United States Department of Agriculture Forest Service Technology & Development Program
		April 1997	9771-2311-MTDC
		7100

This is the sixth in a series of Tech Tips dealing with lead-based paint. This Tech Tip covers the requirements for handling and disposing of potentially hazardous lead-based paint wastes.

Debris generated when removing lead-based paint and painted components is considered a regulated solid waste. Examples of wastes from lead-based paint projects include:

• Solid debris such as old woodwork, plaster, windows, and doors
• Paint chips
• Blasting material mixed with lead-based paint particles
• Plastic sheets and tape used for containment
• Filtered wash water
• Miscellaneous materials such as mops, rags, protective clothing, and respirator filters.

Some of these wastes may be disposed of in a landfill as normal construction debris, but others must be managed as hazardous materials.

What is Hazardous Waste?

The Resource Conservation and Recovery Act (RCRA) regulates all solid waste disposal, including hazardous waste disposal. Solid wastes must be evaluated for their hazard; for lead-based paint wastes, the hazard is toxicity. As outlined in 40 CFR 261, the evaluation begins with a laboratory analysis called the Toxicity Leaching Characteristic Procedure (TLCP) that estimates the mobility of materials in a landfill. A sample of the waste material, such as paint chips or a wooden window frame, is subjected to conditions simulating a landfill. The extract must contain less than 5 parts per million lead to be considered nonhazardous. If the extract contains 5 parts per million or more, the waste is considered hazardous and must be handled as hazardous waste.

Sometimes the amount of hazardous waste can be minimized by separating lead-based paint debris from the waste stream. For instance, paint chips could be filtered from wash water used to prepare a surface.

RCRA requires "cradle-to-grave" tracking of hazardous wastes. Regulations in 40 CFR 262 outline the management and disposal requirements. At a minimum, the following requirements must be met:

Figure 1--Hazardous waste container label.

• Store hazardous waste in closed containers. Containers must be labeled (Figure 1) with their contents and the date they were generated.
• Depending on the amount of waste generated, obtain a permit to store hazardous wastes onsite before disposal.
• Engage the services of a licensed hazardous waste transporter.
• Ensure that the hazardous waste treatment or disposal faculty is licensed with proper permits.
• Maintain all waste determination and handling records for at least 3 years.

Forest Service Responsibilities

As the owner of facilities with lead-based paint, the Forest Service is considered the generator of wastes when a lead-based paint project is undertaken, even if the work is done by a contractor. The Forest Service is responsible for selecting waste abatement and containment methods to minimize the possibility that lead-based paint debris will be released. Unless the wastes are assumed to be hazardous, the Forest Service is responsible for having them tested for toxicity. If the wastes are hazardous, they must be managed according to the requirements of RCRA. The Forest Service must ensure that licensed handlers and permitted disposal sites are used.

Where to Get More Information

Most states are authorized by the Environmental Protection Agency to administer the Federal RCRA program. There may be additional State and local regulations that apply to lead-based paint wastes. The best source of information will be your State Department of Environmental Quality or the equivalent Agency. Usually the State agency can provide information on regulations, accredited laboratories for TLCP analyses, hazardous waste disposal contractors, and landfills. Additional resources are available from the:

• National Lead Information Clearinghouse, phone: 800-424-5323
• RCRA Hotline, phone: 800-424-9346.

About the Authors...

Andy Trent is a mechanical engineer at MTDC.

Bev Young is an environmental engineer at the Forest Service's Northern Regional Office in Missoula.

Next in the Lead-Based Paint Series...

Lead-Based Paint: Lead Training and Certification will describe the requirements for training and certifying individuals and firms who conduct lead-based paint inspections, risk assessments, and abatement services in residences and facilities occupied by children.

Hard copies of this document may be ordered from:

USDA Forest Service
Missoula Technology & Development Center
Building 1, Fort Missoula
Missoula, MT 59804-7294
Phone: (406) 329-3900
Fax: (406) 329-3719

For further technical information, contact Andy Trent at the address above.

Phone: (406) 329-3912
Fax: (406) 329-3719
DG: A.Trent:R01A
E-mail: /s=a.trent/ou1=r01a@mhs-fswa.attmail.com

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