EPA Approved RRP Testing Kits & Procedures

[SLS-Construction]

First the facts, there are only 2 ways out of testing for lead in a house built before 1978; you either have in your hands a certified report from a licensed lead inspector that no lead is present in the area you are working on, or you automatically assume lead is present and follow all the containment and work rules issued by the EPA. (Article: Should you test or not) (http://blog.sls-construction.com/?p=443)

As a CLR (Certified Lead Renovator) you only have one testing method available to you and that is to use a lead swab kit approved by the EPA. At this time, there are two approved kits, but only 1 is available to CLR's. The second kit is only available to certified Massachusetts state lead inspectors and risk assessors. As more kits or manufacturers are approved they will be listed here: http://www.epa.gov/oppt/lead/pubs/kits.htm

The only generally available kit at this time is the LeadCheck (http://www.leadcheck.com/)® system produced by Hybrivet. The general steps to test for lead in paint:



If dirty, clean the surface with a household cleaner, rinse and dry.
Cut a small V-shaped notch (about ¼ inch long) to expose all painted layers down to the bare surface.
Activate a LeadCheck Swab® according to the instructions.
Rub the activated Swab into the notch for 30 – 60 seconds.
Examine the Swab tip and/or test surface for a color change to pink or red.
*If testing paint on commercial structures, (which may have lead chromate paint), wait several hours to check for color change.
The full steps are listed here http://www.leadcheck.com/PB-15Paint.shtml

EDIT: While LeadCheck can be used on on plaster or drywall per the manufacturers directions located here: http://www.leadcheck.com/PB-08Plaster.shtml - the EPA will not recognize the result... (See posting below made 1.15.10)

Speaking of bad training information, many people have reported that during training many trainers deemed the swabs as untrustworthy are not required to meet X standard. The standard they are slamming is the minimum standard that must be reached for approval. Just because a vendor is listed does not mean that they do not exceed those standards. Information on LeadCheck's testing - http://www.leadcheck.com/3rdParty.pdf so you can decide for yourself if they are as bad as some insist.

The EPA is trying to allow the greatest amount of vendors a chance to develop and manufacture a valid testing kit for use and has phased in a two step process which can be found here http://www.epa.gov/lead/pubs/overview.htm. The second phase of testing and the approvals will be completed by September of 2010.

[Silvertree]

I tested the varnish/ sealer on my 1957 built home 2 days ago.

Swab turned pink, that means lead in the finish.

[Allrounder]

Paul, did you find a local source or order them online? My Hirshfields rep is looking into stocking them at the stores.

[Silvertree]

No local source at this time.

[SLS-Construction]

Well I actually got a reply pretty quick

LeadCheck Swabs will detect lead in paint on drywall – they were just not recognized by EPA for this surface type. Attached is a color guide showing detection for drywall at different lead concentrations. As you can see the drywall results are almost identical to the metal & wood results. When LeadCheck Swabs turn pink on any surface you know that lead is present.

Attachment below....

Well after reading this I had to send the following reply...

Thank you – but this leads to another question, can you define exactly what you mean by the EPA doesn’t recognize your product for this surface type? Is that because of testing, they were not testing for this or what?

I did state that he could either email me or post it on the blog article that Len placed out. Either which way I will post it here as soo as I hear from him again

[SLS-Construction]

Well here we go - and back to square 1: (original post also edited to address this)

FOLLOW UP: per LeadCheck
Plaster and drywall contain chemicals that can potentially block the LeadCheck color reaction with lead. Although this does not seem to be a problem in “real world” field test situations. I believe that the EPA is just taking a conservative approach by limiting LeadCheck recognition to 2 substrates (wood & metal). Even though the EPA does not recognize LeadCheck for testing paint on drywall and plaster – it does no harm for contractors to test paint on those surfaces with LeadCheck. If the Swabs turn pink (or red) the contractor knows that lead is present and would have to follow EPA regulations. The contractor cannot assume that lead is not present when the LeadCheck is negative due to the potential interference. Attached is a copy of the LeadCheck Applications note for plaster which describes the issue in a little more detail ( http://www.leadcheck.com/PB-08Plaster.shtml )

[SLS-Construction]

Well here we go - and back to square 1: (original post also edited to address this)

FOLLOW UP: per LeadCheck
Plaster and drywall contain chemicals that can potentially block the LeadCheck color reaction with lead. Although this does not seem to be a problem in “real world” field test situations. I believe that the EPA is just taking a conservative approach by limiting LeadCheck recognition to 2 substrates (wood & metal). Even though the EPA does not recognize LeadCheck for testing paint on drywall and plaster – it does no harm for contractors to test paint on those surfaces with LeadCheck. If the Swabs turn pink (or red) the contractor knows that lead is present and would have to follow EPA regulations. The contractor cannot assume that lead is not present when the LeadCheck is negative due to the potential interference. Attached is a copy of the LeadCheck Applications note for plaster which describes the issue in a little more detail ( http://www.leadcheck.com/PB-08Plaster.shtml )

[Silvertree]

Are we done yet?:laugh3:

[ChrWright]

So essentially, it's the same thing we're taught in the class: you can't use the stick test on drywall and plaster to establish if lead is NOT present.

