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Sampling and Testing for Residential Lead Abatement

Last updated 11/06/07

The following guidance is intended to provide background information about lead based paint hazards in residential structures (homes and apartments, but not day care centers or public areas).

Residential lead hazards are regulated by the Environmental Protection Agency (EPA) and U. S. Department of Housing and Urban Development (HUD), not the Department of Ecology or the EPA's Hazardous Waste Program.

The tests are different than the tests required for lead designation under the dangerous waste rules  (the Toxicity Characteristic Leaching Procedure (TCLP) or the Toxic Criteria tests). However, the sample collection guidance together with advice from the laboratory that will be performing the tests may help the dangerous waste generator to develop a representative sampling plan for non-residential wastes.

The most accurate way to determine lead, asbestos, PCBs and other environmental hazards at a site is to hire an independent hazard assessment expert to survey for them. An assessment contractor should be separate and financially independent from any environmental remediation companies that could be hired to remove the hazards.

Current EPA Guidance

The Regulatory Definition of Lead Based Paint

Lead-Based Paint (LBP) is a term used by Housing and Urban Development (HUD) and the EPA's Toxic Substances Control Act (TSCA) program. It defines paint with lead levels equal to or exceeding 1.0 milligram per square centimeter (1mg/cm2) or 0.5 percent by weight. Lead-based paint is not a term used by the Dangerous Waste program because the program only regulates lead if there is to leach 5.0 or more milligrams per liter on a TCLP Test - a different method of measurement. (Section 302(c) of the Lead-Based Paint Poisoning Prevention Act)

Residential Lead Identification and Lead Hazard Standards - TSCA Section 403

New  EPA's official policy on the identification of residential lead-based hazards in paint, dust and soil became effective on March 6, 2001. The standards establish criteria for identifying hazards in

  • interior and exterior lead-based paint,
  • lead-contaminated household dust, and
  • lead-contaminated residential soil hazards.

Under the new standards, lead is considered a hazard if there are greater than:

  • 40 micrograms of lead in dust per square foot on floors;
  • 250 micrograms of lead in dust per square foot on interior window sills and
  • 400 parts per million (ppm) of lead in bare soil in children's play areas or
  • 1200 ppm average for bare soil in the rest of the yard.
Where to Get More EPA Information About the New Standards:

Refer to Residential Lead Hazard Standards - (TSCA Section 403) Exit Ecology on the EPA Lead home page at www.epa.gov/lead/ for the final rule, facts sheets and other information.

Contact the National Lead Information Center Clearinghouse Exit Ecology at 1-800-424-LEAD for guidance documents about lead hazard sampling and testing methods. The following references are specifically listed in the EPA's TSCA Section 403 regulation - 40 CFR 745.227 Work practice standards for conducting lead-based paint activities: target housing and child-occupied facilities.

Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing. U.S. Department of Housing and Urban Development, (June 1995) The HUD Guidelines  and other HUD information can be accessed via the Internet at: http://www.hud.gov/lea/learules.html Exit Ecology

Guidance on Residential Lead-Based Paint, Lead-Contaminated Dust, and Lead-contaminated Soil, EPA 540-F-94-045, NTIS Order Number  PB94-963284, available from the Department of Commerce National Technical Information Service Exit Ecology, 1-800-553-6847

(EPA deposits most of its publications with the National Technical Information Service (NTIS). NTIS sells these publications in microform or hardcopy.)

Residential Sampling for Lead: Protocols for Dust and Soil Sampling, EPA 747-R-95-001 (March 1995) is now available from the National Lead Information Center Clearinghouse Exit Ecology at 1-800-424-LEAD.

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  • The hazard standards will be used to determine if lead-based paint hazards exist in pre-1978 housing and child-occupied facilities (e.g., daycare centers).
  • The regulation establishes hazard standards for lead paint in residential lead-based paint, residential dust and soil.
  • The regulation identifies lead hazards for the entire Title X EPA / HUD program including:

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Sampling and Testing Methods

Dust Wipe Sampling and Testing (Dust Lead Loading)

Wipe samples have two uses:

  • to find the amount of lead in the dust on a surface, and
  • as clearance samples to show that surfaces were thoroughly cleaned after a lead abatement or lead disturbance.

Wipe samples can't find or measure lead within a layer of paint - only loose dust.

