On June 22, 2018 the Schubert Center submitted comments on the Ohio Department of Health’s new Lead-Safe Rental Registry Rules. In the letter we raised several concerns regarding the proposed rules. The critical issue is that while lead contamination is mostly invisible the proposed rules do not require lead testing, but will accept a visual inspection of the property. We recommended that lead inspections for inclusion on the registry must require dust sample testing for the presence of lead. We also recommended that language be included in the rules to ensure that the implementation and maintenance of the registry is monitored for quality assurance purposes.