Under the Lead Renovation, Repair and Painting (RRP) Rule, is composite sampling acceptable for clearance in lieu of cleaning verification?

Yes. Under the RRP Rule, cleaning verification need not be performed if the contract between the renovation firm and the person contracting for the renovation or another Federal, State, Territorial, Tribal or local law or regulation requires:

• The renovation firm to perform dust clearance sampling at the conclusion of a renovation covered by this subpart;
• The dust clearance samples are required to be collected by a certified inspector, risk assessor or dust sampling technician; and
• The renovation firm is required to re-clean the work area until the dust clearance sample results are below the clearance standards in 40 CFR 745.227(e)(8) or any applicable State, Territorial, Tribal or local standard.  

Clearance must be performed following the procedures in 40 CFR 745.227(e)(8), which allow the use of composite sampling. Not all laboratories will analyze composite samples, so check with your laboratory before collecting them. Typically, interior clearance is achieved by means of dust wipe sampling by a certified inspector or risk assessor using single surface dust wipes. This is required on all U.S. Department of Housing and Urban Development (HUD) jobs.  

Question Number: 23002-20755

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