_________________________________________________

This EP Supercedes EP 1110-1-31 Dated 15 September 2000

CEMP-RA

Pamphlet No.

1110-1-31

Department of the Army

U.S. Army Corps of Engineers

Washington, DC 20314-1000

EP 1110-1-31

31 August 2001

Engineering and Design

COMBINED LEAD INSPECTION/RISK 

ASSESSMENT

FOR TARGET HOUSING PROPERTY TRANSFERS

 STANDARD SCOPE OF WORK

Distribution Restriction Statement

Approved for public release; distribution is unlimited.

This Engineering Pamphlet has been 

developed to incorporate the 

Environmental Protection Agency’s 

definition of lead hazards to young 

children as published in 40 CFR 745 

Subpart D: Lead, Identification of 

Dangerous Levels of Lead; Final Rule, 5 

January 2001

EP 1110-1-31

31 Aug 01 

A-1

APPENDIX A

COMBINED LEAD INSPECTION/RISK ASSESSMENT

FOR TARGET HOUSING PROPERTY TRANSFERS

 STANDARD SCOPE OF WORK

TABLE OF CONTENTS

1.0 PROJECT OVERVIEW, OBJECTIVES, AND DESCRIPTION OF WORK....................................................A-5

1.1 REFERENCES ...............................................................................................................................................................A-5

1.1.1 Federal.....................................................................................................................................................................A-5

1.1.1.1 Consumer Product Safety Commission (CPSC)..........................................................................................A-5

1.1.1.2 U.S. Environmental Protection Agency (EPA)............................................................................................A-5

1.1.1.3 U.S. Department of Housing and Urban Development (HUD) ................................................................A-5

1.1.1.4 Occupational Safety and Health Administration (OSHA).........................................................................A-6

1.1.2 U.S. Army (DA) ....................................................................................................................................................A-6

1.1.2.1 Army Regulation (AR) AR 200-1, Environmental Protection and Enhancement .................................A-6

1.1.2.2 AR 420-70, Facilities Engineering, Buildings and Structures...................................................................A-6

1.1.2.3 DA Public Works Technical Bulletin 420-70-2, Installation Lead Hazard Management....................A-6

(see http://www.usacpw.belvoir.army.mil/ pubs/pubs.htm)........................................................................................A-6

1.1.2.4 DA Memorandum (DAIM-FD (420-70)) Subject: Guidance for Lead-Based Paint Hazard 

Management During Transfer of Army Real Property, 28 March 2000, as applicable..........................................A-6

1.1.2.5 DA Hazardous Asbestos and Lead Optimal Management System (HALO)..........................................A-6

1.1.2.6 U.S. Army Corps of Engineers EM 385-1-1, Safety & Health Requirements Manual.........................A-6

1.1.3 State, Local, Outside Continental United States (OCONUS), Host Nation Agreements, etc. .................A-6

1.1.4 Other Organizations..............................................................................................................................................A-6

1.1.4.1 American Association for Laboratory Accreditation (A2LA)..................................................................A-6

1.1.4.2 American Industrial Hygiene Association (AIHA).....................................................................................A-6

1.1.4.3 American Society for Testing and Materials (ASTM)...............................................................................A-7

1.2 REGULATORY REQUIREMENTS..........................................................................................................................A-7

1.2.1 Regulatory Authority/Requirements ..................................................................................................................A-7

1.2.1.1 Federal Requirements.......................................................................................................................................A-8

1.2.1.2 State and Local Requirements.........................................................................................................................A-8

1.3 SITE CHARACTERISTICS, OBJECTIVES AND DESCRIPTION OF WORK..............................................A-8

1.3.1 Site Location/Characteristics and Occupant Use Patterns..............................................................................A-8

1.3.2 Previous Studies and Results...............................................................................................................................A-9

1.3.3 Project Work Tasks/Description or Work.........................................................................................................A-9

1.3.4 Unit Selection Strategy .........................................................................................................................................A-9

1.3.5 Data Quality Objectives (DQOs)......................................................................................................................A-10

1.3.6 Bid Assumptions..................................................................................................................................................A-11

2.0 PROJECT REQUIREMENTS...................................................................................................................................A-12

2.1 TASK 1 DESCRIPTION OF CURRENT CONDITIONS/PROJECT WORK PLAN....................................A-12
EP 1110-1-31

31 Aug 01

A-2

2.1.1 Background Data.................................................................................................................................................A-12

2.1.1.1 Lead Hazard Management Plan Review.....................................................................................................A-12

2.1.1.2 Interviews .........................................................................................................................................................A-12

2.1.1.3 Summary of Preexisting Data, [Lead Hazard Management Plan] and Interviews..............................A-13

2.1.2 Project Boundaries Identification/Floor Plans................................................................................................A-13

2.1.3 Preliminary Site Visit/Walkover.......................................................................................................................A-14

2.1.4 Occupant Notification/Housing Unit Access..................................................................................................A-14

2.1.5 Project Work Plan ...............................................................................................................................................A-14

2.2 TASK 2 – CONDUCT LEAD INSPECTION/RISK ASSESSMENT................................................................A-15

2.2.1 Lead Inspection....................................................................................................................................................A-15

2.2.1.1 Visual Assessment ..........................................................................................................................................A-15

2.2.1.2 Substrate Correction .......................................................................................................................................A-15

2.2.1.3 Surface Testing Using XRF Measurement .................................................................................................A-16

2.2.1.4 Classification of XRF Results.......................................................................................................................A-16

2.2.1.5 Specific Requirements for Multi-Family Housing....................................................................................A-17

2.2.2 Risk Assessment ..................................................................................................................................................A-17

2.2.2.1 Visual Assessment ..........................................................................................................................................A-17

2.2.2.2 Sample Location Selection............................................................................................................................A-18

2.2.2.3 Risk Assessment Sample and Sample Location Documentation ............................................................A-21

2.2.3 Single Surface Dust Sampling...........................................................................................................................A-21

2.2.4 Deteriorated Paint Chip Sampling....................................................................................................................A-21

2.2.5 Soil Sampling.......................................................................................................................................................A-22

2.2.6 Sample Identification ..........................................................................................................................................A-22

2.2.7 Sample Chain-of-Custody ..................................................................................................................................A-22

2.2.8 Decontamination..................................................................................................................................................A-23

2.3 TASK 3 SAMPLE DATA ANALYSIS, EVALUATION OF FINDINGS .......................................................A-23

2.3.1 XRF Data Interpretation .....................................................................................................................................A-23

2.3.2 Sample Preparation and Analysis .....................................................................................................................A-23

2.3.2.1 Dust Sample Preparation and Analysis .......................................................................................................A-23

2.3.2.2 Paint Chip Sample Preparation and Analysis .............................................................................................A-24

2.3.2.3 Soil Sample Preparation and Analysis.........................................................................................................A-24

2.3.2.4 Laboratory Turnaround Time........................................................................................................................A-24

2.3.3 Quality Assurance and Quality Control (QA/QC).........................................................................................A-24

2.3.3.1 XRF Performance Validation and Verification..........................................................................................A-24

2.3.3.2 Field Blank Dust Wipe QA Samples...........................................................................................................A-25

2.3.3.3 Field Spike Dust Wipe QA Samples............................................................................................................A-25

2.3.3.4 Field Duplicate/Spike Paint Chip QA Samples .........................................................................................A-26

2.3.3.5 Field Rinsate Blank QA Samples (Soil)......................................................................................................A-27

2.3.3.6 Matrix Spike/Matrix Spike Duplicate (MS/MSD) Soil QC Samples.....................................................A-27

2.3.4 Project Data Review and Assessment ..............................................................................................................A-27

2.3.4.1 Field Dust Wipe Quality Assurance Verification ......................................................................................A-28

2.3.4.2 Laboratory QA and QC Verification. ..........................................................................................................A-28

2.3.4.3 Contractor Certification of Project Data Validity......................................................................................A-29

2.3.4.4 Comparison with Table A-1 Lead Hazard Action Levels ........................................................................A-29

2.3.4.5 Laboratory Report ...........................................................................................................................................A-29

2.4 TASK 4 LEAD INSPECTION/ RISK ASSESSMENT REPORT .....................................................................A-30

2.4.1 General Report Contents....................................................................................................................................A-30

2.4.2 Summary of Pre-Existing Data Lead Hazard Management Plan and Interviews.....................................A-31

2.4.3 Other Field and Laboratory Data......................................................................................................................A-31
EP 1110-1-31

31 Aug 01 

A-3

2.4.4 Contractor Data Certification ............................................................................................................................A-31

2.4.5 Project Data Presentation/Electronic/HALO Data Downloading...............................................................A-31

2.4.6 Update Installation Management Plan.............................................................................................................A-32

2.4.7 Comparison of Contractor Findings to Installation HALO Findings.........................................................A-32

2.4.8 Contractor Conclusions and Recommendations............................................................................................A-32

2.4.9 Lead Hazard Identification Summary ..............................................................................................................A-33

2.4.10 Regulatory Statements of Compliance.............................................................................................................A-33

3.0 SUPPLEMENTAL REQUIREMENTS FOR CONTRACTED SERVICES ....................................................A-33

3.1 CONTRACTOR FIRM/PERSONNEL QUALIFICATIONS..............................................................................A-33

3.1.1 Contractor Firm Experience ..............................................................................................................................A-33

3.1.2 Contractor Lead Inspector/Risk Assessor/Project Manager Qualifications ..............................................A-33

3.1.2.1 EPA Certification............................................................................................................................................A-34

3.1.2.2 State and Local Certification.........................................................................................................................A-34

3.1.2.3 Radioactive Materials License......................................................................................................................A-34

3.1.2.4 Evidence of Certification...............................................................................................................................A-34

3.1.2.5 Record of Experience .....................................................................................................................................A-34

3.1.2.6 Use of Lead Inspector/Risk Assessment Teams........................................................................................A-34

3.1.2.7 Project Manager Experience .........................................................................................................................A-36

3.1.3 Contracted Laboratory Qualifications..............................................................................................................A-36

3.1.4 Contractor Errors and Omissions Liability Insurance ...................................................................................A-36

3.2 PROJECT RECORDS.................................................................................................................................................A-36

3.2.1 Record keeping Requirements ..........................................................................................................................A-36

3.2.1.1 Project Work Plan...........................................................................................................................................A-37

3.2.1.2 Lead Inspection/Risk Assessment Report ...................................................................................................A-37

3.3 PROJECT COORDINATION ...................................................................................................................................A-37

3.4 GOVERNMENT SUPPORT ......................................................................................................................................A-37

3.4.1 Government Quality Control Oversight ..........................................................................................................A-37

3.4.2 Security and Escorts............................................................................................................................................A-37

3.4.3 Temporary Office/Equipment Storage/Staging Areas ..................................................................................A-38

3.5 TRAVEL AND MEETINGS .....................................................................................................................................A-38

3.5.1 Preliminary Project Site Visit/Walkover.........................................................................................................A-39

3.5.2 Project Work Plan Review and Start-up Meeting..........................................................................................A-39

3.5.3 Data Certification Meeting ................................................................................................................................A-39

3.5.4 Final Lead Inspection/Risk Assessment Report Meeting.............................................................................A-39

3.5.5 Additional Meetings............................................................................................................................................A-39

3.6 SCHEDULES................................................................................................................................................................A-40

3.7 SUBMITTALS .............................................................................................................................................................A-40

3.7.1 Project Work Plan ...............................................................................................................................................A-40

3.7.2 Progress Report(s)...............................................................................................................................................A-40

3.7.3 Final Lead Inspection/Risk Assessment Data Submission in Electronic Format .....................................A-40

3.7.4 Final Lead Inspection/Risk Assessment Report .............................................................................................A-40

3.7.5 Backup Data (optional).......................................................................................................................................A-41
EP 1110-1-31

31 Aug 01

A-4

3.8 MISCELLANEOUS....................................................................................................................................................A-41

3.8.1 Glossary.................................................................................................................................................................A-41

******************************************************************************

NOTE TO SCOPE OF WORK EDITOR

This Standard Scope of Work (SOW) is to be used for performing combined lead inspection/risk 

assessments at Department of Army (DA) properties known as target housing and child occupied 

facilities (see Glossary) that are being prepared for sale based on Section 1013 of Title X (42 

U.S.C. 4822) implemented by 24 CFR 35, 15 September 1999 (64 FR 50142). 

This SOW requires that the lead inspection/risk assessment be performed at one time, thereby 

minimizing cost and disruption to housing occupants.

The lead inspection provides a report describing the location(s) of lead-based paint (LBP) and 

the risk assessment provides a report describing lead hazards found and control measures 

recommended eliminating the hazards.

This SOW is not to be used to mitigate lead hazards discovered during the lead inspection/risk 

assessment. Lead hazard abatement is contractually addressed under separate contract using U. 

S. Army Corps of Engineers Guide Specification 13281 “Lead Hazard Control Activities”.

This SOW does not include requirements for conducting elevated blood lead (EBL) 

investigations addressed in Reference 1.1.1.3.c of this SOW. EBL investigations are of concern 

at active target housing or child-occupied facilities and involve comprehensive analyses of all 

lead exposure sources to the child or children with EBL, both inside and outside the home, and 

can involve input and cooperation between a number of regulatory agencies.

This SOW does not include requirements to assess lead in drinking water. This issue is 

adequately covered under the Safe Drinking Water Act monitoring requirements, should it 

become an issue at the time of sale or transfer of property.

The editor of this SOW should note the following conventions used throughout this Standardized 

SOW: 1) [brackets] indicate that the SOW editor must either select from the text within the 

brackets or provide project specific information for insertion into the text, and 2) when the 

complete text of a given paragraph is within [brackets] and the bracketed text is deleted the SOW 

editor must also delete the paragraph heading and renumber accordingly.

