Risk Assessor Resources
Risk Assessor Resource Page
This page is intended to provide risk assessors with the technical guidance, forms, templates, and program updates necessary to prepare complete and accurate risk assessment reports. Whether you are new to the Lead Safe Certification Program or have years of experience, this page should serve as your primary reference for City expectations.
Our goal is to promote consistency, reduce report revisions, and ensure every Lead Safe Certificate represents a home that can be trusted by residents, property owners, and our community.
Program Updates & Guidance
This section serves as a living library of program updates, technical guidance, and clarified expectations for conducting lead risk assessments and preparing reports for the City of Cleveland. Check back regularly for new guidance, updates, and resources.
Effective Date: Applies to paint chip samples collected on or after November 1, 2026.
The City of Cleveland is clarifying its expectations for paint chip sampling as part of Lead Safe Certification Risk Assessments.
- Photographic documentation is required. Risk Assessors must provide photographs of each paint chip sample location. Photographs must clearly identify the sampled component and location and support that the sample was collected down to the substrate. The photographs, field documentation, and laboratory results must be clearly correlated.
- Substantial substrate in a sample. If the laboratory identifies a substantial amount of substrate in a paint chip sample, the City will presume the paint contains lead-based paint unless additional testing establishes otherwise.
Risk Assessors are responsible for ensuring that paint chip samples are collected appropriately and that submitted documentation supports the laboratory results and conclusions in the Risk Assessment.
For additional guidance on sample collection, refer to HUD Appendix 13.2, Paint Chip Sampling.
To improve consistency, completeness, and regulatory compliance in risk assessment reports submitted to the City of Cleveland Lead Safe Certification Program, the following reporting requirements and expectations will be implemented effective July 10, 2026.
All risk assessment reports submitted on or after this date shall comply with the requirements outlined in this memorandum. Reports that do not meet these requirements may be returned for correction prior to acceptance.
Dust Sampling Clarification Requirements To ensure consistency among reports OAC Rule 3701-32-07(G)(5) and (6) require dust sampling within residential units and applicable common areas:
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Floor Plan Requirements Floor plans shall be legible and shall:
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Exterior Photograph Requirements Reports shall include:
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Interior Photograph Requirements Reports shall include either:
Additional photographs of specific components may be used as necessary to document observed conditions. Photographs shall be labeled by room or location, and photographs of all identified deteriorated lead-based paint hazards shall be included. |
Exclusion Requirements To establish consistency among reviewers and submitted reports, exclusions shall be limited to the following categories:
Reports shall clearly identify the exclusion category used for each excluded component and provide supporting photographs. |
Additional Documentation Requests The Program reserves the right to request additional information, photographs, documentation, or clarification regarding any component, exclusion, observation, or determination contained within a submitted report. Additional documentation may be requested when the information provided is insufficient to support the assessor's conclusions or when staff are unable to confidently verify the basis for a reported finding or exclusion. Examples may include, but are not limited to:
Submission of a report does not preclude the Program from requesting additional supporting information as part of the review process. |
Control Recommendations Reports shall include acceptable abatement and interim control recommendations for all documented hazards and potential hazards. For purposes of this program, a potential hazard is defined as an intact friction, impact, or chewable surface that is presumed or known to contain lead-based paint. Risk assessors shall:
The inclusion of recommendations for potential hazards is intended to promote long-term compliance and reduce the likelihood of future lead exposure. |
XRF Raw Data Documentation To improve consistency and transparency in risk assessment reports, all reports shall include XRF raw data as an appendix. For purposes of this program, raw data shall mean the original testing data generated by the XRF instrument and exported directly from the manufacturer’s software. Acceptable formats include manufacturer-generated spreadsheets, sequential reports, or similar electronic exports containing individual test readings and associated testing information. Reports shall:
The purpose of this requirement is to provide complete documentation of XRF testing results, support report review, and maintain consistency among submitted reports. |
Report Organization and Order To promote consistency and improve review efficiency, reports should follow the organization and section order in the current City of Cleveland Risk Assessment Report Template. Minor deviations are acceptable; however, required information shall be presented in a logical and organized manner. Reports may be returned for correction if report organization makes required information difficult to locate or review. |
Professional Standards The following practices are prohibited:
Risk assessors shall not perform or direct any cleaning prior to dust sampling. Property owners, tenants, property managers, or other associated parties may clean before testing; however, a minimum of one (1) hour shall elapse between cleaning and the start of the risk assessment
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The role of the risk assessor is to identify and evaluate hazards, not to sell certifications. Accurate reporting protects families, property owners, and the integrity of the Lead Safe Certification. Rev. June 24, 2026 |
The purpose of this guidance document is to establish clear, consistent standards for how assessors must evaluate and document these components. By understanding industry timelines, architectural histories (including Cleveland's historic district mandates), and specific visual indicators, assessors can ensure their report narratives are defensible, compliant, and structured to pass regulatory staff review without delays or flags. This is only the quick reference guide, please contact the Lead Safe Compliance Team via email leadcertcle@clevelandohio.gov or call 216.664.2274 to obtain a full copy of this guide.
