Waste from renovations

The certified renovator or a worker trained and directed by a certified renovator must, at the conclusion of each work day, store any collected lead-based paint waste from renovation activities under containment, in an enclosure, or behind a barrier that prevents release of dust and debris and prevents access to the waste. In addition, the certified renovator or a worker under the direction of the certified renovator transporting lead-based paint waste from a worksite must contain the waste to prevent identifiable releases. 

In describing the containment to be established, the rule text referred to visible dust and debris and in the section on waste from renovations the rule text referred to identifiable dust. It was not EPA s intention to create subjectivity as to whether dust and debris were being dispersed. By conforming its terminology EPA is clarifying that certified renovators and renovation firms must ensure that the dust and debris (as opposed to visible or identifiable dust and debris) generated by the renovation is contained. Should an EPA inspector observe dust or debris escaping from the containment, the certified renovator and the renovation firm would be in violation of this final rule. 

Disposal of waste from renovation projects that would be regulated by this rule is covered by the Resource Conservation and Recovery Act (RCRA) regulations for solid waste. This rule does not contain specific requirements for the disposal of waste from renovations. 

Under this final rule the certified renovator or a worker trained by and under the direction of the certified renovator is required to ensure that all personnel, tools, and other items including waste are free of dust and debris when leaving the work area. The certified renovator or a worker trained by and under the direction of the certified renovator must also contain waste to prevent releases of dust and debris before the waste is removed from the work area for storage or disposal. If a chute is used to remove waste from the work area, it must be covered. At the conclusion of each work day and at the conclusion of the... 

Close to an asbestos mine or factory, levels may reach 10,000 fibers/m (0.01 fibers/mL) or higher. Levels could also be above average near a building that contains asbestos products and that is being tom down or renovated or near a waste site where asbestos is not properly covered up or stored to protect it from wind erosion. 

The capacity of the geochemical mechanisms in the geologic materials to renovate contaminants from leachates is finite and, if exceeded, will allow the leachate to pass with little change. Therefore, the attenuation capacity of the site s geologic materials must be the limiting factor for volume of wastes for disposal. 

The regulations are designed to minimize lead poisoning from waste materials. Waste must be contained, and any chute used must be covered. At the end of each work day, waste must be contained or placed behind a barrier that prevents release of the waste and prevents access to the waste. Renovation waste must be contained while it is transported off-site. ... 

The final rule requires renovation firms to use precautions to ensure that all personnel, tools, and other items, including the exteriors of containers of waste, be free of dust and debris before leaving the work area. There are several ways of accomplishing this. For example, tacky mats may be put down immediately adjacent to the plastic sheeting covering the work area floor to remove dust and debris from the bottom of the workers shoes as they leave the work area, workers may remove their shoe covers (booties) as they leave the work area, and clothing and materials may be wet-wiped and/or HEPA-vacuumed before they are removed from the work area. 

EPA understands that renovation projects can generate a considerable amount and variety of waste material. However, EPA believes that the requirements of the final rule protect occupants and others from potential lead-based paint hazards presented by this waste. While storing the waste in a locked container is one way to meet the performance standard of this final rule, EPA does not believe that it is necessary to specify that as a requirement. The waste may be stored in the work area, which will already be delineated with signs cautioning occupants and others to keep out. EPA believes the owner/occupants have some responsibility for observing these signs. Renovation sites pose potential hazards other than lead-based paint hazards, including the potential for falls, sharp protrusions, and so on. 

When cleaning following an exterior renovation, all paint chips and debris must be picked up. Protective sheeting used for containment must be misted with water. All sheeting must be folded from the corners or ends to the middle to trap any remaining dust and either taped shut to seal or sealed in heavy-duty bags. The sheeting must be disposed of as waste. 

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