The editor of this SOW must have a certificate of completion of current U.S. Environmental 

Protection Agency (USEPA) training or state training (if required by the state where the work is 

to be performed) as a certified lead inspector/risk assessor (see 40 CFR 745.223). In addition, 

the SOW editor must be familiar with Federal, state and local requirements applicable in the 

jurisdiction in which the project is to be completed. Contact state and local authorities to 

determine whether established requirements and procedures are more restrictive than those 

outlined in this SOW. State contacts for the Centers for Disease Control Childhood Lead 

Poisoning Prevention Program may be found on the Internet at 
EP 1110-1-31

31 Aug 01 

A-5

http://www.cdc.gov/nceh/program/lead/grants/contacts/contacts.htm

******************************************************************************

1.0 PROJECT OVERVIEW, OBJECTIVES, AND DESCRIPTION OF WORK

1.1 REFERENCES

1.1.1 Federal

1.1.1.1 Consumer Product Safety Commission (CPSC)

a. CPSC Finds Lead Poisoning Hazard for Young Children in Imported Vinyl 

Miniblinds, Press Release 96-150, June 25, 1996 

(see http://www.cpsc.gov/cpscpub/prerel/prhtml96/96150.html) 

1.1.1.2 U.S. Environmental Protection Agency (EPA)

a. EPA National Lead Laboratory Accreditation Program, (NLLAP) Laboratory 

Quality System Requirements (LQSR) Revision 2.0, August 1, 1996

(see http://www/epa/gov/opptomtr/lead/nllapacr.txt)

b“Lead; Requirements for Lead-Based Paint Activities in Target Housing and ChildOccupied Facilities”, 40 CFR Part 745, Subpart L, Lead-Based Paint Activities; Final Rule, 61 

FR 45813, August 29, 1996, 

c. “Lead; Requirements for LBP Activities in Target Housing and Child-Occupied 

Facilities; Certification Requirements and Work Practice Standards for Individuals and Firms, 

Amendment”; 40 CFR Part 745, Subpart L, Lead-Based Paint Activities; Final Rule, 64 FR 

42849, August 6, 1999.

d. “Lead; Identification of Dangerous Levels of Lead”, Final Rule, 40 CFR Part 

745, Subpart D Lead-Based Paint Hazards, and Subpart L, Lead-Based Paint Activities, 66 FR 

1206, January 5, 2001.

 1.1.1.3 U.S. Department of Housing and Urban Development (HUD)

a. Requirements for Notification, Evaluation, and Reduction of Lead-Based Paint 

Hazards in Federally Owned Residential Property and Housing Receiving Federal Assistance; 

Final Rule 24 CFR Part 35, September 15, 1999. 
EP 1110-1-31

31 Aug 01

A-6

b. Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in 

Housing, U.S. Department of Housing and Urban Development, Government Printing Office, 

Washington, D.C. June 1995. (Chapter 7 revised 1997)

c. The Lead Listing, The National Lead Service Providers' Listing System. This 

listing is accessible on the Internet at http://www.leadlisting.org.

1.1.1.4 Occupational Safety and Health Administration (OSHA)

a. Lead Exposure in Construction; Interim Final Rule 29 CFR 1926.62, May 4, 

1993.

1.1.2 U.S. Army (DA)

1.1.2.1 Army Regulation (AR) AR 200-1, Environmental Protection and Enhancement

1.1.2.2 AR 420-70, Facilities Engineering, Buildings and Structures

1.1.2.3 DA Public Works Technical Bulletin 420-70-2, Installation Lead Hazard 

Management. 

(see http://www.usacpw.belvoir.army.mil/ pubs/pubs.htm)

1.1.2.4 DA Memorandum (DAIM-FD (420-70)) Subject: Guidance for Lead-Based Paint 

Hazard Management During Transfer of Army Real Property, 28 March 2000, as applicable.

1.1.2.5 DA Hazardous Asbestos and Lead Optimal Management System (HALO)

1.1.2.6 U.S. Army Corps of Engineers EM 385-1-1, Safety & Health Requirements Manual

1.1.3 State, Local, Outside Continental United States (OCONUS), Host Nation Agreements, 

etc.

[Insert applicable references]

1.1.4 Other Organizations

1.1.4.1 American Association for Laboratory Accreditation (A2LA)

 Environmental Lead Program Requirements, February 1994. (A2LA offers accreditation under 

NLLAP.)

1.1.4.2 American Industrial Hygiene Association (AIHA)

Analytical Quality Programs Quality Manual and Policies, Environmental Lead Laboratory 

Accreditation Program (ELLAP) and Industrial Hygiene Laboratory Accreditation Program, July 

1997. (http://www.aiha.org)
EP 1110-1-31

31 Aug 01 

A-7

1.1.4.3 American Society for Testing and Materials (ASTM)

a. E1605, Standard Terminology Relating to Abatement of Hazards from LeadBased Paint in Buildings and Related Structures

b. E1613, Standard Test Method for Analysis of Digested Samples for Lead by 

Inductively Coupled Plasma Atomic Emission Spectrometry (ICP-AES), Flame Atomic 

Absorption (FAAS), or Graphite Furnace Atomic Absorption (GFAAS) Techniques

c. E1644, Standard Practice for Hot Plate Digestion of Dust Wipe Samples for the 

Determination of Lead by Atomic Spectrometry

d. E1645, Standard Practice for the Preparation of Dried Paint Samples for 

Subsequent Lead Analysis by Atomic Spectrometry

e. E1726, Standard Practice for Sample Digestion of Soils for the Determination of 

Lead by Atomic Spectrometry

f. E1727, Standard Practice for Field Collection of Soil Samples for Lead 

Determination by Atomic Spectrometry Techniques

g. E1728, Standard Practice for Field Collection of Settled Dust Samples Using 

Wipe Sampling Methods for Lead Determination by Atomic Spectrometry Techniques

h. E1729, Standard Practice for Field Collection of Dried Paint Samples for Lead 

Determination by Atomic Spectrometry Techniques

i. E1792, Standard Specification for Wipe Sampling Materials for Lead in Surface 

Dust

j. E1979, Standard Practice for Ultrasonic Extraction of Paint, Dust, Soil, and Air 

Samples for Subsequent Determination of Lead

k. PS95-98, Standard Provisional Practice For Quality Systems For Conducting In 

Situ Measurements Of Lead Content In Paint Or Other Coatings Using Field Portable X-Ray 

Fluorescence (XRF) Devices

l. PS116-99, Provisional Practice For The Performance Evaluation Of The 

Portable X-Ray Fluorescence Spectrometer For The Measurement Of Lead In Paint Films

1.2 REGULATORY REQUIREMENTS 

1.2.1 Regulatory Authority/Requirements
EP 1110-1-31

31 Aug 01

A-8

The Contractor shall conduct all work in accordance with the following Federal, state, and local 

regulations and requirements. Where inconsistencies exist between the requirements and this 

Scope of Work (SOW), the Contractor shall use the most protective. 

1.2.1.1 Federal Requirements

a. Lead Inspection/Risk Assessment Procedures and Requirements.

The Contractor shall comply with 24 CFR 35 Subparts B, C and R; and 40 CFR 745 Subpart D 

and L (as amended) in meeting the requirements of this SOW. Referenced methodologies in 

Lead-Based Paint Guidelines for Disposal of Department of Defense Residential Real PropertyA Field Guide, the Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in 

Housing, HUD, June 1995 (Chapter 7 Revision, 1997) shall be used where applicable. Lead 

hazards shall be identified based on “Lead; Identification of Dangerous Levels of Lead”; 40 

CFR 745 Final Rule, 66 FR 1206, 5 January 2001. The Contractor shall comply with DA Public 

Works Technical Bulletin 420-70-2, Installation Lead Hazard Management regarding use of DA 

Hazardous Asbestos and Lead Optimal Management System (HALO) (See Glossary).

b. Health and Safety Requirements

The Contractor shall comply with applicable OSHA standards and with the USACE Safety and 

Health Requirements Manual, EM 385-1-1, to include the submission of an Accident Prevention 

Plan (APP) to the Contracting Officer (See Glossary) prior to performing field activities. Field 

activities shall not begin without acceptance of the APP.

1.2.1.2 State and Local Requirements

******************************************************************************

NOTE: Reference state, local, (and OCONUS if applicable) or installation-specific 

requirements that differ from the federal requirements cited above that are applicable to 

the work addressed in this SOW.

******************************************************************************

[The Contractor shall comply with the following state [and local] [and installation] requirements 

in completing the activities required by this SOW. [Insert applicable references]]

1.3 SITE CHARACTERISTICS, OBJECTIVES AND DESCRIPTION OF WORK

1.3.1 Site Location/Characteristics and Occupant Use Patterns

******************************************************************************

NOTE: Identify the target housing/child-occupied facilities to be addressed in the 

combined inspection/risk assessment on a unit-by-unit basis. Provide site location 
EP 1110-1-31

31 Aug 01 

A-9

information including installation or building designations, unit addresses and floor plans. 

Attach the information to the SOW. Summarize any physical characteristics and 

occupant use pattern information (see Glossary) that may be relevant to the risk 

assessment in light of the property transfer, that the Contractor must review by 40 CFR 

745 Subpart L. This SOW requires the Contractor to collect detailed physical 

characteristics information during the visual assessment in Task # 2 using Forms 1 and 2 

(Figure B-1 and Figure B-2, Appendix B).

******************************************************************************

The Contractor shall perform lead inspections/lead risk assessments at [insert unit description

information]. Procedures and requirements for conducting these activities are defined in the 

following paragraphs. The physical characteristics, and occupant use patterns include [insert 

physical characteristic and occupant use pattern descriptive information].

1.3.2 Previous Studies and Results 

******************************************************************************

NOTE: Include previous lead studies and results that are to be reviewed and considered 

by the lead inspector/risk assessor in making decisions and conclusions for the work 

specified in this SOW.

******************************************************************************

[Prior to initiating field activities required by this SOW, the lead inspector/risk assessor shall 

review the previous study data results collected at the location(s) provided as an attachment to 

this SOW.]

1.3.3 Project Work Tasks/Description or Work

The project work tasks include: [describe each project specific work task that is required to 

accomplish the Tasks described in this SOW]. The lead inspections/risk assessments shall 

include a visual assessment, and sampling each testing combination (see Glossary) for the 

presence of LBP, and where found, sampling for the identification of lead hazards at each unit 

included in the survey. Procedures and requirements for completing the inspection/risk 

assessment activities are defined in the paragraphs that follow. The combined lead 

inspection/risk assessment shall be performed at one time in each selected unit. 

1.3.4 Unit Selection Strategy

******************************************************************************

NOTE: All lead inspections/risk assessments involving multi-family housing units 

greater than 20 units of similar construction and maintenance histories at Army 

installations shall be evaluated using random sampling strategy. All single unit housing, 

multi-unit housing comprised of 20 or fewer units, and all units that have dissimilar 
EP 1110-1-31

31 Aug 01

A-10

construction or maintenance histories must be evaluated individually. Housing unit 

access and common area sampling strategies must also be addressed as a part of sampling 

strategy.

******************************************************************************

[The Contractor shall perform a lead inspection/risk assessment on each unit identified in this 

SOW.]

[The Contractor shall randomly select (see Glossary) the housing units for lead inspection/risk 

assessment from the total unit population. The minimum number that must be randomly selected 

shall be determined by using Table B-1 (Appendix B). The Contractor shall randomly select 

alternate housing units beyond the minimum number required in Table B-1 to provide flexibility 

based on information obtained on site and the success in gaining access to the selected housing 

units. The procedure used to randomly select the units shall be specified in the Project Work 

Plan.]

1.3.5 Data Quality Objectives (DQOs)

******************************************************************************

NOTE: Refer to EPA’s “Lead; Identification of Dangerous Levels of Lead”, Final Rule, 

66 FR 1206, 5 January 2001, and “Requirements for Notification, Evaluation, and 

Reduction of Lead-Based Paint Hazards in Federally Owned Residential Property and 

Housing Receiving Federal Assistance”; Final Rule 24 CFR Part 35, September 15, 1999 

for guidance in applying the action levels to use for the project.

******************************************************************************

The Contractor shall meet the project-specific DQOs (see Glossary) for the sampling, analysis 

and Quality Assurance/Quality Control (QA/QC) by meeting the requirements of Paragraphs 2.2 

and 2.3. DQOs must be met in order to provide project required data quality. The data thus 

collected shall be compared to the action levels defining lead hazards provided in Table A-1 

below. If the data are below the action levels, recommendations shall be made in the Lead 

Inspection/Risk Assessment Report in accordance with Paragraph 2.4.10.

Table A-1

Lead-Based Paint and Hazard Leve ls for a Lead Inspection/Lead Risk Assessment

Sample Matrix/Surface Type Action and Lead Hazard Level1

Lead-based paint1 1.0 mg/cm2 (XRF)

0.5% by weight or 5,000 μg/g (paint chip if not used 

in conjunction with XRF measurements. If paint 

chip is used in conjunction with XRF measurements, 

lab must report paint chip lead loading in units of 

mg/cm2 and must specify paint chip sample 
EP 1110-1-31

31 Aug 01 

A-11

collection techniques required to the contractor)

Deteriorated Paint Any Lead-Based Paint on any substrate (interior or 

exterior) that is peeling, chipping, chalking or 

cracking, or otherwise damaged or separated from 

the substrate.

Paint-lead Hazard Any friction surface subject to abrasion with 

horizontal dust lead levels below and nearest the 

surface equal or exceed Dust-Lead Hazard levels in 

this Table. 

Any chewable lead-based paint surface with teeth 

marks.

Damaged or deteriorated lead-based paint impact 

surface such as caused by door knobs or out-ofplumb doors. 

Dust-Lead Hazard2 (single surface wipe 

sampling only)

All Floors, Hard Surface and Carpeted

Interior Window Sills

40 μg/ft2

250 μg/ft2

Floors or windowsills in unsampled dwellings or 

common areas part of multi-family units if at least 

one sampled unit tested positive for these 

parameters.

Soil-Lead Hazard2: Bare Soil :Child Play 

Area

>400 ppm

Soil-Lead Hazard2 : Remainder of Yard 

Excluding Child Play Areas 

>1200 ppm

1

 See Glossary 

2 See 40 CFR 745.223 for definition. 

1.3.6 Bid Assumptions

******************************************************************************

NOTE: Review lead inspection/risk assessment sampling, analysis, QA/QC and 

reporting tasks that will be performed in Paragraphs 2.0 through 2.4. Typically, 135 XRF 

shots are taken in a three-bedroom home with a cost range per shot of $1.50 to $2.00 

each. Six to eight dust wipes are typically sampled per unit during most risk assessments. 

