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, Chromium, Barium and Arsenic

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.

Table of Building Dates and Estimated Amounts of Lead and Mercury in Paint

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

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)

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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Possible Dangerous Waste Codes

  • 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 Paint Waste Disposal

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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Paints and Coatings that Can Be Excluded From the Dangerous Waste Regulations

  • 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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Consumer Lead Paint Information Sources

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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