Several member firms have contacted NAA/NMHC to report that regional EPA officials have stated that the federally approved testing protocol that has been in place under the Lead-based Paint Hazard Reduction Act (40 CFR Part 745.227) will not be sufficient to comply with the requirements of the new Renovation, Repair and Painting (RRP) rule.
NAA/NMHC have received an informal, yet definitive, response back from the EPA that this is incorrect. Member firms are advised that the testing protocols found in the Residential Lead-based Paint Hazard Reduction Act remain appropriate for compliance purposes under the RRP rule. The EPA will be communicating directly with its regional offices to clarify this matter.