Three paint chip samples should be allowed for each unit, either to confirm XRF readings 

or for deteriorated paint or paint on small surfaces. A total of two composite soil samples 

per unit are also typical for most risk assessments. One QA dust spike sample for each 50 

field wipes, and QA paint chip samples at 1% to 5% of total paint chip samples collected 

should be allowed. Typical lab cost for lead dust, paint chip, and soil can range to $25.00 

per sample keeping in mind that an NLLAP recognized lab must be used. The prices 

may vary depending on geographical region. Check with qualified labs in the area that 
EP 1110-1-31

31 Aug 01

A-12

are likely to be used. It may be cost-effective to overnight mail samples to remote labs 

with known proficiency and cost savings in lead analysis. This information can easily be 

obtained by asking some of the large national consultants that do business with the 

District Office in other areas. In the bid, ask the contractor to provide a unit cost per 

sample to be charged by them in calculating their overall proposal, in the event additional 

samples beyond those projected must be collected once the contract begins (e.g., resampling certain areas, etc.) or there is a reduction in samples. Consult with the 

contracting officer. Also include the requirement for a preliminary site walkover.

******************************************************************************

Bid assumptions include: [insert assumptions as applicable]

2.0 PROJECT REQUIREMENTS

2.1 TASK 1 DESCRIPTION OF CURRENT CONDITIONS/PROJECT WORK PLAN

******************************************************************************

NOTE: Determine the need for the Contractor to review information contained in the 

installation’s Lead Hazard Management Plan if one is available and conduct interviews 

with personnel familiar with the unit histories, in the Contractor’s development of the 

Project Work Plan and Risk Assessment Sampling Plan.

******************************************************************************

2.1.1 Background Data 

The Contractor shall review general information on physical characteristics and occupant use 

patterns affecting children under six years old for the units that will be addressed in the lead 

inspection/risk assessment, [and preexisting survey data ] prior to performing Task 2.

2.1.1.1 Lead Hazard Management Plan Review

[The Contractor shall review the installation’s Lead Hazard Management Plan, including the 

history of LBP hazards in the units to be assessed in this SOW.]

2.1.1.2 Interviews

[The Contractor shall conduct interviews of personnel familiar with facility history and with 

facility use patterns. Personnel to be interviewed shall include:

a. Installation Lead Hazard Management Team Leader

b. Installation Environmental Officer - to determine if LBP has been found in 

previous assessments, to identify LBP locations, to verify maintenance histories, and to 
EP 1110-1-31

31 Aug 01 

A-13

coordinate unit access procedures.

c. Director of Public Works - to discuss assessment logistics, e.g., access and 

assessment scheduling

d. [The Safety Officer]

e. [Installation Medical Authority – to review the Childhood Lead Poisoning 

Prevention Program (CLPP Program)]

f. [The Chief of Housing – to coordinate assessment logistics including occupant 

access and notification procedures]

g. [Any team members of the BRAC team to consider any requirements that may be 

imposed for property transfer. This might include report format, transmission of data, use of 

local subcontractors, etc.]

2.1.1.3 Summary of Preexisting Data, [Lead Hazard Management Plan] and Interviews

[The Contractor shall complete a project deliverable as an attachment to the Project Work Plan 

that summarizes the review of preexisting data, [the Lead Hazard Management Plan] and 

interviews for the units to be assessed, based on the information provided and addressed above. 

The summary shall address the following:

a. Reliability of Previously Collected Data

A brief summary of the reliability of data from previous studies.

b. Lead Hazard Management Plan

[A brief description of the Installation’s Lead Hazard Management Plan and summary of 

information pertinent to the Lead Inspection/Risk Assessment to be performed including any 

previous lead-based paint identification data, and maintenance history and practices.]

c. Interviews

A brief summary of the interviews and the conclusions reached.]

2.1.2 Project Boundaries Identification/Floor Plans

*****************************************************************************

NOTE: If digital site maps and floor plans for each type of unit are not available, the 

SOW editor may wish to have the contractor prepare Computer Assisted Design and 
EP 1110-1-31

31 Aug 01

A-14

Drafting (CADD) drawings of the units involved with the lead inspection/risk 

assessments. Such drawings should be prepared by the contractor in accordance with the 

Tri-Service GIS Spatial DATA Standards. Having the contractor prepare the CADD 

drawings can significantly increase the cost of the lead inspection/risk assessments.

*****************************************************************************

Site maps identifying individual units for all facilities that will be inspected/assessed, and floor 

plans/sketches for each type of unit are [provided in CADD format and] attached as a part of this 

SOW. The Contractor’s risk assessor shall use the [CADD] floor plans/sketches when 

performing Task 2 to identify and record sample locations. 

2.1.3 Preliminary Site Visit/Walkover

The lead inspector/risk assessor shall conduct a preliminary site visit/walkover. This walkover 

shall be used to ensure that all site-specific conditions and special accessibility requirements are 

addressed in the Project Work Plan and Lead Inspection/Risk Assessment Sampling Plan.

2.1.4 Occupant Notification/Housing Unit Access

******************************************************************************

NOTE: Occupant notification of planned lead inspection/risk assessment activities is an 

installation responsibility. Coordinate with the Director of Public Works, the 

Environmental Manager and the Housing Authority.

******************************************************************************

The Government shall notify the occupants of the units that will be inspected/assessed regarding 

the activities planned [insert text as applicable] days prior to beginning the assessment activities, 

and shall arrange access to housing units. The Contractor shall coordinate with the Contracting 

Officer and establish a schedule for unit entry based upon the contractor’s Lead Inspection and 

Risk Assessment Sampling Plans and requirements of Paragraph 3.4.2. The Contracting Officer 

shall be notified of the approximate schedule of any required field-repeated testing QC process at 

least [Insert number of day] days in advance. The Contracting Officer also has the right to 

request the contractor perform this repeated testing upon request, (unannounced visit) so long as 

these requests do not exceed 10% of the units surveyed.

2.1.5 Project Work Plan 

The Contractor shall prepare a project work plan after the preliminary site visit/walkover and 

preliminary review of this SOW. The project work plan shall address the following:

• Accident Prevention Plan (APP) including Radiation Safety Program describing 

procedures to limit and prevent radiation exposure from using XRF instruments 
EP 1110-1-31

31 Aug 01 

A-15

• Project work tasks/description of work including any recommended changes 

following preliminary walkover and review, including the [CADD] floor 

plans/sketches, and including [usability of preexisting data] unit access requirements, 

scheduling, escort requirements, and laboratory turn-around requirements if different 

than as specified in this SOW

• The Lead Inspection Sampling Plan to include unit and sample selection logic, and 

the type, model and serial number of each XRF unit and its associated Performance 

Characteristic (PC) Sheet. 

• Risk Assessment Sampling Plan to include unit and sample selection and analysis 

strategy.

• Project personnel/team identification and qualifications

• Identification and qualifications of each laboratory used to analyze lead samples

• [Summary of Preexisting Data, Lead Hazard Management Plan, and Interviews]

2.2 TASK 2 – CONDUCT LEAD INSPECTION/RISK ASSESSMENT

******************************************************************************

NOTE: Under Task 2 the lead inspection and risk assessments are to be accomplished 

concurrently. 

******************************************************************************

2.2.1 Lead Inspection

The lead inspection shall be conducted using an X-Ray Fluorescence Analyzer (XRF) that meets 

the performance requirements specified in this SOW.

2.2.1.1 Visual Assessment

The lead inspector/risk assessor shall as a part of the visual assessment of the lead inspection, 

identify each interior and exterior component or component system (see Glossary) with a distinct 

painting history for the housing units to be inspected as shown on the floor plans/sketches 

provided as part of this SOW and included as part of the Project Work Plan.

The contractor shall prepare as a part of the visual assessment a list of all testing combinations 

(see Glossary) of the component or component systems in all interior rooms, on all exteriorbuilding surfaces, and on surfaces in other exterior areas, such as fences, playground equipment, 

and garages to be submitted with the Lead Inspection/Risk Assessment Report. Descriptions or 

identification of testing combinations shall be sufficiently detailed to permit verification by the 

Contracting Officer.

2.2.1.2 Substrate Correction

The lead inspector/risk assessor shall perform substrate correction using the red NIST SRM (1.02 

mg/cm2) over test locations that have been scraped clean of their paint covering. The lead 
EP 1110-1-31

31 Aug 01

A-16

inspector/risk assessor shall follow the computation methods for determining substrate correction 

values provided in the PC Sheet for each respective XRF instrument used during the survey. 

When scraping painted surfaces for substrate correction, the lead inspector/risk assessor shall 

contain the paint scrapings and dispose of the waste off-site. Wipe the scraped area and any 

surrounding area to avoid the release of leaded dust or debris.

For multi-family housing, randomly choose two housing units to collect and calculate substrate 

measurements, and use those values in all tested units, common areas, and exteriors. If 

substrates exist in common areas and exteriors that were not found in the unit interiors, select 

two locations from these areas for substrate correction.

The location of the substrate correction for each substrate material shall be indicated on the floor 

plans/sketches, and submitted as part of the QA/QC portion of the Lead Inspection/Risk 

Assessment Report.

2.2.1.3 Surface Testing Using XRF Measurement

The lead inspector/risk assessor shall test at least one location per testing combination, except for 

interior and exterior four-wall combinations comprising the typical room or building exterior, 

where four readings shall be taken, one on each wall. The selection of the test location for a 

specific testing combination shall be representative of the paint over the areas, which are most 

likely to be coated with old paint or lead-based paint coatings. All layers of paint shall be 

included and the XRF probe faceplate shall be able to lie flat against the surface at the test 

location. If no acceptable location for XRF testing exists for a given testing combination, a 

paint-chip sample shall be collected and submitted to the laboratory following the laboratory’s 

SOP for collecting paint chip samples to determine lead loading per cc of surface area, and 

ASTM’s Standard Practice for Field Collection of Dried Paint Samples for Lead Determination 

by Atomic Spectrometry Techniques (E 1729). All testing locations shall be marked on the floor 

plans/sketches and Form 1 (Figure B-1, Appendix B). 

 2.2.1.4 Classification of XRF Results

The lead inspector/risk assessor shall classify the XRF results as positive, negative or 

inconclusive as defined in the XRF instrument’s PC sheet. Test results are positive if they are 

greater than the upper boundary of the inconclusive range, negative if they are less than the 

lower boundary of the inconclusive range, or inconclusive if in between. The inconclusive range 

includes both its upper and lower bounds. All XRF readings and results shall be recorded for 

each testing combination tested at the time the readings are taken during and as a part of the 

visual assessment on Form 1 (See Figure B-1, Appendix B), compared to the Action and Lead 

Hazard Levels in Table A-1 and submitted as an attachment to the Lead Inspection/Risk 

Assessment Report. Field-repeated testing shall be accomplished, at no additional cost to the 

Government, in accordance with the XRF validation requirements of this SOW.
EP 1110-1-31

31 Aug 01 

A-17

Paint chip samples shall be collected for all inconclusive XRF readings in addition to those 

surfaces where the XRF cannot be properly operated (e.g., small, rounded, surfaces etc.). The 

location of all paint chip samples shall be documented on the building drawing and documented 

in accordance with this SOW.

2.2.1.5 Specific Requirements for Multi-Family Housing

******************************************************************************

NOTE: The following requirements should be selected for multi-family housing. These 

requirements are in addition to those listed in Paragraph 2.2.1 through 2.2.1.4. 

******************************************************************************

Contractor shall identify testing combinations and conduct XRF testing in common areas and 

building exteriors. The lead inspector/risk assessor shall classify XRF results following the 

Multi-Family Decision Flow Chart provided Figure B-2 Appendix B. Paint chip samples taken 

in accordance with the chart to confirm XRF readings shall be taken and submitted to the 

laboratory following the laboratory’s SOP for collecting paint chip samples to determine lead 

loading per cc of surface area, and ASTM’s Standard Practice for Field Collection of Dried 

Paint Samples for Lead Determination by Atomic Spectrometry Techniques (E 1729). 

2.2.2 Risk Assessment

2.2.2.1 Visual Assessment

****************************************************************************

NOTE: Since lead testing will be performed in conjunction with the risk assessment, the 

lead inspector/risk assessor shall immediately review XRF results and determine if the 

potential hazard areas contain LBP.

******************************************************************************

The lead inspector/risk assessor shall perform concurrently with the lead inspection visual 

assessment, an assessment of all selected units to locate potential LBP hazards and to evaluate 

the magnitude of each hazard. Following the floor plans or sketches, the lead inspector/risk 

assessor shall visually inspect the unit exterior and every room of each unit that will be assessed 

to evaluate paint and building conditions. Every lead-based paint component system with the 

same distinct painting history (see Glossary) testing positive for lead shall be inspected for 

deterioration.

The lead inspector/risk assessor shall review the XRF data recorded on Form 1 (see Figure B-1, 

Appendix B) and identify through observation:

• Any friction surface or impact surface with visibly deteriorated paint, and

• All other lead-based paint surfaces with visible deteriorated paint. 
EP 1110-1-31

31 Aug 01

A-18

• Visible dust

• Bare soil 

The lead inspector/risk assessor shall visually assess painted surfaces in common areas 

accessible to children. The lead inspector/risk assessor shall inspect deterioration on friction and 

impact surfaces by operating and examining the friction and/or impact surfaces of several of the 

windows and doors that are used most frequently (if known) that contain LBP. The visual 

assessment of each unit shall be documented using Form 2 and Form 3 (see Figures B-3 and B-4, 

Appendix B). The forms shall be submitted as attachments to the Lead Inspection/Risk 

Assessment Report.

2.2.2.2 Sample Location Selection

******************************************************************************

NOTE: Multi-unit common areas must be sampled when performing multi-unit 

assessment sampling. Sampling criteria for community buildings, day care, or other 

spaces frequented by children require coordination with customer prior to beginning the 

project.

