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Your Interactive Resource for EPA RRP Information

RRPedia logoLooking for accurate information about the EPA RRP rule?

RRPedia has been created by Shawn McCadden to help remodelers and others affected by the New EPA Renovation Repair and Painting Rule. 

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


You Can Browse For RRP Topics By Using The Tags List To The Right

If a Lead Test Indicates No Lead, Can A Non-Certified Firm Do The Work?

Posted by Shawn McCadden on Mon, May 30, 2011 @ 06:00 PM

If An EPA Recognized Lead Test Kit Indicates No Lead, Can A Non-Certified Firm Do The Work?

Lead tesing for RRP



This can be tricky.  Keep in mind that for RRP purposes, only a certified renovator or licensed lead testing professional can do testing to determine that no lead is present.  As EPA indicates in their answer below, if the certified renovator working for a certified firm does the testing, that firm must maintain the required documentation regarding the testing.   So, if the firm that did the testing is doing the renovation, and the testing shows no lead, they can hire (subcontract to) non-certified firms and non-certified workers to do the work.  


Here is one question and answer I found on the EPA FAQ page to help clarify:

Question: If a certified renovator using an EPA-recognized test kit determines that the components that will be affected by a renovation are free of lead-based paint, can a firm that does not have RRP certification do the actual renovation work? What record-keeping requirements would apply?

EPA Answer: Where a certified renovator uses an EPA-recognized test kit, follows the kit manufacturer’s instructions, tests each component affected by the renovation, and determines that the components are free of paint or other surface coatings that contain lead at regulated levels, the renovation can be performed by a non-certified firm and without regard to the work practice standards or record-keeping requirements of the RRP Rule. See 40 CFR 745.82(a)(2). 

However, the certified renovator and firm making the lead-based paint free determination are still subject to the recordkeeping requirements of 745.86(b)(1)(ii) and 745.86(a). Specifically, the certified renovator must prepare a record that states the brand of test kit used, the components tested, and results of the tests. The certified renovator’s firm must retain a copy of this record for three years. EPA further recommends that the firm actually performing the renovation also retain a copy of these records to demonstrate that compliance with the RRP Rule was not required.


Lead paint testingSo it appears that a non-certified firm can do the work if testing that proved no lead was found was done by someone else, as long as the determination was made by a certified lead inspector or risk assessor, or by a certified renovator using an EPA recognized test kit and following the kit manufacturer’s instructions.    The key is however, that the non-certified firm must have written proof from the person or business that did the testing that there is no lead in the work areas to be disturbed.




So, here is the rub. 

If you are a certified firm and have a certified renovator do the testing, and you give the homeowner a copy of the testing report you create, that homeowner could then hire a non-certified firm to do the work because that homeowner and the non-certified firm they hire can use your test results to avoid RRP firm and work requirements.  Think about this before you test and make your own best decision about if and when you will test during the sales process.

Topics: RRP Questions, Sales Considerations, Subcontractor Considerations, Compliance Options, Info for Landlords, Firm Certification, Lead Test Kits and Testing

Breaking News: 3M Acquires Hybrivet Systems, Makers of Lead Test Kits

Posted by Shawn McCadden on Thu, Feb 17, 2011 @ 10:16 AM

Breaking News Release!

3M Acquires Hybrivet Systems Inc.

This Just released at 10AM February 17, 2011

3m logoST. PAUL, Minn. – Feb. 17, 2011 – 3M announced today it has acquired Hybrivet Systems Inc., a leading provider of instant-read products to detect lead and other contaminants and toxins. Terms of the transaction were not disclosed.


LeadCheck sold to 3MHybrivet Systems Inc.’s flagship product is LeadCheck® Swabs, which is widely recognized as the fastest, easiest, most cost-effective lead detection product on the market. LeadCheck® has been at the forefront of lead detection and awareness since 1991.


The addition of Hybrivet Systems Inc. provides 3M immediate access to the potentially large market for testing paints in older houses and commercial buildings for lead to meet new Environmental Protection Agency lead-safe work practices regulations.  LeadCheck® was the first EPA recognized instant test kit under the Renovation, Repair and Painting rule that went into effect April 20, 2010.

