The Case for Clearance Sampling: You Don’t Have To, But You Might Want To

I know, many looked at it as the boogeyman … but the EPA’s consideration of requiring Clearance Testing has some merit. Before you all click through to something else, hear me out. First, one of the most significant issues arising out of the RRP rulemaking was the issue of how to determine whether a renovation had been properly completed. Second, the EPA has wrestled with some compelling arguments based on health and the general goal of the movement to rid homes of the lead paint dust danger. The EPA has struggled with claims that cleaning verification with the card is subjective and: 1.There’s no definitive method to judge the Certified Renovator’s “…understanding and application of the protocol, (use of the verification card), ability to define the floor sampling area(s), or use of the cleaning verification card to determine whether a surface has been adequately cleaned.” 2. Accuracy:  the “…renovator’s accuracy in comparing the cleaning cloth to the verification card”, citing their visual acuity, light levels, degradation and fading of the card, missing cards, etc. 3.Conflict of interest for the renovator who does the work, checking the work without substantiation. To address these various concerns, EPA began looking for an alternative to dust wipe testing and clearance that would be quick, inexpensive, reliable, and easy to perform. EPA conducted a series of studies using commercially available disposable cleaning cloths to determine whether variations of a “white glove” test could serve as an effective alternative to clearance. Based on the favorable final report of these studies, entitled “Electrostatic Cloth and Wet Cloth Field Study in Residential Housing” (Disposable Cleaning Cloth Study) (Ref. 16), EPA's 2006 Proposal included a cleaning verification protocol using wet and dry disposable cleaning cloths. While all interior experiments resulted in final passed cleaning cloths for all floor zones and for all windowsills, nearly half of the experiments in the study ended with average work-room floor lead levels above EPA's dust-lead hazard standard for floors of 40 µg/sqft. The Clean Air Scientific Advisory Committee, who was asked to review the underlying analysis for the estimation of the effect of the RRP rule on children's blood lead levels, stated that in the Dust Study, cleaning verification did not provide sufficiently reliable results, leading to an inaccurate assessment of cleaning efficiency. Yes, there are additional costs with laboratory testing, and these costs increases can be debated as to whether they should be borne by the contractor or the homeowner. The bottom line.  This author has long proposed that wipe sampling be done for all jobs as a matter of reducing liability. The whole of RRP has been intrusive, however maybe the effort should be made to look for ways to make this work for us, because it's not going away.  The arguments for protecting residents and workers from lead poisoning are just too compelling.