Answer to Question #1827 Submitted to "Ask the Experts"

Q

I am looking for a standard for the disposal of lead aprons. This would be for any lead protective apparel that has failed the visual inspection and then the fluoroscopic inspection.

A

Under the Resource Conservation and Recovery Act (RCRA), the Environmental Protection Agency (EPA) has established regulations for disposal of hazardous wastes. Hazardous wastes are specifically described in the regulations (that is, listed hazardous wastes) or may have a characteristic defined as hazardous (that is, characteristic hazardous waste). The characteristics are ignitability, reactivity, toxicity, and corrosivity. The EPA has developed toxicity characteristics to regulate wastes likely to leach hazardous concentrations through a landfill into groundwater. Lead falls under toxicity characteristic and must not leach more than 5 mg/liter (40 CFR 261.24). The EPA established a laboratory procedure to test whether a product will leach into groundwater at dangerous levels. This procedure is called the "Toxicity Characteristic Leaching Procedure" (TCLP). The procedure is available from the EPA in Publication #SW-846, "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," test method 1311. It is our understanding that lead aprons have powdered metallic lead incorporated into vinyl or man-made rubber. Although we are unaware of anyone who has actually performed the TCLP on lead aprons, individuals who have been contacted by us who are responsible for disposal of hazardous materials at hospitals have concluded that the lead aprons meet the criteria for disposal as a hazardous waste and dispose of them as such.

Kent Lambert, CHP

Cynthia G. Jones, PhD