Appendix E 
Memorandum from Elizabeth Cotsworth, 
Director, Dffice of Solid Waste 
July 31. 2000 
MEMORANDUM 
From: Elizabeth A. Cotsworth, Director 
Office of Solid Waste 
To: RCRA Senior Policy Advisors 
EPA Regions 1-10 
Subject: Regulatory Status of Waste Generated by Contractors and Residents from Lead- 
Based Paint Activities Conducted in Households 
What is the purpose of this interpretation? 
This memorandum clarifies the regulatory status of waste generated as a result of lead-based paint 
(LBP) activities (including abatement, renovation and remodeling) in homes and other residences. 
Since 1980, EPA has excluded “household waste” from the universe of RCRA hazardous wastes 
under 40 CFR 261.4(b)(1). In the 1998 temporary toxicity characteristic (TC) suspension 
proposal, we clarified that the household waste exclusion applies to “all LBP waste generated as a 
result of actions by residents of households (hereinafter referred to as “residents”) to renovate, 
remodel or abate their homes on their own.” 63 FR 70233, 70241 (Dec. 18, 1998). In this 
memorandum, EPA is explaining that we believe lead paint debris generated by contractors in 
households is also “household waste” and thus excluded from the RCRA Subtitle C hazardous 
waste regulations. Thus, the household exclusion applies to waste generated by either residents or 
contractors conducting LBP activities in residences. 
What is the practical significance of classifying LBP waste as a household waste? 
As a result of this clarification, contractors may dispose of hazardous-LBP wastes from residential 
lead paint abatements as household garbage subject to applicable State regulations. This practice 
will simplify many lead abatement activities and reduce their costs. In this way, the clarification 
in today’s memorandum will facilitate additional residential abatement, renovation and 
remodeling, and rehabilitation activities, thus protecting children from continued exposure to lead 
paint in homes and making residential dwellings lead safe for children and adults. 
Memorandum from Elizabeth Cotsworth 
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