Testing in advance is less expensive and burdensome than clearance
inspections and it makes sense in situations where there is a low to medium
probability of finding LBP.  For projects with a high probability of finding LBP,
testing in advance may just be an added cost that serves no purpose.  The
table and recommendations below can help in making decisions to save time
and cut costs.
Probability of LBP (low, medium, and high)
Component type
Before 1940
    Interior walls, floors, ceilings
    Interior windows
    Interior cabinets
    Interior doors
    Interior trim
    Exterior walls
    Exterior windows
    Exterior doors
    Exterior trim
This guide is for the purpose of completing renovation projects in pre-1979 construction with the least
cost and burden associated with lead-based paint (LBP) regulations.  It's written primarily for projects
inside the City of San Diego but there may be occurrences when it's useful for projects elsewhere.  In
San Diego, unless tested in advance to show otherwise, pre-1979 paint is assumed to be LBP and a
lead clearance inspection is required at the end of the project.  This decision guide can help avoid paying
for testing twice (pre-renovation testing and clearance testing) on a project.
Lead Test Kits - What you Need to Know
False Negative - occurs when a test result gives a negative reading when in fact the material sampled is
positive for lead.  False negatives pose a threat to human health by giving a false impression that lead is
not present and that lead-safe work practices are not needed.
If all components impacted have a low or medium probability:  Test with certified lead inspector in advance
of the work.
If any components impacted are high probability:  Assume everything to be LBP, use lead-safe work
practices, and have a clearance inspection performed by a certified lead inspector upon completion of
the work.
It's the opinion of San Diego Testing that such levels of inaccuracy are unacceptable for anyone with
budget concerns.  XRF lead testing is less expensive than clearance inspections and far less expensive
than the combination of clearance inspections and the usage of lead-safe work practices.  If XRF lead
testing is used with consideration to the probability table and recommendations above then cost savings
will be achieved.
The EPA has "recognized" two test kits: D-Lead and 3M LeadCheck.  Most
states permit the usage of these test kits to make a determination on whether
lead-based paint is present and whether RRP certification and lead-safe work
practices are required.  California does not permit the usage of test kits to make
such determinations due to their high level of inaccurate results.  However, test
kits are available in California and are often promoted as a lead screening tool.
San Diego Testing recommends against using lead test kits as a screening tool
because the inaccuracies ultimately will waste time and money to the contractor
and property owner (as will be explained in detail below).  We have found that the
most cost effective method to handle lead paint requirements is to use the
probability table and recommendations previously suggested on this page.  To
explain the reasoning for this conclusion it's necessary to discuss two terms that
are used to describe the accuracy of a test method.
False Positive - occurs when a test result gives a positive reading when in fact the material sampled is
negative for lead.  False positives pose no threat to human health but they do cause unnecessary
expenses associated with lead-safe work practices and clearance inspection requirements.
The original text of the EPA RRP Rule stated that recognized test kits must have no more than 5% false
negatives and no more than 10% false positives.  Once it was apparent that these levels of accuracy
were impossible to achieve using a home test kit, EPA reconsidered and decided to focus only on false
negatives.  That's because a false positive is not going to put human health in jeopardy and a false
negative could.  False positives cause contractors and property owners unnecessary expenses, but
reducing such expenses is not an objective of the EPA.  To get a sense of how much wasted costs these
test kits cause, it's important to know the percentage of false positives each generate.
D-Lead false positives:  29% in a non-laboratory environment.  See page 22 of full results.
3M LeadCheck false positives:  98% in a non-laboratory environment.  See page 21 of full results.
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Lead Testing Decision Guide for pre-1979 Renovations
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