/ IN THIS BLOG
01 / Introduction: understanding the danger of lead-paint waste
One needs to appreciate the mechanism by which lead paint is dangerous to understand the ins & outs of lead-paint disposal.
There’s a misconception that lead paint is only hazardous to children, and then only if they were to eat the chips from deteriorating paint. But this isn’t true. Deteriorating lead paint is dangerous mostly because it emits lead dust.
Odorless, tasteless, invisible, and highly toxic, lead dust disperses into indoor air undetected. Thus, entire families can be breathing lead dust and absorbing it through their skin—not just the kids. And the health dangers are serious and lifelong.
The problem also exists in offices, factories, and other commercial spaces, which is why OSHA has extensive rules regarding how much lead dust an employee can be exposed to during a workday (S.N. 1926.62).
02 / Why do some paints contain lead?
Until its toxic effects were discovered, lead was used as an additive to paints and primers to speed drying, increase durability, maintain a fresh appearance, and resist corrosive moisture. It was banned by the federal government in 1978 for most uses, although lead paint still used for road markings, military equipment, and other heavy-duty applications.
03 / Lead paint in good condition isn’t actually dangerous
Because there’s no lead dust to consider, in-tact & well-maintained lead paint isn’t a problem; and it’s unlikely anyone’s going to eat it off the wall. You can just paint over it with modern latex paint when it’s time to redecorate. But lead dust is a significant problem during renovation or demolition of buildings.
Chances are a building contains lead paint if it was built prior to 1978. That’s 40+ years ago. And since older buildings are the logical targets of renovation & demolition, lead-paint disposal is a significant tactical challenge to contractors, remodelers, renovators, etc.
04 / Household lead-paint waste doesn’t require hazardous waste disposal
Interestingly enough, lead-paint waste disposal is excluded from EPA hazardous waste management regulations if the waste comes from a residential household project. I.e., residential lead-based paint waste can be managed as non-hazardous household waste.
The agency did this to make it easier for people to remove deteriorating lead-based paints from homes. Nonetheless, certain commonsense procedures must be followed to minimize lead dust, limit access to lead-paint waste, and maintain the integrity of waste-packaging materials during transit to a household-waste facility. Among them:
Collecting lead-paint chips, dust, dirt, and rubble into plastic trash bags for disposal
Storing larger lead-contaminated waste in containers for eventual disposal (preferably in covered mobile dumpsters)
Contacting municipal or county solid-waste agencies in advance to determine local regulations about lead-paint disposal
05 / Removing residential lead-based paint requires special procedures
The EPA Lead Renovation, Repair and Painting (RRP) Rule establishes regulations for contractors, property managers, and others who disturb painted surfaces while performing renovations on properties constructed before 1978.
This is because the chipping, scraping, and sanding required to remove deteriorated lead-based paint from walls (to prepare them for latex paint) creates toxic dust, chips, flakes, and wastewater that must be properly managed and contained.
The work must be done by hand, without power tools, and the area must be isolated to minimize dust created and dispersed into the air. Carpeting, furniture, and fixtures need to be protected with poly covering. Warning signs should be posted; and there are specific cleanup procedures.
This RRP rule includes education, training, and work-practice mandates, as well as requiring lead-paint certification for any person, firm, or sole proprietorship paid to perform work that disturbs paint in any pre-1978 houses, apartments, schools, or childcare centers.
06 / Non-residential lead-paint might require hazardous waste disposal
Lead-paint waste from commercial or industrial sources that are a consequence of renovation, abatement, or whole-building demolition projects might be subject to state and federal hazardous waste management rules.
To make this determination, one must assay the lead-paint waste for lead toxicity, using the Toxicity Characteristic Leaching Procedure (TCLP). This is a chemical analysis that simulates landfill leaching to yield a rating.
The rating indicates the amount of listed contaminants present in the lead-paint waste and thus likely to be absorbed by soil and groundwater. In the case of lead, 5.0 mg/liter or more indicates the waste has significant lead toxicity and thereby requires hazardous waste disposal.
07 / States and localities might have stricter rules about lead-paint waste disposal
The EPA encourages contractors and residents to contact their state and/or local agencies to
determine what local restrictions apply to the disposal of residential lead-based paint waste. This is because these jurisdictions can enforce regulations that are broader and more stringent than federal RCRA requirements—and they often do.
08 / The upshot about lead-paint waste disposal
As they tend to come simultaneously from federal, state, and local bureaucracies, environmental regulations about lead-paint disposal are plentiful, evolving, and challenging to track. Ignoring or misunderstanding them can subject you to significant financial consequences and even criminal prosecution.
If you have a lead-paint waste challenge and are unsure whether it requires hazardous-waste vs household-waste disposal, don’t take chances. You need an environmental services partner with a solid history of providing safe, efficient, and compliant waste disposal services.
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