Q: Can a certified renovator using an EPA recognized lead test kit or performing paint chip sampling pr

EPA's regulations only provide for a No, only a certified inspector or risk assessor can conduct lead-based paint inspections and prepare lead-based paint inspection reports.

The results of paint testing using lead test kits or paint chip sampling are part of the official lead-based paint testing record for a home, and must be disclosed under EPA's Real Estate Disclosure regulation (40 CFR part 745, subpart F).  However, EPA's regulations only provide for a certified inspector or risk assessor to conduct a lead-based paint inspection and to prepare a lead-based paint inspection report.  Thus, allowing renovators to test components does not negate the requirement that a certified inspector or risk assessor follow the requirements set forth in § 745.227(b) when conducting a lead-based paint inspection.