[SLS-Construction]

Yep - got to love the EPA ignoring existing testing data already completed by NIST (National Institute of Science and Technology) that says it does work. This is almost like them saying UL listings are no longer valid because someone might not insert the plug in properly.

I think they just threw the testing in there to appease us, but they seriously want everything tarped off like its asbestos.

[Silvertree]

Well Sean, you know this will start a stampede for non compliant people in our business.

Its conflicting, adds time, adds money.
Plus we will be frightening people, not the EPA, us personally.

The public already doesn't trust us.

I was told to quit whining,

I'm just getting started thank you.

Nice work by the way, very good information even though it changes the story from time to time.

[Century Man]

I was in the process of ordering test swabs when I read this message.

Due to increased demand, all orders will be shipped within 14 weeks.
This leadtime will decrease over the next several months as capacity increases.

[SLS-Construction]

The email I just got...

Sean it took me a while to track down how this was resolved for me at the RRP training I attended.

The instructor stated that while the situation can be avoided, where the tool used to freshly expose paint surfaces also penetrates sheetrock or plaster, the sulfates (when present in the form of dust) in the sheetrock, plaster or stucco, etc. can potentially inhibit the pink color development in the presence of lead. My instructor and the Lead Check Swab instructions offer some guidance for these situations. As always confirm a negative result by using the card. If the dot does not turn pink, plaster dust may have interfered with the test and lead may still be present. Using a fine, sharp, blade and slicing obliquely can expose all paint layers broadly while barely (and cleanly if so) penetrating sheetrock or plaster. Of course XRF is superior, but the Lead Check Instruction Manual at least helps us get the best, validated, performance from this widely available and inexpensive tool.

I appreciated your comments and perspectives at the AL RRP public hearing. It helped me to identify the challenges you encounter as we implement the RRP program. Please contact me if you have any other questions and I know that Mr. Gray and Mr. Brookins would also be happy to answer any of your questions. liz

Elizabeth Wilde
Regional Lead Coordinator
Air, Pesticides & Toxics Management Division U.S. Environmental Protection Agency Region 4, Atlanta GA
Phone: 404 562-8998
email: Wilde.Liz@EPA.gov (Wilde.Liz@EPA.gov)



From: "Sean"

To: Liz Wilde/R4/USEPA/US@EPA

Date: 03/18/2010 10:08 PM

Subject: AL Health Dept Meeting - follow up on Lead Check Swabs

As a reminder, you were going to verify that Lead Check swabs are allowed to be used on Drywall & plaster contrary to many individuals training providers. Thanks & have a good day

Sean Lintow Sr.
SLS Construction
(256) 352-7235

[Taylordhome]

I just plan on lead safe procedures on all my jobs and don't test. Better safe than sorry. Besides, it makes it easier to clean up anyhow...

[RCP]

"As part of the effort to reduce childhood lead poisoning, scientists at RTI International, under contract with the U.S. Environmental Protection Agency (EPA), have developed a new field method for measuring the amount of lead in paint that is faster and less expensive than current methods.

The new testing method, published online in the Journal of Environmental Monitoring, takes approximately 10 minutes and costs $6 per sample."



More here.... (http://www.laboratoryequipment.com/news-new-method-measures-paint-lead-faster-060910.aspx?xmlmenuid=51)

[neolitic]

"As part of the effort to reduce childhood lead poisoning, scientists at RTI International, under contract with the U.S. Environmental Protection Agency (EPA), have developed a new field method for measuring the amount of lead in paint that is faster and less expensive than current methods.

The new testing method, published online in the Journal of Environmental Monitoring, takes approximately 10 minutes and costs $6 per sample."

More here.... (http://www.laboratoryequipment.com/news-new-method-measures-paint-lead-faster-060910.aspx?xmlmenuid=51)

Sounds like a test you have to hire
a lab to do, unless you happen to have
a "portable turbidity meter" on you. :rolleyes3:
Technician's time, plus $6 per sample cost to them,
so probably still hundred$ to us.

[orson]

Sean it took me a while to track down how this was resolved for me at the RRP training I attended.

