Last week, we had an audit for compliance with the requirements in the Lead Based Paint RRP Program. On one of the random jobs selected for review, we were found to be in violation because the lead testing that was done by a testing company hired by the contractor was not the correct one for what is required before disturbing painted surfaces on any pre-1978 residential buildings. This could result in a fine by the EPA. Over the last couple of years, as we have stepped out of the role as a contractor and become a subcontractor, we have learned that there are requirements for both roles when painted surfaces in pre-1978 buildings are being disturbed. As a Certified Renovation Firm, when we are working as a subcontractor, we are required to do one of the following: obtain lead-based paint test results from the contractor on the job for the painted surfaces being disturbed, test the surfaces ourselves before disturbing painted surfaces, or assume lead-based paint is present and follow the lead-safe work practice requirements. This includes giving the property owner the Lead Safe Renovate Right pamphlet and completing all necessary paperwork. Contractors are required to provide subcontractors with lead-based paint test results or verify that they have the proper lead certifications and are doing one of the things listed above. As found on the EPA website, options for paint testing by certified professionals include an EPA-recognized paint test kit, sending a paint chip sample to a National Lead Laboratory Accreditation Program certified lab, or performing X-ray fluorescence (XRF) testing. EPA has recognized three lead test kits for use in complying with the RRP Rule. They are the 3M™ LeadCheck™, D-Lead®, and the State of Massachusetts lead test kits. 3M™ LeadCheck™. EPA recognizes that when used by a Certified Renovator, the 3M™ LeadCheck™ lead test kit can reliably determine that regulated lead-based paint is not present on wood, ferrous metal (alloys that contain iron), or drywall and plaster surfaces. As of October 2023, 3M has suspended the production and sale of 3M™ LeadCheck™ test kits. D-Lead®. EPA recognizes that when used by a Certified Renovator, the D-Lead® paint test kit manufactured by ESCA Tech, Inc., can reliably determine that regulated lead-based paint is not present on wood, ferrous metal (alloys that contain iron), or drywall and plaster surfaces. State of Massachusetts. EPA recognizes that when used by trained professionals, the Commonwealth of Massachusetts lead test kit can reliably determine that regulated lead-based paint is not present on drywall and plaster (Doesn’t help us in Idaho). For additional information and requirements for the Lead Renovation Repair and Painting program please see the following website: https://www.epa.gov/lead/lead-renovation-repair-and-painting-program | 
