Yes. Because certified renovator training does not cover sampling protocols, certified renovators using EPA-recognized test kits to determine the applicability of the RRP Rule must test each and every component that will be affected in order to determine that the RRP Rule does not apply to a particular renovation.
Under the Renovation, Repair, and Painting (RRP Rule, when testing a property for the presence of lead prior to beginning a renovation using an EPA-recognized test kit, must I test every component affected by the renovation?
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