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The Washington State Department of Ecology's Hazardous Waste Program and the United States Environmental Protection Agency regulate lead wastes above certain concentrations because it is very toxic to people and other living things.
Lead (abbreviated Pb) is a naturally occurring bluish-gray metal used for many household and industrial items. Lead in structures is usually in the form of compounds of refined metallic lead and other chemicals. Lead is an element, which means that it cannot be broken down and it cannot deteriorate into less toxic substances.
Metallic or elemental lead is a heavy, dull, gray metal. This is the form of lead that can be seen in fishing weights.
Compounds of lead and other substances were used in older paints, pipes and plumbing fixtures and are still used in construction products.
See the Index to Potentially Regulated Building Wastes for information about paint and other products manufactured with lead.
The toxicity of lead has been recognized for hundreds of years but it has also been very useful in industrial and consumer products for hundreds of years. Lead contamination has been spread throughout the world by industrial emissions, gasoline and paints. This means that every person on earth already has some level of lead contamination from environmental exposure.
Construction workers exposed to lead and their families are at risk of lead poisoning. Workers can unknowing carry hazardous substances home, exposing their families and causing various health effects. The long-term effects of lead exposure are irreversible and are much more damaging to children than to adults.
Lead dust or fumes are created when lead-based paint is dry scraped, dry-sanded, or heated during renovation or maintenance. Dust also forms when painted surfaces bump or rub together through normal use. Lead chips and dust can get on surfaces and objects that people touch. Settled dust can reenter the air when people vacuum, sweep, or walk through it.
For more information refer to the section on Lead Exposure Information for Workers and their Families .
See Lead Poisoning for more information about symptoms and effects.
See Blood Lead Level Testing for more information.
See Non-occupational Sources of Lead Poisoning for more information.
Lead is a common component in renovation and demolition debris from older buildings. It is most often found in interior and exterior painted wood, siding, window frames and plaster, and lead pipes or copper pipes with lead solder. It is less common in new construction wastes.
Most buildings constructed before 1960 contain heavily leaded paint. Buildings constructed as late as 1978 also may contain lead-based paint.
The Washington State Department of Health estimates 1.2 million homes in Washington have lead based paint.
Lead pipe or solder can be found in all but the most recently constructed buildings. Lead pipe would probably designate as a dangerous waste. Generally it should be removed before renovation or demolition, separated from the waste pile, and recycled as scrap metal.
Asbestos may be mixed with, or beneath lead paint. Asbestos was added to paint to provide decorative texture. Paint with regulated dangerous waste components may also be covering asbestos building materials such as pipe wrapping or siding.
Lead, mercury, arsenic, barium, cadmium, and chromium were commonly used paint ingredients and may now be found in paint on older buildings. They are most often found in interior and exterior painted wood, siding, window frames and plaster. These metals are all regulated by the Dangerous Waste Program because they are known to leach into water under landfill conditions as simulated by the Toxicity Characteristic Leaching Procedure (TCLP) test.
Polychlorinated biphenyls (PCBs) were added to paint formulations as drying oils and plasticizers or softening agents.
The age of a structure is directly related to the amount of lead that can be present.
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Date of Building Construction |
Sources of Lead Hazards |
| 1920 - 1978 | Paint |
| 1923 - 1986 | Auto Exhaust |
| 1920 - 1978 | Plumbing |
Lead abatement debris, and debris from other kinds of renovation and demolition work are all regulated for disposal under the Washington State Dangerous Waste Regulations.
See Index to Potentially Regulated Building Wastes for information about paint and other products manufactured with lead.
See Dangerous Waste Contamination in the Soil for information about the cleanup of lead contaminated soil.
The Department of Ecology regulates lead and lead contaminated debris from renovation and demolition work when it is disposed or recycled as a waste under the Dangerous Waste Regulations.
Ecology does not regulate lead products or the procedures used to remove lead.
Other federal and state agencies and programs also regulate lead - especially lead paint in households, and worker protection.
See Local Lead Regulations and Guidance , State Regulations and Guidance , and Federal Lead Regulations and Guidance for more information.
See Lead Industry Resources for information from lead consultants, building industry associations, and manufacturers of lead abatement products.
The most accurate way to determine lead, mercury, asbestos, PCBs and other environmental and health hazards at a site is to hire an independent hazard assessment expert to survey for them. An assessment contractor should be separate and financially independent from any environmental remediation companies that could be hired to remove the hazards.
Lead in plumbing pipes and fixtures, batteries, fluorescent lamps, and electrical switches can be recycled, avoiding the costs and difficulties of testing for dangerous waste disposal.
