18.1 Dust-Lead Action Levels vs Reportable-Level Hazards

Two number systems, one mop

Quick Answer: On or after January 12, 2026, 40 CFR 745.227(e)(8)(viii) sets dust-lead action levels at 5 µg/ft² on floors, 40 µg/ft² on interior window sills, and 100 µg/ft² on window troughs. Before that date the same paragraph used 10 / 100 / 400. Action levels (745.223) are the post-abatement dust values that must be beaten for the abatement to complete when dust sampling is required. EPA previously called them clearance levels. A dust-lead hazard on floors and interior sills is now any reportable level (745.227(h)(3); 745.65(b)). Completing the job still requires dust below the action levels. A floor wipe of 4 µg/ft² that the lab reported as 4 (not as less-than) can finish abatement and still be a hazard.

Chapter 14 was how you clean and when the visual gate stops you. This section is the scoreboard the inspector or risk assessor will hold up after those wipes. Curriculum topic 745.225(d)(3)(xi) is action levels and testing. If you walk into the third-party exam still carrying 40 / 250 / 400 from an old HUD table, or 10 / 100 / 400 from a 2025 handout, you will miss the item even if you know every HEPA pass.

Today is after January 12, 2026. Teach and test 5 / 40 / 100 as current. The older rows exist so you can recognize a wrong option, not so you can keep using them on a 2026 job.

Current versus historical numbers

Dust is reported as loading — micrograms of lead per square foot of wiped surface — not as a soil-style ppm. Compare every post-abatement wipe to the action level for that component type.

Equals or exceeds fails. A floor at 5.0 µg/ft² is not a generous pass because it "hit the number." It equals the action level. Reclean and retest the floors that sample represents (Section 18.3). Below 5 is the completion test for floors.

Units. Action levels are µg/ft², not mg/cm² (that is XRF paint) and not ppm (that is soil: play area 400 ppm, rest of yard 1,200 ppm under 745.227(h)(4)). A distractor that puts 5 ppm on a floor wipe is mixing languages.

Action levels are not "clearance levels" anymore — and they are not hazards

745.223 defines action levels as the values that indicate the amount of lead in dust on a surface following completion of an abatement activity. To complete abatement when dust sampling is required, values below these levels must be achieved. The same definition states, in one sentence you should be able to quote: EPA previously used the term "clearance levels" to refer to these levels.

So:

• Field slang and HUD Guidelines still say clearance. That is the same event: independent inspector or risk assessor visual plus dust wipes after final cleanup.
• The regulation's name for the numeric bar is action levels. An exam item that asks for the 745.223 term wants action levels, not "clearance standards," "hazard standards," or "reportable levels."
• Abatement itself is defined as permanent elimination of lead-based paint hazards, and in the case of dust-lead hazards to below the action levels (745.223). Dust-lead abatement is not "get every lab to print ND." It is below 5 / 40 / 100 on the sampled floors, interior sills, and troughs.

Hazard is a different legal switch. 745.65(b) and 745.227(h)(3)(i) say that on or after January 12, 2026, a dust-lead hazard is present in a residential dwelling or child-occupied facility on floors and interior window sills when the lead loading for any single-surface or composite sample is equal to or greater than any reportable level of dust-lead for those surfaces. Reportable level (745.63) is the lowest analyte concentration (or amount) that does not contain a "less than" qualifier and that is reported with confidence for a specific method by a laboratory recognized by EPA under TSCA section 405(b) — an NLLAP lab.

The reportable level is not a number EPA printed next to 5 / 40 / 100. It moves with the lab's method. Supervisors do not invent "the reportable level is always 4." They read whether the laboratory reported a value with confidence and without a less-than.

Troughs sit on the action-level row, not on the 2026 hazard sentence. 745.227(h)(3) names floors and interior window sills for the reportable-level hazard. Troughs still have a 100 µg/ft² action level. A trough at 60 µg/ft² is below 100 (the job can complete for that trough) even though 60 is a real laboratory number. Do not import the "any reportable level" hazard sentence onto troughs, and do not drop troughs from post-abatement testing because they are missing from the hazard clause.

