7.2 Reading Risk Assessment Reports and Selecting Control Options
Key Takeaways
- A risk assessment may be conducted only by a certified risk assessor (40 CFR 745.227(d)(1)). It includes a visual for deteriorated paint and causes, background and occupant-use patterns for children under 6, testing of deteriorated friction/impact surfaces and all other deteriorated paint, dust on sills and floors in living areas those children use (plus extra common-area and COF samples), and bare soil in play areas, the rest of the yard, and dripline/foundation areas.
- The RA report must describe the location, type, and severity of identified lead-based paint hazards and interim controls and/or abatement options for each hazard with a suggested prioritization. If an encapsulant or enclosure is recommended, the report must include a maintenance and monitoring schedule (745.227(d)(11)(xvii)–(xviii)).
- The supervisor translates those options into a work plan that matches the contract design: replacement, enclosure, encapsulation, paint removal, and soil removal or permanent covering are abatement when designed as permanent elimination; paint stabilization, specialized cleaning, mulch, and monitoring are interim.
- Do not ignore soil or play areas. A play-area soil-lead hazard is ≥ 400 ppm bare soil; rest-of-yard is ≥ 1,200 ppm (745.227(h)(4)). On or after January 12, 2026, a dust-lead hazard on floors or interior sills is any reportable level; abatement of dust-lead still completes only below the 5 / 40 / 100 µg/ft² action levels.
- Supervisors cannot collect the RA's paint, dust, or soil samples and cannot collect clearance dust samples. Post-abatement testing is inspector or risk assessor only (745.227(e)(8), (f)).
The RA report is a control-option memo, not a bid
Quick Answer: A risk assessment may be conducted only by a certified risk assessor (40 CFR 745.227(d)(1)). It finds lead-based paint hazards (paint, dust, and soil) and, in the report, must describe the location, type, and severity of identified hazards and interim controls and/or abatement options for each, with a suggested prioritization. If an encapsulant or enclosure is recommended, the report shall recommend a maintenance and monitoring schedule (745.227(d)(11)(xvii)–(xviii)). The supervisor translates those options into a work plan that matches the contract design (Chapter 5): permanent elimination is abatement; paint stabilization and specialized cleaning are interim. Do not ignore soil or play areas. Do not collect the RA's paint, dust, or soil samples, and do not collect clearance dust samples.
Inspection told you which films are LBP. The RA tells you which of those films — plus dust and soil — are hazards now, and what the control menu looks like. You still write the OPP, pick the methods you will actually use, notify EPA or the authorized state, and later prepare the abatement report. You do not become the risk assessor by rewriting the dust numbers.
What a full RA is required to look at
745.227(d)(2)–(8) is the fieldwork the report is summarizing:
| RA step | Regulatory requirement | Supervisor read |
|---|---|---|
| Visual | Locate deteriorated paint, assess extent and causes, and other potential LBP hazards | Moisture, friction, impact, and ordinary failure should be named; causes drive method choice |
| Background / use | Physical characteristics and occupant-use patterns that may expose children under 6 | Living areas, play rooms, and chewable height are not optional color |
| Paint testing | Each friction or impact surface with visibly deteriorated paint, and all other surfaces with visibly deteriorated paint, if they have a distinct painting history | This is not the poor-condition screen gate. Full RA tests visibly deteriorated paint, not only 2 / 10 / 10% |
| Dust — dwelling | Interior window sills and floors in living areas where children under 6 are most likely to contact dust (composite or single-surface) | On or after January 12, 2026, a dust-lead hazard on floors or interior sills is any reportable level |
| Dust — multi-family / COF | Additional sill and floor dust in common areas adjacent to the sampled unit or COF and other common areas where children under 6 contact dust | Halls, stairs, and lobby play corners belong in the plan |
| Dust — COF extra | Each room, hallway, or stairwell used by children under 6, plus other common areas they use | A daycare classroom cannot be represented by the office |
| Soil | Bare soil in exterior play areas, the rest of the yard (non-play), and dripline/foundation areas | 400 ppm play area / 1,200 ppm rest of yard (745.227(h)(4)) |
All of that sampling uses documented methodologies with quality control (745.227(d)(9)). Chips, dust, and soil go through (f): inspector or risk-assessor collection, NLLAP analysis. HUD Guidelines are again an (a)(3) methodology for how those samples are typically taken.
Required RA-report contents you will actually use
745.227(d)(11) is long on purpose. Identifying information mirrors the inspection report: date, address, construction date, apartment number, owner, assessor name, signature, and certification, firm, and the recognized laboratory name, address, and telephone. Then the substance:
- Results of the visual inspection
- Paint-testing method, specific locations tested, on-site data including quality-control data and XRF serial number
- Laboratory results for paint, soil, and dust, and any other sampling
- Background and occupant-use information
- Previous inspections used in the hazard determination
- (xvii) Location, type, and severity of identified LBP hazards and other potential lead hazards
- (xviii) Interim controls and/or abatement options for each identified LBP hazard, with a suggested prioritization. If encapsulant or enclosure is recommended, include a maintenance and monitoring schedule.
(xviii) is the supervisor's shopping list. A report that lists hazards but no options is incomplete. A report that recommends encapsulation with no monitoring schedule is incomplete. You do not invent a monitoring interval because the manufacturer ran a TV ad.
