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Environmental Risk Advisor:
SBA Lead Testing Requirements 

Charlotte, North Carolina - Due to the hazards associated with lead, the federal government banned the production of lead-based paint in 1978. However, millions of homes and other properties across the United States had already been impacted by its use in construction for decades.   Peeling and chipping paint and lead dust pose serious health hazards if not addressed.  Homes and businesses with pipes containing lead and/or lead-based solder also provide an avenue for lead to be released into drinking water, creating another potential route for exposure.

The Small Business Administration (SBA) Standard Operating Procedures (SOPs) require lead assessments for “Special Use Facilities” constructed prior to 1980.  Special Use Facilities include childcare centers, nursery schools or residential facilities occupied by children. The SBA also recognizes residential care facilities constructed prior to 1980 as facilities having increased lead exposure risk. 

The required lead assessments include a lead-based paint risk assessment and testing for lead in drinking water.  Lead risk assessments should be conducted based on guidelines established by the U.S. Department of Housing and Urban Development (HUD) as required by the Environmental Protection Agency (EPA).  The risk assessment focuses on the potential dust hazards that may result from peeling or damaged paint along both the exterior and interior of target facilities. Lead in soil along the exteriors of facilities should also be evaluated as a potential exposure risk.  Soil surrounding building structures can easily be contaminated with lead paint particulates, resulting from refinishing/sandblasting older exterior walls, which were formerly painted with lead-based paint. Soils contaminated with lead-based paint particulates can readily be transferred into building structures via tenant traffic. An inspection for lead-based paint, although not specifically required, includes surveying a facility and performing surface by surface testing of building components such as walls, doors and windows with an X-Ray Fluorescence analyzer (XRF).  Paint or other coatings with lead levels above an established threshold are considered lead-based paint and may require special training to manage.  Water samples should be collected from drinking water outlets and analyzed in a certified laboratory for lead.

SBA SOPs states, “Disbursement will not be authorized unless the risk for lead exposure to infants and small children has been sufficiently minimized.” Compliance with the SOPs will help ensure a smooth closing process while reducing the health risks to occupants at collateral properties.

About Environmental Risk Innovations
Environmental Risk Innovations (ERI) is the nation’s largest environmental risk consulting firm, specializing in the environmental risk management services for commercial lenders.   ERI’s clients include a broad base of commercial lenders, from small regional banks to large banks with national footprints.  ERI develops internal environmental risk policy for commercial lenders, provides third-party review of environmental assessment reports, and conducts Records Search with Risk Assessments (RSRAs)/“desktop reviews” on commercial properties.  ERI is not a traditional environmental consulting firm that performs Phase I or Phase II Environmental Site Assessments.  As a result, ERI’s recommendations represent a truly independent, third-party opinion that conforms to the client bank’s specific risk tolerance. 

For more information on ERI's environmental consulting expertise, please contact Karen Nelson at knelson@eRiskInnovations.com or 704.548.9333.

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