_____________________________________________

This EP Supercedes EP 1110-1-28 Dated 31 March 2000

CEMP-RA

Pamphlet No.

1110-1-28

Department of the Army

U.S. Army Corps of Engineers

Washington, DC 20314-1000

EP 1110-1-28

31 Aug 01

Engineering and Design

LEAD HAZARD RISK ASSESSMENT FOR

TARGET HOUSING /CHILD OCCUPIED FACILITIES

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

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APPENDIX A

LEAD HAZARD RISK ASSESSMENT

FOR TARGET HOUSING/CHILD-OCCUPIED FACILITIES

STANDARD SCOPE OF WORK

APPENDIX A TABLE OF CONTENTS

1.0 PROJECT OVERVIEW, OBJECTIVES, AND DESCRIPTION OF WORK A-8

1.1 REFERENCES A-8

1.1.1 Federal A-8

1.1.1.1 Consumer Product Safety Commission A-8

1.1.1.2 U.S. Environmental Protection Agency (EPA) A-8

1.1.1.3 U.S. Department of Housing and Urban Development 

(HUD) A-8

1.1.1.4 Occupational Safety and Health Administration (OSHA) A-9

1.1.2 U.S. Army (DA) A-9

1.1.2.1 Army Regulation (AR) AR 200-1 Environmental Protection 

and Enhancement A-9

1.1.2.2 AR 420-70, Facilities Engineering, Buildings and StructuresA-9

1.1.2.3 AR 608-10, Child Development Services A-9

1.1.2.4 DA Public Works Technical Bulletin 420-70-2, Installation 

Lead Hazard Management. A-9

1.1.2.5 DA Hazardous Asbestos and Lead Optimal Management 

System (HALO) A-9

1.1.2.6 U.S. Army Corps of Engineers (USACE) Engineering 

Manual (EM) 385-1-1, Safety & Health Requirements 

Manual A-9
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1.1.3 State, Local, & Outside Continental United States (OCONUS) 

HOST Nation Agreements, etc. A-9

1.1.4 Other Organizations A-9

1.1.4.1 American Association for Laboratory Accreditation 

(A2LA) A-9

1.1.4.2 American Industrial Hygiene Association (AIHA) A-9

1.1.4.3 American Society for Testing and Materials (ASTM) A-9

1.2 REGULATORY REQUIREMENTS A-10

1.2.1 Regulatory Authority/Requirements A-10

1.2.1.1 Federal Requirements A-10

1.2.1.2 State and Local Requirements A-11

1.3 SITE CHARACTERISTICS, OBJECTIVES AND DESCRIPTION OF 

WORK A-11

1.3.1 Site Location/Characteristics and Occupant Use Patterns A-11

1.3.2 Previous Studies and Results A-12

1.3.3 Project Work Tasks/Description of Work A-12

1.3.4 Unit Selection Strategy A-12

1.3.5 Data Quality Objectives (DQOs) A-13

1.3.6 Bid Assumptions A-14

2.0 PROJECT REQUIREMENTS A-15

2.1 TASK 1 DESCRIPTION OF CURRENT CONDITIONS/PROJECT 

WORK PLAN A-15

2.1.1 Background Data A-15

2.1.1.1 Lead Hazard Management Plan Review A-15

2.1.1.2 Interviews A-16
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2.1.1.3 Summary of Preexisting Data, Lead Hazard Management 

Plan, and Interviews A-16

2.1.2 Project Boundaries Identification/Floor Plans A-16

2.1.3 Preliminary Site Visit/Walkover A-17

2.1.4 Occupant Notification/Housing Unit Access A-17

2.1.5 Project Work Plan A-17

2.2 TASK 2. CONDUCT RISK ASSESSMENT A-18

2.2.1 Risk Assessment A-18

2.2.1.1 Visual Assessment A-18

2.2.1.2 Sample Location Selection A-18

2.2.1.3 Risk Assessment Sample and Sample Location 

Documentation A-21

2.2.2 Single Surface Dust Sampling A-21

2.2.3 Deteriorated Paint Chip Sampling A-21

2.2.4 Soil Sampling A-22

2.2.5 Sample Identification A-22

2.2.6 Sample Chain-of-Custody A-22

2.2.7 Decontamination A-22

2.3 TASK 3 SAMPLE DATA ANALYSIS, EVALUATION OF FINDINGS A-22

2.3.1 Sample Preparation and Analysis A-22

2.3.1.1 Dust Sample Preparation and Analysis A-23

2.3.1.2 Paint Chip Sample Preparation and Analysis A-23

2.3.1.3 Soil Sample Preparation and Analysis A-23

2.3.1.4 Laboratory Turnaround Time A-23
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2.3.2 Quality Assurance and Quality Control (QA/QC) A-24

