Looking for accurate information about the EPA RRP rule? D-Lead Manufacturer Offers Some Clarification about Their Test Kits
Recently 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:
First 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:
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:
In 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
