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Hazardous Substances in Buildings

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Hazardous Substances in Buildings

  • Hazardous substances in Forest Service buildings can be a hetitleh risk to employees and customers. Building materials may contain hazards such as asbestos and lead-based paint. Building configuration and local geology may combine to create a buildup of radon gas in a building. Common building components such as fluorescent light bulbs, mercury thermostats, lighting ballasts, and exit signs may contain chemicals dangerous to human hetitleh and the environment. This section of the Toolbox will help you deal with hazardous materials in your buildings.

    Historic Ninemile Ranger Station.

    Forest: Lolo
    District: Ninemile
    Region: 1


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  • Magnified Asbestos Fibers

    Asbestos is a group of naturally occurring mineral fibers used in many building materials, especially those manufactured before 1980. Its use is not entirely banned, so you still may find it in commercially available products. Asbestos causes serious diseases, including cancer, of the lungs and other abdominal organs. Working with asbestos-containing materials (ACM)is highly regulated to minimize occupational disease and environmental contamination.

    Must Forest Service buildings be inspected for asbestos?

    Who can inspect the building?

    What's the difference between friable and non-friable asbestos?

    I have asbestos in my building. Now what?

    Can Forest Service employees remove asbestos or work with it?

    Can I sell or excess a building that contains asbestos?

    I want to demolish a building that contains asbestos. What must I do?

    Can I burn a building with asbestos?

    What about mobile homes?

    What about vermiculite?

  • Is this windowsill painted with lead-based paint?

    Forest: Bitterroot
    District: Stevensville
    Region: 1

    Buildings constructed before 1978 may contain lead-based paint. Lead from paint, paint chips, and dust can pose hetitleh hazards if not taken care of properly. Lead-based paint that is in good condition is usually not a hazard. However, lead dust can form when the paint is scraped, sanded, or heated. Lead exposure may cause a range of hetitleh effects, from behavioral problems and learning disabilities, to seizures and death. Children 6 years old and younger are most at risk, because their bodies are growing quickly.

    How can I tell whether a building has lead-based paint?

    Do we have to tell people about lead-based paint in Forest Service buildings?

    Can I sand and repaint the woodwork in a building with lead-based paint?

    Do we have to remove lead-based paint in Forest Service buildings?

    Can I demolish or burn a building with lead based paint?

    Who can work on lead-based paint abatement projects?

    What am I supposed to do with lead-based paint debris?

    Can I sell an excess building with lead-based paint?

    Which buildings are considered "target" housing and child-occupied facilities?

    Where can I learn more about lead based paint?

  • Wall mold in a Forest Service residence.

    Molds (sometimes called mildew) are forms of fungi that are found both indoors and outdoors all year round, everywhere on the planet. There are thousands of species of mold. All molds need moisture to grow, and most prefer warm temperatures. Mold may be white, orange, green, brown, black, or other colors. Sometimes mold can be detected by a musty odor. Molds reproduce by microscopic cells called "spores" that spread through the air and form new mold colonies when they find the right conditions. All of us are exposed to fungal spores daily in the air we breathe, both outside and inside. Very few of us are affected.

    For a few people, too much exposure to mold may cause or worsen asthma or allergies. The most common symptoms are cough, congestion, runny nose, eye irritation, and aggravation of asthma. More serious hetitleh effects—such as fevers and breathing problems—can occur but are unusual. Most symptoms are temporary and disappear when the mold problem is corrected.

    Rot caused by mold in a Civilian Conservation Corps-era Forest Service building.

    When molds are present in large quantities, they may cause nuisance odors. Mold can damage building materials, finishes, and home furnishings. Some molds can cause structural damage to wood and other building components.

    Excellent general information about mold, along with instructions for mold discovery and removal, personal protective equipment, links, and references is available in the 2014 Region Six Technical Update MOLD.

    This section is under construction. Please check back later for more information. Meanwhile, check out the Washington Office Engineering FSWeb section on mold (Web site available only to FS and BLM employees) for some Web links that provide more information.

  • Radon is a toxic, colorless, odorless gas. It is produced during the radioactive decay of uranium and is naturally present in soil and rocks in many parts of the country. Exposure to high levels of radon greatly increases the risk of developing lung cancer, especially for smokers. Radon may enter water supplies or buildings from adjacent soils and rock. Average outdoor radon levels are about 1.3 picocuries per liter of air. Buildings with an annual average of 4 picocuries per liter or more are considered to have elevated radon levels. All Forest Service buildings must be tested for the presence of radon gas, and those with elevated radon levels must be modified to reduce the level below 4 picocuries per liter.

    This section is under construction. Please check back later for more information. Meanwhile, check out the Washington Office Engineering FSWeb section on radon (Web site available only to FS and BLM employees) for some web links that provide more information.

    Map courtesy of Lawrence Berkeley National Laboratory and Columbia University Department of Statistics, Phillip N. Price, Anthony Nero, Kenneth Revzan, Michael Apte, Andrew Gelman, W. John Boscardin, Linda Gundersen, Randy Schumannand and others.

  • Simply stated: YES, unless you want to treat all the materials in your existing buildings as if they contain asbestos.

    The Environmental Protection Agency's Asbestos National Emission Standard for Hazardous Air Pollutants (NESHAP) asbestos operations and maintenance website explains the requirements. Basically, the asbestos NESHAP requires a thorough inspection of both the inside and outside of a building before renovation or demolition. The asbestos NESHAP protects the general public from airborne contaminants that are hazardous to human hetitleh.

    Two Occupational Safety and Hetitleh Administration (OSHA) standards affect our employees and contractors who work at our facilities. The General Industry Standard (29 CFR 1910.1001) covers custodial work and the Construction Standard (29 CFR 1926.1101) covers construction work including repair, renovation, telecommunications, and demolition. The OSHA Asbestos Fact Sheet summarizes OSHA asbestos regulations. OSHA requires that building owners communicate asbestos hazards to those who may be exposed to asbestos. To do so, the owner must know whether asbestos-containing materials (ACM) are present and if so, their location and quantity. Unless testing has been conducted that proves otherwise, OSHA regulations require building owners to presume that the following building materials contain asbestos if they were installed before 1981:

    • Thermal systems insulation—includes furnace ductwork and water pipe insulation.
    • Sprayed, troweled and other surfacing materials—includes popcorn and other texture on ceilings and walls.
    • Resilient flooring—includes linoleum and vinyl tile and sheet flooring.

    Guilty until proven innocent!

    The NESHAP and OSHA regulations don't cover exactly the same set of circumstances. For instance, NESHAP asbestos regulations exempt residential buildings with four or fewer units, but OSHA covers employees working with ACM in residences. Building managers can be assured of compliance with all regulations if they have all buildings inspected both inside and outside.

    Let’s not forget our own Forest Service directives:

  • The Environmental Protection Agency's (EPA) Asbestos Hazard Emergency Response Act (AHERA) dictates that public and commercial buildings, including Federal facilities, must be inspected by accredited asbestos inspectors. You can read the regulation in 40 CFR Part 763, Appendix C to Subpart E, the Model Accreditation Plan ,particularly the top of the second page. Accredited inspectors have had a special 3-day training session and are certified either by their State or the EPA. They attend yearly refresher classes and are accredited on an annual basis. Always use an accredited inspector, and require inspectors to provide you with a copy of their most current credentials, including documents showing yearly refreshers since their initial training. A list of these inspectors can be obtained from your EPA asbestos NESHAP coordinator.

