HUD Sampling Protocol for Lead Appendix F-2
material that is not assumed to be ACM, and shall coliect the samples as

follows:

(1) At least three bulk samples shall be collected from each

homogeneous area that is 1,000 ft\2\ or less, except as provided in

Sec. 763.87(c)(2).

(2) At least five bulk samples shall be collected from each

homogeneous area that is greater than 1,000 ft\2\ but less than or equal

to 5000 ft\2\, except as provided in Sec. 763.87(c)(2).

(3) At least seven bulk samples shall be collected from each

homogeneous area that is greater than 5,000 ft\2\, except as provided in

Sec. 763.87(c)(2).

(b) Thermal system insulation. (1) Except as provided in paragraphs

(b) (2) through (4) of this section and Sec. 763.87(c), an accredited

inspector shall collect, in a randomly distributed manner, at least

three bulk samples from each homogeneous area of thermal system

insulation that is not assumed to be ACM.

(2) Collect at least one bulk sample from each homogeneous area of

patched thermal system insulation that is not assumed to be ACM if the

patched section is less than 6 linear or square feet.

(3) In a manner sufficient to determine whether the material is ACM

or not ACM, collect bulk samples from each insulated mechanical system

that is not assumeo to be ACM where cement or plaster is used on

fittings such as tees, elbows, or valves, except as provided under

Sec. 763.87(c)(2).

(4) Bulk samples are not required to be collected from any

homogeneous area where the accredited inspector has determined that the

thermal system insulation is fiberglass, foam glass, rubber, or other

non-ACBM.

(c) Miscellaneous material. In a manner sufficient to determine

whether material is ACM or not ACM, an accredited inspector shall

collect bulk samples from each homogeneous area of friable miscellaneous

maledal that is not assumed tO be ACM.

(d) Nonfriable suspected ACBM. If any homogeneous area of nonfriable

suspected ACBM is not assumed to be ACM, then an accrethted inspector

shall collect, in a manner sufficient to oetermine whether the material

is ACM or not AcM, bulk samples from the homogeneous area of nonfriable

suspected ACBM that is not assumed to be ACM.
Settled Lead

Contamina

Wipe samples for settled leaded dust can be collected from floors (both carpeted and

uncarpeted),

interior and sash/sill contact areas, and other reasonably smooth surfaces. Wherever

possible,

hard surfaces should be sampled. Wipe media should be sufficiently durable so that it is

not

easily torn, but can be easily digested in the laboratory. Recovery rates of between 80-

120% of

the true value should be obtained for all media used for wipe sampling. Blank media

should

contain no more than 25 pg/wipe (the detection limit using Flame Atomic Absorption).

Additional standards for wipe sampling can be found by consulting ASTM ES 30-94.

1. Wipe Sampling Materials and Supplies

a. Type of disposable wipe: Any wipe material that meets the following criteria may

be used:

(i) Contains (ow background lead levels (less than 5 pg/wipe)

(H) Is a single thickness

(iH) Is durable and does not tear easily (do not use WhatmanTM filters)

(iv) Does not contain aloe

(v) Can be digested in the laboratory

(vi) Has been shown to yield 80-120% recovery rates from samples spiked with

leaded dust (not lead in solution)

(vii) Must remain moist during the wipe sampling process (wipes containing alcohol

may be used as long as they do not dry out)

Examples of acceptable wipe media include: “Little Ones Baby Wash ClothsTh,’I

“Little Ones Baby Wipes Natural FormulaTM,H or “Liffle Ones Baby Wipes Lightly

ScentedTM,” available at K-Mart Stores. This product is also available under the

brand names “Pure and Gentle Baby WipesTM” and “Fame Baby WipesTM.fl

Individually-packaged “Wash’n Dri Wipes” are also acceptable. “Wet Wipes,” which

are available at Walgreens and other stores, may also be used. Other brands are also

acceptable if equivalence in both lead contamination (analysis of blanks) and

laboratory digestion recoveries (analysis of wipes spiked with known amounts of

leaded dust, not lead in solution) can be established. The wipes listed above have

proven to be sufficiently durable under field use and to have acceptable recovery

rates. Do not use “Little Ones Diaper Wipes,” also available at K-Mart stores, or any

other brand of wipes for which recovery data have not been established. Do not use

wipes that contain abe. Wipes that contain alcohol may be used as long as they do

not dry out during the wipe process.

b. Non-steriHzed non-powdered disposable gloves. Disposable gloves are required to

prevent cross-sample contamination from hands.

