[hammerz_nailz]

I have heard several interpretations of the new RRP rule on plaster and drywall testing so I emailed the EPA.
The response I got was that as a certified renovator, I am not qualified to do any lead testing on plaster or drywall.


To: Sam Brown/DC/USEPA/US@EPA

Date: 04/27/2010 07:56 AM

Subject: LeadCheck on plaster and drywall






Sam,

My name is David Bailey and I am a certified renovator in Connecticut.

On the EPA website is says this " EPA recognizes that, when used by a
certified renovator, the LeadCheck® lead test kit can reliably determine
that regulated lead-based paint is not present on all surfaces, except
plaster and drywall."

Does this mean that certified renovators cannot use the EPA approved
LeadCheck kits on plaster and drywall?

Thank you in advance for clearing this issue up for me.

Thanks,
David Bailey





Yes, this is the case.

In order to check for lead on plaster and drywall, you can hire a
certified risk assessor or lead inspector and have them to take XRF
measurements or have them collect paint chip samples and send them to a
laboratory. Or you can assume lead is present and perform the RRP
activities.

Samuel F. Brown
Mathematical Statistician
OPPT/NPCD/PAOB
202-566-0490

 

[Steve Richards]

In order to check for lead on plaster and drywall, you can hire a
certified risk assessor or lead inspector and have them to take XRF
measurements

The lady that taught my class was a lead inspector.
She said she charges $175 to show up at the door with her XRF, plus (I think she said) $30 per surface, averaging about $400 per house total.

I plan on figuring there's lead and dealing with it accordingly. Unless the property owner wants to shell out the extra.

For now anyhow...

 

[FStephenMasek]

The lady that taught my class was a lead inspector.
She said she charges $175 to show up at the door with her XRF, plus (I think she said) $30 per surface, averaging about $400 per house total.

I plan on figuring there's lead and dealing with it accordingly. Unless the property owner wants to shell out the extra.

For now anyhow...

Watch out for that kind of pricing (low base plus so much per sample). To test a whole house according to the protocol in Chapter 7 of the HUD guidelines will require 200 to 300 samples, so it seems her price is really be $6,175 to $9,175 for a house! As an example, consider a typical bedroom. The following surfaces would have to be tested: Wall 1, Wall 2, Wall 3, Wall 4, Ceiling, Window frame assembly, window sash, base molding assembly, door frame assembly, door, closet door frame assembly, closet door, closet walls, closet shelf assembly, and so forth - you get the idea. Each is a seperate surface.

A reasonable price for a whole house would be $600, maybe $750 for large old one. How long would it take for you to spend that much on RRP procedures? This is especially signifiant for the newer buildings where there may not be any lead-based paint.
________
Vaporizer Reviews

 

[festerized]

As Mr. Brown stated in his letter, “Or you can assume lead is present and perform the RRP
activities.” Otherwise you force your home owner to have their house listed as known to have lead present.

 

[superseal]

And what happens if a pre 78 home was remodeled in 1991 and you know for a fact ( because you did it) will testing and RRP still apply?

Sorry, just having a hard time grasping all the variables :wallbash:

 

[festerized]

Mandate is determined by the date on the title of the house not when it was renovated

 

[TempestV]

According to the guy that taught my class, you have to take a representative sample- in other words, one sample on the wall in a particular room would be sufficient, not a sample from each of the 4 walls. Also, if you are not disturbing something, you don't need to test it. In other words, if you are tearing out the trim, but not touching the drywall or plaster, you could test the trim, and not worry about the walls. The only time I would test is if the house is from the 70's. Anything older than that, the chances of finding lead paint are so high anyways that it isn't really worth testing.

 

[FStephenMasek]

And what happens if a pre 78 home was remodeled in 1991 and you know for a fact ( because you did it) will testing and RRP still apply?

Sorry, just having a hard time grasping all the variables :wallbash:

Documentation is always helpful. If the materials were installed in 1991, they are not suspect. Common sense still applies. For example, a person might also realize that certain products were not used in 1978 or earlier, such as MDF moldings, so there is no need to worry about them being coated with llead-based paint.
________
Volcano Vaporizer

 

[FStephenMasek]

According to the guy that taught my class, you have to take a representative sample- in other words, one sample on the wall in a particular room would be sufficient, not a sample from each of the 4 walls.

In the example, a price for a whole house survey was mentioned. To do it according to the guidelines, one test on each of the four largest walls in each "room equivalent" would be needed.
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_GODIVA_ live

 

[MRBILL0]

LeadCheck Not Accepted in California

David, I just completed the certification for the RRP and while LeadCheck seems like such a perfect product AND allows us to do our own assessments for the presence of lead, our instructor told us it is not allowed in California due to the many false negatives. I wonder if the EPA is going to reconsider the product's acceptance in view of this.

Accordingly, I have spent a fair amount of time researching LeadCheck and found a rather lengthy but thoroughly researched article on LeadCheck called "Reliability of spot test kits for detecting lead in household dust" written by several PhD's at the University of Rochester. Since I am a new member, I cannot post the URL but it looks something like this:

ncbi dot nlm dot nih dot gov slash pmc slash articles slash PMC2170477

The article states that the product had a false negative rate of 64% when compared to the lab results for the corresponding dust wipe. Thus, in California, we have either to submit paint chips for lab analysis or have a certified inspector perform on-site XRF (X-Ray Fluresence) testing. In a way I am glad since it removes a whole bunch of liabilty off my shoulders.

Glad I found your post. I plan on contacting Samuel Brown and will advise if he has a reply.
Bill Pickard

 

[FStephenMasek]

....our instructor told us it is not allowed in California due to the many false negatives. Bill Pickard

That blanket assertion is incorrect.

One issue in California is that LA County (except Pasadena and Long Beach) has lowered the threshold to greater than 0.7, and San Diego City has lowered it to greater than or equal to 0.5, levels the swabs are not designed to achieve. Otherwise, they are OK for RRP compliance (of course subject to the plaster and drywall limitation, and the other limitations contained in the instructions).

Another issue is that Cal-OSHA (Title 8, Section 1532.1) states "Methods for the determination of lead concentrations of surface coatings and material shall be determined by methods which have an accuracy (to a confidence level of 95 percent) of not less than plus or minus 25 percent at 0.06% lead dry weight (600 ppm)." There is a great deal of mis-information in California due to the Cal-OSHA requirements. Some crooked or mis-informed contractors and consultants try to claim than an abatement contractor is needed for all work with lead. That is baloney.

Both federal and California OSHA regulate ANY amount of lead. However, all this really means for low levels not considered to be lead-based paint is that contractors need to have their exposure assessment data and be acting according to what it shows. Exposure assessments are done for lead (and asbestos) using small battery-powered "personal pumps" clipped to workers' belts, with a hose to a filter cassette clipped to the lapel of their shirt for a work shift. The data is gaterhed for diffeent types of work by different types of workers, and kept organized. It is just that simple, and is mandatory.
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Side effects from depakote