While I agree that combining the two regulations into one will be less confusing the wording does nothing to ensure that children, even those deemed at-risk, will be tested for elevated blood lead levels.  A major concern of mine, as the mother of a lead poisoned son, is that there is no uniform lead level of concern in Virginia.  UPAL has been getting a rash of calls from parents with children with ebls.  In responding to the calls I'm finding that the action level for ebls vary from locality to locality.  For instance Henrico's is 20 ug/dL while Richmond/Chesterfield is 15 ug/dL.  We should  include wording in the regulations that would make the action level uniform across the state.  Otherwise the testing and screening process that leads to case management and prompts residential lead inspections/risk assessments is convoluted and designed for failure to the detriment of our children.  The Commonwealth's level should also be more in line with the CDCs reference value of 5 ug/dL.  Moreover once a child has tested high the home should be automatically inspected to determine if the home is the source of poisoning.  This business of having to test "repeatedly and persistently" at elevated leves, does a disservice to our children and uses them as modern day canaries in the mines and reduces them to lead detectors.   CHILDREN'S LIVES MATTER - A CHILD IS A TERRIBLE THING TO WASTE!