7.3 Lead Hazard Screens vs Full Risk Assessments
Key Takeaways
- A lead hazard screen may be conducted only by a certified risk assessor (40 CFR 745.227(c)(1)). A person certified only as an inspector, and a certified supervisor, cannot perform a screen.
- A screen is limited: background and occupant-use patterns for children under 6; a visual for deteriorated paint; paint testing only of deteriorated surfaces in poor condition with a distinct painting history; two composite dust samples (floors and windows) where children under 6 are most likely to contact dust; plus common-area composites in multi-family dwellings and child-occupied facilities. Soil sampling is not required.
- The screen report includes identifying information and limited results and may recommend a follow-up full risk assessment. It is not required to include the full RA's location/type/severity narrative or the interim-control and abatement options with encapsulant/enclosure monitoring schedules (745.227(c)(5) excluding (d)(11)(xv)–(xviii)).
- A screen is not a green light to skip abatement planning. When the screen says a full RA is recommended, do not treat the screen as a complete hazard map or a work order.
- Do not start abatement off a screen alone unless the owner has separately scoped certified abatement of identified lead-based paint (for example, replacing windows the screen or an inspection actually tested as LBP). Unsampled soil, untested 1.5 ft² deteriorated patches, and unsampled rooms are not in that scope.
A screen is a limited look, not a smaller risk assessment
Quick Answer: A lead hazard screen shall be conducted only by a certified risk assessor (40 CFR 745.227(c)(1)). It is a limited evaluation: background on the building and how children under 6 use it; a visual for deteriorated paint and for at least two dust-sampling locations; paint testing only of deteriorated surfaces that are in poor condition and have a distinct painting history; two composite dust samples (one floors, one windows) where children under 6 are most likely to contact dust; plus common-area composites in multi-family dwellings and child-occupied facilities. The screen report may recommend a follow-up full risk assessment. It is not a green light to skip abatement planning, and it is not a complete hazard map. Do not start abatement off a screen alone unless the owner has separately scoped certified abatement of identified LBP.
Inspectors who are not risk assessors cannot perform a screen. Supervisors cannot perform a screen. A screen is still a lead-based paint activity under 745.227(a)(2) — if someone labels the visit a screen, it must meet (c). Calling a walkthrough a screen does not make it one.
Side-by-side: inspection, screen, full RA
| Feature | Inspection (b) | Lead hazard screen (c) | Full risk assessment (d) |
|---|---|---|---|
| Who | Certified inspector or risk assessor | Certified risk assessor only | Certified risk assessor only |
| Question answered | Is LBP present on each distinct-history component? | Might hazards be present in a limited look? | Where are the hazards, how severe, and what are the control options? |
| Paint testing | Each interior and exterior component with distinct painting history, except post-1978 replacements or determined not LBP; common areas in multi-family/COF | Only deteriorated paint in poor condition with a distinct painting history | Friction/impact with visibly deteriorated paint and all other visibly deteriorated paint |
| Dust | Not required for an inspection | Two composites: floors and windows, where children under 6 most likely contact dust; plus common-area composites in multi-family/COF | Sills and floors in living areas used by children under 6; extra common-area and COF room/hall/stair samples |
| Soil | Not required | Not required | Bare soil in play areas, rest of yard, and dripline/foundation |
| Report options | Presence/absence table in method-appropriate units | May recommend follow-up RA and further actions; does not have to include the full RA's hazard-severity narrative or control-option/monitoring sections | Must include location/type/severity and interim and/or abatement options with prioritization and encapsulant/enclosure monitoring |
Poor condition (Chapter 6.1) is the screen's paint-testing gate: more than 2 ft² interior large, 10 ft² exterior large, or 10% of a small component. A 1.5 ft² peeling living-room wall can go untested on a screen. That is a screen limitation, not a finding that the patch is safe. A full RA would test that visibly deteriorated film.
Composite dust on a screen is two samples, not a room-by-room map. 745.227(g) still applies: at least two subsamples, every component being tested included, and do not mix component types (floors and windows stay separate composites). A single blended house-dust number is not a screen.
No soil. A screen can miss a 900 ppm play area entirely. Starting the abatement from a screen that never sampled the sandbox is how children keep eating the yard while the windows get replaced.
What the screen report is required to contain — and what it leaves out
745.227(c)(5)(i) points to the RA report list (d)(11)(i) through (xiv) — identity of the property, the assessor, the laboratory, visual results, paint-testing method and locations, XRF quality-control data and serial number, and laboratory results — and excludes (d)(11)(xv) through (xviii). Background collected under (c)(2)(i) is added back. Then (c)(5)(ii) requires recommendations, if warranted, for a follow-up risk assessment, and as appropriate any further actions.