    The AHERA regulations specify a protocol for sampling building materials inside schools and public and commercial buildings. You should ask that an AHERA inspection be conducted and ask that the exterior be inspected as well.

    If you read the regulations closely, you might notice instances where the use of an AHERA-accredited inspector is not mandated, such as in a single-family dwelling. In these cases, an OSHA-trained inspector is required. Since OSHA accepts the AHERA training for asbestos inspectors, it’s easiest to use an AHERA inspector for all inspections, both inside and outside the building.

  • Once you know that you have asbestos-containing materials (ACM) in your building, you need to manage those materials. Depending on the type and condition of the ACM, you may need to remove it, encapsulate it (seal it within a covering), or leave the ACM in place. Some ACM is friable, meaning it can easily crumble or fall apart and release airborne fibers. Other ACM is nonfriable and will not release fibers unless drilled, cut, sanded, or otherwise disturbed.

    The Buildings and Related Facilities Handbook 7309.11,40 requires that each unit develop an asbestos management plan. The plan identifies how each ACM in each building will be treated to minimize the risk of asbestos exposure to employees and visitors. The treatment chosen depends on the type of asbestos, its location and condition, and the activities that are expected to occur near the material. No regulation requires us to remove ACM before we plan to renovate or demolish a building. Once we do, Asbestos NESHAP comes into play and requires removal of ACM in many instances. Most nonfriable ACM does not present a hetitleh risk if left intact, so you may elect to manage it in place until a building is renovated or demolished. Friable asbestos will normally be managed by encapsulation or removal.

    Labeling asbestos-containing material is a way of communicating the potential hazard. OSHA requires signing ACM (29 CFR 1910.1001(j)(2)–(4) ) and so does our Forest Service Handbook 7309.11, 41.11. Signs or labels can be placed on the ACM, in a mechanical room, in the janitor’s closet, or in another area of the building where those working on or around the ACM will be alerted. The sign or label should state what the material is, where it is, and convey that there is a hetitleh risk. Check out the OSHA regulation for the specific wording.

    Except in very limited situations, ACM must be removed by an accredited asbestos contractor. The removal process must be specified by an accredited asbestos abatement designer. These contractors and designers are trained and accredited yearly similarly to asbestos inspectors. One person or company may have both accreditations, or you can contract separately for design and removal. We cannot write our own removal specifications unless our staff is accredited. No Forest Service employee should remove friable asbestos and only trained and equipped Forest Service employees target="_blank" can remove nonfriable ACM. Notification of your State or EPA Asbestos NESHAP coordinator is required for asbestos abatement in public and commercial buildings with more than 260 linear feet, 160 square feet, or 35 cubic target="_blank" feet of ACM. See the Hazardous Materials Requirements for Building Demolition web site (available only to Forest Service and BLM employees) for detailed information on who to notify and how to do so.

    A useful tool in managing and working with ACM is OSHA’s Asbestos Advisor 2.0. This software program can help you comply with the OSHA asbestos standard whether the work is custodial, maintenance, or abatement.

  • Except for the Plumas National Forest asbestos abatement group, no Forest Service employee should remove friable asbestos and only properly trained and equipped Forest Service employees can remove nonfriable ACM. OSHA requires that all individuals working with or around ACM have some training. Custodial staffs are required to have 2 hours of training and maintenance workers must have 16 hours. Someone pulling telecommunications cables is one example of a maintenance worker. OSHA prescribes what must be covered in these training sessions in 29 CFR 1910.1001(j)(7). Your State or EPA Asbestos NESHAP coordinator can provide the names of companies that provide this training.

    The Plumas National Forest's asbestos abatement group is an enterprise team known as Asbestos Crew Services. They have a special waiver from the Washington Office that allows them to do asbestos work because they are fully certified by the Occupational Safety and Hetitleh Administration and the Environmental Protection Agency to do asbestos inspection, project design, and abatement. To obtain further information about the crew or inquire about scheduling work, contact facilities engineer Andrea Seller at 530-283-7872 (aseller@fs.fed.us) or crew supervisor Jim Hogg at 530-283-7732 (jhogg@fs.fed.us).

  • If you’re going to excess a building that has not been inspected for asbestos, you don't have to inspect it first unless you will be using the Facility Realignment and Enhancement Act. However, if the building was built before 1981, you must assume that the following building materials contain asbestos:

    • Thermal systems insulation—includes furnace ductwork and water pipe insulation.

    • Sprayed, troweled, and other surfacing materials—includes popcorn and other texture on ceilings and walls.

    • Resilient flooring—includes linoleum and vinyl tile and sheet flooring.

    You may be able to excess buildings that contain asbestos without removing the asbestos-containing material. Because this hazard is attached to the building and not the land, land cleanup requirements do not apply. Notice must be given to the new owner and all records of asbestos inspection, management, and abatement must transfer with ownership. If the sale of the building involves its removal from the site, friable ACM that may be disturbed during the move must be abated first.

    Buildings conveyed under the Facility Realignment and Enhancement Act must be inspected for asbestos by a certified asbestos inspector. A detailed asbestos inspection report must be provided to bidders and included in purchase, sale, and lease agreements. A notice that future construction activity may trigger OSHA requirements and that they will comply with laws and release the FS from any future asbestos obligations is also required. You can read more at FSREA Minimum Requirements for Asbestos Containing Materials.

    Mobile homes are treated differently from permanent structures.

    The Excess Facilities section of the Facilities Toolbox contains more information on excessing unneeded structures and land.

  • If your facilities master plan shows that disposal is the best option for a structure and you have completed the facilities disposal documentation, you can demolish or burn a building with asbestos, but there are some things you have to do first.

    All buildings to be burned or demolished must first be inspected by an AHERA-accredited inspector. There are few exceptions to this requirement, so either have the building inspected or consult with your State or EPA asbestos NESHAP coordinator.

    If you have more than the threshold amounts of regulated ACM—260 linear feet, 160 square feet, or 35 cubic feet of friable ACM or ACM that will become friable during demolition—the ACM must be removed before demolition. Removal must be in compliance with OSHA and EPA standards.

    Notification must be made to the State or EPA asbestos NESHAP coordinator 10 working days before demolition of any building, even if it does not contain asbestos. See the Hazardous Materials Requirements for Building Demolition web site (available only to Forest Service and BLM employees) for detailed information on who to notify and how to do so.

    All asbestos containing materials must be removed before burning a structure.

    The Excess Facilities section of the Facilities Toolbox contains more information on disposing of unneeded structures.

  • Burning is considered demolition, so the Asbestos NESHAP standard for demolition applies. Just as with other forms of demolition, the building must be inspected first. The only time a building containing asbestos can be burned is when a fire department does it as a training exercise. If there is more than the regulated amount of ACM (260 linear feet, 160 square feet, or 35 cubic feet of friable ACM or ACM that will become friable during burning) then all asbestos materials, both friable and nonfriable, must be removed before burning.

    If you want to burn a building, you must first notify your State or EPA Asbestos NESHAP coordinator. See the Hazardous Materials Requirements for Building Demolition web site (available only to Forest Service and BLM employees) for detailed information on who to notify and how to do so.

    The Excess Facilities section of the Facilities Toolbox contains more information on disposing of unneeded structures.

  • Mobile homes are considered real property when they're on a foundation or on piers and have a skirt. If you want to demolish or burn a mobile home at the location where it was used as housing or office space, see the sections of this toolbox that apply to permanent buildings.

    Once mobile homes become mobile, they’re considered personal property and a new set of regulations apply. If you want to dispose of a mobile home off site, you are governed by the Federal Property Management Regulations (41 CFR 101-42.1102-1 ).

