C.M.R. 06, 096, ch. 424, app 096-424-A

Current through 2024-51, December 18, 2024
Appendix 096-424-A - Sampling Protocols

1. Wipe sampling for settled lead-contaminated dust. Wipe samples for settled leaded dust can be collected from floors (both carpeted and uncarpeted), interior and sash/sill contact areas, and other reasonably smooth surfaces. Wherever possible, hard surfaces should be sampled. Wipe media should be sufficiently durable so that it is not easily torn but can be easily digested in the laboratory. Recovery rates of between 80-120% of the true value should be obtained for all media used for wipe sampling. Blank media should contain no more than 2 ug/wipe (the detection limit using Flame Atomic Absorption). Additional standards for wipe sampling can be found by consulting ASTM E1728-16.

A. Wipe sampling materials and supplies.

(1) Type of disposable wipe: Any wipe material that meets the following criteria may be used:

(a) Contains low background lead levels;

(b) Is a single thickness;

(c) Is durable and does not tear easily (do not use Whatmanä filters);

(d) Does not contain aloe;

(e) Can be digested in the laboratory;

(f) Has been shown to yield 80-120% recovery rates from samples spiked with leaded dust (not lead in solution); and

(g) Must remain moist during the wipe sampling process (wipes containing alcohol may be used as long as they do not dry out).

Note: Do not use any other brand of wipes before recovery data has been established. Do not use wipes that contain aloe.

(2) Non-powdered disposable gloves. Disposable gloves are required to prevent cross-sample contamination from hands.

(3) Non-sterilized polyethylene centrifuge tubes (50 ml size) or equivalent hard-shell container that can be rinsed quantitatively in the laboratory.

(3) Dust sample collection forms.

(4) Camera to document exact locations (Optional).

(5) Template Options.

(a) Masking tape;

(b) Hard, smooth, reusable templates may be used to define the area to be wiped. Decontaminant templates after each use or;

(c) Disposable templates are also permitted so long as they are not used for more than a single surface.

Templates must be larger than 0.1 ft2, but smaller than 2 ft2. Templates for floors are typically 1 ft2. Templates are usually not used for windows due to the variability in size and shape (use masking tape instead). Note: Masking tape may damage the painted surface.

(6) Container labels or permanent marker.

(7) Trash bag or other receptacle (do not use pockets or trash containers at the residence).

(8) Rack, bag, or box to carry tubes (optional).

(9) Measuring tape.

(11) Disposable shoe coverings (optional).

B. Single surface wipe sampling procedure

(1) Outline wipe area:

(a) Floors: Identify the sample area to be wiped. Do not walk on or touch the surface area to be sampled. If applying masking tape, create about one square foot sample area. No measurement is required at this time. The tape should be positioned in a straight line and corners should be nominally perpendicular. When putting down any template, do not touch the interior wipe area.

(b) Windowsills and other rectangular surfaces: Identify the area to be wiped. Do not touch the wipe area. Apply two strips of masking tape across the sill to define a wipe area at least 0.1 square foot in size (approx. 4 inches x 4 inches).

(2) Preliminary inspection of the disposable wipes. Inspect the wipes to determine if they are moist. If they have dried out, do not use them. When using a container that dispenses wipes through a "pop-up" lid, the first wipe in the dispenser at the beginning of the day should be thrown away. The first wipe may be contaminated by the lid and is likely to have dried to some extent. Rotate the container prior to each use to ensure liquid inside the container contacts the wipes.

(3) Gloves. Don a disposable glove on one hand; use a new glove for each sample collected. If two hands are necessary to handle the sample, use new gloves, one for each hand. It is not necessary to wipe the gloved hand before sampling.

(4) Collection of samples

(a) Place the wipe at one corner of the surface to be wiped with wipe fully opened and flat on the surface. For square sample areas, complete a first wipe pass side-to-side as follows. With the fingers together, grasp the wipe between the thumb and the palm. Press down firmly, but not excessively with both the palm and fingers. Do not use only the fingertips or the heel of the hand to hold down the wipe, because there will not be complete contact with the surface and some dust may be missed. Do not touch the surface with the thumb. Proceed to wipe side-to-side with as many "S"-like motions as are necessary to completely cover the entire wipe area. Exerting excessive pressure on the wipe will cause it to curl. Exerting too little pressure will result in poor collection of dust. Attempt to remove all visible dust from the wipe area.

(b) Next, fold the wipe in half with the contaminated side facing inward. The wipe can be straightened out by laying it on the wipe area, contaminated side up, and folding it over. Once folded, place in the top corner of the wipe area and press down firmly with the palm and fingers. Complete a second wipe pass moving from top-to-bottom and wiping the area with "S"-like motions. Attempt to remove all visible dust. Do not touch the contaminated side of the wipe with the hand or fingers. Do not shake the wipe in an attempt to straighten it out, since dust may be lost during shaking.

