“I just found out my kiddo was Lead poisoned and an inspector from the Health Department is coming out on Monday, what might I expect?”
The extent of your home inspection (if done by a public agency) really will depend on two things:
- The budget of your health department (which impacts the resources and tools they have available to them to test your home) and
- The training of the inspector who comes to your home (how recently they were trained, what kind of training and certification they have, etc.)
The following is quite detailed, but the details are very important – so please do read it carefully and post in the comments below if you have questions.
Types of Testing
Your health department inspector will utilize one or more of several inspections methods:
#1 Visual Inspection:
The inspector will take a look around & using their experience to determine if they see peeling chipping paint that may potentially be hazardous or other obvious visual hazards in your child’s environment.
#2 Dust Wipe Sampling:
They first set up a square on the floor with tape – taping of one square foot exactly, and wiping it precisely and thoroughly with a ghost wipe (a thing that looks like a small baby wipe.) They will hopefully take at least 3 or 4 wipe samples at different spots and, depending on the specifics of your site, a good inspector may take as many as ten or more. They will then send these wipes to a lab to have them “digested” in a furnace to tell you how much lead is in the dust on your floor (at the location of each sample) – expressed as micrograms per square foot (ug/sf).
The federal standard – the level at which HUD considers dust on the floor officially unsafe for children – is 40 ug/sf; the National Center For Healthy Housing has recommended that the hazard level be lowered to 10 ug/sf – as 40 has been shown not protective of the health and well being of children. 10 ug/sf is also the low threshold of some testing labs – they won’t always be able to give you low levels below ten, but will instead tell you that your result is “less than 10” and that they consider this “negative”.
Note: the top experts on this subject (who are also interviewed in my film) had originally made the recommendation to HUD – when the levels were set – that the hazard level should be that any reading of 5 ug/sf or higher should be considered toxic to children.
HUD chose instead to set the level at eight times that level.
The bar was set so low (the action level set so high) because HUD administrators at the time did not think they could afford (using public funding) to remediate hazards in the exponentially larger number of homes that would require action if the recommended stricter standard (lower maximum level for contamination before triggering publicly-funded agency intervention) were adopted — NOT because the levels adopted are levels that are safest for children.
- KNOW what your numbers are (How many micrograms per square foot? What is the low threshold of the lab they used?)
- MAKE informed decisions about how to clean up the hazards and whether or not to stay in the home based on the scientifically supported lower hazard numbers (5 or 10 micrograms per square foot), not the higher numbers set by HUD.
#3 XRF Testing:
The inspector will test the paint on surfaces in your home with a scientific instrument that resembles a space-age ray gun—this is called an X-Ray Fluoresence Spectrometer (“XRF”).
One of the biggest flaws in the politics of this issue is the “acceptable levels” and “hazard levels” set for XRF testing. XRF is a terrific instrument for measuring hazardous levels of lead accurately but the federally set HUD standards for the allowable amount of lead in paint during a federally funded inspection (county, city, state or otherwise) leave children at risk of being poisoned.
Now stay with me here…
Depending on the instrument, an XRF may be commonly calibrated to read in one of two measurement systems: parts per million (ppm) -OR- milligrams per square centimeter (mg/cm2). The Feds consider paint “lead paint” (and potentially toxic for children and therefore eligible for federally funded interventions) at 1.0 mg/cm2.
Most XRF instruments are of a radioactive source type design, and these will give you readings for your painted surface with a LOW of 1.0 and a HIGH of 9.9 mg/cm2. 9.9 is not the highest number attainable – it is just commonly the high limit of detection for these instruments.
On the other hand, 1.0 is rarely the low limit of detection of these instruments; you can get readings of 0.1 through 0.9 and everything in-between.
Unfortunately, your county hazard assessor (depending on their training) will likely tell you that under a 1.0 is “negative” for lead and “safe” for your children. This is absolutely not true; the only thing a reading under 1.0 (milligram per cm2) actually signifies here is that your home is not eligible for federally subsidized interventions.