******************************************************************************

The lead inspector/risk assessor shall select single surface dust wipe and soil sample locations 

during the visual assessment. Paint chip samples, as required, should be selected in concert with 

the lead inspection phase of the project. Sample locations for each unit shall be identified on 

each unit floor plan or sketch, and shall be based on visual observations, separate component 

systems with distinct histories, pre-assessment unit information (including physical 

characteristics, use patterns, previous study results), and on the following:

• Lead-based paint surfaces that have been chewed or where chewing or mouthing has 

been reported shall be identified as LBP hazards and shall not require sampling. 

• Chewed surfaces may include interior windowsills, balusters, shelves, stairs, and other 

component systems accessible to children’s mouths. 

• Samples shall not be collected from worn portions of the painted surfaces that will be 

tested. 

• Friction or impact surface hazards shall be evaluated by dust wipe analysis, and 

accordingly shall not require paint chip sampling.

a. Dust Wipe Sample Locations

One dust sample shall be collected from interior windowsills and floors in all living areas

representing distinct component systems, where one or more children, less than 6 years of age 

are most likely to contact dust. Any lead-based paint on a friction surface with visibly 

deteriorated paint or that is subject to abrasion shall be sampled where the lead dust levels on the 

nearest horizontal surface beneath the friction surface can potentially exceed the dust-lead hazard 

action levels in Table A-1.
EP 1110-1-31

31 Aug 01 

A-19

• Multi-family dwellings

In addition to samples required above, interior windowsill and floor dust samples shall be 

sampled for lead concentration in:

• Common areas adjacent to the sampled residential dwelling or child-occupied facility

• Other common areas in the building where the risk assessor determines children six 

or under might contact dust according to the following:

 Common Areas – Multi-Unit Low Rise (up to and including four stories):

• one from the entry floor, and

• one from the floor of the first story landing of a common hallway, or stairway

• If a hallway window is frequently used, the risk assessor shall collect an interior 

windowsill sample as a substitute for the first story floor-landing sample.

Common Areas – Multi-Unit High Rise (greater than four stories):

• Two additional samples from the corridor of every fourth floor

• One sample from the floor areas

• One sample from the windowsill

• Two additional samples from stairways: one from the stair treads, one from the 

landing

For child-occupied facilities:

Interior window sill and floor dust samples shall be collected in each room, hallway or stairwell 

utilized by one or more children, age six or under, and in other common areas in the childoccupied facility where such children are likely to come in contact with dust according to the 

following:

Community buildings, day care, or other spaces frequented by children - Spaces up to 

2000 square feet:

• Floors: two samples from widely separated “high traffic” areas

• Windows: two samples - each sample from a window sill, up to two 

Community buildings, day care, or other spaces frequented by children - Spaces over 

2000 square feet:

• Floors: one additional sample for every 2000-square foot increment

• Windows: one additional sample from a windowsill for every 2000-square foot 

increment.

Community buildings, day care, or other spaces frequented by children - Management 

office:
EP 1110-1-31

31 Aug 01

A-20

• Resident-waiting area: one floor sample if under 400 square feet, two samples if over 

400 square feet.]

b. Paint Chip Sample Locations

******************************************************************************

NOTE: The lead inspector/risk assessor uses an XRF instrument to determine which 

painted components contain LBP. Therefore, paint chip samples need only be collected 

for those components with deteriorated paint where the XRF cannot operate properly. If 

the SOW editor wishes to rely on the results of the lead inspection (XRF data with paint 

chip data for surfaces not accessible with XRF instruments or with inconclusive XRF 

readings) and wishes to use the data for the risk assessment, choose option 1. If the SOW 

editor does not wish to rely on the results of the XRF for the risk assessment, (which is 

part of this work), the SOW editor should select option 2. (This will incur additional 

expense of laboratory paint chip sample analysis.)

******************************************************************************

[Option 1]

[The lead inspector/risk assessor shall immediately review the results of the lead inspection, and 

determine if any identified LBP surfaces contain deteriorated paint and note the extent of the 

damage.] 

[Option 2]

[One paint chip sample shall be collected from each interior [and exterior] deteriorated paint 

component system with a distinct painting history. Only one sample shall be taken for each 

such component system for which a common painting history can reasonably be assumed. The 

deteriorated areas of the represented paint system shall be given sampling priority for ease of 

removal. Samples shall be collected from inconspicuous locations whenever possible and safe. 

Sampling locations shall be sele cted based on presence of all intact layers of paint.] 

c. Soil Sample Locations

******************************************************************************

NOTE: In some parts of the country, particularly the South and coastal areas, family 

housing may have accessible crawl spaces used as play areas by small children. Samples 

should be collected from the bare soil in these crawl spaces.

******************************************************************************

The lead inspector/risk assessor sha ll collect at least two composite soil samples representing all 

bare soils accessible to children. Only bare soils shall be sampled. Bare soil areas to be 

considered include:
EP 1110-1-31

31 Aug 01 

A-21

• one composite from the foundation drip line and,

• one composite from exterior play areas including accessible crawl spaces

• [gardens]

2.2.2.3 Risk Assessment Sample and Sample Location Documentation

All XRF testing locations shall be marked on the floor plans/sketches and Form 1 (Figure B-1, 

Appendix B) at the time of actual testing during the inspection phase of the combined 

inspection/risk assessment. Paint chip sample locations shall be recorded on the floor plans or 

sketches and by filling in the identifying information on Form 4 (Figure B-5, Appendix B).

Single surface dust sample locations shall be recorded on the floor plans or sketches and by 

filling in the identifying information on Form 5 (Figure B-6, Appendix B).

Each composite soil sample location and identity shall be recorded on Form 6 (Figure B-7, 

Appendix B), and on the floor plans or sketches by sub-sample location. The plans or sketches 

shall include property boundaries.

The Contracting Officer reserves the right to audit the Risk Assessment Sample and Sample 

Location Documentation for any unit, at any time during the course of the project. The Risk 

Assessment Sample and Sample Location Documentation shall be included as an attachment to 

the Risk Assessment Sampling Plan following completion of the fieldwork and submitted as a 

part of the Lead Inspection/Risk Assessment Report.

2.2.3 Single Surface Dust Sampling 

Dust samples shall be collected for analysis by single surface wipe sampling. Dust wipe samples 

shall always be collected before paint chip samples to avoid cross-contamination. Gloves shall 

always be changed before each additional sample is collected. After donning gloves, do not 

touch anything other than the wipe and surface to be sampled. If the wipe is dropped, or contact 

is made outside the sampling area, discard the wipe and sample another undisturbed area. In 

each unit that will be sampled, discard the first wipe from the dispenser before initiating 

sampling. Fold the wipes completely before inserting into the collection tube.

The lead inspector/risk assessor shall collect wipe samples in accordance with ASTM’s Standard 

Practice for Field Collection of Settled Dust Samples Using Wipe Sampling Methods for Lead 

Determination by Atomic Spectrometry Techniques (E 1728), using wipe materials meeting the 

requirements of Standard Specification for Wipe Sampling Materials for Lead in Surface Dust 

(E 1792). (see AIHA web site (http://www.aiha.org) for a listing of wipe vendors meeting 

ASTM Method E 1792 criteria.)

2.2.4 Deteriorated Paint Chip Sampling
EP 1110-1-31

31 Aug 01

A-22

******************************************************************************

NOTE: If option 1 was selected in Paragraph 2.2.2.2b then select option 1 here. If 

option 2 was selected in Paragraph 2.2.2.2b, then select option 2 here. 

******************************************************************************

[Option 1] 

[The XRF data properly collected as part of the inspection phase of this assessment shall be used 

to evaluate all deteriorated paint surfaces for the presence of lead. Deteriorated painted surfaces 

that were not suitable for testing by XRF due to shape, or accessibility etc., or where 

inconclusive XRF readings were generated during the inspection phase, shall be tested 

destructively by paint chip sample collection. The paint chip samples shall be collected and 

submitted in accordance with the laboratory’s SOP for collecting paint chip samples to determine 

lead loading per cc of surface area, and ASTM’s Standard Practice for Field Collection of 

Dried Paint Samples for Lead Determination by Atomic Spectrometry Techniques (E 1729).]

[Option 2]

[The lead inspector/risk assessor shall collect and preserve paint chip samples on all deteriorated 

painted surfaces in accordance with ASTM’s Standard Practice for Field Collection of Dried 

Paint Samples for Lead Determination by Atomic Spectrometry Techniques (E 1729).]

2.2.5 Soil Sampling 

Each composite sample shall include not less than two (2) and not more than ten (10) subsamples collected from distinct locations roughly equidistant from each other along an axis. 

Sub-samples along drip lines shall generally be collected two to six feet from each other. In 

other sampling locations such as play areas sub-samples shall be collected from roughly 

equidistant locations along each leg of an X-shaped pattern. Sample collection shall be 

conducted in accordance with the most current edition of Standard Practice for Field Collection 

of Soil Samples for Lead Determination by Atomic Spectrometry Techniques, ASTM Standard 

E 1727.

2.2.6 Sample Identification 

Dust, paint, and soil samples shall be identified using unique sample numbers. Field and 

laboratory blanks and spiked samples submitted to the laboratory for QA/QC purposes shall be 

numbered in such a way that the sample identity will not be revealed to personnel conducting the 

analysis.

2.2.7 Sample Chain-of-Custody

The Contractor shall follow a standard chain-of-custody protocol to ensure and document a 

continuous record of sample possession from sample collection to receipt by the laboratory. The 

Contractor shall complete and maintain chain-of-custody forms for each set of samples shipped 
EP 1110-1-31

31 Aug 01 

A-23

to the laboratory, and a copy of the forms shall accompany each shipment of samples. An 

example chain-of-custody Form7 is included as Figure B-8 in Appendix B.

The Contractor shall include copies of all chain-of-custody forms completed during the 

assessment in the Lead Inspection/Risk Assessment Report.

2.2.8 Decontamination

Field sampling equipment shall be decontaminated following the appropriate ASTM standard. 

At a minimum, the field decontamination procedures for non-disposable sampling equipment 

(e.g., knives, coring devices, scrapers) shall consist of either wiping the equipment off twice 

using a clean wet wipe each time, or washing in a solution of non-phosphate detergent (e.g., 

Liquinox®), and rinsing with distilled water. The equipment shall be decontaminated prior to 

each use, between each sample, and prior to leaving the site. Disposable latex gloves shall be 

discarded after each sample. Gloves need not be changed between each sub-sample when 

collecting composite soil samples. The Contractor shall coordinate with the installation 

environmental officer to determine requirements for the disposal of decontamination waste and 

used personal protective equipment.

2.3 TASK 3 SAMPLE DATA ANALYSIS, EVALUATION OF FINDINGS

2.3.1 XRF Data Interpretation

XRF results shall be interpreted by the Contractor in accordance with ASTM Standards, the XRF 

manufacturer’s PCS, and as otherwise required in this SOW. 

2.3.2 Sample Preparation and Analysis 

Samples collected by the lead inspector/risk assessor during the assessment(s) shall be sent to an 

[independent] laboratory recognized by the EPA under the NLLAP for analysis. The laboratory 

must be accredited for each type of analysis required. The Contractor shall verify the following 

with the laboratory:

2.3.2.1 Dust Sample Preparation and Analysis

Dust samples shall be prepared for analysis following the ASTM Practice for Hot Plate 

Digestion of Dust Wipe Samples for the Determination of Lead by Atomic Spectrometry (E 1644) 

or Standard Provisional Practice for Ultrasonic Extraction of Paint, Dust, Soil, and Air Samples 

for Subsequent Determination of Lead (E 1979) and analyzed following the Standard Test 

Method for Analysis of Digested Samples for Lead by Inductively Coupled Plasma Atomic 

Emission Spectrometry (ICP-AES), Flame Atomic Absorption (FAAS), or Graphite Furnace 

Atomic Absorption (GFAAS) Techniques (E 1613). The most current version of the methodology 

shall be used. The laboratory shall report results in units of microgram per square foot (μg/ft2), 

allowing direct comparison with Table A-1, EPA, and HUD criteria.
EP 1110-1-31

31 Aug 01

A-24

2.3.2.2 Paint Chip Sample Preparation and Analysis

Paint chip samples shall be prepared for analysis following the ASTM Standard Practice for the 

Preparation of Dried Paint Samples for Subsequent Lead Analysis by Atomic Spectrometry

(E 1645) or Standard Provisional Practice for Ultrasonic Extraction of Paint, Dust, Soil, and Air 

Samples for Subsequent Determination of Lead (E 1979), and analyzed following the Standard 

Test Method for Analysis of Digested Samples for Lead by Inductively Coupled Plasma Atomic 

Emission Spectrometry (ICP-AES), Flame Atomic Absorption (FAAS), or Graphite Furnace 

Atomic Absorption (GFAAS) Techniques (E 1613). The most current version of the methodology 

shall be used. Results shall be reported in units of micrograms per gram (μg/g) and parts per 

million (ppm), allowing direct comparison with Table A-1, EPA, and HUD criteria.

2.3.2.3 Soil Sample Preparation and Analysis

Soil samples shall be prepared for analysis following the ASTM Standard Practice for Sample 

Digestion of Soils for the Determination of Lead by Atomic Spectrometry (E 1726) or Standard 

Provisional Practice for Ultrasonic Extraction of Paint, Dust, Soil, and Air Samples for 

Subsequent Determination of Lead (E 1979) and analyzed following the Standard Test Method 

for Analysis of Digested Samples for Lead by Inductively Coupled Plasma Atomic Emission 

Spectrometry (ICP-AES), Flame Atomic Absorption (FAAS), or Graphite Furnace Atomic 

Absorption (GFAAS) Techniques (E 1613). The most current version of the methodology shall 

be used. Results shall be reported in units of μg/g and ppm, allowing direct comparison with the 

EPA criteria.

2.3.2.4 Laboratory Turnaround Time

The Contractor shall require the laboratory to report analytical results to the Contractor within 

[Insert appropriate number of days] days of the laboratory’s receipt of the samples in the 

laboratory.

2.3.3 Quality Assurance and Quality Control (QA/QC)

2.3.3.1 XRF Performance Validation and Verification

The lead inspector/risk assessor shall use only XRF spectrum analyzers with current, published 

Performance Characteristic (PCS) sheets that provide valid measurements at the Action Levels 

specified in Table A-1. A copy of the PCS for the XRF instruments used on this project shall be 

submitted in the Lead Inspection Sampling Plan section of the Lead Inspection/Risk Assessment 

Report.

