Regulatory and Policy

Issues for Reuse and 

Remanufacture of Wood 

Materials Coated With 

Lead-Based Paint 

Thomas R. Napier

Robert H. Falk

George B. Guy

Suzan Drodz

United States

Department of

Agriculture

Forest Service

Forest

Products

Laboratory

General 

Technical 

Report

FPL–GTR–164
December 2005

Napier, Thomas R.; Falk, Robert H.; Guy, George B.; Drodz, Susan. 2005. 

Regulatory and policy issues for reuse and remanufacture of wood materials coated with lead-based paint. Gen. Tech. Rep. FPL-GTR-164. Madison, 

WI: U.S. Department of Agriculture, Forest Service, Forest Products 

Laboratory. 6 p.

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Abstract

At present, there is no regulatory or policy guidance at the 

Federal level that permits, prohibits, or qualifies practice 

for salvaging and reusing building materials coated with 

lead-based paint (LBP). This paper describes the current 

regulations and standards relative to LBP in buildings (in 

particular LBP on lumber and timber products), LBP mitigation, and disposal of LBP-containing waste, and the applicability of these regulations and standards to recovering and 

reusing building materials.
Problem

At the Federal level, there is at present no regulatory or policy guidance that permits, prohibits, or qualifies practice for 

salvaging and reusing building materials coated with leadbased paint (LBP), in particular lumber and timber products. 

Regulations and standards relative to LBP in buildings, LBP 

mitigation, and disposal of LBP-containing waste have been 

promulgated by many agencies. These standards define LBP 

differently and for different purposes: the Occupational 

Safety and Health Administration (OSHA 1999) regulates 

lead in regards to worker exposure; the Consumer Products 

Safety Commission (CPSC 2001), the allowable presence of 

lead in consumer products; the Department of Housing and 

Urban Development (HUD 1996), lead in terms of occupant 

exposure in housing; and the Environmental Protection 

Agency (EPA 2001), the outdoor release of lead from various sources. Despite regulatory coverage from these various 

agencies, the applicability of the regulations to recovering 

and reusing building materials is unclear or nonexistent. 

In many cases, this ambiguity creates a disincentive to reusing the high quality materials that are often found under 

paint. Interpretation and common practice are most frequently driven by risk aversion; thus, the most conservative 

interpretation drives policy and practice. The paradigm is, 

if there is no explicit statement that allows a given activity, 

then the activity is not allowed. Distinctions made under 

current regulations influence the economics of recovery and 

potential reuse of painted materials when compared to conventional demolition and landfill disposal of debris. 

It is clearly important to mitigate and remove LBP from human exposure, and, at the same time, protect the natural environment, particularly soils and groundwater. However, the 

current regulations that relate to the building industry 

(issued by the EPA, OSHA, HUD, and CPSC), while serving environmental and human health concerns, de facto encourage the disposal of not only LBP itself but all underlying materials as well. Much of this material would be valuable were it not for LBP. In addition to wasting potentially 

valuable resources, this practice increases the landfill burden and the stress on natural systems to produce more virgin 

materials. Clarification is needed either by modifications to 

existing regulations or development of new regulations.

The inability to recover and reuse wood building materials 

coated with LBP is an important problem nationally because 

of the large volume of these materials that are now and will 

continue to be generated by demolition activities. For example, this problem affects the ability of Federal agencies 

to meet solid waste diversion goals. For the Department of 

Defense, the influx of construction and demolition debris, 

especially from the thousands of wood structures to be 

removed in current and anticipated installation, modernization, and consolidation activities, seriously jeopardizes the 

agency’s ability to meet an established measure of merit for 

40% solid waste diversion. More ambitious goals, such as 

those developed by the California Integrated Solid Waste 

Management Board, target a 50% diversion requirement for 

construction and demolition debris. These goals would be 

more readily met if LBP-coated wood could be recovered 

for reuse.

The objectives of this paper are to describe current regulations for wood materials coated with LBP and to highlight 

the need for guidance in reusing or remanufacturing these 

materials so that human and environmental health are protected. It is not the intent of this paper to suggest that existing regulations regarding LBP be disregarded. Rather, the 

authors hope that specific guidance can be developed that 

addresses the reuse and remanufacture of LBP-coated wood.