(c) For rectangular sample areas two side-to-side passes must be made over half of this surface, the second pass with the wipe folded so that the contaminated side faces inward. For a windowsill, do not attempt to wipe the irregular edges presented by the contour of the window channel. Avoid touching other portions of the window with the wipe. If there are paint chips or gross debris in the windowsill, attempt to include as much of it as possible on the wipe. If all the material cannot be picked up with one wipe, field personnel may use a second wipe at their discretion and insert it in the same container. Consult with the analytical laboratory to determine if they can perform analysis of two wipes as a single sample. When performing single-surface sampling, do not use more than two single surface wipes for each container. If heavily dust-laden, a smaller area should be wiped. It is not necessary to wipe the entire window well but do not wipe less than 0.10 ft2 (approx. 4" x 4").

(5) Packaging the wipe. After wiping, fold the wipe with the contaminated side facing inward again, and insert aseptically (without touching anything else) into the centrifuge tube or other hard-shelled container. If gross debris is present, such as paint chips in a window well, make every attempt to include as much of the debris as possible in the wipe.

(a) Seal the tube and label with the appropriate identifier. Record the laboratory submittal sample number on the field sampling form.

(6) Area measurement. After sampling, measure the surface area wiped to the nearest eighth of an inch using a tape measure or a ruler. The size of the area wiped must be at least 0.10 ft2 in order to obtain an adequate limit for lab analysis. No more than 2 square feet should be wiped with the same wipe or else the wipe may fall apart. Record specific measurements for each area wiped on the field sampling form.

(7) Form completion. Fill out the appropriate field sampling forms completely. Collect and maintain any field notes regarding type of wipe used, lot number, collection protocol, etc.

(8) Trash disposal. After sampling, remove the masking tape and throw it away in a trash bag. Remove the glove; put all contaminated gloves and sampling debris used for the sampling period into a trash bag. Remove the trash bag when leaving the dwelling unit. Do not throw away gloves or wipes inside the dwelling unit where they could be accessible to young children, resulting in a suffocation hazard.

(9) Repeat steps 1 through 8 for additional samples in the same dwelling unit.

(10) See "Residential Sampling for Lead: Protocols for Leaded Dust and Soil Sampling" from EPA and ASTM E1792-03 (2016) "Standard Specification for Wipe Sampling Materials for Lead in Surface Dust" for further information.

C. Composite wipe sampling. Composite sampling is only allowed as part of a lead hazard screening. Consult with the analytical laboratory to determine if the laboratory can analyze composite samples. When conducting composite wipe sampling, the procedure stated above for single wipe sampling should be used with the following modifications: When outlining the wipe areas (step 1), set up all of the areas to be wiped before sampling. The size of these areas should be roughly equivalent, so that one room is not over-sampled. After preparing the centrifuge tube, put on the glove(s) and complete the wiping procedures for all subsamples (steps 4-5). A separate wipe must be used for each area sampled. After wiping each area, carefully insert the wipe sample into the same centrifuge tube (no more than 4 wipes per tube). Once all subsamples are in the tube, label the tube. Record a separate measurement for each area that is subsampled on the field collection form. Finally, complete trash disposal, making sure that no masking tape is left behind. Risk assessors, inspectors, and sampling technicians do not have to remove their gloves between subsample wipes for the same composite sample if their gloved hands do not touch an area outside of the wipe areas. If a glove is contaminated, the glove should be immediately replaced with a clean glove.

(1) In addition to these procedural modifications, the following rules for compositing should be observed:

(a) Separate composite samples are required from carpeted and hard surfaces (e.g., a single composite sample should not be collected from both carpeted and bare floors).

(b) Separate composite samples are required from each different component sampled (e.g., a composite sample should not be collected from both floors and windowsills).

(c) Separate composite samples are required for each dwelling unit.

D. Blank preparation. After sampling the final dwelling unit of the day, but before decontamination, field blank samples should be obtained. Analysis of the field blank samples determines if the sample media is contaminated. Each field blank should be labeled with a unique identifier similar to the others but that identifies the sample as a field blank.

(1) Blank wipes are collected by removing a wipe from the container with a new glove, shaking the wipe open, refolding as it occurs during the actual sampling procedure, and then inserting it into the centrifuge tube without touching any surface or other object. One blank wipe is collected for each dwelling unit sampled or, if more than one dwelling unit is sampled per day, one blank for every 50 field samples, whichever is less. Also, collect one blank for every lot used. Record the lot number.

