1 DECEMBER 2002
Offsite transportation of asbestos material is regulated under 40 CFR 61 part 150
(http://www.access.gpo.gov/nara/cfr/waisidx_00/40cfr61_00.html)and also the Department
of Transportation regulations in 49 CFR 171 178
(http://www.access.gpo.gov/nara/cfr/waisidx_01/49cfrv2_01.html). These regulations
should be consulted prior to transportation.
4-2.2 Lead-Based Paint (LBP). If a structure was built before 1978, it should be
assumed that it is coated with LBP. LBP was primarily applied in kitchens, baths, and on
wood trim and siding. When an architectural component coated with LBP is displaced
and separated from a building during abatement or demolition activities, lead-
contaminated debris is generated.
Public Works Technical Bulletin 420-70-2 provides technical guidance to identify and
control lead hazards from lead-contaminated paint, dust, soil, and from other sources in
Army-owned facilities constructed before 1978. Unified Facilities Guide Specifications in
Division 13 describes the safety, health, and disposal requirements and procedures to
be implemented for LBP removal and material handling activities.
The rules for storing, handling, record keeping, and disposing of LBP debris are
changing. To reduce the costs and remove the obstacles associated with disposal of
LBP debris, the USEPA is proposing a rule to shift the regulations from management
and disposal of LBP from the Resource Conservation and Reservation Act (RCRA) to a
tailored program under the Toxic Substances Control Act (TSCA). Currently, Federal
facilities are required under Title IV of the Toxic Substance Control Act, Lead Exposure
Reduction (Public Law 102-550), to comply with State and local regulations on LBP.
Under the RCRA, installations and facilities are currently required to characterize their
LBP waste and dispose of it by an approved method. If LBP debris is determined to be
hazardous (equaling or exceeding 5 mg/liter lead according to the EPA Toxicity
Characteristic Leaching Procedure, or TCLP), then the waste is strictly managed from
identification to disposal.
Many states have regulations that are more stringent than the Federal standards and
installations are required to comply with these more restrictive state standards. Workers
exposed to lead are protected by standards established by OSHA.
In August 2000, the USEPA issued a policy clarification on how they will regulate the
disposal of LBP debris under RCRA. Essentially, any LBP debris from a "residential"
building will be considered non-hazardous, by definition. See the following URL for the
latest EPA guidance: http://www.epa.gov/lead/fslbp.htm . Of course, states will have
their own interpretations.
DEMOLISH (Lead-Based Paint)
LBP debris can be removed from the C&D waste stream and be managed separately,
or it can remain in the larger contaminated waste stream which will then all have to be
managed as LBP debris. Waste managers must determine whether it is more cost
effective to simply dispose of the commingled debris in appropriate landfills, or to
remove LBP debris and handle it separately so that the rest of the waste can be reused