How do I prepare for a lead paint inspection:

Rhode Island is considered a Lead Safe state, not a Lead free state. Because of this, we are not required to do a full Comprehensive inspection on each dwelling unit. Comprehensives are where we would test every painted surface in your unit to determine whether or not lead is present and at what concentration. These inspections are very labor intensive and time consuming, and consequently, quite expensive. The solution to make lead compliance more financially reasonable for landlords is the Lead Hazard mitigation Inspection which produces a Certificate of Conformance.

  • The Lead Hazard Mitigation Inspection is largely visual, which is why it needs to be renewed every two years. Lead is safe in the home as long as it is intact and encapsulated so when we perform a lead hazard mitigation inspection we are not actually testing to see if any of your surfaces do or do not have lead paint- we are instead assuming all painted surfaces are positive for lead and performing a visual inspection to confirm that they are ‘conditionally safe’ due to their condition. With that said, we are not able to take into account the age of the substrate, how many layers of paint there are between old lead paint and more modern paint, etc. ALL SURFACES IN THE UNIT MUST BE IN TACT AND ENCAPSULATED WITH NO SIGNS OF DETERIORATION IN ORDER TO PASS A LEAD HAZARD MITIGATION

INSPECTION. We also will look for friction surfaces which are areas where paint can be easily deteriorated due to wear and tear such as doors that bind, old wood rope and pulley windows or painted stairs without tread covers. All of these risk factors need to be addressed before a Certificate of Conformance can be issued. Below you will find our pre inspection checklist which goes over in detail all of the things that our inspectors will be looking for during the inspection. Please note that these guidelines are strict and if you have a question about whether or not something will be a problem, it probably will be. When in doubt, it is best to address it before the inspection.

Lead Hazard Mitigation (LHM) Inspection Frequently Asked Questions

Do I (the landlord) need to be present for the inspection?

Leadsafe HIGHLY recommends that landlords be present for the inspection, specifically if they have never had an inspection done before. Lead paint is a vastly misunderstood element of property maintenance and the inspector can educate the landlord on what to look for if they are on site for the inspection.

During this inspection we will NOT be testing your paint for lead. We will be assuming all painted surfaces to be positive for lead paint and will seek to certify that the property is conditionally lead safe due to all paint being intact and encapsulated with no friction surfaces that can cause paint to deteriorate at a faster than normal rate. We know that when lead is intact it does not pose a danger to people. We are required to return to the property every two years to ensure that as time goes by all paint remains in good condition to protect occupants from lead exposure.

During this inspection we will NOT be testing your paint for lead. We will be assessing all painted surfaces within the unit, common areas and exterior to ensure that all paint is intact and encapsulated with no friction surfaces thereby certifying it as conditionally lead safe. The only testing that will be done during this inspection will be dust samples. We will wipe several surfaces throughout the apartment & common areas with a dust wipe (these surfaces will most commonly be floors and windowsills although inspectors are instructed to sample the ‘worst case scenario’.) which will be sent to a lab for testing. This will tell us what concentration of lead is present in your dust.

A friction surface is an area where two surfaces will come together to produce friction which will cause the paint to deteriorate at a faster rate. Examples of this would be painted stairs without rubber or carpet tread covers, sticking/binding doors that do not open or close freely, original painted cabinetry with no drawer runners or old wood rope and pulley windows.

The best remedy for making old wood windows lead safe is to replace them with vinyl windows as this is a permanent solve and will not require future upkeep. If this is not an option for you, you will need to install either metal or vinyl track liners and wrap the window well to reduce the friction caused by operation. We highly encourage customers to visit L Sweet Lumber (located at 709 Harris Ave, Providence, RI 02909) for assistance in determining which track liner will work best for you. To browse track liners online we encourage you to visit jrproductsinc.com

To test paint for lead is quite labor intensive and costly, so the government allows us to conduct the LHM inspection as a more affordable alternative for the landlord. Because of the age of the housing supply in RI, most of our properties have a significant amount of lead in them. In the majority of cases, testing for lead often results in the same list of hazards but costs significantly more to get there. If the house has undergone significant renovations (to the studs) or was built in the late 1970’s it may be worthwhile to consider the more in-depth inspection. Pricing for this type of inspection depends on the square footage of your property and begins at $675 per unit.

