Missoula Technology and Development Center Facilities Toolbox: Hazardous Substances in Buildings
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What am I supposed to do with lead-based paint debris? 

The requirements for disposal of debris containing lead-based paint vary depending on the concentration of lead in the debris and the building's use.

If ordinary construction or remodeling debris from a residential building includes some lead-based paint, the debris may be disposed of as general waste in a municipal landfill or a construction and demolition waste landfill. Cabins, bunkhouses, family housing, and other residential buildings are all considered "residences". The disposal of this sort of debris is easy to encourage people to remove surfaces painted with lead-based paint from homes where children might contact it. States may have more stringent disposal regulations, so check with your regional environmental engineer.

Construction debris from non-residential sites that may be contaminated with lead-based paint and lead-based paint waste such as paint chips, dust, or sludge must be treated as toxic waste unless an analysis proves that the percent of lead falls below the hazard threshold. Proper disposal of debris from lead-based paint removal should be included in the construction contract. The debris can be analyzed using either of the two procedures explained below.

To analyze the waste characteristics using "applied knowledge" or a "knowledge of process" method, the lead content of the waste must be calculated by weight to determine the milligrams of lead per kilogram of waste or the parts per million of lead in the waste. This method can only be used if the total mass of the lead and the total mass of the debris can be determined with precision.

To analyze the waste using the toxicity characteristic leaching procedure (TCLP), a representative sample of the waste must be tested by an accredited testing laboratory. Accredited testing labs can be located using a search tool at the American Council of Independent Laboratories Web site, or by calling 202-887-5872. ASTM standard D6009 defines the standard for obtaining a representative sample from a debris pile. 

If the sample contains less than 100 milligrams of lead per kilogram (or 100 parts per million) of waste as analyzed by the applied knowledge method, then the waste is considered non-hazardous. A TCLP result of less than 5 milligrams per liter is also considered non-hazardous. Non-hazardous waste can be disposed at a municipal waste landfill.

If the waste contains more than 100 milligrams of lead per kilogram (or 100 parts per million) as analyzed by the applied knowledge method or more than 5 milligrams per liter as analyzed by the TCLP, the waste is considered toxic and generally must be disposed as hazardous waste. In some cases, special procedures can render the waste nonhazardous so it can be disposed in an ordinary municipal landfill.

The requirements for disposal of lead-based paint debris may vary by State. For instance, some States don't require testing debris from a complete building demolition, even if the debris includes some lead-based paint. See the Hazardous Materials Requirements for Building Demolition web site (available only to Forest Service and BLM employees) for information on debris testing requirements in your state. Also check the EPA's Lead Abatement Web page, the Construction Industry Compliance Assistance Center's State Lead-Based Paint Abatement Tool, or with your regional environmental engineer (link available only to Forest Service employees) for more information about the requirements in your state.


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