i 

EPA/600/R-10/066 March 2007 www.epa.gov/ord 

Lead Paint Test Kits Workshop 

October 19 and 20, 2006 

Summary Report 

Sharon Harper, Kim Rogers, Jeanette Van Emon, Myriam Medina-Vera

Human Exposure and Atmospheric Sciences Division 

National Exposure Research Laboratory 

Office of Research and Development 

Research Triangle Park, NC 27711 
ii 

Disclaimer 

The information in this document has been funded wholly or in part by the U.S. Environmental 

Protection Agency (EPA) under EPA Contract No. 68-C-02-067. It has been subjected to the 

Agency’s peer and administrative review. Mention of trade names or commercial products does 

not constitute endorsement or recommendation for use. 
iii 

Acknowledgments 

The workshop proceedings were recorded by Jennifer Blanton and Danielle Glitz, staff of 

Science Applications International Corporation, 11251 Roger Bacon Drive, Reston, VA 20190, 

under EPA Contract No. 68-C-02-067 for the National Environmental Research Laboratory 

(NERL), EPA, Research Triangle Park, NC. Sharon Harper of NERL served as the EPA Work 

Assignment Contracting Officer’s Representative. 

Special acknowledgment is given to Mrs. Katherine Bass and Mrs. Susan Pearce, Human 

Exposure and Atmospheric Sciences Division, NERL-RTP, EPA, for their assistance in 

arranging the workshop accommodations and travel. 
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v 

Table of Contents 

List of Acronyms .......................................................................................................................... vi 

Executive Summary.....................................................................................................................vii 

Introduction ...................................................................................................................................1 

Welcome, Introductions, and Meeting Overview...........................................................................1 

Development of the Next Generation of Lead Paint Test Kits ......................................................1 

Lead-Based Paint; Renovation, Repair, and Painting Proposed Rule..........................................2 

New Generation of Test Kits: Technical Approach .......................................................................3 

Key Items from the Issue Paper....................................................................................................4 

Delamination and X-ray Fluorescence Analysis of National Institute of Standards and 

Technology Lead-in-Paint Film Standards....................................................................................4 

Group Discussion..........................................................................................................................5 

Highlights of Group Discussion and “Dream” Test Kit Handout..................................................10 

Highlights of the Responses to Handout.....................................................................................11 

Appendix A: Workshop Flip Charts........................................................................................... A-1 

Appendix B: National Institute for Occupational Safety and Health Comments on the 

U.S. Environmental Protection Agency Proposed Rule ............................................................ A-5 

Appendix C: Workshop Handout Summary ............................................................................ A-15 

Appendix D: Workshop Agenda.............................................................................................. A-19 

Appendix E: List of Attendees................................................................................................. A-21 
vi 

List of Acronyms 

ASTM American Society for Testing and Materials 

ASV anodic stripping voltametry 

CRADA cooperative research and development agreement 

EPA U.S. Environmental Protection Agency 

ETV Environmental Technology Verification Program (EPA) 

HEASD Human Exposure and Atmospheric Sciences Division (EPA/ORD/NERL) 

HUD U.S. Department of Housing and Urban Development 

NERL National Exposure Research Laboratory (EPA) 

NIOSH National Institute for Occupational Safety and Health 

NIST National Institute of Standards and Technology 

OPPTS Office of Prevention, Pesticides, and Toxic Substances (EPA) 

ORD Office of Research and Development (EPA) 

RRP Lead; Renovation, Repair, and Painting Program; Proposed Rule 

SRM standard reference material 

TSCA Toxic Substances Control Act 

XRF X-ray fluorescence 
vii 

Executive Summary 

The U.S. Environmental Protection Agency’s (EPA’s) Office of Research and Development 

(ORD) designed and conducted the Lead Paint Test Kits Workshop on October 19 and 20, 

2006, at the EPA’s Research Triangle Park, NC, campus. The workshop was conducted as part 

of ORD’s support to EPA’s Office of Pollution Prevention and Toxics (OPPT). OPPT has 

requested ORD’s assistance in lead paint test kit technology development to support the 

proposed “Lead; Renovation, Repair, and Painting Program; Proposed Rule” (RRP rule) 

published in the January 10, 2006, Federal Register (pp.1587-1636). The proposed rule 

supports the attainment of the Federal government’s goal of eliminating childhood lead 

poisoning by 2010. In the rule, EPA proposes new requirements to reduce exposures to lead 

hazards created by renovation, repair, and painting activities that disturb lead-based paint. EPA 

has proposed the use of EPA-recognized test kits to determine whether the components to be 

affected are free of regulated lead-based paint. The Federal regulated level is defined as paint 

containing lead at or above 1.0 mg/cm2

 or 0.5% by weight. 

Research to date has shown that commercially available lead paint test kits suitable for use by 

remodelers, renovators, and painters are not an effective means of identifying homes that 

contain regulated lead levels in paint. In the proposed RRP rule, EPA has provided the following 

performance standards for a test kit to be recognized by EPA. 

• Demonstrated probability (with 95% confidence) of a negative response less than 5% to lead 

levels above the regulated level 

• Demonstrated probability of a false positive response of no more than 10% to lead levels 

below the regulated level 

Additionally, in the proposed RRP rule, the stated goals for current EPA test kit research are to 

develop kits that meet the above performance standards and that 

• can be used reliably by a person after minimal training (i.e., nonanalyst), 

• inexpensive (under $2 per test), 

• provide results within 1 h, and 

• are available commercially within the next 3 years. 

The workshop was a component of the first of a four-part approach developed by the Human 

Exposure and Atmospheric Sciences Division/ National Exposure Research Laboratory 

(HEASD/NERL/ORD) to facilitate the development and improvement of lead paint test kits to 

meet the performance specifications of the proposed RRP rule. The approach consisted of (1) 

evaluation of the state of the science of lead paint test kits as of 2006; (2) conducting research 

to address the identified sources of error; (3) development of synthetic lead paint test materials 

that are predictive or diagnostic of kits’ performance with real-world paints; and (4) development 

of collaboration with vendors to refine, produce, and market lead paint test kits that meet the 

RRP requirements. 

The first part of the HEASD approach, evaluation of the state of the science of lead paint test 

kits as of 2006, was supported by the preparation of an issue paper entitled “Draft Report on the 

State of Development, Availability, Evaluation, and Future Use of Test Kits for the Measurement 

of Lead in Paint.” This report was sent to the participants as part of the preworkshop materials. 

The Lead Paint Test Kits Workshop provided a forum for technical information exchange among 

experts from EPA, other government agencies, academia, private industry, and testing and 
viii 

standards organizations regarding the performance of lead test kits. The objectives and 

discussion areas of the workshop were to obtain information on (1) the accuracy, precision, and 

cost of lead test kits to determine the amount of lead present in paint in respect to the two 

Federal standards; (2) the specifications, availability, and costs of testing and reference 

materials to evaluate the performance of test kits for lead in paint in respect to the Federal 

standards; and (3) the specifications and availability of protocols to evaluate the performance of 

test kits for lead in paint in respect to the Federal standards, as well as the cost to perform these 

protocols. 

The workshop began as a series of short presentations by EPA staff from ORD and OPPT, 

followed by general question and answer periods to elicit input from the workshop participants. 

The presentations outlined the technical and regulatory needs for lead paint test kit technology 

development to support the RRP rule, key items from the issue paper, and a procedure to 

delaminate the National Institute of Standards and Technology (NIST) standard reference 

material film for test kit use. 

At the request of the workshop participants, discussions on the three objectives or discussion 

areas were held by the group as a whole, instead of in small breakout groups, as had been 

planned. Suggestions and comments from the participants were recorded on flip charts during 

the discussion periods. The highlights of the comments and action items from the first day were 

recapped at the beginning of day 2 before continuing discussions. 

Among the wide range of input from the workshop participants, there were several key 

reoccurring comment areas. 

Approaches to adjust test kit performance to support the proposed RRP rule 

• Chemistries are available to detect the lead from paint, but there are constraints. 

• Improvements may be made in precision and bias in kits used for in situ and ex situ testing by 

- increasing the exposure of the lead-containing paint layer to the extraction chemicals, 

- increasing the extraction efficiency of the lead from the paint, and 

- adjusting the kit sensitivity. 

Verifying and ensuring the performance of test kits 

• Few reference/characterized lead-in-paint films near the regulated lead levels in paint are 

commercially available for methods development and performance evaluation. 

• Test kit performance evaluation needs and concerns included the procedures and protocols 

to be used for testing and interpreting the kits’ responses in conjunction with the type of 

evaluation materials (real-world versus synthetic), their compositions, and availability over 

time. 

