Window Replacement Requires
Lead Testing and RRP Practices
The EPA has put window replacement on the list of the most dangerous sources
of lead dust along side belt sanders and heat guns. Under RRP’s 6 sqft rule,
which allows ignoring of lead safe practices in a target house, the lone exception
is window replacement. Even the press targets lead painted windows, evidenced
by the powerful article in USA Today (go to
http://www.usatoday.com/news/health/2007-10-28-lead-cover_N.htm). 
Program money for lead removal is earmarked far more for window 
replacement than for siding, roofing, or other supposed lead paint “hot spots”.
Part of the lead dust study conducted by the EPA shows far greater dust creation
than all the other projects except high power heat gun and power planning:
Dust lead levels (in g/ft2):
• Cut-outs--422. 
• Kitchen cabinet removal--958. 
• Low temperature heat gun--2,080. 
• Dry scraping--2,686. 
• Window replacement--3,993. 
• High temperature heat gun--7,737. 
• Power planing--32,644. 
When the jobs were done, the residual lead dust followed the same order with
window replacement only surpassed by heat gun use (which is banned) and
power planning (which is restricted). Why are windows so much 
trouble? There are three primary reasons:
1. More sources of lead paint are on windows. Due to the durability of
lead paint and its weatherability, approximately three-quarters of the homes built
before 1978 contain some lead-based paint most commonly found on exterior-
painted surfaces, doors, and windows- almost 2 to 1 over interior lead paint
sources.  And, because windows bridge outside to inside, lead based paint coated
windows bring the lead paint to the inside surfaces.
2. Moisture absorbed bubbles the paint, creating chips. Lead paint
has never been the culprit. Lead chips (which kids eat) and lead dust (which
everyone breathes) are the culprit. Years of rain, moisture and weathering have
allowed old wood windows and trim to absorb moisture. And just as lead paint
kept out the moisture, it also traps the moisture in the wood. This causes even-
tual breaking of the bond, paint bubbles, eventual paint cracking as it dries, and
the creation of lead paint chips.
3. Opening and Closing of Windows is like a pepper grinder. Repeated
opening and closing of sliding windows (vertical or horizontal) will grind the paint
chips into dust, day after day. One only needs to look into the trough of a window
to see the result.So it is not hard to imagine disturbing even the smallest amount
of surface area on an old window can create the very dust and debris that the
Toxic Substances Control Act (TSCA) of the early 1990’s labeled as poisoning
children and threatening the health of the workers doing window replacement.
Kids Love Lead Dust.
Opening and Closing
Constantly Grinds Lead Dust
Old Paint makes Lead Chips
If a Packet of Sweet ‘n’ Low 
were Lead Dust, it could 
contaminate 10 homes.
Window Fitters Guide to Window Installation 
140                ©2022 AWDI, LLC Do not reproduce without permission
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