My firm is not certified and does not employ an 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 Lead Renovation, Repair, and Painting (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

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