“The LeadCheck products complement and build on our paint preparation, tape and safety businesses and broaden our product offerings in the paint aisle,” said Jack Truong, vice president and general manager, 3M Construction and Home Improvement Markets Division.

Hybrivet Systems Inc. is based in Natick, Mass and employees 11 people. 

About Hybrivet Systems Inc.

Marcia Stone, PhD, Hybrivet Systems Inc. Founded in 1987 by Marcia Stone, PhD, Hybrivet Systems Inc. is passionately dedicated to protecting the public from contaminants and toxins by offering a series of instant-read detection products. Recognized by the EPA, LeadCheck® Swabs are the most effective way for Certified Trainers and contractors to comply with the EPA Repair, Renovation and Painting (RRP) rule. Commercially available to all contractors, EPA trainers, and home owners, LeadCheck swabs help protect families, and especially children, against lead poisoning.


About 3M

3M captures the spark of new ideas and transforms them into thousands of ingenious products. Our culture of creative collaboration inspires a never-ending stream of powerful technologies that make life better. 3M is the innovation company that never stops inventing. With $27 billion in sales, 3M employs about 80,000 people worldwide and has operations in more than 65 countries. For more information, visit www.3M.com or follow @3MNews on Twitter.

Media Contact:

Donna Fleming Runyon, 3M

(651) 736-7646

Investor Contacts:

Matt Ginter, 3M

(651) 733-8206

Bruce Jermeland, 3M

(651) 733-1807

Topics: Lead Test Kits and Testing

Costs Of RRP Challenging Many Businesses And Likely To Go Higher!

Posted by Shawn McCadden on Tue, Jan 11, 2011 @ 06:00 AM

Costs Of RRP Compliance Challenging Many Businesses and Likely To Go Higher!

Renovators have justified their concerns about the additional costs of complying with the EPA RRP Rule based on two different but interdependent reasons.  First is the cost to the business.  Businesses that do comply have to pay to become a certified firm, pay training fees for the required certified renovator training, pay the wages of the certified renovator while he/she trains non-certified workers, pay the wages of employees while they attend training, and must purchase all of the tools, related equipment and personal protection equipment needed by workers to do the work.   Second, they cite the additional labor and material costs to perform the work.  

RRP Challenges and RRP Problems


These additional costs might not be all that burdensome if all contractors doing RRP work shared the same burdens and where able to recover these costs through the selling prices of their jobs.  But, the additional costs become an extreme burden for many businesses if and when they are in competition with illegally operating businesses that avoid the additional costs and therefore are offering lower prices to consumers.  Many contractors are reporting that the additional costs are putting them out of business.


Ready for some more bad news?   The costs of compliance are likely to go up even higher, for complying businesses as well as for consumers. 

  • First, the proposed dust wipe amendment, if approved, will definitely increase projects costs and will result in delaying when the consumer can get back into the renovated space. 
  • Second, in addition to the costs related to the dust wipe testing, because contained areas cannot be re-inhabited until the tests show no lead dust, consumers may need to seek alternate living arrangements while waiting for test results to come back from laboratories. 
  • Third, because of the lack of a cost effective lead test kit that will recognize lead based on the legal definition of lead equal to or in excess of 1.0 mg/cm\2\ or 0.5% by weight, many projects that would not require lead safe practices must still be performed using lead-safe practices. 

Here is excerpt from the final rule preamble:

RRP Costs“Number of events and individuals affected: In the first year that all of the rule requirements will be in effect, there will be an estimated 8.4 million renovation, repair, and painting events where lead-safe work practices will be used due to the rule. As a result, there will be approximately 1.4 million children under the age of 6 who will be affected by having their exposure to lead dust minimized due to the rule. There will also be about 5.4 million adults who will be affected. After improved test kits for determining whether a painted surface contains lead-based paint become available (which is assumed in the analysis to occur by the second year of the rule), the number of renovation, repair, and painting events using lead-safe work practices is expected to drop to 4.4 million events per year. No change in the number of exposures avoided due to the rule is expected because the improved test kit will more accurately identify paint without lead, thus reducing the number of events unnecessarily using the required work practices.”