• There were extensive discussions on real-world versus synthetic reference paint films and, if 

synthetic films are used, on which key variables (such as paint type, formulations, lead 

compounds, paint thickness or number of layers, substrates, and aging) should be considered 

to ensure that the use of the synthetic films predict the kits’ performance on real-world paints. 

• Ensure that the kits will perform in the field, not just in the laboratory, and that the 

performance is validated throughout the shelf life of the kit. 

• Include a performance evaluation material or control material in the kit. 

• Adequate hands-on training and clear instructions are needed to ensure testers properly use 

the kits and correctly interpret the kits’ response. 
ix 

At the end of the discussions, comments noted on the flip charts were reviewed, and a handout 

on designing the “dream” test kit was distributed. At the close of the workshop, highlights from 

the responses to the handout were read, and next steps were discussed. EPA invited the 

attendees to continue to interact with ORD and stated that research partnerships are needed to 

develop the next generation of lead test kits. 

The discussions and recommendations from the workshop, along with the issue paper, will be 

used to inform the execution of the final three parts of the HEASD approach to facilitate the 

development and improvement of lead paint test kits to meet the performance specifications of 

the proposed RRP rule. 
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1 

Lead Paint Test Kits Workshop 

Introduction 

The U.S. Environmental Protection Agency’s (EPA) Office of Research and Development (ORD) 

hosted the Lead Paint Test Kits Workshop on October 19 and 20, 2006, at the EPA’s Research 

Triangle Park, NC, campus. The objectives of the workshop were to obtain information on the 

accuracy, precision, and cost of lead test kits to determine the amount of lead present in paint in 

respect to the two Federal standards; the specifications, availability, and costs of testing and 

reference materials to evaluate the performance of test kits for lead in paint in respect to the 

Federal standards; and the specifications and availability of protocols to evaluate the 

performance of test kits for lead in paint in respect to the Federal standards, as well as the cost 

to perform these protocols. The workshop provided a forum for information exchange among 

experts from EPA, other government agencies, academia, private industry, and testing and 

standards organizations. This summary report is not a transcript of the meeting and is not meant 

to serve as a comprehensive record. It is, however, detailed and intended to document the 

breadth of discussions that took place. Appendix A of this report contains the recommendations 

and comments from the participants recorded on flip charts during the workshop. Appendix B 

contains comments submitted by the National Institute for Occupational Safety and Health 

(NIOSH) to EPA. Appendix C presents a summary of the responses to a handout distributed 

during the workshop. Appendix D and E contain a copy of the workshop agenda and a list of 

workshop participants, respectively. 

Welcome, Introductions, and Meeting Overview 

Dr. Myriam Medina-Vera with EPA’s National Exposure Research Laboratory (NERL) welcomed 

all of the attendees to the workshop, thanked them for their participation, and discussed the 

format of the workshop. 

Development of the Next Generation of Lead Paint Test Kits 

Dr. Larry Reiter (Director, NERL) provided background on EPA’s role in reducing lead-based 

paint health hazards and discussed the workshop goals. 

Since the removal of lead from gasoline, exposure from paint and paint dust is regarded as the 

primary source of high-dose lead exposure in children. Title X was passed in 1992, creating 

“Title IV—Lead Exposure Reduction” of the Toxic Substances Control Act (TSCA) and giving 

EPA responsibilities to reduce lead-based paint hazards. Section 405(b) of TSCA Title IV 

directed EPA to establish protocols, criteria, and standards for the analysis of lead-in-paint films, 

soil, and dust. EPA issued a proposed rule in 2006 for renovation, repair, and painting activities 

that disturb lead-based paint in housing built before 1978 to support the goal of eliminating 

childhood lead poisoning by 2010. EPA’s ORD and the Office of Prevention, Pesticides, and 

Toxic Substances (OPPTS) have taken the technical lead in developing improved lead paint test 

kits. The role of ORD is to perform research on test kits to support the proposed regulation and 

to seek technical collaborators to develop test kits that can be commercialized. The goals of the 

workshop were to solicit input on improvements in test kit technologies and to obtain comments 
2 

on technical issues pertaining to the proposed rule to initiate a dialogue between EPA and 

manufacturers on the development of the next generation of test kits. Workshop discussions 

focused on two major challenges: (1) test kit performance characteristics, ease of use, quality 

control, and cost; and (2) test kit verification. NERL currently is engaged in research to examine 

test kit chemistry and modify the chemistry to improve test kit performance relative to the 

proposed rule, as well as to evaluate available film standards. This research and collaborations, 

facilitated through agreements such as cooperative research and development agreements 

(CRADAs), will result in commercially available products. 

Lead-Based Paint; Renovation, Repair, and Painting Proposed Rule 

Dr. Maria Doa (Director, OPPTS, National Program Chemicals Division) discussed the purpose, 

criteria, and phased implementation schedule of the Lead-Based Paint; Renovation, Repair, and 

Painting (RRP) proposed rule. 

The purpose of the RRP proposed rule is to prevent the introduction of lead hazards during 

renovation, repair, and painting activities in homes containing lead-based paint by ensuring 

renovators are trained and certified properly, and that lead-safe work practices are followed. 

The proposed rule applies to housing built before 1978, where renovation is being done for 

compensation, and the renovation disturbs more than 2 ft2

 of painted surface. Each year, 10.7 

million renovations are performed on pre-1978 housing. Only 24% of housing built between 

1960 and 1978 contain lead-based paint. The figure is 69% for housing built between 1940 and 

1959, and 87% for housing built before 1940. The exception to the rule is housing where no 

lead-based paint is being disturbed, as determined by a certified inspector or an EPArecognized test kit used by a certified renovator. Currently, there are no test kits for lead-based 

paint detection recommended by EPA, but the rule proposes to introduce improved test kits to 

determine whether lead is present that are simple and inexpensive. The proposed rule includes 

criteria for the test kits to be recognized by EPA in prerenovation lead testing. 

ORD has been asked to initiate research to ensure that test kits that meet the criteria will be 

available when the rule becomes effective. The criteria for the test kits are that the kit can be 

used reliably by a person with minimal training; the kit should be inexpensive ($2 per test); the 

kit should be fast, providing results within 1 h; the kit should have a false positive rate of no 

greater than 10% relative to the Federal regulated level; and the kit should have a false negative 

rate of no greater than 5% relative to the Federal regulated level. Phase I of the proposed rule’s 

implementation will take effect 2 years after the final rule becomes effective and applies to 

owner-occupied housing built before 1960, where a child under the age of six resides; rental 

target housing built before 1960; and housing built before 1978, where a child under the age of 

six with an elevated blood level resides. By the time of Phase I implementation, the test kits 

should have no more than 5% false negative results. Phase 2 implementation of the proposed 

rule will occur 3 years after the final rule becomes effective and applies to all owner-occupied 

housing built before 1978, where a child under the age of six resides, and to rental housing built 

before 1978. At the time of Phase 2 implementation, the test kits need to meet all of the criteria 

of the proposed rule. The goal is that the test kits meet all of the criteria for Phase 2 

implementation, be commercially available, and that the independent test kit evaluation results 

be available by December 2009. 

Dr. Doa responded to questions from the workshop participants regarding the costs associated 

with blood level screening; the feasibility of a national laboratory system that could provide 

timely and inexpensive mail-out test results when renovator test results are questionable, the 

sensitivity of available test kits, and the potential for hazardous situations to arise resulting from 
3 

a false sense of security on the part of the renovators. Dr. Doa stated that the purpose of the 

proposed rule is primarily prevention of exposure to lead from lead-based paint. The rule does 

not address directly the prevention of elevated blood lead levels. The point of the test kits is to 

obtain a quick and clear result. The universe of people using these test kits likely consists of 

renovators conducting 1- to 2-day jobs. Therefore, a mail-in laboratory would not meet the 

“quick” criterion. Dr. Doa clarified that the purpose of the proposed rule is to develop test kits 

that have a much lower false positive rate vis-à-vis the Federal regulatory level of lead-based 

paint, rather than to remove overly sensitive test kits that are currently on the market. The 

question of whether hazardous situations can arise when renovators think they are not dealing 

with lead-based paint (e.g., they could sand the paint and create a dust hazard) is really a 

question of whether EPA is using the right level for regulating lead-based paint. Dr. Doa 

explained that the proposed rule level criteria are what EPA has to work with at this time. 

New Generation of Test Kits: Technical Approach 

Dr. Linda Sheldon, Acting Director of NERL’s Human Exposure and Atmospheric Sciences 

Division (HEASD), discussed the goals for the next generation of test kits and the challenges to 

their development and performance verification. 

