Is the White Glove Test Dead?

Will the EPA's July 15th announcement re: Clearance Testing eliminate the White Glove Test? There is much speculation,  but the details that were outlined in the proposal printed in the May 6, 2010 Federal Register provide some insight.

Contained in that document, the EPA states that they are proposing to require dust wipe testing be performed after the following interior renovation jobs: (May 6 Federal Register, page number 25047)

  • Removal or replacement of window or door frames
  • Use of a heat gun below 1100 degrees F, or high speed tools (i.e. sanders) for paint removal.
  • Scraping 60 or more square feet of painted surface.
  • Removing 40 or more square feet of trim, cabinetry, molding or other fixtures.
  • Removal of 6 or more square feet of  plaster and lath by “destructive” means, which the EPA has loosely defined as that done with a sledgehammer.  If you are not performing these types of work, the new ruling may not have any effect on your business.

These work sites would require dust-wipe testing by an accredited dust-sampling technician, a certified inspector, or a certified risk assessor in an EPA-certified off-site laboratory or in a mobile laboratory on-site. 

In the Federal Register it is clarified that “under this proposal, dust-wipe testing would be performed after cleaning verification, not instead of it.”

If you do the types of work listed above, the proposed changes are would greatly impact the cost, procedure, timing and difficulty of performing RRP.  If the EPA decides to extend the proposal for all types of work currently noted in the RRP Rule, it will mean that current methods of sampling and clearance testing will no longer be something a firm can accomplish … unless the new rule allows renovators to choose to take on more training, tools, and certification to allow compliance.

Clarification of Terms You Need to Know
Some of our readers have indicated confusion about the July 15 Clearance Testing proposal terminology and requirements, with respect to clearance testing, dust sampling, and certification levels as defined by the EPA.  There is good cause for the confusion, since we aren’t lawyers and there is a lot of gray area in RRP and the proposed changes as far as how things are defined.  Here are some common terms used by the EPA as they are defined in the May 6, 2010 Federal Register:

Dust-wipe sampling vs. Dust-wipe testing

Dust Wipe Sampling refers to specific activity of collecting the wipe samples, not to the analysis or reporting of results.

Dust Wipe Testing goes beyond the collection.  It is the collecting of wipe samples of dust on floors, windowsills, window troughs, and the analyzing of those samples for lead content, and reporting the results of the analysis to the owners and occupants of the building being renovated.

EPA is using "Dust Wipe Testing" in this notice to signal that sample analysis may be performed offsite in a traditional lab setting or on-site by a portable lab, so long as the entity performing the analysis is accredited by National Lead Laboratory Accreditation Program.

This is demonstrating, through dust wipe testing, that the floors, windowsill and window troughs in renovation work are below regulatory clearance standards. Clearance provides permission for occupancy and further work to continue and signals the finalization of on-site RRP work.

Certified Renovator vs. Dust Sampling Technician
Certified Renovator is the basic certification level that every firm performing RRP work must have.  It is important to note that the certified renovator is not the same as a Dust-sampling technician, which requires further credentials. To become an EPA-certified dust sampling technician, an individual must successfully complete the appropriate course accredited by EPA under §745.225.

A Dust Sampling Technician can perform dust clearance sampling.  The Dust Sampling Technician is also able to prepare the final clearance report based on the results from the EPA-certified lab.

Risk Assessors and Certified Inspectors
A lead risk assessor is trained to conduct risk assessments.  He can also sample for the presence of lead in dust and soil for the purposes of abatement clearance testing.

EPA website