Lead-based paint testing

S. Environmental Protection Agency (EPA), A Field Test of Lead-Based Paint Testing Technologies Summary Report (1995). 

In 1998 a Californian (MMWR, 2001) mother requested a blood lead level determination for her 18-month-old child. The result was a blood lead level (BLL) of 26 LLg/dl, which was well above the Center for Disease Control s (CDC) recommended criterion for clinical case management. It was subsequently found that the father had a BLL of 46 ( lg/dl, which was above the Occupational Safety and Health Administration (OSHA) requirement that workers with BLLs greater than 40 lg/dl receive additional medical examinations. Further testing found that his 4-month-old daughter had a BLL of 24 Rg/dl. This worker was employed in a company that refinished antique furniture, some of which was covered with lead-based paint. Subsequent testing of co-workers found that two refinishers had BLLs of 29 and 54 Rg/dl and four carpenters had BLLs of 46, 46, 47, and 56 ( lg/dl. A child in another family had a BLL of 16 ( lg/dl. What will be the long-term effects on the intellectual abilities of these children ... 

Sellers and landlords of target housing must disclose to prospective purchasers or tenants details of any lead-based paint or lead-based paint hazards of which they are aware. They must give the prospective purchasers and tenants records of any lead testing, and a copy of the EPA/HUD pamphlet entitled Protect Your Family From Lead in Your Home or another pamphlet that has EPA approval. Prospective purchasers and tenants must receive the disclosure and a warning before the contract or lease becomes binding, and purchasers must be given ten days to conduct a risk assessment or inspection. ... 

Under the lead-based paint activities rule, only certified individuals and firms may conduct lead-based paint activities. Individuals may become certified by attending an accredited course and meeting additional requirements that vary according to the specific activity the person is certified to do. Individuals must be recertified every three years if they took a course and had a hands-on assessment, or every five years if they took a course and a proficiency test. Firms may be certified also, and certified firms may only employ... 

There are work practice standards that must be employed in all lead-based paint activity. For example, for inspections, the regulations detail the minimum requirements including where to select paint samples to test, how to sample, how to test, what records to keep, and reports that must be prepared. 

Not later than 30 months after October 28, 1992, the President shall, after notice and opportunity for comment, establish by rule appropriate criteria, testing protocols, and performance characteristics as are necessary to ensure, to the greatest extent possible and consistent with the purposes and policy of this subchapter, that lead-based paint hazard evaluation and reduction products introduced into commerce after a period specified in the rule are effective for the intended use described by the manufacturer. The rule shall identify the types or classes of products that are subject to such rule. The President, in implementation of the rule, shall, to the maximum extent possible, utilize independent testing laboratories, as appropriate, and consult with such entities and others in developing the rules. The President may delegate the authorities under this subsection to the Environmental Protection Agency or the Secretary of Commerce or such other appropriate agency. 

Has this dwelling been tested for lead-based paint or lead-contaminated DUST yes no (circle)... 

In September 2011, the EPA released new precautions for dealing with lead exposure. Renovations of buildings or facilities built or remodeled before 1978 may have had lead-based paint used in the process. Again, the key to understanding unsafe exposure is to determine whether lead-containing materials (LCM) exist in the workplace. Several different tests can be completed to determine whether lead is... 

New EPA Recognized D-Lead Paint Test Kit Twin Pack makes it more convenient for contractors to test for lead-based paint. The Twin Rack is the same EPA Recognized test as the D-Lead Paint Test Kit (Contractors 24-test kit), but in a convenient pack of two complete 7-test kits which allows easier testing at multiple job sites. ESCA Tech, Inc., www. ESCA-Techrom, (877) 877-6590. Circle 332... 

In 1990, the U.S. HUD issued interim guidance for lead paint identification and abatement methodologies for public and Indian housing under the above LBPPPA Amendments (55 FR 14556-14614). These guidelines were addressed to testing for lead-based paint, criteria for lead paint abatement contractor selections, specific lead paint abatement criteria and methodologies, cleanup postabatement, and waste disposal. 

Containment of the water used for pressure washing is an important concern. If used to remove lead-based paint, the water may contain suspended lead particles and needs to be tested for teachable lead using the toxicity characteristic leaching procedure... 

Final report Lead hazard control plan or certification of lead-based paint compliance Lead concentrations for each surface tested... 

