47-Doc 00 73 00 12 - Appendix E - lead rpt-final.pdf
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- 124 Easton Road Demolition 25-01189. 01
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- Pennsylvania
About this file
This is a Lead-Based Paint Inspection Report prepared by Criterion Laboratories, Inc. for Horsham Township, Pennsylvania, documenting the presence of lead-based paint at 124 Easton Road in Horsham, Pennsylvania. The inspection was conducted on November 6, 2025, by Michael Martin, a Pennsylvania-licensed Risk Assessor, and involved testing nine apartment units for lead-based paint using an X-550 Lead Paint Analyzer. The analysis identified lead-based paint (defined as 1.0 milligrams per square centimeter or greater) on various interior and exterior painted surfaces throughout eight of the nine units tested, with Unit B-5 showing no lead-based paint detection. Tested surfaces included baseboards, door casings, door jambs, and other wood components in living areas, bedrooms, bathrooms, hallways, and basement storage areas, with paint colors ranging from white to red and grey.
The report establishes that all identified lead-based paint surfaces were rated as intact in condition, classified as either friction or non-friction surfaces. The findings indicate that if renovation or painting activities disturb lead-based paint, work must comply with the EPA's Renovation, Repair, and Painting Program Final Rule (40 CFR Part 745) and OSHA regulations (29 CFR Part 1926.62), requiring certified individuals and firms to employ lead-safe work practices. The report notes that recommendation codes do not apply to the buildings as they are scheduled for demolition, and the facility owner/operator will be responsible for testing debris during demolition to determine whether it should be disposed of as hazardous or non-hazardous waste using the Toxicity Characteristic Leaching Procedure (TCLP) with a lead threshold of 5 parts per million.
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Text version
400 Street Road, Bensalem, PA 19020 / 215-244-1300 / Fax 215-244-4349 www.criterionlabs.com
At:
124 Easton Road Horsham, PA 19044
For:
Mr. Larry Burns Horsham Township 1025 Horsham Road Horsham, PA 19044
Prepared By:
Mr. Eric Wysocki Senior Project Manager
Report Date:
November 14, 2025
Project Number:
254068
Date of Project:
November 6, 2025
LEAD-BASED
PAINT
INSPECTION
Field Services
Lab
Training
Lead-Based Paint Inspection Report Horsham Township Criterion Laboratories, Inc.
TABLE OF CONTENTS
1.0 Executive Summary
2.0 Findings And Recommendations
Attachments
Testing Report Legend Calibration Check Test Results XRF Testing Report Sheets License Documentation
1.0 EXECUTIVE SUMMARY
Criterion Laboratories, Inc. (Criterion) was requested to perform a Lead-Based Paint Inspection of nine (9) apartment units located at 124 Easton Road in Horsham, Pennsylvania (the “Property”). The purpose of the inspection was to explore the presence of painted surfaces for lead-based throughout the property.
Mr. Michael Martin, a PA-licensed Risk Assessor for Criterion, performed the inspection on November 6, 2025.
Painted surfaces were analyzed for lead using an X-550 Lead Paint Analyzer manufactured by SciAps.
The U.S. Department of Housing and Urban Development (HUD) considers 1.0 milligrams of lead per square centimeter of painted surface, or greater, to be lead based paint ( 1.0 mg/c m²).
2.0 FINDINGS AND RECOMMENDATIONS
During the inspection, the presence of lead-based paint was detected on various surfaces on the on the property, (refer to Attachments). No lead-based paint was detected in Unit B-5. Listed on the attached sheets (Attachments) are location and components for the areas where painted surfaces were sampled. A summary of the locations/components testing positive for lead-based paint is included in the following table. You will find a legend in the Attachments Section, which will explain the codes used in this table.
The Environmental Protection Agency’s (EPA) Renovation, Repair, and Painting Program Final Rule (40 CFR Part 745) (RRP Rule) mandates that if lead-based paint is disturbed during renovation or painting activity then the work should be completed using lead-safe work practices as defined in the RRP Rule. In addition, the individual disturbing the lead-based paint has to be certified as well as the firm with whom he/she is employed.
Any painted surface that has lead content should not be sanded, demolished or disturbed without the proper engineering controls and work methods, as spelled out under the OSHA’s 29 CFR Part 1926.62 Lead Exposure in Construction, Interim Rule. Improper disturbance of any paint with lead content can cause lead to become airborne. The emphasis on controlling lead dust derives from the conclusion that lead dust appears to be the primary route of exposure to lead, especially of low-level exposure.
It is therefore important that occupants of the building and any contractors be made aware of the presence of the lead-based paint and the potential health risks associated with the ingestion of lead-based paint or the associated dust that results from the damaging of the painted surfaces.
Occupants and/or contractors should also be made aware of the importance of not damaging the painted surfaces and creating loose and flaking paint or the creation of dust. If the painted surfaces are damaged this should be reported to the proper building representative/maintenance personnel to properly correct the problem to prevent an increased exposure potential.
