Background

On April 22, 2008, EPA published the Lead Renovation, Repair and Painting (RRP) rule, which, among other things, established performance recognition criteria for lead test kits for use as an option to determine if regulated lead-based paint is not present in target housing and child-occupied facilities. The use of an EPA-recognized lead test kit, when used by a trained professional, can reliably determine that regulated lead-based paint is not present by virtue of a negative result. The RRP rule also established negative response and positive response criteria outlined in 40 CFR 745.88(c) for lead test kits recognized by EPA.

Lead test kits recognized before September 1, 2010 must meet only the negative response criterion outlined in 40 CFR 745.88(c)(1). The negative response criterion states that for paint containing lead at or above the regulated level, 1.0 mg/cm² or 0.5% by weight, a demonstrated probability (with 95% confidence) of a negative response less than or equal to 5% of the time must be met. The recognition of kits that meet only this criterion will last until EPA publicizes its recognition of the first test kit that meets both of the criteria outlined in the rule. 

Lead test kits recognized after September 1, 2010 must meet both the negative response and positive response criteria outlined in 40 CFR 745.88(c)(1) and (2). The positive-response criterion states that for paint containing lead below the regulated level, 1.0 mg/cm² or 0.5% by weight, a demonstrated probability (with 95% confidence) of a positive response less than or equal to 10% of the time must be met.

Despite the EPA’s commitment of resources to this effort, to date no lead test kit has met both of the performance criteria outlined in the RRP rule. However, there are three EPA-recognized lead test kits that meet the negative response criterion and continue to be recognized by EPA.

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EPA-Recognized Lead Test Kits

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. Obtain the National Institute of Standards and Technology (NIST) lead test kit laboratory evaluation report. Also obtain the 3M™ LeadCheck™ laboratory evaluation report (PDF) . Certified renovators seeking to use the 3M™ LeadCheck™ test kit for purposes of meeting requirements in the RRP rule can purchase the 3M™ LeadCheck™ test kits from either 3M™ LeadCheck™ directly or from certain retail outlets. To order a 3M™ LeadCheck™ test kit call 800-494-3552 or contact 3M™ at leadcheck.com/contactus. Exit

  NOTE: FOR USE ON PLASTER AND DRYWALL, users of 3M™ LeadCheck™ should download updated instructions for using the lead test kit on plaster and drywall (PDF) (2 pp, 391K). Exit The updated procedure for testing plaster and drywall is slightly different than the procedure used previously. 3M™ LeadCheck™ test kits shipped to retail outlets after April 1, 2012, will contain the updated instructions. Kits purchased prior to April 1, 2012, or that contain the older instructions can still be used but the user must follow the updated instructions when testing plaster and drywall.

• D-Lead®. Based on the results of the Environmental Technology Verification (ETV) report of vendor-submitted lead test kits, 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. Obtain the EPA environmental technology verification report on the D-Lead® test kit (PDF) . Certified renovators seeking to use the D-Lead® paint test kit for purposes of meeting requirements in the RRP rule can purchase it from certain distributors and retail outlets. Locate a distributor or retailer at www.esca-tech.com, Exit e-mail rrp@esca-tech.com or call 414-962-3006.

• 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; it is not recognized for use on wood and ferrous metal (alloys that contain iron) surfaces. Obtain the National Institute of Standards and Technology (NIST) lead test kit laboratory evaluation report.

Read a fact sheet on the EPA-recognized lead test kits (PDF) .

For any questions pertaining to the recognition of these kits, contact the National Lead Information Center.

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Lead Test Kit Environmental Technology Verification

EPA's Environmental Technology Verification (ETV) Program has completed its verification of the performance of four vendor-submitted lead test kits developed to meet the negative response and positive response performance criteria for improved lead test kits set forth under the 2008 RRP Rule.

Based on the ETV results, there are no kits that have met both the negative response and positive response criteria requirements; however, there is one kit that met only the negative response criterion (D-Lead®), and it was recognized for use as a negative response-only kit on August 31, 2010.

Get the individual lead test kit verification reports and a description of the ETV lead test kit verification program.

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