    These rules specifically state that personal property containing friable asbestos normally cannot be transferred, donated, or sold. An inspection is required to determine if and what type of ACM is present in the mobile home before disposal can proceed. If friable asbestos is present, it must be removed unless General Services Administration first gives approval to do otherwise. Contact your property officer for assistance with disposal.

    The Excess Facilities section of the Facilities Toolbox contains more information on excessing unneeded structures and land.

  • Vermiculite is a mineral ore that has been expanded to produce the familiar light granules that are sometimes used as loose fill insulation. Only a few vermiculite ores contain asbestos. However, between 1960 and 1990, 70 percent of the world’s vermiculite ore came from a mine in Libby, MT, and was marketed as Zonolite. That particular ore is contaminated with tremolite, one of the six asbestos mineral forms. Consequently, if you have vermiculite insulation in any of your buildings, it is likely to be an asbestos-containing material (ACM). Vermiculite is a common attic and wall insulation that should be sampled during an asbestos inspection. If your vermiculite contains asbestos, a management plan must be developed. The plan must take into account the location of the vermiculite and the potential for human exposure. Asbestos-contaminated vermiculite is regulated as a friable form of ACM.

    You can find out more about vermiculite by going to EPA's Web site for vermiculite. It’s possible that the EPA will recommend new sampling and analytical methods specific to vermiculite in the future, because tremolite appears to be a particularly dangerous form of asbestos.

    You can find out more about the asbestos in the vermiculite produced from the ore in the mine at Libby, MT at the University of Montana's Libby Asbestos Web site.

  • Preservative-treated wood deck.

    Since the 1940s, Forest Service designers and maintenance staff have depended on pressure treated lumber impregnated with chromated copper arsenate (CCA) preservative. It has been used wherever wood structures come in contact with soil or concrete and in other locations where decay resistance is important. CCA is an extremely effective and durable treatment against both decay and insect damage, and is also relatively inexpensive. However, since January 2004, CCA has only been available for certain industrial and commercial uses. It is no longer available at local lumberyards for use in residential applications.

    New strategies must be developed to replace the formerly automatic purchase of "green treated" lumber. It does not appear that any one product will serve as an effective substitute for CCA-treated lumber in all applications. However, there are several newer, less toxic preservative treatments for lumber available. Ammoniacal copper quaternary (ACQ) and copper azole seem to be emerging as the primary CCA replacements for exterior and ground contact use. Borate treatments are becoming more common for interior uses such as sill plates. Naturally decay-resistant native or tropical woods may be appropriate for some applications. In addition, some "plastic" and composite lumber may be an effective substitute material for some uses. Under some circumstances, it may make sense to use materials such as steel or concrete rather than wood.

    This section is under construction. Please check back later for more information. Meanwhile, check out the following web links that provide more information.

    Preservative—Treated Wood and titleernative Products in the Forest Service (Optional link for FSweb users) contains the most up-to-date information about the types and uses of preservative-treated wood.

    titleernatives for Dimension Lumber is a paper from Stan Lebow at the Forest Products Lab. It explains the CCA restrictions, titleernative preservative treatment options, and common quality assurance issues with preservative treated wood.

    What Lumber Is Affected? is a note from Stan Lebow at the Forest Products Lab to some structural engineers within the Forest Service explaining what categories of lumber have been affected by the restrictions on CCA and the basic reasoning behind the restrictions. It also contains links to some publications about using treated wood on bridges and boardwalks. He has agreed to allow us to post this information here for internal Forest Service use.

    Properties of Imported Tropical Woods by B. Brancis Kukachka of the Forest Products Lab includes information on which tropical woods are decay and insect resistant.

    Simpson Strong Tie Pressure Treated Wood FAQs includes a good discussion about corrosion of fasteners used on preservative treated lumber.

    Recycled Plastic Lumber, provides an overview of the various types of plastic lumber from the state of California. The site acknowledges the lack of uniform structural standards and minimal structural information about plastic lumber.

    Trimax and TREX are plastic composite lumber manufacturers that have posted span and load tables for their products on the web. These tables DO NOT apply to other manufacturer's products.

    Wood Casework manufacturers are beginning to use pressure treatment systems as an titleernative to the previously standard penta dip treatment. Jeld-Wen is using a vacuum/pressure treat of tebuconazole and imidacloprid to resist decay and insects.

  • Even small buildings such as the Taylor Creek Visitor Center at Lake Tahoe contain hazardous materials that must be managed properly.

    Forest: Lolo
    District: Lake Tahoe Basin MU
    Region: 4, 5

    Many materials and products used in buildings contain hazardous substances. These are not necessarily "bad" products—they may help keep us warm, provide energy efficient lighting, or keep our food safe to eat. Most of these materials are not hazardous when used as intended, but may release hazardous substances if they are broken or they may become hazardous waste if they are disposed of improperly. Some materials require special precautions during construction and repairs.

    When constructing a new building or renovating an existing one, it's smart to choose the least toxic components that will do the job effectively. But you still need to deal with the materials that are in your existing buildings. The following information will help you deal effectively with some hazardous materials commonly found in buildings.

    Can I still use oil-based paint or stain on our buildings?

    What should I do with used fluorescent and HID lamps?

    Are thermostats dangerous?

    What do I need to know about "silent switches," heavy duty switches, and relays?

    Is there a problem with dumping old lighting ballasts in the trash?

    What should I do with dead batteries?

    Are lead roofing and flashings a problem?

    Should lead and copper plumbing be replaced?

    Are fluorocarbons still an issue in refrigerators, freezers, and air conditioners?

    Is there a problem with hydraulic fluid?

    Will smoke detectors cause radiation poisoning?

    Are exit signs radioactive?

    How should we dispose of janitorial products that contain hazardous chemicals?

  • Recycle them!

    All commonly available fluorescent tubes and high-intensity discharge (HID) lamps contain mercury. The most common HID lamps are mercury vapor, metal halide, and high-pressure sodium lamps.

    Older fluorescent lamps may contain nearly 50 milligrams of mercury per 4-foot-long fluorescent lamp. Lamps manufactured after 1994 contain less mercury—an average of a little less than 23 milligrams of mercury per 4-foot-long lamp.

    In recent years, GE, Phillips, and Osram Sylvania have begun producing some fluorescent lamps that contain only a little mercury—3 to 10 milligrams per 4-foot-long lamp. These low-mercury tubes pass the U.S. Environmental Protection Agency's (EPA) Toxicity Characteristic Leaching Procedure (TCLP) test, and usually may be disposed of the same as ordinary trash (titlehough it is better to recycle them). GE and Sylvania low-mercury lamps use an additive that keeps the small amount of mercury in the lamps from leaching into the environment after the bulbs are crushed in a landfill. Phillips "titleO" fluorescent lamps contain even less mercury, so they don't need additives to pass the leaching test. Phillips "titleO" lamps have bright green end caps. Osram Sylvania “Ecologic” and GE “Ecolux” use green lettering on the lamps for identification. If you have a choice, you should purchase low-mercury fluorescent lamps.

    Discarded regular fluorescent and HID bulbs are "Universal Wastes". Regulations for disposal vary by state, and some states require special disposal no matter how few bulbs you dispose. Check out http://www.LampRecycle.org for information about State regulations and lamp recycling in all 50 states. The Association of Lighting and Mercury Recyclers provides practical recycling information for users of fluorescent or HID lamps. Lamp recycling businesses supply shipping containers that can be used to store bulbs for up to a year while you accumulate a full container. Because the value of recovered products from lamp recycling is relatively low, you may have to pay to recycle used lamps, titlehough many localities have free recycling drop-off sites.