The technical goal of the workshop was to discuss innovative techniques that can be used to 

support the goals of the proposed rule. There are many challenges to meeting the goals of the 

proposed rule, but the main one is getting a test kit to perform to the specified criteria. ORD is 

seeking research partners, through CRADAs, to identify available test kits and develop 

approaches to optimize test kit chemistries. The problem is that commercially available test kits 

are too sensitive for rule requirements. The biggest challenge may be to reduce the sensitivity of 

the tests to reduce the rate of false-positive results. 

Information is needed on kit technologies developed since 2000, including any unpublished 

evaluations of these technologies. Currently, there are 22 known available test kits. Some are in 

situ (test the paint on the wall) and some are ex situ (test a sample of paint removed from the 

wall). Two of the test kit challenges are the response and detection of lead. The goal is to obtain 

accurate and reproducible responses to lead, adjusted to the action level. Another challenge is 

extraction. Different paints behave differently, and it is harder to leach lead from some formulas. 

The eventual goal is to have a reproducible extraction for lead-based paint. Paint sample 

removal is another challenge. Many test kit evaluations are not using real-world scenarios such 

that if the lead is not evenly distributed throughout the paint, the test kits might not work properly 

with real-world paints. The test kits need to demonstrate performance with known film materials 

similar to, but not necessarily, real world materials. This challenge will be addressed more in 

test protocol development than in kit development. 

The test kits will need to be verified, but there is a lack of known reference materials at 

appropriate lead concentrations. Appropriate protocols for validating test kits also are needed. 

The charge to the workshop attendees was to provide technical input and approaches that will 

modify test kits to meet the needs of the RRP rule and to identify potential roadblocks and 

constraints to developing and commercializing these test kits. 
4 

Key Items from the Issue Paper 

Ms. Sharon Harper (NERL HEASD) discussed the issue paper Draft Report on the State of 

Development, Availability, Evaluation, and Future Use of Test Kits for the Measurement of Lead 

in Paint. 

The purpose of the issue paper was to review the state of the science for lead paint test kits as 

of 2006 by identifying available test kits and summarizing their operational parameters and 

reviewing available literature on test kit evaluations. The paper was developed to advise the 

NERL test kit team on the key issues. The goal was to determine variables that can be modified 

to adjust kit performance to support the proposed rule and identify technical gaps in verifications 

of performance of kits developed to support the proposed RRP rule. The issue paper also 

identified technologies (kits) developed since the last formal kit evaluations performed from 

1998 to 2000. 

The commercially available lead test kits use chemistries such as chloranilic acid, dithizone, 

rhodizonate, and sodium sulfide, as well as mailers, anodic stripping voltametry, and 

colorimetry. There are three kits in development based on catalytic DNA-gold nanoparticle, 

immunoassay, or rhodizonate. 

Literature reviewed for the issue paper included both field and laboratory studies that tested 

real-world paint chips and prepared films using professional and nontechnical users. Kits based 

on the same lead indicators had a wide range of performance. In the field studies, the variability 

of the paint on the tested surfaces impacted how well the test kits performed. Variables that 

influenced test kit performance included sample size collected, sample collection efficiency, 

exposure of lead layer to extraction chemicals, extraction rate and efficiency, interferences, 

strength of the response, chemical stability, and detection method (how the response was 

perceived: visual, use of a color wheel, or some other type of device). 

Reference materials are needed to evaluate the kits to ensure they meet the proposed rule 

standards. Such materials can be real-world paint chips and powdered paints or laboratoryprepared films. EPA is seeking the input and insight of test kit manufacturers and researchers 

who have developed films to evaluate their test kits. There is a need to determine the paint film 

characteristics necessary to evaluate the kits’ performance. Developing laboratory-prepared 

films present many challenges. Considerations for such films include the different paint bases, 

latex or oil; the number and thickness of lead paint layers and overcoats; the lead compounds 

that should be used in the formulations; interferences; the need for substrates; aging; and the 

similarity of the film to real-world materials. 

The issue paper identified only two performance evaluation protocols that deal explicitly with 

onsite paint analysis. They are American Society for Testing and Materials (ASTM) E1828, 

which may require hundreds of films to evaluate a test kit, and ASTM E1775, which is a 

standard for electrochemical or spectrophotometric analysis. 

Delamination and X-ray Fluorescence Analysis of National Institute of Standards 

and Technology Lead-in-Paint Film Standards 

Dr. Kim Rogers (NERL, Las Vegas Laboratory) discussed delamination and X-ray fluorescence 

(XRF) analysis of the National Institute of Standards and Technology (NIST) lead-in-paint film 

standards. 
5 

The delamination protocol for the NIST Standard Reference Material (SRM) 2573 film standard 

(nominal 1.0 mg lead/cm2

) involved labeling the film, removing an archive strip (to measure in 

the future), running portable XRF analysis at five places on the film, heating and removing the 

polymer coating, and rerunning the XRF analysis. The purpose of measuring the concentration 

by XRF in four different places (quadrants) on the film plus the center was to determine whether 

the film was homogeneous after coating removal. Paint does wrinkle in places, but this did not 

make a difference in the XRF analysis. Dr. Rogers presented data for prepeeled and postpeeled 

SRM 2573 paint films, showing that the films had identical lead concentrations and 

reproducibility after delamination. This protocol for delaminating the NIST SRM 2573 film does 

not change the lead concentration and is relatively simple, reproducible, and applicable to all of 

the NIST film standards. 

Dr. Rogers also discussed the results from the field and laboratory studies shown in Table 8 

section 3.1.2 and Table 15 section 3.1.8 of the issue paper Draft Report on the State of 

Development, Availability, Evaluation, and Future Use of Test Kits for the Measurement of Lead 

in Paint. The percentage of false positives of various lead test kits versus the percentage of 

false negatives was charted. Plotting the data showed that the relationships are linear. The RRP 

rule goal of 10% false positives and 5% false negatives is far from the line, indicating that these 

are lofty goals. 

Group Discussion 

All of the workshop attendees participated in a group brainstorming session led by Ms. Sharon 

Harper on the precision, accuracy, and cost of the lead paint test kits, and the specifications and 

availability of testing and reference materials and protocols to evaluate the performance of test 

kits. 

The first topic discussed was the test kits themselves. It was noted that instructions on the test 

kit needed to be followed. A question was raised, “How can we be sure the test kits will be able 

to perform outside of a laboratory?” Sometimes kits include a “tester,” which contains a small 

amount of lead to make sure the kit is working. An attendee commented that testers containing 

lead once were included in the kits that his company produced, which led to problems with the 

test kit being shipped overseas. The European Union has very strict regulations and will not 

allow the import of any product containing trace amounts of lead. 

There was a discussion on how the results of the test kits were hard to interpret. In some kits, 

the color change was not obvious. A participant commented that to be able to correctly interpret 

the test, one needs to see examples of both a positive test and a negative test. Differences in 

lighting also can influence how the tests are interpreted. Sometimes, there can be a range of 

colors, which also makes the tests difficult to interpret. 

There was a lengthy discussion regarding the amount of training necessary to use the test kits. 

Certification requirements for contractors should include 30 min of training on the test kits. The 

training should include examples of positive and negative test results. Dr. Medina-Vera 

suggested that lead test kits work like pregnancy tests that have a clear positive sign for a 

positive result and a clear negative sign for a negative result. Dr. Mark Geisberg of Silver Lake 

Research Corporation has a lead paint test kit in development that works like a pregnancy test. 

Their current water lead test kit is too sensitive. 

Dr. Walter Rossiter discussed in detail the NIST study that he helped conduct. In this study, 

available test kits were given to lead inspectors. The inspectors participated in a 15- to 20-min 
6 

training session that covered the manufacturers’ instructions, as well as an extra set of 

instructions created after trial and error use of the kits. (The inspectors were given written 

copies of the instructions as well.) The extra instructions included details like “wear latex 

gloves.” The participants in the study followed the instructions very closely, and the kits worked 

properly. Dr. Rossiter believes the instructions were followed properly because the participants 

were lead inspectors and, therefore, had a sense of responsibility. However, an average 

renovator might not follow the instructions as well as the lead inspectors did. Dr. Rossiter said 

the manufacturers were asked to review the extra instructions, but it is not known if the 

manufacturers made any changes to their original instructions as a result of reviewing the extra 

instructions created during the study. 

Dr. Gary DeWalt, who worked on the aforementioned project with Dr. Rossiter, stressed the 

point that the instructions were critical to the proper operation of the test kits, and the people 

using the test kits need to see test result samples so they can distinguish a positive result from 

a negative result. Ms. Harper agreed that it is sometimes very difficult to distinguish between 

positive and negative results. 

