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A Closer Look: SBA Lead Risk Assessments at Childcare Centers

The human health risk of lead exposure means that lead assessments are an important step before transacting or leasing a property.

The human health risk of lead exposure means that lead assessments are an important step before transacting or leasing a property where people will live, work, or play. This is especially true when it comes to vulnerable populations, like daycare facilities occupied by children.

When it comes to SBA Lead Risk Assessments for daycares, there is no step-by-step process provided by the SBA in SOP 50 10 5 (I) or previous versions. The SOP indicates the requirement of a lead risk assessment at special use facilities such as daycares, child care centers or nursery school buildings constructed prior to 1980. The actual assessment process is left to the environmental professionals with the technical knowledge to complete the investigation in accordance with industry standards. The environmental professional must also provide adequate data to the lender so that they may make a prudent decision.

Based on years of working with the SBA, Partner’s understanding is that while the SOP indicates a “Lead Risk Assessment” (which denotes a specific scope of work to an Industrial Hygiene (IH) professional), it is meant in the general sense to “determine if lead is present and where.” What we have determined is the SBA prefers an x-ray fluorescence (XRF) inspection and lead in drinking water testing. Although the SBA will accept data derived from paint chip testing, the collection of the samples creates a potential lead dust hazard in a daycare which is expressly what all parties are trying to assess and prevent. Furthermore, the XRF has the advantage of providing more data through non-destructive means. 

Again, while not specifically stated in the SOP, this sampling method requires someone who is properly certified as a lead inspector/assessor; although, prudent lenders and professional practices require that any lead assessor be properly certified to work in the area of the site, Agency requirements notwithstanding.

You will also need to keep in mind that XRFs also have manufacturer certifications and training requirements. Partner can meet these requirements.

The quantity of samples required will be dependent on a range of things, including: the number of suspect materials; scope of work; whether you are just looking at damaged substrates, lead hazards, or a full inspection; lab samples etc. The environmental professional should also keep in mind these considerations: HUD regulates lead for residential housing; OSHA regulates lead for worker exposure; and, certain states also have their own lead regulations.

To ensure compliance and occupant safety, it pays to work with a consultant with the experience and technical knowledge to adequately assess any lead risks.