| Compenent | Pre-1989 Indicators (Assess for Lead) | Post-1978 Indicators (Excludable as New) |
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| Windows | Wood sash, single-pane, aluminum frame, rope-pulley system, paint buildup | Vinyl/PVC frame, double-pane, tilt-in sash, glass block, no paint |
| Interior Doors | Solid wood, heavy weight, mortise hardware, wood grain, multi-layer paint with corner buildup | Hollow-core, lightweight, smooth MDF face, molded or routed profiles, modern cylindrical bore, factory powder coat or primer |
| Exterior Doors | Solid wood, mortise lockset, wood checking, multi-coat paint, no weatherstrip | Fiberglass or insulated steel, compression weatherstrip, modern hardware, energy label |
| Porch Floors | Tongue & groove, tight boards, no gaps, painted, Heart Pine/fir/cypress | Spaced deck boards (PT lumber), composite/Trex boards, or PVC — no paint |
| Porch Railings | Turned wood balusters OR heavy, straight square wood spindles (2x2", 3x3", 4x4") Thick multi-layer paint buildup showing signs of checking or alligatoring. Wider historic on-center spacing (gaps exceeding 4 inches) | PVC/vinyl, aluminum system or standard nominal 2x2” square square-edge pressure-treated wood, modern fasteners or deck screws. Tight safety spacing (gaps under 4 inches) |
| Garage Doors | Solid wood or heavy plywood construction | Sectional roll-up design, embossed steel or fiberglass faces, uniform factory finish, interior foam core, rubber bottom seals |
Per Cleveland’s Lead Safe Certification requirements and OAC Rule 3701-32, components may be excluded from testing only when clearly documented as one of the following:
- New (post-1978 installation)
- Uncoated (no paint or surface coating present)
- Enclosed (not accessible for contact)
- Inaccessible
Importance of Record Keeping:
Although this document provides exclusion options for “New” components it is worth noting that record keeping is the most reliable way to ensure safety, reduce financial and legal liabilities, and build trust. Best practices include:
- Purchase/installation receipts and permits
- Documented inspections and test results
- Using lead safe practices and documenting lead safe practices performed
This memo serves as a formal clarification regarding proper completion of Section C: Interior and Exterior Surfaces on the Ohio Department of Health (ODH) HEA 7729 – Lead Visual Assessment Form.
Recent report reviews have identified a recurring issue in which inspectors list generalized descriptions such as “All windows,” “All doors,” or “All chewable surfaces” instead of identifying individual components and their specific conditions.
While these entries indicate the intent to perform a thorough inspection, they do not meet the documentation standards required by the Ohio Administrative Code (OAC 3701-32-07) or the HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards (Chapter 5, Risk Assessment).
Regulatory Basis
1. Ohio Administrative Code 3701-32-07(G)(3) A lead risk assessor shall perform a visual assessment of the interior and exterior of the residential unit, child care facility, or school and identify, on forms prescribed by the director:
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2. Key Expectations for Visual Assessment: The purpose of the visual assessment is to: “Locate and document the specific location and approximate size of each instance of deteriorated paint, friction-surface hazards, impact-surface hazards, and chewable-surface hazards.” HUD emphasizes that this information must be detailed enough for the report to stand alone as a complete record — including component-by-component identification of locations, conditions, and tested surfaces. Risk Assessors must clearly document the specific location and condition of each component visually assessed and/or tested. This level of detail can be documented in on of two ways:
This includes identifying:
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3. Required Level of Detail Each visually assessed and/or tested surface must include:
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| Insufficient Entry Example: | Compliant Entry Example: |
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4. Friction, Impact, and Chewable Surfaces
Per HUD and EPA (40 CFR 745.63 and 745.65):
- Friction surfaces include windowsills, stair treads, painted floors, or shelves subject to abrasion.
- Impact surfaces include door frames, baseboards, and walls repeatedly struck by doors or objects.
- Chewable surfaces include windowsills, railings, and other surfaces showing bite marks or identified risk of mouthing by children under six.
Inspectors must evaluate and document these surfaces individually, noting whether the paint is intact or deteriorated and whether dust sampling was performed beneath these areas (as required to confirm or rule out a hazard).
