EPA Decides RRP Trainers Can Use Either Test Kit at RRP Training Classes
Through 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.
Hybrivet 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.
At 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.
Here 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