Ms. Sandra Cole, of Cole Environmental, mentioned that there are two different audiences for 

the test kit instructions: homeowners, who are not going to have much training, and industry 

professionals (renovators), who will have the benefit of training. Even with the use of a color 

chart, homeowners might not be familiar with the terms involved in testing. She suggested the 

tests for homeowners be extra sensitive so as to reduce the chance of a false negative. In 

addition, if a homeowner gets a positive result, he or she should be encouraged to conduct 

further testing. Ms. Harper clarified that the proposed rule is aimed specifically at renovators 

who have completed the training. Dr. Rogers later commented that having different test kits for 

homeowners and renovators might create problems; for example, if a homeowner’s more 

sensitive test kit shows that there is lead present, but the contractor’s test kit shows the lead is 

below the regulatory threshold, the homeowner might be upset if the contractor is not using 

lead-safe work practices. 

Dr. Mark Geisberg, of Silver Lake Research Corporation, asked who would conduct evaluations 

of test kit instructions. Dr. Doa suggested that there be a focus group for evaluation of the test 

kit instructions prior to the test kits being made commercially available. Dr. Geisburg said that 

out of the tens of thousands of test kits his company sells to homeowners, they only receive a 

few calls per week regarding the instructions. A toll-free phone number should be provided in 

the test kit instructions for those that have questions on how to use the test kits. 

Dr. Geng Lu of the University of Illinois asked about the false positive/false negative range EPA 

wanted to obtain. Dr. Doa said the preamble mandates 95% confidence. Dr. Rogers added to 

her statement by saying the 1991 RTI International report has a range of 0.1 to 0.7 mg/cm2

. Any 

positive tests below 0.1 mg/cm2

 were considered false positives. Any negative tests above 0.7 

mg/cm2

 were considered false negatives. Using this range improved the accuracy and 

decreased the number of false positives and false negatives. Dr. Doa said the ultimate goal is 

for there to be zero false negatives, but ORD thinks this goal is unreasonable, hence the 95% 

false negative goal. Basically, EPA wants to minimize the false negatives and have a 

reasonable false positive rate. Dr. David Binstock of RTI International commented that the 

definitions of false positives and negatives are still not clear. 

The discussion on false negatives and false positives led to a discussion of the standards. Dr. 

William Gutknecht of RTI International provided some background on the 1-mg/cm2

 number. In 

1999, EPA visited Scitec, one of the first companies making an XRF machine to test for lead. 1 
7 

mg/cm2

 was the lowest concentration detected by the XRF machine, and that number became 

the standard. There has been a bit of confusion because there is another standard, 0.5% by 

weight, which also has been used. Dr. Albert Liabastre, USACHPPM-South, said there should 

only be one standard to which all kits can calibrate (or else there would be too much confusion, 

and contractors would have to go through a separate training for each kit). Dr. Lu asked which 

standard should be used in the event that the standards conflict. Mr. John Schwemberger, of 

EPA, said Title X defined the regulatory standard for lead-based paint as 1.0 mg/cm2

 or 0.5% by 

weight. Some of the history of the evolution of a regulatory standard for lead-based paint is 

documented in the U.S. Department of Housing and Urban Development (HUD) 

“Comprehensive and Workable Plan for the Abatement of Lead-Based Paint in Privately Owned 

Housing” dated December 7, 1990. EPA and NIST reports have noted that a rough rule of 

thumb is that 1.0 mg/cm2

 is about 1% by weight. However, the 1.0 mg/cm2 and the 0.5%-byweight standards are not interchangeable, and there is no universally recognized way to convert 

from one to the other. Manufacturers are free to choose which standard they wish to adhere to. 

The 0.5%-by-weight value is the stricter of the two standards. 

Dr. Gutknecht added that one of the advantages of the 1.0-mg/cm2

 standard is that there are 

not many houses that have lead at the level of 1.0 mg/cm2

. There are many houses with higher 

levels and many with lower levels, so the 1.0 mg/cm2

-standard is a good break point. Ms. 

Harper qualified this assessment by mentioning a study in which hundreds of houses were 

examined; very few had lead-in-paint levels close to 1.0 mg/cm2

. 

Mr. Brian Vargo, of EMD Chemicals, Inc., asked if there is a law that allows contractors to use 

lead-safe work practices in lieu of conducting a lead test. Dr. Doa said that there is nothing to 

that effect in the proposed rule, but that a contractor can assume that lead is present and use 

lead-safe work practices without testing. Using lead-safe work practices involves the use of 

extra plastic and duct tape, cleaning with dust collecting devices (such as Swiffers), and adds 

about $50 to $100 to the cost of a job. If lead-safe work practices are being used, a contractor 

does not have to buy a kit. However, most contractors do not want to assume that lead is 

present, especially in houses built after 1960. Regardless of whether a test is used or not, in 

cases where the proposed rule would apply, the contractor must test the work area with an 

electrostatic cloth at the end of a renovation to verify that the work area has been cleaned 

properly. Ms. Harper said (as an example of safe work practices) that, in houses built during a 

certain timeframe, renovators will not rip up flooring because the assumption is that the floor 

covering contains asbestos. 

Extraction of lead from paint was discussed as being a critical part of testing. Paints are made 

and age differently. Therefore, the extraction efficiency is variable. Extracting the lead in the 

paint and making sure the lead in the paint is exposed to the testing reagents is critical for the 

tests to work properly. It was suggested that a tool be constructed to generate the appropriate 

particle sizes for testing. The cost of such a tool would be about $500. Assuming the tool is 

used several hundred times, the cost per use would be approximately $1 to $2. However, most 

of the contractors and renovators affected by the proposed rule work for small firms, and a large 

up-front cost would be a burden. Such a tool would also necessitate additional training. It was 

suggested that there be a disposable tool developed to keep the costs of testing down. 

Dr. Rossiter discussed an anodic stripping voltametry (ASV) study using some of the same paint 

panels and operators as his previous study. The expectations were that 80% of the known lead 

would be extracted. However, only 50% of the known lead in a sample was able to be extracted. 

Half of the samples had white lead and the other half had lead chromate, but the type of lead 

pigment was not a contributing factor to the poor results. The procedure used manual grinding 
8 

of the paint and dry ice (the dry ice was not in the manufacturer’s protocol but was based on an 

ASTM guideline). In one trial, vinegar was used to extract lead chromate. After an overnight 

extraction, vinegar still was unable to extract lead chromate. However, it was concluded that, 

even though the extraction is difficult, once the lead is in the solution, it will be detected. The 

ASV testing equipment cost approximately $4,000 at the time of the study (it is less expensive 

now) but can be used for thousands of tests. It should be able to generate a quantitative result 

within 1 h. It is estimated that, on average, a contractor completes approximately 100 renovation 

jobs in a year and likely bids (and, therefore, conducts tests) on more than 100 jobs. 

Paint particle size is significant in testing. The feasibility of using a microwave or an ultrasonic 

cleaner to aid in the digestion was raised. A participant commented that this technique does not 

perform very well, and many contractors, especially those working in low-income housing, do 

not want to pay the associated up-front costs. 

Dr. Doa stated that the $2 per test kit criterion is based on the cost of tests currently on the 

market. Home Depot sells Lead Check kits for less than $3. 

There are many ways to remove the paint from the test surface. One way is a small propane 

soldering tool that will soften the paint. Small grinder-like tools with vacuums also exist and are 

effective if the paint is thick enough. However, if the paint is thin, the tool will pick up substrate 

as well as paint. The substrate, especially if it is a porous substance like wood, can contain high 

levels of lead. 

If paint particles are ground in a mortar and pestle, the smaller particles (the particles that are 

left behind) contain higher concentrations of lead. When using a mortar and pestle, a finite 

amount of lead is left behind rather than a percentage, so the smaller the paint sample, the 

larger the percentage of the lead lost. By removing paint with vacuum extraction, a large amount 

of the sample can be lost. 

Mr. Mike Wilson, of EPA, asked if there is a way to improve the accuracy of in situ testing 

because of the complicated nature of ex situ testing. Dr. DeWalt said that a standard V-cut will 

expose all layers of paint. However, exposure of the lead in the paint to the testing chemical 

depends on the thickness of the paint layer at the site of the cut. The thickness of lead-based 

paint layers will be different at different cut sites on the test surface, causing variability in the 

test results. Although most of the lead-based paint is in the bottom layers of paint, one cannot 

tell the thickness of the layers. 

Questions were raised about validating test kits at various periods during their shelf lives. Test 

kit storage is important to the stability of the testing chemicals. For example, some acids are 

temperature and medium sensitive. If and when test kits are approved, EPA’s Environmental 

Technology Verification (ETV) Program could be a mechanism to conduct the evaluations. The 

ETV program uses third-party evaluation centers to perform technology evaluations, then 

publishes the performance data. Currently, the ETV program is looking at test kits for other 

analyates to see how they operate using both technical and nontechnical operators. 