So, because the EPA falsely assumed that the improved test kits would be available by September 2010, 4.4 million RRP projects will bear the additional cost of lead-safe practices that would not be required if the improved test kits were available.  That one bad assumption by EPA, based on the bogus and underestimated average additional cost of $35 per project, will result in $140 million in additional costs for projects “unnecessarily using the required work practices”.   What do you think about that?   What would consumers think about that?

Topics: Effects of the RRP Rule, Estimating Considerations, Statistics, Amendments, Tools and Supplies, Lead Test Kits and Testing

D-Lead Offers Some Clarification about Their Lead Test Kits

Posted by Shawn McCadden on Wed, Nov 24, 2010 @ 10:23 AM

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.

Topics: Lead Test Kits and Testing

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

Posted by Shawn McCadden on Mon, Nov 15, 2010 @ 07:00 AM

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

Topics: EPA Announcements, Certified Renovator Training, Info for Trainers, Lead Test Kits and Testing

Choosing Between EPA Approved Lead Test Kits

Posted by Shawn McCadden on Thu, Nov 11, 2010 @ 07:00 AM

Choosing Between EPA Approved Lead Test Kits

Now that they have more than one option, many renovators are now asking how to go about choosing a lead test kit.  Currently there are two commercially available Lead Test Kits approved by EPA for use on RRP regulated renovations. The recognized lead test kits are offered by Hybrivet Systems, Inc. and ESCA Tech, Inc.   

Hybrivet Systems, Inc. manufactures and distributes the Lead Check test kit

Lead Check test kit

ESCA Tech, Inc. manufactures and distributes the D-Lead Test kit

D-Lead test kit


The D-Lead test kit was only recently recognized for RRP use.  The Lead Check Kit has been recognized since before the RRP rule came into effect on April 22, 2010.

RRP Instructor Shawn McCaddenGiven the choice, as Massachusetts and EPA authorized RRP instructor, I will definitely use the Lead Check Swabs in my training classes.  I offer some reasons for this choice below.  However keep in mind, if you do RRP renovations, you will likely be choosing which test lead test kit to use and why for different reasons than I would as an instructor.   I hope the information below helps you make a good decision when you select a lead test kit.  Please feel free to add any other comparisons or consideration for choosing a lead test kit by commenting at the end of this article.

Comparison of Lead Test Kits

  • In my opinion the Lead Check test kits are simpler to use.  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. 
  • The Lead Check kits can be used on the surface to tested, but the D-lead kit requires the collection of samples and placement of the samples into test solution bottles. 
  • 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.
  • I believe the Lead Check kits are much safer, as they do not contain any toxic or harmful chemicals.  The D-Lead test kits contain sodium hydroxide and ammonium sulfide, both of which are considered irritants to the skin and eyes and should not be ingested.  Sodium sulfide smells like rotten eggs.  Ammonium sulfide is also flammable.
  •  The Lead Check Kits can be disposed of right after use, where the D-lead kit chemicals, because they are hazardous, must first be poured into a waste disposal bag.  The disposal bag is provided with the D-Lead kit and contains a waste absorbent to neutralize the harmful chemicals.
  • The D-Lead kits are approved for use on drywall and plaster.  The Lead Check Kit is not currently approved for use on drywall and plaster by EPA, but Hybrivet Systems, Inc. reports they should have that approval in the near future.
  • The D-Lead kit has a relatively short shelf life of 12 Months unopened, but 6 months once opened.  The Lead Check kits have an indefinite shelf life and therefore do not have an expiration date.
  • Lead Check is available in stores everywhere and on-line.   D-Lead is new to the market and therefore is not yet readily available for purchase in all markets.  Their web site says it is available at The Home Depot under the name of Klean-Strip.  The ESCA Tech, Inc. has a list of distributors where their product is available.
  • The 8 Swab Lead Check kits are available on-line for $24.95 (about $3.12/test).  When used as per the instructions, each swab can only be used once.  The 6-test D-Lead kit was available at the same on-line distributer for about $28.95 (About $4.83/test) and if used as per the instructions each test can only be used once.
Note: I had previously reported in this article that the individual Lead Check swabs could be used up to three times as long as the swab did not turn red.   Doing so would be in violation of the manufacturers instructions and would therefore not be in compliance with the RRP rule.  EPA states that users must follow the manufacturers instructions when using the test kits.  This makes sense because the EPA used the manufacturer's instructions as part of their standard process when evaluating the kits and ultimately recognizing them for RRP use.  It has also been pointed out to me that EPA does not "approve" test kits for RRP use, rather they "recognize" test kits for RRP use.  This article was updated on 12/15/10 to reflect the information in this note.