Unfortunately – in my experience – many inspectors for public agencies do not seem understand the distinction here.
Based on testing I have done, a radioactive-source XRF reading of 1.0 can correspond (approximately) to XRF readings with a different type of XRF instrument that are as high as 5000 ppm lead, and therefore, a 0.9 reading on that type of instrument could be “less than 1” (considered “negative” by HUD) — yet as high as 4,500 ppm lead!
For context it is important to understand the federal law outlawing lead paint (in 1978!) required that paint be “less than 600 ppm lead” to be safe, [and that regulation was recently changed – so paint is now required to be “under 90 ppm lead”.] For children’s toys, surface coatings must also be under 90 ppm lead to be considered safe for children.
So with this context you can see that even a reading as low as a 0.2 (mg/cm2) is possibly as high as 1000 ppm lead — and while HUD might consider that “negative” (because they don’t want to fund the remediation at that level) that level (or higher) in your house paint could certainly indicate an exposure source for your child.
Most county/city/state employed hazard inspectors I have come across do not seem to be aware of this distinction — in part because their training only focuses on federal standards, based on interventions HUD will fund for low income families NOT based on levels that will actually protect children.
Very important to note: The type of XRF instrument used for home inspections is definitely not appropriate for testing consumer goods for some of the same reasons stated above. Read more about this in #6 below.
#4 Soil Sampling:
The inspector take spoonfuls of your soil and send them to a lab.
Results should be given in parts per million (ppm).
You want to see the numbers, and you should know where each of the samples was taken from (they should include their sampling map).
It is advisable for you to be there during this and the other samplings (make sure you find care off-site for your kiddo), so you can show them where your children play and ask they take samples from those areas. They should not necessarily merely follow a routine or “standard protocol” in choosing testing locations—as standard protocol does not dictate where your children play! As an example of this, when my children were poisoned, the inspectors did not want to sample the soil at the drip-line of the house; I insisted that they test there, because my boys would ALWAYS play in the dripline with their toy cars and dumptrucks – so I wanted them to designate that as a “children’s play area”, even though that was not necessarily their standard protocol. [They do have some discretion in where they test, based on your input.]
Federal standards by which soil in children’s play areas is considered toxic (again not based on science, but based on what the feds calculated they can afford to remediate) is anything 400 ppm lead in the soil or higher. Preeminent soils scientist, Howard Mielke (who is also a featured scientist in our film, and has recently joined our Board of Directors) has officially recommended that the hazard level for soil for children’s play areas be lowered to 100 ppm or lower; The State of California considers soil safe for gardening at 80 ppm or lower. Given my experience with soil testing, I have always recommended that children’s play areas be 40 ppm or lower as that appears to be attainable even in urban environments.
#5 Water Testing:
They will take a sample of your water (usually from your kitchen faucet) – if they don’t offer to do this, request that they do so. Usually they prefer that they get a sample of the water from a faucet that has not been running overnight, and then a second sample of the water after it has been running for several minutes (to see the highest levels that might be in the standing water in your faucets vs. the lower level that may be in your water once it has been running a bit.)
IF YOU CAN, do not have your water run starting on the morning of the inspection (stop using it the night before) – so the inspector does not have to come back another time to do your water sample.
Again, here the hazard levels are politically influenced – not set based on what is safest and best for children… Water is considered toxic by the federal government (and federally-funded agencies and programs) at 15 parts per billion (ppb). The latest scientific advice (from scientists independent of government influence) is that the hazard level should be lowered to 5 ppb. So, again – as with all of these testing methodologies, ASK to see the results and LOOK at the numbers. (I have an earlier post about water filtration that may be helpful as most older homes have lead somewhere along the water delivery system and even newer homes can have lead as a result of holes in federal legislation that has ineffectively regulated total lead content and leachable lead levels in facuets, fittings and fixtures.)