The use of synthetic films versus real-world samples was discussed. Samples taken from the 

real world will have problems such as unknown concentrations and interferences. An advantage 

of synthetic films is that the desired concentration can be selected. Known interferences and 

thicknesses can be built into the films. 
9 

Test kit performance validation issues to be addressed include oil-based paint versus latex 

paint, interferences, the type of lead (lead chromate is the most difficult form of lead to remove 

from paint, but it is not very common), thickness, aging, and paints on substrates versus paints 

on stand-alone films. It was suggested that there be a limit on the variables tested. However, 

initial limiting of variables followed by the addition of complexities as the program continues can 

lead to problems. For example, it is possible that test kits would have to be reapproved and 

approvals could be stripped. 

There may be lead oxide, lead chromate, white lead, driers, and titanium dioxide present in 

paint. Test specimens cannot incorporate every kind of lead and every component of paint that 

exists. A good experimental design will include at least one type of lead that is difficult to get into 

solution. It was suggested that elements in test samples be similar to elements found in paints 

manufactured between 1960 and 1978, the time period of most testing relevance. 

Dr. Geisberg asked if comparing the results of the test kit validation studies with XRF for realworld sampling would be acceptable. Have there been any comparisons between test kits and 

XRF in real-world situations, where a test kit analyzed a sample then the XRF analyzed the 

same area? Dr. DeWalt said that synthetic test panels were made on substrates. These panels 

were compared to what is currently in the archive.1

 For flat, nonporous surfaces, the XRFs of 

synthetic panels matched the archive relatively well. The porous surfaces did not fare as well. 

Lead was absorbed into the substrate. Therefore, the substrate is an important parameter that 

needs to be included in validation tests. 

In regard to the availability of a standard substrate, paints will penetrate different substrates 

differently. Variability is high on porous surfaces, which can affect the results of the test kit 

validation. One challenge is to create a consistent film that has variations, as in the real world. 

One of the biggest challenges is to design the synthetic films to mimic the effect of aging on 

real-world paint layers. Humidity, drying, freezing, and aging techniques are not good enough to 

mimic the real world. Test kit responses are different for new and aged films. New films are 

difficult to handle. In the NIST ASV study, grinding the newer films did not yield the desired 

particle sizes. Older paint samples were very easy to grind. It is not difficult to age test films by 

heating them, but most of the test kit providers would not have the equipment to heat the films. 

Another variable the NIST ASV study tested was paint thickness. The study used a film with 15 

layers (thick) and another film with 3 layers (thin). The films also had varying paint formulations. 

Creating samples is one way to control certain variables. One of the problems with using realworld samples is that few real-world samples of 1 mg/cm2

 exist, and, because this is the 

regulatory level, it is important that testing be conducted at this level. Therefore, synthetic 

samples are necessary. 

Collecting an archive of real-world samples would be very expensive. EPA does not have a 

budget sufficient to support such an endeavor, but it is possible that collection could be 

achieved, as in an EPA study that tested XRF instruments and test kits in the 1990s. In this 

study, painted components were collected from study buildings to create a collection of realworld building components with a range of lead levels in the paint. This collection, called “the 

Archive,” was used to test new XRF instruments that became commercially available after the 

 

1

 The Archive is documented in the EPA reports “Methodology for XRF Performance Characteristic 

Sheets” (September 1997, EPA 747-R-95-008) and “Archive Operations and Protocols” (September 

1997, EPA 747-R-97-004). Both of these documents are available at the Web site 

http://www.epa.gov/lead/pubs/leadtpbf.htm. 
10 

study ended. If a manufacturer goes through the trouble of making a set of paint standards, it is 

expecting to recoup the costs. If it does not recoup the cost, then more will not be made. A costeffective reference material is needed. It was suggested that HUD cover some of the costs of 

the films. 

Highlights of Group Discussion and “Dream” Test Kit Handout 

Dr. Medina-Vera (NERL) recapped the highlights of the group discussion. She discussed the 

next generation of test kits. The workshop charge was to provide technical input for the next 

generation of test kits and provide technical input on potential constraints to development and 

commercialization. The constraints include making lead available to the extraction reagent, the 

particle size, aggressive versus safe extraction, and availability of reference materials. Other 

considerations are verifications of the test methods and protocols, training for users, and a clear 

definition of responsibilities. Action items are to clarify the target standard (percent of false 

positives and negatives, concentration response range, and concentration windows), identify 

who will develop the standards and protocols, and clarify varying points of views that may come 

from the homeowners and contractors. 

The participants were asked to fill out a handout on a dream test kit based on their experiences. 

They also were asked to consider things that might not be possible. Some ideas for the dream 

test kit were that it be easy to use, provide a quick and clear result, employ mixed chemistries, 

work on a range of concentrations, use two steps (pulverize, then a chemical reaction), and two 

steps with a positive and negative control. The handout also asked about the perfect standard, 

the protocol for validating test kits, and what a reasonable cost would be. 

Extraction is the key to getting the test kit to perform properly. Dr. Rogers proposed the idea of 

using a cylinder with a capsule containing strong acid in the cylinder. This likely would raise the 

cost of a kit and would require a special bag for disposal. Dr. Rossiter referred to the ASV study, 

in which trained lead inspectors were not willing to do a test if it required too many steps, but 

compliant if a spot test kit was used. Dr. Gutknecht mentioned a multistep kit made by Hach 

Company that students use, with reasonable but slow results. 

Dr. Kevin Ashley, of the Centers for Disease Control and Prevention/NIOSH, said he does not 

like the idea of painters or contractors performing the analyses because they have a monetary 

interest in the result of the test. He thinks an independent third party should perform the testing. 

He also worried about contractors cutting corners so a job can be done cheaply. Later during 

the discussion, Mr. Kenn White, of Consultive Services, commented that he has trained 

contractors and renovators. Many of them are not thinking about what they are doing when 

performing lead tests. 

ASTM E1828 requires hundreds of samples to verify test kits. These verifications are very 

expensive, and materials are not readily available. EPA may not have the funding to validate the 

test kits and may have to partner with a manufacturer. The ETV program has the ability to 

develop an evaluation protocol and will evaluate commercially available products. Part of the 

function of the ETV program is to pool funding and resources. 

A number of the participants suggested that the test kits be verified at various times during the 

kits’ life cycles to determine the stability of the materials. This may depend on the resources 

available. The manufacturers should display information on the stability of the chemicals and the 

expiration date of the reagents on the outside of the test kit packaging. 
11 

A question was raised regarding who would be evaluating the kits in the validations 

(professionals or nonprofessionals), which sparked a discussion on training users to use the test 

kits. The training is still in development, but it will be 30-min long. Based on her experience with 

pesticides, Dr. Jeanette Van Emon, of EPA, felt that training will affect the outcome of test 

results, and suggested using videos to aid in training. Training needs to be simple. Many of the 

companies going through the training are small operations that have employees who would not 

understand highly technical terms. Many contractors do not speak English (there will be a 

training course available in Spanish). It was suggested that the vendor should provide training, 

but that could create a problem because only contractors who go through the training will be 

able to perform the test. 

A participant said that there needs to be a simple yes/no test. If there is any lead present, even 

if it is below the regulatory level, then lead-safe practices should be used because the ultimate 

aim of the proposed rule is to protect children from lead poisoning. Definitions of a “false 

positive” and “false negative” are strictly from a regulatory standpoint. A “false positive” usually 

means that there is lead present in the paint, but below the regulatory levels. Ms. Jacqueline 

Mosby, of EPA, said the goal of the test kits in the proposed rule is to reduce the burden when 

lead in paint is below the regulatory standard. Dr. Ashley stated that the regulatory levels are 

inappropriate for protecting human health, and felt that using sensitive kits is acceptable. He 

does not think that the goal of the proposed rule should be to save money on the cost of 

renovations. 

Dr. DeWalt said the extra costs of using lead-safe work practices are not excessive, and, if the 

extra costs are balanced against the increased liability, it is a good idea to use lead-safe work 

practices regardless of the outcome of a test. Dr. Liabastre agreed and said that lead-safe work 

practices are good work practices in general and using them adds only about 1% of the total 

cost of the job. Mr. White said there was a requirement at one time that lead-safe work practices 

be followed in all target housing. 

Mr. White asked, if a spot test is positive, does the result have to be disclosed later to a 

potential buyer of the home? Mr. Schwemberger said that it does. 

Mr. Schwemberger also pointed out that States may have lead programs that differ from the 

Federal government’s lead program, and, in particular, Massachusetts and at least one other 

New England state currently allow the use of test kits for paint testing. 