c. Non-sterilized polyethylene centrifuge tubes (50 ml size) or equivalent hard-shell
the templates to determine if the template is contaminated. Disposable templates are also permitted so long as they are not used for more than a single surface. Templates must be larger than 0.1 ft2, but smaller than

2 ft2. Templates for floors are typically 1 ft2.Templates are usually not used for windows due to the variability in size and shape (use masking tape instead).

g. Container labels or permanent marker. h. Trash bag or other receptacle (do not use pockets or trash containers at the residence).

i. Rack, bag, or box to carry tubes (optional) j. Measuring tape

k. Disposable shoe coverings (optional)

2. Single Surface Wipe Sampling Procedure

a. Outline Wipe Area:

Floors: Identify the area to be wiped. Do not walk on or toubh the surface to be sampled (the wipe area). Apply adhesive tape to perimeter of the wipe area to form

a square or rectangle of about one square foot. No measurement is required at this time. The tape should be positioned in a straight line and corners should be nominally perpendicular. When putting down any template, do not touch the interior wipe area.

Windowsills and other rectangular surfaces: Identify the area to be wiped. Do not

wipe

touch the wipe area. Apply two strips of adhesive tape across the sill to define a area at least 0.1 square foot in size (approx.

4 inches x 4 inches). When using tape, do not cross the boundary tape or floor markings, but be sure to wipe the entire sampling area. It is permissible to touch the tape with the wipe, but not the surface beyond the tape. b. Preliminary inspection of the disposable wiRes: Inspect the wipes to determine if they are moist If they have dried out, do not use them. When using

a container that dispenses wipes through

a “pop-up” lid, the first wipe in the dispenser at the beginning of the day should be thrown away. The first wipe may be contaminated by the lid and is likely to have dried to some extent. Rotate the container before starting to ensure liquid inside the container contacts the wipes.

c. Preparation of centrifuge tubes: Examine the centrifuge tubes and make sure that the tubes match the tubes containing the blind spiked wipe samples. Partially unscrew the cap on the centrifuge tube to be sure that it can be opened. Do not use plastic baggies to transport or temporarily hold wipe samples.. The laboratory cannot measure lead left on the interior surface of the baggie. d. Gloves

Don

a disposable glove on one hand; use a new glove for each sample collected. If
down firmly, but not excessively with both the palm and fingers (do not use 

of the hand). Do not touch the surface with the thumb. If the wipe area is a square,

proceed to wipe side-to-side with as many “S-like motions as are necessary to

comp!etely cover the entire wipe area. (See step h for non- square areas.) Exerting

excessive pressure on the wioe will cause it to curl. Exerting too little Dressure will

result in poor collection of dust. Do not use only the fingertips to hold down the

wipe, because there will not be complete contact with the surface and some dust may

be missed. Attempt to remove all visible dust from the wipe area.

g. Second wipe pass - (top-to-bottom):

Fold the wipe in half with the contaminated side facing inward. (The wipe can be

straightened out by laying it on the wipe area, contaminated side up, and folding it

over.)Once folded, place in the top corner of the wipe area and press down firmly

with the palm and fingers. Repeat wiping the area with “S-like motions, but on the

second pass, move in

a top-to-bottom direction. Attempt to remove all visible dust.

Do not touch the contaminated side of the wipe with the hand or fingers. Do not

shake the wipe in an attempt to straighten it out, since dust may be lost during

shaking.

h. Rectangular areas (e.g. window sills):

If the surface is

a rectangle (such as a window silO, two side-to-side passes must be -.

made over half of this surface, the second pass with the wipe folded so that the

contaminated side faces inward. For a window sili, do not attempt to wipe the

irregular edges presented by the contour of the window channel. Avoid touching

other portions of the window with the wipe. If there are paint chips or gross debris

in the window sill, attempt to include as much of it as possible on the wipe. If all

of the material cannot be picked up with one wipe, field personnel may use

a second

wipe at their discretion and insert it in the same container. Consult with the

analytical laboratory to determine if they can perform analysis of two wipes as

a

single sample. When performing single-surface sampling, do not use more than two

single surface wipes for each container. If heavily dust-laden,

a smaller area should

be wiped. It is not necessary to wipe the entire window well but do not wipe less

than 0.10 ft2 (aporox4” x 4”).

i. Packaging the Wipe:

After wiping, fold the wipe with the contaminated side facing inward again, and

insert aseptically (without touching anything else) into the centrifuge tube or other

hard-shelled container. If grcss debris is present, such as paint chips in a window

well, make every attem pt to include as much of the debris as possible in the wipe.

j. Labelling the Centrifuge tube: Seal the tube and label with the appropriate identifier, Record the laboratory submiffal

sample number on the field sampling form (see Chapters 5 and 14).

k. Area Measurement:

After samz[ng. measure the surface area wiped to the nearest eighth of an inch using

a tape measure or a ruler. The size of the area wiped must be at east 0.10 ft2 in

order to obtain an adequate limit of quantitation (25 pg/wipe is the typical detection
p

g, 

ove the masking tape and throw it away in

a trash bag. Remove the glove; put all contaminated gloves and sampling debris used for the sampling period into a trash bag. Remove the trash bag when leaving the dwelling. Do not throw away gloves or wipes inside the dwelling unit where they could be accessible to young children, resulting in

a suffocation hazard.