Why a 4 µg/ft² floor can still be a hazard while the job completes

This is the 2026 exam's favorite collision, and it is not a trick if you keep the two columns apart.

Worked example — 4 µg/ft² floor. Final cleanup is done. Visual passed. The hour ran (Section 18.2). The NLLAP report for the living-room floor is 4 µg/ft², printed as 4, not as <5 or <4. Interior sills are <20 or similarly less-than. Troughs are 30 µg/ft².

• Action levels: 4 is below 5. 30 is below 100. Less-than sill results are not ≥40. Dust sampling does not fail. The abatement may complete for those components (745.227(e)(8)(vii)–(viii); 745.223).
• Hazard: 4 µg/ft² on a floor is a reportable level. On or after January 12, 2026 that floor has a dust-lead hazard (745.227(h)(3)(i)). Occupants are not moving into a "lead-free" room. The certified supervisor or project designer still writes the abatement report, and because results are below action levels and at or above reportable levels, the mandatory dust-lead hazard statement in 745.227(e)(10)(vii) belongs in that report (Section 18.4).

Worked example — 5.0 µg/ft² floor. Same room, lab reports 5.0 µg/ft². That equals the action level. Fail. Reclean and retest the floors represented. Do not attach the 2026 statement and call it complete. The statement is for jobs that already got below action levels and still have reportable dust. It is not a sticker you put on a failed wipe.

Worked example — floor reported as <4 µg/ft². The lab's reporting limit for that method is 4, and the result is <4 µg/ft². That print does not contain a reportable number at or above a reportable level; it is a less-than. It is also below the 5 µg/ft² action level. The job can complete. Whether the (e)(10)(vii) statement is triggered depends on other samples (a reportable sill, another floor). Do not treat every less-than as a hidden 4.0 that you compare to 5.

Worked example — owner wants "zero." The contract said "eliminate all lead dust." The legal completion test in 745.223 / 745.227 is below action levels, not a blank chromatogram. You still clean as hard as Chapter 14 requires. You do not hold the keys until every result is ND unless the contract added that specification. You also do not tell the owner the unit has no dust-lead hazard when a floor came back reportable at 3 or 4 µg/ft².

What the supervisor does with this split — and the exam traps

You do not collect the wipe (Section 18.2). You do use the scoreboard:

1. Train and clean to 5 / 40 / 100, not to a visual empty floor and not to 10 / 100 / 400.
2. When the laboratory packet arrives, sort each row into below action level, equals or exceeds action level (reclean / retest), and reportable but below action level (job can complete; hazard statement may apply).
3. Do not brief the owner that "clearance means no hazard." After January 12, 2026 that sentence is false for floors and interior sills.
4. Do not skip troughs because the hazard definition names floors and sills. Troughs still have to come in below 100 µg/ft².

Exam traps for this section:

• 40 / 250 / 400 as "the EPA numbers." Retired. Wrong.
• 10 / 100 / 400 as current. That row died on January 12, 2026.
• Any reportable level fails the job. That confuses hazard with action level. Reportable-and-below-5 can complete.
• 5 / 40 / 100 are the new hazards. No. They are the action levels. The hazard on floors and sills is any reportable level.
• Action level and OSHA action level are the same idea. OSHA's 30 µg/m³ air action level (29 CFR 1926.62) is not a dust wipe. Do not mix µg/ft² dust with µg/m³ air.

Official sources: 40 CFR 745.227(e)(8)(viii), (h)(3) (current 5 / 40 / 100 action levels; reportable-level dust-lead hazard on floors and interior sills; post-abatement still below action levels); 40 CFR 745.223 (action levels; former term clearance levels; abatement of dust-lead to below action levels); 40 CFR 745.63 (reportable level); 40 CFR 745.65(b) (dust-lead hazard).