I hope you find this information helpful.  Whether you are an RRP instructor or a renovator doing RRP work, the best way to understand the differences between lead test kits would be to read the instruction manuals for both and decide for yourself.   For access to written and video instructions for both test kits see: EPA Approved Test Kit Instructions

Topics: RRP Questions, Tools and Supplies, Lead Test Kits and Testing

EPA Approved Lead Test Kit Instructions

Posted by Shawn McCadden on Tue, Nov 09, 2010 @ 07:00 AM

EPA Approved Lead Test Kit Instructions

Currently there are only two commercially available Lead Test Kits approved by EPA for use on RRP regulated renovations. The approved test kits are offered by Hybrivet Systems, Inc. and ESCA Tech, Inc.  Selecting a lead test kit should be an informed decision. 

Lead Check Test KitHybrivet Systems, Inc. manufactures and distributes the Lead Check test kit






D-Lead Lead Test KitESCA Tech, Inc. manufactures and distributes the D-Lead Test kit






There is one more EPA-recognized test kit, called the Massachusetts Lead Test Kit.  The Massachusetts Test Kit is not commercially available and can only be used by trained professionals—risk assessors or lead abatement professionals

Below, I have included links to written instructions as well as video instructions for both test kits for your convenience.  I find the lead test kit videos particularly helpful because viewers can actually see how each test kit is typically used, what is involved and make a judgment about how long each test will take.


Lead Check Test Kit Video Instructions


Lead Check Test Kit Written Instructions


D-Lead Test Kit Video Instructions


D-Lead Test Kit Written Instructions


If 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.

Topics: EPA RRP for Dummies, RRP for Dummies, Tools and Supplies, Lead Test Kits and Testing

MA RRP Assessment Form Introduced By CLPPP

Posted by Shawn McCadden on Tue, Oct 12, 2010 @ 06:02 PM

MA RRP Assessment Form Introduced By CLPPP

Recently Massachusetts Releases MA RRP Assessment formMassachusetts, one of the states delegated by EPA to administer and enforce the RRP rule, released a new form and protocol to be used by Massachusetts licensed lead inspectors when doing testing for lead prior to a RRP project.   Although under the Massachusetts and EPA RRP rules a certified renovator can use EPA approved test kits to do this testing, as an alternative some home owners and renovators may elect to have the testing done by a lead testing professional.  The following article was written by John MacIsaac of ASAP Environmental.  John is a leader in the lead inspection industry and currently serves as President of the New England Chapter of (LEHA), The Lead and Environmental Hazards Association.



John MacIsaac

John’s Article:

As of September 2010, CLPPP (Childhood Lead Poison Prevention Program) has produced a new report for RRP inspections.  It is called the Renovation Repair and Painting Assessment Report.  This new MA RRP inspection form will be used when licensed MA lead inspectors are testing surfaces that will be impacted during renovation of properties built prior to 1978.  The information on this report will definitively say which surfaces are positive or negative for lead based paint based on findings from an XRF analyzer or sodium sulfide solution purchased by the inspector from the state of MA.  If the surfaces tested negative for lead paint then the contractor is not required to follow the RRP protocol.  If the surfaces are positive for lead based paint the contractors are required to follow the RRP protocol for set up, containment, and clean up.

There has been a MA Lead Determination report in place since before the current lead law was enacted.  This report has been primarily used for testing for lead based paint as part of home sales.  It was also used for RRP inspections prior to the release of the RRP Assessment report.  The RRP Assessment report as well as the Lead Determination report cannot be used for deleading purposes.  In order to perform deleading activities for compliance with the MA lead law you will need a Full Comprehensive Initial Inspection and/or Risk Assessment.  Certified firms and the Lead Safe Renovators who work for them are not licensed to do deleading activities for compliance in MA unless they take an additional 4 hour deleading training course.  Since April 22, 2010 we have seen a number of deleading jobs for compliance that have had unauthorized contractors perform the deleading activities.  As a result of this the owners of these properties are getting letters of Unauthorized Deleading which does not remove them from liability from the lead law and they are also not eligible for  available tax credits of up to $1,500 from the state.


