Paint and Coatings
Paint debris from renovation and demolition work may be
regulated dangerous waste:
- Painted or coated building components
- Chemical paint stripping wastes
- Paint chips, dust, or sandblast grit
- Paint rags and containers with paint, and paint thinners, or other
solvents
- Paint or other containments in wastewater
- Personal protective equipment, (plastic sheeting, etc.)
- HEPA filters
No one can tell if paint has lead, PCBs or asbestos by looking at
it although the age
of a building can be a good indicator. Generally, painted waste
must be designated or evaluated to see if it is dangerous waste before
it is disposed. For more detailed information about testing and
sampling paint refer to the pages on
Lead, mercury, cadmium, and chromium were commonly used in paint as
pigments and preservatives and are now found in paint on older
buildings. Arsenic has used as a pigment, a wood preservative and as
an anti-fouling ingredient. Barium has been used as a pigment and a
corrosion inhibitor.
- Lead in paints has primarily been lead carbonate (white lead), The
amount of lead in pigment may be very high, up to 40% (or 400, 000
parts per million) of dry old paint (prior to the 1960s) is composed
of white lead. It was also used in colored paints.
- Lead chromate (chrome yellow) was used in colored paint in 5 to 7%
concentrations (or 50,000 to 70,000 parts per million).
- Lead tetroxide (red lead) is also a component of paints.
- Auto exhaust is a second and sometimes overlooked source of lead
on structures. Gasoline exhaust was rich in lead oxide, also
tetraethyl lead (an organic chemical and lead compound).
- It has been estimated that twice as much lead was used in leaded
gasoline between 1940 and 1989 than was used in white lead pigmented
paints from 1910 to 1989. Seventy-five percent of that lead went into
the environment and settled in soil and on buildings - Lead
Based Paint and the Lead Abatement Issue in the United States, Journal
of Coatings Technology, July 1994.
Regulated amounts of these metals are found on all types of painted
surfaces, but higher levels of lead and mercury paints were used on
exterior painted wood, metal and concrete, and interior window frames
and doors.
- The metals regulated by the Dangerous Waste and Toxics Reduction
(HWTR) Program are toxic and are able to leach into the water table if
put into a landfill.
- Lead-Based Paint (LBP) is a term used by Housing and Urban
Development (HUD) and the EPA's Toxic Substances Control Act (TSCA)
program. It is not used in the Dangerous Waste Regulations. It means
paint has lead equal to or exceeding 1.0 milligram per square
centimeter (1mg/cm2) or 0.5 percent by weight.
- Lead-based paint is not a term used by the Dangerous Waste program
because the program only regulates lead if there is to leach 5.0 or
more milligrams per liter on a TCLP Test - a different method of
measurement.
- Dangerous waste metals are detected with the Toxicity
Characteristic Leaching Procedure (TCLP) test.
The age of a structure is directly related to the type and
amount of dangerous materials that can be in the paint:
| Date |
Hazardous Materials Used in Paint |
| 1953 |
Paint industry standards reduced lead levels in paint
to 1.0% (or 10,000 parts per million) |
| 1962 |
Lead reduced to 0.5% (or 1,000 parts per million).
Most buildings constructed before 1960 contain heavily leaded paint. |
| 1972 |
The Lead Based Paint Poisoning Prevention Act
established the level of 0.5% in house paints. |
| 1972 |
Mercury compounds were banned by the Environmental
Protection Agency from use in marine paint. |
| 1978 |
The final 1977 Lead Based Paint Poisoning Prevention
Act regulation set the maximum allowable level at 0.06% (or 600 parts
per million) became effective and lead at 0.06 percent or more was
banned from consumer paints. The Washington State Department of Health
estimates 1.2 million homes in Washington have lead based paint. Refer
to Banned Lead Products for more
information. |
| 1990 |
Mercury in interior latex paint was banned by the
Environmental Protection Agency. Up until it was banned in interior
paints in 1990, paint was the third largest manufacturing use of
mercury. Most buildings constructed before 1990 or 1991 probably
contain some mercury in their paint. |
| 1992 |
Mercury in interior paint banned but most
manufacturers had reduced the amounts of mercury in their products
before these dates. Refer to Banned
Mercury Products for more information. |
| 1993 |
A Consumer Product Safety Commission study of consumer
paint samples found that paints on the market meet the standard and
are actually below the 0.06 percent level. |
| 1996 |
Lead was not banned from gasoline used in
transportation until December 1995. See Banned
Lead Products for more information. |
Excellent information about historic paint ingredients (including
20th century paints) and many other building topics is available on The Old House Web at
www.oldhouseweb.net. As an example refer to Painting
Historic Interiors.
Asbestos has been used to provide decorative texture to paint .
- The Environmental Protection Agency (EPA) and local air quality
programs regulate asbestos.
- Ecology's Hazardous Waste and Toxics Reduction program regulates
any dangerous wastes such as lead paint that may be mixed with
asbestos.
In 1989 the EPA banned U.S. manufacturing, importation,
processing, or distribution in commerce of many asbestos-containing
product categories. However, much of the original "Asbestos
Ban and Phase out" rule was set aside in 1991. EPA does NOT track
the manufacture, processing, or distribution in commerce of
asbestos-containing products.
Refer to Banned Asbestos Products for
more information.
Lists of common building and consumer products with asbestos are
found in two EPA publications for homeowners:
Asbestos
in Your Home from the EPA, Region Three web site at
http://www.epa.gov/iedweb00/pubs/asbestos.html
Asbestos
in the Home from the EPA, Region Four web site at
http://www.epa.gov/region04/air/asbestos/homeasb.htm
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PCBs (polychlorinated biphenyls) were used in paint
formulations as drying oils (resins) and plasticizers or softening
agents (liquids).
