Compliance with 105 CMR 460.000 must begin with a lead inspection in all circumstances in which a Letter of Full Compliance is the goal, or with a risk assessment, whenever a Letter of Interim Control is the goal. There may be reasons for having a lead inspection or risk assessment performed other than to initiate the compliance process, such as for informational purposes. This is the case when a prospective purchaser exercises his or her right to have an inspection performed at the time of property transfer. Having an inspection performed does not in itself trigger any obligation to achieve compliance. Lead inspectors and risk assessors shall follow procedures outlined in inspector training and refresher training and in policies and procedures as determined by the Director, including:

1. (A) Providing pre-inspection information to the owner;
2. (B) Identifying surfaces covered with paint, other coating, plaster or putty;
3. (C) Testing surfaces with loose paint, other coating, plaster or putty at any height. If the surface is inaccessible to the inspector, it is the owner’s responsibility to either provide, in the presence of the inspector, a sample of the paint, other coating, plaster or putty, or bring the surface in question into compliance with the requirements of 105 CMR 460.110. Inspectors must also indicate if loose surfaces are eligible to be made intact under 105 CMR 460.175(B)(1)(b) or for encapsulation in accordance with 105 CMR 460.135(A).
4. (D) Testing moveable impact surfaces, accessible mouthable surfaces, and friction surfaces.

5. (E) Discovering of evidence of unauthorized deleading. Inspectors shall be observant for evidence of unauthorized deleading while conducting initial inspections, the lead determination enforcement procedure, lead determinations, reinspections or post-compliance assessments. Consult policies and inspector training materials approved by the Director for evidence to be considered. Upon discovery of such evidence, the inspector shall take the following basic steps, as well as follow the requirements of policies and educational materials issued by the Director:

   1. (1) Refuse to issue any Letter of Compliance or a Certification of Maintained Compliance or Restored Compliance.
   2. (2) Attempt to find out if there are any lead inspection reports, deleaders’ invoices or letters of compliance for the property.
   3. (3) Report evidence of unauthorized deleading to the State Program for investigation.
   4. (4) Complete the lead inspection report form, reinspection report form or post-compliance assessment report form, as applicable, and record signs of unauthorized deleading.