XRF Testing with XRF Gun 

It is important that property owners make the decision on whether or not they will or will not have testing done either by a licensed lead inspector or a lead safe renovator.  The property owners are required to disclose all findings, from a licensed lead inspector’s Lead Check EPA Approved test kit used for testing for leadRRP Assessment report or from a Lead Safe Renovator who has used an EPA approved lead based paint test kit to test surfaces for lead, to all tenants or potential buyers.


Note:  This information was provided by John MacIsaac of ASAP Environmental, Inc.

If 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.

Topics: RRP in MA, Definitions, Compliance Options, Info for Landlords, MA RRP Updates, Lead Test Kits and Testing

Home Inspectors Will Help Spread The News About The EPA RRP Rule

Posted by Shawn McCadden on Fri, Sep 24, 2010 @ 08:04 AM

Home Inspectors Will Help Spread The News About The EPA RRP Rule

ASHI LogoIf home buyers aren’t aware of lead paint or the implications of buying a property that has or may have lead paint, a good home inspector may likely provide such knowledge. 

In April this year I did a presentation about lead and the new RRP Rule for the New England Chapter of the American Society of Home Inspectors (ASHI New England).  Ironically, the meeting was scheduled for Earth Day, the same day the RRP rule went into effect.  At this meeting I informed the inspectors not only about the required EPA RRP lead –safe work practices, but also about the health effects of lead and the required documentation that home owners should receive on completion of a renovation if the property was built prior to 1978.  The inspectors were quick to connect the dots between identifying recent renovations and suggesting to the buyer that they ask the seller for a copy of these documents.

In my experience, home inspectors, particularly ASHI members, are typically a very detailed and knowledgeable group of professionals who seek to constantly increase their knowledge.  In fact, to maintain their membership in ASHI, members are required to obtain continuing education credits.  Home inspectors separate themselves from their completion through their knowledge and expertise and use these advantages to better serve their clients.  Home buyers have home inspections performed prior to a purchase as a way to not only identify the condition of a home, but to also identify any health and or safety issues the home may have. Good home inspectors should have knowledge about the EPA RRP rule and will share this information with their clients.

ASHI Home InspectorHome inspectors will help cause compliance with the EPA RRP rule in a few ways.  First, they will likely make home buyers aware of the fact that if built before 1978, the home may likely contain lead paint.  The only way to verify if lead paint is present is to do a lead test.  Inspectors can suggest their clients ask the seller if the home has been tested and if it has to obtain a copy of the required lead inspection report.  Next, if the home does have lead, or it hasn’t been tested, inspectors should inform the buyers that any renovations to the home would need to be done using lead-safe work practices.  This will have two effects.  The first would be to let the buyer know that lead-safe work practices are required should they be planning any renovations after purchasing the home.  Second, and most critical, would be to verify that any recent renovations done at the home were done using lead-safe work practices and to verify this by making sure who ever did the work did it in compliance with the EPA RRP requirements.  Again, requesting a copy of the required documentation will be the best way a buyer can confirm how such renovations were completed.

Home Owner paintingAdditionally, if the work was done by the home owners themselves, or perhaps was done illegally by a non-complaint contractor, the only way to find out if the work may have contaminated the home with lead would be to have the home tested by a licensed lead inspector.   This is likely to create heartburn for both the seller and the realtors involved in the sale.  Federal disclosure rules about lead require that if a home is tested, the required lead test report must be disclosed to any buyer or anyone planning to rent or lease the property.  Failure to do so would result in serious legal liabilities for the seller and also for the realtor should the realtor be aware of the testing.  If the seller refuses to allow testing, the buyer may just walk away from the purchase and has the legal right to do so.  


As the above described scenarios take place during real estate transactions, I predict home owners, home buyers and realtors will all become more and more aware of the EPA RRP rule.  Each, and for their own reasons, will likely become frustrated and or disappointed.  All will share their frustration and disappointment with someone else.  Its only human nature to do so.  This will result in spreading the word about the EPA RRP rule and will contribute to the reporting of violations and the enforcement of the rule by either the EPA and or those states that have assumed administration and enforcement of the rule.