Regulatory and Policy Issues for Reuse 

and Remanufacture of Wood Materials 

Coated With Lead-Based Paint

Thomas R. Napier, Research Architect

Department of the Army, Engineer Research and Development Center, 

Construction Engineering Research Laboratory, Champaign, Illinois

Robert H. Falk, Research Engineer

Forest Products Laboratory, Madison, Wisconsin

George B. Guy, Director of Operations

Hamar Center for Community Design, Pennsylvania State University, University Park, Pennsylvania

Susan Drodz, Chemist

Department of the Army, Engineer Research and Development Center, 

Construction Engineering Research Laboratory, Champaign, Illinois
General Technical Report FPL–GTR–164

2

Background

The annual construction and demolition (C&D) debris 

burden for the United States has been estimated at about 

20 million tons from residential demolition, 45 million tons 

from non-residential demolition, and 60 million tons from 

both residential and non-residential remodeling and renovation. In total, nearly 125 million tons of building debris is 

generated each year in the commercial marketplace. About 

27 million tons of this debris is recoverable solid wood 

(Falk and McKeever 2004). An additional 18 million tons of 

solid wood is available in the municipal solid waste (MSW) 

stream. 

In the case of the U.S. Army, this burden is significant. 

More than 2.7 million square meters of surplus buildings 

from the World War II era must be removed, which will 

generate an estimated 26 million tons of debris (Concurrent 

Technologies Corp. 2003). An additional 7 million tons of 

debris will be generated by the replacement of 84,000 family housing units (U.S. Army 2005). Most of these buildings 

are wood framed. In addition, the construction of new facilities frequently requires the demolition of obsolete buildings, which further adds to the debris burden. For example, 

hundreds of enlisted men’s barracks from the 1950s will 

be replaced with new barracks. Demolition of each barrack 

will generate roughly 6,000 tons of debris. These are only 

a few examples that indicate the magnitude of the disposal 

problem facing one agency. Other agencies face the same 

problem.

The C&D debris burden is also felt in the private sector. It 

is estimated that the equivalent of 250,000 residential buildings are demolished each year in the United States, creating 

a significant impact on the C&D waste stream (Carliner 

1996, EPA 1998).

Over the past several years, there has been a groundswell 

of interest in the salvage and reuse of wood materials from 

building removal. Using deconstruction (or dismantlement) 

rather than demolition, this material can be salvaged in 

whole form and reused as lumber for the construction of a 

new building or for remodeling. Alternatively, the lumber 

can be remanufactured into high value building products 

(e.g., flooring, molding, trim). It is estimated that more 

than 1 billion (109) board feet of usable lumber is salvageable from only the residential homes demolished each year, 

representing more than 3% of U.S. annual softwood lumber 

production (Falk and McKeever 2004). 

Most buildings that are candidates for deconstruction were 

constructed during the decades of old-growth timber harvest and contain wood largely unavailable from any other 

source. This old-growth lumber is often of higher quality 

(e.g., higher density, slower grown, fewer defects) than lumber produced today. From a holistic viewpoint, the reuse of 

these materials helps conserve our natural resources, helps 

maintain carbon sequestration and ecological balance, such 

as biodiversity, and can ease harvesting pressure on the 

existing forest resource. 

Approximately 24 million or 25% of housing units in the 

United States have significant LBP hazards. Although renovation or deconstruction in general potentially increases 

short-term exposure to LBP, the level of hazard can be mitigated by safe work practices. The President’s Task Force on 

Environmental Health Risks and Safety Risks to Children 

found that the number of housing units with LBP declined 

by 10 million from 1989 to 1999 solely as a result of renovation and demolition (Jacobs and others 2002). The removal of older homes allows the creation of new lead-free housing (Farfel and others 2003). Farfel and others (2003) also 

found that the traditional method of mechanical demolition 

(a track-mounted excavator), compared with deconstruction, 

increases lead dust within 10 m of the demolition block site 

by more than 40 times during the process of demolition and 

more than 6 times during the removal of debris. Deconstruction, a component removal process, has been found to 

produce the lowest exposure level of any other form of LBP 

removal, including scraping, chemical stripping, and demolition (Reames and others 2001). 

Case studies representing both private (AFCEE 1999, Triangle J Council of Governments 1995) and military (project 

documentation,1 multiple military installations) environments have shown that salvaging or recycling 50% to 90% 

of a building’s content is readily achievable. Keeping tens 

of millions of tons of building debris out of landfills will be 

of significant environmental and economic benefit. Unfortunately, the presence of LBP within much of the Nation’s 

building infrastructure creates a considerable obstacle to the 

salvage and reuse of these materials.