We will be looking for any evidence of deteriorated paint of the exterior (which includes accessory dwellings such as garages, sheds, etc), interior of units and common areas. Common areas are defined as any area tenants have uninhibited access to such as storage areas, laundry rooms, stairways, hallways, foyers, etc.

Deteriorated paint is any paint that is chipping, peeling, flaking, cracking, excessively worn or otherwise separating from the surface material.

Certificates are issued for each unit. In order to issue a certificate the visual inspection of the unit, common areas and exterior all must pass. If any of these areas do not pass the visual inspection a certificate cannot be issued and no samples will be taken until all hazards are remedied. Dust samples need to pass in both the unit and common areas for a certificate to be issued. If dust samples within a unit pass and the common areas fail (or vice versa) a retest with passing results will need to be conducted within 30 days of the original inspection date. If the area with failed results does not pass within 30 days we are required to discard all results and begin a new inspection.

Because certificates are issued by unit we are not required to pass all units at once. Meaning, if common areas & unit 1 dust samples pass and unit 2 dust samples do not, we can still issue the certificate for unit 1. In this example, we would only need to retest unit 2 samples again.

This can be a bit tricky depending on the cooperation from your tenants. We always recommend doing a thorough walkthrough of the unit several weeks prior to inspection to determine if any maintenance work needs to be done before the inspection takes place. That can be coordinated between the landlord and the tenant.

We recommend notifying the tenant of the inspection and asking them to assist with cleaning in anticipation for the inspection but recognize that not all tenants will accommodate this request. We’ve seen clients have success by informing the tenant that the inspection will begin 1 hour before its scheduled time so they can do a quick cleaning themselves prior to the inspection. Just be sure to change your water and rags often!

You need to create an account with the RI rental registry at https://slate.tolemi.com/c/ridoh-ri. This can be done before or after your lead inspection. Once your inspection takes place and a certificate has been issued Leadsafe will upload the certificate to the DOH database for you. As long as you have created your account, no further action is needed. At this time, DOH is requiring all landlords to renew their registration every October so be sure to sign into your account and confirm all information is accurate each year.

We are required to assess any common areas that the tenant has uninhibited access to. If an area of the property is locked and the tenant has no access to a key, we are not required to assess it. If any area is left unlocked and available for the tenant to access we will conduct a visual inspection of that area. All stand alone structures such as a shed or garage will be subject to an exterior assessment.

Children most commonly consume lead through dust which is why that is where we focus our testing. Suppose you have a friction surface such as a binding door. As the door opens and closes the paint rubs and breaks down over time, releasing lead into your dust. The child residing in the apartment is crawling around on the floor, they put their hands in the dust and then in their mouth. This is how lead is most commonly ingested.

You’ll want to work with an RRP certified contractor to remedy any issues identified during the lead inspection. To become RRP certified contractors must take an 8 hour class to learn how to work with lead paint safely. They are required to renew this certificate every 5 years. For more information on RRP certification please email theleadpaintguy@gmail.com

If a visual inspection fails, there is no timeline for reinspection as we will not take any dust samples. It’s important that we take dust samples after all work is completed to ensure that adequate cleanup takes place after any work which disturbs lead. In the case of a failed visual inspection we will create a report of our findings which you can use to prepare for your reinspection. Please note that the findings in this report are a snapshot of what was noted on the day of our inspection and any new or undisclosed paint deterioration will need to be remedied before the reinspection. It is highly recommended that the homeowner or a representative complete a thorough walkthrough of the property prior to the reinspection.