RRP lead test kit records: what to write down

Who can test, and with which kit

Only a certified renovator can use a test kit to make this call. The kit must be one EPA recognizes under section 745.88. EPA's test kit page lists the kits it recognizes and the surfaces each one is recognized for. Check that page before you buy, and use the kit only on those surfaces.

Follow the maker's instructions exactly. A kit used the wrong way, or on a surface it is not recognized for, does not give a result you can rely on.

Test every part the job will disturb

Section 745.82(a)(2) requires a test on each component affected by the renovation. A window job may disturb the sash, stops, stool, apron, and casing, and each one can have a different paint history.

There is one shortcut. If parts make up an integrated whole, such as the treads and risers of one staircase, you can test one of them, unless some appear to have been repainted or refinished separately. If in doubt, test more.

What the record must show

Section 745.86(b)(1)(ii) lists the facts: the maker and model of each kit used, a description of each part tested and where it is, and the result of each test. The renovator's certification in section 745.86(b)(6) must also state that the named kit was used at the named locations with the stated results.

EPA's sample renovation recordkeeping checklist has a place for this. You can use it, or any form that holds the same facts. Our free recordkeeping checklist is based on EPA's sample.

• Kit maker and model.
• Lot number and expiration date, if printed. Not required, but useful.
• Each part tested, described plainly. For example: left window casing, living room.
• Location of each test.
• Result of each test.
• Name of the certified renovator who tested, and the date.
• A photo of each test spot and result. Not required, but useful.

What each result means

A negative result on every affected part means those parts are treated as lead-free, and the rule does not apply to work on them. A positive result on any part means you treat that part as lead-based paint and follow the full rule.

You can also skip testing and assume lead is present. Either way, record the choice.

Give the results to the owner and occupant

Section 745.86(c) says the firm must give the job's compliance information to the owner and, if different, an adult occupant. The deadline is when the final invoice is delivered or within 30 days of finishing the job, whichever comes first. That information includes the test kit details. In common areas of apartment buildings, the firm posts the information or explains how occupants can get a copy.

Keep a copy of what you sent, and when. Our recordkeeping requirements guide covers the rest of the job file.

Questions contractors ask

Can an uncertified worker run the test? No. The rule says a certified renovator.

Is a paint chip test better? It is another option. A certified renovator collects a chip from each part and an EPA-recognized lab analyzes it. Keep the lab report.

Does a negative test from a past job count? The rule does not say. The safe choice is to test each part again for each job.