Under the RRP Rule, is composite sampling acceptable for post-renovation dust-lead testing in lieu of cleaning verification?

Yes. Under the RRP Rule, cleaning verification need not be performed if the contract between the renovation firm and the person contracting for the renovation or another federal, state, territorial, Tribal or local law or regulation requires:

• The renovation firm to perform post-renovation dust-lead testing at the conclusion of a renovation covered by this subpart;
• The post-renovation dust-lead samples are required to be collected by a certified inspector, risk assessor or dust sampling technician; and
• The renovation firm is required to re-clean the work area until the post-renovation dust-lead testing results are below the action levels in 40 CFR 745.227(e)(8) or any applicable State, Territorial, Tribal, or local standard.

Post-renovation dust-lead testing must be performed following the procedures in 40 CFR 745.227(e)(8), which allow the use of composite sampling. Not all laboratories will analyze composite samples, so check with your laboratory before collecting them. Typically, interior clearance is achieved by means of dust wipe sampling by a certified inspector or risk assessor using single surface dust wipes. This is required on all U.S. Department of Housing and Urban Development (HUD) jobs.  

Question Number: 23002-20755

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