Clinical Pharmacist and Master’s student in Clinical Pharmacy with research interests in pharmacovigilance, behavioral interventions in mental health, and AI applications in clinical decision support. Experience includes digital health research with Bloomsbury Health (London) and pharmacovigilance practice in patient support programs. Published work covers drug awareness among healthcare providers, postpartum depression management, and patient safety reporting. 
Clinical Pharmacist and Master’s student in Clinical Pharmacy with research interests in pharmacovigilance, behavioral interventions in mental health, and AI applications in clinical decision support. Experience includes digital health research with Bloomsbury Health (London) and pharmacovigilance practice in patient support programs. Published work covers drug awareness among healthcare providers, postpartum depression management, and patient safety reporting. What was reviewed?
This review evaluates the EPA dust-lead action levels and associated dust-lead reportable levels under TSCA §§402–403, as presented on the EPA’s “Hazard Standards and Clearance Levels for Lead in Paint, Dust and Soil” webpage, with a focus on their operational meaning for HTMC program design, auditing, and laboratory interface. In October 2024, EPA finalized stronger requirements that set dust-lead reportable levels to any reportable level detectable by an EPA-recognized laboratory and tightened dust-lead action levels used to judge post-abatement completion to 5 µg/ft² for floors, 40 µg/ft² for window sills, and 100 µg/ft² for window troughs; together, these measures redefine compliance thresholds and cleaning verification benchmarks in pre-1978 housing and childcare settings. The review highlights how these thresholds were decoupled from hazard identification, the renamed terms, and the practical sequence from risk assessment to abatement to clearance.
Who was reviewed?
The policies and requirements reviewed apply to pre-1978 homes and childcare facilities where lead-based paint hazards may be present, directly affecting certified risk assessors, abatement contractors, laboratories accredited through EPA’s National Lead Laboratory Accreditation Program, property owners, and state or local agencies implementing the lead-based paint program. Post-abatement testing must demonstrate that dust lead is below the action levels before work is considered complete, and when results are at or above reportable levels but below action levels, EPA recommends enhanced housekeeping practices rather than abatement, shaping owner and operator responsibilities for ongoing risk reduction. Certification and work-practice requirements in the Lead-Based Paint Activities program apply to firms and individuals performing abatements.
Most important findings
| Critical point | Details |
|---|---|
| New terminology and decoupling | EPA replaced “hazard standards” with dust-lead reportable levels (DLRLs) for identifying the presence of dust-lead and replaced “clearance levels” with dust-lead action levels (DLALs) for determining when EPA recommends abatement and when an abatement is considered complete, separating identification from clearance and tightening alignment with laboratory measurement capability. |
| Reportable level now “any reportable level” | A dust-lead hazard is now present at any reportable level detected by an EPA-recognized lab, reflecting the agency’s acknowledgment that no blood lead level is safe for children; this shifts screening and documentation from fixed numeric thresholds to laboratory reporting limits. |
| Action levels for post-abatement clearance | DLALs were lowered to 5 µg/ft² (floors), 40 µg/ft² (window sills), and 100 µg/ft² (window troughs), representing the lowest levels that can be reliably and quickly measured in accredited labs and redefining pass/fail criteria for completion. |
| Scope and settings | The standards govern pre-1978 residences and childcare facilities and operate within lead risk assessments, hazard screens, abatements, and post-abatement clearance; owners and professionals must use certified personnel and approved work practices under EPA’s Lead-Based Paint Activities program. |
| Response when DLRL ≤ result | If dust-lead loadings are at or above DLRLs but below DLALs, EPA does not recommend abatement based solely on dust levels; instead, it recommends best-practice cleaning (HEPA vacuuming and damp wiping), establishing a tiered response framework. |
| Regulatory lineage | The 2024 final rule supersedes earlier numeric hazard and clearance levels from 2001, 2019, and 2021 and explicitly decouples identification from clearance, closing historical ambiguity where a single number served dual purposes. |
| Programmatic implications for certification | Abatement work must be performed by certified firms and individuals, with laboratory analysis by EPA-recognized labs, linking field practices and lab reporting directly to compliance evidence for clearance determinations. |
| Communication and disclosure context | Separate real-estate disclosure obligations remain under Section 1018 and are not altered by the 2024 reconsideration, preserving parallel compliance channels for sellers and lessors of target housing. |
Key implications
The primary regulatory impacts consolidate around universal detectability standards that elevate laboratory reporting to the central evidence of hazard, while the certification requirements emphasize accredited labs and certified abatement firms for defensible clearance. Industry applications include retooling SOPs to meet 5/40/100 µg/ft² DLALs and documenting DLRL-based findings. Research gaps include field variability near reporting limits and cleaning efficacy. Practical recommendations include validated sampling plans, HEPA-centric housekeeping where results fall between DLRL and DLAL, and rigorous laboratory QA.
Citation
U.S. Environmental Protection Agency. Hazard Standards and Clearance Levels for Lead in Paint, Dust and Soil (TSCA Sections 402 and 403). Last updated August 6, 2025.
Lead is a neurotoxic heavy metal with no safe exposure level. It contaminates food, consumer goods and drinking water, causing cognitive deficits, birth defects and cardiovascular disease. HMTC’s rigorous lead testing applies ALARA principles to protect infants and consumers and to prepare brands for tightening regulations.
