My firm is not RRP-certified and does not employ an RRP-certified renovator. If we are asked to perform a renovation in a pre-1978 home, we first test the home for the presence of lead using an EPA-recognized lead test kit. If lead is present, we decline the job. If lead is determined not to be present, we accept and proceed normally. Can we perform these lead tests without being a certified renovator?
No. When performing a renovation in a pre-1978 home, a firm is exempted from the requirements of the RRP Rule if a determination has been made that the surfaces affected by the renovation are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 mg/cm2 or 0.5% by weight. However, in order for this exception to apply, the determination must be made by a certified lead inspector or risk assessor, or by a certified renovator using an EPA-recognized lead test kit and following the lead test kit manufacturer’s instructions.