5. Reference Resources
- HUD Guidelines, Chapter 5: Risk Assessment and Reevaluation
- Section II.D – Visual Assessment
- Section IV – Friction and Impact Surfaces
- Table 5.4 – Illustrative List of Painted Components
- Ohio Administrative Code 3701-32-07 and 3701-32-15
- ODH HEA 7729 Visual Assessment Form
Implementation Effective immediately, all new reports should begin reflecting this level of detail under Section C. We recognize this is an adjustment, and our team will work collaboratively with risk assessors over the next several weeks to ensure consistency. During this transition period, our focus will be on feedback and improvement but reports that do not move toward compliance may still receive additional information required notices. Visual Example Table: Proper Documentation of Section C (HEA 7729)
Disclaimer: The example provided solely for illustration and training purposes. Each property will have its own unique layout, construction type, and component conditions. Inspectors must adapt their documentation to accurately reflect the site-specific details observed during their inspection and ensure that the recorded information corresponds directly to the property being assessed. BEFORE (Incorrect): AFTER:
How to Complete a Risk Assessment
A lead risk assessor plays a critical role in protecting children and families from lead exposure. The purpose of a risk assessment is to identify and evaluate lead-based paint hazards and provide clear, accurate recommendations for hazard control. Accurate reporting protects families, property owners, and the integrity of the Lead Safe Certification Program.
Pursuant to Ohio Administrative Code, a lead risk assessor shall perform a visual assessment of the interior and exterior of the residential unit, child care facility, or school and identify, on forms prescribed by the Director:
- Overall building condition
- Areas of bare soil
- Interior and exterior surfaces with deteriorated paint
- Painted surfaces that are impact points or subject to friction
- Chewable surfaces
The guidance below is organized by report section and is intended to help risk assessors prepare complete, accurate, and internally consistent reports that meet City of Cleveland program expectations.
Property Characteristics The Property Characteristics section should provide a concise description of the dwelling and any features that affect the risk assessment. This section gives the reviewer an overview of the property before reviewing the visual assessment, floor plans, and sampling results. Describe the physical characteristics of the property and include any atypical features or conditions that may impact the assessment. Include the following, when applicable:
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Examples of unusual conditions Document any circumstances that would help explain the property layout or assessment, such as:
Template Example: The subject property is a [single-family/duplex/multi-family] residential dwelling constructed in approximately [year]. The building consists of [number] story(ies) with [number] bedroom(s) and [number] bathroom(s). The property includes [basement], [attic], and [attached/detached/no] garage. The dwelling was [occupied/vacant] at the time of the assessment. The exterior is primarily constructed of [materials] with [window type] windows. Entrances are located on Sides A, B, C, and/or D, with [porches/decks/stairs] as applicable. The surrounding area is primarily [residential/commercial/mixed-use]. Any unique building characteristics or discrepancies between observed conditions and available public records are documented below. |
Areas Not Accessible Areas that cannot be physically examined during the risk assessment must be clearly documented. Components should only be classified as Inaccessible when they genuinely cannot be evaluated at the time of the assessment. What qualifies as inaccessible? A component may be classified as inaccessible when it cannot be physically examined due to an obstruction or restricted access, including:
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Requirements for Locked Rooms A locked room may only be classified as inaccessible when all of the following conditions are met:
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Documentation For every inaccessible area, the report should include:
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When Additional Access Is Required If an area does not meet the criteria for being classified as inaccessible, the assessment is considered incomplete for that area. Additional access may be required before the report can be approved. Examples include:
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Building Maintenance & Renovations This section should summarize the maintenance history and renovations that are known, documented, or readily observable during the assessment. The information provided here should help explain the current condition of the property and support later determinations made in the visual assessment, exclusions, and potential hazards.
Document maintenance or renovation activities reported by the owner or property representative, as well as improvements that are clearly observable during the assessment.
Examples include:
- Replacement windows (e.g., vinyl windows throughout the property)
- Glass block basement windows
- New siding or exterior cladding
- New porches, decks, or stairs
- Replacement entry or interior doors
- Enclosed flooring (e.g., vinyl plank flooring, ceramic tile)
- Aluminum coil stock enclosing exterior window casings or trim
- Replacement railings, columns, or other exterior components
- Other newly installed building components
When documenting renovations, be as specific as possible. For example:
Side A and Side B entry doors are new fiberglass pre-hung door systems. Side C contains a new metal entry door with the original wood frame and threshold remaining.
Providing this level of detail helps explain why some components may later be excluded as New (Post-1978) while adjacent components remain subject to evaluation.
Include, when applicable:
- Maintenance history provided by the owner or property representative
- Renovations or remodeling activities
- Replacement windows and doors
- Newly installed building components
- Documentation supporting Post-1978 components
- Observable improvements that affect the assessment
- Any renovation that may affect presumed lead-based paint or the identification of lead hazards
Best Practice
The information in this section should be consistent with the remainder of the report. Renovations described here should align with the visual assessment, floor plans, exclusions, photographs, and any components identified as New (Post-1978).