2.3.2.1 Field Blank Dust Wipe QA Samples A-24

2.3.2.2 Field Spike Dust Wipe QA Samples A-24

2.3.2.3 Field Duplicate/Spike Paint Chip QA Samples A-25

2.3.2.4 Field Rinsate Blank QA Samples (Soil) A-25

2.3.2.5 Matrix Spike/Matrix Spike Duplicate (MS/MSD) Soil QC 

Samples A-25

2.3.3 Project Data Review and Assessment A-26

2.3.3.1 Field Wipe Quality Assurance Verification A-26

2.3.3.2 Laboratory QA and QC Verification. A-26

2.3.4 Contractor Certification of Project Data Validity A-27

2.3.5 Comparison with Lead Hazard Criteria A-27

2.3.6 Project Data Presentation A-28

2.3.6.1 Laboratory Report A-28

2.4 TASK 4 RISK ASSESSMENT REPORT A-28

2.4.1 General Report Contents A-28

2.4.2 Summary of Pre-existing Data, Lead Hazard Management Plan, 

and Interviews A-29

2.4.3 Contractor Data Certification A-29

2.4.4 Electronic HALO/Installation Data Downloading into Installation 

System A-29

2.4.5 Update Installation Management Plan A-30

2.4.6 Comparison of Contractor Findings to Installation HALO FindingsA-30

2.4.7 Contractor Conclusions and Recommendations A-31

2.4.8 Other Field and Laboratory Data A-31
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2.4.9 Summary of Lead Hazard Risk Assessment Results A-31

2.4.10 Regulatory Statements of Compliance A-31

3.0 SUPPLEMENTAL REQUIREMENTS FOR CONTRACTED SERVICES A-31

3.1 CONTRACTOR FIRM/PERSONNEL QUALIFICATIONS A-31

3.1.1 Contractor Firm Experience A-31

3.1.2 Contractor Risk Assessor/Project Manager Qualifications A-31

3.1.2.1 EPA Certification A-32

3.1.2.2 State and Local Certification A-32

3.1.2.3 Evidence of Certification A-32

3.1.2.4 Record of Experience A-32

3.1.2.5 Use of Risk Assessment Teams A-32

3.1.2.6 Project Manager Experience A-32

3.1.3 Contracted Laboratory Qualifications A-32

3.1.4 Contractor Errors and Omissions Liability Insurance A-33

3.2 PROJECT RECORDS A-33

3.2.1 Record keeping Requirements A-33

3.2.1.1 Project Work Plan A-33

3.2.1.2 Risk Assessment Report A-33

3.3 PROJECT COORDINATION A-33

3.4 GOVERNMENT SUPPORT A-34

3.4.1 Government Quality Assurance Oversight and Support A-34

3.4.2 Rights of Entry, Security, and Escorts A-34

3.4.3 Temporary Office/Equipment Storage/Staging Areas A-35
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3.5 TRAVEL AND MEETINGS A-35

3.5.1 Preliminary Project Site Visit/Walkover A-35

3.5.2 Project Work Plan Review and Start-up Meeting A-35

3.5.3 Data Certification Meeting A-36

3.5.4 Final Risk Assessment Report Meeting A-36

3.5.5 Additional Meetings A-36

3.6 SCHEDULES A-36

3.7 SUBMITTALS A-37

3.7.1 Project Work Plan A-37

3.7.2 Progress Report(s) A-37

3.7.3 Final Risk Assessment Data Submission in Electronic Format A-37

3.7.4 Final Risk Assessment Report A-37

3.8 MISCELLANEOUS A-37

3.8.1 Glossary A-37

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NOTE TO SCOPE OF WORK EDITOR

This Standard Scope of Work (SOW) is to be used for performance of lead hazard 

risk assessments at active Army target housing, Family Child Care (FCC) homes, child 

development centers, and other child-occupied facilities (see Glossary). All 

Continental United States (CONUS) target housing and child-occupied facilities 

constructed prior to 1 January 1978 are assumed to contain lead-based paint 

(LBP) (see Glossary) by Department of the Army (DA) policy. The presence or 

use of LBP in target housing/child-occupied facilities, regardless of age, in 

Outside Continental United States (OCONUS), must be determined on a caseby-case basis. Lead hazard risk assessments determine the presence, nature, 

severity and location of lead hazards to children (under the age of 6) or 

document that no hazards exist through a review of site characteristics, visual 
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inspection and collection/analysis of dust, paint and soil samples. The 

assessment provides a report describing lead hazards found and control 

measures recommended to eliminate the hazards.

This SOW is not to be used, as written, for conducting lead hazard screens, and 

conducting risk assessments using targeted or worst-case sampling strategies. 

For information on modifications necessary for targeted or worst case sampling 

strategy, contact the US Army Corps of Engineers Hazardous, Toxic and 

Radioactive Waste (HTRW) Center of Expertise. Currently, lead hazard 

screens are not to be performed at installations because of unresolved issues 

regarding composite dust sampling and composite dust sample analysis.

