22 | August 2019
ysis and reporting issues, contact your NLLAP-accredited
laboratory. The laboratory manager should be able to ex-
plain these issues to you and what their capabilities are for
floor dust wipes at the 10 μg/ft² level.
Acknowledgements
The author would like to thank:
Howard Varner, Laboratory Director and General Manager
at Environmental Hazards Services LLC in Richmond, Vir-
ginia for his contributions to content and technical review
and comments.
Michael Breu, CIH, Technical Manager at Fiberquant An-
alytical Services, Phoenix, Arizona for his technical review
and comments.
References:
1. 40 CFR Part 745, Lead-based Paint Poisoning Preven-
tion In Certain Residential Structures, these EPA regula-
tions can be found at: https://tinyurl.com/y62z67c6
2. 24 CFR Part 35, Lead Safe Housing Rule (LSHR),
these HUD regulations can be found at; https://
www.hud.gov/program_offices/healthy_homes/
enforcement/lshr
3. HUD Policy Guidance Number 2017-01 Rev 1, Re-
vised Dust-Lead Action Levels for Risk Assessment
and Clearance; Clearance of Porch Floors. The doc-
ument can be found here: https://www.hud.gov/sites/
documents/LEADDUSTLEVELS_REV1.PDF
4. Federal Register, Vol. 84, No. 131, Tuesday, July 9,
2019 "Review of the Dust-Lead Hazard Standards
and the Definition of Lead-Based Paint" Environmen-
tal Protection Agency (EPA), Final rule. This notice
can be found at: https://www.govinfo.gov/content/pkg/
FR-2019-07-09/pdf/2019-14024.pdf
5. Guidelines for the Evaluation and Control of Lead-
Based Paint Hazards in Housing, July 2012, Chapter
15, Page 15-21 "Composite Sampling" The document
commonly known as the "HUD Guidelines" can be
found here: https://tinyurl.com/y646goyw
6. National Institute for Occupational Safety & Health
(NIOSH) Manual of Analytical Methods (NMAM); LEAD
by Flame AAS, Method 7082. The method can be found
here: https://www.cdc.gov/niosh/docs/2014-151/pdfs/
methods/7082.pdf
7. NLLAP link: http://www.epa.gov/lead/national-lead-
laboratory-accreditation-program-nllap
8. International Organization for Standardization https://
www.iso.org/home.html
9. EPA National Lead Laboratory Accreditation Program,
Laboratory Quality System Requirements (LQSR)
porting limitations to the very common flame AA analysis
technique. All should know this to assure client sampling
and analysis meets method and accreditation program re-
quirements, protecting your client from potential liabilities
should the work be performed incorrectly.
Breu CIH Laboratory, LLC
123 Cowboy Lane, Dusty AZ, 85003
Phone: 867-5309
NLLAP Accreditation # 54321
July 25, 2019
RE: New HUD Guidelines for Lead Dust Wipes
Based on policy set forth by The Office of Lead Haz-
ard Control and Healthy Homes, Breu CIH Laborato-
ry, LLC has implemented the following steps to ensure
lead analysis results are in full compliance on or be-
fore April 1st, 2017.
Validate Method Detection Limit (MDL) not to exceed
2.5 μg for lead analysis by flame AA. Adjust Reporting
Limit (RL) to 5μg for lead analysis by flame AA.
Certified Inspectors and Risk Assessors who utilize
the services of Breu CIH Laboratory may continue
conducting floor dust wipe samples using the stan-
dard minimum of 1ft².
New Grant-based HUD Lead Clearance Action Levels:
Interior Floors: < 10 μg/ft²
Porch Floors: <40 μg/ft²
Window Sills: <100 μg/ft²
Window Troughs: <100 μg/ft²
Sincerely,
Elijah M. Breu, CIH
Laboratory Director
Three options for floor dust samples at the 10
µg/ft² level;
1. Get a letter from your NLLAP-accredited laboratory
to be able to use 1 ft
2
for floor sampling (as described
above),
2. Take 2 ft² floor wipe samples, or
3. Have the laboratory perform analysis via Inductively
Coupled Argon Plasma, Atomic Emission Spectroscopy
(ICP-AES), or commonly referred to as ICP. With ICP
the 10 μg/ft² level on floors does not present the set of
problems found with flame AA.
If you have any further questions regarding sample anal-