Repeat steps a. through m. for additional samples in the same dwelling unit.

3. Composite Wipe Sampling

Whenever composite sampling is contemplated, consult with the analytical laboratory to determine if the laboratory is capable of anafy2ing composite samples. When conducting composite wipe sampling, the procedure stated above should be. used with the following modifications:

When outlining the wipe areas (step a), set up all of the areas to be wiped before sampling. The

size of these areas should be roughly equivalent, so that one room is not over-sampled. After preparing the centrifuge tube, put on the glove(s) and complete the wiping procedures for

all subsamples (steps e-i).

A separate wipe must be used for each area sampled. After wiping

each area, carefully insert the wipe sample into the same centrifuge tube (no morethan

4 wipes

per tube).

Once all subsamples are in the tube, label the tube. Record

a separate measurement for each area .

-

that is subsampled on the field collection form (see Form 5.4a or Form 14.2a for a sample form).Finally, complete trash disposal (step m), making sure that no masking tape is left behind.

Risk assessors and inspector technicians do not have to remove their gloves between subsample

wipes for the same composite sample as long as their gloved hands do not touch an

area outside

of the wipe areas. If

a glove is contaminated, the glove should be immediately replaced with

a

clean glove.

In addition to these procedural modifications, the following rules for compositing should be

observed:

• Separate composite samples are required from carpeted and hard surfaces (e.g., a single composite sample should not be collected from both carpeted and bare floors). Separate composite samples are required from each different component sampled (e.g.,

a
contaminated. Each field blank should be labeled with

a unique identif

e

others

so that the laboratory does not know which sample is the blank (i.e., the laboratory

should be

“band” to the blank sample).

Blank wipes are collected by removinc a wipe from the container with a new glove,

shaking the

wipe open, refolding as it occurs during the actual sampling procedure, and then

inserting it into

the centrifuge tube without touching any surface or other object. One blank wipe is

collected for

each dwelling unit sampled or, if more than one dwelling unit is sampled per day, one

blank for

every 50 field samples, whichever is less. Aiso, collect one blank for every lot used.

Record

the lot number.

5. Inspector Decontamination:

After sampling, wash hands thoroughly with pienty of soap and water before getting into

car.

A bathroom in the dwelling unit may be used for this purpose, with the owner’s or

resident’s

permission. If there is no running water in the dwefling unit, use wet wipes to clean the

hands.

During sampling, inspectors must not eat, drink, smoke, or otherwise cause hand to

mouth

contact.

6. Spike Sample Submission

Sampes spiked with a known amount of leaded dust should be inserted into the sample

stream

randomly by the person conducting field sampling to determine if there is adequate

quality

control of the digestion process at the laboratory. Dust-spiked wipe samples should be

submitted

blindly to the laboratory by the individual performing field sampling at the rate of no less

than

one for every fifty field samples. Any laboratory can spike wipe samples using the

procedure - in Appendix 14.3. The laboratory performing the analysis of the field samples can also

prepare

the spike sample as :ong as the person performing the field sampling makes the spike

sample
y 

present being between 50 -1000 pg. For wipe samples, labs should use NIST Standard Lead Paint Dust (Standard 1578) or an equivalent secondary standard. See Appendix 14.3 for further details.

7. Field Qualifications of Dust Sampling Technicians

All individuals performing dust sampling should have state-certified training. Where possible, field experience in environmental sampling is preferable.

8. Quality Assurance/Quality Control

Blind analysis of spiked samples must fall within 80% - 120% of the true value, If the laboratory fails to obtain readings within the QA/QC error limits:

a. Two more spikes should be sent immediately to the lab for analysis. b. If the two additional spike samples fail, the sample batch should be considered invalid.