#6 Consumer Goods Testing:
The hazard assessor may also inspect consumer goods – like your child’s toys and your dishes. Most hazard inspectors know nothing whatsoever about how to test consumer goods, and are truly doing their customers a disservice by claiming they are qualified to do so. Not only do they not have the training or experience required for testing consumer goods, I have not yet come across one hazard inspector [in my 14 years of knowing what a hazard inspector is and helping probably hundreds of families across the country find and hire hazard inspectors near them] who had the appropriate instrumentation for testing consumer goods.
The instrument used to test consumer goods is a specific type of XRF instrument that generally costs 3 to 5 times as much as the type of XRF instrument used by most home inspectors. Home inspectors typically use a type of instrument that is a radioactive-source XRF analyzer; these have a low threshold of detection (in the range of 0.1 to 1.0 milligrams per cm squared and are designed and intended for detecting (the very high amounts of Lead in) Lead-based house paint), and are low-precision instruments.
These instruments cost typically between $10,000 and $15,000. This is not an appropriate instrument for testing toys and most other consumer goods – ever. It can only detect extremely high levels of Lead, and cannot distinguish common consumer items with “lower” – but still poisonous/unsafe-for-children items from Lead-free items.
An instrument specifically designed for testing consumer goods (like the ones used by the Consumer Product Safety Commission) retail for $50,000 to $60,000 (or more!) – with the price further dependent on which optional/critical software modules you have installed [for testing consumer goods, a Consumer Goods testing package which correctly interprets and reports back metals detection spikes down to single-digit ppm is required].
Hazards in consumer goods are measured in Parts Per Million (ppm). If your inspector does not have an instrument that measures ppm (but you are having him out for an inspection anyway) – make a note of the readings (with the understanding that, due to the inherent low-precision of the instrumentation they may not be anywhere near accurate)… and I may be able help you interpret them. For consumer goods (especially things like dishes and toys), if they tell you it is “negative” because it is “less than one (mg/cm2)” (or even because it is “less than 0.1 (mg/cm2)”) – please understand they are misinformed — as they have not been trained in consumer goods testing and relevant toxicity limits.
More specifically, the concern here is that toys are toxic at levels of 90 ppm Lead and higher. Even in the LOOSE interpretation for the conversion of milligrams per cm squared to ppm, the lowest possible reading of a typical XRF used by a home inspector is 0.1 – and a reading of 0.1 could still indicate something in the range of 500 or 600 ppm Lead (in the neighborhood of an order of magnitude above the 90 ppm toxicity level set for toys and other items intended for use by children!), and so even something approaching a “negative” (using an inappropriate XRF instrument) is not meaningful/useful as a reading – because it may actually be negative (given the high margin of error of these inappropriate instruments) OR it may be positive – merely at a level below 600 ppm (and still very unsafe for children!).
Consumer goods testing takeaway:
Please don’t waste your money hiring a home inspector to test your toys with an inappropriate instrument. HOWEVER, If you are having an inspector out to test your HOME for Lead-based paint (building components, windows, siding, interior paint, tubs, etc.), and have the opportunity to have him test a few of your consumer goods while he (or she) is there, please know that only the readings over 1.0 are useful – and anything under a 1.0 may still be very unsafe for a child to use and should be re-tested by an appropriate instrument before you make a determination that it is safe or unsafe.
So we had our inspection, now what?
- Make sure you get a copy of your full written inspection report.
- They should have most of the results in two or three days (even though they may tell you it could be weeks).
- If your child has been poisoned (they have already tested positive for Lead in their blood) and you cannot afford to leave your home (to stay in a hotel or with friends) while you wait for the results, make sure to communicate this to the inspector and ask them to expedite getting you the results.
- If you don’t understand the numbers or the report that is given to you, you can e-mail it to me and (if I have time in my schedule) I will do my best to help you to understand the readings.
As always, thank you for reading and thank you for sharing my posts.
Please let me know if you have any questions.