14.2 Pre-Clearance Visual Inspection and When Cleanup Is Not Done
Key Takeaways
- Following an abatement, a visual inspection determines whether deteriorated painted surfaces and/or visible amounts of dust, debris, or residue are still present. If they are, those conditions must be eliminated before post-abatement testing continues (40 CFR 745.227(e)(8)(i)).
- The regulatory visual and the dust sampling are performed only by a certified inspector or risk assessor (745.227(e)(8), (f)). The supervisor's HUD preliminary visual is how you decide the room is ready to call that person — not a substitute wipe.
- Dust samples for post-abatement testing shall be taken a minimum of 1 hour after completion of final post-abatement cleanup activities (745.227(e)(8)(iv)). Recleaning after a failed visual restarts cleanup; do not wipe during the mop.
- A certified supervisor shall be onsite during post-abatement cleanup of work areas (745.227(e)(2)). Do not call the inspector or risk assessor until the work area is visually clean.
- If a single-surface dust sample equals or exceeds the action level (or a composite fails the composite rule), the components represented by the failed sample shall be recleaned and retested (745.227(e)(8)(vii)) — not automatically the entire dwelling unless the failure represents the entire dwelling.
Visual first — sampling does not start on a dirty room
Quick Answer: After abatement, 745.227(e)(8)(i) requires a visual inspection to determine whether deteriorated painted surfaces and/or visible amounts of dust, debris, or residue are still present. If they are, those conditions must be eliminated prior to continuation of post-abatement testing. The visual and the dust sampling are inspector or risk assessor work (745.227(e)(8), (f)), not supervisor wipes. Dust samples shall be taken a minimum of 1 hour after completion of final post-abatement cleanup (745.227(e)(8)(iv)). A certified supervisor shall be onsite during that cleanup (745.227(e)(2)). Do not call the risk assessor until the room is visually clean. A failed visual means cleanup is not done. A failed dust sample means reclean and retest the components represented by that sample, not a standing order to rewash the entire house every time unless the failure represents the entire house.
Section 14.1 was how to clean. This section is how you know cleaning is finished, who is allowed to say so in the regulatory sense, and what happens when it is not. Sample-location counts, composite math, multi-family random sampling, the 2026 dust-lead hazard statement, and the abatement report are Chapter 18. Keep this section on the gate in front of those wipes.
Two visuals, one regulatory gate
HUD Guidelines Chapter 14 tells the supervisor to perform a preliminary visual inspection after final cleaning and to reclean if visible dust and debris remain. That is documented methodology for not wasting a clearance visit. It is not the 745.227 visual.
745.227(e)(8) opens with a discipline lock: the following post-abatement procedures shall be performed only by a certified inspector or risk assessor. Paragraph (i) is the visual. Paragraph (ii) is dust sampling after that visual and after any extra cleanup the visual demanded. Paragraph (f) repeats that paint-chip, dust, and soil samples under this section are collected by persons certified as an inspector or risk assessor and analyzed by an EPA-recognized laboratory.
| Who | What they do | What they do not do |
|---|---|---|
| Certified supervisor (on site for cleanup) | Runs the HEPA / wet / HEPA sequence; does a HUD preliminary visual; recleans until the room looks empty of dust, debris, residue, and leftover deteriorated paint the job was supposed to fix; holds the 1-hour clock after final cleanup | Collect post-abatement dust samples; analyze wipes; declare the dwelling below action levels |
| Certified inspector or risk assessor | Performs the 745.227(e)(8)(i) visual; if it fails, sampling does not continue until the crew eliminates the conditions; if it passes, collects dust samples ≥1 hour after final cleanup | Supervise the mop in the supervisor's place; skip visual because the crew said it was fine |
| Certified abatement worker | Cleans under the supervisor | Authorizes clearance, collects wipes, or signs the visual |
| RRP renovator or dust sampling technician | Not the abatement post-abatement tester under 745.227(e)(8) | Do not treat cleaning verification or a technician wipe as abatement clearance |
The exam will offer the supervisor a ghost wipe because the supervisor was on site and knows where the dust was. Refuse it. Being on site for cleanup is how the room gets clean. It is not a sampling credential.
What failed visual actually looks like
745.227(e)(8)(i) names two families of leftover conditions. Either one stops testing:
- Deteriorated painted surfaces still present. If the work order was to abate a peeling LBP wall and the film is still hanging, the abatement is not in a state where dust testing should proceed. Visible chips on a sill are debris and a paint-condition problem. Do not argue that dust wipes will catch it later.
