Section 1:
1. I conducted a lead hazard evaluation on multiple days at one property. Can I use one CDPH Form 8552 for all days? Or do I need to submit separate CDPH Forms 8552 for each day, even if it is one inspection?
If lead hazard evaluation on a property cannot be completed on one single day and requires multiple days then one CDPH Form 8552 form can be submitted but Section 1 should have the date ranges. However, if you return to the property at a later date to conduct an additional lead hazard evaluation, such as a follow-up investigation or clearance inspection, then a separate CDPH Form 8552 must be submitted.
Sectiāāon 2:
2. The clearance dust wipe samples failed when I went out to do a clearance inspection. Do I need to submit a CDPH Form 8552?
Yes, every time that you perform sampling you need to submit a CDPH Form 8552. For failed clearance samples this provides a record that lead hazards are still present at this property. By definition, a clearance inspection consists of both a visual examination and clearance sampling. See Title 17 section 35013.
3. What does the checkbox āOther" stand for under Section 2?
The space provided after the checkbox āOther" is for all other evaluations that do not fall under the Title17 defined activities of lead inspection, risk assessment or clearance inspection. CDPH certified individuals are required to submit CDPH Form 8552 for all compensated lead hazard evaluation activities, including limited lead-based paint testing, modified risk assessments or lead-based paint inspections, Phase I/II site assessments, etc. Childhood Lead Poisoning Prevention Programs are trained to check āOther" and use specific wording in the space provided, when conducting a lead hazard evaluation in response to a child with an elevated blood lead level.
Sectiāāon 3:
4. Under Section 3 do I need to put the year the house was built? How do I find out that information? What do I put if I don't know?
A CDPH Inspector/Assessor has the responsibility to practice due diligence to obtain the date when the property was built. Property dates are significant for determining whether the property should be treated as a pre-1978 property or a post-1978 property. Additionally, the age of the housing helps to determine the likelihood of lead-based paint being present on the structure. There are several ways to determine this information: the property owner may have this information from the mortgage documents; a real estate website might have this information (check multiple real estate websites to compare the dates provided); or the county clerk/recorder and/or tax assessor's office will have this information. Use the original year of construction even if the house was remodeled.
5. What does the checkbox āOther" stand for under Section 3?
Lead hazard evaluation can be conducted on structures other than multi-unit buildings, single family dwellings, schools or daycares. The checkbox āOther" under Section 3 is for all such structures and may be appropriate for bridges, flag posts, garages, barns, etc. When you check the box marked āother," please specify the type of structure in the space provided.
Sectioāān 4:
6. I did an evaluation at a rental property and my main contact was the tenant living in the property. Can I list the tenant as the property owner/contact?
No, you need to list the actual owner of the property. If you have trouble locating the property owner's name you can contact the county assessor's office for this information.
Sectionāāā 5:
7. If I perform a risk assessment and identify one component with intact lead-based paint, and there is another component that I did not test but it has deteriorated paint and I suspect it to have the same painting history of the component that I did test, on the CDPH Form 8552, do I check āDeteriorated lead-based paint detected" as well as āIntact lead-based paint detected?" Or do I only check āIntact lead-based paint detected?" The dust and soil sample results are all below the regulatory limits.
Only include information on your specific testing results on the CDPH Form 8552. These results would include x-ray fluorescence instrument (XRF) readings and laboratory sample results. In this case, you would check, under Section 5, both āIntact lead-based paint detected" (you identified lead-based paint that was intact) and āNo lead-hazards detected" (the intact lead-based paint is not a current lead hazard and the dust and soil sample results were below regulatory limits).
8. I performed a visual inspection on a house built in 1910 and noted deteriorated paint on window sills. Do I complete a CDPH Form 8552 and check, āDeteriorated lead-based paint detected"?
No, a CDPH Form 8552 is for reporting quantitative lead testing results for paint, dust and soil. A visual inspection alone is insufficient to be considered a lead hazard evaluation.
9. I tested a child play area soil sample which was 330 parts per million (ppm) and under the 400 ppm California regulatory limit for lead-contaminated soil. Because the child ate the soil, I believe this area should be remediated. What do I fill out under Section 5 of the CDPH Form 8552?
You should check the box āOther" and note āchild lead exposure source (soil sample result was 330 ppm)", in the space provided.
10. I performed dust wipe sampling as well as a visual inspection at a house. The dust wipe samples tested positive for lead. I did not test the paint. However, I suspect that the paint is lead-based paint since the house is very old. Do I check only āLead-contaminated dust found?" or do I also check āDeteriorated lead-based paint detected?"