Typically, when an abatement is performed, the housing is either unoccupied or the occupants are temporarily relocated to lead-safe housing until the abatement has been demonstrated to have been properly completed through dust clearance testing. Carpet in the housing is usually removed as part of the abatement because it is difficult to demonstrate that it is free of lead-based paint hazards. Uncarpeted floors that have not been replaced during the abatement may need to be refinished or sealed in order to... 

This final rule exempts renovations that affect only components that a certified renovator, using a test kit recognized by EPA, determines are free of lead-based paint. EPA has deleted the regulatory thresholds for lead-based paint from this definition because they unnecessarily complicate the exception. A certified renovator is a person who has taken an accredited course in work practices. This training will include how to properly use the EPA-approved test kits. This final rule also establishes the process EPA will use to recognize test kits. 

Some commenters, representing a variety of interests, supported an exception for renovations affecting components that have been found to be free of regulated lead-based paint by use of a test kit. One commenter cited the need for faster and cheaper methods of accurately checking for lead and expressed the opinion that this approach will expand access to lead screening in... 

However, most commenters did not favor the use of test kits. The most commonly cited reason for not supporting this approach was the potential conflict-of-interest present in having the certified renovator be the one to determine whether or not he or she mnst use the work practices required by the rule. EPA addressed potential conflicts of interest in its lead-based paint program in the preamble to the final Lead-Based Paint Activities Regulations. That discussion outUned two reasons for not requiring that inspections or risk assessments, abatements, and post-abatement clearance testing all be performed by different entities. 

Another commonly cited reason for not supporting the use of test kits by certified renovators was the lack of any sampling protocol in the regulation. A related concern was that the training in sampling techniques and protocols in the lead-based paint inspector course could not be shortened to fit within the 8-hour renovator course and still retain all of the necessary information. EPA wishes to make it clear that the 8-hour renovator course will not train renovators in how to select components for sampling because the certified renovator must use a test kit on each component affected by the renovation. The only exception to this is when the components make up an integrated whole, such as the individual stair treads and risers in a staircase. 

The NIST research on existing test kits shows that existing test kits cannot reliably determine that lead is present in paint only above the statutory levels because the kits are sensitive to lead at levels below the federal standards that define lead-based paint, and therefore are prone to a large number of false positive results (i.e., a positive result when regulated lead-based paint is, in fact, not present). The NIST research found that such false positive rates range from 42 to 78%. This means that the currently available kits are not an effective means of identifying the 76% of homes built between 1960 and 1978 that do not contain regulated lead-based paint. 

In the 2006 Proposal, EPA noted that it would look to ASTM International s E1828, Standard Practice for Evaluating the Performance Characteristics of Qualitative Chemical Spot Test Kits for Lead in Paint, or equivalent for a validation method for test kits. With the input of stakeholders, EPA is adapting this ASTM Standard for use in the laboratory validation program. The testing protocol will consist of an evaluation of the performance of the test kits, using the manufacturer s instructions, on various substrates, such as wood, steel, drywall, and plaster, with various lead compounds, such as lead carbonate and lead chromate, at various lead concentrations above and below regulatory threshold for lead-based paint. 

This pamphlet gives information on lead-based paint hazards, lead testing, how to select a contractor, what precautions to take during the renovation, and proper cleanup activities, while still incorporating the information already included in the original Protect Your Family from Lead in Your Home and mandated by section 406(a) of TSCA. 

When requested by the party contracting for renovation services, use an acceptable test kit to determine whether components to be affected by the renovation contain lead-based paint... 

A few commenters contended that EPA should not require dust clearance testing because there is a difference between abatement, which is intended to eliminate lead-based paint hazards, and renovations in which the focus should be to not create any new lead-based paint hazards. Some commenters asserted that dust clearance testing should not be required because this would result in the renovator being responsible for existing... 

For abatements, clearance testing and clearance are used to minimize potential exposure by eliminating lead-based paint hazards after completion of the job. Clearance acts as the means to ensure that minimization, and signal the end of the job. For renovations, given the presence of residents, the concern is for potential exposure both during and after the job. Dust clearance testing and clearance would only address the second part of the exposure equation. Thus, dust clearance testing conducted after renovation activities have been completed would not provide the equivalent determination of potential exposure that it does for abatement. 

---