Wayne's World

EPA-Recognized Test Kits

Currently, a lead test kit can be EPA-recognized if it meets the negative response criterion of no more than 5 percent false negatives, with 95 percent confidence for paint containing lead at or above the regulated level, 1.0 mg/cm² or 0.5 percent by weight. After September 1, 2010, the recognition of such kits will last until EPA publicizes its recognition of the first test kit that meets both the negative response and positive response criteria outlined in the 2008 Renovation, Repair and Painting (RRP) rule. (See below for preliminary results of EPA’s evaluation of test kits for both the negative response and positive response criteria.)

To date, EPA has recognized two currently available lead test kits, with limitations. They are the LeadCheck® kit and the State of Massachusetts kit.

• EPA recognizes that, when used by a certified renovator, the LeadCheck® lead test kit can reliably determine that regulated lead-based paint is not present on all surfaces except plaster and drywall. Certified inspectors, renovators, and risk assessors seeking to use the LeadCheck® kit for purposes of meeting requirements in the Renovation, Repair, and Painting Rule can purchase the LeadCheck® kits from either LeadCheck® directly or from certain retail outlets. LeadCheck® is manufactured by Hybrivet Systems, Inc.    To order a Hybrivet System LeadCheck® test kit call 508-651-7881 or e-mail Hybrivet at info@leadcheck.com.

Check back regularly for any updates or new products which may be approved by the EPA.

Wayne

There hasn’t been much said about the requirements for schools to have certified renovators.  However, with school just around the corner, administrations in various schools need to know the answer to this question.

Must maintenance workers at kindergartens and elementary schools become certified renovators if they perform renovations covered by the Renovaton, Repair, and Painting (RRP) Rule in the portions of the school that are child-occupied facilities?  Are the schools or school systems then required to become certified renovations firms?

Answer:  On or after April 22, 2010, all renovations covered by the RRP Rule must be directed by certified renovators and must be performed by certified renovators or individuals trained by a certified renovator. The RRP rule requires any firm, including a local government agency, that performs, offers, or claims to perform renovations to be certified by EPA.

Firms performing tasks that disturb no painted surfaces whatsoever do not need to be certified.  However, since conditions at the job site may be difficult to predict, EPA strongly recommends that all firms involved in the renovation be certified and use properly trained and certified personnel.  For example, a firm hired to install an HVAC system after demolition of painted surfaces has taken place may find that to complete the job painted surfaces need to be disturbed.  The HVAC firm may not engage in activities that disturb painted surfaces if it is not certified.

As every renovation job is different, it is up to the firm acting as the general contractor to determine what activities are within the scope of the renovation and to ensure that other firms are properly trained and certified for the tasks they will be performing.  All firms, including the firm acting as the general contractor, are responsible for making sure the renovation is performed in accordance with the work practice standards, including keeping containment intact and making sure lead dust and debris do not leave the work site.   General contractors should keep in mind that if a firm hires a subcontractor that fails to follow the work practice standards or otherwise violates the Renovation, Repair, and Painting rule, the firm that hired the subcontractor is also responsible for the violation.

Wayne Pope