A full review of laboratory procedures may be necessary. Additional samples may need to be collected from the dwelling units from locations near the locations previously sampled. If more than 50 pg/wipe is detected in a blank sample, the samples should be collected again since the media is contaminatd. Blank correction of wipe samples is not recommended,

9. Other Information

See Chapter 5 and Chapter 14 for additional information on dust wipe sampling. Also

see “Residential Sampling for Lead: Protocols for Leaded Dust and Soil Sampling” from EPA and ASTM ES 30-94 for further information.

Appendix 13.2

Paint Chip Sampling

Dust sampling must always be done before paint chip sampling in order to minimize the

prospect of cross-sample contamination. Paint chip sampling is a destructive method that may release

a small quantity of lead dust. Although paint chip samples are to be collected from inconspicuous areas, the occupant must always be notified that paint chip sampling may be necessary.

1. Paint Chip Sampling Tools and Materials

a. Sharp stainless steel paint scraper (such as ProprepTM Scraper, $7.50, 1-800-255-4535) available at many paint stores.

b. Disposable wipes for cleaning paint scraper.

c. Non-sterilized non-powdered disposable gloves.

d. Hard-shelled containers (such as non-sterilized 50-mi polypropylene centrifuge tubes) that can be rinsed quantitatively for paint chip samples if results are to be reported in mg/cm 2.Ziplock baggies can be used only if results are to be reported in pg/g or percent by weight.
removal.

2. Containment

a. Method One: Plastic Sheeting Underneath Samzling Area

A clean sheet of plastIc measuring four feet by four feet should be placed under the area

to be sampled to capture any paint chips that are not captured by the collection device or

creased piece of paper. Any visible paint chips falling to the plastic should be included in

the sample. Dispose of the plastic after each sample is collected by placing the sheeting

in a trash bag. Do not throw away the plastic at the dwelling. Wet wipes may be used to

clean the area.

b. Method Two: “Glovebag” Approach

If further containment is deemed necessary, a “glovebag” approach may be used.

A

durable sheet of plastic is loosely taped to the surface to be sampled, with a paint

scraper, collection device, and shipment container housed inside the plastic. There

should be enough ‘play” in the plastic to permit a scraping motion without dislodging the

tape holding the plastic to the surface. Large plastic baggies can be used in lieu of the.

sheet of plastic if paint chips are to be shipped to the lab in plastic baggies. Properly

conducted, this method completely seals the surface during the actual scraping

operation.

A four by four foot sheet of plastic is still required under the glove bag to

capture any debris that falls to the ground during tne glove bag removal. The tape

should be slowly removed from the surface to avoid lifting any additional caint off of the

surface.

3. Paint Sample Collection

The paint chip sample need not be more than 2-4 square inches in size (consult with the

laboratorv for the optional size). Persons collecting paint chips should wear new

disposable gloves for each sample. The most common paint sampling method is to

scrape paint directly off the substrate. The goal is to remove all layers of paint equally,

but none of the substrate.

A heat gun should be used to soften the paint before removal

to reduce the chances of including substrate with the sampe and to help prevent sample

loss. Including substrate in the sample will dilute the lead content if results are reported

in pg/g or weight percent. Hold the heat gun no closer than six inches from the surface.

Do not scorch the paint. Discontinue heating. as soon as softening or blistering is

observed. Use a razor-sharp scraper to remove paint from the substrate. Paint samples

collected in this fashion are usually reported in gJg or

% cad only. The sample may be

placed in a baggie fcr shipmert to the laboratory. If the area sampled is measured

exactly, and all the paint within that area can be removed and coflebted, it is possible to

also report the results in mg/cm 2.All of thesample must be placed in a hard-shelled

container for shipment to the laboratory. The hard-shelled container is used since the

laboratory wiH analyze the entire sampe submitted. The exact dimensions of the area

sampled must be recorded on the fied samplng form. Fcr mg/cm 2,including

a small

amount of substrate in the sample is permitted.
o 

t

an 5 subsamples should be included in the same sample container or ziplock baggie. If both single-surface and composite samples are collected side-by-side, the individual samples can be submitted for analysis without returning to the dwelling if the composite result is above the composite standard. If the laboratory does not analyze the entire composite sample, it mustuse a validated homogenizing technique to ensure that all sub-samples are completely mixed together.

5. Cleanup and Repair

a. All settled dust generated must be cleaned up using wet wipes. b. The surface can be resealed with new paint if necessary. If desired, apply spackling and/or new paint to repair the area where paint was removed.

c. Personnel conducting paint sampling should avoid hand-to-mouth contact

(specifically, smoking, eating, drinking, and applying cosmetics) and should wash

their hands with running water immediately after sampling. The inspector should ask to use the resident’s bathroom for this purpose. Wet wipes may be used if no running water is available or if the bathroom is not available.