The lead inspector/risk assessor shall perform calibration checks at the beginning and 

end of the inspection work or every four hours, whichever comes first or as otherwise specified 

in Chapter 7 of the HUD Guidelines: “Guidelines for the Evaluation and Control of Lead-Based 
EP 1110-1-31

31 Aug 01 

A-25

Paint Hazards in Housing, June 1995. (Chapter 7 revised 1997)”. If the PCS of the XRF 

spectrum analyzer manufacturer requires additional or more stringent warm up, quality control, 

or calibration check instructions than those described in the HUD Guidelines, they shall be 

followed. Calibration shall also be performed before and after turning the instrument on or off 

throughout the inspection work (e.g., lunch breaks, changing batteries). If the failed calibration 

results occur at the end of a testing period, the results obtained during that testing period shall be 

discarded and the unit re-tested. The lead inspector/risk assessor shall record all calibration 

check results and submit this record in the Contractor Data Certification section of the Lead 

Inspection/Risk Assessment Report.

Validation shall be accomplished with the lead inspector/risk assessor randomly selecting 10 

testing combinations for retesting in the surveyed units for every 10 units tested. The retesting 

shall be with the same XRF spectrum analyzer. The average of the 10 XRF retest results shall 

not vary from the 10 original XRF results by more than the retest tolerance limit that is 

calculated as specified on the XRF PCS sheet. If the limit is exceeded, the procedure shall be 

repeated using 10 different testing combinations. If the retest tolerance is exceeded again, the 

original inspection is considered invalid. This process must be documented in the Contractor 

Data Certification section of the Lead Inspection/Risk Assessment Report.

2.3.3.2 Field Blank Dust Wipe QA Samples

Field blanks for single wipe sampling shall be collected in accordance with ASTM’s Standard 

Practice for Field Collection of Settled Dust Samples Using Wipe Sampling Methods for Lead 

Determination by Atomic Spectrometry Techniques (E 1728), using wipe materials meeting the 

requirements of Standard Specification for Wipe Sampling Materials for Lead in Surface Dust 

(E 1792) using the same wipe material used to collect the field wipe samples. There shall be no 

indication to the laboratory, by sample identification numbers or other means, that the field blank 

samples are QA samples.

2.3.3.3 Field Spike Dust Wipe QA Samples

****************************************************************************** 

NOTE: The AIHA produces the most reliable spiked lead samples that are commercially 

available and are specified over all other sources if commercial spikes are purchased, since the 

AIHA prepared spiked samples are used in the Environmental Lead Proficiency Analytical 

Testing (ELPAT) certification program. The AIHA stock samples are obtained through the 

AIHA.

AIHA

2700 Prosperity Road

Fairfax, Virginia 22031

(703) 849-8888 (voice)

(703) 207-3561 (fax)

http://www.aiha.org/fees.html/
EP 1110-1-31

31 Aug 01

A-26

The text below gives the Contractor two options to generate spiked wipe samples:

In Option a, the Contractor must obtain the same wipe material used by the commercial source in 

preparing the spikes, to collect field samples.

Option b allows the Contractor to use a second independent laboratory to prepare spikes sent to 

the laboratory doing the analysis of the field data. NIST traceable materials must be used 

by the laboratory in preparing the spike samples.

******************************************************************************

The Contractor shall submit double-blind (spiked) QA dust wipe samples to the laboratory at a 

frequency of one double-blind sample per 50 field samples collected (with a minimum of at least 

one) using one of the two following options:

a. The Contractor shall obtain commercially prepared spiked wipe samples that are 

prepared by meeting the same QA/QC requirements required in preparing spiked wipe samples 

used by the AIHA in its management of the Environmental Lead Proficiency Analytical Testing 

(ELPAT) laboratory certification program, for submittal to the laboratory. [One source of spike 

samples meeting the QA/QC requirements is listed on the AIHA web site: http:\\www.aiha.org]. 

The Contractor shall obtain from the commercial source, wipes of the same brand and type as 

those used to prepare the spiked samples. The Contractor shall use these wipes to collect field 

samples and to prepare field blank samples.

b. The Contractor shall hire a laboratory to prepare spiked wipe samples using 

National Institute of Standards and Testing (NIST) traceable materials. Spiked samples shall be 

prepared using leaded dust, not lead in solution. The lead concentration in the spiked wipe 

samples shall approximate the amount of lead in the lead action level criteria for hard floors in 

Table A-1 of this SOW. The Contractor shall provide uncontaminated wipes of the same brand 

and lot as the wipes that will be used to collect field samples, to the laboratory preparing the 

spiked samples. The laboratory shall use these wipes to prepare the spiked wipe samples. The 

laboratory preparing the spiked samples shall be independent of the laboratory that will be used 

to analyze the field samples and field QA samples.

There shall be no indication to the laboratory analyzing the field samples, by sample 

identification numbers or other means, that the spiked samples are QA samples. 

2.3.3.4 Field Duplicate/Spike Paint Chip QA Samples

******************************************************************************

NOTE: The use of commercially prepared paint chip samples as spike samples allows 

the contractor to submit spiked paint chip samples of predetermined, known lead 

concentrations to the laboratory for QA purposes. This option can be used in conjunction 

with the requirement to prepare field duplicate spike samples.
EP 1110-1-31

31 Aug 01 

A-27

******************************************************************************

The Contractor shall submit double-blind QA paint chip samples to the laboratory for analysis. 

At a minimum, these shall include field duplicate samples, prepared by using standard mortar 

and pestle homogenizing techniques, collected at a rate of 2-5% of total samples collected. [The 

Contractor shall submit standard refe rence samples (commercially-prepared paint chip samples 

with a known concentration of lead) at a rate of 2-5% of the total samples collected, to the 

laboratory for analysis. The lead concentration in the samples used shall be within 75% to 125% 

of the lead hazard action levels in Table A-1 if available.] There shall be no indication to the 

laboratory, by sample identification numbers or other means, that the samples are QA samples. 

The Contractor shall evaluate the results of the analyses of QA samples as outlined in the DQOs 

developed under this SOW.

2.3.3.5 Field Rinsate Blank QA Samples (Soil)

One rinsate blank (see Glossary) for coring or spoon sampling techniques (refer to ASTM 

Method E1727) shall be included with each batch of soil samples sent to the laboratory.

2.3.3.6 Matrix Spike/Matrix Spike Duplicate (MS/MSD) Soil QC Samples

The Contractor shall collect a sufficient quantity of soil to ensure that the laboratory can prepare 

the MS/MSD samples. (One set of MS/MSD samples shall be prepared for each batch of soil 

samples submitted to the laboratory for analysis in accordance with ASTM’s Standard Practice 

for Sample Digestion of Soils for the Determination of Lead by Atomic Spectrometry (E 1726).)

2.3.4 Project Data Review and Assessment

******************************************************************************

NOTE: The analytical data acceptance criteria for lead hazard identification and control 

samples provided in Table B-3 (Appendix B) have been adapted from the Laboratory 

Quality System Requirements (LQSR) Revision 2.0 (August 1996), Table 1, Section 10-

Quality Assurance and Quality Control. Table B-3 must be verified (and updated as 

needed) as a part of the SOW editing process by contacting the EPA NLLAP Program 

Manager (call the EPA Hot Line 1-800-424-LEAD). Any time laboratory data are 

reviewed for acceptability; the current revision of the LQSR must be consulted to make 

required changes to Table B-3.

******************************************************************************

The Contractor shall review all project data collected as part of the current assessment and verify 

that the data is acceptable to meet the DQOs. Data review includes (1) Field sample collection 

and control review, and (2) analytical laboratory data review. Field sample collection and 

control review includes evaluating the adequacy of the Lead Inspection Sampling Plan and Risk 

Assessment Sampling Plan throughout the performance of the assessment.
EP 1110-1-31

31 Aug 01

A-28

2.3.4.1 Field Dust Wipe Quality Assurance Verification

Prior to beginning field dust sampling, the Contractor shall provide the laboratory with at least 

one uncontaminated wipe per each container of bulk packed wipes that will be used for 

collecting field dust wipes, to verify that the wipe material meets the requirements of Standard 

Specification for Wipe Sampling Materials for Lead in Surface Dust (E 1792). Wipes containing 

more than 5.0 μg/wipe of background lead shall render the entire container of bulk packed wipes 

represented by the analyzed wipe, contaminated and disqualify the represented wipes for field 

use. (See AIHA web site for a listing of wipe vendors meeting ASTM Method E 1792 criteria.)

2.3.4.2 Laboratory QA and QC Verification.

******************************************************************************

NOTE: The Contractor must choose the most advantageous technique to provide extra 

samples to the laboratory, should additional samples be required by the laboratory to 

replace sampling or QA/QC data lost due to laboratory mistakes. The Government is not 

liable for cost of additional sample collection due to laboratory mistakes, Contractor 

sample collection problems, or chain-of-custody errors.

******************************************************************************

a. Evaluation of Laboratory Data

The Contractor shall obtain and review NLLAP-required QC data generated for each sample run 

completed under this SOW. The QC data shall include batch QC validation data and the 95% 

confidence interval data (determined by the laboratory from QC charts or a QC database for each 

matrix, i.e., single surface dust wipe samples, deteriorated paint chip samples, soil samples) 

determined at concentrations equivalent to 40 μg/ft2 for dust wipe samples, 0.5% by weight 

(5000 μg/g (ppm)) for paint chip samples, and [insert applicable criteria from Table A-1] μg/g 

(ppm)) for bulk soil samples. The Contractor shall evaluate the data package to determine that 

the QA/QC data generated for each sample run falls within current NLLAP Laboratory Quality 

System Requirements (LQSR) parameters listed in Table B-3 (Appendix B). Spiked samples 

submitted to the laboratory in accordance with this SOW shall fall within 75% - 125% of the true 

value.

b. Rejection of Laboratory Data

The Contractor shall not accept or use data from the laboratory that does not fall within current 

NLLAP LQSR parameters specified in Table B-3. If the laboratory fails to obtain spiked results 

within the specified error limits:

• Two more spikes of the same matrix shall be sent immediately to the laboratory for 
EP 1110-1-31

31 Aug 01 

A-29

analysis.

• If the two additional spike samples fail, the sample batch shall be considered invalid 

for the matrix represented.

If laboratory data are rejected and insufficient quantities of the samples remain to allow reanalysis of the samples while adhering to QA/QC requirements, the Contractor shall collect and 

submit additional samples, at no cost to the Government, for laboratory analysis using NLLAP 

QA/QC protocols. The Contractor shall also be responsible for any re-sampling required due to 

laboratory errors that result in the destruction or loss of data, or a failure to report results on any 

samples submitted.

2.3.4.3 Contractor Certification of Project Data Validity

The Contractor shall certify that all field data collected to determine the presence of a lead 

hazard were valid and meet the DQOs.

2.3.4.4 Comparison with Table A-1 Lead Hazard Action Levels 

The Contractor shall compare the collected data with the lead hazard criteria listed in Table A-1 

to determine whether lead-based paint and/or lead hazards are present. This comparison shall be 

documented in the Lead Inspection/Risk Assessment Report.

For all lead hazard evaluations, the data shall be examined to determine if consistent patterns 

emerge (e.g., the window troughs contain high levels, while floors and interior sills are low); 

such patterns will be used in the development of recommendations for focused cost-effective 

control measures.

2.3.4.5 Laboratory Report

The Contractor shall require that the laboratory report information necessary for the Contractor 

to comply with the data evaluation/validation requirements outlined in this SOW. The 

Laboratory Report shall include the following information addressing all field samples submitted 

to it by the Contractor excluding sample data collected by the Contractor using XRF 

instrumentation:

• cover page information including Laboratory name and address, methods, dates, 

instruments, digestions, and signature of the laboratory director

• sample information including identification and results for blanks, QC samples, 

samples, dilution factors, and batch identification

• results of initial precision and accuracy runs

• results of calibration, including sources of standards and detection limits

• results of blanks, including type of blank, and any corrections used

• results of calibration verification checks
EP 1110-1-31

31 Aug 01

A-30

• results of tests for precision and accuracy

• results of standard sample analysis to 95% confidence intervals which contain 

concentrations of lead that correspond to a given action level

2.4 TASK 4 LEAD INSPECTION/ RISK ASSESSMENT REPORT

******************************************************************************

NOTE: 40 CFR 745.227(h) requires that Lead Inspection and Risk Assessment reports 

be retained for a minimum of three years. State, local, or installation regulations may 

require a longer retention period. 

******************************************************************************

The Contractor shall prepare a Lead Inspection/Risk Assessment Report containing the elements 

described below.

2.4.1 General Report Contents

In addition to the information described in Paragraphs 2.4.2 through 2.4.10 below, the 

assessment report shall include:

• Date of [each] lead inspection/risk assessment

• Address of [each] building

• Unit number

• Date of construction of [each] building

• Name, signature, and certification number of each lead inspector/risk assessor 

conducting the lead inspection/risk assessment

• Name, address, and telephone number of the Contractor’s firm employing the 

certified lead inspector(s)/risk assessor(s)

• Lead Inspection Sampling Plan with discussion of room equivalents, testing 

combinations, and XRF PC sheet. Also list the XRF instrument manufacturer, model, 

serial number, mode(s) of operation and age of radioactive source

• An XRF data summary table listing results for all painted components tested (all 

field-completed XRF Readings/Results Forms (Form 1) can be submitted in place of 

this XRF data summary table with prior concurrence and approval of the Contracting 

Officer. This table shall report by unit the following: positive results, negative results 

and inconclusive results. This table shall list the actual result by substrate. For any 

inclusive results, the contractor shall list the corresponding paint chip sample results. 

• Risk Assessment Sampling Plan to include Risk Assessment Sample and Sample 

Location Documentation

• Laboratory Report

• Pre-existing data used in decision process (other than that provided as part of this 

SOW or addressed in Paragraph 2.4.2 below)
EP 1110-1-31

31 Aug 01 

A-31

2.4.2 Summary of Pre-Existing Data Lead Hazard Management Plan and Interviews

[The Contractor shall attach a copy of the Summary of Pre-existing Data, Lead Hazard 

Management Plan, and Interviews]

2.4.3 Other Field and Laboratory Data

The report shall include correspondence, conference notes, field notes and forms and other 

documentation including copies of field calculations, building and paint evaluation forms, 

sample collection forms, chain-of-custody forms, and other records of field data that are not 

already addressed in the requirements for this report.