Please note that recommendation codes have not been listed as they don’t apply to the buildings inspected testing positive for lead, as they will be demolished. During demolition activity, the facility owner/operator is responsible for testing the actual debris to determine if it should be disposed of as hazardous or non-hazardous waste. Waste toxicity is measured by using the Toxicity Characteristic Leaching Procedure (TCLP) (40 CFR 261.24).
The TCLP extract is analyzed for lead (or other constituents) to determine if it is above or below the allowable Toxic Characteristic (TC) regulatory threshold, which for lead is 5 parts per million (ppm) or milligrams per liter (mg/l).
The following is a list of paints that tested positive for lead content.
124 Easton Road, Horsham, PA
Color/Substrate/
Location Component Surface/Condition
Unit A-1
Living Room/Dining Room White/Wood/Baseboard Non-Friction/Intact
Bedroom Door White/Wood/Door Casing Non-Friction/Intact
Bedroom Door White/Wood/Door Jamb Friction/Intact
Bedroom Closet Door White/Wood/Door Casing Non-Friction/Intact
Bathroom White/Wood/Door Casing Non-Friction/Intact
Bathroom White/Wood/Door Jamb Friction/Intact
Bathroom Closet Door White/Wood/Door Casing Non-Friction/Intact
Bathroom Closet Door White/Wood/Door Jamb Friction/Intact
Hallway White/Wood/Baseboard Non-Friction/Intact
Entry Red/Wood/Door Jamb Friction/Intact
Entry Red/Wood/Door Casing Non-Friction/Intact
Unit A-2
Living Room/Dining Room White/Wood/Baseboard Non-Friction/Intact
Bedroom White/Wood/Baseboard Non-Friction/Intact
Bedroom White/Wood/Door Casing Non-Friction/Intact
Bedroom White/Wood/Door Jamb Friction/Intact
Bedroom Closet Door White/Wood/Door Jamb Friction/Intact
Unit A-2 (continued)
Bathroom White/Wood/Door Jamb Friction/Intact
Bathroom White/Wood/Door Casing Non-Friction/Intact
Hall Closet White/Wood/Door Jamb Friction/Intact
Hall Closet White/Wood/Door Casing Non-Friction/Intact
Hallway White/Wood/Baseboard Non-Friction/Intact
Entry Red/Wood/Door Casing Non-Friction/Intact
Entry Red/Wood/Door Jamb Friction/Intact
Unit A-3
Bedroom Closet Door White/Wood/Door Casing Non-Friction/Intact
Bedroom Closet Door White/Wood/Door Jamb Friction/Intact
Unit A-4
Bedroom White/Wood/Door Jamb Friction/Intact
Bedroom White/Wood/Door Casing Non-Friction/Intact
Bedroom Closet Door White/Wood/Door Jamb Friction-Intact
Bedroom Closet Door White/Wood/Door Casing Non-Friction/Intact
Hall Closet White/Wood/Door Jamb Friction/Intact
Hall Closet White/Wood/Door Casing Non-Friction/Intact
Entry Grey/Wood/Exterior Door Casing Non-Friction/Intact
Hall/Stairwell A-3/A-4
Stairs Grey/Wood/Stair Stringer Non-Friction/Intact
Hall Grey/Wood/Door Casing Non-Friction/Intact
Exterior Door Red/Wood/Door Casing Non-Friction/Intact
Basement Beneath A Units
Storage Room Green/Wood/Door Non-Friction/Intact
Storage Room Green/Wood/Door Jamb Friction/Intact
Storage Room Green/Wood/Door Casing Non-Friction/Intact
Exit Door White/Wood/Door Non-Friction/Intact
Basement Beneath A Units
Exit Door White/Wood/Door Jamb Friction/Intact
Exit Door White/Wood/Door Casing Non-Friction/Intact
Interior Exit Door White/Wood/Door Jamb Friction/Intact
Exterior Door Red/Wood/Door Casing Non-Friction/Intact
Unit B-1
Bedroom Closet Door White/Wood/Door Jamb Friction/Intact
Bedroom Closet Door White/Wood/Door Casing Non-Friction/Intact
Bedroom White/Wood/Door Casing Non-Friction/Intact
Bedroom White/Wood/Door Jamb Friction/Intact
Bathroom White/Wood/Door Casing Non-Friction/Intact
Bathroom White/Wood/Door Jamb Friction/Intact
Bathroom Closet Door White/Wood/Door Casing Non-Friction/Intact
Bathroom Closet Door White/Wood/Door Jamb Friction/Intact
Entry Red/Wood/Door Casing Non-Friction/Intact
Entry Red/Wood/Door Jamb Friction-Intact
Unit B-2
Bedroom Closet Door White/Wood/Door Casing Non-Friction/Intact
Bedroom Closet Door White/Wood/Door Jamb Friction/Intact
Bedroom White/Wood/Door Casing Non-Friction/Intact
Bedroom White/Wood/Door Jamb Friction/Intact
Bathroom White/Wood/Door Casing Non-Friction/Intact
Bathroom White/Wood/Door Jamb Friction/Intact
Hallway White/Wood/Baseboard Non-Friction/Intact
Hall Closet White/Wood/Door Jamb Friction/Intact
Hall Closet White/Wood/Door Casing Non-Friction/Intact
Entry Red/Wood/Door Jamb Friction/Intact
Entry Red/Wood/Door Casing Non-Friction/Intact
Unit B-3
Living Room/Dining Room White/Wood/Baseboard Non-Friction/Intact
Bedroom White/Wood/Baseboard Non-Friction/Intact
Bedroom White/Wood/Door Casing Non-Friction/Intact
Bedroom White/Wood/Door Jamb Friction/Intact
Bedroom Closet Door White/Wood/Door Casing Non-Friction/Intact
Bedroom Closet Door White/Wood/Door Jamb Friction/Intact
