Frequent Questions About Testing for Lead-Based Paint

How to Check your Home for Lead-Based Paint

How can I tell if my home contains lead-based paint?

The older your home, the more likely it contains lead-based paint. For example, 87% of homes built before 1940 have some lead-based paint, while 24% of homes built between 1960 and 1978 have some lead-based paint. Lead-based paint may be present in private single-family homes or apartments, government-assisted or public housing, and in urban, suburban or rural settings. If you want to know whether or not your home contains lead-based paint, EPA recommends one of the following:

Assume your home contains lead-based paint and take the appropriate precautions. In pre-1978 homes and buildings, this is the simplest and safest approach.
Hire a certified professional to check for lead-based paint. A certified lead-based paint inspector or risk assessor can conduct an inspection to determine whether your home or a portion of your home has lead-based paint and where it is located. This will tell you the areas in your home where lead-safe work practices should be used for renovation, repair or painting jobs. A certified risk assessor can conduct a risk assessment telling you whether your home currently has any lead hazards from lead in paint, dust or soil. The risk assessor can also tell you what actions to take to address any hazards. For help finding a certified risk assessor or inspector, call the National Lead Information Center at 1-800-424-LEAD (5323).

A number of lead test kits are available for consumer purchase in most retail hardware stores, however, the Consumer Product Safety Commission (CPSC) states that consumers should exercise caution when using these lead test kits to evaluate consumer products for potential lead exposures.

To test for lead-based paint in your home, EPA recommends that you hire a certified inspector or risk assessor. For determining whether lead-based paint is present in pre-1978 housing and childcare facilities that are subject to renovation, repair and painting regulations, EPA has recognized three lead test kits, but recognition only applies to use by Lead-Safe Certified renovators.

You may also choose to contact a laboratory recognized under EPA’s National Lead Laboratory Accreditation Program (NLLAP) for lead paint chip, dust or soil sample analysis. View a list of available NLLAP laboratories, including their recognized sample type(s).

Question Number: 23002-16836

When the Renovation, Repair and Painting (RRP) Rule Requires Testing

Is lead paint testing required under the RRP Rule?

No. A firm can either assume lead-based paint is present and follow the requirements of the RRP Rule (which requires no testing), or test and if lead-based paint is found follow the requirements of the regulation.

Question Number: 23002-32338

When testing a work area, does one lead test kit or paint chip sample suffice for any single component?

The certified renovator is only required to use one lead test kit or paint chip sample for each component, even if the surface of the component is extensive (e.g., a large wall).

Question Number: 23002-23865

Does the RRP Rule apply to work on windows that have been installed within the last 20 years in a pre-1978 housing unit?

The RRP Rule applies unless you have determined that all the components affected by the renovation, including the windows, are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm²) or 0.5% by weight. This determination must be made either by a certified inspector or risk assessor, or by a certified renovator using an EPA-recognized lead test kit or performing paint chip sampling. You must keep records of any lead-based paint free determination and make the records available to EPA if requested.

Question Number: 23002-15694

When a certified renovator uses an EPA-recognized lead test kit or performs paint chip sampling to determine the presence of lead, can the results be grouped? For instance, may the certified renovator test just one window sill in a room if all will be affected?

No. The certified renovator must test each component affected by the renovation. If the components make up an integrated whole, such as the individual stair treads and risers of a single staircase, the renovator is required to test only one of the individual components, unless the individual components appear to have been repainted or refinished separately. Multiple window sills in a room are not integrated parts of a whole. They are separate components and must be tested separately.

Question Number: 23002-23701

Under the RRP Rule, when testing a property for the presence of lead prior to beginning a renovation using an EPA-recognized lead test kit, must I test every component affected by the renovation?

Yes. Certified renovators using EPA-recognized lead 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 because certified renovator training does not cover sampling protocols.

Question Number: 23002-20750

Lead-Based Paint Test Kits

What lead test kits are recognized by EPA?

EPA recognizes three lead test kits for use in complying with the negative response criterion of the RRP Rule. They are the Luxfer Magtech LeadCheck™ kit (for use on ferrous metal, plaster, drywall and wood), the State of Massachusetts kit (for use on drywall and plaster), and the D-Lead® kit (for use on wood, drywall, plaster and ferrous metal). If a substrate material is not listed above (such as stucco or non-ferrous metals) then the EPA-recognized lead test kits cannot be used on that substrate to comply with the testing requirements of the RRP Rule.