The Executive Summary should provide a clear, concise conclusion of the risk assessment. It should summarize the assessment activities performed, identify the lead hazards that were found (or not found), and clearly state the overall findings.
This section should be supported by the remainder of the report. The conclusions presented here must be consistent with the visual assessment, photographs, XRF results, environmental sampling, laboratory results, floor plans, and all other report sections.
The Executive Summary should allow the reader to understand the outcome of the assessment without reviewing the entire report.
Include the following:
Assessment Activities Performed
Provide a brief summary of the activities completed during the assessment, as applicable:
- Completion of a questionnaire to identify potential sources of lead exposure
- Visual inspection of the interior and exterior painted surfaces
- If a visual-only assessment was performed (no XRF): State that the visual inspection was conducted under the presumption that all coated surfaces may contain lead-based paint
- Component-by-component evaluation of impact, friction, and chewable surfaces
- Use of a portable X-ray fluorescence (XRF) analyzer to determine the presence or absence of lead-based paint, when applicable
- Collection of environmental samples (dust wipe, soil, and/or paint-chip samples, as applicable)
- Preparation of the risk assessment report documenting the observations, testing, and findings.
Findings
Clearly state whether lead-based paint, lead-based paint hazards, or both were identified.
When XRF testing is performed:
- Differentiate between lead-based paint (intact coated surfaces confirmed to contain lead) and lead-based paint hazards (deteriorated lead-based paint, lead-contaminated dust, lead-contaminated soil, or other identified hazards).
When XRF testing is not performed:
- State that coated surfaces are presumed to contain lead-based paint and explain whether lead hazards were identified based on the visual assessment and environmental sampling.
Avoid ambiguous statements such as:
"Lead-based paint and lead-based paint hazards were present." Instead, clearly identify:
- Where hazards were identified
- Whether hazards require interim controls or abatement
- Whether no hazards were identified despite the presence of intact lead-based paint
Best Practice
The Executive Summary should be the final section completed after the remainder of the report has been reviewed for internal consistency. Before finalizing the report, verify that the conclusions accurately reflect:
- Visual assessment findings
- Photographs
- XRF and laboratory results
- Environmental sampling
- Potential hazards
- Exclusions
- Recommended interim controls or abatement activities
Any conflicting statements between the Executive Summary and the remainder of the report may result in a request for revisions.
The visual assessment is the foundation of the risk assessment report and the most detailed portion of the evaluation. Because the City of Cleveland permits the presumption of lead-based paint, the visual assessment must accurately identify and document all actual hazards, potential hazards, and excluded components. When XRF testing is not performed, the visual assessment becomes the primary method for identifying painted surfaces that may present a lead hazard.
Presumption vs. XRF Testing The City permits risk assessments to be completed without the use of a portable X-ray fluorescence (XRF) analyzer. In these cases, coated surfaces are presumed to contain lead-based paint unless they can be excluded for another reason (e.g., new, uncoated, enclosed, or inaccessible). While an XRF analyzer is not required, it offers several advantages:
This guidance focuses primarily on conducting a visual assessment without the use of an XRF analyzer. |
Purpose of the Visual Assessment The purpose of the visual assessment is to identify and document the specific location and approximate size of each instance of:
HUD emphasizes that the report should contain sufficient detail to stand alone as a complete record of the assessment. Documentation should identify each component, its location, its condition, and, when applicable, any testing performed. |
What Must Be Documented Not every painted or coated component is required to be documented as a potential hazard. Documentation should focus on components that present a lead hazard or have the potential to become one. Components should be documented in one of the following categories: Actual Hazards
Deteriorated paint should be documented regardless of whether the component is an impact, friction, or chewable (IFC) surface. Potential Hazards
For example:
Excluded Components
Documentation throughout the report should be internally consistent and should not contradict the photographs, floor plans, exclusions, executive summary, or other report sections. |
Areas to be Evaluated The visual assessment should include all accessible areas of the property, including:
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Documenting Findings Visual findings should be documented on the Ohio Department of Health HEA 7729 Lead Visual Assessment Form or an equivalent worksheet that provides the same level of detail. Documentation should identify:
Each component should be individually identified rather than grouped together whenever practical. |
Using HEA 7729 When using the HEA 7729:
If using an equivalent reporting format, clearly distinguish between:
Reporting Requirement: The HEA 7729 Lead Visual Assessment Form is required as part of every submitted risk assessment report. If you use your own visual assessment worksheet or reporting format, you must still include the HEA 7729 in the report. Complete the form by listing all room equivalents and inspected areas, and include a note directing the reviewer to your detailed component-by-component visual assessment. |
Best Practices
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Commonly Missed Components Include a checklist of components that are frequently omitted from reports, such as:
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Floor Plans The floor plan serves as the roadmap for the entire risk assessment. It should allow a reviewer to understand the layout of the dwelling, verify where dust samples were collected, and confirm that the visual assessment accounts for every accessible area of the property. The floor plan should be consistent with all other portions of the report, including the visual assessment, photographs, dust sample locations, and narrative. Floor Plan Requirements Floor plans shall be clear, legible, and accurately represent the dwelling. At a minimum, they should:
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Consistency Matters A reviewer should be able to compare the floor plan with the visual assessment and photographs without finding discrepancies. Examples of inconsistencies include:
If an accessible room or building component is not shown on the floor plan, it cannot be verified during report review and may result in a request for additional information. |
COMMON FLOOR PLAN SYMBOLS
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Dust Sampling Dust sampling evaluates whether lead-contaminated dust hazards are present within the dwelling. Proper sample collection and documentation are essential for determining whether a property meets Ohio's lead hazard standards. To ensure consistency among reports, Ohio Administrative Code Rule 3701-32-07(G)(5) and (6) establishes minimum sampling requirements for residential units and applicable common areas. |
Dust Sampling Requirements Risk assessors shall:
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Common Areas When common areas are present, sampling should include applicable room equivalents such as:
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Documentation The report should clearly identify:
Sample locations should be documented consistently throughout the report. The floor plan, laboratory chain of custody, field forms, and narrative should all identify the same locations |
Best Practices
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Common Floor Plan Deficiencies
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Common Dust Sampling Deficiencies
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A portable X-ray fluorescence (XRF) analyzer can be used to determine whether a painted surface contains lead-based paint without disturbing the surface. XRF testing and the visual assessment should be performed together because the assessor must identify both the lead content of the coating and the condition and location of the component.
The City does not require an XRF analyzer to conduct a Lead Risk Assessment. When XRF testing is not performed, the City permits the presumption that applicable coated surfaces contain lead-based paint. However, XRF testing can provide greater certainty about which components contain lead-based paint and may help property owners avoid unnecessary lead-related repairs, replacement, or other controls on components that do not contain lead.
What surfaces require paint testing?
- All surfaces with deteriorated paint — interior and exterior.
- Intact paint on friction surfaces.
- Chewable surfaces showing evidence of teeth marks, when a child under six resides in or regularly visits the property.
- Intact paint expected to be disturbed by future rehabilitation, renovation, maintenance, or other work, when applicable.
- Previously tested surfaces may be used when the prior testing is determined to be reliable.
Important: The visual assessment identifies the components that require evaluation. XRF testing provides the additional information needed to determine whether the coating contains lead-based paint.
| Visual Condition | XRF Result | Surface Type | General Documentation |
| Deteriorated | Lead-based paint | Any | Actual lead-based paint hazard |
| Deteriorated | Not lead-based paint | Any | Not a lead-based paint hazard based on XRF |
| Intact | Lead-based paint | Impact/Friction/Chewable (IFC) | Potential lead-based paint hazard |
| Intact | Lead-based paint | Not IFC | Potential lead-based paint hazard |
| Intact | Not lead-based paint | Any | Not a lead-based paint hazard based on XRF |
Remember: The condition of the component and the XRF result are separate pieces of information. An XRF result does not replace documentation of the component's condition or location.
XRF Testing Practices
XRF readings should be obtained under conditions where the instrument can produce a reliable measurement. HUD recommends that the tested area be large enough to completely cover the instrument's active detector window and be flat or nearly flat.
XRF testing should generally be performed on intact paint. When deteriorated paint is present, an intact area of paint on the same component may be used when available.
If an XRF reading is obtained under conditions that do not meet the instrument's reliable testing conditions, a low reading should not automatically be interpreted as proof that the surface is free of lead-based paint. Additional testing, such as laboratory analysis of a paint-chip sample, may be necessary.
Documenting XRF Results
XRF results should be entered directly into the visual assessment field report or equivalent worksheet and should be clearly cross-referenced to the component tested.
The report should identify what was tested, where it was tested, the condition of the component, and the XRF result.
Example:
Unit 1 – Bedroom 1 – Door Panel – Side A – Intact – XRF: 0.0 mg/cm²
Raw/unfiltered XRF data should also be included with the report.
When Paint Chip Sampling is Used
Paint-chip sampling is a destructive method of determining whether a coating contains lead-based paint. It may be used when XRF testing is unavailable, impractical, or unable to provide a reliable determination.
Because paint-chip sampling disturbs the painted surface, HUD specifies that destructive paint testing should be conducted after dust sampling so that the sampling process does not disturb dust before it is collected.
What Should Be Tested?
Paint testing should be performed on applicable surfaces identified during the visual assessment, including:
- Deteriorated painted surfaces;
- Intact painted friction surfaces;
- Chewable surfaces with evidence of teeth marks when applicable; and
- Intact painted surfaces expected to be disturbed by rehabilitation, renovation, maintenance, or similar work.