This SOW is not to be used for projects associated with the transfer of Army 

target housing/child-occupied facilities under Base Realignment and Closure 

(BRAC) procedures. EP 1110-1-31 “Combined Lead Inspection/Risk 

Assessment for Target Housing Property Transfers Standard Scope of Work” 

is published for these types of BRAC projects.

DA policy disallows the use of x-ray fluorescence (XRF) in conducting lead 

hazard risk assessments in Army target housing and child-occupied facilities. 

Therefore this methodology is not included in the SOW, excepted when 

conducted as part of a combined lead inspection/risk assessment provided for in 

EP 1110-1-31.

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

investigations. EBL investigations involve a more thorough investigation of 

additional sources of lead hazards to children such as contaminated eating 

utensils, food and beverage containers, personal hygiene practices, off-site day 

care, community water supply, public playgrounds, lead painted surfaces in 

residences and other spaces occupied by children. EBL investigations require 

a coordinated effort of the installation’s lead hazard management team and 

could include state and local public health departments. See Public Works 

Technical Bulletin (PWTB) 420-70-2, Installation Lead Hazard Management.

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

issue is addressed under the Safe Drinking Water Act monitoring 

requirements.

The editor of this SOW must have successfully completed a US Environmental 

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

to be performed) accredited training course required for certification as a risk 

assessor (see 40 CFR 745.223) and must have received a course completion 

certificate. In addition, the editing risk assessor must have familiarity with 

Federal, state and local requirements applicable in the jurisdiction in which the 

project is to be completed. If the SOW editor is under contract to the 
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government, certification as a risk assessor should be required. Contact state 

and local authorities to determine whether established requirements and 

procedures are more protective 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

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

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1.0 PROJECT OVERVIEW, OBJECTIVES, AND DESCRIPTION OF WORK

1.1 REFERENCES

1.1.1 Federal

1.1.1.1 Consumer Product Safety Commission

a. Ban of Lead-Containing Paint and Certain Consumer Products Bearing LeadContaining Paint, 16 Code of Federal Regulations (CFR) 1303.

b. 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, 40 CFR 745, Subpart D LeadBased Paint Hazards, and Subpart L, Lead-Based Paint Activities; Final Rule, 66 FR 1206, January 5, 

2001.

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

a. 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)
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b. Residential Lead-Based Paint Hazard Reduction Act of 1992 (Title X), U.S.

Department of Housing and Urban Development, 102 P.L. 550.

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.

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 AR 608-10, Child Development Services

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

Management.

(http://www.hnd.usace.army.mil/)

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

1.1.2.6 U.S. Army Corps of Engineers (USACE) Engineering Manual (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)

1.1.4.3 American Society for Testing and Materials (ASTM)

The Contractor shall assure use of the most current versions of the listed ASTM 

standards applicable to the project.

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

1.2 REGULATORY REQUIREMENTS 

1.2.1 Regulatory Authority/Requirements

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 SOW, the 

Contractor shall use the most protective.

1.2.1.1 Federal Requirements

a. Assessment Procedures and Requirements.

The Contractor shall comply with all 40 CFR 745 Subpart L requirements as outlined in this SOW, 

using referenced methodologies of the Guidelines for the Evaluation and Control of Lead-Based Paint 

Hazards in Housing, HUD, June 1995 (Chapter 7 Revision, 1997); and EPA “Lead; Identification of 

Dangerous Levels of Lead”; 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).
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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 including 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 by the Contracting Officer.

1.2.1.2 State and Local Requirements

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NOTE: Reference state, local, (and OCONUS if applicable) or installationspecific requirements that differ from the Federal requirements cited above 

that are applicable to the work addressed in this SOW.

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

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NOTE: Identify the target housing/child-occupied facilities and Family Child 

Care (FCC) homes to be addressed in the risk assessment on a unit-by-unit basis. 

Obtain site location information including installation and building designations 

(e.g., single unit or multiple unit housing, child development centers) unit floor 

plans and addresses. Provide the information and floor plans as an attachment 

to the SOW. Summarize physical characteristics and occupant use pattern 

information (see Glossary) that the Contractor must review as required 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).

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The risk assessment shall address the following locations [insert unit description information]. The 

physical characteristics and occupant use patterns at these locations are summarized as follows: [insert 

physical characteristic and occupant use pattern descriptive information].
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1.3.2 Previous Studies and Results

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

considered by the risk assessor in making lead hazard decisions and 

conclusions for the work specified in this SOW.

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[Prior to initiating field activities required by this SOW, the risk assessor shall review the previous study 

data results collected at the location(s) identified in Paragraph 1.3.1, and provided as an attachment to 

this SOW.]

1.3.3 Project Work Tasks/Description of 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 hazard risk assessment shall include a visual 

assessment and sampling for the identification of lead hazards at each unit included in the survey. 