Note: 3M sold the formulation and trademarks related to the 3M™ LeadCheck™ test kits to Luxfer Magtech. EPA recognizes the LeadCheck™ test kit made and distributed by Luxfer Magtech. Find more information about the EPA recognized lead test kits.

Question Number: 23002-23255

How can I obtain 3M LeadCheck™ test kits?

3M sold the formulation and trademarks related to 3M™ LeadCheck™ Instant Lead Tests to Luxfer Magtech. EPA recognizes the LeadCheck™ test kit made and distributed by Luxfer Magtech for compliance with EPA’s RRP Rule when used by a trained professional. The Luxfer Magtech LeadCheck™ test kits are expected to be available at home centers and major hardware stores in early 2025. For more information on Luxfer Magtech LeadCheck™ test kits, call 800-503-4483 to speak with a customer service representative. You may continue to use 3M™ LeadCheck™ test kits you may have on hand. Find more information about the EPA-recognized lead test kits.

Question Number: 23002-16393

Does EPA recognize the Luxfer Magtech LeadCheck™ test kit for use on red paint?

Yes. EPA recognizes this lead test kit for use on any color paint as long as the lead test kit is used in accordance with the manufacturer’s instructions.

Note: 3M has sold the formulation and trademarks related to the 3M™ LeadCheck™ test kits to Luxfer Magtech. EPA recognizes the LeadCheck™ test kit made and distributed by Luxfer Magtech. Find more information about the EPA-recognized lead test kits.

Question Number: 23002-15505

Is it true that the lead test kits that were recognized by EPA before September 1, 2010, are no longer recognized since that date?

No. The lead test kits that were recognized by EPA before September 1, 2010 did not automatically lose their recognition on September 1, 2010. As discussed in the 2008 RRP Rule, prior to September 1, 2010, manufacturers seeking recognition of their lead test kit had to meet only the negative response criterion. EPA recognition of lead test kits meeting this criterion will last until EPA publicizes its recognition of a lead test kit that passes both the negative response and the positive response criteria.

Question Number: 23002-19098

Will there be any phase two lead kits approved as a result of EPA’s Environmental Technology Verification (ETV) evaluations?

Based on the results of the ETV evaluations in 2010 no lead test kits were approved that meet both the negative response and positive response criteria requirements. However one lead test kit, D-Lead®, did meet the negative response criterion for drywall, plaster, ferrous metal and wood, and was recognized for use by certified renovators on August 31, 2010. Thus, after September 1, 2010, EPA will continue to recognize 3M LeadCheck^TM (now Luxfer Magtech LeadCheck^TM) the State of Massachusetts kit and the newly recognized D-Lead® kit.

Note: 3M sold the formulation and trademarks related to the 3 LeadCheck™ test kits to Luxfer Magtech. EPA recognizes the LeadCheck™ test kit made and distributed by Luxfer Magtech. Find more information about the EPA-recognized lead test kits.

Question Number: 23002-25349

How can I obtain D-Lead® test kits?

The D-Lead® test kits are available for purchase from certain distributors and retail outlets. Purchase the test kits online, email cservice@esca-tech.com or call (414) 962-3006.

Question Number: 23002-16390

Can a person who is color blind use the Luxfer Magtech LeadCheck™ test kits?

A certified renovator seeking to use an EPA-recognized lead test kit for RRP purposes must be able to use the lead test kit and interpret the results, in accordance with the manufacturer’s instructions. A person who is unable to accurately use the product due to a permanent or temporary disability cannot, and should not, rely on any results for RRP purposes.

Question Number: 23002-32520

Who Can Use Test Kits

The lead information pamphlet titled "Renovate Right" states there is a kit consumers can use to collect samples to send to a lab if they suspect any lead hazards have been left after a renovation. Do samples like these need to be taken by certified abatement personnel or a dust sampling technician?