If lead hazard evaluation results for the dust wipe samples were above the regulatory limit, please check the box āLead-contaminated dust found" under Section 5. Since paint samples were not taken, do not check any box related to lead-based paint. Only quantitative results are indicated on the CDPH Form 8552. A visual inspection alone is insufficient to be considered a lead hazard evaluation.
11. I performed a risk assessment at a home. All of the paint, dust and soil samples were below the regulatory limit. However, I found a clay bean pot that tested positive. Do I list the bean pot in the āOther" box under Section 5?
The Lead Hazard Evaluation Report has to be submitted to the State only if lead hazards were detected in paint, soil or dust (building-based information). You do not submit CDPH Form 8552 for testing non-housing samples such as utensils, toys, cosmetics, spices, home remedies, etc.
12. I tested water at a home during a recent Risk Assessment, do I list that in the āOther" box under Section 5?
The Lead Hazard Evaluation Report has to be submitted to the State only if lead hazards were detected in paint, soil or dust. The check box āOther" can be used for lead hazards identified on friction surfaces, impact surfaces, chewable surfaces, or deteriorated substrate conditions.
13. I tested a ceramic tile kitchen countertop during a lead based paint inspection, and found it to have 4.0 mg/cm2 of lead. Should I list this as an āOther" under Section 5? Is ceramic glaze considered a paint coating regulated by Title 17, California Code of Regulations?
Although some Inspector/Assessors include glazed ceramic tile testing in their lead-based paint inspections, these surfaces are not considered to be lead-based painted surfaces (for example, Title 16, Code of Federal Regulations, Ā§1303.2(b)(1)). The Title 17 Ā§35033 definition of lead-based paint includes āā¦paint or other surface coatingā¦" which glaze is not considered to be. Rather, ceramic glaze is bonded to the substrate at the time of manufacture and not applied at a later time. Ceramic glaze results should not be reported as paint on the CDPH Form 8552. Although ceramic glaze is not considered paint, creating a lead hazard is a violation of California Health and Safety Code sections105255 and 105256. A lead-contaminated dust hazard could be created if lead glazed tile were pulverized during remodeling or demolition.
Sectāāion 6:
14. If a lead hazard evaluation was conducted by multiple individuals, do we enter everybody's certification numbers?
Yes, if a lead hazard evaluation was conducted by an Inspector/Assessor and Sampling Technicians have assisted him/her on the evaluation, please enter name and certification numbers of all the individuals who collected the samples in the space provided.
Sectiāāon 7:
15. Do I need to submit to CDPH all the attachments (foundation diagram or sketch, testing methods, etc.) from my lead hazard evaluation along with the CDPH Form 8552?
No, you just need to submit the CDPH Form 8552 to CDPH. You will submit the CDPH Form 8552 and all the attachments to the person who ordered the lead hazard evaluation. Maintain copies of all of your Lead Hazard Evaluation Reports and testing results for at least 3 years after the evaluation date. If you are audited by CDPH CLPPB, you may be asked to submit these documents to the staff at CDPH CLPPB.
Additionāal Questions:
16. I have made a custom designed Form 8552 to create some extra space to include additional information related to my company and the lead hazard evaluation conducted. Is it alright for me to do this?
No, it is important that you use the CDPH Form 8552 as created by CDPH. Use and submittal of altered forms is not allowed.
17. Is it alright to fill in the checkboxes with a dot or a dash instead of a checkmark?
No, you must use a checkmark (āā") in each applicable checkbox.
18. I think I made a mistake on my original CDPH Form 8552 that I submitted to CDPH. How do I correct it?
You need to submit a revised version of CDPH Form 8552. To do so, you need to note, on the top of the form āRevised version for (Investigation Date)" and re-submit the form with the correct information.
19. It has been 30 days since I conducted a lead hazard evaluation and I am still waiting on some lab results. Do I wait for all my lab results before submitting the CDPH Form 8552?
No, you must submit CDPH Form 8552 within 30 days of completion of lead hazard evaluation. You should complete the CDPH Form 8552 based on the results that you have (XRF readings and/or lab sample results). An amended version of CDPH Form 8552 should be submitted if the remaining lab results alter your original CDPH Form 8552 findings.
20. āāI performed a Phase 2 site assessment that included testing for lead-based paint for a real estate transaction. Since I did not conduct a lead-based paint inspection or risk assessment per HUD Guidelines, do I have to submit a CDPH Form 8552?
Yes, you must submit a CDPH Form 8552 for all lead hazard evaluations that are performed for compensation. Lead hazard evaluation is a broad term defined in Title 17 to encompass both evaluations per HUD Guidelines and other forms of limited sampling or testing for lead-based paint and/or lead hazards.