Procedures and requirements for completing the risk assessment activities are defined in the paragraphs 

that follow.

1.3.4 Unit Selection Strategy

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NOTE: All 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 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.

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[The Contractor shall perform a risk assessment on each unit identified in this SOW.]

[The Contractor shall randomly assess (see Glossary) the housing units identified in this SOW. Units 

shall be selected for risk assessment from the total unit population identified in Paragraph 1.3.1. The 

minimum number that must be randomly assessed shall be determined by using Table B-1 (Appendix 

B). Following random selection of units to be assessed, any Family Child Care (FCC) homes not 

included in the list identified for assessment through the random selection process shall be added to and 

included in the list. The Contractor shall randomly select alternate housing units beyond the minimum 

number required in Table B-1 (Appendix B) to provide flexibility based on information obtained on site 
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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)

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NOTE: Refer to EPA “Lead; Identification of Dangerous Levels of Lead”, 

Final Rule, 66 FR 1206, 5 January 2001.

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The Contractor shall meet the project-specific DQOs 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 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 Risk Assessment Report in accordance with

Paragraph 2.4.10.
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Table A-1

Hazard Levels for a Lead Risk Assessment

Sample Matrix/Surface Type Paint-Lead Hazard Action Level1

Lead-Based Paint 0.5% by weight or 5,000 μg/g (ppm) 

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

exterior) that is peeling, chipping, chalking or cracking, or 

otherwise damaged or separated from the substrate

Paint-Lead Hazard11

Any friction surface subject to abrasion with 

horizontal dust lead levels below and nearest the 

surface equal or exceeding 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 doorknobs or out-of-plumb doors.

Dust-Lead Hazard1 (single surface wipe

sampling only)

All Floors, Hard Surface and Carpeted 40 μg/ft2

Interior Window Sills 250 μg/ft2

Floors or windowsills in unsampled dwellings or common 

areas that are part of multi-family units if at least on

sampled unit tested positive for these parameters.

Soil-Lead Hazard1: bare soil: child play area 400 ppm

Soil-Lead Hazard1: remainder of yard

excluding child play areas

1200 ppm

1See 40 CFR 745.65 for more detailed definition.

1.3.6 Bid Assumptions

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

tasks that will be performed. As a rule of thumb, six to eight dust wipes and 
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five deteriorated painted surfaces are sampled per unit during most risk 

assessments. The number of paint chips analyzed per unit should typically range from 

two (2) to ten (10). A total of two composite soil samples per unit are also 

typical for 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 

sample analysis 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 of the project. 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 contractors 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., re -sampling certain areas, etc.). Include the 

requirement for a preliminary site walkover.

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Bid assumptions include: [insert bid parameters]

2.0 PROJECT REQUIREMENTS

2.1 TASK 1 DESCRIPTION OF CURRENT CONDITIONS/PROJECT WORK 

PLAN

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

in the installation’s Lead Hazard Management Plan 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.

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2.1.1 Background Data 

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

affecting children less than six years old for the units that will be addressed in the 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.]
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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 review preexisting survey data, if provided, to identify LBP locations, to verify

maintenance histories, and to coordinate unit access procedures.

c. Director of Public Works - to discuss assessment logistics, i.e., 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. [insert others whose interviews are important to the project]]

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 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 summary of the Installation’s Lead Hazard Management Plan information pertinent to the risk 

assessment 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

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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 Drafting (CADD) drawings of the units involved with the 
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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 risk assessment.

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

each type of unit assessed are [provided in CADD format and] attached as a part of this SOW. The 

Contractor’s risk assessor shall use the [CADD] plans/sketches when performing Task 2 to identify and 

record sample locations in developing the Risk Assessment Sample and Sample Location

Documentation.

2.1.3 Preliminary Site Visit/Walkover

The 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 Risk Assessment Sampling Plan.

2.1.4 Occupant Notification/Housing Unit Access

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NOTE: Occupant notification of planned lead-hazard risk assessment activities 

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

the Environmental Manager and the Housing Authority.

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The Government shall notify the occupants of the units that will be 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 installation 

authority responsible for notification and unit access, and establish a schedule for unit entry based upon 

the contractor’s Risk Assessment Sampling Plan and requirements of this SOW. 

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).

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

review including the [CADD] floor plans/sketches provided, 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

• Risk Assessment Sampling Plan including unit and sample selection and analysis strategy.

