Q: Did EPA intend to prevent HUD and RRP standards used for wipe samples?

No. In establishing work practice standards for lead-based paint activities, EPA did not intend to prevent the use of EPA/HUD standards. As a general matter, the requirements are not prescriptive...

No. In establishing work practice standards for lead-based paint activities, EPA did not intend to prevent the use of EPA/HUD standards. As a general matter, the requirements are not prescriptive but instead state that certain activities be conducted using appropriate documented methodologies. For example, §745.227(c)(3) requires that dust samples be taken using documented methodologies that incorporate adequate quality control procedures. At §745.227(a)(3), EPA lists documented methodologies that are appropriate for the work practice standards, including the HUD Guidelines and certain EPA methodologies, and also states that “other equivalent methods” are acceptable. Although the definition of “wipe sample” refers specifically to ASTM standards, EPA does not interpret this as limiting the acceptable standards to those of ASTM. EPA considers the description of wipe materials found in the HUD Guidelines for Evaluation and Control of Lead-Based Paint Hazards in Housing, June 1995 edition, at Appendix 13.1, “Wipe Sampling for Settled Lead-Contaminated Dust” and the discussion of wipes on pp. 15-16 of EPA’s document Residential Sampling for Lead: Protocols for Dust and Soil Sampling, March 1995, EPA 747-R-95-001 to be the equivalent of the ASTM standards, and therefore, acceptable for use.