How to actually pass a lead clearance.
Whether you are cleaning up after RRP work or running a full abatement, the cleaning is the same discipline. This is the field version: the order you clean in, how you keep dust from spreading, and how to find what you missed before the check does. The regs are collapsed at the bottom if you need them.
Pass/fail bar, since Jan 12 2026:5 / 40 / 100 µg/ft²(was 10 / 100 / 400)
The method
You pass by removing dust you mostly cannot see.
This cleaning works whether you are under RRP or doing abatement. What changes is how you sign it off, that is the section after this one.
Three rules under everything below
- Top to bottom, back to front. Ceilings and walls, then components, then floors. Work from the far corner toward the door so you exit across clean surfaces.
- Clean to dirty. Never drag lead back across a surface you already finished.
- HEPA, wet, HEPA. Vacuum the loose dust, wet wash with detergent, then HEPA vacuum again once it dries. Every surface.
1
Baseline the floor before you start
Check the floor first and HEPA up any lead dust that is already there. If you drop containment over existing dust, you have just sealed contamination into the work area and it will show up at clearance.
◆ This is the step most people skip.
2
Lay containment on a clean floor, then control the dust as you work
Critical-barrier the openings and any HVAC. Keep paint disturbance wet, never dry-sand or dry-scrape, and bag debris as you go. Assume anything outside the plastic can come back in on boots and tools.
◆ Run the reagent at the seams to catch dust escaping where it should not be.
3
Clean in the right order
Top to bottom, back corner to the door, cleanest area to dirtiest. The sequence is the whole game: done out of order, you recontaminate finished surfaces and chase your tail.
See the order diagram below.
4
Run HEPA, wet, HEPA on every surface
HEPA vacuum the loose dust. Wet wash with an all-purpose detergent, which lifts the bound dust. Let it dry, then HEPA vacuum again. Change your wash water often and use disposable cloths so you are removing lead, not spreading it.
HUD Guidelines Ch. 14 (Cleaning)
5
Seal what the rules say to seal
Paint or seal all treated non-floor surfaces (walls, woodwork) before clearance, and seal floors. Sealing also gives a clean, smooth surface to wipe. Materials not traditionally painted (vinyl, aluminum) are exempt.
HUD Guidelines Ch. 14 §E, p. 14-19
6
Let it settle, then walk it with UV before you call the wipe
Wait for airborne dust to resettle. The clearance wipe is keyed to a minimum of one hour after your final cleanup. Before that, spray or scan the surfaces with the reagent and re-clean anything still glowing. Clean to no-glow, then call clearance.
◆ Glow does not mean you failed. It means there is still lead there. Keep cleaning until it is gone.
40 CFR 745.227(e)(8)
Signing it off
How each group proves it is clean.
RRP renovator
The cleaning verification card
After HEPA and wet cleaning, wipe each uncarpeted floor, sill, and counter with a wet disposable cloth and compare it to the EPA cleaning verification card. Match or lighter, that section is clean. Darker, re-clean and wipe again. Split anything over 40 ft² into sections.
You do it yourself. No lab, no independent party, unless you opt into clearance instead.
40 CFR 745.85(b)
Abatement contractor
An independent lab clearance
After the HEPA-wet-HEPA cleaning and sealing, wait at least an hour, then an independent certified inspector, risk assessor, or dust-sampling tech runs the visual and wipes floors, sills, and troughs. The lab measures against 5 / 40 / 100 µg/ft². Fail a sample and you re-clean that component and re-sample.
The checker cannot be on your payroll. That independence is the whole point.
40 CFR 745.227(e)(8)
HUD-funded
Clearance, by the LSHR
Federal money applies the Lead Safe Housing Rule on top of the EPA work. The clearance numbers are the same 5 / 40 / 100, but clearance is required across more activities, the examiner must be independent (not paid by you), and the program adds resident notification plus ongoing lead-safe maintenance and reevaluation.
Same pass line as EPA. The strictness is in the scope and the ongoing duties, not the threshold.
24 CFR 35.1340(f)
What helps every group
Finding the lead is the move in all three.
The proof differs by group, but the failure is the same one: lead dust you could not see until the check caught it. Being able to find it on the spot, before the card or the lab, helps every case.
RRP
Pass the card the first time
Walk the floors, sills, and counters and clean until nothing lights up. When you run the verification card, the wet cloth comes up clean, no second and third re-wipes.
Abatement
Be clean before the independent wipe
You get one shot in front of a clearance tech you are paying for. Pull the lead-rich specks first, clean to no-glow, then call them. Fewer failed samples, fewer re-mobilizations.