• Identification and qualifications of each laboratory used to analyze lead samples
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• Project personnel/team identification and qualifications

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

2.2 TASK 2. CONDUCT RISK ASSESSMENT

2.2.1 Risk Assessment

2.2.1.1 Visual Assessment

The risk assessor shall conduct a visual assessment of all selected units to locate potential LBP hazards 

and to evaluate the magnitude of each hazard. If previous paint inspections have been conducted, the 

assessor shall focus on the painted surfaces that are known to contain lead-based paint and the dust 

reservoirs around them. Paint on surfaces older than 1 January 1978 shall be assumed to be LBP 

where testing has not determined otherwise. The risk assessor shall visually inspect the unit exterior and 

every room of each unit that will be assessed to evaluate paint and building conditions using the floor 

plans/sketches. Every lead-based paint component system with the same distinct painting history (see 

Glossary) shall be evaluated separately. All potential paint-lead hazards shall be visually identified 

based on condition as follows:

The risk assessor shall identify:

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

potentially exceed the dust-lead hazard action levels in Table A-1

• Any chewable surface with evidence of teeth marks. 

• Any other deteriorated lead-based paint identified on any component system. 

• Visible dust

• Bare soil

In addition the risk assessor shall visually assess painted surfaces in common areas accessible to 

children. The 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). The visual assessment of each unit shall be documented using Form 1 and Form 

2 (see Figure B-1 and Figure B-2, Appendix B). The forms shall be submitted as attachments to the 

Risk Assessment Report.

2.2.1.2 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

******************************************************************************
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The assessor shall select single surface dust wipe, paint chip, and soil sample locations during the visual 

assessment. Sample locations for each unit shall be identified on each unit floor plan/sketch, and shall 

be selected based on visual observations, separate component systems with distinct painting histories, 

pre-assessment unit information (including physical characteristics, use patterns, previous study results), 

and on the following: Surfaces to be tested for lead include each friction surface or impact surface with 

visibly deteriorated paint, and all other surfaces with visibly deteriorated paint. Surfaces that have been 

chewed (or where chewing and/or mouthing have been reported) shall be identified as lead-based paint 

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 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, age 6 and under 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.

For 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:
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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 child-occupied 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:

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

square feet.]

b. Paint Chip Sample Locations

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 selected 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 risk assessor shall 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:

• One composite from the foundation drip line and,

• One composite from exterior play areas including accessible crawl spaces

• [Gardens]

• [Other locations as required by applicable regulations]
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2.2.1.3 Risk Assessment Sample and Sample Location Documentation

Upon completion of the visual examination for each unit included in the assessment, and prior to actual 

sampling, the Contractor shall clearly mark, number and otherwise uniquely identify all dust, paint chip, 

and soil samples by marking the locations on the floor plan or sketch and by using the forms indicated 

below. The resultant information shall be compiled and labeled the “Risk Assessment Sample and 

Sample Location Documentation” before actual sampling commences on a unit-by-unit basis. Sampling 

shall be completed immediately following the visual examination and sample location documentation, 

prior to exiting the unit to proceed to the next.

Single surface dust sample locations shall be recorded on the floor plan or sketch and by filling in the 

identifying information on Form 4 (see Figure B-4, Appendix B).

Paint chip sample locations shall be recorded on the floor plan or sketch and by filling in the identifying 

information on Form 3 (see Figure B-3, Appendix B).

Each composite soil sample location and identity shall be recorded on Form 5 (see Figure B-5, 

Appendix B) and on the floor plan or sketch by sub-sample location. The plan or sketch 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 Risk Assessment 

Report.

2.2.2 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.

Samples 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). (see AIHA web 

site (http://www.aiha.org) for a listing of wipe vendors meeting ASTM Method E 1792 criteria.)

2.2.3 Deteriorated Paint Chip Sampling

The risk assessor shall collect and preserve paint chip samples for each deteriorated paint component 

system with a distinct painting history in accordance with ASTM’s Standard Practice for Field 
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Collection of Dried Paint Samples for Lead Determination by Atomic Spectrometry Techniques

(E 1729).

2.2.4 Soil Sampling

Each composite sample shall include not less than two (2) and not more than ten (10) sub-samples 

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 Xshaped 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.

2.2.5 Sample Identification

Dust, paint chip, 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.

2.2.6 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 to the laboratory, and a 

copy of the forms shall accompany each shipment of samples. Form 7 is included as an example chainof-custody form. See Figure B-7 in Appendix B.

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

the Risk Assessment Report.

2.2.7 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 Sample Preparation and Analysis 
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Samples collected by the risk assessor during the assessment(s) shall be sent to a 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:

2.3.1.1 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 and EPA criteria.

2.3.1.2 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 the EPA criteria.

2.3.1.3 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.

2.3.1.4 Laboratory Turnaround Time

The Contractor shall require the laboratory to report analytical results to the Contractor within [5] 

[insert number of days] days of the laboratory’s receipt of the samples in the laboratory.
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2.3.2 Quality Assurance and Quality Control (QA/QC)

2.3.2.1 Field Blank Dust Wipe QA Samples

Field blanks for single wipe sampling shall be 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.

2.3.2.2 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/

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. The 

laboratory must use NIST traceable materials 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 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 
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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 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. 

2.3.2.3 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.

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

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 reference 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.

2.3.2.4 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.

2.3.2.5 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 
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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).)