Note! Hazardous and Dangerous Waste regulations don't allow wipe sampling to substitute for the TCLP test or state criteria tests. 

Lead levels measured by wipe samples depend on two factors:

  • the amount of collectable dust on a surface, and
  • the concentration of lead in that dust.

The wipe method is a recommended method for collecting dust samples on interior window sills. Wipe methods are not recommended for highly textured surfaces such as brickwork and rough concrete.

Large amounts of low-lead concentration dust, or a small amounts of high lead concentration dust, can result in a sample with a high lead level. Interior paint may be relativity low in lead while interior dust is highly contaminated by lead from exterior soils that have been tracked in. Neighborhood levels of lead may also contribute to high interior levels of lead, for example, local industry,  neighborhood demolition, or sandblasting. The reverse is also possible - high exterior soil lead levels can originate in building paint or lead activities.

How to Collect Dust Wipe Samples:
The recommended method is described in Chapter C of the EPA report Residential Sampling for Lead: Protocols for Dust and Soil Sampling, EPA 747-R-95-001 (March 1995). It is available from the National Lead Information Center Clearinghouse Exit Ecology at 1-800-424-LEAD.

Dust samples should be selected and collected by a certified risk assessor.

Lab Tests of Dust Samples:
Analyze dust samples using a laboratory recognized by EPA pursuant to Section 405(b) of the Toxic Substances Control Act (TSCA) as being capable of performing analyses for lead compounds in dust samples. Contact the National Lead Information Center Clearinghouse Exit Ecology at 1-800-424-LEAD and ask for the NLLAP (National Lead Laboratory Accreditation Program) list of laboratories.

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Paint Chips Sampling and Testing

Paint chip samples show the amount of lead in paint. There are two tests:

  • Atomic Spectrometry shows the volume/or weight of lead in a paint sample, and
  • the Toxicity Characteristic Leaching Procedure (TCLP) test determines how the lead would leach out in a landfill.

Note! Hazardous and Dangerous Waste regulations don't allow chip sampling by Atomic Spectrometry Techniques to substitute for the TCLP or state criteria tests. However, paint chip test results can be used to screen areas for TCLP or state criteria testing.

There are two ways to sample paint on a substrate:

  • collect a paint chip sample and test it in a lab, or
  • measure lead on a painted surface on the spot with a portable XRF instrument.

How to Collect Paint Chip Samples:
A standard method for collecting paint chip samples should be followed. Examples are:

  • ASTM E 1729, Standard Practice for Field Collection of Dried Paint Samples for Lead Determination by Atomic Spectrometry Techniques
  • The paint chip collection protocol in Appendix 13.2 of the 1995 HUD Guidelines.
  • ASTM E 1645, Standard Practice for the Preparation of Dried Paint Samples for Subsequent Lead Analysis by Atomic Spectrometry, is a related standard that may also be consulted regarding the preparation of paint chip samples for laboratory analysis.

Paint samples should be selected and collected by a certified risk assessor.

Collect all layers of paint in the area selected and have enough to run the anticipated test method.

The results may be reported in either milligrams of lead per square centimeter or in micrograms of lead per gram or both.

  • If results are reported in milligrams per square centimeter, sample within a demarcated area, and collect all paint within that area.
    • Results in milligrams per square centimeter are usually not affected by including any material underneath the paint.
  • If results are reported in micrograms per gram, minimize including any material underneath the paint.
    • Results in micrograms per gram would be lowered if material underneath the paint is included in the sample.

Paint Chip Sampling Using an XRF:
If an on the spot measurement is made with a portable XRF instrument:

  • Operate the instrument in accordance with the procedures in the HUD Guidelines and with the procedures in the EPA/HUD Performance Characteristic Sheets (or their equivalents).
  • Substrate correction should be done when recommended.
  • Collect paint chip samples for laboratory analysis where the XRF reading would be suspect or inconclusive.

 XRF results are reported in milligrams per square centimeter.

Portable XRF is most practical on intact painted surfaces; paint chip sampling may be necessary on a deteriorated or a curved surface because of limitations of the XRF instruments on such surfaces. A representative area on each component to be tested should be identified. This should be neither the thickest nor the thinnest spot on the component, but one that is characteristic of the overall thickness of the component. Use a non-deteriorated area or non-curved area on the component for sampling, as long as the available evidence and information indicates that the non-deteriorated or non-curved portion has the same painting history as the deteriorated or curved portion.