- Visible amounts of dust, debris, or residue. Chips in a trough, gray film on a baseboard, slurry at the bucket ring, grit on a window stool, plastic fragments, sanding powder in a corner, or a mop trail that dried as a stripe. Visible is the test. You do not need an XRF to fail a visual.
If those conditions are present, they must be eliminated prior to the continuation of post-abatement testing. That sentence is the whole gate. The inspector or risk assessor does not collect floor wipes around a pile of chips to see whether the rest of the room might pass. The crew goes back to Section 14.1. The supervisor is on site for that recleaning, because recleaning is post-abatement cleanup of work areas.
Failed visual = not ready. Occupants do not move back. The 1-hour sampling clock does not start from the first, failed cleanup. Furniture does not come off the truck. The abatement report does not get a clearance table. Cleanup is not done.
Worked example — gray trough, shiny floor. The supervisor's preliminary look says the oak floor is empty. The inspector arrives, shines a light into the window trough, and sees a line of grit. Visual fails. No dust samples. Crew HEPA/wet/HEPA the trough and any surfaces the grit may have flagged, supervisor on site. Then visual again. Then the hour. Then wipes. Calling that first visit a clearance attempt with a footnote about the trough is not 745.227(e)(8)(i).
Worked example — deteriorated paint the scope missed. Component replacement took the sashes. A window casing the report identified as LBP is still chalking and peeling. The inspector's visual finds deteriorated painted surfaces. Those conditions must be eliminated before testing continues — more cleanup and, if the paint is still a hazard the job claimed to abate, more abatement, not a wipe on the floor under the casing.
Do not call the risk assessor until the room is visually clean
This is a supervisor management rule with a regulatory backbone. Every time you invite an inspector onto visible dust, you have scheduled a failed (e)(8)(i) visual, a stand-down, a reclean with you on site, another wait, and another trip charge. HUD's preliminary visual exists so that call happens after your own eyes find no deteriorated paint and no visible dust, debris, or residue.
Do not:
- Call from the van because the owner is waiting and the floor looks pretty good from the doorway.
- Ask the inspector to wipe first and visual later to save time. The regulation is visual then sampling.
- Treat a worker's thumbs-up text as the visual. The supervisor is on site for cleanup; the supervisor looks.
- Start the EPA 1-hour clock while someone is still wringing a mop. Samples are taken a minimum of 1 hour after completion of final post-abatement cleanup. If visual fails and you reclean, final cleanup is the reclean, not the 10 a.m. pass.
Two different one-hour waits, both real:
| Wait | Source | What it is for |
|---|---|---|
| After paint-disturbing work, before final cleaning | HUD Chapter 14 documented methodology | Let airborne dust settle onto surfaces you will then HEPA and wash |
| After final post-abatement cleanup, before dust samples | 745.227(e)(8)(iv) | Samples a minimum of 1 hour after cleanup is actually finished |
Do not collapse them. Do not wipe 20 minutes after the last mop because the inspector's parking meter is running. Do not skip the HUD settle hour, clean while the room is still a dust cloud, and then blame the 5 µg/ft² action level.
Workers stay out of cleaned rooms until after the clearance examination so they do not re-soil the surfaces the inspector will wipe. That is HUD Chapter 14 practice and ordinary site control, not a loophole to send the supervisor home. The supervisor's on-site duty was the cleanup. After cleanup is complete, the 2-hour availability rule can cover other remaining abatement activity; it still does not let the supervisor collect the wipes.
Failed dust samples: reclean what the sample represents
Once visual passes and the hour has run, the inspector or risk assessor compares each result to the action levels. On or after January 12, 2026 those levels are 5 µg/ft² floors, 40 µg/ft² interior sills, 100 µg/ft² troughs. Equals or exceeds fails.
745.227(e)(8)(vii): if a single-surface dust sample equals or exceeds the applicable action level, the components represented by the failed sample shall be recleaned and retested. If a composite dust sample equals or exceeds the applicable action level divided by half the number of subsamples, the components represented by that composite are recleaned and retested. Composite arithmetic is Chapter 18. The supervisor's operational sentence is the same: reclean the represented components, then retest those components.
That is not a standing order to reclean the entire dwelling after every fail. A failed living-room floor wipe is the floors represented by that sample, not an automatic rewash of every wall in the attic. A failed trough is those window troughs, not a philosophy that the kitchen must come with them.
