Lead Free Certification

Protocol

To acquire a Lead-Free inspection certificate the property must be inspected with an XRF (X-Ray Fluorescence) device (like a radar gun) according to the Pennsylvania Department of the Environment protocol for Lead Free inspections. The guidance for this protocol is based upon the U.S. Department of Housing & Urban Development “Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (1997 Revision).  This requires that the Lead-Free testing is performed by a Lead-Based Paint Inspector/Risk Assessor (not a Dust Wipe Technician as is required for “Lead Safe” inspections) and is performed via the XRF device per the Performance Characteristic Sheet.  XRF devices can only be used by a technician with a valid license as the device contains radioactive material. Of course, the use of the device does not occur with anyone within a close distance other than the technician. Once the sample is taken, there are no excess materials that can harm any occupants. 

Advantages

• The advantage of “Lead Free” is that a percentage of the building (including both common areas and apartment units) can be tested and if it passes, can certify the remaining building as “Lead-Free”. Although this may be advantageous for some properties (that have been completely renovated from top to bottom), the XRF device and the testing methodology is quite comprehensive and obtaining results of less than 1.0mg/cm can be difficult to achieve (especially for older buildings). 

• This certificate is valid for the lifetime of the building. 

Disadvantages

• In Norristown, it is estimated that less than 5% of buildings (even those that were renovated) will be eligible for "Lead Free" certification.

• “Lead free” requires multiple tests per room (unlike “lead safe” per below) so the testing takes a few hours to perform and testing is performed on all painted surfaces).  “Lead safe” only requires 2 tests per bedroom (and 2 tests per common area) and takes just a few minutes to perform

• If you fail a “Lead Free” test, you will need to then have a lead safe test performed.  The cost of the “Lead-Free” test cannot be applied to the cost of the “lead safe” test

Calculation of % Testing Required (Apartment Buildings Only)

The “Lead Free” testing process includes testing exterior components (which is not included in “Lead Safe” testing).   Lastly, a building (and the relative % of testing required) is dependent upon two broad characteristics:  

• The date the building was built

• The number of similar units, similar common areas or exterior sites in a building or development. 

This data is input into the HUD table to determine the # of tests required to certify the property as “Lead Free”.  This % can range from as low as 5% or as high as 20% of the apartments in the building to be tested (again depending upon age and total # of apartments)

Sampling

“Lead Free” sample readings must be taken from each room in the property including common areas (hallways, stairwells, laundry rooms, etc.), not just the rental units/apartments but the entirety of the building. Any painted surface is sampled.  Sample readings throughout the exterior of the property must also be taken. This would include walls, windows, doors and all exterior trim. Sampling is performed based upon grouping of common components:

•  Apartment units-walls, floors, trim, baseboards, etc.

• Common areas-laundry rooms, lobbies, hallways etc.

Additionally, substrates (brick, stucco, siding, if painted, etc.) are tested using the same methodology.

Passing

The level of lead in paint in Pennsylvania & Norristown that is considered “Lead Free” is 1.0mg/cm or below. Once the property has been tested with an XRF device and found to have no elevated levels of lead paint inside and out, the property is then considered to be “Lead Free” and a certificate (for the life of the property) can be issued. This certificate can also be transferred with the sale of the property. 

Failing a “Lead Free” Test

A property is deemed to fail the “Lead Free” testing (which is quite complex and stringent) if lead-based paint is present with 99% confidence if 15% or more of the components are positive. 

If the property fails “Lead Free”, then a “Lead Safe” test is to be performed.