EPA-recognized lead test kits and determining the absence of regulated lead-based paint
This domain tests when a certified renovator may use an EPA-recognized test kit to establish that a component is not coated with lead-based paint. Questions focus on the limits of kits, who may use them, and what a negative result actually proves.
What kits can and cannot do
- A certified renovator may use an EPA-recognized test kit, following the manufacturer’s instructions, to determine the absence of lead-based paint on components that will be disturbed.
- EPA recognition criteria include a false-negative rate of no more than 5% and a false-positive rate of no more than 10%. The kit must be used before disturbance and within its expiration date.
- Test every component to be disturbed. A single negative spot does not clear a room or a whole window assembly.
- A positive or inconclusive result means the component must be treated as lead-based paint; use lead-safe work practices.
- A renovator may not use an XRF analyzer or perform an inspection or risk assessment. Those are separate credentials for certified inspectors and risk assessors.
Documentation
- Record the kit manufacturer, lot number, test date, tester, components tested, and results. Keep the records for 3 years.
- If the kit is expired, used on an inappropriate substrate, or used contrary to instructions, the result is invalid and the component is presumed to contain lead-based paint.
Worked example
A renovator is replacing a complete window in a pre-1978 home. He tests only the sill with an EPA-recognized kit, gets a negative result, and installs the new window without containment. The result is invalid for the job because the sash, jamb, casing, and other painted components were not tested. If any component tests positive or is not tested, the job must be treated as lead-based paint. Correct practice is to test every component to be disturbed, or presume lead-based paint and use lead-safe work practices.
Traps that cost marks
- Treating one negative kit result as clearance for the entire house.
- Testing after work has begun.
- Treating a positive result as a paperwork failure rather than as an instruction to use lead-safe practices.
- Confusing a renovator’s test kit with an inspector’s XRF inspection.
- Ignoring kit expiration or manufacturer instructions.