2.3.3 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 A-1, Section 10-Quality Assurance and Quality Control. 

Table B-3 (Appendix B) 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 (Appendix B).

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

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

the data was collected in accordance with 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 Risk Assessment Sampling Plan throughout the 

performance of the assessment.

2.3.3.1 Field Wipe Quality Assurance Verification

Prior to beginning field dust sampling, the risk assessor 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, or verify to the Contracting Officer 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.)

2.3.3.2 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-ofcustody errors.
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******************************************************************************

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 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, (Appendix B). If the laboratory fails to obtain spiked sample 

results within the specified error limits:

• Two more spikes of the same matrix shall be sent immediately to the laboratory for 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 re-analysis 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 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.

2.3.5 Comparison with Lead Hazard Criteria

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

determine whether lead hazards are present. This comparison shall be documented in the Risk

Assessment Report, as outlined below.

For all 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.
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2.3.6 Project Data Presentation

The Contractor shall provide the project data to the Contracting Officer in both a written laboratory 

report and an electronic format [HALO] [insert other data management system as applicable].

2.3.6.1 Laboratory Report

The Contractor shall require the laboratory to provide the information necessary for the Contractor to 

comply with the data evaluation/validation procedures outlined in this SOW. This shall be included in a 

data package containing the following information:

• Cover page information including 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.

• 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 RISK ASSESSMENT REPORT

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

NOTE: 40 CFR 745.227(h) requires that 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 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] assessment

• Address of [each] building

• Unit number
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• Date of construction of [each] building

• Name, address and telephone number of each installation point of contact (POC) for 

buildings assessed

• Name, signature, and certification number of each risk assessor conducting the assessment

• Name, address, and telephone number of the Contract firm employing the certified risk 

assessor(s)

• Name, address and telephone number of each laboratory used to [prepare and] analyze 

samples collected during the assessment

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

Documentation.

• Laboratory Report

• Pre-existing data used in decision process

• A description of the location, type, and condition of identified lead-based paint hazards and 

any other potential lead hazards. [The Contractor shall include a photograph of each

deteriorated paint sample location.]

• Correspondence, Conference and Field Notes, Forms, Other Documentation.

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 Contractor Data Certification

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

reviewed, valid, and met the DQOs (i.e., that the data were of sufficient quantity and quality to identify 

and characterize lead hazards at the units).

2.4.4 Electronic HALO/Installation Data Downloading into Installation System

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

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 the 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 

PentiumÒ 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:
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USACE Engineering Research and Development Center (CEERDC)

CEERD CF-M

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

Where the installation has no unique data management system for LBP data, 

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

SOW should detail the procedure for the Contractor to follow in providing the 

results of the lead hazard risk assessment to the Contracting Officer for 

uploading into HALO or other system used 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 required default values. The dictionary is part of the HALO program 

and can be obtained through the installation, or by contacting USACE CEERDCF-M. If the transferee is known, consult with 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].

2.4.5 Update Installation Management Plan

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

NOTE: If the installation does not use HALO for lead hazard program data 

management, you may choose to include the requirement in the SOW that the 

Contractor update the installation lead hazard management program 

documentation to incorporate the new data. Consult with the customer 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 HALO program to 

generate an updated installation lead hazard management plan.]

[The Contractor shall update the installation lead hazard management plan.]

2.4.6 Comparison of Contractor Findings to Installation HALO Findings

[The Contractor shall include a comparison of the risk assessor findings and recommendations with 

those generated by HALO.]
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2.4.7 Contractor Conclusions and Recommendations 

The report shall contain conclusions and lead hazard control recommendations. The Contractor shall 

use Table B-2 (Appendix B) in developing conclusions and control recommendations. [Where the 

assessor’s findings and recommendations differ from those generated by HALO, the report shall

provide the rationale for the assessor’s findings and recommendations.]

2.4.8 Other Field and Laboratory Data

The report shall include copies of field data, including building and paint evaluation forms, sample 

collection forms, chain of custody forms, and other forms and notes used to record field data that were 

used but not already addressed in drafting this report.

2.4.9 Summary of Lead Hazard Risk Assessment Results

The Contractor shall prepare a summary form for each housing unit assessed. An example Form 6 is 

included (see Figure B-6, Appendix B). The summary forms to be submitted by the Contractor as a 

part of the Risk Assessment Report shall include as a minimum the information contained on Form 6 in 

Figure B-6, Appendix B.

2.4.10 Regulatory Statements of Compliance

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

NOTE: This requirement addresses recommendations where no hazards 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 assessment and 

accepted practices.

3.0 SUPPLEMENTAL REQUIREMENTS FOR CONTRACTED SERVICES

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 hazard 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 Risk Assessor/Project Manager Qualifications

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

NOTE: Some states or local jurisdictions may use different terminology for 

individuals certified to complete the services described in this SOW, i.e., the 
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31 Aug 01

A-32

certificate may include a title other than “risk assessor.”

