Do I need an US EPA Recognized Test Kit to test for lead?
Long story long- It depends.
It depends on really only one thing, if your trying to comply with the RRP rule.
You may be wondering, why does the importance of an EPA recognized test kit hinge complying with a law.
to understand lets look at what this rule is and establish some baseline on how lead poisoning prevention fits into federal regulations.
Lead Renovation, Repair and Painting Rule (RRP)
The US Environmental Protection Agency (EPA) has established standards for lead test kits used to detect lead-based paint. These standards are part of the Lead Renovation, Repair and Painting (RRP) Rule, which aims to protect individuals, especially children, from lead exposure during renovation activities in homes built before 1978 and in child-occupied facilities.
The law requires all people who renovate properties built before 1978 to become certified renovators, attend training with the EPA, keep records of their activities and most importantly gives them the ability to test properties for lead based paint.
This is important because
EPA lead test kits were recognized only once in 2010, this was at the time free to manufactures and required them only to submit a sufficient number of tests to a contracted laboratory
Kits recognized in 2010 had to meet the following criteria
- Negative Response Criterion: The kit must reliably indicate a negative result (no lead detected) for lead-based paint when the lead concentration is below the regulated level with 95% accuracy.
As of now, three kits are recognized by the EPA for their reliability in detecting lead-based paint under specific conditions and only by trained operators:
1. 3M™ LeadCheck™: Effective on wood, ferrous metal, drywall, and plaster. 3M suspended the production and sale of this kit in late 2023.
2. D-Lead®: Effective on wood, ferrous metal, drywall, and plaster.
3. State of Massachusetts Kit: Effective on drywall and plaster, but not recognized for use on wood or ferrous metal.
Lets take a look at the results these test kits got, lets use LeadCheck as an example.
As you can probably see the results are pretty striking, LeadCheck predicted a positive result over 50% of the time when there was ZERO LEAD
Now lets look at an example of EPA's requirements for a lead test kit post 2010
After 2010 EPA Recognized test kits needed to meet a second criteria, the Positive Response Criterion in addition to the Negative Response Criterion
Which states
- Positive Response Criterion: This ensures the kit does not produce false positives when lead is present at levels below the regulatory threshold with 90% accuracy.
Lets take a look at this requirement on paper.
None of the currently recognized test kits could meet this requirement, the requirement states specifically that the test kit needs to identify levels of lead on a surface area basis.
Below is a breakdown of the other methods for complying with RRP and their costs.
- Laboratory Testing: Sending paint chip samples to a National Lead Laboratory Accreditation Program (NLLAP) certified lab for analysis. 30-100$
- Certified Inspector: Hiring a certified lead-based paint inspector or risk assessor to perform the testing. 200-400$
- Assumption of Lead Presence: Assuming that lead-based paint is present and following all lead-safe work practices without testing. 300-5000$
assuming lead safe work practices can be costly if there is no lead present and and the job is large, for this reason its common practice to use EPA recognized test kits.
However if anyone used an unrecognized test kit, like fluorospec, which has no false positives for any substances which aren't lead, they could use it to inform them there is lead present and fall under the category of assumption of lead presence. Saving money while complying with the rules.
If contractors follow the rules, obey lead safe work practices and and keep adequate records they are excused from liability if anyone gets poisoned form jobs they work on.
For more information on EPA recognized lead test kits and guidelines, you can visit the EPA's official page on lead test kits.
At the end of the day EPA's obligations are to everyone, its a huge job and every action they take has a cost to many, driving up cost and complexity. I commend the EPA's fine workforce for doing their best on the issue of lead, which to put mildly is an ongoing problem.
If you suspect contamination, or that you are being exposed to a source of lead , I encourage you to test it. Fluorospec is the lowest cost, most accurate lead testing kit on the market, the dust detection abilities alone are worth 50$ a spray. Sometimes new technology is really just THAT big of a leap forward, and i hope everyone who needs to use it gets it.
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