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EPA Lead Paint Regulations – Disposal Training

Keeping the job site clean of dust and debris training exercise

Have bags and tape ready for the demonstration, if you choose to perform it, and for the required hands-on activity.

  • Waste should be stored in a secure area to prevent children from getting into it and being exposed to leaded dust.
  • Discuss methods to handle waste water.
  • Waste water produced during the job from mopping, wet cleaning, or misting should not be poured down the sink or tub (because it will contaminate the sink or tub), into the yard or down a storm drain.
  • Before disposal, waste water may need to be filtered through a filter capable of filtering out particles 5 microns or larger, depending on state and local wastewater regulations.
  • If local regulations allow, waste water may be poured down the toilet. If local regulations do not allow this, you may be required to contain and test the water, and contact a waste disposal company to assist you with disposal. Your local water authority can assist you with this decision.
  • Always be aware of Federal, state and local regulations regarding waste water disposal.
  • All waste should be handled carefully and sealed in heavy duty plastic bags.
  • Do not overfill the bags. Renovation debris is heavy, and, if overfilled, will split the bags and could injure workers.
  • Certified Firms must be aware of all components of the waste produced at the job site and of the proper method of disposal. Again, always be aware of Federal, state and local waste disposal regulations.

Disposal – Federal, State and Local Information

  • Waste disposal is regulated under the Resource Conservation and Recovery Act (RCRA), and various associated state and local laws and regulations.
  • Some waste generated from lead work may meet the definition of “hazardous waste” because it is toxic, corrosive, ignitable or explosive. Therefore, it is important for contractors to segregate waste into categories that are likely to be hazardous and non-hazardous. Examples of hazardous waste may include paint chips, vacuum debris, sludge or chemical waste from stripper, and HEPA filters.
  • Generators of less than 220 pounds of waste per job site per month are exempt from Federal waste disposal regulations and most state regulations.
  • Many states have more stringent regulations than Federal requirements. It is, therefore, important for contractors to understand their obligations under these laws and regulations.
  • You should always be aware of how much waste you are generating per job site per month.
  • EPA’s website has links to state information on solid and hazardous waste disposal at https://www.epa.gov/hwgenerators/links-hazardous-waste-programs-and-us-state-environmental-agencies.

In a memorandum to RCRA Senior Policy Advisors and EPA Regions 1-10, dated July 31, 2000, EPA’s Office of Solid Waste stated that lead-based paint waste from households may be disposed of as household garbage subject to applicable state regulations. For more information, see Appendix 8 and the EPA website at http://www.epa.gov/lead/pubs/fslbp.htm. Although EPA considers lead-based paint waste commonly generated during residential renovation and painting to be household waste, some states have not yet adopted this interpretation. Until states do adopt EPA’s interpretation, they may continue to regulate lead-based paint waste as potentially hazardous if generated in large enough quantities.

DTadmin in EPA Lead Paint Regulations,Training on March 17 2010 » comments are closed

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