HUD & exterior
Catch what the visual misses
Make the dripline chips and tracked-in dust glow instead of hunting for them in the dirt. The same check that helps the wipes helps the exterior visual.
It does not replace the card or the lab, those are the legal proof. It is how you get there clean the first time, on any job.
The surfaces that decide it
Floors, sills, and the trough.
Clearance wipes the surfaces lead dust collects on. On windows, across multiple openings you alternate: sill on one window, trough on the next, one wipe each. The trough, the well the sash slides into, is the dirtiest point in the house.
Here is the trap people misread: the level is a loading (µg per square foot), and these surfaces are small. A real sill is ~0.5 ft² and a trough ~0.35 ft², so the actual lead a passing surface can hold is tiny, about 20 µg on a sill, 35 µg on a trough. A single 1 mm leaded chip is ~300 µg. One chip blows either by 8 to 15x.
The rules behind it
The regs, collapsed.
The how-to above is the job. This is the reference underneath it. Open what you need.
Which group are you under? RRP, abatement, or HUD
RRP and abatement are the two work regimes. HUD is not a third kind of work, it is a funding overlay: a HUD job runs RRP or abatement practices and adds the Lead Safe Housing Rule on top. The cleanup is about the same; where they split is how you prove it is clean.
| RRP renovator | Abatement contractor | HUD-funded job | |
|---|---|---|---|
| The work | Routine repair or paint that disturbs paint in pre-1978 housing | Work meant to permanently eliminate lead paint or hazards | Any of the above when federal housing money is involved |
| Cleanup | Debris, HEPA vacuum, wet wash | HEPA, wet wash, HEPA, then seal surfaces | The same specialized cleaning |
| How you prove it | Cleaning verification card (wet cloth vs the EPA card) | Lab clearance (dust wipes vs 5 / 40 / 100) | Lab clearance to the same 5 / 40 / 100 |
| Who checks | You, the certified renovator | An independent certified tech, not your crew | An independent clearance examiner |
| Lab needed | No, unless a contract or state requires it | Yes | Yes |
| If it fails | Re-clean that section, wipe again | Re-clean the component, re-sample | Re-clean, re-clear |
RRP can opt into a lab clearance in lieu of the card; abatement and HUD cannot opt out of it. HUD uses the same dust-lead numbers as EPA, what it adds is scope, examiner independence, notification, and ongoing maintenance, not a tighter pass line. 745.85 · 745.227(e)(8) · 24 CFR 35.1340
What changed in 2026: the bar dropped, and split in two
Judgment calls on real jobs
New components
The new, unpainted trough still gets sampled
It is catching migrated dust from the work area, not being tested as wood. You cannot clear before it is installed. Abatement is "complete" when the last lead is disturbed and cleaned.
40 CFR 745.223 · 745.227(e)(8)
Other trades
Re-clean after anyone tracks through
Signs and curtain doorways do not stop tracking. If another trade disturbs or walks a cleared area afterward, you re-clean before clearance. A pass earlier does not survive lead walked back in.
HUD Guidelines Ch. 8
Separate contract
A standalone install drops to RRP
If the window install is a genuinely separate contract done after the abatement is signed off, that install is its own job under RRP or HUD de minimis, not the original clearance.
Outside
Exterior is a visual, and UV helps it
For exterior work the examiner visually confirms no debris and checks for paint chips along the dripline and foundation, 10 to 20 ft out. Not a soil-lab sweep. Fluorescence makes those chips easier to spot in the dirt.
References, the regs, and the standards
Start here: the official hubs
- EPA Lead — rules, RRP, hazard standards
- HUD Office of Lead Hazard Control & Healthy Homes
- CDC Lead Prevention
The regs
- 40 CFR 745 — RRP, abatement, hazards
- 24 CFR 35 — HUD Lead Safe Housing Rule
- OSHA lead in construction — 29 CFR 1926.62
- 745.227(e)(8) — clearance sequence
The HUD Guidelines (2012)
- Ch. 8 Worksite Prep · Ch. 12 Abatement
- Ch. 14 Cleaning · Ch. 15 Clearance
- Full set (HUD)
The ASTM practices
Labs & training
- NLLAP — find an accredited lab
- EPA RRP program
- EPA accredited training providers
Working reference and general information only. Not legal advice and not a substitute for EPA/HUD-required certification, the HUD Guidelines, or the applicable federal, state, tribal, and local rules, which can be stricter than the federal floor here. Clearance and abatement must be performed by certified professionals. Verify every citation against the current rule before relying on it; standards changed January 12, 2026. Per-particle and per-surface figures are fitted or population values, not a measurement of any specific job.