Issues

On one hand, it is desirable to salvage and reuse the high 

quality LBP-coated wood resource. On the other hand, reuse 

must not expose workers and the public to the detrimental 

health effects of LBP. The authors believe that both objectives can be met. However, current regulatory and policy 

stances have institutionalized a disincentive to reuse or 

remanufacture LBP-coated wood materials—not explicitly, 

but through interpretation and common practice. 

The requirements for monitoring and protective measures 

promulgated by the Occupational Safety and Health Administration (OSHA) for all lead-related work may be unnecessarily excessive for deconstruction practices. Initial 

studies have shown that the component removal process of 

deconstruction does not create the same level of exposure as 

do other lead removal activities (Reames 2001).

1 Project documentation for deconstruction at Fort Carson, Colo- 

 rado; Fort Gordon, Georgia; Fort Knox and Fort Campbell, Ken- 

 tucky; Wright Patterson Air Force Base, Ohio; Fort Monroe, 

 Virginia; Fort Hood, Texas; and Fort McCoy, Wisconsin.
3

The intended destination of the material must be considered. 

The Resource Conservation and Recovery Act (RCRA) of 

the Environmental Protection Agency (EPA) defines waste, 

including what materials qualify as solid waste. However, 

because reuse (e.g., giving or selling a building material 

containing LBP to another party) is not focused on waste 

generation, it is not covered under the RCRA. In 1998, the 

EPA Office of Toxic Substances proposed a regulation that 

would prohibit the resale of LBP-containing items or require 

a warning label upon resale. To date, however, this proposal 

has not been accepted and therefore has no force of law.

Another consideration is whether a waste is hazardous. 

Some hazardous wastes are specifically defined in regulations, based on their origin or nature, while others only qualify as hazardous when they meet a particular characteristic, 

the criteria for which are defined in the rules. In terms of 

LBP, the most important characteristic is toxicity, as defined 

by the presence of certain toxic materials at regulated levels. 

The toxicity characteristic is determined through the use of 

the Toxicity Characteristic Leaching Procedure (TCLP), a 

test under which materials are ground up and exposed to an 

acidic solution to simulate landfill conditions and leaching. 

If a material leaches out 5 mg/L or more of lead after application of the TCLP, it is considered a hazardous waste.

To properly determine whether a waste is hazardous requires 

answering some intermediary questions. First, what constitutes a representative sample of the waste? This is a difficult 

question to answer when considering a building, which is 

composed of a wide variety of materials. The applicability 

of the TCLP test and its ability to characterize something 

as varied and heterogeneous as a building is, in itself, problematic. More fundamentally, if some building materials 

are not destined for the landfill and are to be reused, is the 

TCLP test, which is designed to simulate landfill conditions, 

applicable to qualify these materials? Furthermore, should 

the definition of hazard be based on materials salvaged from 

the building, on the materials destined for the landfill after 

salvaging, or on a broader sample of the building materials? 

The answers to these questions can determine whether the 

“building and/or its contents” are classified as hazardous or 

non-hazardous solid waste, and if deconstruction and salvage of associated material are appropriate. 

If a waste is determined to be hazardous, guidance is also 

needed regarding its “point of origin,” or the point at which 

it was generated. For example, the point of origin could be 

when painted siding is removed from a building, or when 

the painted surface of that board is planed off in a remanufacturing process. The operation of removing the siding 

could be an entirely different procedure from remanufacture, 

both from a business standpoint and geographically. Who 

becomes the responsible party and therefore manages the 

hazardous waste for proper disposal?

It is not always clear how to proceed when trying to salvage 

LBP-containing materials, especially LBP-coated wood. If 

lumber removed from a structure has a lead level exceeding 

the TCLP threshold, the wood could be classified as hazardous waste. The question is, must that lumber be disposed 

of as hazardous waste or is it hazardous waste only if it is 

introduced into the waste stream? It is also unclear what, if 

any, regulatory guidance governs the handling and reuse of 

LBP-coated lumber. Uncertainties include (1) whether it is 

permissible to reuse the painted lumber and, if so, what precautions must be taken; (2) whether the paint must be removed prior to reusing the wood and, if so, what lead levels 

are permissible in the lumber once the coating is removed; 

(3) how residual wood shavings and paint should be handled 

and disposed of; (4) whether the lumber (either painted or 

unpainted) can be transferred from one party to another and, 

if so, what information or disclosures should accompany 

transfer; and (5) what, if any, exemptions or restrictions 

may apply to a salvage and reuse scenario at the individual 

household level.

There is also the issue of debris. If clean lumber is removed 

from the debris of a building, the remaining debris may exceed the TCLP threshold because of an increase in the ratio 

of lead to clean debris, potentially triggering the definition 

of hazardous waste. Unfortunately, this situation creates a 

disincentive to resource recovery and conservation. The total amount of lead entering the waste stream will not differ, 

regardless of whether the clean lumber is removed. However, the reluctance to risk the characterization of the debris 

as hazardous drives the practice of disposing of the whole 

building; that is, allowing clean reusable materials to dilute 

the debris to a non-hazardous level. 

The reprocessing and reuse of LBP-containing materials 

requires clear guidance on how to do so properly, legally, 

and safely. At present, this guidance is unavailable. What 

guidance is available is not applicable in the context of recovering and reusing building materials. 

Regulations govern LBP in housing where children most 

vulnerable to the hazards of lead (children under age 6) are 

present. This is referred to as “target housing” and “residential dwelling or child-occupied facility.” These regulations 

apply to a very narrow definition of the environment. In 

the context of target housing, LBP hazard is defined as a 

condition where paint dust is generated by friction or impact 

(such as at windows and doors) and as deteriorated paint 

that is detached from the surface and available for ingestion 

by children (EPA 2001). The paint is defined as not being a 

hazard if it is in good condition and not subject to friction or 

impact. 

Further, when a residential structure constructed prior to 

1978 is sold or leased, the potential for the presence of LBP 

must be disclosed to the buyer or renter (HUD/EPA 1996). 

If LBP testing has been conducted, the results must be disclosed. This rule does not require testing or mitigation of 

LBP—only that the buyer or renter acknowledge the receipt 

Regulatory and Policy Issues for Reuse and Remanufacture of Wood Materials Coated With Lead-Based Paint
4

of the disclosure and is given an opportunity to perform 

their own inspection before committing to the sale or lease. 

The required language for this disclosure includes reference 

to the EPA pamphlet “Protect Your Family from Lead in 

Your Home” (EPA/CPSC/HUD 2003). 

The CPSC has established a limit on the lead content in 

consumer paints as 0.06% by weight (industrial and other 

specialty paints are exempt). This limit applies to the lead 

content of paint on toys, furniture, and other household articles to which children may be exposed (CPSC 2001). This 

limit was established to correspond to the maximum allowable amount of lead a child might ingest per day without 

inducing serious health problems (limit = 15 μg). While lead 

can also be hazardous to adults, it is clear that the intent of 

the lead content limitation is to protect children from health 

hazards associated with ingesting lead. These precautions 

ought to apply to any environment in which children are 

present, even though this is not explicitly stated in the regulations. What is not clear is how, if at all, these regulations 

apply to salvaging materials from one structure and reusing 

them in another structure and in associated processes, such 

as remanufacturing, transportation, and handling. 

Because no clear guidance is available, agencies such as the 

U.S. Army are reluctant to remove LBP-coated materials 

from military installations and reuse them in local communities. The preference is to put LBP-coated debris in the 

landfill debris, in the belief that this is the only safe place 

for it. The primary motivation is that someone, sometime, 

will suffer harm, and the Army will be held liable. This conservative and protective posture is not misplaced. However, 

it is borne out of uncertainty instead of explicit guidance.

Regulations are also in place to protect tradespersons and 

workers from lead hazards. Of particular interest in the context of construction and materials reuse are the Safety and 

Health Regulations for Construction, published by OSHA 

(1999). While not explicitly directed toward lead mitigation 

activities, these regulations address environments where 

elevated levels of airborne lead-containing dust are present, 

which require similar mitigation activities. Worker protection requirements assume the worst exposure. Protective 

measures may be reduced only when actual exposure levels 

are below the specified thresholds as verified by monitoring. However, air monitoring conducted during deconstruction projects indicates that actual airborne lead levels have 

historically been trace amounts, or even non-detectable 

(Reames 2001; personal correspondence from George H. 

Thomas III to Thomas R. Napier, April 5, 2002). Yet, OSHA 

regulations require full personal protective equipment to be 

used on every project until it is proven such protection is not 

required. While it is always appropriate to err on the side of 

safety, such measures might add an expense to deconstruction activities that may not be warranted.

Suggested Actions

Ongoing research is helping to define the real risks in the 

remanufacture of LBP-coated wood (Falk and others 2005, 

Janowiak and others 2005). The authors of the work reported here suggest that the EPA, in collaboration with other 

regulatory agencies, provide clear guidance on appropriate 

methods and practices for salvaging and reusing LBP-coated 

building materials, specifically LBP-coated lumber and 

timber materials. Important issues include (1) removing 

LBP-coated materials from a structure, (2) handling painted 

materials, (3) processing painted materials, which may also 

include removing paint and remanufacturing the material 

into other products, (4) disposing of waste and residual paint 

materials, (5) transferring ownership of the materials (with 

and without LBP), and (6) reusing the materials in another 

structure or other use. 

Such guidance may involve issuing clarifications or qualifications to existing guidance, revising existing guidance, 

and/or developing new guidance, specifically within the 

context of the salvage and reuse of building materials. Specific elements of concern include the following:

 • Clarify whether materials recovered from building removal through deconstruction and intended for reuse or 

remanufacture are regulated waste. If so, what agency 

should be responsible for regulation? 

 • Clarify and make consistent the methods for analyzing 

buildings for LBP content. Clarify whether TCLP is 

the appropriate method to determine whether materials 

generated in building removal are hazardous, both those 

materials intended for the landfill and those intended 

for reuse. 

 • Clarify whether removing clean building material alters 

the characterization of the remaining building debris, 

even though the total amount of lead is not altered.

 • Clarify whether the LBP hazard in “target housing” applies to salvaging and reusing LBP-coated building materials. In the context of building material salvage and 

reuse, clarify what conditions create and do not create 

a LBP hazard and what conditions allow or prevent the 

transfer of materials from one party to another. Develop 

appropriate disclosure language, processes, and precautions that must be taken when removing, transporting, 

remanufacturing, and reusing LBP-coated building 

materials.

 • Establish reasonable requirements for warning labels or 

markings that follow a consistent format and are based 

on realistic scenarios of reuse. For example, does the 

reuse of a painted wood stud as wall framing (normally 

enclosed within wall cavity and not accessible to direct 

contact) require the same level of concern as a salvaged 

window painted with LBP?

General Technical Report FPL–GTR–164
5

 • Consider and address issues of legal responsibility regarding the reuse of underlying wood materials once 

the LBP coating has been removed through remanufacture. Clarify the chain-of-custody responsibility for 

future removal, salvage, reuse, or demolition.

 • Quantify the acceptable lead content of materials reprocessed from LBP-coated wood materials. Distinguish 

between the amount of lead allowable on the material’s 

surface (similar to a coating or film) and in the body of 

the material.

 • Examine the actual worker exposure to LBP in the removal of coated wood components in light of the fact 

that isolated case studies have found no exposure in the 

absence of grinding, sanding, burning, breaking, etc. 

Provide better definition within OSHA regulations for 

destructive mechanical or manual removal processes, 

manual removal processes for salvage, and protective 

measures required for each process based on actual onsite conditions.

 • Collectively and consistently develop guidance and 

regulation for lead exposure, thresholds, and content for 

(1) materials being removed, (2) process of removal, 

(3) materials intended for remanufacture and reuse, and 

(4) materials to be considered hazardous waste. Develop guidance and regulation into a single document 

for ease of implementation.

 • Conduct or sponsor further research in developing costeffective methods and handling of LBP removal from 

wood and by-product disposal.

 • Clarify scenarios where LBP debris from stripping 

of lead from residential sources can be disposed of in 

Class I or III C&D landfills as non-hazardous material, 

when the source of debris (i.e., building materials) is 

considered household waste before the lead is stripped.

 • Establish Best Management Practices for removing 

LBP-containing materials from a structure, handling 

materials, removing paint or conducting other reprocessing or remanufacture activities, transferring materials from one party to another, and reusing the materials, 

either with or without paint coating.

Conclusion

In conclusion, guidance is needed on the appropriate methods and practices for salvaging and reusing building materials coated with lead-based paint. Positive incentives should 

be integrated into the guidelines that encourage the recovery 

and reuse of clean materials while safely disposing of only 

the hazardous portion of the building debris.

References

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