For deteriorated paint, HUD recommends testing each similar building component within each room equivalent rather than assuming one tested component represents every similar component. For example, if all four walls of a room have deteriorated paint, each wall should be evaluated rather than testing only one wall.
Collecting Paint Chip Samples
Paint-chip samples should include all layers of paint within a measured sample area without removing the underlying substrate. Do not collect only the peeling or deteriorated layer.
The purpose is to obtain a sample representative of the complete paint system so that the laboratory result can be appropriately compared with an XRF measurement.
Following destructive paint sampling, minor cleanup of the immediate area should be performed using wet wipes.
City program expectation: If the laboratory identifies a substantial amount of substrate in a paint chip sample, the City will presume the paint contains lead-based paint unless additional testing establishes otherwise. Applies to paint chip samples collected on or after November 1, 2026.
Documentation
City program expectation: Photographs should clearly identify the sampled component and location and support that the paint was collected down to the substrate. Reviewers must be able to connect the photograph, field documentation, and laboratory result. Applies to paint chip samples collected on or after November 1, 2026.
Each paint-chip sample should have a unique sample number and be cross-referenced to the visual assessment.
For example:
Unit 1 – Bedroom 1 – Window Sash – Side A – Sample PC-04
The sample number should appear both on the paint-testing field form and in the corresponding location on the visual assessment so the reviewer can determine exactly which component was tested.
Purpose
Soil sampling is used to determine whether bare soil presents a potential lead-based paint hazard. The risk assessor should consider both the concentration of lead in the soil and how the area is used, including the frequency of contact and whether young children are likely to access the area.
HUD generally recommends sampling bare soil. If there is no bare soil, soil sampling is generally not necessary under the HUD guidance provided here.
Areas to Evaluate
Risk assessors should look for bare soil throughout the property, including:
- Play areas, including sandboxes;
- Dripline/foundation areas;
- Other non-play areas of the yard;
- Vegetable gardens; and
- Unusual areas such as beneath elevated porches.
Consider whether bare soil is accessible to children and whether the area has a pattern of use that could increase exposure.
Soil Sampling Method
HUD specifies that soil samples should be composite samples. Samples may be collected using a coring tool or scooping technique.
The top 5/8 inch (1.5 cm) of soil should generally be collected.
Each composite sample should generally consist of subsamples collected from 3–10 distinct locations. Subsamples should be approximately equal in bulk and, when possible, spaced approximately 2–6 feet apart.
For dripline/foundation and other non-play areas, subsamples should be distributed to represent the pattern of bare soil within the area being sampled.
Paint chips encountered in the soil should be included in the sample; however, the assessor should not intentionally oversample paint chips.
Number and Location of Samples
The number of soil samples depends on the type and size of the property, the number of residential buildings, the number of dwelling units, and the location and use of bare-soil areas.
Play areas, dripline/foundation areas, and other areas of the yard have different sampling considerations. For larger multi-building properties, HUD provides specific selection procedures for determining which buildings and areas should be sampled.
Documentation
Soil sample locations should be clearly identified on the site plan or equivalent drawing. Each sample should have a unique sample number and the report should identify:
- Sample number;
- Location;
- Type of area sampled;
- Approximate area of bare soil represented by the sample; and
- Corresponding location on the site plan.
This documentation should allow the reader to identify exactly where each soil sample was collected.
Interim controls mean a set of measures designed to temporarily reduce human exposure or likely human exposure to lead hazards. Interim controls include specialized cleaning, repairs, painting, temporary containment, ongoing lead hazard maintenance activities, and the establishment and operation of management and resident education programs.
Methods of Interim Controls for Lead-Based Paint (LBP) Hazards Hazard
| Hazard | Interim Control |
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| LBP - Deteriorated | Paint Film Stabilization (PFS) |
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| LBP - Friction Surface | Treat to Minimize Friction |
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| LBP - Impact Surface | Treat to Prevent Impact |
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| LBP-Chewed | Cover to Prevent Chewing |
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| Lead Contaminated Interior Dust | Environmental Cleaning / HUD Cycle |
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| Lead Contaminated Bare Soil | Cover or Restrict Access |
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Lead abatement means a measure or a set of measures, designed for the single purpose of permanently eliminating lead hazards. Lead abatement includes all the following:
- Removal of lead-based paint and lead-contaminated dust. This includes stripping or scraping paint from the surface and repainting
- Permanent enclosure or encapsulation of lead-based paint
- Examples of enclosure are installation of drywall over lead coated surfaces or wrapping and siding exterior lead painted surfaces
- Encapsulation if the application of an ODH approved liquid coating to seal lead coated surfaces
- Replacement of surfaces or fixtures painted with lead-based paint.