E. Lead inspector decontamination. After sampling, wash hands thoroughly with plenty of soap and water. A bathroom in the dwelling unit may be used for this purpose, with the owner's or resident's permission. If there is not running water in the dwelling unit, use wet wipes to clean the hands. During sampling, lead inspectors and risk assessors must not eat, drink, smoke, or otherwise cause hand to mouth contact.

2. Paint chip sampling. Dust sampling must always be done before paint chip sampling in order to minimize the prospect of cross-sample contamination. Paint chip sampling is a destructive method that may release a small quantity of lead dust. Although paint chip samples are to be collected from inconspicuous areas, the occupant must always be notified that paint chip sampling may be necessary.

A. Paint chip sampling tools and materials

(1) Sharp stainless steel paint scraper.

(2) Disposable wipes for cleaning paint scraper.

(3) Non-sterilized non-powdered disposable gloves.

(4) Hard-shelled containers (such as non-sterilized 50-mil polypropylene centrifuge tubes) that can be rinsed quantitatively for paint chip samples if results are to be reported in mg/cm2. Sealed baggies can be used only if results are to be reported in ug/g or percent by weight.

(5) Collection device (clean creased piece of paper or cleanable tray).

(6) Field sampling and laboratory submittal forms.

(7) Tape measure or ruler (if results are reported in mg/cm2).

(8) Ladder.

(9) Plastic trash bags.

(10) Flashlight.

(11) Masking tape.

(12) Heat Gun or other heat source operating below 1,100°F to soften the paint before removal.

B. Containment

(1) Method one: Plastic Sheeting Underneath Sampling Area. A clean sheet of plastic measuring four feet by four feet should be placed under the area to be sampled to capture any paint chips that are not captured by the collection device or creased piece of paper. Any visible paint chips falling to the plastic should be included in the sample. Dispose of the plastic after each sample is collected by placing the sheeting in a trash bag. Do not throw away the plastic at the dwelling unit. Wet wipes may be used to clean the area.

(2) Method two: "Glovebag" Approach. If further containment is deemed necessary, a "glovebag" approach may be used. A durable sheet of plastic is loosely taped to the surface to be sampled, with a paint scraper, collection device, and shipment container housed inside the plastic. There should be enough "play" in the plastic to permit a scraping motion without dislodging the tape holding the plastic to the surface. Large plastic baggies can be used in lieu of the sheet of plastic if paint chips are to be shipped to the lab in plastic baggies. Properly conducted, this method completely seals the surface during the actual scraping operation. A four by four-foot sheet of plastic is still required under the glove bag to capture any debris that falls to the ground during the glove bag removal. The tape should be slowly removed from the surface to avoid lifting any additional paint from the surface.

C. Paint sample collection. The paint chip sample need not be more than 2-4 square inches in size (consult with the laboratory for the optional size). Persons collecting paint chips should wear new disposable gloves for each sample.

(1) The most common paint sampling method is to scrape paint directly off the substrate. The goal is to remove all layers of paint equally, but none of the substrate. A heat gun should be used to soften the paint before removal to reduce the chances of including substrate with the sample and to help prevent sample loss. Including substrate in the sample will dilute the lead content if results are reported in ug/g or weight percent. Hold the heat gun no closer than six inches from the surface. Do not scorch the paint. Discontinue heating as soon as softening or blistering is observed.

(2) Use a razor-sharp scraper to remove paint from the substrate. Paint samples collected in this fashion are usually reported in ug/g or % lead only. The sample may be placed in a baggie for shipment to the laboratory.

(3) If the area sampled is measured exactly (+/- 1/16th of an inch or 1 mm), and all the paint within that area can be removed and collected, it is possible to also report the results in mg/cm2. All of the sample must be placed in a hard-shelled container for shipment to the laboratory. The hard-shelled container is used since the laboratory will analyze the entire sample submitted. The exact dimensions of the areas sampled must be recorded on the filed sampling form. For mg/cm2, including a small amount of substrate in the sample is permitted.

D. Cleanup and repair

(1) All settled dust generated must be cleaned up using wet wipes.

(2) The surface can be resealed with new paint if necessary. If desired, apply spackling and/or new paint to repair the area where paint was removed.

(3) Personnel conducting paint sampling should avoid hand-to-mouth contact (specifically, smoking, eating, drinking, and applying cosmetics) and should wash their hands with running water immediately after sampling. The lead inspector should ask to use the resident's bathroom for this purpose. Wet wipes may be used if no running water is available or if the bathroom is not available.

E. Laboratory submittal. The samples should be submitted to a laboratory accredited by the EPA National Lead Laboratory Accreditation Program. Appropriate sample submittal forms should be used. The field sample number should appear on the field sampling form, the laboratory submittal form, and the container label. The name of the laboratory, the date the samples were sent to the lab, and all personnel handling the sample from the time of collection to the time of arrival at the laboratory should be recorded on a chain of custody form, if appropriate.