    Refer to the "Everyday Hazmat User's Training Guide" for more information about mercury lamp disposal and universal waste.

    Hetitleh Issues: Mercury is a potent neurotoxin that can damage the brain and nervous system at very low levels. Mercury contamination is most likely to occur by eating contaminated fish or other animals, or by breathing evaporated or incinerated mercury released during waste processing. The effects on children can be particularly serious.

  • Many thermostats use mercury switches, but as long as a thermostat is intact, it isn't dangerous.

    Electronic and magnetic snap switch thermostats don't contain any mercury. To identify whether a thermostat contains mercury, remove the front plate. If one or more small glass bulbs are inside, they contain mercury. These bulbs are called tilt switches. Each tilt switch contains roughly 3 to 6 grams of mercury. Thermostats may have up to six tilt switches.

    Most thermostats last at least 20 years before they wear out. When they must be replaced, discarded mercury switch thermostats become "universal waste". Requirements for disposal vary from State to State, but most States require or encourage recycling of mercury thermostats by businesses and individuals, no matter how few are disposed. An industry program allows heating, ventilation, and air conditioning contractors to recycle mercury switches at no cost through participating wholesalers and the Thermostat Recycling Corporation. If you want to replace a thermostat yourself, you may be able to take the old thermostat to a participating wholesaler. You also may be able to take the thermostat to a household hazardous waste collection event or drop-off location sponsored by your county, city, or waste disposal district or company.

    Refer to the "Everyday Hazmat User's Guide" for for more information about mercury the rmostat disposal and universal waste.

    When you replace a thermostat, consider installing one with electronic programmable switching. Electronic programmable switches eliminate any chance that mercury could be released if the thermostat is damaged and eliminate future mercury disposal problems. They also save heating and cooling costs if they are set to reduce heating and cooling automatically when the building isn't in use or doesn't need heating or cooling.

    Hetitleh Issues: Mercury is a potent neurotoxin that can damage the brain and nervous system at very low levels. Mercury contamination is most likely to occur by eating contaminated fish or other animals, or by breathing evaporated or incinerated mercury released during waste processing. The effects on children can be particularly serious.

  • "Silent switches" for lights and some other heavy-duty switches and relays use mercury as an electrically conductive switching mechanism.

    Wall switches in older buildings that don't make a "click" sound when activated are probably mercury tilt switches. Each tilt switch has about 3 grams of mercury in a little sealed "button" that is very difficult to break. This type of switch is quiet and durable. Manufacturing was discontinued in the late 1980s because of concern over the hetitleh effects of mercury.

    Mercury tilt switches also may be found in appliances that have interior lights activated by opening a lid. If you can't see a mechanical on/off connection, there may be an embedded mercury switch.

    Float switches used in water tanks, sump pumps, and sewage lift stations may also contain mercury. Typically, either the float itself contains a mercury tilt switch or the float arm is attached to a control box that contains a mercury tilt switch. The movement of the arm turns the switch on or off.

    Another type of mercury switch is the displacement or plunger relay. The "wetted reed relay" or "wetted reed switch" is found in circuit controls for low-voltage electronic devices. Older, more specialized equipment is more likely to contain mercury switches. Plunger or displacement relays also are used in high-current lighting and commercial and industrial cooling and heating equipment. These switches can contain up to160 grams of mercury. Normally, a HVAC contractor or licensed electrician should be employed to work on this kind of equipment, and the contractor should be required to dispose of the switches properly.

    Discarded mercury switches are "universal waste". Requirements for disposal vary from State to State, but most States require or encourage recycling of mercury switches by businesses and individuals, no matter how few are disposed. You may be able to take the switch to a household hazardous waste collection event or drop-off location sponsored by your county, city, waste disposal district or company, or hetitleh department.

    Refer to the "Everyday Hazmat User's Guide" for for more information about mercury the rmostat disposal and universal waste.

    Hetitleh Issues: Mercury is a potent neurotoxin that can damage the brain and nervous system at very low levels. Mercury contamination is most likely to occur by eating contaminated fish or other animals, or by breathing evaporated or incinerated mercury released during waste processing. The effects on children can be particularly serious.

  • There may be.

    Lighting ballasts generate an initial high voltage to start the arc that excites the gases in fluorescent and HID lamps and makes them shine. They're usually rectangular black boxes with wires coming out of one or both ends.

    Lighting ballasts for fluorescent light bulbs and HID lamps made before 1980 may contain polychlorinated biphenyls (PCBs). When the manufacture of PCBs was banned, existing equipment containing PCBs was allowed to remain in use. Because ballasts can last for 30 years or more, there are still some PCB-containing ballasts in older buildings. Fortunately, you can easily tell whether a ballast contains PCBs. Ballasts that don't contain PCBs have the words "No PCBs" printed on them. "No PCBs" ballasts can be disposed with normal trash in most states. Ballasts that have PCBs are regulated by the U.S. Environmental Protection Agency (EPA) under the Toxic Substance Control Act (TSCA). They aren't hazardous when used as intended, as long as they don't leak.

    You may be able to dispose of a few intact ballasts containing PCBs the same as ordinary trash or at a household hazardous waste collection event or drop-off location sponsored by your county, city, or waste disposal district or company. Many states have developed regulations governing the disposal of intact ballasts containing PCBs that are more stringent than Federal regulations. If you have a lot of ballasts (the number varies by State) or if you have leaking ballasts, special disposal is required through EPA-approved disposal methods. Arrangements may be made with companies that provide EPA-approved PCB storage for shipment of ballasts containing PCBs to an EPA-approved chemical waste processing site. Because requirements vary by State, check with your regional environmental engineer (Web site available only to FS and BLM employees) before making disposal decisions.

    Hetitleh Issues: PCBs can enter the environment through both use and disposal. PCBs stay in the body, so effects can get continually worse every time a person is exposed to PCBs. Severe concentrated exposure to PCBs can result in skin lesions, liver damage, or other problems. Lower level exposures are more common, and typically occur through eating contaminated fish, milk, or other foods. Over time, lower exposures may result in thyroid, immune system, and reproductive system problems and cancer. Infants born to mothers that have consumed PCBs may have problems with motor skills, hearing, and brain function.

  • Batteries come in several different types. Proper disposal depends on the type of battery you have.

    Ordinary Batteries: Regular alkaline, manganese, and carbon-zinc batteries are not considered hazardous waste and can be disposed of with ordinary trash.

    Other common single use or rechargeable batteries such as lithium and button batteries are recyclable, but access to recycling may not be available in all locations. You may be able to take these batteries to a household hazardous waste collection event or drop-off location sponsored by your county, city, waste disposal district/company, or hetitleh department.

    "Universal Waste" Batteries: Nickel-cadmium (Ni-Cd) and small sealed lead-acid (SSLA) rechargeable batteries are considered "universal waste". These batteries are commonly encountered in emergency lighting, exit signs, security systems, and alarms. They are expensive to purchase, but are rechargeable. Overall they may save the use of hundreds of disposable batteries over their lifetimes, providing good life-cycle cost effectiveness. All "universal waste" batteries produced since 1997 must include the following wording on their labels: "BATTERY MUST BE RECYCLED" or "BATTERY MUST BE RECYCLED OR DISPOSED OF PROPERLY". You can search for local rechargeable battery recycling facilities by zip code at Earth 911. Refer to the "Everyday Hazmat User's Guide" for more information about Ni-Cd and SSLA battery disposal and universal waste.