The instructor stated that while the situation can be avoided, where the tool used to freshly expose paint surfaces also penetrates sheetrock or plaster, the sulfates (when present in the form of dust) in the sheetrock, plaster or stucco, etc. can potentially inhibit the pink color development in the presence of lead. My instructor and the Lead Check Swab instructions offer some guidance for these situations. As always confirm a negative result by using the card. If the dot does not turn pink, plaster dust may have interfered with the test and lead may still be present. Using a fine, sharp, blade and slicing obliquely can expose all paint layers broadly while barely (and cleanly if so) penetrating sheetrock or plaster. Of course XRF is superior, but the Lead Check Instruction Manual at least helps us get the best, validated, performance from this widely available and inexpensive tool.

I appreciated your comments and perspectives at the AL RRP public hearing. It helped me to identify the challenges you encounter as we implement the RRP program. Please contact me if you have any other questions and I know that Mr. Gray and Mr. Brookins would also be happy to answer any of your questions. liz

Elizabeth Wilde

Well I guess that clears it right up. :smash:

At what point in that email does she actually answer the question of whether we are allowed to use Lead Check tests on plaster and drywall to determine if activities require the application of the RRP rule?

[neolitic]

Who is Elizabeth Wilde ?

[Len]

FYI -

For those of you using these products (or plan on) you can get the Lead Check Swabs from our RC store. Along with a HEPA Vac.

You will also see the in the right side ad (RC Suggested Products)

RC Amazon store links.
Lead Check Swabs (http://astore.amazon.com/remodelcrazy-20/search?node=1&keywords=Lead+Check+Swabs&x=7&y=7&preview=)
Super QuarterVac Backpack hepa (http://astore.amazon.com/remodelcrazy-20/search?node=46&keywords=Super+QuarterVac+Backpack+hepa&x=0&y=0&preview=)

RC Amazon Store (http://astore.amazon.com/remodelcrazy-20)

[SLS-Construction]

Neo - Elizabeth Wilde is the main EPA Lead person for my district which includes Georgia, Missisippi, probably Florida & ???

Owen, you have got to love how her "training" & "knowledge" of the rules contradicts there web site

[neolitic]

Neo - Elizabeth Wilde is the main EPA Lead person for my district which includes Georgia, Missisippi, probably Florida & ???

Owen, you have got to love how her "training" & "knowledge" of the rules contradicts there web site

Apparently she wasn't an
english major either.

[Taylordhome]

Just best to do the lead safe practices and not take any chances...makes for a cleaner work site anyhow!

[PA Woodbutcher]

I just plan on lead safe procedures on all my jobs and don't test. Better safe than sorry. Besides, it makes it easier to clean up anyhow...

Just best to do the lead safe practices and not take any chances...makes for a cleaner work site anyhow!

Although I can appreciate you wanting to take care of your customers and protect their health and property. You may be costing them hundreds if not thousands of dollars unnecessarily.

[RCP]

So the new tests don't make the cut.........

"Based on the preliminary ETV results, there are no kits that have met both the false negative and the false positive response criteria requirements; however, there is one kit that has met the false negative response criterion."

More here.... (http://www.epa.gov/lead/pubs/testkit.htm#etv).


Related article (http://www.paintsquare.com/news/article_news.cfm?id=4046)

[Allrounder]

Just found out today that there is now an approved test kit available that tests for lead on plaster and drywall surfaces:

D-Lead®. Based on the results of the Environmental Technology Verification (ETV) study of vendor-submitted lead test kits, EPA recognizes that when used by a certified renovator the D-Lead® Paint Test Kit manufactured by ESCA Tech, Inc., can reliably determine that regulated lead-based paint is not present on wood, ferrous metal (alloys that contain iron), drywall and plaster surfaces. Certified renovators seeking to use the D-Lead® Paint Test Kit for purposes of meeting requirements in the RRP Rule can purchase it from certain distributors and retail outlets. To locate a distributor or retailer visit www.esca-tech.com, Exit EPA Disclaimer e-mail rrp@esca-tech.com or call (414) 962-3006.
http://www.epa.gov/lead/pubs/testkit.htm

Interesting, you can buy it at Home Depot of all places:
http://www.homedepot.com/h_d1/N-5yc1vZ1xit/R-202510104/h_d2/ProductDisplay?langId=-1&storeId=10051&catalogId=10053

[Dean CRCNA]

Mentioned this 3 months ago ... http://www.remodelcrazy.com/forum/showthread.php?t=5703

[Allrounder]

Doh! Thanks Dean, I searched but didn't find your post.

[RCP]

Here is more.. (http://www.shawnmccadden.com/rrpedia/).

[FStephenMasek]

The best "test kit" of all is a good consultant with an XRF. It is the most accurate, and in all but trival cases, the least expensive.