Lead is the one hazard where independence isn’t a philosophy we brought with us. For clearance testing, it is written into both Alabama regulation and federal law — the person who checks the work cannot be the person who did it.
Here, independence isn’t our preference. It’s the rule.
On our mold and asbestos work we make a point of the fact that we don’t remediate, because in those fields nothing forces the question. Lead is different. Two separate authorities say it outright.
“Clearance testing shall be performed by accredited persons or entities independent of those performing hazard reduction activities. If accredited in-house employees are used to conduct clearance testing, the in-house accredited employee shall not have played a part in performing that abatement work.”
Alabama Administrative Code r. 420-3-27-.13(1), “Independence/Conflict of Interest”
“Clearance examinations shall be performed by persons or entities independent of those performing hazard reduction or maintenance activities… An in-house employee shall not conduct both a hazard reduction or maintenance activity and its clearance examination.”
24 CFR 35.1340(f), HUD Lead Safe Housing Rule
Read those carefully, because the honest scope matters: they govern clearance — the test that says the work is finished and the space is fit to reoccupy. They don’t reach every lead inspection ever performed, and both contemplate an in-house employee doing clearance so long as that individual had no hand in the work itself.
What they establish is the principle. The rule-writers looked at a contractor certifying their own cleanup and decided it wasn’t acceptable. We simply don’t create the problem in the first place: AIM performs no lead abatement, bids none, and takes nothing from the firms that do. There is no job on which our conflict question is a close call.
What we’re certified and accredited to do
These are distinct credentials with distinct scopes, and the differences are the sort of thing that decides whether a report is worth anything. Ours:
| Credential | What it answers |
|---|---|
| Lead Inspector | Is lead-based paint present, and on which specific surfaces? A surface-by-surface answer — presence or absence, not risk. |
| Risk Assessor | Are there lead hazards, and where, and how bad? Covers deteriorated paint, dust and soil, plus clearance. Requires Inspector accreditation first. |
| Dust Sampling Technician | Clearance dust sampling following renovation and interim controls. It does not extend to post-abatement clearance — that requires an inspector or risk assessor, and we won’t pretend otherwise. |
Both halves of Alabama’s structure apply to us: AIM EH&S holds firm certification from the Alabama Department of Public Health, and the individual doing your work holds accreditation through the University of Alabama’s Safe State program. Firm certification is required even for inspection-only work — a firm without it cannot lawfully perform or even bid the job.
Where the lead rules actually bite
Most lead pages online lean on the pre-1978 date and imply the law forces your hand. It mostly doesn’t. The places it genuinely does:
Where the duty is real
The Lead Safe Housing Rule scales with the money. Up to $5,000 in federal assistance per unit: test the paint you’ll disturb, or presume it’s lead. Above $5,000 and up to $25,000: paint testing plus a risk assessment, with interim controls. Above $25,000: abatement territory. Paint testing must be done by a certified inspector or risk assessor.
Inspection and assessment
Public housing carries both an inspection and a risk assessment obligation. Note that for Section 8 / Housing Choice Voucher units the rule calls for a visual assessment — and HUD says plainly that a visual assessment alone is not an evaluation. If someone told you a walk-through satisfied the rule, it may not have.
After the work
Once hazard reduction is done, clearance decides whether the space can be reoccupied — and it’s the step where the independence rules above apply directly. In Alabama, clearance samples go to an approved laboratory; an XRF reading on the wall does not clear a job here.
What the Disclosure Rule does — and doesn’t — require
This is the most oversold claim in the business, so here it is straight. The federal Lead Disclosure Rule requires sellers and landlords of most pre-1978 housing to disclose lead information they already know, hand over the pamphlet, and give a purchaser a 10-day opportunity to have the property tested.
It does not require anyone to test. It does not require you to go find information you don’t have. The buyer can waive the opportunity, and buyers routinely do. Anyone telling you federal law mandates a lead inspection before a sale is either confused or selling you one.
What’s genuinely worth knowing is the other direction: under the HUD rule, a property inspected and found free of lead-based paint is permanently exempt from these requirements. For an owner with a pre-1978 portfolio, one clean inspection can end the question for that property for good. That is a real reason to test — and it’s a better one than a rule that doesn’t say what people think it says.