Bathroom White/Wood/Door Jamb Friction/Intact
Bathroom White/Wood/Door Casing Non-Friction/Intact
Hallway White/Wood/Door Baseboard Non-Friction/Intact
Hall Closet Door White/Wood/Door Casing Non-Friction/Intact
Hall Closet Door White/Wood/Door Jamb Friction/Intact
Unit B-4
Bedroom White/Wood/Door Casing Non-Friction/Intact
Bedroom White/Wood/Door Jamb Friction-Intact
Bedroom Closet Door White/Wood/Door Casing Non-Friction/Intact
Bedroom Closet Door White/Wood/Door Jamb Friction/Intact
Bathroom White/Wood/Door Jamb Friction/Intact
Bathroom White/Wood/Door Casing Non-Friction/Intact
Hall Closet White/Wood/Door Jamb Friction/Intact
Hall Closet White/Wood/Door Casing Non-Friction/Intact
Entry Grey/Wood/Door Casing Non-Friction/Intact
Entry White/Wood/Door Jamb Friction/Intact
ATTACHMENTS
Testing Report Legend
Recommendations
HR – Hazard Reduction
It is recommended that these surfaces be periodically observed for chalking, peeling or cracking.
If the surface is chalking, it can be cleaned with Trisodium Phosphate and repainted. If it is peeling or cracking, it should be repaired or abated.
AR – Abatement Replacement
A strategy of abatement that entails the removal of building components coated with lead-based paint and installation of new components free of lead-based paint.
A Encp – Abatement Encapsulation
“Encapsulant” means a coating or rigid material that relies on adhesion to a lead-based paint surface and is not mechanically fastened to the substrate with a 20-year warranty.
“Encapsulation” means a process to make lead-based paint inaccessible by providing a barrier between the lead-based paint and the environment, where the primary means of attachment for the encapsulant is bonding of a product to the surface covered either by the product itself or through the use of an adhesive.
A Encl – Abatement Enclosure
“Enclosure” means the installation of a rigid, durable barrier that is mechanically attached to building components, with all edges and seams sealed with caulk or other sealant and having a design life of at least 20 years.
CA – Complete Abatement
A process designed either to permanently eliminate lead-based paint hazards on a component and includes, but is not limited to: the removal of lead-based paint and lead-contaminated dust.
OSHA
Any painted surface that has lead content should not be sanded, demolished or disturbed without the proper engineering controls and work methods. As spelled out under OSHA’s CFR Part 1926 Lead Exposure in Construction, Interim Rule. Improper disturbance of any paint with lead content can cause lead to become airborne.
NA – Non-applicable
X-ray Fluorescence Spectrometer (XRF) results indicated 0.0 or below, which indicates no lead detected by the XRF Spectrometer.
Surface/Condition
Surface
A determination of whether a painted surface is considered friction/impact surface or non-friction impact surface.
Friction/Impact Surface – any interior or exterior surface subject to abrasion, friction or damage by repeated impact or contact.
Non-friction/Impact Surface – any interior or exterior surface not subject to abrasion, friction or damage by repeated impact or contact.
Condition
An intact good paint surface is smooth, continuous and free of surface defect, which would result in the release of paint dust or chips.
Large surfaces such as walls, floors and ceilings should be rated as follows:
Good or intact condition shall indicate a surface that is entirely intact;
Fair condition shall indicate a surface where less than or equal to two square feet of surface are not intact;
Poor condition shall indicate a surface where more than two square feet of surface are not intact.
Components without large surfaces, such as window sills, baseboards, or other small areas, shall be rated as follows:
Good or intact condition shall indicate that the surface is entirely intact;
Fair condition shall indicate that less than or equal to 10 percent of the surface is not intact;
Poor condition shall indicate that more than 10 percent of the surface is not intact.
Exterior components with large surface areas shall be rated as follows:
Good or intact condition shall indicate that the surface is entirely intact;
Fair condition shall indicate that less than or equal to ten square feet of surface is not intact;
Poor condition shall indicate that more than ten square feet of surface is not intact.
Wall
When entering a room the wall that is the address side of the room is labeled as “A” Wall. The walls are then labeled in a clockwise fashion as “B” Wall and “D” Wall.
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