Translate options into a work plan
Chapter 5's design test still governs. The RA is allowed to offer both interim and abatement for the same hazard. The written contract chooses the rule. If the job is certified abatement, you select permanent methods from the abatement column. If the owner bought interim controls, you are not on this supervisor credential for that design.
| RA finding (examples) | Interim-control option you may see | Abatement option you may see | What a certified abatement work plan should not do |
|---|---|---|---|
| Friction-sash paint-lead hazard; sill dust reportable | Paint stabilization, window-well cleaning, restrict sash use, monitor | Component replacement of the window assembly; dust taken below action levels | Strip and latex-paint an operable sash and call it permanent; encapsulate a grinding pair |
| Deteriorated LBP on living-room walls | Wet-scrape, repair, repaint, monitor | Encapsulation (true encapsulant) or enclosure, with the report's monitoring schedule, or paint removal | Encapsulate and throw the monitoring schedule away |
| Dust-lead on bedroom floor (reportable; for example 18 µg/ft²) | Specialized cleaning, furniture HEPA, occupant education | Interior dust abatement and cleanup until dust is below action levels | Treat a mop-down as abatement complete without inspector/RA testing |
| Play-area bare soil 850 ppm | Mulch, grass, restrict play, monitor (temporary) | Remove and replace with soil as close to local background as practicable, ≤ 400 ppm, and do not reuse as residential topsoil; or permanently cover (pavement/concrete — not grass/mulch) | Ignore soil because the crew is a paint crew, or dump play-area dirt in the side yard |
| Rest-of-yard bare soil 600 ppm | Usually not a soil-lead hazard (off-play-area hazard is 1,200 ppm) | No rest-of-yard soil abatement required by this number | Apply the 400 ppm play-area number to the whole lot without reading the RA's play vs yard split |
| Dripline/foundation bare soil the RA classified as a hazard | Temporary covering / restrict access | Address as the RA prioritized (often remove or permanently cover) | Leave a chip-loaded dripline because the windows were the bid |
Dust numbers to keep straight (clearance mechanics are Chapter 18): on or after January 12, 2026, dust-lead action levels are 5 µg/ft² floors, 40 µg/ft² interior window sills, 100 µg/ft² window troughs. A dust-lead hazard on floors or interior sills is any reportable level. Abatement of dust-lead is complete only below the action levels. A floor at 3 µg/ft² can still be a hazard if 3 is reportable, while 18 µg/ft² is both a hazard and above the floor action level. Do not use retired 40/250/400 or 10/100 figures as current.
Prioritization in the report is a suggested order, often: surfaces a child under 6 can mouth or grind (chewable, friction windows), interior dust in living areas, play-area soil, then lower-traffic films. You may re-sequence for logistics. You may not drop a prioritized play-area soil hazard because the paint bid is easier.
Worked example — one RA page into one work plan
A 1964 single-family RA (children under 6 in the home) lists:
- Living-room windows: deteriorated LBP on sashes; sill dust reportable → options: replace assemblies (abatement, first priority) or stabilize and educate (interim).
- Living-room walls: LBP, 12 ft² peeling → options: encapsulate with 6-month visual monitoring for two years, then annual (abatement) or paint stabilization (interim).
- Bedroom floor dust 18 µg/ft² → specialized cleaning (interim) or full interior dust abatement to below 5 µg/ft².
- Play-area bare soil 850 ppm → mulch (interim) or remove/replace to ≤ 400 ppm or pave (abatement).
- Rest of yard 600 ppm → not a rest-of-yard soil-lead hazard.
The owner signs a certified-abatement contract to permanently eliminate the identified hazards. The supervisor's work plan therefore replaces the living-room window assemblies (not stabilize); encapsulates the walls only with the specified system and copies the maintenance and monitoring schedule into the owner discussion and into the abatement report (745.227(e)(10)(vi) requires any suggested monitoring of encapsulants or enclosures); performs interior dust cleanup aimed at below action levels; and removes/replaces or permanently covers the play-area soil. Planting rye grass over 850 ppm play-area soil is not soil abatement. Leaving the play area for a later phase while declaring the job complete is ignoring a listed hazard.
If the owner had instead bought interim controls, paint stabilization, specialized cleaning, and mulch could match the RA's other column — and you would not file this as Subpart L abatement. Mixing columns — abatement notice plus mulch as the soil method — is how reports and jobs stop matching.
What the supervisor still cannot do with an RA in hand
- Cannot collect paint, dust, or soil samples to fill in a thin RA (745.227(f)).
- Cannot collect clearance dust samples. Post-abatement visual and dust testing is inspector or risk assessor (745.227(e)(8)), at least 1 hour after final cleanup, compared to 5 / 40 / 100.
- Cannot treat encapsulant as fire-and-forget. The RA's monitoring schedule is part of the option; the abatement report must carry suggested monitoring forward.
- Cannot skip soil because the crew's skill is interior paint. 745.227(e)(7) soil abatement is still remove-and-replace (≤ 400 ppm, no reuse as residential topsoil) or permanent cover as defined in 745.223 (pavement or concrete, not grass or mulch).
The RA is the input. The OPP, notice, method selection, and abatement report are the outputs. Section 7.3 is what happens when the document in the truck is only a lead hazard screen.
A risk-assessment report for a 1964 house with children under 6 lists deteriorated friction-sash lead-based paint with replacement (abatement) or stabilization (interim) as options, living-room walls recommended for encapsulation with a monitoring schedule, play-area bare soil at 850 ppm, and rest-of-yard soil at 600 ppm. The owner signs a certified-abatement contract to permanently eliminate the identified hazards. Which work plan matches 40 CFR 745.227?
A certified risk assessor recommends encapsulating deteriorated lead-based paint on living-room walls as an abatement option. What does 40 CFR 745.227 require of that recommendation and of the supervisor who uses it?
Which statement correctly describes a full risk assessment under 40 CFR 745.227(d) and who may collect the samples?