What we document
What we’ll put in writing
- Components tested, by room and surface, with the result for each
- Sampling rationale — why these locations, why this many
- Dust, soil and paint results as the laboratory reported them
- Chain of custody end to end
- Condition of the paint, not just its composition — intact lead paint and deteriorated lead paint are different problems
- Surfaces found negative, stated as clearly as the positives
What we won’t do
- Perform, bid, or manage the abatement or the renovation
- Clear our own work — we don’t do the work, so we never could
- Offer an opinion on anyone’s blood lead level or medical condition
- Clear an abatement project on a dust-technician ticket, or clear anything on an XRF reading
Credentials
- Lead firm certified by the Alabama Department of Public Health — required for lead inspection and risk assessment work in Alabama, including inspection-only firms.
- Personnel accredited through UA Safe State as Lead Inspector, Risk Assessor and Dust Sampling Technician, under the Alabama Lead Reduction Act. Numbers provided on request.
- Analysis by an NLLAP-recognized laboratory — Alabama’s rules require it, and we don’t own the lab.
- Independent by policy and by structure — no abatement arm, no removal bids, no referral arrangements.
- 20+ years in environmental compliance — built on regulated industrial work where documentation gets audited, not filed.
Areas we serve
AIM’s health services — mold and indoor air quality, asbestos, and lead — are delivered throughout South Alabama from our office in Jackson. We work across Mobile, Baldwin, Clarke, Monroe, Washington, Conecuh and Escambia counties and the surrounding Gulf Coast region. Property managers and owners with pre-1978 rental portfolios in the Mobile area are who this service is built for. If your property sits outside that footprint, ask — travel is quoted openly rather than buried in the price.
Frequently asked
Do you also do the lead removal?
No — and on the clearance side we couldn’t even if we wanted to. Alabama’s rules and HUD’s both require the person performing clearance to be independent of whoever performed the hazard reduction. We don’t abate, don’t bid it, and take nothing from the firms that do.
Does the law require me to test before I sell or rent?
No. This gets misstated constantly. The federal Disclosure Rule requires you to disclose what you know about lead in most pre-1978 housing, provide the pamphlet, and give a buyer a 10-day chance to test. It does not require testing, and buyers often waive it. If you want to test, the better reason is that a property found free of lead-based paint is permanently exempt from the requirements going forward.
What’s the difference between an inspection and a risk assessment?
An inspection answers “is there lead-based paint here, and on what?” — surface by surface, presence or absence. A risk assessment answers “is there a lead hazard, where, and how serious?” and looks at deteriorated paint, dust and soil. Intact lead paint on a windowsill nobody touches and the same paint on a friction surface that sheds dust into a child’s bedroom are the same inspection result and completely different risk findings. Tell us the decision you’re trying to make and we’ll tell you which one you need.
Can you clear the job after my contractor finishes?
Yes, and that’s precisely the work the independence rules were written for. Because we have no part in the hazard reduction, there’s no conflict to disclose or manage. One limit we’ll state up front: post-abatement clearance requires an inspector or risk assessor rather than a dust sampling technician, and in Alabama the clearance samples go to an approved laboratory — an XRF reading doesn’t clear a job here.
How quickly can you get out here?
Lead is the one service where we can’t promise same-day. Alabama requires written notice to ADPH at least three working days before any lead inspection or risk assessment, so the calendar has a floor built into it. We’ll give you a real date when you call rather than a date we’d have to walk back.
What does a lead inspection cost?
It’s quoted per property. A single-unit inspection, a risk assessment on an occupied rental, and clearance across a multi-unit building are different jobs with different sampling counts, and a headline price would just mean pricing most of them wrong. Describe the property and the decision you’re facing and you’ll get a real figure.
Not sure whether you need an inspection, a risk assessment, or clearance? Describe the property and who’s asking — we’ll tell you what the rules actually require, including when the answer is nothing. Talk to AIM or call (251) 308-5327.
This page describes federal and Alabama regulatory requirements in general terms for orientation only. It is not legal advice and is not a substitute for the rule text or for guidance from ADPH on a specific property. Requirements turn on facts — property age, occupancy, funding source and project scope — and nothing here should be read as an opinion on health effects or blood lead levels.