“It doesn’t have to be LBP to be a hazard! Regulations that can lead you astray!”

“It doesn’t have to be LBP to be a hazard! Regulations that can lead you astray! These and other myths surrounding paint and coatings dispelled (or at least discussed)!”

Presented By Michael C. Sharp of Hazard Management Services, Inc.


OSHA regulates lead down to any detectable amount of lead in paint and has no cutoff date concerning when paints no longer might contain lead. This acknowledges that lead is a problem at nearly any level in the paint, yet many regulations are unconcerned if the paint is not LBP!

The belief that non-lead-based paint is safe is a fallacy.

Sanding one square foot of LBP can contaminate 23,000 (+) square feet above the EPA hazard level for floors.

Paints produced and sold via retail outlets between 1978 and 2009 were allowed to contain 600 ppm of lead – roughly 1/10 that of lead based paint.

Sanding one square foot of paint with 600 ppm could contaminate 2300 square feet of floor space above EPA hazard levels.

Paint since 2009 is allowed to contain up to 90 ppm.

Sanding one square foot of 90 ppm paint can contaminate up to 400 square feet of floor space.

All of the above assumes there is a single layer of paint – with multiple layers of paint, the numbers can be worse. These numbers assume minimum required levels of lead in the paint when discussing lead based paint. This does move from lead per area to percent lead per, which could affect the numbers slightly.

The belief that lead based paint is no longer in use is a fallacy.

LBP is still legal and in use outside of homes, schools and public buildings.

The belief that the level in lead that  determines whether it is lead-based or non-lead-based is based on health concerns is a fallacy

The level of lead required to be in paint to determine that paint is lead-based, when measured by lead per a defined area, was based on the lowest level of lead necessary for an XRF to be accurate.

The level of lead required to be in paint to determine that paint is lead-based, when measured by weight or percent, was based on the ability of manufacturers to remove lead from paint and continue to produce a viable product.

Levels determining paints to be LBP have nothing to do with Health – our responses should not be based on whether the paint is LBP!

The belief that paint is what put most lead in the soils around older homes (pre-1978) is a partial fallacy.

Does anyone remember when we used to have to warm up our cars before we drove them?

The belief that lead-based coatings and materials were banned from homes in 1978 is a fallacy.

The belief that contractors will handle paint, and other lead coatings, correctly because they are professionals is a fallacy. 

This incorrectly assumes that painting and other contractors know the hazards and the regulations – which many do not.

The belief that lead is the worst thing we ever put into paint is a fallacy.

What about Cadmium, Barium, Arsenic, Mercury and other heavy metals and toxic substance?

We should be concerned with the handling of all paints as the rules and work practices used to handle paint in a “lead safe fashion” will protect us (and the environment) from all these hazards. We should handle paint the same whether paint contains lead or not. Think of how much money this would save in inspection costs!

Regulations that can lead you astray

The HUD and EPA stops regulating paint when there is less lead than LBP levels. This leads to big problems when the paint contains lead but not at LBP levels.

Federal rules require LBP to be stripped 6 inches beyond areas of structural steel being welded or torch cut – this leads to the belief that welding and torch cutting can be conducted safely once the paint is removed 6 inches from the work to be done – that is a complete fallacy.

Lack of knowledge of Regulations can also lead you astray

How many contractors (or building owners) realize that paint is suspect for containing asbestos? Lack of enforcement does not mean it is legal to remove paint without checking it for asbestos (this falls under the Federal NESHAPs regulation).

People addressing mold growth in their home or building often address the obvious problems, mold growth and water intrusion, completely forgetting or ignoring that the materials the mold is growing on may contain lead or asbestos.

If we don’t address all of these issue – we ignore many potential hazards (lead and otherwise) – while making people think they safe because the there is no “lead-based paint” or that issue has been dealt with (while others are ignored).

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