It is also not a license to reclean a 12-inch square under the wipe and ignore the rest of the same component. Components represented means the floor system, sill, or trough the sample stood for — typically the floors (or sills, or troughs) in that room or in the set the sampling plan used that wipe to represent. HUD Chapter 14 says the same idea in contractor language: repeat cleaning of the surfaces that failed and all other surfaces represented by the surfaces that failed.
When does failure imply the whole unit? When the sampling plan's failed sample represents the whole unit — for example a job with no containment and a floor result that stands for the dwelling's floors, or a pattern of fails that shows you never actually cleaned. If every floor wipe fails, you do not argue room-by-room. If one trough fails and floors are below 5, you reclean and retest that trough (and troughs it represents), not the entire house as a ritual.
Worked example — one failed sill. Visual passed. Hour ran. Bedroom floor 3 µg/ft², bedroom sill 55 µg/ft², trough 40 µg/ft². The sill equals or exceeds 40. Reclean the interior window sills represented by that sample, retest those sills. You do not automatically wet-wash the kitchen, and you do not skip the sill because the floor passed.
Worked example — failed floor that represents more than one room. A hallway floor wipe is the sample the inspector used for that hallway (and, depending on the plan, for connected floors). It reports 8 µg/ft². Reclean the floors represented, which is at least that hallway floor and any other floor the sampling design tied to that wipe — not a 2-foot patch where the wipe sat, and not a revenge-clean of the roof.
After recleaning, you are back at the gate: supervisor on site for the reclean, visual must pass, then a new 1-hour wait after that final cleanup, then retesting by the inspector or risk assessor. Do not rewipe immediately on a wet floor to save the second trip.
Cleanup is not done — a supervisor checklist
Treat cleanup as not done until every item is true:
- Paint-disturbing work in the work area has actually stopped, and HUD's settle time before final cleaning was honored.
- Sheeting is out, dirty-side in, as waste. Troughs, sills, trim tops, HVAC registers, radiators, carpets, floors, and belongings that stayed have had a real HEPA / wet / HEPA (or equivalent) sequence, high to low, toward the decon (Section 14.1).
- The certified supervisor was on site for that cleanup, including any reclean after a failed visual or failed wipe.
- Supervisor preliminary visual: no visible dust, debris, or residue; no leftover deteriorated painted surfaces the job still owes. If anything is visible, do not call the inspector yet.
- Inspector or risk assessor visual under (e)(8)(i) passes. If it fails, sampling does not continue. Reclean, then visual again.
- ≥1 hour has passed after completion of final cleanup — the last reclean, not the first mop.
- Dust samples are collected only by the certified inspector or risk assessor. Results are compared to 5 / 40 / 100, not to historic tables.
- Any fail is answered by recleaning and retesting the components represented, then repeating this gate. Occupants do not reoccupy the work area on a failed visual or a failed action-level wipe.
Worked example — owner pressure. The tenant wants keys at 3 p.m. Cleanup finished at 2:20. The risk assessor is in the driveway. Visual is clean. Wipes at 2:25 would be samples taken less than 1 hour after final cleanup. That is an (e)(8)(iv) fail even if every number would have been low. Wait until 3:20. The owner's schedule is not a documented methodology.
Worked example — supervisor collects wipes to help. The inspector is delayed. The supervisor, who is certified as a supervisor only, takes floor wipes at the 1-hour mark so the lab can start. Those samples do not satisfy 745.227(e)(8) or (f). Post-abatement dust sampling is inspector or risk assessor. Redo it correctly. Do not paper over it in the abatement report.
Official sources: 40 CFR 745.227(e)(2), (e)(8), (f) (supervisor on site for cleanup; inspector/risk-assessor visual and sampling; 1-hour wait; reclean components represented by a failed sample; 5 / 40 / 100 action levels); HUD Guidelines Chapter 14 (supervisor preliminary visual; reclean failed and represented surfaces); 40 CFR 745.225(d)(3)(ix) (interior dust cleanup as hands-on curriculum).
After interior abatement, the certified inspector's visual inspection finds a line of grit in a window trough even though the floor looks empty. What does 40 CFR 745.227(e)(8)(i) require?
Final post-abatement cleanup in a contained bedroom finished at 2:00 p.m. The risk assessor is in the driveway at 2:20 and wants to collect dust samples immediately. Which statement matches 40 CFR 745.227(e)(8)(iv)?
A single-surface bedroom floor dust sample is 9 µg/ft² after visual passed. Bedroom sills and troughs are below their action levels. Other rooms were not represented by that floor wipe. What does 40 CFR 745.227(e)(8)(vii) require?
Who may collect the post-abatement dust samples, and when should the supervisor call that person?