Lead is a Four-Letter Word

by Steven P. Roetter, Tank Industry Consultants, Inc., 49112 West 16 Street, Speedway, IN 46224,

Serial Information: Civil Engineering—ASCE, 1993, Vol. 63, Issue 7, Pg. 58-59

Document Type: Feature article

Abstract: New regulations and strict enforcement make it difficult and expensive to remove lead-laden coatings from steel structures. Lead-based primers and paints are not considered hazardous as long as they remain on the steel structure, but as soon as somebody decides on removal, environmental regulations and restrictions come into play. The owner becomes a hazardous waste generator who must obtain a generator's ID number from the state EPA. The owner, no matter what clauses he puts into the contract documents, cannot abdicate this responsibility to the contractor. Therefore, proper documentation, evidence of compliance with testing requirements and completed manifest forms are imperative throughout a removal project. Regulations prohibit the lead from endangering the public by entering the air, water or land. The owner's (and engineer's) potential liability is enormous. A project should start with a review of the regulations and thorough testing to determine which regulations apply. Dust and debris, including that from spot cleaning, must be handled exactly as the hazardous waste from complete removal, and must be disposed of daily. In addition to the six commercially viable methods for removal, several others are under trial as prototypes.

Subject Headings: Environmental issues | Hazardous materials | Lead (chemical) | Owners | Waste disposal |

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