- Removal or permanent covering of lead-contaminated soil
- Preparation, cleanup, and disposal activities associated with lead abatement
| Lead Paint Abatement |
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1. Replace
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2. Remove (least recommended)
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3. Encapsulate
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4. Enclose
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| Contaminated Soil Abatement | ||
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| 1. Remove | 2. Pave | |
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Connecting the Findings
A Lead Risk Assessment is not simply a collection of laboratory results. The risk assessor must bring together the visual assessment, testing results, photographs, floor plans, sampling locations, and observed conditions to make a clear determination regarding lead hazards at the property.
Every test result should be traceable to the specific component or area that was evaluated.
Visual Condition + Testing Result = Determination
| Visual Finding | Testing | Result |
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| Deteriorated coated surface | XRF confirms lead | Actual lead-based paint hazard |
| Deteriorated coated surface | No XRF/paint testing | Presumed lead-based paint hazard |
| Intact coated IFC surface | XRF confirms lead | Potential lead-based paint hazard |
| Intact coated IFC surface | No XRF/paint testing | Presumed potential hazard |
| Intact non-IFC surface | XRF confirms lead | Potential lead-based paint hazard |
| Uncoated/new/enclosed/inaccessible | N/A | Excluded component, with reason documented |
| Bare soil | Laboratory analysis | Evaluate result and applicable soil hazard criteria |
Cross Referencing
The final report should tell a consistent story. A reviewer should be able to move from the visual assessment to the floor plan, photographs, XRF or paint-chip results, and final hazard determination without encountering conflicting information.
For example, if the visual assessment identifies a deteriorated bedroom window, the report should allow the reviewer to determine:
- Where the window is located;
- What component was evaluated;
- What its condition was;
- Whether it is an impact, friction, or chewable surface;
- Whether it was tested for lead;
- The corresponding XRF or paint-chip result, if applicable; and
- What interim control or abatement recommendation applies.
Compliance Team Meetings with Risk assessors
Forms & Templates
These are forms or templates you may need to include in a Risk Assessment Report
What it is:
A lead risk assessment report is a written check‑up of a home that shows:
- If there is lead‑based paint,
- If any lead hazards are present
- What steps are needed to fix the hazards and keep people safe.
It’s created by a licensed lead risk assessor, who inspects the home and tests paint, dust, and sometimes soil.
What a report usually includes:
- Basic property information: the address, type of home, year built, and who owns or lives in it.
- Summary of what the assessor found: a simple overview of where lead hazards were found or if the home passed.
- Paint testing results : which surfaces were tested (windows, doors, trim, walls) and whether the paint contains lead.
- Dust wipe results: lab results showing if dust on floors or window sills has unsafe lead levels.
- Soil test results: if soil was tested, the report shows whether the yard has unsafe lead levels.
- Photos of hazards: pictures of peeling paint, damaged areas, or other hazards.
- List of lead hazards: a clear list of each problem area, written in plain language (for example: “Peeling paint on window frame in bedroom”).
- Recommended fixes: what repairs or cleaning steps are needed to make the home safe, such as repainting, replacing windows, or deep cleaning.
- Timeline and next steps: what the owner must do, by when, and how to stay in compliance.
- Clearance requirements: explains that after repairs, the home must pass a clearance test to show it’s safe again.
Risk Assessment Report Template
Approved Software Applications
The following software applications have been identified as meeting the City’s template requirements for preparing Lead Safe Certification documentation.
EasyPb
PbPilot
Important Disclaimer: Approved software applications are tools to assist Risk Assessors in preparing reports. They do not perform the Risk Assessment or replace the professional judgment, knowledge, and responsibilities of the licensed Risk Assessor. The Risk Assessor is solely responsible for the accuracy and completeness of the information entered into the application, the content and accuracy of the reports it generates, and all documentation subsequently submitted to the City. Use of an approved application does not guarantee that a report will meet all applicable requirements or be accepted by the City.
You can request to be excused from Lead Safe Certification if your property:
Was Not Constructed before January 1, 1978.
Is Currently Vacant and you are not receiving any rent through government subsidies or assistance programs
You are living in the property (Owner Occupied) Please provide the unit number on the form.
What it is:
A checklist-style form that helps the assessor record the visible condition of the building—inside and out. It does not include lab results (like dust wipes or soil samples). Instead, it focuses on what can be seen, such as peeling paint, damaged surfaces, or bare soil that could create lead exposure risks.
What it usually includes:
- Basic property information — owner name, address, date, assessor name, and license number.
- Overall building condition — a checklist of major structural or maintenance issues: roof damage, broken gutters, cracked foundation, deteriorated walls, water stains, broken windows/doors, etc. These conditions often contribute to paint deterioration.