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

The Contractor shall employ a certified risk assessor to complete the assessment 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 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 Evidence of Certification

A copy of each current applicable certificate shall be included in the Project Work Plan for each 

Contractor risk assessor participating in this project.

3.1.2.4 Record of Experience

A resume or other description of the certified risk assessor’s experience, which is directly applicable to 

the activities required under this SOW shall be included in the Project Work Plan.

3.1.2.5 Use of Risk Assessment Teams

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

NOTE: Indicate the number and size of assessment teams for large, complex 

projects 

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

The Contractor shall specify in the Project Work Plan the number of risk assessors and risk assessment 

teams are to be used to perform the risk assessment addressed in this SOW. No more than [insert 

appropriate number] risk assessors per team shall be assigned to conduct the risk assessments. Team 

leaders shall have a minimum of three years experience in conducting lead hazard risk assessments.

3.1.2.6 Project Manager Experience

The project manager shall have a minimum of three years experience in managing lead hazard 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
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A-33

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 currant 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 risk assessment for at least [insert appropriate 

number of years] years following completion of the assessment(s) outlined under this SOW. Records 

shall include:

3.2.1.1 Project Work Plan

3.2.1.2 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, 
EP 1110-1-28

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A-34

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, and transportation while on the 

installation, etc. delineating who is responsible.

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

3.4.1 Government Quality Assurance Oversight and Support

[insert appropriate provisions]

The Contracting Officer reserves the right to quality assure the Risk Assessment Sample and Sample 

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

3.4.2 Rights of Entry, 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 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.

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 
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A-35

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.

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

[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 both the Contractor project or task manager and the certified risk 

assessor if these are different individuals.

3.5.1 Preliminary Project Site Visit/Walkover

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

NOTE: Where the Contractor’s project manager is not the same individual as 

the risk assessor, both the risk assessor and the project manager must be 

required to participate in the site visit. If the Contractor is to use a number of 

risk assessment teams, the 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 and] 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
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A-36

The Contractor shall attend a start-up meeting to review, finalize and approve the Project Work Plan to 

include the 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 risk assessment data certification 

outcomes.]

3.5.4 Final Risk Assessment Report Meeting

The Contractor shall attend a meeting to review the final Risk Assessment Report prior to final

submittal.

3.5.5 Additional Meetings

[insert additional meetings if required]

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 meeting

3) Project start-up meeting, if not combined with item 2

4) Data certification meeting, if not combined with item 5

5) Final Risk Assessment Report submission meeting

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

[Insert appropriate schedule milestones]
EP 1110-1-28

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A-37

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 compliance, etc. as appropriate.].]

3.7.3 Final Risk Assessment Data Submission in Electronic Format

The Contractor shall submit risk assessment data in electronic [HALO] [specify other] format.

3.7.4 Final Risk Assessment Report

The Contractor shall provide [insert appropriate number of copies] of the Risk Assessment Report in 

[three ring binders] [specify other]. A compact disc (CD) of the report shall be included with each 

copy of the submittal.

3.8 MISCELLANEOUS

3.8.1 Glossary

This paragraph contains acronyms, and terms 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 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 risk assessments. A risk assessor also samples for the presence of lead 

in dust and soil for the purposes of abatement clearance testing. (40 CFR

745.223)

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)
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A-38

Component, 

component system, 

building component

Specific design or structural elements of fixtures of a building or child-occupied 

facility that are distinguished from each other by form, function, and location. 

These include, but are not limited to, interior components...(40 CFR 745.223)

Contracting Officer The Contracting Officer, or his/her designated Contracting Officer

Representative (COR) or Contracting Officer Technical Representative

(COTR)

Contractor A private firm, corporation, or individuals operating under contract to provide 

service to the government as client or purchaser of the service. The contractor 

must possess all valid licenses and certifications as required by applicable

regulations and the Contracting Officer. The term “contractor” in this SOW 

also implies the firm or individuals that hire and control the qualified risk

assessors and support staff who perform the risk assessment.

Deteriorated paint Any interior or exterior paint or other coating that is peeling, chipping, chalking 

or cracking, or any paint or coating located on an interior or exterior surface or 

fixture that is otherwise damaged or separated from the substrate (40 CFR 

745.63)

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.

Elevated blood lead

level (EBL)

An excessive absorption of lead that is a confirmed concentration of lead in 

whole blood of 20 μg/dl (micrograms of lead per deciliter of whole blood) for a 

single venous test or of 15-19 μg/dl in two consecutive tests taken 3 to 4 

months apart. (40 CFR 745.223)

Family Child Care

(FCC) home

Authorized family housing units, other than the child’s home, in which a family 

member provides child care to one or more unrelated children on a regular 

basis. (AR 608-10)

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.

