screen" to reduce scope
• Omitting common-area composites in multi-family/COF screens
• Mixing floor and window wipes into one illegal composite
• Claiming screens may be performed by inspectors-only credentials