Lead is a naturally occurring element found in small amounts in the earth’s crust. Although it has some beneficial uses, it can be toxic to humans and animals causing a range of negative health effects. Lead can be located everywhere in our environment – the air, the soil, the water, and even inside our homes. Most of our exposure comes from human activities including the use of fossil fuels. The past use of leaded gasoline, some types of industrial facilities, and past use of lead-based paint in homes were main sources of exposure. Lead can affect almost every organ and system in your body. Exposure to lead can cause cardiovascular effects, decreased kidney function, and reproductive problems (in both men and women) (EPA).

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EPA and EPD Letters of Explaination

Attached is “EPAs memorandum on residential waste” and “GA- EPD’s memorandum on lead base paint waste disposal requirements” explaining the rules for lead in residential housing and non-residential projects; reference page 10 of the pdf document for summary for complying with the lead rules for non-residential projects. Projects involving residential housing can be exempted under the hazard waste rules; however the exemptions are based on the locations generator status for hazardous waste, which are regulated by EPA under RCRAs Hazardous Waste Rules.  The residential exemptions will apply for most off campus locations which has a generator status of conditionally exempt, but for campuses with small and large quantity generator status designations the exemption most likely will not apply. Keep in mind that this exemption does not apply to any non-residential facilities or commercial facilities.