Lead Paint
Lead is considered to be one of the seven metals of antiquity. Its unique color properties lead to its use as a pigment on buildings around 3,000 B.C. This quality of lead pigment is one of the reasons that it was used as an additive in paint for thousands of years. Lead compounds, such as white lead (lead carbonate), red lead (lead dioxide), and lead chromate, are the most widely used pigments used in paints, primers, and varnishes. Lead is used in these formulations because it makes these materials more durable and wearable. Lead is used in many industrial and commercials applications due to its anti-corrosion properties and bright colors. Lead chromate has been used as the colorant paint for heavy equipment, machinery, and school buses, as well as highway and parking lot striping. Lead based coatings have been used for residential purposes until the early 1980’s before it was banned. Despite the ban, it is thought that the number of household units that contain lead numbers in the tens of millions
Health Issues
The initial concerns about lead paint centered on work environment where employees were exposed during the manufacturing of this material, titanium dioxide and zinc oxide, which were observed to be suitable for use. However, the concern for lead these days involve tasks associated with the chipping, sanding, grinding, or welding on surfaces that may be coated with lead paint. Persons who may inadvertently inhale or ingest lead may become ill and experience various signs and symptoms including: abdominal pain, irritability, tremors, hypertension, anemia, as well as reproductive system complications and fetal anomalies.
Regulatory Requirements
OSHA
The Occupational Safety and Health Administration (OSHA) in 1971 established a permissible exposure limit (PEL) of 200 micrograms per cubic meter (ug/m3) of air for persons in the work environment. However, it was not until 1978 that OSHA promulgated a new lead standard (29 CFR 1910.1025) for the general industry, which protected workers involved production or use of lead containing materials. Later, a specific lead standard was established in 1993for the construction industry (29 CFR 1926.62) for those workers involved with the use or generation of lead that might result in an exposure. The construction standard was very important, because it was able to address those specific workplace issues associated with lead base paint abatement. As a result of newly acquired information regarding the adverse affects of lead that OSHA lowered the PEL to50 ug/m3 and established a 30 ug/m3 action level, which would require medical screening.
HUD
The Department of Housing and Urban Development (HUD) has established Guidelines for Public and Indian Housing that describe the need and appropriate methods for identifying and abating lead based paint (LBP). The Lead Based Paint Poisoning Prevention Act (LBPPPA) of 1971 and subsequent amendments in 1987 and 1988 required Public and Indian Housing Authorities to conduct inspection and sampling of pre-1978 family dwellings and common areas where children are expected to live. The Act specified the use of an X-ray fluorescence analyzer (XRF) and an atomic absorption spectrophotometer as the instruments to be used for the analysis of lead based paint. The act further established a limit of 1.0 milligrams per square centimeter (mg/cm2) as the amount that would indicate a positive indication to be considered as lead based paint.
EPA
The Resource Conservation and Recovery Act (RCRA) of 1976 established the requirements that involve waste identification, characterization, permitting, recordkeeping, manifesting, recycling, disposal, treatment, and storage. Lead abatement activities that generate a hazardous waste would be required to comply with all applicable requirements of the Act. One of these requirements is the Toxicity Characteristic Leaching Procedure (TCLP), which is the teat that is used to determine if the quantity of lead present would cause the material to be a hazardous waste. The quantity of generated lead waste on a monthly basis would determine if the generator would be required to register as a conditionally exempt, small quantity, or large quantity generator.