Paint Chip Sample Composites:
Paint chip samples may be composited (that is combined) to reduce the cost of chemical analysis. The number of samples in the composite will increase the weight of the sample. Call the testing laboratory to find out how many samples can be combined in one composite. Composite sample results can be expressed in milligrams per square centimeter or micrograms per gram.

  • To report the results in milligrams per square centimeter, all the sub-samples in the composite should have been collected from approximately the same size surface area.
  • To report the results in micrograms per gram, all the sub-samples in the composite should be of approximately the same mass.

As a practical matter, it is easier to maintain a constant surface area than equal mass for different paint samples.

Lab Tests of Paint Chip Samples:
Analyze paint chip samples using a laboratory recognized by EPA pursuant to Section 405(b) of TSCA as being capable of performing analyses for lead compounds in paint samples. Contact the National Lead Information Center Clearinghouse Exit Ecology at 1-800-424-LEAD and ask for the NLLAP (National Lead Laboratory Accreditation Program) list of laboratories.

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Soil Sampling and Testing

Disturbed soil may release lead into the air and directly contaminate the shoes and clothing of construction workers or neighborhood children who play in the bare soil.

Note! Soil does not need to be sampled for Hazardous or Dangerous Waste regulatory purposes unless it will be removed (generated) for off-site disposal during site preparation or excavation.

Only areas of bare soil are considered likely lead health hazards, concrete or sod keeps soil in place unless it is disturbed.

Lead contaminated soil is a major reservoir of lead in the environment. Soil has been contaminated with lead from many years of airborne particulate fallout from automobile exhaust, from industrial sources, and from the extensive use of lead-based paint on residential housing and other structures.

Lead contamination from weathering of lead painted building exteriors will be concentrated close to the building and along the building perimeter. Lead contamination from airborne sources such as industrial discharges may be spread about the property. Lead from auto exhaust will be concentrated close to past or current traffic areas and will decrease away from the traffic areas.

It is not possible to give detailed advice about choosing sampling locations because there are so many variables to consider at a particular site. Urban or rural location, past use of the property, neighborhood industry, and number and maintenance history of the buildings that will be renovated or demolished will have an effect on site lead levels. A certified lead risk assessment consultant is trained to do a preliminary assessment of the property and use professional judgment to advise the person collecting the samples.

How to Collect Soil Samples:
Soil sub-samples may be collected using either a coring method or a scoop method. A coring method would not be appropriate for sandy, dry, or friable soil. In these cases, a scooping method would be necessary.

Recommended methods for collection of soil sub-samples are presented in Chapter B of the EPA report Residential Sampling for Lead: Protocols for Dust and Soil Sampling. These protocols call for collection of the top half inch of soil. If paint chips are collected in the soil sub-sample, they should be included. Do not attempt to over sample paint chips.

Soil samples should be selected and collected by a certified risk assessor.

Soil Sample Composites:
As described above, compositing of soil sub-samples for laboratory analysis is the recommended approach. Combining soil samples usually does not present the difficulties associated with combining dust or paint samples. This is because composited soil samples can be readily dried, sieved, homogenized, and then sub sampled before chemical analysis. Nevertheless, it is recommended that the testing laboratory be consulted to make sure the samples submitted for chemical analysis can be analyzed without any problems. Soil sub-samples in a composite should be approximately the same mass.

Lab Tests of Soil Samples:
Analyze soil samples using a laboratory recognized by EPA pursuant to Section 405(b) of TSCA as being capable of performing analyses for lead compounds in soil. Call the National Lead Information Center Clearinghouse Exit Ecology at 1-800-424-LEAD and ask for the NLLAP (National Lead Laboratory Accreditation Program) list of laboratories.

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Tools

Chemical Test Kits

Chemical test kits are designed to detect lead in paint by a chemical reaction when chemicals in the test kit are exposed to lead on painted wood, metal, pottery, dinnerware, glassware, plumbing pipes and toys. The reaction causes a color change that the user can see.

Chemical Test Kits are sold in hardware stores, are inexpensive, and give immediate results, however their results are inaccurate.

Chemical Test Kit Results Cannot be Used for Dangerous Waste Designation
A 1993 study by Midwest Research Institute and QuanTech, and funded by the Environmental Protection Agency and the Department of Housing and Urban Development recommended not using chemical test kits to detect lead in paint.

