Environmental Assessment

Lead in Paint

Lead is a natural metal found in the ground through mining. The mineral can occur in various products such as gasoline, paint, batteries, ceramics, etc. This article enlightens the most significant aspects of lead in paint.

What is Lead in Paint?

Essentially, it is lead compounds added to paint. Regulations and standards are in place in many countries to limit lead levels in paint. However, it is not the case worldwide, as some countries still have lead in paint at hazardous levels.

Historical Use of Lead in Paint

Lead compounds help with the

  • durability;
  • freshness;
  • moisture resistance;
  • and drying of paints.

Significantly, paint containing lead was the main type of paint used for house exteriors between 1960 and 1990.

Afterward, buildings constructed after 1990 in the U.S and Canada paint had to be lead-free, because of public health concerns.

Lead in paint

The Hazard of Lead in Paint

  • Human Health Hazard

Paint removed, repaired, or torn from basic home renovation is susceptible to exposing one to lead dust. Such exposition can cause serious health issues such as anemia or brain cell damage. Moreover, children exposed to harmful lead levels can suffer from cognitive, IQ loss, and vital organs damages.

 

  • Environmental Concerns

Lead-containing paint removed from a building and released into the environment is likely to mix in with soil and water. Harmful levels of lead in nature results in decreased plant growth and the decline of animal reproduction. Likewise, it generates neurological deficits in vertebrates.

CPSIA US CFR 1303 - Ban of Lead-Containing Paint and Consumer Products Bearing Lead-Containing Paint

Various painting

CPSIA US CFR 1303 in a Nutshell

Lead has been removed from the paint to safeguard customers and the environment. The instruction was issued by the United States Environmental Protection Agency (EPA) in 1978. As a result, on February 27, 1978, the Consumer Product Safety Improvement Act (CPSIA) U.S. Code of Federal Regulations (CFR) 1303 Ban on Lead-Containing Paint was first issued.

The hazardous lead level in paint was initially at 0.06 percent of the weight of the dried paint film. However, the 2009 amendment reduced the accepted level to 0.009 percent.

The Scope

  • Application of CFR 1303

Part 1303 of the ban aims at eliminating any risk of lead poisoning. As a result, it addresses consumer products potentially containing lead paint. Examples are:

  • toys, other articles for children’s use;
  • furniture, i.e., movable articles, like chairs, bookcases, tables, pianos, etc.

However, the term furniture does not apply to home appliances, such as refrigerators, clothes washers, dryers, air conditioners, etc. Other regulations target such appliances, like California RoHS.

  • Exemptions from CFR 1303

A whole list of products remains exempt from the CFR 1303 Ban. Indeed, any agricultural and industrial equipment and building coating are out of scope.

Moreover, graphic art coating used for industrial purposes, artist paints, and metal furniture are exempted from this ban or have their exemptions.

Importantly, these exempted applications must bear a label wording that they contain lead at hazardous levels.

Label lead content in paint

Other Lead Control Policies

The Scope and Exemptions of Lead in Paint

REGULATION

SCOPE

LIMITS

EXEMPTIONS

U.S. CFR 1303

Toys, articles for children's use, and furniture articles containing lead paint; furniture, meaning movable articles.

0.009 percent of the weight of the dried paint film.

Agricultural, and industrial equipment and building coating.

California Proposition 65

Proposition 65 requires businesses to provide a clear and reasonable warning before exposing consumers to any of the listed chemicals.

0.5 micrograms of lead per day (µg/day) exposure for developmental, female, and male toxicity.

Businesses with nine or fewer employees; Exposures that pose no significant risk of cancer; etc.

Canada Consumer Product Safety Act

(CCPSA)

Toys, children’s articles, carriages and strollers, cribs, cradles, and bassinets; and all toys for children under 3 years of age.

Every accessible part of a consumer product containing lead must not contain more than 90 milligrams of lead per kilogram of the product (90 mg/kg).

Every accessible component may have a lead content of more than 90 mg/kg if:

No substitute part containing less lead is available, lead is required to generate an important property of the part, and the part releases no more than 90 mg/kg of lead when tested in line with appropriate laboratory methods.

China RoHS

Electrical and electronic equipment

0.1 % at the level of the homogeneous materials.

Obligation to declare above the threshold.

REACH candidate list of SVHCs and Annex XVII list

Addresses chemicals in any substance, preparation, mixture, or articles.

0.05% is applied to articles and accessible parts that can be mouthed by children;

Obligation to communicate lead and lead compounds above 0.1% at the part level;

In jewelry articles and in articles or accessible parts that may, during normal or reasonably foreseeable conditions of use;

Lead and lead compounds (Lead carbonates (Trilead-bis (carbonate)-dihydroxide 2PbCO3-Pb (OH)2, Neutral anhydrous carbonate (PbCO3 )), Lead sulfates (Sulphuric acid, lead salt PbSO4, Lead sulfate PbSO4)) are banned in paints. 

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EU RoHS

Electrical and electronic equipment, and spare parts. For more information, please see Enviropass’s EU RoHS scope page.

0.1 % at the level of the homogeneous materials.

Please see the RoHS Exemption Annexes for more information.

How to Know if your Home contains Lead Paint?

There are many ways to meet the lead restrictions in paint and thus respect CFR 1303 ban. As mentioned above, the year your house is from is the first indicator of whether the paint on its walls is at risk of containing lead.

Analytical Testing

One way of knowing is with analytical testing. It is possible to send a sample of paint to specialized labs. Also, some contractors can analyze paint with X-ray equipment.

Paint containing lead

How to Meet the Lead Restrictions in Paint?

The latter also applies to producers. You can determine if paint satisfies the standards by analyzing dried and wet paint.

No Dilution

Diluting paint that contains lead is not permitted. If you are a paint producer, you must meet the CFR 1303 requirements.

Substitutes for Lead

Substitutes of lead-based paints include:

  • Red oxide (Iron (III) oxide or ferric oxide);
  • Zinc phosphate primers;
  • Activated zinc primers;
  • Alkyd primers;
  •  Etc.

Approved Lead-Free Paints

audit Enviropass

Other ways to confirm that your purchased products meet the CFR 1303 requirements include:

  1. Verifying the risk of non-compliance in your product materials;
  1. Auditing your supply chain accordingly; gathering and archiving manufacturers’ Certificates of Compliance and Safety Data Sheets (SDS).

Such information should ideally be requested when submitting orders.

In conclusion, meeting the CFR 1303 lead-ban requirements is mandatory. As a producer, you should make or use compliant paints. Finally, a robust management system, like ISO 14,001, can help you develop diligent practices and avoid the risks of violations.

If you have any other questions or concerns about lead in paint, Enviropass can assist you with the audit. Contact Enviropass, we are here to help you!