2.4.4 Contractor Data Certification

The Contractor shall certify that the data used to develop conclusions and recommendations were 

reviewed, are valid, and meet the DQOs (i.e., that the data were of sufficient quantity and quality 

to identify and characterize lead hazards at the units).

2.4.5 Project Data Presentation/Electronic/HALO Data Downloading

******************************************************************************

NOTE: All data collected during activities described in this SOW is to be provided to the 

Army in a format compatible with the Army’s Hazardous Asbestos and Lead Optimal 

Management System (HALO) or, if the installation does not utilize HALO, compatible 

with Army installation data management system requirements. HALO is a hazard 

management system designed to track lead and asbestos hazards and actions taken in 

response to the identified hazards. HALO requires an IBM-compatible personal 

computer (with a Pentium processor), Windows 95, 16 MB of RAM, 10MB of 

available hard disk space, Word 97, and display resolution of 800x600 pixels. The 

current point-of-contact for HALO is:

USACE Engineering Research and Development Center (CEERDC)

CEERD-CF-M

(217) 352-6511, extension 7239 (commercial)

Where an Army installation has no unique data management system for LBP data, HALO 

will be the default program for all deliverables under this SOW. The SOW must detail 

the procedure for the Contractor to follow in providing the results of the lead 

inspection/risk assessment to the COTR for downloading into HALO or other system 

agreed upon to be used in the transfer process by the installation.

At a minimum, the Contractor must be provided with a copy of the HALO Data 

Dictionary. The dictionary identifies the table names, field names, data types, and any 
EP 1110-1-31

31 Aug 01

A-32

required default values. The dictionary is part of the HALO program and can be obtained 

through the installation, or by contacting CEERD CF-M. If the transferee is known, 

consult them for reporting requirements. In every case, electronic archives should be 

produced for the record.

******************************************************************************

The Contractor shall provide laboratory data to the Contracting Officer in both hard copy and 

electronic format. The electronic data report shall be provided in [HALO format] [insert other 

data management system as applicable] with the capability of being downloaded into the 

[Installation’s] electronic data management system.

2.4.6 Update Installation Management Plan 

******************************************************************************

NOTE: Since this is for property transfer, select the most efficient method of reporting 

that meets the transfer requirements and preserves the record. If the installation does not 

have a Lead Hazard Management Program, it would probably be best to specify the 

HALO Program as the reporting system. If the Installation has a Lead Hazard 

Management Plan, it is probably best to update it to the requirements of this SOW. 

Consult with the transferee (if known) to determine the scope of this task (e.g., whether to 

limit the task to entry of new data into the appropriate electronic format, to include an 

update of a hard copy document, or to deliver an addendum to the existing installation 

plan).

******************************************************************************

[After entering the assessment data into HALO, the Contractor shall run the installation 

management program to generate an updated installation lead hazard management program.]

[The Contractor shall update the installation lead hazard management plan.]

2.4.7 Comparison of Contractor Findings to Installation HALO Findings

[The Contractor shall include a comparison of the lead inspector/risk assessor findings and 

recommendations with those generated by HALO.]

2.4.8 Contractor Conclusions and Recommendations 

The report shall separate housing constructed prior to 1960 from housing constructed from 1960 

through the end of 1977. For housing constructed during these time periods the contractor shall 

use Table B-2 (Appendix B) in developing conclusions and control recommendations. The 

report shall contain the Contractor’s conclusions and lead hazard control recommendations. 

[Where the lead inspector/risk assessor’s findings and recommendations differ from those 
EP 1110-1-31

31 Aug 01 

A-33

generated by HALO, the report shall provide the rationale for the lead inspector/risk assessor’s 

findings and recommendations.]

2.4.9 Lead Hazard Identification Summary

The Contractor shall prepare a lead hazard identification summary form for each housing unit 

assessed. The summary form shall contain the location, the surface type, and the basis of 

determination of each identified lead-based paint hazard and any other potential lead hazards. 

[The Contractor shall include a photograph of each deteriorated paint sample location.] An 

example Form 8 is included (see Figure B-9, Appendix B). The summary forms to be submitted 

by the Contractor as a part of the Lead Inspection/Risk Assessment Report shall include as a 

minimum the information contained on Form 8.

2.4.10 Regulatory Statements of Compliance

******************************************************************************

NOTE: This requirement addresses recommendations where no ha zards are identified.

******************************************************************************

If lead hazards are not identified, the Contractor shall provide recommended monitoring 

protocols to minimize future lead hazard development, based on observations made during the 

inspection/assessment, and accepted practices.

3.0 SUPPLEMENTAL REQUIREMENTS FOR CONTRACTED SERVICES

******************************************************************************

NOTE: The supplemental requirements are part of the solicitation for services and not 

part of each delivery or task.

******************************************************************************

3.1 CONTRACTOR FIRM/PERSONNEL QUALIFICATIONS

3.1.1 Contractor Firm Experience

The contracted firm shall have a minimum of [insert appropriate number of years] years 

experience in conducting lead inspections and risk assessments and have adequate qualified staff 

. Three references, at a minimum, shall be required for completed projects equal in complexity 

to the one described in this SOW.

3.1.2 Contractor Lead Inspector/Risk Assessor/Project Manager Qualifications

******************************************************************************
EP 1110-1-31

31 Aug 01

A-34

NOTE: Some states or local jurisdictions may use different terminology for individuals 

certified to complete the services described in this SOW, i.e., the certificate may include 

a title other than “lead inspector” or “risk assessor.”

******************************************************************************

The Contractor shall employ a certified lead inspector/risk assessor to complete the inspections 

and risk assessments described in this SOW.

3.1.2.1 EPA Certification

EPA certification (or certification under an EPA-approved state program) is required pursuant to 

40 CFR 745.226. (64 FR 42849, 6 August 1999).

3.1.2.2 State and Local Certification

Each lead inspector/risk assessor shall possess current certification or licensing required under 

state or local jurisdictions, if applicable, in addition to or in place of EPA certification, 

depending or the requirements of the jurisdictions.

3.1.2.3 Radioactive Materials License

The contractor must have a current Radioactive Materials License if required by the State where 

the work will be performed.

3.1.2.4 Evidence of Certification

A copy of each current applicable certificate shall be included in the Project Work Plan for each 

Contractor lead inspector/risk assessor participating in this project.

3.1.2.5 Record of Experience

A resume or other description of the certified lead inspector/lead risk assessor’s experience, 

which is directly applicable to the activities required under this SOW shall be included in the 

Project Work Plan.

3.1.2.6 Use of Lead Inspector/Risk Assessment Teams

******************************************************************************

NOTE: Indicates the number and size of assessment teams.

******************************************************************************

The Contractor shall specify in the Project Work Plan the number of lead inspection/risk 
EP 1110-1-31

31 Aug 01 

A-35

assessment teams are to be used to perform the lead inspection risk assessment addressed in this 

SOW. No more than [insert appropriate number] lead inspectors/risk assessors per team shall be 

assigned to conduct the lead inspection/risk assessments. Team leaders shall have a minimum of 

three years experience in conducting lead hazard risk assessments.
EP 1110-1-31

31 Aug 01

A-36

3.1.2.7 Project Manager Experience

The project manager shall have a minimum of three years experience in managing lead 

inspections and risk assessments. A resume or other description of the project manager’s 

experience that is directly applicable to the activities required under this SOW shall be provided 

as a part of the Project Work Plan.

3.1.3 Contracted Laboratory Qualifications

The Contractor shall provide as a part of the Project Work Plan evidence of current NLLAP 

recognition for each laboratory used for either preparation or analysis of samples taken for this 

assessment. The evidence of NLLAP recognition shall include certifications for each sample 

matrix analyzed. The laboratory conducting any worker exposure air sample analysis shall be 

accredited by the AIHA and shall be a current successful passing participant in the AIHA’s 

Proficiency Analytical Testing (PAT) Program for analyte sampled.

3.1.4 Contractor Errors and Omissions Liability Insurance

******************************************************************************

NOTE: Consult with the Contracting Officer to develop requirements for Contractor 

errors and omissions liability insurance that are appropriate for the scope of the project.

******************************************************************************

The Contractor shall provide documentation to the Contracting Officer that the Contractor is 

currently covered by an errors and omissions liability insurance policy. [Insert errors and 

omissions text as appropriate]

3.2 PROJECT RECORDS

3.2.1 Record keeping Requirements

******************************************************************************

NOTE: EPA regulations (40 CFR 745.227(h)) require that lead-hazard risk assessment 

reports be retained for a minimum of three years. State, local, or installation regulations 

may require a longer retention period. Include the applicable retention period in the 

SOW requirements below.

******************************************************************************

The Contractor shall maintain records related to the lead inspection/risk assessment for at least 

[insert appropriate number of years] years following completion of the assessment(s) outlined 

under this SOW. Records shall include:
EP 1110-1-31

31 Aug 01 

A-37

3.2.1.1 Project Work Plan

3.2.1.2 Lead Inspection/Risk Assessment Report

3.3 PROJECT COORDINATION

The Contractor shall coordinate activities through the Contracting Officer . Contact with 

installation personnel, including the installation POC, members of the installation lead hazard 

management team, building occupants or POCs, and other installation personnel shall be 

coordinated through the Contracting Officer.

3.4 GOVERNMENT SUPPORT

******************************************************************************

NOTE: Little standard language is offered in this paragraph, since the requirements will 

be very project-specific. The specific language will need to be defined with the 

customer. Include in the following paragraphs provisions for utilities, water, phone lines, 

computers, transportation while on the installation, etc. delineating who is responsible.

******************************************************************************

3.4.1 Government Quality Control Oversight

[Insert Appropriate Provisions]

The Contracting Officer reserves the right to audit the lead inspection and risk assessment 

sample and sample location documentation for any unit, at any time during the course of the 

project. 

3.4.2 Security and Escorts

******************************************************************************

NOTE: It is advisable for Contractor personnel to be accompanied by an escort from the 

Housing Office while in family housing units. The escort should introduce the team on 

behalf of the Housing Office, state how long the work is expected to take, answer 

questions, and observe the team while it works. This is good public relations and protects 

the installation, the Contractor, and the occupants from disputes about claims of loss and 

damage. It reassures occupant family members, especially those who have forgotten 

about or have not heard about the lead inspections/risk assessments. If occupants 

(especially spouses) are likely not to understand the explanation in English, a bilingual 

escort should be provided. The escort may use the time on behalf of the Housing Office 

to discuss occupants’ concerns and to observe actual and potential hazards and 

maintenance problems of all types. 
EP 1110-1-31

31 Aug 01

A-38

If an escort cannot be provided, special precautions must be taken to protect all parties:

• The notice to occupants about the impending work should include information to 

the occupant on how Contractor personnel should identify themselves at the door.

• Contractor personnel should be directed to never enter a unit unless there is an 

adult present or, at minimum, an older and responsible adolescent (18 years or 

older) who clearly understands the intended work and agrees to the team entering. 

Personnel should be directed not to ask children who answer the door whether a 

parent is home, but rather whether a parent is free to come to the door. This is to 

avoid encouraging children to tell strangers that no adult is home.

• Agreement should be reached on what Contractor personnel can tell occupants 

about the work or in response to questions, as opposed to referring occupants to 

the Housing Office.

It is not practical for a single person to introduce multiple teams of risk assessor(s) to 

each occupant because it is not possible to predict in advance how long each risk 

assessment will take.

The contractor is responsible for the security of their equipment (especially XRF units), 

their employees, and to relock doors upon exit.

If special security arrangements must be made for the work, this should be noted below. 

This might include both personnel and vehicle passes, as well as any information or 

passes to enter secure locations.

******************************************************************************

[Insert Appropriate Provisions]

3.4.3 Temporary Office/Equipment Storage/Staging Areas

The installation shall provide space for the duration of the field activities that the Contractor may 

use as a temporary office, equipment storage, and staging area. [The Government] [The 

Contractor] shall provide [insert appropriate text for utilities, phone lines, permits, etc.].

3.5 TRAVEL AND MEETINGS

All meetings shall be attended by the Contractor project or task manager and the certified lead 

inspector/risk assessor if these are different individuals.
EP 1110-1-31

31 Aug 01 

A-39

3.5.1 Preliminary Project Site Visit/Walkover

******************************************************************************

NOTE: Where the Contractor’s project manager is not the same individual as the lead 

inspector/risk assessor, the lead inspector/risk assessor and the project manager must be 

required to participate in the site visit. If the Contractor is to use a number of lead 

inspection/risk assessment teams, the lead inspector/risk assessor who is to act as the field 

team leader for each team must participate in the site visit. Other team members and 

support staff need not participate.

******************************************************************************

The [Contractor’s project manager] lead inspector/risk assessor(s) shall visit a representative 

sample of the units that will be assessed with the Contracting Officer and installation POC.

3.5.2 Project Work Plan Review and Start-up Meeting

The Contractor shall attend a start-up meeting to review finalize and approve the Project Work 

Plan to include the Lead Inspection Sampling Plan and Risk Assessment Sampling Plan 

immediately prior to beginning field activities. The Contractor shall generate meeting minutes 

that will be submitted to the Contracting Officer within [two weeks] of the meeting.

3.5.3 Data Certification Meeting

******************************************************************************

NOTE: Data certification may also be discussed at the Final Risk Assessment Report 

Meeting, Progress Report Meeting, or other meeting to help limit the number of required 

meetings.

******************************************************************************

[The Contractor shall attend a meeting to review the Contractor’s lead inspection and risk 

assessment data certification outcomes]

3.5.4 Final Lead Inspection/Risk Assessment Report Meeting

The Contractor shall attend a meeting to review the final Lead Inspection/Risk Assessment 

Report prior to final submittal.

