DESCRIPTION OF THE STRATEGY
Testing for lead-contaminated dust is a critical tool for advancing lead poisoning prevention—both to ensure that lead hazards are not left behind after work that disturbs or repairs painted surfaces and to help to identify lead hazards in high-risk properties for corrective action. Home inspectors, community development corporations, public housing authorities, community-based organizations, housing code and HQS inspectors, and public health nurses can use lead dust testing to advance prevention efforts. HUD’s lead-safe housing rule accepts clearance by a state-certified lead sampling technician (LST) after non-abatement work. Further, EPA has developed a six-hour training course for LSTs, sponsored its delivery in several communities, and initiated its translation into Spanish. To help make dust testing services by certified personnel more readily available, ten states certify the LST as a free-standing discipline within their EPA-authorized lead programs: Indiana, Iowa, Kentucky, Maine, Michigan, Minnesota, New Hampshire, Ohio, Vermont, and Wisconsin.
By certifying lead sampling technicians as a free-standing discipline, states can greatly enhance local capacity for lead dust testing. Trained LSTs are already qualified to perform initial checks to detect lead hazards in housing. With certification, they can conduct clearance following non-abatement lead hazard reduction activities or renovations under the HUD lead-safe housing rule and by state regulation. Increasing the pool of qualified individuals who can perform lead dust testing can help states to comply with HUD’s regulation, which requires clearance following rehab work or lead hazard reduction activities in federally-owned or assisted pre-1978 housing, and can advance state-initiated clearance requirements after non-abatement projects.
Certifying LSTs can significantly increase opportunities for primary prevention. Because LST training requirements are not onerous, and requirements for entry into the discipline are minimal, persons from a wide range of professions can obtain LST certification and incorporate lead dust testing into their work. For example, housing code inspectors can routinely perform dust sampling when a visual inspection in pre-1978 housing reveals potential hazards, and community-based organizations can document lead hazards in high-risk housing and use the data in organizing and advocacy campaigns to seek solutions.
In 2001, EPA issued standards identifying dangerous levels of lead in paint, dust, and soil. These standards provide uniform benchmarks for stakeholders to use in making informed decisions regarding lead hazards. Certifying LSTs helps to facilitate the widespread use of the standards, since the testing required to determine compliance with the standards will be more accessible and affordable than a risk assessment.
Scope of Potential Impact
|Health Department||Housing Agency|
Code or Building Inspection Agency
States that already have EPA-authorized certification programs in place for lead abatement workers and supervisors, risk assessors, lead inspectors, and project designers will be able to add approval of certifications for LSTs with a nominal amount of staffing.
Other resource requirements:
Training materials, testing material samples for practice in lead sampling.
In some states, the laws establishing EPA-authorized certification programs may need to be amended to accommodate LST certification. Elsewhere, agencies administering EPA-authorized programs will only need to promulgate regulations detailing LST certification requirements. Accredited training providers may need to develop LST training programs, but states should be able to approve their plan to use the EPA model course.
Once a LST certification program is underway, the increased availability of lead dust testing will bring the cost of that service down significantly.
Assuming the statutory authority to certify LSTs is in place, as much as a year may be required to adopt regulations. Individuals typically are certified as LSTs for one or two years and can easily extend their certification through renewal.
High. Certifying LSTs as a free-standing discipline is readily achievable in states with EPA-authorized certification programs. In states not currently authorized by EPA to administer certification, sampling technicians who are certified by other states can perform non-abatement clearance in accordance with HUD regulations.
Confusion or perceived competitive interests may interfere in consideration of certifying LSTs. The benefits of diversifying and expanding capacity need to be communicated.