MIL-HDBK-1110
To meet the air regulations described above,
containment of work areas may be required. More extensive
containment may be needed when removing lead-based paint. The
Steel Structures Painting Council (SSPC) SSPC Guide 6I,
Containing Debris Generated During Paint Removal Operations,
describes five categories of containment. Worker protection must
also be considered in designing containment and ventilation
systems. Protecting both the environment and the workers is a
challenging task.
3.3.2
Waste. Debris resulting from surface preparation may
be hazardous waste as defined by Federal solid waste regulations
(40 CFR 240-280). Waste may be classified as hazardous if it
exhibits any of the following characteristics: ignitability,
corrosivity, reactivity, or toxicity, or if it is on a special
EPA list. For paint debris, wastes are most likely to be
hazardous because of their toxicity (e.g., exceeds limits for
lead, cadmium, chromium or mercury) or because of their
corrosivity (e.g., pH greater than or equal to 12.5 or pH less
than or equal to 2). For toxicity, waste is tested using the
toxic characteristic leaching procedure (TCLP) test, described in
Appendix II of 40 CFR 261. Waste is classified as hazardous
because of toxicity if lead concentration in the leachate exceeds
5 mg/kg, cadmium concentration exceeds 1 mg/kg, chromium
concentration exceeds 5 mg/kg, or mercury concentration exceeds
0.2 mg/kg. Paint debris wastes fail most often because of lead.
Some industrial paint wastes have also been reported to fail
because of chromium or cadmium. Although paint debris may
contain low concentrations of mercury from old films in which
mercury additives were used to control fungal or bacterial
growth, experience indicates that paint waste is unlikely to fail
because of mercury toxicity.
3.4
Surfaces Coated With Leaded Paint. The presence of
lead in paint films causes health, environmental, and worker
safety concerns. This section describes the DOD policy for
dealing with leaded-paint associated problems and summarizes DOD
guidance. References for specific guidance are given in the
References section.
3.4.1
Background
3.4.1.1
Use of Lead in Paint. Most oil-based residential
paints contained lead pigments prior to 1940. Lead pigments
provided hiding and color (tints of orange, yellow, green, and
red). Lead driers were used in both pigmented oil-based paints
and varnishes. The concentrations of lead in white or light-
colored paints sometimes exceeded 50 percent of the mass of the
dry film. Concentrations of lead in paints colored using lead
pigments ranged from 1 to about 10 percent of mass of the dry
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