Topics: Effects of the RRP Rule, Legal Considerations, Shawn's Predictions, Info for Landlords, Lead Test Kits and Testing, Enforcement and Inspections

What is Required To Become A Licensed Lead Inspector?

Posted by Shawn McCadden on Fri, Aug 27, 2010 @ 09:32 AM

What is Required To Become A Licensed Lead Inspector?

Licensed Lead InspectorMany remodelers have shared with me that they have been entertaining the idea of become licensed lead inspectors.  Recognizing the new EPA RRP rule as here to stay, many see doing inspections as an opportunity to diversify their business's offerings and at the same time add some much needed revenue due to our current economic challenges.

I asked John MacIsaac of ASAP Environmental, a lead testing expert and recognized leader in his industry, to write an article for RRPedia.  The article below was written by John to help contractors understand what is involved if they would like to consider become inspectors.  John pointed out to me that licensing requirements definitely vary from state to state.  John's article is specific to Massachusetts requirements, but should help provide a general understanding of what to expect if you seek to be licensed in other states.

The Article:

The first step in being licensed as a lead inspector in Massachusetts is to attend a six-day, 48-hour CLPPP approved training course.  The course costs $1675 at The Institute of Environmental Education (IEE).  The training course teaches how to perform lead inspections and risk assessments in residential property in Massachusetts. Topics include background information on lead, sources of lead exposure, health effects for adults and children, regulatory information, testing equipment, and procedures for performing lead inspections, risk assessments, re-inspections and post compliance inspections.  Once the course is completed you have to take an exam given by the Massachusetts Department of Public Health.  You will need an 80% or better in order to pass the test.  There is no charge to take this test.

Blood Test VialUpon successful completion of the examination and a lead physical and blood test, you need to complete an apprenticeship program with a licensed Master Lead Inspector.  It costs between $3,000 and $5,000 to do an apprenticeship.  You must work with the Master Lead Inspector for a total of 80 hours and you must accompany the Master inspector on 15 inspections.  The 15 inspections will consist of 7 Initial Inspections (5 using the XRF gun and 2 using sodium sulfide), 6 re-occupancy reinspections or final deleading reinspections, and 2 PCADs (post compliance assessment determinations). 

Once the apprenticeship is completed the paperwork is sent to the Childhood Lead Poising Prevention Program (CLPPP) and they will issue you a lead inspector’s license for Massachusetts.  This license will allow you to do Initial Lead Inspections, Reinspections, and Lead Determinations.  It will also allow you to issue Letters of Reoccupancy and Letters of Compliance.  The license will only be valid in Massachusetts.  There is no reciprocity with your licenses, in other words you will not be able to use the license in any other state for inspections.  All other states in New England have their own licensing process that would need to be followed to inspect in that state.

After having preformed 75 Inspections or Reinspections you can apply for a risk assessors licenses in MA.  As a Risk assessor you can do risk assessments for interim control. 

CLPPP offers refresher courses that will need to be taken periodically to maintain your license.  They are a 1 day course with a test at the end of the day that you must pass in order to maintain your license

You must renew your license once a year.  For Lead Inspectors/Risk Assessors the renewal fee is $325.  For Master Lead Inspectors the fee is $425.

XRF GunBrand new XRF Machines go for anywhere from $15,000 to upwards of $30,000.  You may be able to purchase one used from the manufacturer or online.  It can cost upwards of $5,000 a year to maintain them. 

If you are a Certified State Licensed Renovator as well as a Certified Lead Inspector, Massachusetts will not allow you to do Comprehensive Initial Inspections, Risk Assessments, or Lead Determinations on your own property or a property you are working on (RRP) because of a potential conflict of interest.  You will be required to have it tested by another Massachusetts licensed inspector.

For information you can go to the following:

Childhood Lead Poison Prevention Program (CLPPP)

Massachusetts Childhood Lead Poisoning Prevention Program’s database for lead inspected homes.

MA Department of Occupational Safety (DOS)


Institute for Environmental Education (IEE)

RMD Instruments

Thermo Scientific

Note:  This information was provided by John MacIsaac of ASAP Environmental, Inc.

Topics: RRP Questions, Definitions, Lead Test Kits and Testing