 "No test kit in the study achieved low rates of both false positive and false negative results. Some kits yielded a positive result at low levels of lead. Other kits were prone to a negative result when lead in paint was above the federal thresholds of 1.0 mg per centimeter squared and 0.5% by weight".

From A Field Test of Lead-based Paint Testing Technologies, EPA number 747-R-95-002a, May 1995, available on the internet at http://www.epa.gov/oppt/lead/pubs/summary.txt Exit Ecology or from the National Lead Information Center Clearinghouse Exit Ecology at 1-800-424-LEAD. A more detailed technical report, A Field Test of Lead-based Paint Testing Technologies, Technical Report, EPA number 747-R-95-002b is also available.

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XRF Devices

XRF stands for X-Ray Fluorescence, a type of portable battery powered scanner that can be used to read and analyze metals within minutes or seconds. XRF instruments measure metals by directing high energy X-rays and gamma rays into the paint, causing the atoms in the paint to emit X-rays which are detected and converted to a measurement of the amount of lead and other metals in paint, soil or other media. Some units come with a computer and software. 

  • XRF instruments are widely used for chemical analysis in the petroleum, plastics, coatings, environmental, industrial hygiene, food, pharmaceutical, cosmetics, and mineral industries.

XRF Results Can be Used as Knowledge for Dangerous Waste Designation
Note! XRF results don’t show if a waste will leach lead or any other constituents on the TCLP list so they cannot be substituted for Toxicity Characteristic Leaching Procedure (TCLP) test method 1311. However, it would be possible to use knowledge obtained from an XRF to show that the level of a constituent is so low that it could not leach from a sample if method 1311 was run.

XRF results also can’t be substituted for a fish or rat bioassay for Washington State Toxic Criteria testing. However, it would be possible to use knowledge obtained from an XRF together with toxicology references to book designate instead of running a state Toxic Criteria test.

XRF Operation
XRF analysis needs to be conducted by well-trained field experienced technicians. Just about anyone can operate one but an understanding of the application and the data quality objectives are essential. Training is provided by manufacturers for their particular products. Calibration for the substrate and the analyses may be factory programmed or may have to be programmed at the site. An understanding of the instrument’s drift and it’s precision for each analyze is necessary.

Different XRF instruments have different limits of detection for particular substrates. Instruments also have a bias (or accuracy), as a function of lead level and substrate. Several XRF manufacturers make equipment specifically for lead paint detection. Lead settings for residential abatement and Title X work give quick results - the XRF unit detects with 95% confidence that lead is at or above the federal lead action level of 1 mg/cm2. The technician can also set an XRF to show more detailed analysis  for OSHA compliance, hazardous property assessments, facilities management, building demolition and renovation, and waste classification purposes.

Quality Control for XRF Readings
Quality control for XRF readings can be obtained by using National Institute of Standards and Technology Exit Ecology (NIST) Standard Reference Material (SRM) paint film. NIST SRM paint film is a thin layer of lead paint with a known level of lead enclosed between two layers of plastic. The surface to be tested is scraped bare of paint, then the NIST SRM paint film is placed over the bare substrate. A reading shows if the substrate is interfering with the XRF results.

Laboratory Testing to Verify  XRF Results
Current XRF testing requires a percentage of the site samples be sent to a laboratory for independent testing to confirm the accuracy of the results. 

The EPA Lead Program provides a testing program for XRF operators to demonstrate that they achieve identical data quality as that of EPA-accredited laboratories. This is the Environmental Lead Proficiency Analytical Testing (ELPAT) program, currently available for lead in dust wipes, soils and paint chips.

For more information about  ELPAT  contact the American Industrial Hygiene Association Exit Ecology at 703-849-8888. 

The Environmental Technology Verification Program
The Environmental Protection Agency (EPA) has a new program, the Environmental Technology Verification Program - or ETV. 

Research and verification reports are available on the EPA ETV website, EPA's Environmental Technology Verification Program (ETV) at http://www.epa.gov/etv/ Exit Ecology for seven XRF units that were approved by EPA in field tests. Results of the XRF field tests were compared to conventional laboratory sampling and analysis of arsenic, barium, copper, lead, zinc, nickel, iron, cadmium and antimony in soil.

Refer to the section on Lead Industry Guidance for information from the lead industry about products, services and XRF technology.

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