    Rechargeable Ni-Cd and SSLA batteries contain lead and/or cadmium, which can leak, be vaporized and carried on the wind, or leach from incinerator waste if they are disposed of improperly. During recycling, the heavy metals are removed from the batteries so the metals don't escape into the environment.

    Hetitleh Issues: Lead and cadmium are toxic heavy metals that can cause severe hetitleh effects depending on the total concentration a person is exposed to over time. The effects of cadmium depend on whether it was ingested or inhaled.

    Lead affects every organ in the body, especially the central nervous system. Cadmium affects the digestive and excretory systems and lungs. Both can cause cancer. The effects of lead and cadmium exposure on fetuses and young children include delays in physical and mental development, lower IQ levels, shortened attention spans, and increased behavioral problems.

  • Lead roofing and flashings are much more likely to be a hetitleh hazard for people working with the materials than for people using the building.

    Lead has been used for roofing for centuries and is one of the oldest flashing materials. It is durable and soft enough to be formed into complex shapes. Lead roofing and flashings can last over 200 years. Generally speaking, lead roofing or flashing that is in good shape may safely be left in place.

    Lead can be used safely if worker exposure is monitored and lead is handled properly to avoid skin contact, ingestion, and exposure to lead dust and fumes. If you need to remove lead roofing or flashing materials, follow OSHA requirements for protection and monitoring for workers. OSHA's Lead in Construction Advisor is a free, interactive web site that helps users understand OSHA's Lead in Construction Standard. About half of the States have their own OSHA-approved requirements.

    Lead is a toxic hazardous waste that must be managed and disposed of in accordance with Resource Conservation and Recovery Act (RCRA) subtitle C requirements, including land disposal restrictions. This means that you must handle and remove lead materials using proper personal protective equipment or have a properly equipped contractor do so. Lead waste must be recycled or disposed of at a hazardous waste disposal site. Different States have different hazardous waste disposal and recycling requirements..

    Check with local scrap metal recyclers to see whether they accept lead sheets such as roofing and flashing. If the phone book doesn't list scrap metal recyclers, try the member directory of the Institute of Scrap Recycling Industries, Inc. You may also be able to take the lead to a household hazardous waste collection event or drop-off location sponsored by your county, city, waste disposal district or company, or hetitleh department.

    Hetitleh Issues: At high levels, lead can cause convulsions, coma, and even death. Lead exposure affects every organ in the body, especially the central nervous system. The effects of lead exposure on fetuses and young children include delays in physical and mental development, lower IQ levels, shortened attention spans, and increased behavioral problems.

    (Photo courtesy of C. John Hebert Custom Woodworking http://www.cjohnhebert.com/index.htm)

  • Yes, they are.

    Most refrigerants found in air conditioners, refrigerators, and freezers contain fluorocarbons, and many fluorocarbon compounds contain chlorine. Chlorofluorocarbon (CFC) refrigerants were commonly used in equipment manufactured before 1995. Equipment manufactured before 2010 may use hydrochlorofluorocarbon (HCFC) refrigerant. Some newer equipment uses hydrofluorocarbon (HFC) refrigerants, which contain no chlorine.

    The Clean Air Act outlines specific refrigerant containment and management practices. Basically, all CFC and HCFC refrigerants must be recovered, recycled, and reclaimed during servicing and repairs. This means relying on an EPA-certified ("section 608 certification") service technician to repair refrigeration systems, because they have equipment to assure that refrigerants are handled as required. Don't do it yourself, and don't haul old equipment to the dump without having the refrigerant recovered first.

    The atmospherically benign HFC refrigerants will remain in production, but CFC and HCFC refrigerants will be phased out. Production of CFCs ceased in 1995. HCFC production will cease in 2020 (HCFC-22) or 2030 (HCFC-123). This means that titlehough equipment that uses these refrigerants may operate just fine for 20 or 30 years, new or recycled refrigerant to service it may not be available. Don't buy equipment that uses CFC refrigerants. Consider product life and future availability of refrigerant when considering purchasing equipment that uses HCFC refrigerants. If possible, avoid purchasing equipment that uses HCFCs.

    Tree coolers are generally the biggest refrigeration systems in the Forest Service. Because they are so expensive, it may be more economical to convert them to another refrigerant than to replace the refrigeration system.

    Hetitleh Issues: CFCs and HCFCs are lighter than air, so they rise into the stratosphere, where ultraviolet light frees the chlorine. A single chlorine atom can destroy thousands of ozone molecules, thinning the Earth’s protective ozone layer. The ozone layer is important because it moderates the radiation the earth receives from the sun. A thinner ozone layer means more skin cancers and cataracts. Marine and terrestrial plants may be harmed as well.

  • There may be, but it's not likely.

    Hydraulic fluid containing polychlorinated biphenyls (PCB) was mostly used in high-temperature applications such as die-casting machines. There's a small possibility that hydraulic fluids for elevators or automotive lifts may be contaminated by PCBs, if the fluids haven't been completely flushed and replaced since about 1984, and there's no manufacturer-applied label that states that the fluids are PCB-free.

    Monsanto's Pydraul brand accounted for nearly all hydraulic fluids with PCBs in the United States, but they also produced fluids that didn't contain PCBs that had the Pydraul label. If you have a hydraulic system containing pre-1984 fluids of this brand, you should probably check for PCBs. Fluid tests costing about $50 are available through many testing labs.

    If hydraulic fluid has more than 0.5% non-dissolved PCB material or more than 50 parts per million total concentration of PCBs, it is considered a hazardous material regulated by the U.S. Environmental Protection Agency (EPA) under the Toxic Substance Control Act (TSCA) and Resource Conservation and Recovery Act (RCRA). PCB wastes must be disposed of in a TSCA-compliant incinerator, TSCA/RCRA-compliant chemical waste landfill, or by an EPA-approved titleernative method. Arrangements may be made with companies that provide EPA-approved PCB storage for shipment of fluid containing PCBs to an EPA-approved chemical waste processing site.

    The TSCA allows machines that used hydraulic fluids with PCBs to be disposed of in a municipal solid waste landfill if they have been drained of all free-flowing liquids. Hydraulic machines that contained PCBs at a concentration greater than 1,000 parts per million must be flushed with a solvent before disposal. The drained liquid and solvents must be disposed of like other PCB wastes.

    Hetitleh Issues: PCBs can enter the environment through use and disposal. PCBs stay in the body, so effects can get continually worse every time a person is exposed to PCBs. Severe concentrated exposure to PCBs can result in skin lesions, liver damage, or other problems. Lower level exposures are more common, and typically occur through eating contaminated fish, milk, or other foods. Over time, lower exposures may result in thyroid, immune system, and reproductive system problems and cancer. Infants born to mothers that have consumed PCBs may have problems with motor skills, hearing, and brain function.

  • No. Fires kill people but smoke detectors don't even irradiate them.

    Ionization chamber and photoelectric smoke detectors are the two most common types. Both work very well and are safe to use.

    There are no hetitleh concerns with photoelectric smoke detectors because no radiation is involved. Photoelectric smoke detectors sound an alarm when smoke particles scatter a beam of light in the detection chamber. They respond quickly to fires with lots of smoke.

    Ionization chamber smoke detectors contain a small amount of americium-241, a radioactive material. Smoke particles disrupt the low, steady electrical current produced by radioactive particles and trigger the detector's alarm. They react quickly to fires that give off little smoke. Ionization smoke detectors expose people to a tiny amount of radiation—about 1/100 of a millirem per year. This is well below the background radiation level of about 360 millirems a year. If a smoke detector contains radioactive materials, a printed notice on the packaging will say so.

