# Possible Changes Being Considered by the EPA



## Roamer

I got this information in an email newsletter from NARI.



> *Lead Test Kits*
> On October 26, NARI representatives attended the latest RRP Implementation meeting. These meetings are comprised of interested stakeholders from industry, environmental groups, and the government. At each meeting, different divisions from the Environmental Protection Agency (EPA) talk with the group about the implementation of the lead paint program. In this last meeting, one of the items discussed was EPA's continuing efforts to address the Lead Test Kit issue.
> 
> In 2008, the EPA published the Lead Renovation Repair and Paint rule, which set negative and positive response criteria for lead test kits recognized by the EPA. To date, no test has been developed that meets both criteria, so last year Congress directed EPA to identify solutions that would allow for a test kit that meets all the criteria specified in the 2008 rule. EPA has held a number of meetings on this issue and has requested comments from the public. NARI was one of the groups that submitted comments to EPA.
> 
> At the October RRP meeting, EPA reported that the comments the Agency has received generally fall into three areas:
> 
> 1) Test Kit modification - Encourage the EPA to modify the positive test kit requirement
> 2) XRF - Reduce the certification for XRF
> 3) Narrow the scope of the RRP program - Specifically, comments encouraged limiting the RRP program to those houses built before 1960, and implementing a limited opt out for those homes built between 1960 and 1978
> 
> The EPA representative said they are currently engaging in internal discussions. The Agency has no timeframe for when they anticipate coming to a conclusion, however, the representative did say they hope to have a final action next year.


We would welcome the acceptance of an opt out clause for homes built between 1960 and 1978. Has anyone else heard anything about any of these possible changes?


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## MIZZOU

What's xrf?


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## Gough

MIZZOU said:


> What's xrf?


X-Ray fluorescence. The accepted non-destructive method to measure Lead in paint.


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## MIZZOU

Huh never heard of it, thanks


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## Gough

MIZZOU said:


> Huh never heard of it, thanks


IIRC, it often runs between $400-500 to check a modest-sized for lead.


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## RCP

Gough said:


> IIRC, it often runs between $400-500 to check a modest-sized for lead.


Yep, and besides being non destructive, they measure the level, not just the presence of lead. So while a "stick" test may prove positive, an XRF can determine the level of lead.


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## Gough

RCP said:


> Yep, and besides being non destructive, they measure the level, not just the presence of lead. So while a "stick" test may prove positive, an XRF can determine the level of lead.


We typically have samples tested in a lab to get actual levels. For that $400-500, we can get up to 20 actual samples checked. On the downside, it is destructive testing and takes a few days. OTOH, I think the nearest XRF outfit is a 2-hour drive from here, so I assume the actual cost would be even higher.

I know some PCs will wonder why we bother to learn the actual level. We do that for OSHA, not RRP. Knowing the level gives us an indication of what levels of PPE, etc. we need to be compliant with the Lead in Construction Rule.


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## Roamer

If they lower the qualifications for using the XRF then this could become a cottage industry for many painting companies to offer XRF testing. 

XRF is done by a gun that contains an xray device. XRF guns are regulated by the Nuclear Regulatory Commission.

http://nofuloge.tumblr.com/portable-x-ray-fluorescence-xrf-analyzer


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## straight_lines

I think there should be a packet written by the government with a signature line resolving the contractor of all liability and allow them to opt out of any house. Its their property and as long as neighboring properties or the environment and employees aren't contaminated it should be the owners informed decision.


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## jacob33

straight_lines said:


> I think there should be a packet written by the government with a signature line resolving the contractor of all liability and allow them to opt out of any house. Its their property and as long as neighboring properties or the environment and employees aren't contaminated it should be the owners informed decision.





The original version did have an opt out as long as no children under 6 lived in the house which I think was fair. It was removed. I think it should be put back in.


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## DeanV

The only downside is that what if someone does a job that contaminates the house and then it is sold to an unsuspecting family with young children?


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## straight_lines

Not much different than selling a house full of peeling lead paint everywhere. Or a what about a basement with 100's of feet of pipes wrapped in failing asbestos.


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## DeanV

straight_lines said:


> Not much different than selling a house full of peeling lead paint everywhere. Or a what about a basement with 100's of feet of pipes wrapped in failing asbestos.


Except that stuff is visible. Once lead dust is distributed through a house, it is not visible.


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