The definition of “soil sample” at 40 CFR §745.63 relies on certain American Society of Testing Materials (ASTM) standards. Did EPA intend to prevent the use of EPA and HUD standards for soil samples?
Answer: 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…