Lead paint repair invoices in voucher units: the photo shows a clean window sill, the clearance report shows the dust numbers

A housing authority inspector walks a 1960s unit rented to a voucher family with a toddler and notes peeling paint on two window sills and a door frame. Your painter fixes it and invoices for “lead-safe paint stabilization”, with photos: the sills scraped, then the sills freshly painted and wiped clean. The photos may be perfectly real. But lead dust is the hazard here, and it is invisible: a sill that looks spotless can fail a dust test. In HUD-assisted housing, the federal lead rule doesn’t treat the job as finished until someone independent of the painter has tested the dust and written a report. This piece covers what that report must hold and what to ask for before you pay. It is not legal advice.

Why the photo can’t answer the question

The job isn’t paint that looks good. It’s a unit that has been cleaned of lead dust after old paint was disturbed. A photo shows the first and can’t show the second. And one freshly painted white sill looks like another, in this unit or the one next door.

When HUD’s lead rule applies

The rule is 24 CFR part 35, from the U.S. Department of Housing and Urban Development. It covers housing that receives HUD assistance. It doesn’t apply to a residential property whose “construction was completed on or after January 1, 1978”, or to “A zero-bedroom dwelling unit”, and it has other exemptions, including most housing for the elderly (24 CFR 35.115).

For voucher units, the part that applies is subpart M, tenant-based rental assistance. It “applies only to dwelling units occupied or to be occupied by families or households that have one or more children of less than 6 years of age”, plus the common areas and exterior painted surfaces that go with them (24 CFR 35.1200). At the housing authority’s initial and periodic inspections, an inspector looks for deteriorated paint, and the owner has to stabilize it. If the family has already moved in, the work “must be completed within 30 days of notification” of the results, and the housing authority can extend that for reasonable cause, but not “beyond 90 days” (24 CFR 35.1215).

The sentence that matters most for your invoice: “Paint stabilization is considered complete when clearance is achieved in accordance with § 35.1340.” (24 CFR 35.1215(b)). Project-based and other HUD programs have their own subparts of part 35. We read only subpart M closely, so ask your HUD contact which subpart covers a property that isn’t a voucher unit.

The paper behind the job: the clearance report

A clearance examination includes “a visual assessment, dust sampling, submission of samples for analysis for lead in dust, interpretation of sampling results, and preparation of a report”. “Dust samples shall be wipe samples and shall be taken on floors and, where practicable, interior window sills and window troughs.” (24 CFR 35.1340(b)(2)). It must be done by a certified risk assessor, a certified lead-based paint inspector, or a trained or licensed sampling technician under the conditions the rule sets out (24 CFR 35.1340(b)(1)).

For stabilization and other work short of full abatement, the rule lists what the report must include (24 CFR 35.1340(c)). Among them:

• The address and, in a multifamily property, “the specific dwelling units and common areas affected”.
• “The name, address, and signature of each person performing the clearance examination, including certification number”.
• “The results of the analysis of dust samples, in µg/sq.ft., by location of sample”, and “The name and address of each laboratory that conducted the analysis”, with its EPA recognition number.
• “The start and completion dates of the hazard reduction or maintenance activity”, the firm that did it, “the name of each supervisor assigned”, and “A detailed written description of the hazard reduction or maintenance activity”, including the rooms and components worked on.

Two more parts of the rule are what make this paper worth more than the photo. First, independence: “Clearance examinations shall be performed by persons or entities independent of those performing hazard reduction or maintenance activities, unless the designated party uses qualified in-house employees to conduct clearance. An in-house employee shall not conduct both a hazard reduction or maintenance activity and its clearance examination.” (24 CFR 35.1340(f)). Second, failure has a consequence: “All surfaces represented by a failed clearance sample shall be recleaned or treated by hazard reduction, and retested” until they pass (24 CFR 35.1340(e)).

So the report is written by someone other than the painter, names a lab, gives a number for each sample location, and carries dates for both the work and the test. A photo of the painter’s own sill carries none of those.

Which dust levels pass

We found two tables, and we don’t settle how they fit together. HUD’s own table in 24 CFR 35.1320 still prints clearance levels of 40 µg/sq ft for floors, 250 for interior window sills and 400 for window troughs, and says risk assessors must use standards “at least as protective as” EPA’s. EPA’s rule for clearance after abatement, 40 CFR 745.227(e)(8)(viii), now reads: “On or after January 12, 2026, the action levels for lead in dust are 5” for floors, 40 for sills and 100 for troughs. If a report’s numbers matter to a decision, ask the risk assessor and your housing authority which levels it was judged against.