Information on research partnerships is available on the Environmental Technologies 

Opportunities Portal Web site www.epa.gov/etop/epa/. The Web site provides information on 

various programs, including development and verification programs, as well as partnership 

programs. The next steps include modifying technologies for responses and detection, 

improving extraction and reproducibility, assessing the sampling procedure, and applying the 

new approaches. Research partnerships are needed to develop the next generation of test kits. 

Highlights of the Responses to Handout 

Handout responses to the question about the dream test kit 

• Simple 

• Different principles of operation 

• Work like a home pregnancy test 

• All renovators use lead-safe practices. 
12 

• In situ-ex situ is complicated. 

• Quantitative kits 

• Exact change at the action level 

• Minimal handling of paint and chemicals 

• Fast 

Comments about the perfect standards 

• Multilayered standards 

• On substrates 

• Tailored to a spot test kit 

• Available at little or no cost to the user 

• Uniformly distributed 

• Unknowns as well as knowns 

Responses on what protocols should be used in validating the test kit 

• Use ASTM methods 

• Lab method in the field 

• Number of standards in the protocols is driven by statistical differences. 

• Real-world versus synthetic 

• Performance parameters look at temperature, user information. 

The handout included a question on how much the kits should cost. The answers included $5 to 

$15 for a spot test and $18 to $36 for a quantitative test. Many of the workshop participants felt 

that the creation of a dream kit is possible. 

Mr. Schwemberger expressed his optimism about the future of the test kits. Dr. DeWalt thinks it 

is possible to desensitize the kits; it is possible that a pH adjustment would make the kits more 

controllable. However, this may cost more than $2 per kit. Ms. Harper said, if the goals of the 

proposed rule cannot be met entirely, they at least will be moving in the right direction. It may be 

the case that the manufacturers have to design two test kits: one to test whether lead is present 

and one to support the proposed rule. This may not be inexpensive, and most manufacturers do 

not have the research and development funds to make a test kit that fulfills the criteria within the 

next 2 years. However, this is still a proposed rule, and comments have been received and 

evaluated. 
A-1 

APPENDIX A

Workshop Flip Charts 

Test Kits

(1) Instructions (problems), whose to follow? 

(2) Functional reagents, lot testers, preuse validations, present lead standard problems 

 (hazardous substances) 

(3) Clarity of results 

 Yes/no 

 (Range) examples 

 Specificity for light conditions 

(4) Training certification 

 -Experience, 30 min 

 -Test 

(5) Zone rather than color alone (Immuno will do this.) 

(6) NIST used 15- to 30-min training written instructions. 

(7) Kits to include real test sample 

(8) Two types of kits 

 -Homeowner―conflict? 

 -Industrial 

(9) Rule to clarify instructions 

(10) 95% confidence about false positive, false negative versus stated concentration window 

(11) What about concentration range? 

(12) Need clear definition of negative, positive 

(13) Must train for all specified kits 

 -What if 1 mg/cm2

 and 0.5% contradict? 

 -Not equivalent 

 -People can choose. 

 -0.5% is lower. 

(14) Suggestion of same standard for all kits

(15) Most house paint is above or below 1 mg/cm2

(16) Can contractors use lead-safe all the time? Yes. 

(17) Cost differential $50-$100 per job 

 Plastic, duct tape, Swiffers 

(18) Color/ No color as one-sided test 

(19) Leaching is a big problem. 

 -Particle size 

 -Extraction chemical 

(20) Tool for collection/powdering $500-$600 (some added cost) 

(21a) How many houses may be used in fixed cost evaluations? 

(21b) $2 came from market survey. 

(21c) Standard V-cut 

(21d) Chemicals getting into cut 

(21e) Paint thickness causes variability 

(22) Best extraction gives only ±5% so performance evaluation may be a big challenge. 

 50% extraction 

(23) What about quantitative methods? Getting lead into solution is the most difficult problem. 

(24) What about ASV? 
A-2 

(25) How many surfaces are included in the rule? 

(26) Representative 

(27) Mechanical extraction 

(28) Low upfront cost 

Paint Films 

Characteristics most critical aspects 

Lab-prepared versus real-world issues―cost, availability 

Crosswalk synthetic with Real World

Synthetic 

 Variety 

 Some chromate not used often. 

Synthetic 

 Variety of color, but mostly white lead 

 Needs some research 

Limit some variables 

Ongoing certification 

White lead will best approximate real world. 

Also include titanium dioxide and other metals/pigments 

Must consider carefully 

Elements to consider 

 matrix 

 color 

 metals, etc. 

Real-world samples compared to XRF 

Extraction is the issue. 

Synthetic limitations 

Aging (artificial heating) 

Matrix 

Other unknown composition 

How many substrates? 

Substrate is important 

Synthetics 

Advantages 

 Concentration is known. 

 Variability is known. 

 Composition is known. 

How do you make synthetic films act like real paint? 

Combination of synthetic and real world 

Reactions

Safe handling of reagents 

ASV is too complex for field use (i.e., extraction). 
A-3 

Spot test kits are better for field. 

What Will It Cost To Modify Test Kits To Meet Requirements?

Cost needs to be higher. 

Labor/kit combination to determine overall cost 

Concerns about qualifications of analyst 

ASTM standards 

ETV develops protocols and important issues. 

ETV

Uses previously published procedure, then develops test protocol 

Limited funding―so funding comes from companies as well. 

Looks at commercially available technologies 

Manufacturers need test materials and test protocols. 

Need To Summarize Kit Attributes

 Shelf life 

 Positive/negative results 

 Kit standards 

Can it be manufactured at a profit? 

Kit user conflict of interest 

Who is the user? 

Training is an important issue. 

 EPA has not yet started on training. 

 Kits must be very simple. 

What is the ultimate goal? 

Protect kids 

Reevaluate measurement detection limits 

NIOSHRegulatory levels are not appropriate for protection of human health. 

Lead penetrates substrate (i.e., wood) 

Substrate is problem. 

Lead-Safe Work Practices

Why not use the practices as routine? 

There are other advantages to using lead-safe work practices. 

Cost 1% of job 

Specificity Is Issue

One-sided test is already here. 

Lead-safe processes are required for HUD. 

Problem of differing State regulations under Title X 

Was the cost of liability insurance for the contractor considered? 
A-4 

Errors and omissions insurance is ~$12K. 

This will be taken back to EPA rulemakers. 

Does contractor need to be prequalified? 

Kits

Simple 

Color changes 

Immunoassay/format 

Safe practices for all renovations 

Very fast 

Minimal handling of reagents 

Standards 

Multilayer lead 

Substrates―wood, plaster 

Standards

Available at little or no cost 

Protocols

Similar to ASTM 

Lab method in field 

Number of standards/statistical 

Cost Ranges

$5 to $15 spot test 

Quantitative

$22 to $36 

Last Comments

Rule calls for test kits in Phase 1. 

Only requires the 5% false negative 

Phase 2 requires 10% false positive. 

Do not give up―improvement is possible. 

How to desensitize kits? 

What about two kits? 

Public and professionals have different sensitivity levels. 

Questions about health concerns when kits are misused 

Parking Lot

1. Homeowner requests due to differences/results of more sensitive kit versus what is 

suggested in the proposed rule. How do we address the issue? 

2. White glove test (electrostatic cleaning) 

3. Damaged paint 

4. Cr+6

5. Bioavailable 
A-5 

APPENDIX B

NIOSH Comments on EPA Proposed Rule (Faxed) 
A-6 
A-7 
A-8 
A-9 
A-10 
A-11 
A-12 
A-13 
A-14 
A-15 

APPENDIX C

Workshop Handout Summary 

At the lead test kit workshop, a handout, “Technical Exchange Workshop: Next Generation of 

Test Kits,” was distributed to the participants. The handout asked four questions: (1) My “dream” 

test kit looks like: ? (2) What would the perfect standard look like? (3) If you had the standards, 

what would the protocol look like? and (4) What would be a reasonable price? There were 10 

respondents. The responses were anonymous, and the respondents are numbered 1 through 

10. [Note: Not every respondent answered every question.] 

Responses to the question “My ‘dream’ test kit looks like: ?” 

(1) The respondent drew a schematic of the test kit. It is a complicated device that looks a bit 

like a drill. It has a “Specialized Grinding Bit Assembly.” There is a “tape seal” around the 

wall surrounding the paint being extracted, so that the paint would be collected inside the 

instrument. The pieces of paint would fall into a vial on the bottom of the machine. There is 

an “extraction chemical capsule” (probably a strong acid to digest the paint). The capsule 

would be broken and the paint powder would fall to the bottom causing a color change when 

the powder mixes with solution. The vial containing the reaction would slide off and is 

disposable. 