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

Hazardous lead-based paint, dust-lead hazard, or soil-lead hazard as identified 

in Table A-1 and 40 CFR 745.65. 
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A-39

μg/ft2 Micrograms per square foot

μg/g Micrograms per gram (parts per million on mass/mass basis)

MS/MSD Matrix spike/matrix spike duplicate

Occupant use

patterns

Characteristics of occupants including number of child-bearing 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))

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 an 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)

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)
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A-40

Testing Combination A unique combination of room equivalent, building component type, and

substrate. (1995 HUD guidelines, Chapter 7)
EP 1110-1-28

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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 Building/Housing Unit Condition Form

Figure B-2 Paint Condition on Selected Surfaces Data Form

Figure B-3 Deteriorated Paint Chip Sampling Form

Figure B-4 Risk Assessment Dust Wipe Sampling Form

Figure B-5 Risk Assessment Soil Sampling Form

Figure B-6 Summary of Lead-Hazard Risk Assessment Results

Figure B-7 Example Chain-of-Custody Form for Lead Risk Assessment Sampling
EP 1110-1-28

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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 1110-1-28

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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 1110-1-28

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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.
EP 1110-1-28

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B-5

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 1110-1-28

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B-6

Table B-2*

Main Hazard Control Options That Could Be Identified in Risk Assessments

Treatment 

Option

Dust1 on 

Floor

Dust1 on 

windows

Paint 2 on 

Doors

Paint 2 on 

Windows

Paint 2 on 

Floors and 

Walls

Paint 2

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 1110-1-28

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B-7

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
EP 1110-1-28

31 Aug 01

B-8

ACCEPTANCE LIMITS DATA ATTRIBUTE

Frequency

SINGLE WIPE COMPOSITE WIPE PAINT CHIP SOIL

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 1110-1-28

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B-9

EP 1110-1-28 FORM 1

31 AUG 01 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
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B-10

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

Risk Assessor Signature and Certification Number Date

Figure B-1: Building/Housing Unit Condition Form
FORM 2 EP 1110-1-28

PAINT CONDITION ON SELECTED SURFACES DATA 31 Aug 01

B-11

Installation POC 

Housing Group 

Street Address Unit No. City State 

Name of risk assessor 

Building 

Component

Location 

Notes

Paint condition: 

type of 

deterioration.

Deterioratio

n due to 

friction or 

impact?

Deteriorati

on 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
FORM 2 EP 1110-1-28

PAINT CONDITION ON SELECTED SURFACES DATA 31 Aug 01

B-12

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. If the overall condition of a component is similar 

throughout a dwelling, that condition should be recorded. The specific sites of the deteriorated paint 

should be noted. Record-specific locations of any component with bite marks.

(Table adapted from 1995 HUD Guidelines, Form 5.2)

Figure B-2: Paint Condition on Selected Surfaces Data Form
EP 1110-1-28 FORM 3

31 Aug 01 DETERIORATED PAINT CHIP SAMPLING FORM

(One form for each housing unit, common area, or exterior)

B-13

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: 
EP 1110-1-28 FORM 3

31 Aug 01 DETERIORATED PAINT CHIP SAMPLING FORM

(One form for each housing unit, common area, or exterior)

B-14

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-3: Deteriorated Paint Chip Sampling Form
FORM 4 EP 1110-1-28

RISK ASSESSMENT DUST WIPE SAMPLING FORM 31 Aug 01

(Single Surface Sampling)

B-15

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 

Substrat

e

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: 
FORM 4 EP 1110-1-28

RISK ASSESSMENT DUST WIPE SAMPLING FORM 31 Aug 01

(Single Surface Sampling)

B-16

(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-4: Risk Assessment Dust Wipe Sampling Form
EP 1110-1-28 FORM 5

31 Aug 01 RISK ASSESSMENT SOIL SAMPLING

(Composite Sampling Only)

Page _____ of _____ B-17

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: 
EP 1110-1-28 FORM 5

31 Aug 01 RISK ASSESSMENT SOIL SAMPLING

(Composite Sampling Only)

Page _____ of _____ B-18

(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-5: Risk Assessment Soil Sampling Form
B-19

Page _____ of _____

FORM 6 EP 1110-1-28

SUMMARY OF 31 Aug 01

LEAD-HAZARD RISK ASSESSMENT RESULTS

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 

Identifie

r

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
B-20

Page _____ of _____

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 in non-play areas.

 (5) Basis for Determination of Hazard: Dust exceeds Table A-1 action level for surface evaluated or as otherwise defined, paint chip 

exceeds Table A-1 definition for LBP and is deteriorated or as otherwise defined, and soil exceeds Table A-1 action levels based on child 

access and use.

Figure B-6: Summary Form, Lead-Hazard Risk Assessment Results
B-21

EP 1110-1-28 FORM 7

31 AUG 01 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

PhoneASTM 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
B-22

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-7: Example Chain of Custody Form for Lead Risk Assessment Sampling