3.5.5 Additional Meetings

[Insert additional meetings if required]
EP 1110-1-31

31 Aug 01

A-40

3.6 SCHEDULES

*****************************************************************************

NOTE: Consult with the customer in determining schedule requirements. Combine 

meeting topics where appropriate. At a minimum, the schedule milestones are:

1) Site visit/project walkover

2) Project Work Plan submission 

3) Start-up meeting if not combined with item 2

4) Data certification meeting if not combined with item 5

5) Final Lead Inspection/Risk Assessment Report meeting

******************************************************************************

[Insert appropriate schedule milestones]

3.7 SUBMITTALS

3.7.1 Project Work Plan

The Contractor shall submit a Project Work Plan to the Contracting Officer for government 

acceptance.

3.7.2 Progress Report(s)

[The Contractor shall provide [weekly, biweekly, monthly, etc.] project progress reports to the 

Contracting Officer. The reports shall be due to the Contracting Officer [Insert date(s) as 

appropriate]. The reports shall address [progress, schedule, etc. as appropriate].]

3.7.3 Final Lead Inspection/Risk Assessment Data Submission in Electronic Format

The Contractor shall provide the lead inspection/risk assessment data in electronic [HALO] 

[specify other] format.

3.7.4 Final Lead Inspection/Risk Assessment Report 

The Contractor shall provide [insert appropriate numbers] hard copies in [three ring binders] 

[specify other] of the final report as described in Paragraph 2.4. A CD of this report shall be 

included in each binder.
EP 1110-1-31

31 Aug 01 

A-41

3.7.5 Backup Data (optional)

******************************************************************************

NOTE: Request submission of any backup data if required.

******************************************************************************

[Insert backup data requirements]

3.8 MISCELLANEOUS 

3.8.1 Glossary

This paragraph contains acronyms, and terms commonly used in this SOW. For a more 

complete listing of terms commonly used in reference to lead-based paint projects consult 

appropriate regulations or ASTM standards.

Certified lead 

inspector/risk assessor

An individual who has been trained by an accredited 

training program, as defined by 40 CFR 745.223, and 

certified by EPA pursuant to §745.226 to conduct lead 

inspections and risk assessments. The individual samples 

for the presence of lead in dust and soil and conducts risk 

assessments to identify lead hazards to children under six 

years old, associated with the presence lead in dust, paint 

and soil.

Child-occupied facility A building, or portion of a building, constructed prior to 

1978, visited regularly by the same child, 6 years of age or 

under, on at least two different days within any week 

(Sunday through Saturday period), provided that each day's 

visit lasts at least 3 hours and the combined weekly visit 

lasts at least 6 hours, and the combined annual visits last at 

least 60 hours. Child-occupied facilities may include, but 

are not limited to, day-care centers, preschools and 

kindergarten classrooms. (40 CFR 745.223)

Common area A portion of a building that is generally accessible to all 

occupants. Such an area may include, but is not limited to, 

hallways, stairways, laundry and recreational rooms, 

playgrounds, community centers, garages, and boundary 

fences. (40 CFR 745.223)
EP 1110-1-31

31 Aug 01

A-42

Component, component 

system, building 

component

Specific design or structural elements or fixtures of a 

building, or child-occupied facility that are distinguished 

from each other by form, function, and location. (40 CFR 

745.223)

Contracting Officer Contracting Officer or his/her authorized Representative 

(COR) or authorized Technical Representative (COTR)

Contractor A contractor is a private firm, corporation, or individuals 

operating to provide service to clients. The contractor must 

possess all valid licenses and certifications as required by 

state regulations and the CO. The term “contractor” in this 

SOW also implies the firm that is or hires the lead 

inspectors/risk assessors. When this term is used in this 

SOW, it implies both.

 

Data Quality Objective

Deteriorated paint

The qualitative and quantitative statements, guidelines, and 

requirements presented in paragraphs 2.2 and 2.3 of this 

SOW that clarify study objectives, define the appropriate 

type of data, and specify the tolerance levels of potential

errors that will be used as the basis for establishing the 

quality of the data needed to support decisions. (see EM 

200-1-2 Appendix G DQO Attainment Verification 

Worksheet for further refinement of the DQO definition.

Paint that is cracking, flaking, chipping, peeling, or 

otherwise separating from the substrate of a building 

component. (40 CFR 745.223)

Distinct painting history The application history, as indicated by its visual 

appearance or a record of application, over time, of paint or 

other surface coatings to a component or room. (40 CFR 

745.223)

Double-blind sample For the purposes of this SOW, this refers to a QC sample 

(replicate, duplicate, spiked sample, etc.) that is sent to the 

laboratory with no indication of the possible lead content

and without identifying the sample as a QC sample.

HALO The Army’s Hazardous Asbestos and Lead Optimal 

Management System, which is; an electronic management 

system designed for installation use to track lead hazards 

and actions taken in response to identified lead hazards.
EP 1110-1-31

31 Aug 01 

A-43

Lead-based paint (LBP) Paint or other surface coatings that contain lead equal to or 

in excess of 1.0 milligrams per square centimeter or more 

than 0.5 percent by weight (5000 μg/g (parts per million)). 

(40 CFR 745.223) 

Lead-based paint hazard Any condition that causes exposure to lead from dust-lead 

hazards, soil-lead hazards, or lead-based paint that is 

deteriorated or present in chewable surfaces, friction 

surfaces, or impact surfaces, and that would result in 

adverse human health effects. (40 CFR Part 745)

Lead-based paint 

inspection

A surface-by-surface investigation to determine the 

presence of lead-based paint and the provision of a report 

explaining the results of the investigation. (40 CFR Part 

745)

μg/ft2 Micrograms per square foot

μg/g Micrograms per gram (parts per million on mass/mass 

basis)

Occupant use patterns Characteristics of occupants including number of childbearing age females, average age and numbers of children 

occupying units, unit use patterns including entrances most 

frequently used, windows opened most frequently, use of 

window air-conditioners, gardening habits, cleaning habits 

of occupants, yard characteristics and use of yard as play 

area.

QA Quality assurance; defined by NLLAP as an “integrated 

system of activities involving planning, QC, quality 

assessment, reporting, and quality improvement to ensure 

that a product or service meets defined standards of quality 

within a state level of confidence.” (NLLAP LQSR 

Revision 2.0 (August 1, 1996))

QC Quality control; defined by NLLAP as the “overall system 

of technical activities whose purpose is to measure and 

control the quality of a product or service so that it meets 

the needs of users. The aim is to provide quality that is 

satisfactory, adequate, dependable, and economical. 

(NLLAP LQSR Revision 2.0 (August 1, 1996))
EP 1110-1-31

31 Aug 01

A-44

Random Sampling A technique for selecting a sample of n elements from a 

population of elements in such a way that each combination 

of n elements has the same probability of being selected. In 

statistical sampling, the process of selecting sample units in 

such a way that all units under consideration have the same 

probability of being selected. (ASTM E1605)

Rinsate Blank A sample of “used” cleaning fluid rinse solution, also called 

equipment blank. Rinsate blank examples include a final 

rinse of the device used to collect soil or vacuumed dust or 

the final rinse to clean a scoop used to collect soil or 

vacuumed dust samples. The Rinsate blank is used in 

rinsing collection media and equipment prior to use to 

monitor possible cross contamination. The Rinsate blank 

goes through all steps in the analysis including the 

digestion. (EPA, 757-R-92-006, May 1993)

Risk assessment (1) An on-site investigation to determine the existence, 

nature, severity, and location of lead-based paint hazards, 

(2) The provision of a report by the individual or the firm 

conducting the risk assessment, explaining the results of the 

investigation and options for reducing lead-based paint 

hazards. (40 CFR 745.223)

Room equivalent A room equivalent is an identifiable part of a residence, 

such as a room, a house exterior, a foyer, staircase, hallway, 

or an exterior area (exterior areas contain items such as play 

areas, painted swing sets, painted sandboxes, etc.). Closets 

or other similar areas adjoining rooms should not be 

considered as separate room equivalents unless they are 

obviously dissimilar from the adjoining room equivalent. 

Most closets are not separate room equivalents. Exteriors 

should be included in all inspections. An individual side of 

an exterior is not considered to be a separate room 

equivalent, unless there is visual or other evidence that its 

paint history is different from that of the other sides. All 

sides of a building (typically two for row houses or four for 

freestanding houses) are generally treated as a single-room 

equivalent if the paint history appears to be similar. For 

multifamily developments or apartment buildings, common 

areas and exterior sites are treated as separate types of units, 

not as room equivalents (1995 HUD Guidelines, Chapter 7, 

1997 Revision). 
EP 1110-1-31

31 Aug 01 

A-45

Substrate The substrate is the material underneath the paint. 

Substrates should be classified into one of six types: brick, 

concrete, drywall, metal, plaster, or wood. These substrates 

cover almost all-building materials that are painted and are 

linked to those used in the XRF performance characteristic 

sheets. For example, the concrete substrate type includes 

poured concrete, precast concrete, and concrete block. 

If a painted substrate is encountered that is different from 

the substrate categories shown on the XRF Performance 

Characteristic Sheet, select the substrate type that is most 

similar in density and composition to the substrate being 

tested. For example, for painted glass substrates, an 

inspector should select the concrete substrate, because it has 

about the same density (2.5 g/cm3) and because the major 

element in both is silicon. 

For components that have layers of different substrates, 

such as plaster over concrete, the substrate immediately 

adjacent to (underneath) the painted surface should be used. 

For example, plaster over concrete block is recorded as 

plaster. (1995 HUD Guidelines, Chapter 7, 1997 Revision)

Target Housing Any housing constructed prior to 1978, except housing for 

the elderly or persons with disabilities (unless any one or 

more children age 6 years or under resides or is expected to 

reside in such housing for the elderly or persons with 

disabilities) or any 0-bedroom dwelling. (40 CFR 745.223)

Testing Combination A unique combination of room equivalent, building 

component type, and substrate. (1995 or 1997 HUD 

guidelines, Chapter 7, 1997 revision)
EP 1110-1-31

31 Aug 01

A-46

X-Ray

Fluorescence Analyzer 

(XRF)

XRF Performance 

Characteristic Sheet (PC)

An instrument that determines lead concentration in 

milligrams per square centimeter (mg/cm2) using the 

principle of x-ray fluorescence (XRF). Two types of XRF 

analyzers are used—direct readers and spectrum analyzers. 

In this SOW, the term XRF analyzer only refers to portable 

instruments manufactured to analyze paint, and does not 

refer to laboratory-grade units or portable instruments 

designed to analyze soil. (1995 HUD Guidelines) 

The “P.C. Sheet” is unique for each XRF Instrument. It 

specifies the inconclusive range, calibration check 

tolerance, and other instrument – specific information.
EP 1110-1-31

31 Aug 01

B-1

APPENDIX B

TABLES AND FORMS

This appendix contains tables and example forms to be used in completing lead hazard risk 

assessments. The forms are adapted from those presented in the HUD guidelines, and may be 

further modified to meet installation-specific or project-specific requirements. The tables and 

forms include:

Table B-1 Number of Units to be Tested in Multifamily Developments

Table B-2 Main Hazard Control Options That Could Be Identified in Risk Assessments

Table B-3 Analytical Data Acceptance Criteria for Lead-Based Paint Hazard Control 

Activities

Figure B-1 XRF Reading/Results Record Form 1

Figure B-2 Multifamily Decision Flowchart

Figure B-3 Building/Housing Unit Condition Form 2

Figure B-4 Paint Condition on Selected Surfaces Data Form 3

Figure B-5 Deteriorated Paint Chip Sampling Form 4

Figure B-6 Risk Assessment Dust Wipe Sampling Form 5

Figure B-7 Risk Assessment Soil Sampling Form 6

Figure B-8 Example Chain-of-Custody Form 7 for Lead Risk Assessment Sampling

Figure B-9 Lead Hazard Identification Results Summary Form 8
EP 1110-1-31

31 Aug 01

B-2

Table B-1

Number of Units to be Tested in Multifamily Developments

Number of Similar Units, 

Similar Common Areas, or 

exterior Site in a Building or 

Development

Pre-1960 or Unknown-age 

Building or Development: 

Number to Test

1960-1977 building or 

Development: Number to 

Test

1-9 All All

10-13 All 10

14 All 11

15 All 12

16-17 All 13

18 All 14

19 All 15

20 All 16

21-26 20 16

27 21 17

28 22 18

29 23 18

30 23 19

31 24 19

32 25 19

33-34 26 19

35 27 19

36 28 19

37 29 19

38-39 30 20

40-48 31 21

49-50 31 22

51 32 22
EP 1110-1-31

31 Aug 01

B-3

Table B-1 (Continued)

Number of Units to be Tested in Multifamily Developments

Number of Similar Units, 

Similar Common Areas, or 

exterior Site in a Building or 

Development

Pre-1960 or Unknown-age 

Building or Development: 

Number to Test

1960-1977 building or 

Development: Number to 

Test

52-53 33 22

54 34 22

55-56 35 22

57-58 36 22

59 37 23

60-69 38 23

70-73 38 24

74-75 39 24

76-77 40 24

78-79 41 24

80-88 42 24

89-95 42 25

96-97 43 25

98-99 44 25

100-109 45 25

110-117 45 26

118-119 46 26

120-138 47 26

139-157 48 26

158-159 49 26

160-177 49 27

178-197 50 27

198-218 51 27
EP 1110-1-31

31 Aug 01

B-4

Table B-1 (Continued)

Number of Units to be Tested in Multifamily Developments

Number of Similar Units, 

Similar Common Areas, or 

exterior Site in a Building or 

Development

Pre-1960 or Unknown-age 

Building or Development: 

Number to Test

1960-1977 building or 

Development: Number to 

Test

219-258 52 27

259-279 53 27

280-299 53 28

300-379 54 28

380-499 55 28

500-776 56 28

777-939 57 28

940-1004 57 29

1005-1022 58 29

1023-1032 59 29

1033-1039 59 30

1500 87 44

2000 116 58

2500 145 73

3000 174 87

3500 203 102

4000 232 116

*Adapted from Table 7.3 of the 1997 Revision to the HUD Guidelines.

