Is Lead-Based Paint a Hazardous Waste?

Within our homes, the workplace, restaurants, on patios, furniture and more, paint is everywhere. Any object imaginable, there is likely some form, somewhere out there, a version of it that has paint. 

All this to say, paint is everywhere. You see it everyday. 

Regardless of how and where you encounter paint, it’s important to know whether it is lead-based or not and if the composition of the paint is hazardous to the environment

Whether you’re an industrial or commercial business owner or a homeowner, it’s important to know whether or not the lead-based paint you are using is hazardous or not. 

Subsequently, you will need to  know how to properly dispose of the waste if it is, in fact, hazardous. 

Toxicity of Lead-Based Paint

As a general rule of thumb for safety for those dealing with paint particles, all debris, paint chips, dust particles and sludges are very likely to contain the toxic substances that exceed the toxicity characteristic regulatory limit. 

According to the EPA regulations, a lead-based paint is deemed as a toxic waste if it maintains more than 5.0 mg/l of lead. 

Particularly with non-residential construction sites, this lead-based paint debris is likely to need testing to determine toxicity levels. If found hazardous because it is over the permissible limit of lead quantity within any given material, it should be handled as toxic waste and treated accordingly. 

How To Test My Paint For Toxic Lead Levels

With that being said, it’s important to be aware of the proper ways to test the toxic levels of paint. The concentration levels of lead in the paint debris dictates the requirement for disposal. 

Each state differs in disposal requirements for lead-based paint, so it’s important to consult with a certified laboratory in your region to determine the best methods of disposal per state regulation. 

The main differentiating factor for lead disposal is remodeling or construction from a residential building versus construction debris from a non-residential site. 

Residential Buildings

For residential buildings, it is more common for that sort of paint debris to be disposed of as a general waste. This means it can be deposited safely into a municipal landfill or a construction and demolition waste landfill.

According to the EPA’s 40 65 CFR 261.4(b)(1), household wastes are excluded from RCRA’s hazardous wastes. This means that wastes that are generated by contractors, residents using lead-based paint or the result of residential renovations are not subjected to the RCRA hazardous waste requirements. 

Non-Residential Sites 

When it comes to the construction debris from non-residential sites, the lead-based paint waste needs to undergo a TCLP test by an accredited laboratory. If the waste levels prove to be outside the permissible limit set by the EPA (5 mg/L of lead), the debris must be treated as a toxic waste.

Determined by the TCLP test, if the waste leachate contains lead exceeding the regulatory limit, they must be disposed of in accordance with the RCRA hazardous waste management and disposal requirements.  

To learn how to analyze your waste through a toxicity characteristic leaching procedure (TCLP) test, check out our recent article on the process of TCLP tests and how you can properly measure your waste. 

As an accredited laboratory, EHS has experience in determining toxicity levels through TCLP tests. 

How To Manage Your Lead-Based Paint

Because paint is ubiquitous, it is strongly encouraged to familiarize oneself with the EPA-recommended actions when it comes to managing wastes with lead-based paint. One of the first steps when it comes to proper management of lead-based paint is to consider the ways in which you can minimize the generation of lead dust, particles, chips and more. 

Whether you’re in a residential or non-residential site where lead-based paint is present, these are four simple ways you can lessen the generation of lead particles. 

  1. Collect any paint debris (chips, dust, dirt, rubble, etc.) into a plastic trash bag for disposing of. 
  2. Store other lead-based paint debris items that are larger in containers until they’re ready for disposal. 
  3. Follow the EPA guidelines and regulations when it comes to the proper disposal of any and all lead-based paint. 

Test Your Samples With An Accredited Laboratory

Regardless of the type of hazardous waste you may be testing, an accredited and experienced laboratory provides quick and accurate testing results. To understand which steps and protocols to follow when disposing or handling toxic wastes, contact EHS. 

With years of experience and a commitment to keeping the environment safe and healthy, EHS Laboratories can provide expedient results for any lead-based paint samples. 

Contact us today for any testing needs.