Read the exclusion. A screen is not required to include:
- The full RA's (xvii) description of location, type, and severity of identified LBP hazards
- The full RA's (xviii) interim controls and/or abatement options with prioritization and encapsulant/enclosure monitoring schedules
That is why you cannot write a complete hazard-based work plan off a screen the way Section 7.2 taught you to write one off an RA. The document is allowed to stop at limited results plus I recommend a full risk assessment.
Two exam traps — both fail the same way
Trap 1 — Full RA recommended, and the owner wants abatement Monday. The screen found deteriorated paint in poor condition on two windows and a floor-dust composite that is reportable. The assessor wrote follow-up risk assessment recommended. That sentence is doing its regulatory job. It is not a scope of work. It is not a finding that soil is clean. It is not permission to skip the OPP, the five-business-day notice, or method documentation. Do not start a hazard-based abatement off that screen alone. Get the full RA, then translate options as in Section 7.2.
Exception the exam will also test: the owner may separately scope certified abatement of identified LBP. Example: a complete inspection (or even the screen's two poor-condition windows that tested as LBP) plus a contract that says the certified firm shall permanently eliminate those identified LBP components — replace those window assemblies; take dust below action levels. Inspection answers presence; abatement can proceed on identified LBP the owner chose to eliminate permanently. A screen's two tested windows are not a whole-house hazard map. Do not expand those two sashes are LBP into untested soil, untested 1.5 ft² patches, and unsampled bedrooms just because a screen exists.
Trap 2 — treating a clean-looking screen as a pass to skip planning. The visual found no poor-condition paint, both composites are non-detect, and the assessor did not recommend a full RA. That is still not clearance. It is not a finding of no LBP in the building. It is not a finding of no soil-lead hazard. Intact LBP on friction sashes can still grind dust after the screen date. If the owner later wants abatement, you still need a real presence determination (inspection) and/or a full RA, plus OPP, notice, and inspector or risk-assessor post-abatement testing. A screen is not a green light to skip abatement planning when abatement is the job.
Supervisor actions when the file is only a screen
| What the screen says | What you do | What you do not do |
|---|---|---|
| Follow-up full RA recommended | Stop the hazard-based abatement-planning clock until a (d) RA is in the file, unless the owner has a separate, written abatement scope limited to identified LBP | Write an OPP for all hazards in the unit off two composites and two windows |
| Two poor-condition windows tested LBP; no soil data | If separately scoped, you may abate those windows as identified LBP under Subpart L | Assume the play area is fine; assume other deteriorated paint is non-LBP |
| Composites non-detect; no poor-condition paint | Treat it as a limited look. If the owner wants abatement or a hazard-based plan, get inspection and/or a full RA | Declare the property lead-free, skip notice, or self-clear |
| Screen signed by a person certified only as an inspector | It is not a 745.227(c) screen | Use it as if (c) were satisfied |
| Owner asks you to finish the screen with supervisor soil samples | Refuse. 745.227(f) | Collect soil, dust, or chips |
You will still use a proper inspection or RA, when you have one, to write the OPP, select methods, notify, and prepare the abatement report. You will still not collect clearance dust. A screen does not change 745.227(e)(8) or (f). It only changes how little you know until the full RA arrives.
Worked example — three files, three decisions. File A is a screen that recommends a full RA after a reportable floor composite. The owner says start abatement of the whole house Monday. Stop. Get the RA unless a separate contract already names specific identified LBP components to abate. File B is the same screen plus a contract to replace the two poor-condition living-room windows that tested as LBP, as certified abatement, with dust below action levels. Those windows can proceed as identified-LBP abatement; the sandbox is still not in the scope. File C is a full RA with play-area soil at 850 ppm and friction windows. Now Section 7.2 applies: you cannot drop the play area from an abatement contract that is designed to eliminate the identified hazards.
Under 40 CFR 745.227(c), who may conduct a lead hazard screen, and what sampling does a screen require?
A lead hazard screen finds two poor-condition windows that test as lead-based paint, a reportable floor-dust composite, and no soil data. The risk assessor writes that a follow-up full risk assessment is recommended. The owner tells the certified supervisor to start whole-house abatement on Monday. What is the correct response?
Compared with a full risk-assessment report under 40 CFR 745.227(d)(11), what is true of a lead hazard screen report under 745.227(c)(5)?