**Follow the procedures outlined in Section V of Chapter 7 of the HUD Guidelines (1997 Revision):

...multifamily housing is defined as any group of units that are similar in construction from unit to unit, with:

• 21 or more units, if any were built before 1960 or are of unknown age, or

• 10 or more units, if they were all built from 1960 through 1977.

Developments with fewer units should be treated as a series of single-family housing units.

The number of similar units, similar common areas or exterior sites to be tested (the sample size) is based on the total 

number units, similar common areas or exterior sites in the building(s), as specified in Table 7.3. Use the table for 

sampling each set of similar units, each set of similar common areas and each set of exterior sites. For pre-1960 or 

unknown-age buildings or development with 1,040 or more similar units, similar common areas or exterior sites, test 5.8 

percent of them, and round up any fraction to the next whole number. For 1960-1977 buildings or developments with 

1,000 or more units, test 2.9 percent of the units, and round up any fraction to the next whole number. For reference, the 

table shows entries from 1500 to 1000 in steps of 500. For example, in a development built in 1962, with 200 similar units, 

20 similar common areas, and 9 similar exterior sites, sample 27 units, 16 common areas, and all 9 exterior sites.

Appendix 12 of the HUD Guidelines details the statistical rationale for this table.
EP 1110-1-31

31 Aug 01

B-5

Table B-2*

Main Hazard Control Options That Could Be Identified in Risk Assessments

Treatment 

Option

Dust1 on 

Floor

Dust1 on 

windows

Paint2 on 

Doors

Paint2 on 

Windows

Paint2 on 

Floors and 

Walls

Paint2

on Trim

High Soil 

Lead 

Levels

Dust removal X X X X X X X

Paint film 

stabilization

X X X X

Friction 

reduction 

treatments

X X X X

Impact 

reduction 

treatments

X X X X

Planting grass X X

Planting sod X X

Paving the soil X X

Encapsulation X X

Enclosure X X

Paint removal 

by heat gun3

X X X X

Paint removal 

by chemical3

X X X X

Paint removal 

by contained 

abrasive3

X X X X

Soil removal X X X

Building 

component 

replacement

X X X X

*Adapted from Table 5.8 of the 1995 HUD Guidelines.

1

Lead-contaminated dust.

2Deteriorated lead-based paint.

3

Limited areas only.
EP 1110-1-31

31 Aug 01

B-6

Table B-3

Analytical Data Acceptance Criteria for

Lead-Based Paint Hazard Control Activities

ACCEPTANCE LIMITS DATA ATTRIBUTE

Frequency SINGLE WIPE COMPOSITE WIPE PAINT CHIP SOIL

INDEPENDANT CALIBRATION 

VERIFICATION (ICV)

Once per Day

Within ± 10% of Known Value Within ± 10% of Known Value Within ± 10% of Known Value Within 10% of Known Value

INITIAL CALIBRATION BLANK (ICB)

At the Beginning of Run

Absolute Value Not More Than 

10% of the Regulatory Limit or 

Minimum Level of Concern

Absolute Value Not More Than 

10% of the Regulatory Limit or 

Minimum Level of Concern

Absolute Value Not More Than 

10% of the Regulatory Limit or 

Minimum Level of Concern

Absolute Value Not More Than 

10% of the Regulatory Limit or 

Minimum Level of Concern

CONTINUING CALIBRATION 

VERIFICATION CCV)

Beginning and End of Run and Every 10 

Samples or as specified in the SOP

Within ± 15% of Known Value for 

ICP or FAAS; Within ± 20% for 

GFAA

Within ± 15% of Known Value for 

ICP or FAAS; Within ± 20% for 

GFAA

Within ± 15% of Known Value for 

ICP or FAAS; Within ± 20% for 

GFAA

Within ± 15% of Known Value for 

ICP or FAAS; Within ± 20% for 

GFAA

INTERFERENCE CHECK SAMPLE (ICS)

Beginning and End of Run or Twice Every 

Eight Hours

Within 20% of Known Value Within 20% of Known Value Within 20% of Known Value Within 20% of Known Value

CONTINUING CALIBRATION BLANK 

(CCB)

After each ICS and CCV

Absolute Value not More Than 

10% of Regulatory Limit of Level 

of Concern

Absolute Value not More Than 

10% of Regulatory Limit of Level 

of Concern

Absolute Value not More Than 

10% of Regulatory Limit of Level 

of Concern

Absolute Value not More Than 

10% of Regulatory Limit of Level 

of Concern

LABORATORY CONTROL SAMPLE (LCS)

One per 20 Samples or Batch-Minimum 

Frequency 5%

Within ± 20% of Known Value Within ± 20% of Known Value Within ± 20% of Known Value Within ± 20% of Known Value

MATRIX SPIKE SAMPLE (MSS)

One per 20 Samples or Batch-Minimum 

Frequency 5%

Within 25% of Calculated Value Within 25% of Calculated Value Within 25% of Calculated Value Within 25% of Calculated Value

DUPLICATE FIELD SAMPLE (DFS)

One per 20 Samples or Batch-Minimum 

Frequency 5%

Within ±25% Relative Percent 

Difference (RPD)

Within ±25% Relative Percent 

Difference (RPD)

Within ±25% Relative Percent 

Difference (RPD)

Within ±25% Relative Percent 

Difference (RPD)

MATRIX BLANK (MB)

One per 20 Samples or Batch-Minimum 

Frequency 5%

Absolute Value Not More Than 

10% of Regulatory Limit of Level 

of Concern

Absolute Value Not More Than 

10% of Regulatory Limit of Level 

of Concern

Absolute Value Not More Than 

10% of Regulatory Limit of Level 

of Concern

Absolute Value Not More Than 

10% of Regulatory Limit of Level 

of Concern

Adapted from Table 1, EPA NLLAP Laboratory Quality System Requirements (LQSR) Revision 2.0, August 1, 1999
EP 1110-1-31

31 Aug 01

B-7

FORM 1

XRF READING/RESULTS

Address/Unit No.___________________________________________ Date:______________________ Page____of_____

Room Equivalent ____________________________________________________________________________________________

XRF Serial No._________________________ Inspector Signature___________________________________________________

Substrate Component Color Test Locations XRF Reading Correction 

Value Result

Classification 

(pos, neg, inc)

Laboratory 

Result Unit Final Classification

mg/cm2

%

mg/cm2

%

mg/cm2

%

mg/cm2

%

mg/cm2

%

mg/cm2

%

mg/cm2

%

Figure B-1: XRF Reading/Results Form
EP 1110-1-31

31 Aug 01

B-8

Multifamily Decision Flowchart

Figure B-2 Multifamily Decision Flowchart
EP 1110-1-31

31 Aug 01

B-9

FORM 2

BUILDING/HOUSING UNIT CONDITION

(In multi-family housing, use a separate form for each unit.)

Installation POC 

Housing Group 

Street Address Unit No. City State 

Name of risk assessor 

Condition Yes No Comments

Roof missing parts of surfaces (tiles, boards, shakes, 

etc.)

Roof has holes or large cracks

Gutters or downspouts broken

Chimney masonry cracked, bricks loose or missing, 

obviously out of plumb

Exterior or interior walls have obvious large cracks or 

holes, requiring more than routine pointing (if 

masonry) or painting

Exterior siding has missing boards or shingles

Water stains on interior walls or ceilings

Plaster walls or ceilings deteriorated

Two or more windows or doors broken, missing, or 

boarded up

Foundation has major cracks, missing material, 

structure leans, or visibly unsound

Other (specify)

Other (specify)

*Total Number

*If the “Yes” column has two or more checks, the dwelling is usually considered to be in poor condition for the purposes of a leadhazard risk assessment. (Source: HUD Guidelines, Form 5.1)

Additional Comments:

Risk Assessor Signature and Certification Number Date

Figure B-3: Building/Housing Unit Condition Form
EP 1110-1-31

31 Aug 01

B-10

FORM 3

PAINT CONDITION ON SELECTED SURFACES DATA

Installation POC 

Housing Group 

Street Address Unit No. City State 

Name of risk assessor 

Building 

Component

Location 

Notes

Paint condition; 

type* of 

deterioration.

Deterioration 

due to friction 

or impact?

Deterioration 

due to 

moisture?

Location of 

painted 

component with 

visible bite marks

Building siding

Exterior trim

Exterior windows

Exterior doors

Railings

Porch floors

Other porch 

surfaces

Interior doors

Ceilings

Walls

Interior windows

Interior floors

Interior trim

Stairways

Radiator (or 

radiator cover)

Kitchen cabinets

Bathroom 

cabinets

Other surfaces:

Mini blinds

*Types of deterioration: surface deterioration (chalking, mildew, or friction/impact damage); bulk deterioration (checking, cracking and flaking, 

and alligatoring); layered deterioration (blistering, scaling or flaking (peeling), peeling from metal, peeling from exterior wood, peeling from 

plaster walls, and peeling from masonry surfaces); or a combination. Record the overall condition of a component that is similar throughout a 

dwelling. Record specific locations of any component with bite marks.

(Table adapted from 1995 HUD Guidelines, Form 5.2)

Figure B-4: Paint Condition on Selected Surfaces Data Form
EP 1110-1-31

31 Aug 01

B-11

FORM 4

DETERIORATED PAINT CHIP SAMPLING

Installation POC 

Housing Group 

Street Address Unit No. City State 

Dwelling Selection Criteria: All Dwellings Random 

Sample

ID#

Room Name

and Number Component

Lab

Results Units

μg/g (ppm)

μg/g (ppm)

μg/g (ppm)

μg/g (ppm)

μg/g (ppm)

μg/g (ppm)

μg/g (ppm)

μg/g (ppm)

μg/g (ppm)

μg/g (ppm)

Sample all layers of paint, not just deteriorated paint layers.

Total number of samples on this page: 

Date assessed: Date sent to lab: 

Shipped by: Received by: 

(signature) (signature)

Date results reported: Analyzed by: 

(Note: Attach a Copy of the Chain-of-Custody Form to this Form. See Lab Report for QA/QC Information.)

NOTES:

Name of Risk Assessor (print) 

Certification Number(s) 

Signature

Figure B-5: Deteriorated Paint Chip Sampling Form
EP 1110-1-31

31 Aug 01

B-12

FORM 5

RISK ASSESSMENT DUST WIPE SAMPLING

Installation POC 

Housing Group 

Street Address Unit No. City State 

Dwelling Selection Criteria: All Dwellings Random 

Sample 

ID#

Room 

Name 

and 

Number 

Surface Type 

(floor, window 

sill, etc.)

Is surface 

smooth and 

cleanable?

Surface 

Substrate

Dimensions of 

Sample Area 

(inches)

Area 

(ft2)

Results of 

Lab 

Analysis 

(μg/ft2)

X

X

X

X

X

X

X

X

X

X

Total number of samples on this page: 

Date of sample collection: Date sent to lab: 

(Note: Attach a Copy of the Chain-of-Custody Form to this Form. See Lab Report for QA/QC Information.)

NOTES:

Name of Risk Assessor (print) 

Certification Number(s) 

Signature Date 

Figure B-6: Risk Assessment Dust Wipe Sampling Form
EP 1110-1-31

31 Aug 01

B-13

FORM 6

RISK ASSESSMENT SOIL SAMPLING

Installation POC 

Housing Group 

Street Address Unit No. City State 

Sample

ID# Location Bare Results of Lab Analysis (μg/g or ppm)

Date of sample collection: Date shipped to lab: 

(Attach a Copy of the Chain-of-Custody Form to this Form. See Lab Report for QA/QC Information.)

NOTES:

Name of Risk Assessor (print) 

Certification Number(s) 

Signature Date 

Figure B-7: Risk Assessment Soil Sampling Form
EP 1110-1-31

31 Aug 01

B-14

FORM 7

EXAMPLE CHAIN OF CUSTODY FORM

FOR LEAD RISK ASSESSMENT SAMPLING

Page of

Project Name Project Number Sample Preparation/Analysis Required (check the appropriate box)

Installation

Project Manager

Company Name

Company Address

Phone

ASTM E1644 (Prep)ASTM E1645 (Prep)ASTM E1726 (Prep)ASTM E1979 (Prep)

ASTM E1613 (Anal)

Other (specify)

Sample ID Sample Date Time Sample Matrix 

(wipe, paint chip, 

soil, other)

Laboratory ID

Sampler:

Signature

Printed Name/Certification Number

Company Name

Date/Time

1. Released by:

Signature

Printed Name

Company Name

Date/Time

2. Received by:

Signature

Printed Name

Company Name

Date/Time

Special Instructions/Comments:

Figure B-8: Example Chain of Custody Form for Lead Risk Assessment Sampling
EP 1110-1-31

31 Aug 01

B-15

FORM 8

LEAD-HAZARD IDENTIFICATION RESULTS SUMMARY

Installation POC Phone Number: 

Building Address or Location 

Housing Unit No. (if applicable) 

Location of Identified Lead-Based Paint and/or Lead Hazards

Room 

Number 

or 

Identifier

Surface Type (floor, 

window sill, etc.)

Sample Type 

(dust, paint, 

soil)

Sample 

ID#

Results of 

Lab 

Analysis

EPA 

Action 

Levels

Basis for Determination 

of Hazard

(e.g., deteriorated paint)

Comments

Date of sample collection: Total number of samples collected: 

KEY: (1) Room Number or Identifier: must correspond with the unique Unit Number used for each unit as identified in the Risk Assessment Report.

 (2) Sample ID #: Must correspond to the unique sample numbers generated during sample collection and submitted in Laboratory Report as part 

of the Risk Assessment Report.

 (3) Results of Lab Analysis: Report Dust in μg/ft2; Paint Chips in % by weight and μg/g (parts per million (ppm)) and soil in ppm.

 (4) EPA Action Levels: Dust: 40 μg/ft2 for floors; and 250 μg/ft2 for window sills; Paint chips 0.5% by weight (5000 μg/g (ppm)); and soil: 400 

ppm bare soil in play areas; 1200 ppm bare soil, non-play areas.

 (5) Basis for Determination of Hazard: Dust exceeds Table A-1 action level for surface evaluated, paint chip exceeds Table A-1 definition for 

LBP and is deteriorated, and soil exceeds Table A-1 action levels based on child access and use.

Figure B-9: Lead-Hazard Identification Results Summary Form