Skip to main content
California Department of Education Logo

Flow Chart for Lead-Based Paint and PCBs

This is a linear list of the flowchart for lead-based paint/polycholrinated biphenyls (PCBs) and Department of Toxic Substance Controls determinations that are necessary of California Department of Education final approval.
This is an Accessible Version of the flowchart (PDF) for lead-based paint. The Adobe Acrobat Portable Document should be the preferred version for downloading.

This is a flowchart depicting the process districts are required to follow when seeking California Department of Education (CDE) final approval and Department of Toxic Substances (DTSC) determinations when lead-based paint/polychlorinated biphenyls (PCBs) are involved.

Disclaimer: This is a linear list of the decisions from the flowchart and it may not represent the actual flow of information.

Phase 1 without lead-based paint or PCB sampling data, may conclude further investigation is required for only lead/PCB. District submits to DTSC with $1,500.

DTSC approves Phase 1, determines "No Action" required.

Phase 1 without lead-based paint or PCB sampling data, may conclude further investigation is required for only lead/PCB. District submits to DTSC with $1,500.

DTSC approves Phase 1, determines further investigation is required for only lead/PCB via Phase 1 addendum. District commits in writing to do lead/PCB addendum.

District conducts sampling before grading and submits lead/PCB Phase 1 addendum to DTSC.

DTSC approves lead/PCB Phase 1 addendum and determines "No Action" is required.
or
DTSC determines Preliminary Endangerment Assessment (PEA) is required for lead/PCB only.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

Back to top

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 without lead-based paint or PCB sampling data, may conclude further investigation is required for only lead/PCB. District submits to DTSC with $1,500.

DTSC determines Phase 1 is equivalent to a lead/PCB only PEA. District commits in writing to do PEA.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

Back to top

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 without lead-based paint or PCB sampling data, may conclude further investigation is required for only lead/PCB. District submits to DTSC with $1,500.

DTSC determines PEA is required for lead/PCB only. District commits in writing to do PEA.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 without lead-based paint or PCB sampling data, may conclude further investigation is required for only lead/PCB. District submits to DTSC with $1,500.

DTSC concurs PEA is required for lead/PCB and other substance(s).

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

Back to top

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 with lead-based paint or PCB sampling data concludes no further investigation is required. District submits to DTSC with $1,500.

DTSC approves PHASE 1, determines "No Action" required.

Phase 1 with lead based paint or PCB sampling data concludes no further investigation is required. District submits to DTSC with $1,500.

DTSC approves Phase 1, determines further investigation is required for only lead/PCB via Phase 1 addendum. District commits in writing to do lead/PCB addendum.

District conducts sampling before grading and submits lead/PCB Phase 1 addendum to DTSC.

DTSC approves lead/PCB Phase 1 addendum and determines "No Action" is required.
or
DTSC determines Preliminary Endangerment Assessment (PEA) is required for lead/PCB only.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Back to top

Phase 1 with lead-based paint or PCB sampling data concludes no further investigation is required. District submits to DTSC with $1,500.

DTSC determines Phase 1 is equivalent to a lead/PCB only PEA. District commits in writing to do PEA.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 with lead-based paint or PCB sampling data concludes no further investigation is required. District submits to DTSC with $1,500.

DTSC determines PEA is required for lead/PCB only. District commits in writing to do PEA.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

Back to top

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 with lead-based paint or PCB sampling data concludes no further investigation is required. District submits to DTSC with $1,500.

DTSC concurs PEA is required for lead/PCB and other substance(s).

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

Back to top

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 with or without lead/PCB data concludes PEA is required for lead and/or PCBs and possibly other substance(s). With DTSC concurrence, District skips Phase 1 review.

DTSC approves Phase 1, determines further investigation is required for only lead/PCB via Phase 1 addendum. District commits in writing to do lead/PCB addendum.

District conducts sampling before grading and submits lead/PCB Phase 1 addendum to DTSC.

DTSC approves lead/PCB Phase 1 addendum and determines "No Action" is required.
or
DTSC determines Preliminary Endangerment Assessment (PEA) is required for lead/PCB only.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

Back to top

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 with or without lead/PCB data concludes PEA is required for lead and/or PCBs and possibly other substance(s). With DTSC concurrence, District skips Phase 1 review.

DTSC determines Phase 1 is equivalent to a lead/PCB only PEA. District commits in writing to do PEA.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 with or without lead/PCB data concludes PEA is required for lead and/or PCBs and possibly other substance(s). With DTSC concurrence, District skips Phase 1 review.

Back to top

DTSC determines PEA is required for lead/PCB only. District commits in writing to do PEA.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 with or without lead/PCB data concludes PEA is required for lead and/or PCBs and possibly other substance(s). With DTSC concurrence, District skips Phase 1 review.

DTSC concurs PEA is required for lead/PCB and other substance(s).

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Back to top

Questions:   School Facilities and Transportation Services Division| sftsd@cde.ca.gov | 916-322-2470
Last Reviewed: Wednesday, May 28, 2025
Trending in School Facilities
Recently Posted in School Facilities
  • The Guide to Long-Range Facilities Master Plans (updated 10-Nov-2026)
    The Guide to Long-Range Facilities Master Plans (LRFMP) was revised in 2026, with updated guidance on master planning for local educational agencies and Proposition 2 requirements for school districts applying for School Facility Program Funding.
  • Key Components of a Facilities Master Plan (added 10-Nov-2026)
    The elements of a typical facilities master plan (FMP) and guidance on what to include, how to organize the information, and why it matters, from the Guide to Long-Range Facilities Master Plans.
  • Conclusion (added 10-Nov-2026)
    A summary on master plans as living documents that reflect thoughtful educational goals and future planning, from the Guide to Long-Range Facilities Master Plans.
  • Education Programs with Specialized Facility Needs (added 10-Nov-2026)
    The importance of including specialized facilities in facilities master plans to meet the needs of educational programs and students with disabilities, from the Guide to Long-Range Facilities Master Plans.
  • Additional Considerations and Planning the Future (added 10-Nov-2026)
    Integrating sustainability, safety, accessibility, and climate resiliency into every stage of facilities master planning, from the Guide to Long-Range Facilities Master Plans.

  • Appendix A (added 10-Nov-2026)
    A table of Facilities Master Plan Elements vs. Proposition 2 Requirements, from the Guide to Long-Range Facilities Master Plans.
  • Appendix B (added 10-Nov-2026)
    A summary of additional required elements per Proposition 2, from the Guide to Long- Range Facilities Master Plans.
  • Facilities Master Planning Resources (added 10-Nov-2026)
    Additional resources, facilities master plan (FMP) exemplars, and links to the Office of Public School Construction (OPSC) Guidelines for the Five-Year School Facilities Master Plan, from the Guide to Long-Range Facilities Master Plans.
  • Introduction (added 10-Nov-2026)
    An introduction of the Guide to Long-Range Facilities Master Plans.
  • Facilities Master Planning Process (added 10-Nov-2026)
    Best practices for launching a facilities master planning (FMP) effort, engaging stakeholders, and long-term planning, from the Guide to Long-Range Facilities Master Plans.