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EPA Decides Trainers Can Use Either Test Kit at RRP Training Classes

Posted by Shawn McCadden on Mon, Nov 15, 2010 @ 06:00 AM
  
  
  
  
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EPA Decides RRP Trainers Can Use Either Test Kit at RRP Training Classes

NAHB LogoThrough my fellow NARI member contacts I have learned that on November 5, 2010, at their offices in Washington DC, the NAHB hosted a meeting with the EPA to discuss the RRP rule.   Several industry trade associations, including NARI, were in attendance at the meeting.  Also in attendance were representatives from Hybrivet Systems, Inc. and ESCA Tech, Inc. 

Lead Check Test KitHybrivet Systems, Inc. and ESCA Tech, Inc. are the manufacturers of the only two commercially available Lead Test Kits approved by EPA for use on RRP regulated renovations. Hybrivet Systems, Inc. manufactures and distributes the Lead Check test kit.  ESCA Tech, Inc. manufactures and distributes the D-Lead Test kit.  The D-Lead test kit was only recently approved for RRP use.  The Lead Check Kit has been approved since before the RRP rule came into effect on April 22, 2010.

D-Lead Test KitAt the meeting a representative from ESCA Tech, Inc asked the EPA when it was going to require that RRP training instructors demonstrate the proper use of both of the currently approved lead test kits at the EPA required Certified Renovator Training Classes.  EPA responded that they were not going to require training on both kits and instructors could decide which kit they would demonstrate at the training. 

I am an approved Certified Renovator Instructor for Massachusetts and EPA.  I and several other instructors had submitted this same question to EPA a few weeks back.   Although we still have not heard anything back from EPA, it is good that EPA has clarified this for instructors.  I hope the EPA will get this clarification out to all instructors soon.

 

Time for test kitHere is just one reason I will go with the Lead Check kits when I do RRP training.  Using the D-Lead kits will definitely take longer than using the Lead Check kits.  The certified renovator classes at eight hours long make for a long day and it is tough enough already for instructors to cover the subject matter in those eight hours.  Demonstrating and using the D-Lead kits would either cause the class to go past eight hours, or time spent on other topics would need to be cut back to keep the day at eight hours.  I know the students would rather not extend the day and I would prefer not to cut back on or eliminate any of the required subject matter.

Given the choice, I will definitely use the Lead Check Swabs in my training classes.  The main reasons for my decision, in addition to my concerns about the length of the training day, are ease of use and safety.  However, I suggest RRP certified renovator instructors decide for themselves which test kit they will use in their training classes. The same goes for renovators who plan to use test kits on RRP projects.   Both kits offer accurate testing, but both follow different protocol for testing and they both also have limitations or advantages depending on the surface or product to be tested. 

For more on the differences between the two EPA approved test kits see: Choosing Between EPA Approved Test Kits.

For written and video instructions for both test kits see: EPA Approved Lead Test Kit Instructions

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Comments

I have shown the D-Lead Paint Test Kit for training renovator certification classes since it became available in early October. I’ve been a contractor and lead safety trainer for more than 12 years and I believe the D-Lead Paint Test Kit will become the new standard for low cost lead paint testing.  
First off, when first opening the box, you notice all the cleaning and sampling supplies are provided. Other lead testing kits don’t include the supplies needed to clean the test surface, the tools used to take the sample, or for cleanup and disposal after testing. By including all the cleaning supplies this is just one less thing we as contractors have to think about. In addition, the cleaning supplies aren’t just alcohol swabs or wet naps, but are special wipes used for the removal of lead dust. As a result, the risk of possible cross contamination is greatly reduced ensuring the most accurate results. 
Next you notice the metal sampling tool provided. As an instructor, one of the most common questions I get from students is how large of an area to score or scrape for sampling purposes. With the D-Lead Paint Test Kit, a punch tool is included so that you get the same size sample every time. In addition, the small punch size makes for simple repair should any surface damage occur.  
• The color standard on each of the test bottles is at the EPA’s recognized level of 1.0 mg/cm2. This color sample is RIGHT on the test bottles so it’s easy to not only determine if there has been lead found, but how much lead is on the surface based on how light or dark the test results are against the color standard.  
 
• A sample catch tray is provided for ease of collecting your sample. Just stick the tray under the area being sampled and let the sample fall onto the tray.  
 
• This kit is much less messy then previous kits I’ve used. The reality is that while it’s “best practice” to wear protective gloves, it’s not normally done. Other tests suggest that you have to put a “drop somewhere” and that somewhere seems to be your finger or some other random surface which will now bear a yellow stain that remains for quite a while. 
I work with many contractors who like the ease of use as well as the clear distinction between a positive test for regulated lead and no lead or low lead results. Even though I work in Wisconsin, where lead testing is required to be performed by a certified lead inspector, I am aware that contractors and property owners use the kit as a screening tool, which can be a huge cost benefit. If the kit detects low lead or no lead the contractor knows it may be worth having it tested by a certified lead inspector.
Posted @ Tuesday, November 23, 2010 12:47 PM by John
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