6. Laboratory Submittal

The samples should be submitted to a laboratory recognized by the EPA National Lead Laboratory Accreditation Program. Appropriate sample submittal forms should be used.

The field sample number should appear on the field sampling form, the laboratory submittal form, and the container label. The name of the laboratory, the date the samples were sent to the lab, and all personnel handling the sample from the time pf collection to the time of arrival at the laboratory should be recorded on a chain of

custody form, if appropriate. See Appendix 14 for the laboratory analytical procedures to be used.

7. Qualifications of Paint Sampling Technicians

All individuals performing paint sampling should be certified. Where possible, field experience in environmental sampling is preferable.8. Other Information

See ASTM ES 28-94 and ES 37-94 for additional information

Protocol For Housing

A. Collection Technique General Description

Bare soil samples are typically collected with a coring device or

a scooping technique. The device may be used in either of two ways. Most coring devices come equipped with

a “T” handle which can be attached to the top of the coring tool or probe. This allows the

operator to push the tool into the ground. The coring tool can be twisted with the “V’

handle as it is pushed into the ground in order to allow the cutting edge of the soil probe

to cut through roots and packed earth. In softer soils, a disposable new plastic syringe at
p

g

y 

then pulled from the ground and the sofl sample is pushed so that the upper part of the

soil plug lies between one inch marks made on the coring device. The top one half inchof the soil sample is tnen cut from the core with a stainless steel knife or cutting tool

provided for that purpose. Tnis top one haff inch section of the soil core is then

transferred to a sample container. All sub-samples are coliected in this manner. The

collection of subsamples from the sampling line is referred to as a “composite” sample.

After collecting a composite sample, the soil probe should be decontaminated or

discarded if disposable core liners are used. This process consists of wiping the end of

the probe with wet wipes until no more visible dirt is removed from the probe. Similar

cores are then collected from the bottom inch of the six-inch core.

B. Materials and Supplies

1. Core sampling device: Standard soi coring device. Other similar core sampling

devices may be used, such as disposable plastic syringes with the end cut off. The

plunger is used to remove the soil from the syringe body. 2. Disposable wipes.

3. Non-sterilized 5”

x 8” plastic ziplock baggies: Unless baggies are

4 mu industrial

strength, they must be double bagged.

4. Nori-sterilzed non-powdered disposable gloves: For example, Action Scientific

(800-678-1033) No. A-IDE

5. Floor Plan

& Property Sketch

6. Soil Sample Collection Form

7. Laboratory submittal form

8. Pre-printed labels or permanent ink pen

9. Trash bag or other receptacle (do not use pockets or trash containers at the

residence)

C. Bare Soil Sampling Procedures

1. Soil sampling is not recommended when the ground is frozen.

2. The location of soil samples should be recorded on the exterior site plan sketch.

3. Perimeter Sampling Locations: One composite soil sample should be collected so

that at least 5 and no more than 10 different aliquots of surface soil are collected

from the building perimeter. The aliquots should be collected from all sides of the

building where bare soil is present. Each spot should be at east

2 feet distant frDm

each other and

2 feet away from the foundation, unless the bare soil s closer than

2 feet.

4. Play Area Sampling Locations:

A second composite sample should consist of at

least 5 and nc more than 10 aliquots coflected along an X-shaped grid in the child’s

principle play area. Each spot should be at least 1 foot distant from each other.

The soil where the aliquots are collected must be bare.

5. The core sampling device should be used to deliver the top 1/2 inch of soil from

each spot to the baggie. No special effort should be made to collect visible paint

chips. If paint chips are present, they should not be avoided and should be included
g

y

- 0. Laboratory Submittal

1. Submittal Form Preparation The sample numbers on the sample container must be the same as those on the field sampling form and must also be used on the laboratory submittal form. Confirm that all sample recorded on are in fact present on the laboratory submittal form. Chain of custody requirements should be followed if applicable.

E. Laboratory Analytical Procedure.

1. Laboratories analyzing soil samples must participate in the Environmental Lead Laboratory Proficiency Testing Program or equivalent and be an EPA..NLLAP Accredited Laboratory.

2. Soil samples are received, logged in, opened and placed on drying plates, dried, and mixed thoroughly.

3. Sample sieving: Samples are to be sieved once with

a number 10 sieve with

a mesh size of

2 milLimeters. Visible paint chips are disaggregated by forcing the paint chips and other large particles through the sieve by

a rubbing motion. Sieving is always done under

a laboratory hood. 4. Samples are oven dried to

a constant weight and analyzed by EPA Method SW-846

or equivalent.

F. See ASTM ES 29-94 for further information.