- The Environmental Protection Agency (EPA) regulates most PCBs.
PCBs in applied dried paint or varnishes are classified as PCB Bulk
Product Waste.
- Ecology regulates PCBs equal to or greater than 100 parts per
million as Halogenated Organic Compounds, which are included in the
state Persistent Criteria dangerous wastes.
Concrete surfaces and equipment, as well as marine or waterproofing
applications, used at Federal installations and in the manufacturing
and industrial sectors may have painted surfaces contaminated with
PCBs.
Data provided to EPA indicate that PCBs have been found in dried
paint at concentrations that range from leas than 1 part per million
to 97,000 parts per million (Refs. 9 and 13)." From Use
Authorization for and Distribution in Commerce of Non-Liquid
Polychlorinated Biphenyls; Notice of Availability; Partial Reopening
of Comment Period - Proposed Rule, December 10, 1999 (69358-69364)
- Text Format,
PDF Format
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- D002 (federal corrosive characteristic) or WSC2 (Washington State
solid corrosive characteristic) if corrosive solvents are used to
remove paints or coatings.
- D006 (federal toxicity characteristic for cadmium) if there were
enough cadmium to leach 1.0 or more milligrams per liter on a Toxicity
Characteristic Leaching Procedure (TCLP) Test.
- D008 (federal toxicity characteristic for lead) if there were
enough lead to leach 5.0 or more milligrams per liter on a TCLP Test.
- D009 (federal toxicity characteristic for mercury) if there were
enough mercury to leach 0.2 or more milligrams per liter on a TCLP
Test.
- WT01 or WT02 Washington State only dangerous waste if the
concentration of toxics in the waste is enough to be toxic to test
animals in a Washington State Toxicity Criteria Test.
- WP01 or WP02 Washington State only dangerous waste if the
concentration of PCB's or other Halogenated Organic Compounds is
greater than or equal to 100 parts per million.
Asbestos and PCBs do not have dangerous waste codes because they are
regulated by the Toxic Substances Control Act, not the Dangerous Waste
Program.
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Household wastes are excluded from Ecology's Dangerous Waste
Regulations (the WAC). This exclusion only applies to waste disposal.
Homeowners or contractors with household lead wastes don't have to
identify or test lead waste to dispose of it.
However, the following lead wastes are not exempt in
Washington State:
- Lead wastes generated by the demolition of an entire residence .
Demolition wastes are not considered to be a normal household waste
stream.
- Lead wastes generated by a home based business such as cabinet
making.
- Lead wastes generated at non-residential sites.
Note - Homeowners or contractors (including volunteers) disturbing
or removing lead in residential dwellings may be subject to other lead
regulations. Particular activities that may be regulated are occupant
notification, worker protection, worker certification and training,
and real estate transactions. See Local
Regs and Guidance, State Regs and
Guidance, Federal Regs and Guidance,
Sampling and Testing for Residential Lead
Abatement for more information.
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- Household paint wastes are excluded. See Household Hazardous Waste .
- PCBs in paint are excluded from the Dangerous Waste
regulations if the waste is regulated by the EPA as a PCB waste.
However lead paint or certain other dangerous wastes mixed with the
PCBs would remain regulated by the Dangerous Waste program.
- Treated wood waste and wood products including
arsenic-treated wood and wood treated with other preservatives.
- Painted scrap metal (processed scrap metal, unprocessed
home scrap metal, and unprocessed prompt scrap metal) being recycled.
Refer to Wastes Excluded from
Regulation for more information.
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The National Lead
Information Center (NLIC) provides the general public and
professionals with information about lead hazards and their
prevention. NLIC operates under a contract with the U.S. Environmental
Protection Agency (EPA), with funding from the Environmental
Protection Agency, the Centers for Disease Control and Prevention, and
the Department of Housing and Urban Development.
To receive a general information packet, to order other documents,
or for detailed information or questions, call the Center's
clearinghouse and speak with a specialist Monday through Friday, 8:30
am to 6:00 pm EST:
The following on-line publications are available from EPA’s
Office of Pollution Prevention and Toxics - Public Education Resources.
You can also order documents and request information about Lead
Poisoning and Lead Hazards through the National Lead Information
Center (NLIC) at 1-800-424-LEAD. Some documents are
available in Spanish and other formats.
Title: "Lead in
Your Home: A Parent's Reference Guide" (PDF format,
2,128 KB, 67 pages)
Title: "Protect
Your Family From Lead in Your Home"
(PDF format) (April 1999 Edition)
Also available in Spanish
and other formats
Title: "Reducing
Lead Hazards When Remodeling Your Home", September 1997 (EPA
747-K-97-001). This version replaces the previous version of April
1994. (PDF format)
Also available in Spanish (EPA 747-K-97-002) from the National Lead Information
Center.
Title: "Testing
Your Home for Lead in Paint, Dust, and Soil", October 1998
(EPA 747-K-98-001). (PDF format)
The Consumer Product Safety
Commission (CPSC) at http://www.cpsc.gov/ regulates potential
hazards in commercial products.
- Information at 1-800-638-2772.
- Teletypewriter (TTY) for the hearing impaired 1-800-638-8270.
A Consumer Product Safety Commission Safety Alert, Document #5055,
warns about the Hazards
of "Do It Yourself" Removal of Lead Based Paint. The
document is at http://www.cpsc.gov/cpscpub/pubs/5055.html
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