    Because of the long half-life of americium-241, the amount of radioactive material in an ionization chamber smoke detector at the end of its useful life will be about the same as when it was purchased. State and local requirements for disposal of ionization smoke alarms vary. Some States conduct an annual roundup of ionization smoke detectors similar to that for hazardous household chemicals. Others allow ionization smoke detectors to be thrown out with ordinary trash but recommend that used smoke alarms be returned to the supplier. Some States require that used smoke detectors be returned to the supplier. Check with your local solid waste district, hazardous waste program, or hetitleh department to find out the procedures in your area. All manufacturers of ionization smoke detectors must accept returns—when in doubt, return the detector. Return addresses are listed in the product warranty or use instructions.

    Smoke detector batteries should be disposed of as explained in What should I do with dead batteries?

    Hetitleh Issues: Radiation can cause cancer and other problems, including defects in unborn children. Radiation produced during normal use of ionization smoke detectors is so low it has no noticeable effect. If the ceramic chamber containing the radioactive material is removed and swallowed, exposure is about six times the desirable yearly exposure—still too low to cause acute hetitleh effects.

  • The best way to dispose of janitorial and maintenance products that contain hazardous chemicals is to use all of the product for the purpose for which it was purchased. Don't buy more of these materials than you can use in a reasonable length of time. Even better, purchase the least toxic products that will do the job, so that you will have fewer disposal problems and minimize the chance of employee exposure to harmful chemicals.

    If you have a product you can't use that contains hazardous chemicals, proper disposal is essential.

    Disposal requirements vary depending on the product's composition and the amount of product. Discarded janitorial and maintenance products such as aerosol cans, cleaners, pesticides and herbicides, paint thinner, oil based paints/stains/varnishes, anti-freeze, fertilizer, and solvents are hazardous wastes. These wastes are regulated under the Resource Conservation and Recovery Act. If you're not sure whether a waste product is hazardous, check the listed and characteristic wastes on the U.S. Environmental Protection Agency's (EPA) Hazardous Waste Web site.

    Dried latex paint in household quantities is not a hazardous waste. If you have a couple of gallons of latex paint you absolutely can't use, take the lid off, let it completely solidify, and dispose of it with ordinary trash.

    Most Forest Service units are very small quantity generators (formerly called "conditionally exempt small quantity generators") that

    • produce no more than 220 pounds (about 25 gallons) of hazardous waste and no more than 2.2 pounds (less than a quart) of acutely hazardous waste in any calendar month

    • never accumulate more than 2200 pounds of hazardous waste and/or 2.2 pounds of acutely hazardous waste onsite at one time.

    There are specific requirements for record keeping, transportation, and disposal of hazardous wastes. An EPA identification number may be needed by some conditionally exempt small quantity generators because of state or transporter requirements.

    More information about very small quantity generators is available online from Environmental Hetitleh & Safety Online. The “Everyday Hazmat User's Training Guide” explains the requirements for using, storing, transporting, and disposing of hazardous janitorial products. The Missoula Technology & Development Center's Everyday Hazmat(Optional link for FSweb users) Web site is also a good source of information about managing your hazardous materials effectively

  • If your facilities master plan shows that disposal is the best option for a structure and you have completed the facility disposal documentation, you can demolish or burn a building with lead based paint, but there are some things you have to do first.

    States have varying regulations on whether buildings painted with lead-based paint can be burned. See the Hazardous Materials Requirements for Building Demolition web site (available only to Forest Service and BLM employees) for detailed information whether burning is allowed in your state, what permits are necessary, and working with fire departments to accomplish the burn

    Remember that the Hetitleh and Safety Code Handbook (FSH 6709.11 section 35) does not allow Forest Service personnel to demolish structures by burning them. Forest Service fire crews are not trained or qualified to deal with structure fires. In some cases, a structure can be burned by a local fire department as a training exercise. A formal agreement between the Forest Service and the fire department must be signed before the training exercise can be conducted. The grants and agreements staff can help negotiate the agreement. If Forest Service employees are also members of local fire departments, they may participate in the training exercise.

    Demolished lead-based painted materials destined for the landfill will first need to be tested for toxicity. It is possible that the lead-based painted materials may be considered a hazardous waste under the (RCRA) subtitle C requirements, including land disposal restrictions. If so, it must be disposed of at a hazardous waste disposal site. Some states allow disposal of debris from whole structure demolitions in municipal or construction/demolition landfill units even if it contains lead based paint. Contact your regional environmental engineer (Web site available only to FS and BLM employees) about disposal regulations in your state and testing for lead content using the Toxicity Characteristic Leaching Procedure.

  • BLM: Close Encounters

    BLM: Hazmat 101 (Web site available only to FS and BLM employees)

    BLM: If You Can Smell It, You've Been Exposed (Web site available only to FS and BLM employees)

    US Forest Service: Introduction To Hazardous Materials For Field Personnel

    AgLearn

    The Skillsoft learning program within AgLearn includes the following courses dealing with hazardous materials and hazardous wastes.  Most courses take about an hour.

    DOT Hazardous Materials
    Emergency Response and Spill Control
    Hazard Communication
    Hazardous Materials Management
    Hazardous Waste Generator
    Mold Awareness
    Regulatory Overview (Hazwoper)
    Spill Prevention and Control
    Spill Prevention and Countermeasure Plan
    Universal Waste Rule
    Used Oil Management

    Department of Transportation: Hazardous Materials Transportation Training

    Federal Facilities Environmental Stewardship & Compliance Assistance Center:
    Environmental Compliance Training

    Environmental Protection Agency: Trainex
  • Some exit signs contain tritium, the radioactive form of hydrogen. If your exit sign emits a dim glow from glass tubes, but it doesn't have any electric connections or batteries, it contains tritium. The light is produced by a chemical that glows when exposed to radiation from the tritium gas in the tubes. Electric (wired or battery powered) and photoluminescent exit signs (usually flat plastic signs about 1/8” thick) do not contain radioactive materials.


    The narrow tubes that contain tritium gas
    are just barely visible in this photo.

    Tritium exit signs are required to have a label that includes the words "Caution Radioactive Materials" or shows the radiation trefoil symbol. The label is usually on the bottom, but may be on the side, back, or inside.


    The radiation trefoil symbol

    Tritium exit signs are regulated by the Nuclear Regulatory Commission. Do not dispose of tritium exit signs in the trash. You must return the sign to the licensed manufacturer or distributor or transfer it to a licensed radioactive waste broker or a licensed low-level radioactive waste disposal facility. This will cost about $75 for each sign. There are big fines for improperly disposing of tritium.

    Tritium exit signs are safe as long as they are not broken or leaking. If a tube in a tritium exit sign is damaged, don't touch it. Get everybody out of the area, open the windows and outside doors, and call your state's radiation control program and the manufacturer for technical and clean-up information. Clean-up can be very expensive.

    The US EPA has developed a free on-line training course (http://www.trainex.org/web_courses/tritium/index.htm) that explains how to handle and dispose of tritium exit signs. The course contains easy-to-follow, step-by-step guidelines.

    Hetitleh Issues: Tritium exit signs are safe as long as they aren't broken, because the low-energy beta particles emitted by tritium can't penetrate the outer layer of human skin and the tritium itself is sealed in a glass tube.

    If the tubes in the exit signs are broken, the tritium gas will escape. Release of the gas from a tritium exit sign will not result in acute radiation poisoning, but it might exceed the EPA annual recommended dose level and cause a small increased risk of cancer. Tritium exposure has been linked to reproductive problems, genetic abnormalities, development problems, and other hetitleh problems. Breathing tritium gas is not as hazardous as swallowing tritiated water or absorbing tritiated water through the skin.

  • Lead and copper that leaches into drinking water from pipes and fittings in high amounts can affect people's hetitleh, especially that of young children. The surest way to find out if this is occurring is to test the drinking water in the building. In 1991, the National Primary Drinking Water Regulations for Lead and Copper established an action level of 0.015 micrograms per liter for lead in drinking water and 1.3 micrograms per liter for copper in drinking water. Copper seldom exceeds the action level.

    The certified water system operator for your unit should know how to perform the sampling and where to send the samples for testing. Forest Service community and non-transient, non-community drinking water systems have already been tested for lead and copper, and are retested every 3-9 years, depending on previous results. Tests are conducted at a selected sample of buildings representing residences and other locations where people routinely consume water.

    If the tests show that the action levels are exceeded, either the leaching must be stopped or the plumbing must be replaced. Leaching may not occur if the inside surfaces of pipes and fittings have become coated with lime or other mineral deposits or if the water is non-corrosive. It is not necessary to remove lead or copper pipes that are not leaching metal into the drinking water. Removing lead plumbing must be done in accordance with OSHA requirements.

    The Safe Drinking Water Act of 1986 banned the use of lead in the installation and repair of drinking water plumbing. Under the law, "lead free" means that solder and flux may not contain more than 0.2 percent lead, and pipes, pipe fittings, and well pumps may not contain more than 8.0 percent lead.

    When installing new plumbing products, use products that meet the NSF standard for lead. These products carry a certification mark. NSF International and Underwriters Laboratories publish lists of products that meet the NSF Standard. The lists are available on their Web sites.

    Hetitleh Issues: Lead exposure affects every organ in the body, especially the central nervous system. The effects of lead in drinking water are most critical for fetuses and young children and include delays in physical and mental development, lower IQ levels, shortened attention spans, and increased behavioral problems.

    A little copper is necessary for human hetitleh. High levels of copper can cause vomiting, diarrhea, and stomach cramps. High levels of copper in drinking water can cause kidney and liver damage in infants and people with liver disease or Wilson's disease.

  • The only way to tell whether an old building has lead-based paint is to test the paint. If you don't test the paint, you must assume all buildings constructed before 1978 contain lead-based paint, and follow all precautions and requirements for dealing with lead-based paint.

    A number of products are available for testing lead-based paint, but not all work equally well. Some commercial lead test kits are recognized by the U.S. Environmental Protection Agency (EPA) as effective in determining that lead is not present in the paint on certain materials. To find out about effective lead-based paint test kits, visit the EPA Recognition of Lead Test Kits Web page.

    The most reliable way to determine the presence or absence of lead-based paint is to hire a trained and certified testing professional to use either a portable X-ray fluorescence machine or to perform lab tests of paint samples. State and Federal programs ensure that testing by certified professionals is done safely, reliably, and effectively. Contact your regional environmental engineer (link available only to Forest Service employees) or visit the EPA's searchable database of certified lead testing and abatement professionals to locate certified firms in your area. 

    The Forest Service Handbook 7309.11, Buildings and Related Facilities chapter 41.15.4 requires that each building or location with lead-based paint have a management plan for lead-based paint. Before testing for lead-based paint, check to see whether the lead-based paint management plan for the building includes previous test results. If it does, you can use those results rather than paying for new tests.

    If you are testing in preparation for a project that disturbs paint on housing built before 1978 or child-occupied facilities, please see EPA's Lead Renovation, Repair and Painting Program Rule. For the testing to "count", it must be done by someone who is certified to perform the testing.

  • Lead-based paint notification requirements differ depending on the use of the building.

    We have to tell people who occupy Forest Service-owned target housing for more than 100 days about any known lead-based paint in those buildings. The Forest Service Handbook 7309.11, Buildings and Related Facilities, chapter 41.15 refers to governing Federal regulations that require the Forest Service to tell renters and permittees about lead-based paint, and provide them with a copy of the pamphlet "Protect Your Family From Lead in Your Home". You can order copies of the pamphlet from the EPA.

    The brains and nervous systems of children under the age of 6 are more sensitive to the damaging effects of lead than those of adults and children's bodies absorb proportionally more lead. Babies and small children sometimes pick at or chew on objects and to put their hands and other objects in their mouths, which makes them more likely to ingest lead. Also, renters sometimes decide to repaint, hang pictures, or do other work that might disturb lead-based paint and create lead dust. If occupants know that lead-based paint is present, they can take precautions to protect themselves and their children.

    The requirements for notifying renters about other possible hetitleh hazards in Forest Service buildings are explained in the Facilities Toolbox section on Quarters Tools, under What information do we have to provide renters?.

    The EPA's Lead Renovation, Repair and Painting Program Rule requires that we also notify occupants of target housing and child-occupied facilities with lead-based paint before beginning renovation activities, as explained in Can I sand and repaint the woodwork in a building with lead-based paint?.

    We are not required to notify most people who work in Forest Service buildings about lead-based paint. Well-maintained, undisturbed lead-based paint is not hazardous and employees don't normally disturb or ingest the paint in their offices. However, all maintenance people should know which buildings contain lead-based paint, so they can take proper precautions when doing maintenance work that might disturb the paint. See Can I sand and repaint the woodwork in a building with lead-based paint? for more information on precautions to take when working on buildings with lead-based paint.

    To help parents protect their children from exposure to lead-based paint, notification about any known lead-based paint can be provided to employees who bring their children to work in office buildings owned or leased by the Forest Service and to operators of childcare facilities in Forest Service buildings.                 

  • Maintenance work that affects surfaces covered with lead-based paint differs from lead-based paint abatement. Abatement permanently eliminates lead-based paint hazards by removing or permanently encapsulating the lead-based paint. Maintenance keeps a building in good operating condition or returns it to good operating condition. The requirements for worker certification for abatement differ from those for maintenance. Requirements for abatement work are explained in Who can work on lead-based paint abatement projects?.

    Renovations that disturb lead-based paint in target housing and child-occupied facilities must be conducted by certified renovation firms, using renovators who have received accredited training and follow the work practice requirements of the Lead Renovation, Repair and Painting Program Rule (Lead RRP). The Hazardous Materials Requirements for Building Demolition web page (available only to Forest Service and BLM employees) contains information on finding certified firms in your state.

    The rule applies to work at target housing and child-occupied  facilities disturbing more than 6 square feet of lead-based paint surface per room inside a building or more than 20 square feet of lead-based paint surface on the outside of a building. The rule also applies to window repairs, window replacements, and demolition of lead-based paint surfaces, regardless of project size. The rule does not apply to painting projects that don't include preparation activities that cause dust, such as sanding or scraping.

    The Forest Service has obtained agency-wide certification as a "Lead-Safe renovation firm" for non-primacy States. However, nearly half of the States have primacy for Lead RRP. In those States, separate State certification is required in order for the Forest Service to be a certified renovation firm. Check with your regional environmental engineer (link available only to Forest Service employees) or the EPA Authorized State Programs Web site to learn the primacy status for your State. 

    You may perform lead-based paint-disturbing work in target housing or child-occupied facilities ONLY if:

    • The Forest Service is a certified Lead-Safe renovation firm in your State

    • You have received accredited training or are working directly with someone who has received the training and is a certified renovator

    • You follow the work practice requirements in the Lead RRP rule.

