Although excluded from the hazardous waste regulations, EPA encourages residents and 
contractors managing LBP waste from households to take common sense measures to minimize the 
generation of lead dust, limit access to stored LBP wastes including debris, and maintain the 
integrity of waste packaging material during transfer of LBP waste. In particular, we continue to 
endorse the basic steps outlined in the 1998 proposals for the proper handling and disposal of LBP 
waste (63 FR 70242) as the best management practices (BMPs) including: 
• Collect paint chips and dust, and dirt and rubble in plastic trash bags for disposal. 
• Store larger LBP architectural debris pieces in containers until ready for disposal. 
• Consider using a covered mobile dumpster (such as a roll-off container) for storage of LBP 
debris until the job is done. 
• Contact local municipalities or county solid waste offices to determine where and how 
LBP debris can be disposed. 
In addition, contractors working in residential dwellings are subject to either one or both of the 
following: 
• The HUD Guidance for contractors doing publically-funded rehabilitation/renovation 
projects in public housing. (See Guidelines for the Evaluation and Control of Lead-Based 
Paint Hazards in Housing. U.S. Department of Housing and Urban Development, June 
1995) The HUD guidelines can be accessed via the Internet at: 
http://www.hud.eov/lea/learules.html 
• TSCA 402/404 training and certification requirements. (See 40 CFR Part 745; 61 FR 
45778, August 29,1996) and the proposed TSCA onsite management standards (See 40 
CFR Part 745, Subpart P; 63 FR 70227 - 70230, Dec. 18, 1998). [EPA expects to issue the 
final rule next year.] 
The above-mentioned BMPs for households are similar to those included in the HUD Guidelines 
for individuals controlling LBP hazards in housing. HUD requires that contractors using HUD 
funding adhere to LBP hazard control guidelines. Non-adherence to these guidelines can 
potentially result in the loss of funding. 
Does this interpretation apply in my State and/or locality? 
We encourage contractors and residents to contact their state, local and/or tribal government to 
determine whether any restrictions apply to the disposal of residential LBP waste. This 
verification is necessary since, under RCRA, States, local and tribal governments can enforce 
regulations that are more stringent or broader in scope than the federal requirements. Thus, under 
such circumstances, LBP waste from households may still be regulated as a hazardous waste as a 
matter of State regulations. 
We are distributing this memorandum to all 56 States and Territories, and Tribal Programs and 
various trade associations. We encourage States to arrange for implementation of the 
9 B 
Appendix 
