2.6 Lead Hazard Screen Protocol (40 CFR 745.227(c))
Key Takeaways
A lead hazard screen may be conducted only by a certified risk assessor under 40 CFR 745.227(c).
Screens require background information, a visual inspection to find deteriorated paint and at least two dust-sampling locations, testing of deteriorated paint in poor condition with distinct painting histories, and composite dust sampling.
In residential dwellings, collect two composite dust samples—one from floors and one from windows—in rooms/hallways/stairwells where children under 6 are most likely to contact dust; multi-family/COF screens also sample child-use common areas.
The screen report includes the risk-assessment report elements in 745.227(d)(11)(i)–(xiv) plus background information, but excludes (d)(11)(xv)–(xviii); it must recommend a follow-up full risk assessment when warranted.
A lead hazard screen is a limited evaluation—not a substitute for a full risk assessment when comprehensive hazard characterization and prioritized control options are required.
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
| Element | Lead Hazard Screen (745.227(c)) | Full Risk Assessment (745.227(d)) |
|---|---|---|
| Who may perform | Certified risk assessor only | Certified risk assessor only |
| Paint testing focus | Deteriorated paint in poor condition with distinct painting histories | Friction/impact deteriorated surfaces and other deteriorated paint per (d)(4) |
| Dust sampling | Two composites (floors + windows) in child-use areas; plus common areas in multi-family/COF | More comprehensive floor and sill sampling (composite or single-surface) |
| Soil sampling | Not the core screen protocol focus in (c) | Soil sampling in play areas, driplines, and bare yard areas as specified in (d) |
| Report contents | (d)(11)(i)–(xiv) + background; excludes (d)(11)(xv)–(xviii); may recommend follow-up RA | Full (d)(11)(i)–(xviii), including hazard descriptions and prioritized controls |
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:
- Information required in a risk assessment report under (d)(11)(i) through (d)(11)(xiv)
- Background information collected under (c)(2)(i)
- Exclude (d)(11)(xv) through (d)(11)(xviii) from the screen report template
- 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:
- Interview confirms child plays in living room and rear bedroom; chews living-room sill.
- Visual inspection finds deteriorated paint on living-room sill and bedroom window trough area; selects those rooms plus hallway for dust locations.
- XRF/paint-chip testing confirms LBP on the deteriorated sill.
- 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.
- 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
Who is authorized to conduct a lead hazard screen under 40 CFR 745.227(c)?
Any certified lead inspector
Only a person certified as a risk assessor
Any certified abatement supervisor
Any dust sampling technician
In a single-family residential dwelling lead hazard screen, which dust samples are specifically required?
One single-surface trough sample only
Two composite dust samples—one from floors and one from windows—in child-use rooms/hallways/stairwells
Soil cores from every bare yard quadrant and no dust wipes
Air cassettes at the HVAC return for eight hours
Compared with a full risk assessment report, which statement about a lead hazard screen report is correct?
It must include all of 745.227(d)(11)(i)–(xviii) plus a full abatement design specification
It includes (d)(11)(i)–(xiv) and background information, excludes (d)(11)(xv)–(xviii), and must recommend a follow-up risk assessment when warranted
It requires no laboratory analysis of dust samples
It may be signed by an uncertified renovation firm owner
In a multi-family building lead hazard screen, what additional dust sampling is required beyond the dwelling-unit floor and window composites?
No additional sampling is ever required
Composite dust samples from common areas where children under 6 are most likely to contact dust
Only exterior porch clearance wipes after painting
Only potable-water first-draw samples from each unit
Sections you finish are checked off in the contents.