16 | August 2019
by Thomas G. Laubenthal
The Environmental Institute, Marietta, Georgia – A division
of Atlas-ATC Group Services, LLC.
T
here seems to be a bit of confusion for
those that service the lead-based paint
(LBP) control market on the ever evolving
requirements for how dust samples are
evaluated for risk assessments and those
used for clearance of a worksite following
lead hazard control (LHC) activities in pre-
1978 target housing and child-occupied facilities. In the
US Environmental Protection Agency (EPA) context, these
terms are defined at §745.223, Definitions1. The Depart-
ment of Housing and Urban Development (HUD) also uses
the term target housing and other related terms. These
terms are defined at §35.110, Definitions2.
This hub-bub began last year when HUD changed their
policy on risk assessment and clearance levels for two spe-
cific grants that they award. Unfortunately, there were too
few that service this market that bothered to actually read
the guidance provided by HUD in 20173 and assumed that
these newly defined dust levels applied to all of work funded
by HUD or other federally funded work. Some even went
so far to believe that these values applied also to LBP work
regulated by the EPA and EPA-designated states.
Recently, the EPA published in the Federal Register
their plans to lower dust risk assessment values starting in
Evaluation Of Lead-Based Paint Related Dust Samples;
Risk Assessments And Post Lead Hazard Control Clearance;
The Current HUD And Future EPA Requirements.