F. Other information. See ASTM E1792-03 (2016) and ASTM E1645-16 for additional information.

3. Soil Sampling Protocol

A. Collection technique general description

(1) Bare soil samples are typically collected with a coring device or a scooping technique. The device may be used in either of two ways. Most coring devices come equipped with a "T" handle which can be attached to the top of the coring tool or probe. This allows the sample collector to push the tool into the ground. The coring tool can be twisted with the "T" handle as it is pushed into the ground in order to allow the cutting edge of the soil probe to cut through roots and packed earth. In softer soils, a disposable new plastic syringe at least 1/2 inch diameter can be used for each composite sample.

(2) The other method for using the coring tool is to attach a hammer device to the top of the coring tool. To utilize the coring tool in this manner, the hammer device is first attached to the top of the coring tool and the tip of the probe is placed on the ground where the sample is to be collected. The hammer is then raised and allowed to fall while it is guided by the sample collector's hands. The hammer attachment may be the most appropriate tool when the nature of the soils is hard and compacted. Otherwise the "T" handle is easier to use.

(3) The soil samples are collected by driving or pushing the coring tool into the ground. The tool is then moved gently from side to side to loosen a plug of soil. The tool is then pulled from the ground and the soil sample is pushed so that the upper part of the soil plug lies between one-inch marks made on the coring device. The top one-half inch of the soil sample is then cut from the core with a stainless steel knife or cutting tool provided for that purpose. This top one-half inch section of the soil core is then transferred to a sample container. All sub-samples are collected in this manner. The collection of sub samples from the sampling line is referred to as a "composite" sample.

(4) After collecting a composite sample, the soil probe should be decontaminated or discarded if disposable core liners are used. This process consists of wiping the end of the probe with wet wipes until no more visible dirt is removed from the probe. Similar cores are then collected from the bottom inch of the four-inch core.

B. Materials and supplies

(1) Core sampling devices: Standard soil coring device. Other similar core sampling devices may be used, such as disposable plastic syringes with the end cut off. The plunger is used to remove the soil from the syringe body.

(2) Disposable wipes.

(3) Non-sterilized 5" x 8" plastic sealed baggies: Unless baggies are 4 mil industrial strength, samples must be double bagged.

(4) Non-sterilized non-powdered disposable gloves.

(5) Floor plan & property sketch.

(6) Soil sample collection form.

(7) Laboratory submittal form.

(8) Pre-printed labels or permanent ink pen.

(9) Trash bag or other receptacle. Do not use pockets or trash containers at the residence.

C. Bare soil sampling procedures

(1) Soil sampling is not recommended when the ground is frozen.

(2) The location of soil samples should be recorded on the exterior site plan sketch.

(3) Perimeter Sampling Locations: One composite soil sample should be collected so that at least 5 and no more than 10 different aliquots of surface soil are collected from the building perimeter. The aliquots should be collected from all sides of the building where bare soil is present. Each spot should be at least 2 feet distant from each other and 2 feet away from the foundation unless the bare soil is closer than 2 feet.

(4) Play Area Sampling Locations: A second composite sample should consist of at least 3 and not more than 10 aliquots collected along an X-shaped grid in the child's principal play area. Each spot should be at least 1 foot distant from each other. The soil where the aliquots are collected must be bare.

(5) The core sampling device should be used to deliver the top 1/2 inch of soil from each spot to the baggie. If paint chips are present, they should not be avoided and should be included in the sample. When sampling play areas, the lead inspector should make an effort to avoid including grass, twigs, stones, and other gross debris in the sample.

(6) When all aliquots of the composite sample have been placed in the baggie, the baggie should be zip locked or sealed. If the baggie is not 4-mil industrial weight, the sample should be double bagged. A label with the sample number should be affixed to the baggie. The number should be recorded on the soil platform showing the approximate location of each sample and the soil collection field data form.

(7) The core sampler should be cleaned with disposable wipes after each composite sample is collected. If a disposable core sampler is used, it can be used for all sub-samples, but not new composite samples unless it is cleaned thoroughly.

D. Laboratory submittal. Submittal Form Preparation. The sample numbers on the sample container must be the same as those on the field sampling form and must also be used on the laboratory submittal form. Confirm that all samples recorded on are in fact present on the laboratory submittal form. Chain of custody requirements should be followed if applicable.

E. Laboratory analytical procedure. Laboratories analyzing soil samples must participate in the Environmental Lead Laboratory Proficiency Testing Program or equivalent and be an EPA-NLLAP Accredited Laboratory.

F. Additional information. See ASTM E1727-20.

C.M.R. 06, 096, ch. 424, app 096-424-A