- Bare soil areas — notes on where bare soil exists (play areas, dripline, yard). Bare soil can contain lead from old exterior paint or past industrial sources. The form notes whether soil samples were collected.
- Interior & exterior painted surfaces — room‑by‑room or surface‑by‑surface documentation of paint condition: intact vs. deteriorated. It may also include XRF readings if paint was tested for lead.
- Possible causes of deterioration — friction surfaces (windows), impact surfaces (doors), chewable surfaces, moisture problems, substrate deterioration, or heat damage. These help identify why paint is failing.
- Notes and attachments — assessors can add comments or attach an XRF report or photos if needed.
What it is:
A set of questions the assessor asks the tenant or owner to understand:
- how people live in the home
- whether children are present
- what areas they use most
- whether there are known problems (peeling paint, leaks, dust)
- whether recent repairs or cleaning practices might affect lead dust levels.
It supplements the visual inspection and dust/paint testing by adding context about daily life inside the unit.
What it usually includes:
- Occupant information — names, ages, especially children under 6 (highest risk group).
- Unit use patterns — which rooms children spend time in, where they play, sleep, or crawl.
- Cleaning habits — frequency of sweeping, vacuuming, wet-mopping, or dusting.
- Maintenance history — recent repairs, painting, sanding, or remodeling that may have disturbed lead paint.
- Moisture or damage issues — leaks, peeling paint, friction surfaces (windows), or areas that get bumped or chewed.
- Exterior conditions — use of porches, yards, or bare soil areas where children play.
- Resident concerns — anything the occupant has noticed that might be unsafe.
It is part of the larger document HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (2012 Edition). Found in Chapter 5.
What it is:
HUD Form 5.6 is used when a lead risk assessor needs to gather occupant‑use information across multiple units in a building or housing complex. Instead of interviewing each household with a separate 5.0 form, the 5.6 allows the assessor to:
- document patterns across units
- identify shared conditions (moisture, maintenance issues, exterior hazards)
- note differences in how units are used
- and record any unit‑specific concerns.
It helps HUD ensure that multi‑unit properties are evaluated consistently and efficiently.
What it usually includes:
- Property and unit list — building address, owner/manager info, and identification of each unit included in the assessment.
- Occupant information per unit — number of residents, ages of children, and any high‑risk occupants.
- Unit use patterns — how rooms are used, where children spend time, and any special circumstances (e.g., daycare activity).
- Cleaning and housekeeping practices — frequency of cleaning, vacuuming, wet‑mopping, or dusting.
- Maintenance history per unit — recent repairs, painting, sanding, or remodeling that may have disturbed lead paint.
- Moisture or damage issues — leaks, peeling paint, friction surfaces, or structural problems.
- Exterior and shared‑area conditions — porches, stairwells, yards, bare soil, and common spaces.
- Resident concerns — anything occupants have noticed that may be unsafe.
It is part of the larger document HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (2012 Edition). Found in Chapter 5.
A lead clearance report is a formal document that confirms whether a property has been properly cleaned and made safe from lead dust after renovation, paint stabilization, or hazard control work. It documents the visual inspection and dust‑wipe testing results so owners, tenants, and buyers know whether any lead hazards remain.
Approved Software Applications
The following software applications have been identified as meeting the City’s template requirements for preparing Lead Safe Certification documentation.
EasyPb
PbPilot
Important Disclaimer: Approved software applications are tools to assist Risk Assessors in preparing reports. They do not perform the Risk Assessment or replace the professional judgment, knowledge, and responsibilities of the licensed Risk Assessor. The Risk Assessor is solely responsible for the accuracy and completeness of the information entered into the application, the content and accuracy of the reports it generates, and all documentation subsequently submitted to the City. Use of an approved application does not guarantee that a report will meet all applicable requirements or be accepted by the City.
What it is:
The official form that Cleveland property owners submit to the Lead Safe Cleveland Coalition (LSCC) to prove their rental unit meets the City’s lead‑safe requirements.
It’s the final step after completing a lead clearance examination. Once approved, the City issues a Lead Safe Certificate that is valid for two years.
What is usually includes:
- Property information — address, number of units, year built, ownership type, and contact information.
- Owner/agent details — who is legally responsible for the property and who manages day‑to‑day operations.
- Rental status — confirms the unit is non‑owner‑occupied and subject to Cleveland’s lead‑safe law.
- Clearance examination results — the core of the application. Includes:
- clearance report
- dust wipe lab results
- visual assessment documentation
- assessor license number
- Lead-safe repairs or work performed — optional section if repairs were needed before clearance.
- Affidavits and compliance statements — owner certifies the information is accurate and the property meets lead‑safe standards.
- Upload attachments — PDFs of clearance documents, photos, and any supplemental materials.
- Submission + payment — the application is free, but owners must submit everything through the LSCC portal.