Lead, as well as mercury, cadmium, asbestos and sometimes PCBs are other regulated wastes commonly found in older paint wastes (1978 and earlier). These constituents of paint cannot be seen or identified through the generators knowledge so they must be either presumed to be present or identified through testing.
The Dangerous Waste Regulations are concerned with the identification or designation of lead or any other regulated metals that would leach out of the paint waste if it were disposed in a solid waste landfill. Testing for paint disposal is therefore concerned with the Toxicity Characteristic Leaching Procedure (TCLP) test and in some cases with Washington State only tests for toxicity and persistence in the environment.
See Dangerous Waste Identification / Designation for basic information or Ten Designation Steps to identify a lead waste for dangerous waste disposal.
See Dangerous Waste Sampling Requirements and Dangerous Waste Test Methods for information about the Sampling and Testing Methods and Representative Samples cited in the Dangerous Waste Regulations, WAC 173-303-110 Exit Ecology.
See Suggested Sampling Plans for Building Debris Disposal for suggestions about sampling entire buildings or parts of buildings for lead or other hazardous materials. Sampling of mixed building waste is difficult and is not currently addressed in the Dangerous Waste Regulations.
The term 'Lead-Based Paint (LBP)' used by Housing and Urban Development (HUD) and the EPA's Toxic Substances Control Act (TSCA) program is not used by the Dangerous Waste Program. It defines the amount of lead in paint (lead levels equal to or exceeding 1.0 milligram per square centimeter (1mg/cm2) or 0.5 percent by weight) instead of how much lead would leach out of paint.
Lead-Based Paint identification for EPA and HUD lead abatement and OSHA worker protection has different goals and uses different sampling, test methods and rules than the disposal requirements under the Dangerous Waste Regulations.
See Sampling and Testing for Residential Lead Abatement for more information about the following topics:
Lead wastes that do not designate can be managed by the requirements of the Department of Transportation, Federal Highway Administration, The Utilities and Transportation Commission, and the Washington State Patrol.
Universal Waste management requirements for leaded batteries and fluorescent lamps are less stringent than dangerous waste requirements.
For more information refer to:
Universal Waste Rule for Batteries and Mercury Containing Thermostats, July 2000, Ecology Fact Sheet 98-407Universal Waste Rule for Dangerous Waste Lamps, June 2000, Ecology Focus Sheet 00-04-020
Lead wastes that that designate as dangerous wastes and that are generated by regulated generators (rather than Small Quantity Generators or Household Hazardous Waste Generators) must be managed under the same labeling, manifesting and transportation rules as other dangerous wastes.
Refer to the section titled Dangerous Waste Transportation Requirements for more information.
Solid Waste
If lead waste doesn't designate it's solid waste and can be disposed
in solid waste facilities. For the names of construction and
demolition landfill disposal sites or haulers, contact the local
health department.
Ecology's Solid Waste website lists County Solid Waste Contacts and Health Departments at http://www.ecy.wa.gov/programs/swfa/contact/othercontacts.html
Recycle as Scrap Metal
Remove lead pipe or lead painted metal before renovation or
demolition, or separate it from the demolition waste pile and it can
be recycled as scrap metal per WAC 173-303-071(3)(ff). If it is not
recycled it must be designated to see if it would designate require
management as a dangerous waste.
For the complete text of the Scrap Metal exclusion see Selected Exclusions from Dangerous Waste Regulations for Building Wastes or the complete list of exclusions in WAC 173-303-071 Exit Ecology from the State Code Revisers Office
Recycle or Dispose as Universal Waste
Lead in batteries or fluorescent lamps that can be recycled or
disposed as Universal Waste has less stringent management requirements
than waste that is disposed as dangerous waste.
High intensity discharge lamps (HID) lamps with regulated amounts of lead cannot be disposed as Universal Wastes. They must be managed as Dangerous Wastes.
For more information refer to:
Universal Waste Rule for Batteries and Mercury Containing Thermostats, July 2000, Ecology Fact Sheet 98-407Universal Waste Rule for Dangerous Waste Lamps, June 2000, Ecology Focus Sheet 00-04-020
As Dangerous Waste
Manage regulated wastes according to the Dangerous Waste Regulations.
Small Quantity Generator or Household Hazardous Waste status reduces the regulatory requirements.
Refer to the section titled Dangerous Waste Disposal Options for more information about dangerous waste requirements.
Questions about particular dangerous wastes or their management?
Contact Ecology at one of the following numbers and ask to speak to a hazardous waste specialist or toxics reduction specialist.
Regional telecommunications devices for the deaf (TDD) numbers are: