7.1 Reading Inspection Reports, XRF Results, and Paint-Chip Data
Key Takeaways
- A lead-based paint inspection may be conducted only by a certified inspector or risk assessor (40 CFR 745.227(b)(1)). A supervisor interprets the report to write the OPP, select methods, notify, and later prepare the abatement report, and does not perform the inspection unless also certified as an inspector or risk assessor.
- Inspection is surface-by-surface: each interior and exterior component with a distinct painting history must be tested, except components determined to have been replaced after 1978 or not to contain LBP. Multi-family dwellings and child-occupied facilities also require every common-area component with a distinct painting history (745.227(b)(2)).
- The inspection report must include dates, address, construction date, unit numbers, owner, name/signature/certification number of the inspector or risk assessor, firm, testing method and device including XRF serial number and quality-control data, specific locations tested, and results in method-appropriate units (745.227(b)(4)).
- Lead-based paint is present at ≥ 1.0 mg/cm² or ≥ 0.5% by weight on a tested surface, and on like surfaces in the same room equivalent with a similar painting history (745.227(h)(1)). HUD Guidelines / the device PCS classify XRF readings as positive, negative, or inconclusive.
- Never treat an inconclusive XRF as 'no lead.' Confirm with an NLLAP (TSCA 405(b)) paint chip or assume the surface is positive. A chip at 0.6% is LBP; a chip at 0.4% is not. Paint, dust, and soil samples under 745.227(f) are collected only by an inspector or risk assessor.
The supervisor reads the inspection; the inspector wrote it
Quick Answer: A lead-based paint inspection may be conducted only by a person certified as an inspector or risk assessor (40 CFR 745.227(b)(1)). It is a surface-by-surface determination of whether lead-based paint (LBP) is present — not a hazard assessment. Paint is tested on each component with a distinct painting history (and each such exterior component), except components the inspector or risk assessor determines were replaced after 1978 or do not contain LBP. In a multi-family dwelling or child-occupied facility (COF), every common-area component with a distinct painting history is tested the same way. X-ray fluorescence (XRF) results are classified by the device's Performance Characteristic Sheet (PCS) as positive, negative, or inconclusive. Inconclusive is not 'no lead.' Confirm with a National Lead Laboratory Accreditation Program (NLLAP) paint chip or treat the surface as positive. LBP is ≥ 1.0 mg/cm² or ≥ 0.5% by weight, plus like surfaces in the same room equivalent with a similar painting history (745.227(h)(1)).
You do not perform this inspection unless you also hold inspector or risk-assessor certification. Supervisor curriculum topic 745.225(d)(3)(v) is interpretation of inspection and risk-assessment reports. The report is how you know which sashes, casings, and troughs are LBP before you write the occupant protection plan (OPP), pick methods, file the five-business-day notice, and later write the abatement report (Chapters 8, 9, and 18). It is not a menu you can rewrite with a supervisor-owned XRF.
Chapter 5.2 already defined LBP, components, and distinct painting history. This section is how you read the table those rules produce — including the 1.2 / 0.8 / inconclusive XRF rows and the 0.6% / 0.4% chip rows the exam will put in front of you.
What 745.227(b) actually sampled
745.227(b)(2) is the sampling rule, not a suggestion:
| Building | What must be tested | What may be skipped |
|---|---|---|
| Residential dwelling or COF | Each component with a distinct painting history, and each exterior component with a distinct painting history | Components the inspector or risk assessor determines were replaced after 1978, or determines do not contain LBP |
| Multi-family dwelling or COF | The dwelling/COF rule plus each common-area component with a distinct painting history | Same post-1978 / not-LBP determinations |
Distinct painting history (745.223) is the application history of coatings on a component or room, shown by visual appearance or a record of application. Check whether the table actually tested each distinct history, or silently grouped a 2015 stripped sash with a never-stripped 1958 sash.
Paint is sampled under 745.227(b)(3) by documented methodologies that incorporate adequate quality control, and/or by paint-chip samples analyzed under 745.227(f). HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing are listed as documented methodologies in 745.227(a)(3), along with EPA residential sampling protocols and authorized-state methods. That is why inspection tables look like HUD Chapter 7 tables even on an EPA job: the PCS classification, quality-control shots, and inconclusive-confirmation path come from that documented methodology.
745.227(f) is a hard stop for supervisors. Any paint-chip, dust, or soil sample collected under these work-practice standards shall be collected by a certified inspector or risk assessor and analyzed by a laboratory recognized by EPA under TSCA section 405(b) — NLLAP. You do not grab a chip to confirm the report. You do not run clearance wipes. Post-abatement testing is 745.227(e)(8), inspector or risk assessor only.
Required inspection-report contents — 745.227(b)(4)
If a page is missing these items, you do not have a complete inspection report:
| Required element | Why the supervisor cares |
|---|---|
| Date of each inspection | Snapshot date; paint can fail after this date |
| Address of building | Must match the notice, OPP, and abatement report |
| Date of construction | Pre-1978 is why this is target housing or a COF (Chapter 3) |
| Apartment numbers (if applicable) | Unit-by-unit scope; do not copy Unit 2 onto Unit 4 |
| Owner name, address, telephone | Who contracted; who gets copies under 745.227(i) |
| Name, signature, and certification number of each inspector or risk assessor | Unsigned or uncertified is not this report |
| Certified firm name, address, telephone (if applicable) | Firm is certified under 745.226 |
| Each testing method and device and/or sampling procedure, including quality-control data and, if used, the serial number of any XRF | No serial number, no QC — you cannot defend the numbers |
| Specific locations of each painted component tested | Form, function, location — not a row that just says windows |
| Results expressed in terms appropriate to the sampling method | mg/cm² for XRF; % by weight for chips |
Results in the wrong unit are a red flag. An XRF line reported as 0.6% or a chip reported as 1.2 mg/cm² means someone mixed the two languages. Send the report back; do not translate units yourself.
Decode the table: 1.2 vs 0.8 vs inconclusive, 0.6% vs 0.4%
XRF measures loading in mg/cm². The federal LBP number is 1.0 mg/cm². The inspector does not simply compare the raw reading to 1.0 in isolation. HUD documented methodology uses that device's PCS to classify each reading as:
- Positive — LBP is present on that testing combination.
- Negative — LBP is not present on that testing combination.
- Inconclusive — the reading sits in the PCS range where the instrument cannot classify the surface relative to 1.0 mg/cm².
Some PCS documents use an inconclusive range around 1.0; others use a single threshold with no inconclusive band. That is why the classification column, not your mental subtraction of 0.8 from 1.0, controls. If the PCS classified 0.8 mg/cm² as negative, the XRF path says not LBP (unless a chip on that same history says otherwise). If the PCS classified 0.8 as inconclusive, it is not a pass.
Inconclusive typically needs paint-chip confirmation by an NLLAP laboratory, unless the owner assumes the surface is positive (HUD's documented alternative). Never treat inconclusive as no lead. A supervisor who sees 0.8 mg/cm², notices that 0.8 is below 1.0, and crosses the casing off the work order has just made an inspector decision without a PCS and without a chip.
Paint chips speak percent by weight. ≥ 0.5% (5,000 ppm) is LBP. 0.6% is LBP. 0.4% is not. A chip finishes an inconclusive XRF. A chip is not required to confirm a PCS-positive 1.2 mg/cm² sash — that sash is already LBP.
Like surfaces. 745.227(h)(1)(ii) extends LBP to any surface like a tested surface in the same room equivalent with a similar painting history. If one living-room sash is positive at 1.2 mg/cm² and three other living-room sashes share the same color stack, those three are LBP without each being shot. Bedroom sashes in a different room equivalent are not pulled in.
Worked example — one inspection page
| Room / location | Component | Method | Result | PCS / lab class | What the supervisor puts on the work order |
|---|---|---|---|---|---|
| Living room | Window sash A | XRF SN 45211 | 1.2 mg/cm² | Positive | LBP. Replacement or another abatement method. No chip required. |
| Living room | Window sashes B–D, same color stack, not stripped | Not tested | — | Like-surface LBP under (h)(1)(ii) | LBP. Same methods as sash A. Do not skip them because they have no XRF line. |
| Living room | Door casing | XRF SN 45211 | 0.8 mg/cm² | Inconclusive | Not a negative. Do not drop it. |
| Living room | Door casing (confirmation) | Paint chip, NLLAP | 0.6% by weight | LBP (≥ 0.5%) | LBP. Treating 0.8 as below 1.0 would have hidden this. |
| Stair | Newel (inconclusive XRF, then chip) | Paint chip, NLLAP | 0.4% by weight | Not LBP | Not LBP. Confirmation finished the inconclusive. Do not abate it as LBP. |
| Bedroom | Baseboard | Paint chip only | 0.6% by weight | LBP | LBP. Either threshold is enough; no XRF needed. |
| Kitchen | Door slab, replaced 1995 per invoice | Not tested | — | Excluded as post-1978 replacement | Not LBP on this report. Original 1960 casing around it still needs its own line. |
| Common hall (multi-family) | Handrail, original coating | XRF | 1.8 mg/cm² | Positive | LBP. Common-area components with distinct histories are in the inspection, not optional extras. |
Field traps on this page:
- 0.8 is not an automatic negative. PCS inconclusive plus a 0.6% chip is LBP.
- A 0.4% chip after inconclusive is a completed negative, not close enough to abate as LBP unless the contract assumes all paint is LBP.
- Untested similar sashes in the same room equivalent are in play.
- Post-1978 replacement excludes that component, not every painted part of the opening.
- Missing XRF serial number or QC data means you cannot treat the sheet as a finished (b)(4) report.
What you do with a complete inspection (and what you do not)
Use the inspection to name which components are LBP before method selection (Chapter 13) and before notification quantities (Chapter 9). Use it later so the abatement report's locations of rooms and/or components where abatement occurred match the inspection map.
Do not:
- Collect confirmatory chips or dust because the table looks thin (745.227(f)).
- Treat an inspection as a risk assessment. Inspection answers whether LBP is present. Risk assessment (Section 7.2) answers where the hazards are and what the control options are. Intact LBP on a closet shelf is still LBP; it may not be a current hazard.
- Self-clear after abatement. 745.227(e)(8) post-abatement visual and dust testing is inspector or risk assessor only.
If the owner skipped inspection and the contract simply assumes all paint is LBP, that is a scope choice, not a 745.227(h)(1) determination. You still need a certified inspector or risk assessor for post-abatement sampling. You still cannot fill an inspection-report blank with supervisor guesses.
An inspection table shows a living-room sash at 1.2 mg/cm² classified positive on the XRF Performance Characteristic Sheet, and a living-room door casing at 0.8 mg/cm² classified inconclusive. No paint chips have been analyzed yet. What must the certified supervisor conclude?
An inspection table lists: living-room sash A, XRF 1.2 mg/cm², PCS positive; living-room sashes B–D not tested, same color stack and no record of stripping; bedroom baseboard paint chip 0.6% by weight; kitchen door casing, inconclusive XRF then NLLAP chip 0.4% by weight. Which reading of 40 CFR 745.227(h)(1) is correct?
Under 40 CFR 745.227(b) and (f), who may conduct a lead-based paint inspection, and which statement about samples and the report is correct?