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D-Lead Offers Some Clarification about Their Lead Test Kits

  
  
  
  

Please read RRPedia Use and Contribution Information before using or contributing to RRPedia

D-Lead Manufacturer Offers Some Clarification about Their Test Kits

EPA Recognized test kitRecently I published three articles to RRPedia regarding the EPA Recognized test kits.   Links to these articles are at the end of this article.  On November 15th, 2010, Dan Askin, President & Technical Director of ESCA Tech, Inc. (manufacturer of the EPA Recognized D-Lead® Paint Test Kit), contacted me via e-mail to provide some feedback and clarification regarding some of the content of my articles.   Maintaining accuracy of the content I post to RRPedia is very important to me.  I want to thank Dan for taking the time to put together his comments.    Below I will share some of the clarifications Dan provided.

Approved vs. Recognized:

Lead Test kit approvalFirst off, Dan clarified that the test kits are not “approved” by EPA; rather, they are “Recognized” by EPA.  In order to be recognized for RRP use, test kits must pass the EPA approved testing process specified in the final rule.  

Dan’s Comments: The EPA has not and cannot approve a Lead Paint Test Kit.  The EPA has Recognized 3 Test Kits to date.  Government Agencies cannot approve, certify or endorse a commercial product, hence the origin of the term “Recognized”.  See: http://www.epa.gov/lead/pubs/testkit.htm

Ease of Use and Total Testing Time:

Time to use Test kit In my articles I expressed my opinion that the Lead Check test kits are simpler to use and the Lead Check kits give instant results with no waiting, where as the D-Lead Test Kit instructions say the test takes 3-13 minutes.
 

Dan’s Comments: With minimal practice, the D-Lead® Paint Test Kit is simple, fast, and easy to use.  It takes 1 to 2 samples to acquire the knack of collecting a sample with our sample tools.  A positive test is usually instantaneous.  Our test time is the same regardless of the form of lead present and this includes detection of chromate bearing paints.  The lower end of the time range (3 minutes) covers most positive tests and includes preparation, sample collection, testing and recording the results.  
A positive test result is instant unless one of two events occurs:
(a) The lead layer is covered by substrate collected with the sample, or if
(b) The lead layer is embedded in the middle of several layers.  
If the test result is low or negative, then you set the sample aside for 10 minutes before taking a final reading.  The 3 – 13 minute range is the time frame observed by Battelle Memorial Institute during the independent third party ETV Testing Program.
When testing with LeadCheck® the same amount of time is required to clean the sample area and your sample tool, score the paint, test, observe and record the results.  

According to Lead Check’s instructions: “It is a good idea to reexamine a test site that is suspected to contain lead chromate 30 minutes after the initial test and then 60 minutes after the initial test. If there is still no red or pink coloring, then the negative test result is correct.”  

(Click here for video and written instructions for the D-Lead and Lead Check Test Kits)


Kit Contents:

Test kit contentsIn one of my articles I stated that the “Lead Check swabs contain everything you need inside the swabs.  You can just squeeze the kits with your fingers as instructed, shake the swab and you are ready to test.  The D-Lead kits require measuring and mixing chemicals to get ready for testing.”
 

Dan’s Comments: You still need to provide cleaning materials to prevent cross contamination and your own sampling tool with the other recognized test (Lead Check).  We are not aware of any measuring required with our kit as all reagents are premeasured, unless you are referring to counting 5 drops of solution.  We provide a complete kit that includes the D-Wipe® Paint Sample Prep Towels, sampling tools and waste disposal.

 

Links to the three RRPedia articles:

Choosing Between EPA Approved Lead Test Kits

EPA Approved Lead Test Kit Instructions

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

 

Lead Paint Forms StoreIf you are looking for forms and signage to help you with comply with the EPA RRP rule, I recommend you check out what The Lead Paint Forms Store has to offer.

Comments

Shawn, 
 
Thanks for quickly sharing the updates. My colleagues at leadnet@mail-list.com are following your citations closely.
Posted @ Wednesday, November 24, 2010 11:46 AM by Catherine Brooks
I was wondering Shawn, it states on the manufacturer instructions that you can determine if there is lead based on the EPA level (1.0 mg/cm^2) based on the color of the liquid after testing. It seems as if they are claiming they are both a positive and negative test for lead, but as far as I can tell they are only approved as a negative test. Is it true that they are approved as a positive test or are the instructions just a little confusing and they are only a negative test? 
 
Thanks, great article as always
Posted @ Monday, November 29, 2010 7:52 AM by Kevin
Kevin, you are correct, the D-Lead kits are only recognized by EPA as a negative test. Although their test can be used to determine how much lead there is in relative terms, it is done by the color produced by the test compared to a chart. The shade of the color and deciding which color the test generates compared to the chart is subjective. So, I would suggest it would be a good guide to help determine the amount of lead based on a high/low range. However, EPA says the test can't be used to determine if the amount of paint meets the legal definition of lead for RRP Purposes.
Posted @ Wednesday, December 01, 2010 10:42 AM by Shawn McCadden
Sorry to scrape up such an old issue, but I have been using the D-Lead test kit for a while, and I found the testing results to be utterly confusing. Then I rented a hand held GC type of gun that can definitively give me a lead level and I found that the d-lead test kits were all over the map in terms of their ability to detect quantitatively the level of lead. Some d-lead test results appeared to strongly detect lead when the level was below the legal amount, and other times lead was higher than the legal amount and the d-lead test barely changed color. Now I see why the EPA only "recognized" these tests and not approved them.
Posted @ Thursday, March 01, 2012 8:49 AM by Andrew
Andrew, I like the "scrape up an old issue" pun!
Posted @ Thursday, March 01, 2012 2:45 PM by Shawn McCadden
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