The notice to the family

The owner also has to give the occupants a notice “describing the results of the clearance examination” (24 CFR 35.1215(c)), “not more than 15 calendar days after the hazard reduction activities (including paint stabilization) have been completed” (24 CFR 35.125(b)(1)). It includes a summary of the work, its dates and its results, “including clearance”. If there is no clearance report, there is nothing true to put in that notice, which is a second reason to have the report in hand before the invoice is paid.

Small jobs: the de minimis line

“Clearance is not required if the work being cleared does not disturb painted surfaces of a total area more than” the de minimis levels (24 CFR 35.1340(b)). Those are “20 square feet (2 square meters) on exterior surfaces”, “2 square feet (0.2 square meters) in any one interior room or space”, or “10 percent of the total surface area on an interior or exterior type of component with a small surface area”, such as window sills, baseboards and trim (24 CFR 35.1350(d)). So a genuinely small touch-up may have no clearance report, and that is not a problem with the invoice. A bill priced like a large job with no clearance report is worth a question.

Checks before you pay

1. Ask for the clearance report for the unit, and check that the address and unit number match the invoice.
2. Compare the dates. The report gives the work’s start and completion dates and the date of the clearance examination. They should agree with the invoice, and the examination should come after the work.
3. Compare who did what. The firm on the invoice did the work. The person who signed the clearance should be someone else, with a certification number, unless your own qualified in-house employee did it, and even then not the same person who did the work.
4. Compare the rooms and components. The report’s written description of the work should cover the sills and frames the invoice bills for. Its dust sample locations should be in the rooms where the work was done.
5. If the report shows a failed sample, look for the retest. The rule requires recleaning and retesting until the surfaces pass. If you are billed for the recleaning, check that the retest is there too.
6. Ask for the original photo files, not pictures pasted into an invoice PDF, which have usually lost their camera record. Why, and how to ask for the originals.
7. Drop the photos in together with the same painter’s photos from other units. The checker marks any two files in the same batch that are the same file, even under different names. A “finished sill” reused from another apartment shows up that way. A new photo of the wrong sill won’t, which is why the clearance report matters more than the picture.

A gap here is a question, not a finding. The work may have been under the de minimis line; the clearance firm may send its report to you or the housing authority weeks after the painter invoices; and in a multifamily property where “more than 10 dwelling units of similar construction and maintenance” are cleared, the rule allows random sampling (24 CFR 35.1340(b)(2)(i)), so a unit may be covered without dust samples of its own.

What we don’t cover

Lead-safe work by painters in pre-1978 housing generally, outside HUD programs, falls under EPA’s renovation rule, which has its own records. Our piece on painting invoices and lead-safe records covers that. We didn’t cover full abatement in detail, risk assessments, or ongoing maintenance and reevaluation.

Whether someone used AI on the photos

A photo of a freshly painted window sill is easy to generate now, and some generators write a mark into the file saying so. The checker reads those marks in photos, and the notes some phone editors leave when generative AI was used to alter a photo. A file with no such mark is not proven real. Most fakes and most genuine photos look the same to a file reader once they have been through a chat app or a screenshot. And a genuine photo of a clean sill is still only a photo: the lab number on the clearance report is what says whether the dust is gone.

The limits, stated plainly

• We read 24 CFR 35.110, 35.115, 35.125, 35.1200, 35.1210, 35.1215, 35.1320, 35.1325, 35.1330, 35.1340 and 35.1350, and 40 CFR 745.227, on the eCFR, current to November 6, 2026, in November 2026.
• We did not read HUD’s Guidelines, any HUD notice or guidance, NSPIRE inspection standards, any housing authority’s policy, or any state lead rule. States with EPA-authorized programs may run certification themselves.
• We don’t say which dust levels a given clearance was judged against. See above.
• Who is responsible for the work, the clearance and the notice is set by the rule and your HAP contract, and we don’t answer it for you.
• A clearance report shows someone certified tested the dust on a given day. It doesn’t show the price was fair or that the paint will stay intact.
• Our example is made up. We don’t know how often lead paint invoices are padded.
• A photo with no camera record is not a fake. Text messages, chat apps and many portals remove the record from genuine photos every day.
• Our checker gives no confidence score and does not judge a picture by looking at it. It reads what is in the file, in your browser, and uploads nothing. A file with no AI marker is not proven real.
• This is not legal advice.

Related: voucher repair photos instead of a reinspection, and radon mitigation invoices and the follow-up test.

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