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Lead-Based Paint Removal

The Illinois Environmental Protection Agency (IEPA) recognizes the potential for environmental and human health impacts from the removal of lead-based paint (LBP) from the surfaces of various structures.  In response to these concerns, the IEPA has prepared this information package which outlines those LBP removal approaches which IEPA recognizes as being consistent with protecting human health and the environment.  Lead-based paint removal and containment technologies are continually evolving.  Therefore, the IEPA will not be recommending specific methodologies.  However, key general considerations in the removal of LBP are addressed.  It should be noted that, although IEPA regulations focus on the potential for releases of lead to the outdoor environment, the requirements for the handling and disposal of solid and liquid wastes also apply to waste generated during the removal of lead-based paint from interior surfaces.

Questions regarding LBP removal should be referred to Carol Hawbaker of the IEPA Toxicity Assessment Unit at (217) 558- 3351 or specific Agency contacts listed within this information statement.  For questions related to specific requirements for the removal of lead-based paint from residential buildings and child care facilities under the Lead Poisoning Prevention Code (77 Ill. Adm. Code 845), please contact the Illinois Department of Public Health at (217) 782-3517.  Information on the specific requirements of the Renovation, Repair, and Painting Rule can be obtained by accessing the information online or by contacting the USEPA Regional Contact at 312-886-7836.   

Regulatory Overview

The IEPA does not presently have regulations specific to the removal of LBP.  However, violations of the Illinois Environmental Protection Act (415 ILCS) may occur if the LBP waste generated is not contained or disposed of properly. Section 9 of the Environmental Protection Act (Act) prohibits the discharge or emission of any contaminant into the environment so as to cause or tend to cause air pollution.  Section 12 of the Act prohibits the discharge into water or deposit upon the land of any contaminant which may pollute waters of the State.  In addition, Section 21 of the Act contains a general prohibition against open dumping of any waste, plus a number of additional prohibitions on the storage, treatment, and disposal of specific wastes which have not been properly permitted by the IEPA.  Specific environmental regulations will be discussed in greater detail in the individual sections addressing Air Pollution Control, Water Pollution Control, and the Analysis and Disposal of Lead-Based Paint Waste.

All worker safety provisions as outlined by the Occupational Safety and Health Administration (OSHA) should be followed during LBP removal activities.  As part of federal legislation signed by the President in October of 1992 (Residential Lead Based-Paint Hazard Reduction Act of 1992 or Title X), the Secretary of Labor was required to issue interim final regulations for occupational exposure to lead in the construction industry.  OSHA promulgated the Interim Final Lead Standard for Construction in May 1993.  The specific requirements of the standard can be found at 29 Code of Federal Regulations (CFR) 1926.62.  For further information on OSHA requirements, please contact one of the following OSHA offices:

Chicago North Area (847) 803-4800
Fairview Heights Area (618) 632-8612
North Aurora Area (630) 896-8700
Calumet City Area (708) 891-3800
Peoria Area (309) 589-7033