Recycle C&D Debris - Lead
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Lead
According to the EPA, approximately three-quarters of the nation's houses built before 1978 (approximately 64 million dwellings) contain some lead-based paint (LBP), although lead-based paint is not used in new residential construction. Lead is also a common component in C&D debris, found in roofs, cornices, tank linings, and electrical conduits. These materials may leach lead into the environment if not properly managed. Soft solder, an alloy of lead and tin, is used in plumbing for soldering joints. Soft solder has been banned from many uses in the United States.

An estimated one in eleven American children has high lead levels in their blood. The Centers for Disease Control (CDC) describes lead poisoning as the most significant, preventable health problem affecting children today. Consumers are suing contractors for lead contamination that occurs during demolition and renovation. You can protect yourself by becoming aware of the hazards of lead poisoning, managing lead-containing demolition debris appropriately, and by examining your liability carefully (see Section 2-Contractor Liability).

Lead Paint and Real Estate (Title X)
In 1992, Congress passed the Residential Lead-Based Paint Hazard Reduction Act, also known as Title X, to inform the public about the risks of exposure to lead. Under Section 1018 of this law, HUD and the EPA require the disclosure of information on lead-based paint hazards before housing units built before 1978 can be sold or leased (1978 was the year the Consumer Product Safety Commission banned the sale or distribution of lead-based paint for residential use).

Owners of residential property regardless of the number of units) built before 1978 must:
  • Disclose information to renters or buyers about known lead-based paint and lead-based paint hazards and provide any available reports on lead in the dwelling.
  • Give renters or buyers the EPA pamphlet Protect Your Family from Lead in Your Home.
  • Include proper warning, notification, and disclosure language in contracts and leasing agreements.
  • Give buyers a 10-day period to test the dwelling for lead.
  • Retain signed acknowledgments for three years as proof of compliance.
Regulations
  • Title X 1992 Residential Lead-Based Paint Hazard Reduction Act Real estate notification and disclosure rule regarding most houses built before 1978.
Facts about Lead
Below is some general information about lead.
  • The major source of lead in the home is from contaminated dust (old paint, contaminated soil, and leaded gasoline/auto exhaust residues).
  • Other sources of lead include dust from remodeling and lead in the water from solder or fixtures.
  • Lead-based paint is only a hazard if the paint is damaged (peeling, cracking, etc.). The presence of the paint itself is not necessarily a hazard. Paint in good condition poses little threat to health if left undisturbed.
  • There is not a completely safe, do-it-yourself way to remove lead-based paint.
  • Lead-based paint is most commonly found in areas where high durability is needed: windows, doors, door frames, woodwork, and furniture.
  • Research has shown that small doses of lead, once thought to be harmless, can cause serious damage to the human body.
  • Young children are at the greatest risk for lead poisoning, which can cause delayed development, reading and learning problems, lowered IQ, hyperactivity, and discipline problems. Larger doses of lead can cause high blood pressure, anemia, and kidney disorders (even in adults).
Lead Dust
Most buildings constructed before 1960 contain heavily leaded paint. Buildings constructed as late as 1978 may also contain lead paint. Lead pipe and solder can be found in all but the most recently constructed buildings.

Operations that generate lead dust and fumes include:
  • Using flame-torch cutting or welding or using heat guns on lead painted surfaces during repair, reconstruction, dismantling, demolition, or abatement work.
  • Abrasive blasting of bridges and other structures containing lead-based paints.
  • Sanding, scraping, or grinding lead painted surfaces during repair, reconstruction, dismantling, demolition, or abatement work.
  • Maintaining exhaust duct work.
OSHA and EPA Regulations
In June 1993, OSHA developed new lead exposure standards for workers who handle materials containing lead. The standards cover safe work practices, worker exposure limits, labeling, employee training, protective clothing and respirators, medical surveillance, monitoring, and record keeping. OSHA publishes the handbook Lead in Construction that describes your responsibilities in these areas. For a copy of the handbook or for more information, contact either the OSHA.

OSHA Worker Protection Program
Employers of construction workers are responsible for the development and implementation of a worker protection program in accordance with OSHA regulations found in 29 CFR, Parts 1926.20 and 1926.62 (e). This program is essential for minimizing worker risk of lead exposure. The most effective way to protect workers and minimize the generation of hazardous air emissions and waste is through the use of safe work practices and engineering controls. Engineering controls reduce employee exposure in the workplace either by removing or isolating the hazard or isolating the worker from exposure through the use of technology.

Regulations
  • 29 CFR 1910.133 Federal regulations on eye and face protection.
  • 29 CFR 1910.134 Federal regulations on respiratory protection.
  • 29 CFR, 1926.20 and 1926.62 Federal regulations on lead exposure for construction workers.
EPA Training Certification Requirements
The EPA is in the process of adopting lead training certification requirements for lead inspectors, workers, and abatement contractors and supervisors. The laws and regulations for this action were promulgated in August 1996. At that time, states and tribes had two years to seek authorization to manage the program. By the fall of 1998, EPA will manage the program in areas that do not have state/tribal programs, which includes Montana.