(2) A simple piece of paper; place in a solution 1 (solution 1 contains paints). Place the paper in 

a second solution. If the “+” sign is shown; then the result indicated the concentration is 

greater than 1 mg/cm2

. Place all solutions, paper into solution 2. Principle of operation is the 

papers act as an immunoaffinity column; solution 1 acts as a loading process; solution 2 

acts as an eluting/reacting solution. Solution 3 is a magic solution that can destroy lead 

and/or other pollutants. 

(3) In situ test. Fast. Yes/no answer (visual). Minimal handling of paint. Minimal handling of 

chemicals. 

(4) 1. An all-inclusive kit in one package 

2. An all-or-none, yes-or-no result, similar to the widely used home pregnancy test 

(5) Colorimetric kit with a quantitative measurement methodology, possibly modification of 

reflectance spectrometry. If standards are lowered, this technology could continue to be 

relevant. 

(6) No response 

(7) (only options) 

Colorimetric: in situ 

-10

0

10

20

30

40

50

60

70

80

90

100

0 1

ug/cm2

P %
A-16 

 Quantitative: ex situ

 Meets International Organization for Standardization 17025 and National Lead Laboratory 

 Accreditation Program accreditation as a field operations laboratory 

 Both: no/low hazardous waste 

(8) A spot test that is based on application of a solution on the paint surface that will penetrate 

 all layers of paint and will provide a well-defined color change at the 1.0-mg/cm2

 

 concentration. 

(9) I would suggest that all renovators assume that lead is present and practice lead-safe work 

 practices at all times. 

(10) A variation of an easy-to-use kit such as Lead Check, Silver Lake Research paint kit, or the 

 Abottex kit, which has a consistent spike at a known lead level, and the kit can be adjusted 

 to spike at different lead levels. (The respondent drew a simple diagram very similar to the 

 one drawn by respondent 7.) 

Responses to the question, “What would the perfect standard look like?” 

(1) Standard concentration set. 

a. 0, 0.1, 0.5, 1.0, 2.0, 5.0 

(2) Standards should have two to three concentration levels (<1, 1, >1, mg/cm2

). 

Standards can be coated on at least three matrixes. 

Selection of matrix should be based on the existing information. 

And choose three most commonly found matrixes. 

(3) For standards used for evaluations, real world is best. Manufactured films shown to behave 

close to real world would be second best. 

a. For standards used to verify kit function, any lead film would be okay. 

(4) It would have a negative control and a positive control. The positive control would have what 

was determined by consensus to be an average number of overlayers of paint. 

(5) Uniformly painted substrates (characterized by XRF and inductively coupled plasma-atomic 

emission spectroscopy) at five concentrations (e.g., 0, 0.5, 0.8, 1.0, 1.6 mg/cm2

). Standards 

should be characterized for multielements. 

(6) No response 

(7) 

• Available at little/ no cost 

• Replenishable and disposable 

• Multiple lead concentrations, certified reference material 

• Uniformly distributed on various substrates 

• Includes a population of unknowns for conduct of blind performance-based examination of 

 users in the field (also for use in XRF performance analytical testing) 

Red

White

White Lead Paint

Plastic

Blue

Brown

Yellow

Latex 

Paint
A-17 

(8) It would be “tailored” to the test kit. If spot test above is used, the standard would be 

comprised of a segment of a layered substrate that would provide a range of concentrations. 

(9) No response 

(10) A sandwich of the four major lead pigments ([1] lead carbonate, [2] lead silicate, [3] lead 

 sulfide, and [4] lead oxide); lead levels at a variety of levels above and below regulatory 

 standards. 

Responses to the question, “If you had the standards, what would the protocol 

look like?” 

(1) No response 

(2) The protocol should follow similar formats as other EPA methods and/or ASTM methods. 

(3) There are many pieces to such a protocol. The number of standards needed to do 

evaluations is essentially a statistical question. There exists enough variability data on 

existing kits to come to a sound decision as to the number of lead levels needed to properly 

define the response curve (which is needed to really characterize the kits). The number of 

different characteristics these standards would have to have to cover real-world (commonly 

encountered) paint surfaces is somewhat debatable but likely could be established with 

reasonable confidence. 

(4) Use pulverized paint chips (microwaved, sonicated, etc.) from 1 cm2

 would be dumped into 

a tube of liquid extractant (provided as part of the kit). After a set period of time (relatively 

short), the chemistry portion of the protocol would be initiated by mixing chemicals provided 

to the kit and guided to the reactant. 

(5) Protocol would require testing? (n=3) at 0 mg/cm2

 and the action level. In addition, 

procedures to dispose of waste will be simple (disposed into solid packaging?). Recommend 

testing like substrates to be disturbed. 

(6) ETV would develop protocol based on performance parameters of interest to buyers and 

users of test kits (accuracy, precision, false positive, temperature effects, waste disposal, 

etc.). 

(7) Colorimetric: Very simple as an ASTM standard method(s), mostly/based on 

pictograms/pictures/illustrations 

 Quantitative: ASTM standard method(s) for sample prep and analysis 

(8) Follow the ASTM protocol and modify as needed 

(9) No response 

(10) Round robin test with 10 renovators, trained as will be done under the rule, testing of 7 

lead levels, 3 tests per renovator, so about 210 tests per substrate. 

Responses to the question, “What would be a reasonable price?” 

(1) No response 

(2) $5 and/or below. In order to meet the criteria as required. No, it is unlikely a $2 kit can 

perform the job properly. I would suggest that the criteria should be changed to NO (0%) 

false negative rate at 1 mg/cm2

 and no requirement for false positive. 

(3) Any kit >$10 per test would likely not be used by any R&R contractor. Add the cost of lab 

plus shipping (even waiting overnight for an answer) would be less! 

(4) Realistically, up to $10 per kit 

(5) $5 to $10 per sample 

(6) No response 

(7) (Using the “dream” test kit, cost of materials only) 

 Colorimetric: $2 per test 
A-18 

 Quantitative: $18 to $36 per test 

(8) $10 to $15 

(9) No response 

(10) Assuming five tests per renovation, cost needs to be less than $10 per test, or might as 

well use lead-safe work practices. 
A-19 

APPENDIX D

Workshop Agenda 

Lead Paint Test Kits Workshop 

U.S. EPA/Office of Research and Development (ORD)/ 

National Exposure Research Laboratory (NERL) 

 

Research Triangle Park, NC 

October 19-20, 2006 

AGENDA

THURSDAY, OCTOBER 19, 2006

8:00 a.m. Registration - EPA Auditorium 

9:00 a.m. Logistics

Dr. Myriam Medina-Vera, EPA/NERL 

9:10 a.m. Development of the Next Generation of Lead Paint Test Kits

Dr. Larry Reiter, EPA/NERL 

9:40 a.m. Overview of EPA Lead R&R Rule and Role of Lead Paint Test Kits 

Dr. Maria Doa, EPA/OPPT 

10:10 a.m. Break

10:30 a.m. HEASD’s Technical Approach 

Dr. Linda Sheldon, EPA/NERL 

11:00 a.m. Key Items from Issue Paper

Sharon Harper, EPA/NERL 

11:15 a.m. HEASD Technical Update 

11:30 a.m. Lunch (on your own, EPA Cafeteria is available) 

1:00 p.m. Breakout Groups Discussions

1. Accuracy, precision and cost of lead (Pb) test kits to determine Pb in paint at 

the federal action level (chemistry and approaches) - C111A 
A-20 

2. Specifications, and availability of testing/reference materials and protocols to 

evaluate the performance of test kits for Pb in paint at the federal action level 

and cost to perform the protocols – C111C 

2:15 p.m. Break

2:30 p.m. Continuation of Breakout Group Discussions

5:00 p.m. End of Day 1 

FRIDAY, OCTOBER 20, 2006

 

9:00 a.m. Highlights of Discussions from Breakout Groups

Breakout group participants 

10:15 a.m. Break

10:30 a.m. Summary of Discussions 

 Full group 

11:00 a.m. Workshop Wrap-up and List of Key Points 

Myriam Medina-Vera and Sharon Harper, EPA/NERL

12:00 p.m. Workshop Adjourns
A-21 

APPENDIX E

List of Attendees 

Lead Paint Test Kits Workshop 

October 19 and 20, 2006 

Research Triangle Park, NC 

Kevin Ashley, Ph.D. (via phone)

Research Chemist 

CDC/NIOSH 

U.S. Department of Health and Human 

Services 

4676 Columbia Parkway 

Cincinnati, OH 45226-1998 

Phone: 513-841-4402 

E-mail: kashley@cdc.gov 

Satish Barnela, Ph.D. 

Scientist 

U.S. EPA 

109 T.W. Alexander Drive 

RTP, NC 27711 

Phone: 919-541-3622 

E-mail: barnela.satish@epa.gov 

Elizabeth Betz 

HEASD QA Manager 

U.S. EPA/ORD/NERL/HEASD 

U.S. EPA, E205-01 

RTP, NC 27711 

Phone: 919-541-1535 

E-mail: betz.elizabeth@epa.gov 

David Binstock, Ph.D. 

Research Chemist 

RTI International 

3040 Cornwallis Road 

RTP, NC 27709 

Phone: 919-541-6896 

E-mail: binnie@rti.org 

Robert Blake, II, Ph.D. 

Professor and Chair 

College of Pharmacy, Xavier University of 

Louisiana 

1 Drexel Drive 

New Orleans, LA 70125 

Phone: 504-520-7489 

E-mail: rblake@xula.edu 

Karen Bradham, Ph.D. 

Physical Scientist 

U.S. EPA/ORD/NERL/HEASD 

109 T.W. Alexander Drive 

RTP, NC 27711 

Phone: 919-541-9414 

E-mail: bradham.karen@epa.gov 

Jim Bryson 

Team Leader-TSCA Lead & Asbestos 

Programs 

U.S. EPA 

1 Congress Street, Suite 1100 

Boston, MA 02110 

Phone: 617-918-1524 

E-mail: bryson.jamesm@epa.gov 

Bob Carr 

Technical Specialist 

U.S. EPA 

1 Congress Street 

Boston, MA 02114 

Phone: 617-918-1607 

E-mail: carr.bob@epa.gov 
A-22 

Jane Chen Chuang 

Research Leader 

Battelle 

505 King Avenue 

Columbus, OH 43201 

Phone: 614-424-5222 

E-mail: chuangj@battelle.org 

Sandra Cole 

President 

Cole Environmental, Inc. 

10500 Lake Avenue 

Cleveland, OH 44102 

Phone: 216-961-7030 

E-mail: sandicole@aol.com 

Gary DeWalt, Ph.D. 

Scientist 

QuanTech, Inc. 

9 White Oak Road 

Landenberg, PA 

Phone: 610-255-5525 

E-mail: fgdewalt@comcast.net 

Maria Doa, Ph.D. 

U.S. EPA/OPPTS/OPPT/NCPD 

Ariel Rios Building 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

Phone: 202-566-0718 

E-mail: doa.maria@epa.gov 

Robert Fuerst 

U.S. EPA/ORD/NERL/HEASD 

USEPA, 205-05 

RTP, NC 27711 

Phone: 919-541-2220 

E-mail: fuerst.robert@epa.gov 

Mark Geisberg, Ph.D. 

Director of Research and Development 

Silver Lake Research Corporation 

911 South Primrose Avenue 

Monrovia, CA 91017 

Phone: 626-359-8441, x14 

E-mail: mgeisberg@silverlakeresearch.com 

William Gutknecht, Ph.D. 

Assistant Director, Environmental and 

Industrial Sciences Division 

RTI International 

3040 Cornwallis Road 

RTP, NC 27709 

Phone: 919-541-6883 

E-mail: wfg@rti.org 

Sharon Harper 

U.S. EPA/ORD/NERL/HEASD 

U.S. EPA, D205-05 

RTP, NC 27711 

Phone: 919-541-2443 

E-mail: harper.sharon@epa.gov 

Karen Harris 

UICG President 

Abotex Enterprises, Ltd. 

10397 Grand Oaks Drive 

Grand Bend, Ontario, Canada N0M1T0 

Phone: 519-238-8776 

E-mail: service2@leadinspector.com 

Ross Highsmith 

Assistant Laboratory Director for Pesticides 

and Toxics 

U.S. EPA/NERL 

109 T.W. Alexander Drive 

RTP, NC 27711 

Phone: 919-541-7828 

E-mail: highsmith.ross@epa.gov 

David Lachance 

President 

Abotex Enterprises, Ltd. 

10397 Grand Oaks Drive 

Grand Bend, Ontario, Canada N0M1T0 

Phone: 519-238-8776 

E-mail: dmlachance@leadinspector.com 

Albert Liabastre, Ph.D. 

USACHPPM-South 

1312 Cobb Street, SW 

Fort McPherson, GA 30330-1075 

Phone: 404-464-2826 

E-mail: Albert.Liabastre@us.army.mil 
A-23 

Geng Lu, Ph.D. 

Research Scientist 

University of Illinois at Urbana-Champaign 

CLSL A407, 600 S. Mathews Avenue 

Urbana, IL 61801-3602 

Phone: 217-265-0829 

Email: genglu@uiuc.edu 

Myriam Medina-Vera, Ph.D. 

Chief, Methods Development and 

Applications Branch 

U.S. EPA/ORD/NERL/HEASD 

109 T.W. Alexander Drive 

RTP, NC 27711 

Phone: 919-541-5016 

E-mail: medina-vera.myriam@epa.gov 

Jacqueline Mosby 

U.S. EPA/OPPTS/OPPT/NCPD/PAOB 

Ariel Rios Building 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

Phone: 202-566-2228 

E-mail: mosby.jackie@epa.gov 

Larry Reiter, Ph.D. 

Director 

U.S. EPA/ORD/NERL 

USEPA, D305-01 

RTP, NC 27711 

Phone: 919-541-2106 

E-mail: reiter.larry@epa.gov 

Karen Riggs 

Product Line Manager 

Battelle 

505 King Avenue 

Columbus, OH 43201 

Phone: 614-424-7379 

E-mail: riggsk@battelle.org 

Kim Rogers, Ph.D. 

U.S. EPA/ORD/NERL/HEASD 

944 East Harmon Avenue 

Las Vegas, NV 89119 

Phone: 702-798-2299 

E-mail: rogers.kim@epa.gov 

Walter Rossiter 

W.J. Rossiter & Associates 

26400 Forest Vista Drive 

Clarksburg, MD 20871-9624 

Phone: 301-253-3534 

E-mail: wjrossiter@verizon.net 

Dana Ryan 

Vice President 

Cole Environmental, Inc. 

10500 Lake Avenue 

Cleveland, OH 44102 

Phone: 216-961-7030 

E-mail: danalryan@aol.com 

John Schwemberger 

Statistician 

U.S. EPA/OPPTS 

Ariel Rios Building 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

Phone: 202-566-1972 

E-mail: schwemberger.john@epa.gov 

Linda Sheldon, Ph.D. 

Acting Director 

U.S. EPA/ORD/NERL/HEASD 

USEPA, E210-01 

RTP, NC 27711 

Phone: 919-541-2205 

E-mail: sheldon.linda@epa.gov 

E. Travis Stone 

Vice President of Research 

Hybrivet Systems, Inc. 

17 Erie Drive 

Natick, MA 01760 

Phone: 508-651-7881 

Email: estone@comcast.net 

Marcia Stone, Ph.D. 

President, Chief Technical Officer 

Hybrivet Systems, Inc. 

17 Erie Drive 

Natick, MA 01760 

Phone: 800-262-5323 

Email: mstone@leadcheck.com 
A-24 

Maggie Theroux (via phone)

EPA Region 1 

1 Congress Street, Suite 1100 

Boston, MA 02114-20023 

Phone: 617-918-1613 

Email: theroux.maggie@epa.gov 

Dennis Utterback, Ph.D. 

Policy Analyst 

U.S. EPA/ORD/OSP 

Ariel Rios Building 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

Phone: 202-564-6638 

Email: utterback.dennis@epa.gov 

Jeanette Van Emon, Ph.D. 

U.S. EPA/ORD/NERL/HEASD 

944 East Harmon Avenue 

Las Vegas, NV 89119 

Phone: 702-798-2154 

Email: vanemon.jeanette@epa.gov 

Brian Vargo 

EMD Chemicals, Inc. 

480 South Democrat Road 

Gibbstown, NJ 08027 

Phone: 800-222-0342 x481 

Email: BVargo@emdchemicals.com 

Kenn White, CIH, CSP 

Principal 

Consultive Services 

4428 Ironwood Drive 

Virginia Beach, VA 23462 

Phone: 757-499-4420 

Email: kennwhite@cox.net 

Emily Williams 

Healthy Homes Division 

1500 Pinecroft Road, Asheville Building, 

Suite 500 

Greensboro, NC 27407 

Phone: 336-547-4002 x2067 

Email: emily_e._williams@hud.gov 

Mike Wilson 

Environmental Protection Specialist 

U.S. EPA/OPPTS/OPPT/NCPD/LHMIB 

Ariel Rios Building 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

Phone: 202-566-0521 

Email: wilson.mike@epa.gov