No. When all the work is finished, you may want to know if your home, child care facility or school has been cleaned up properly. One way to check is a lead-dust test. Lead-dust tests are wipe samples sent to a laboratory for analysis. You have the choice of having a lead-dust test done by a lead professional or doing the testing yourself. If you choose to do the testing, some EPA-recognized lead laboratories will send you a kit that allows you to collect samples and send them back to the lab for analysis. Contact the National Lead Information Center at 1-800-424-LEAD (5323) for lists of qualified professionals and EPA recognized lead labs. View a list of available EPA-recognized lead laboratories.

Learn more about making sure your home, child care facility or school has been cleaned properly after a renovation.

Question Number: 23002-20555

Do test results from a certified renovator using an EPA-recognized lead test kit (40 CFR 745.83) or performing paint chip sampling (40 CFR 745.82) become an official part of the lead-based paint testing record for that house thus negating the need for a certified lead inspector or certified lead risk assessor to conduct the inspection in that area of the house? Can a certified renovator conduct a complete lead-based paint inspection and give the property owner as an inspection report?

The results of paint testing using lead test kits or paint chip sampling are part of the official lead-based paint testing record for a home, and must be disclosed under EPA's Real Estate Disclosure regulation (40 CFR part 745, subpart F). However, EPA's regulations only provide for a certified inspector or risk assessor to conduct a lead-based paint inspection and to prepare a lead-based paint inspection report. Thus, allowing renovators to test components does not negate the requirement that a certified inspector or risk assessor follow the requirements set forth in § 745.227(b) when conducting a lead-based paint inspection.

Question Number: 23002-15211

If a certified renovator using an EPA-recognized lead test kit or paint chip sampling determines that the components that will be affected by a renovation are free of lead-based paint, can a firm that does not have RRP certification do the actual renovation work? What record-keeping requirements would apply?

Where a certified renovator performs paint chip sampling or uses an EPA-recognized lead test kit following the lead test kit manufacturer’s instructions, tests each component affected by the renovation and determines that the components are free of paint or other surface coatings that contain lead at regulated levels, the renovation can be performed by a non-certified firm and without regard to the work practice standards or record-keeping requirements of the RRP Rule. See 40 CFR 745.82(a)(2).

However, the certified renovator and firm performing the testing are still subject to the recordkeeping requirements of 745.86(b)(1)(ii) and (iii) and 745.86(a) and (c). Specifically, the certified renovator must prepare a record that states the brand of lead test kit used or the name and address of the EPA-recognized laboratory performing the paint chip analysis, a description of the components tested including their location, and results of the tests. The certified renovator’s firm must retain a copy of this record for three years. EPA further recommends that the firm actually performing the renovation also retain a copy of these records to demonstrate that compliance with the RRP Rule was not required.

Question Number: 23002-18220

My firm is not certified and does not employ a certified renovator. If we are asked to perform a renovation in a pre-1978 home, we test for lead using an EPA-recognized lead test kit. 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.

Question Number: 23002-31777

I am an EPA-certified lead risk assessor. Can I use an EPA-recognized lead test kit when assessing whether or not a pre-1978 home contains lead-based paint for purposes of the RRP Rule?

Yes. In addition to a certified renovator, a person certified by EPA as a risk assessor or lead inspector may use an EPA-recognized lead test kit to determine that regulated lead-based paint is not present in a home. Such a report can also be used to confirm that the RRP Rule would not apply to renovation activities in that home. A list of currently EPA-recognized lead test kits is available online.

Note: As of October 2023, 3M has suspended the production and sale of 3M™ LeadCheck™ test kits. Find more information about the EPA recognized lead test kits.

Question Number: 23002-31778

Can a homeowner use an EPA-recognized lead test kit to check for lead-based paint?

A number of lead test kits are available for consumer purchase in most retail hardware stores; however, the Consumer Product Safety Commission (CPSC) states that consumers should exercise caution when using these lead test kits to evaluate consumer products for potential lead exposures. Find more information online.

To test for lead-based paint in your home, EPA recommends that you hire a certified inspector or risk assessor. For determining whether lead-based paint is present in pre-1978 housing and childcare facilities that are subject to renovation, repair and painting regulations, EPA has recognized three lead test kits, but recognition only applies to use by Lead-Safe Certified renovators.

You may also choose to contact a laboratory recognized under EPA’s National Lead Laboratory Accreditation Program (NLLAP) for lead paint chip, dust or soil sample analysis. A list of available NLLAP laboratories, including their recognized sample type(s), is available online.

Question Number: 23002-33650