NAHB article regarding Lead Test Kits could be misleading for Renovators and Home Owners
In a recent article about their efforts to address challenges for builders and remodelers due to the new EPA RRP rule, the National Association of Home Builders (NAHB) left out some critical information that causes their article to be very misleading to renovators and home owners unfamiliar with specific details about the RRP rule. In my opinion, the article also does a disservice to the manufacturer of LeadCheck, the only lead test kit currently approved by the EPA for RRP work. Although I would stress that the NAHB likely didn’t omit the information on purpose, having done so serves to only add to the already existing wide spread confusion about the new rule.
In the August 9, 2010 article, the NAHB sites an announcement by the EPA. The article states that; “More accurate, inexpensive test kits will not be available anytime soon. The kits were expected to be ready by next month and were seen as key to keeping the lead paint rule affordable for home owners”. The NAHB statement is true, but as stated would give renovators and home owners the impression that the current test kits are not accurate. In fact, the current test kits manufactured by Hybrivet Systems, Inc. of Natick Massachusetts have a twenty year plus proven track record of reliable and consistent accuracy.
Let me explain:
Here is what was missing from the NAHB article and what renovators and home owners should know so they can make their own decisions about lead testing using the LeadCheck test kits.
The LeadCheck test kits reliably determine the presence or absence of lead. The test is absolute. If they used these tests the home owner and the renovator would both know if any lead is present at all. However, under the RRP Rule, the EPA says the rule exempts renovations that affect only components that a certified lead inspector or certified risk assessor has determined are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm2) or 0.5% by weight.
In the rule preamble, the EPA stated; “research on the use of currently available kits for testing lead in paint has been published by the National Institute of Standards and Technology (NIST) (Ref. 26). The research indicates that there are test kits on the market that, when used by a trained professional, can reliably determine that regulated lead-based paint is not present by virtue of a negative result.”
The EPA also stated; “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).”
So, if the property owner wants to know if there is any lead at all, the EPA approved LeadCheck test kits could be used to do so. If the owner chooses to use the EPA's action level of lead paint amount to determine if the lead-safe practices would be required, then currently the only way to test for amount of lead would be to use a certified lead inspector or certified lead risk assessor. These individuals have and use testing methods that can determine the presence of lead by amount.
Making better decisions about testing:
One way to think about this might be to relate it to eating fish. The government often says that if you fish in certain bodies of polluted water, you can safely eat up to so many of the fish you catch without any health concerns. If the government says you can eat up to 3 fish a year, how safe would you feel eating even one fish? Using this analogy, how safe might the home owner feel having renovations done without using lead-safe work practices if there is any lead at all present at their property? The choice should be theirs.
If you have opportunity to interact with a property owner, I suggest you might find you would stand out from other renovators the home owner might be considering if you could share what I have written here with the owners. It is my opinion that the property owners should know the facts, know their options and then make a decision about how to move forward regarding lead at their homes. If renovators and home owners are under the impression that the current test kits are not accurate, they would be misinformed.