Best Practices
  • Develop a worker protection program that limits employee exposure to lead. OSHA's new interim final standards for construction workers is 50 micrograms of lead per cubic meter of air averaged over an 8-hour workday. Minimal plan elements should include:
    • Identifying sources of exposure
    • Hazard determination, including exposure assessment
    • Exposure monitoring
    • Protective clothing, respiratory protection, and equipment
    • Housekeeping
  • Select appropriate respiratory devices and monitor effectiveness.
  • Determine the effectiveness of work practices in controlling exposures.
  • Determine the need for engineering controls.
  • Recognize the need for modifying exposure and control practices, including the need for additional engineering controls.
  • Determine the need for medical monitoring.
Lead Disposal
If the material you are examining for lead contamination fails the TCLP test, it must be considered a hazardous waste and managed accordingly (see Toxicity Characteristic Leaching Procedure (TCLP) in this section). The entire site should then be examined for further lead contamination. Discuss options for treatment or disposal with your client as soon as the contamination is discovered. One option is to haul the contaminated material to a treatment, storage, or disposal (TSD) facility.

Disposal of Lead-Based Paint Waste
Disposal of lead-based paint waste is subject to the regulations found in the Resource Conservation and Recovery Act (RCRA) Subtitle C. Normally, household wastes are excluded from the RCRA requirements. However, under the EPA's current reading (May 1994) of the household waste exemption, lead-based paint is not similar to the waste typically generated by a household. Therefore, lead-based paint waste generated from construction, demolition, or renovation activities is not exempt from RCRA Subtitle C and must be managed as hazardous waste (see Section 8-Hazardous Wastes).

On the other hand, if your lead-based paint waste is generated in small enough quantities (less than 220 pounds of hazardous waste per month) to meet the requirements of a conditionally exempt generator (CEG), you may have to comply with fewer regulations (see Section 8-Hazardous Wastes for information about CEG requirements).

The following documents are available from EPA offices:
  • Lead Poisoning and Your Children. EPA 800-B-92-002, Feb 1995
  • Protect Your Family From Lead in Your Home. EPA 747-K-94-001, May 1995
  • Lead in Drinking Water in Schools and Non-residential Buildings. EPA 812-B-94-002, April 1994
  • Guidance on Residential Lead-based Paint, Lead-contaminated Dust, and Lead-contaminated Soil. July 1994
  • Reducing Lead Hazards When Remodeling Your Home. EPA 747-R-94-002, April 1994
  • EPA and HUD Real Estate Notification and Disclosure Rule. EPA 747-F-96-001, March 1996
  • Understanding Title X, A Practical Guide to the Residential Lead-Based Paint Hazard Reduction Act of 1992. Alliance to End Childhood Lead Poisoning
It is becoming more difficult and expensive to dispose of both hazardous and non-hazardous construction and demolition (C&D) waste because of stricter environmental regulations and a shortage of landfill space. Non-hazardous C&D waste typically consists of concrete, insulation, bricks, asphalt, wood, glass, masonry, roofing, siding, plaster and drywall, soil, rock, stumps, boulders, and brush.

Engineering and Work Practice Controls
  • Do not sand, dry scrape, or burn lead-based paint (this generates contaminated dust).
  • Increase the length of cutting torches to increase the worker's distance from the contamination.
  • Reduce lead exposure during torch cutting by stripping paint away from the area to be cut.
  • Substitute blasting techniques that are less dusty than abrasive blasting:
    • wet blasting using high pressure water with or without abrasive media (be aware that control and disposal of water can be a problem)
    • vacuum blasting where a vacuum hood for material removal is positioned around the exterior of the blasting nozzle
  • Use flameless heat guns to remove lead-based paints in residential housing units. Heat guns should have electronically controlled temperature settings to allow usage below the HUD limit of 1,100° F. Heat guns should be equipped with various nozzles to cover all common applications.
  • Remove and replace interior woodwork and entire window systems rather than scraping.
  • Cover lead-based paint surfaces with materials such as vinyl wallpaper, plaster, or wallboard.
  • Use coatings that do not contain lead.
  • Use chemical strippers to soften and remove lead-based paint (Caution: many chemical strippers, such as methylene chloride, are toxic or release toxic by-products when subjected to high temperatures).
  • Use exhaust ventilation that is equipped with a dust collection system to capture lead dust and fumes at the point of generation.
  • Use wet cleaning methods (damp mopping or dusting) to reduce the spread of dust.
  • Use vacuum equipment with high-efficiency particulate filters.
  • Use non-lead solder.
  • Recycle lead pipe removed from demolition jobs (do not reuse).
Respiratory Protection, Protective Clothing, and Equipment
  • Establish a respiratory protection program in accordance with the OSHA standard in 29 CFR 1910.134. Provide an appropriate, clean respirator that has been approved by the Mine Safety and Health Administration (MSHA) and the National Institute for Occupational Safety and Health (NIOSH).
  • Provide employees with dry, protective work clothing and equipment which include coveralls or full-body work clothing; gloves, hats, and shoes or disposable coverlets; and face shields, vented goggles, or other appropriate protective equipment that complies with 29 CFR 1910.133. Also provide appropriate changing and hygiene facilities.
Housekeeping
  • Keep the work site clean. Use either a vacuum with a HEPA filter or a wet cleaning method when removing lead dust. Never use regular vacuums or compressed air for cleaning.
  • Clean up thoroughly. Mop with a solution of 5% trisodium phosphate (TSP) in warm water.
  • Wash hands and face before eating, drinking, smoking, or applying cosmetics.
  • Keep all food away from work areas. Eat, drink, or smoke in areas outside the work site.
  • Shower and change into clean clothes, including shoes, before leaving the work site so that no lead contamination is carried off-site.
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