Guidance for Homeowners & De-Leading Contractors, Revised November 2010

Background

Lead poisoning in children is one of the most common and preventable pediatric environmental health problems in the United States today. A significant source of exposure is lead-based paint. Many buildings, especially those built before 1950, contain lead-based paints on interior and exterior walls, windowsills and other surfaces accessible to young children.

Recently, the U.S. Environmental Protection Agency (EPA) clarified the regulatory status of lead-based paint from renovation and remodeling of homes and other residences. In 1998, EPA stated that the person who renovates his home and generates lead based paint waste does not have to manage it as a regulated hazardous waste. The most recent clarification extends this exemption to de-leading contractors doing work in homes, apartment buildings, and other residential facilities.

This fact sheet explains the appropriate method of disposal for wastes produced from de-leading operations performed by the homeowner or a de-leading contractor.

Change in MassDEP Guidance

Previously, contractors were required to determine through a laboratory test - the Toxicity Characteristic Leaching Procedure (TCLP) - whether a representative sample of the paint chips and/or lead-painted architectural components, such as wooden window casings, doors and door jams, exceeded the lead (TCLP) concentration limit of 5 mg/l. If the waste failed the test, the additional cost of disposal as a hazardous waste has added significant cost to each job.

This policy change means that lead-based paint residues generated from paint removal activities conducted by contractors and residents in residential properties is not subject to hazardous waste regulations. See: Massachusetts Policy on the Management of Wastes from Lead Abatement, Remodeling & Renovation Activities Conducted in Households pdf format of Policy on Management of Wastes from Lead Abatement doc format of Policy on Management of Wastes from Lead Abatement

Information gathered from solid waste facilities in Massachusetts now indicates that there is sufficient control technology. Combustion facilities have been able to treat their ash before it goes off site to be solidified and landfilled. Active landfills in Massachusetts now meet much higher standards - equivalent to the federal - which assure that they will not leach pollutants. By simplifying the procedures for disposal, the Department hopes to encourage additional residential abatement and removal of lead, thus protecting children from continued exposure.

Best Management Practices:

  • Follow occupational health and safety procedures in removing the paint.
  • Collect lead based paint waste and dust, dirt and rubble in plastic trash bags.
  • Store larger painted architectural components in covered containers, such as a roll-off, until ready for disposal.
  • Post warning signs to limit unauthorized access at work sites and storage areas.
  • Contact your local municipality to determine any volume limits for plastic trash bags to be disposed at curb or the solid waste drop-off center.
  • To avoid fugitive lead dust emissions, keep paint wastes covered and conduct any processing, e.g. chipping, grinding, shredding, in an enclosure.

Disposal of Lead-Based Paint Wastes:

  • To minimize waste volume in large de-leading operations, woodwork can be compacted and shipped offsite in a sealed hydraulic-driven compactor.
  • Stripping may be more effective on smaller surfaces. Spent solutions and sludges from residences are also exempt from hazardous waste regulations.
  • Other wastes, such as work clothes contaminated with de-leading wastes, wall and ceiling plaster, plastic sheets and tape used to cover work areas, filters, air-purifying cartridges, and vacuum cleaning dust may contain lead and should be disposed in closed containers or trash bags at the curb or at solid waste facilities.
  • Metal items coated with lead based paint can be recycled into the scrap salvage market.

For More Information

  • MassDEP Business Compliance Assistance: 617-292-5898
  • Listing of contractor training providers: 617-626-697
  • Listing of licensed de-leading contractors: 617-969-717
  • Childhood Lead Poisoning Prevention Program: 617-753-8400 or 800-532-957
  • Certification by a licensed inspector (required documentation in transfer of property): 617-284-8400

Mandatory Training Courses

  • Moderate Risk De-Leading for Homeowners (one-day) offered by the Massachusetts Department of Public Health (617-284-8400)
  • Lead-Safe Contracting (two days for contractor and one-day for employees of contractors). This course is one step in requirements for a contractor license.