    Your regional environmental engineer can provide information on training and let you know who has been trained in your Region. Information about training is also available on the EPA's  Web site for locating accredited lead renovation training. Expect to pay $200 to $250 for this training.

    Before beginning work on target housing or child-occupied facilities with lead-based paint, you must provide a copy of the EPA's "Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools" pamphlet to the residents, or the people who operate the child care facility and the parents or guardians of children under 6 years old who stay at the child care facility. These people must sign a pre-renovation disclosure form that says they received the pamphlet.

    After the renovation work is completed, the following records must be kept for 3 years in the official Forest Service files for the building:

    • A copy of the "Renovate Right" pamphlet and the signed pre-renovation disclosure forms
    • Results of the original lead inspection (chemical tests and/or a copy of the official inspection form showing the results)
    • A copy of the renovation firm's certification
    • A copy of the certification of the renovator who does or is in charge of the work
    • Names and certification of training of other workers
    • Certification of work practices and cleaning verification by the certified renovator

    Even though maintenance work on lead-based paint surfaces in offices that are not child occupied facilities is not governed by the Lead RRP, such work should not be treated casually. The Occupational Safety and Hetitleh Administration's (OSHA) Lead in Construction Standards apply to maintenance of lead-based painted surfaces. These standards limit lead exposure and require the use of specific personal protective equipment, monitoring, ventilation, and other measures. apply to maintenance of lead-based painted surfaces. The National Institute for Occupational Safety and Hetitleh Lead Web page is a good source of information about the OSHA Lead in Construction Standards.

    titlehough the Lead RRP rule currently applies only to target housing and child-occupied facilities, the EPA may extend requirements to public and commercial buildings constructed before 1978.

  • Neither Forest Service direction, national laws, nor regulations require lead-based paint  to be removed from all Forest Service buildings. The Forest Service is required to notify people   of the presence of lead-based paint in some buildings. Check with your regional environmental engineer (link available only to Forest Service employees) to find out whether any State requirements or Regional guidance requires removal of lead-based paint on your unit.

    Lead-based paint abatement is different from maintenance of surfaces with lead based paint. Abatement permanently eliminates lead-based paint hazards by removing or permanently encapsulating the lead-based paint. Maintenance keeps a building in good operating condition or returns it to good operating condition. The requirements for worker certification for abatement work are explained in Who can work on lead-based paint abatement projects?.

    Just because lead-based paint abatement or removal isn't required doesn't mean it should never be done. Lead is most dangerous when it is disturbed and careless removal or abatement procedures can increase the level of lead contamination in a building. Even so,  lead-based paint should probably be removed from target housing and child-occupied facilities or other residential property if there is:

    • Damaged lead-based paint on a surface that is subject to impact or abrasion during use, such as a doorjamb, corner of a cabinet, or the sliding surfaces on a window frame.

    • Lead-based paint on a chewable surface such as a windowsill, especially if the surface already has teeth marks.

    • Any other deteriorated lead-based paint inside or on the exterior of residential buildings or child-occupied facilities.

    Lead-based paint in offices should be kept in good condition. Flaking paint should be removed and the surface should be repainted with quality paint that isn't lead based. Even though maintenance work in offices is not governed by the Lead Renovation, Repair, and Painting Program Rule, maintenance  should not be treated casually. The OSHA's Lead in Construction Standards mandate limits on lead exposure and require monitoring, ventilation, the use of specific personal protective equipment, and other measures. The National Institute for Occupational Safety and Hetitleh's Lead Web page is a good source of information about the OSHA Lead in Construction Standards.

    Debris containing lead-based paint must be disposed of properly (explained in What am I supposed to do with lead-based paint debris?).

  • Lead-based paint abatement differs from ordinary maintenance. Abatement permanently eliminates lead-based paint hazards by removing or permanently encapsulating the lead-based paint. Maintenance keeps a building in good operating condition or returns it to good operating condition. Lead-based paint abatement is not required for Forest Service buildings except under certain circumstances

    The EPA regulates lead-based paint abatement work conducted on target housing and child occupied facilities. Many States, territories, and Indian Tribes are authorized by the EPA to operate their own lead program. The EPA's Lead Abatement Web page contains more information about these programs, which may include requirements that differ from those identified here. Your regional environmental engineer (link available only to Forest Service employees) can provide State and regional guidance for removal of lead-based paint.

    Only people who have been specifically trained and certified may conduct lead-based paint abatement, inspection, or risk assessment for target housing and child occupied facilities. They must follow specific work practices to ensure that they address lead hazards. Forest Service employees normally don't perform this work, which is contracted to certified firms. The Intermountain Region has assembled example specifications (link available only to Forest Service employees) used to contract for lead-based paint abatement.

    Even though lead abatement in offices is not governed by the EPA requirements, it should not be treated casually. The OSHA Lead in Construction Standards limit lead exposure and require the use of specific personal protective equipment, monitoring, ventilation, and other measures. The National Institute for Occupational Safety and Hetitleh's Lead Web page is a good source of information about the OSHA Lead in Construction Standards. 

     Debris containing lead-based paint must be disposed of properly, as explained in What am I supposed to do with lead-based paint debris?. Proper disposal of debris from lead-based paint abatement should be included in the contract for the abatement work.

  • 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.

  • Yes, you can sell or transfer an excess building with lead-based paint, but you will need to do a few things first. At a bare minimum, you will need to document any known lead-based paint and any lead-based paint mitigation so you can give the information to the new owner. Contact your regional environmental engineer (link available only to Forest Service employees) for assistance. 

    Additional requirements depend on the disposal authority, type of building, and age of the building, as explained below. Requirements are stricter for buildings constructed before 1978 that are considered target housing.

    For all target housing, a certified lead-based paint inspection and a risk assessment are required. These reports must be provided to the new owner and referred to in the transfer deed. Additionally, the transfer deed that the new owner signs must include a statement that the new owner agrees to comply with Federal, State, and local requirements relating to lead-based paint management, including demolition and disposal requirements.

    If the conveyance is under the authority of the 2005 Forest Service Facility Realignment and Enhancement Act (FSFREA), no abatement of lead-based paint or lead-based paint hazards is required. If the conveyance is under any other authority, and the target housing was constructed before 1960, lead-based paint hazards must be abated .

    More information about selling or transferring buildings containing lead based paint is available in

    In any case, the process to sell or transfer an excess building is complex. The very first step is to discuss the potential sale with the unit property management officer and the lands officer (if the sale includes land).

  • Target housing and child occupied facilities are defined in 40 CFR Part 745, Lead-Based Paint Poisoning Prevention in Certain Residential Structures.

    Target housing includes any housing constructed before 1978, except:

    • Housing for the elderly or persons with disabilities (unless a child under 6 years of age resides or is expected to reside in the housing)

    • Any zero-bedroom dwelling—a home or apartment where the living areas are not separated from the sleeping area, such as a studio apartment or dormitory.

    A child-occupied facility is any building or part of a building constructed before 1978 that is visited regularly by the same child

    • Under six years of age
    • On at least two different days within any week, if
      • Each day's visit lasts at least 3 hours and
      • The combined weekly visits last at least 6 hours and
      • The combined annual visits last at least 60 hours

    Forest Service recreational rental cabins are considered target housing, except for single room cabins or lookouts, which meet the definition of zero bedroom dwellings. Forest Service-owned and -leased office buildings constructed before 1978 are considered child-occupied facilities if employees bring their children to work often enough to meet this definition. Forest Service child day care facilities that use buildings constructed before 1978 meet the definition of a child-occupied facility.   

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