Draft Memo Prepared by Dennis Livingston of Community Resources
28 E. Ostend Street, Baltimore, MD 21230 (410) 727-7837

A memo to people and communities working to solve the childhood lead
poisoning problem and protect workers and the environment in the process.

1. All phosphates, including tri-sodium phosphate (TSP), are so damaging to the environment, particularly lakes and rivers, that more than 19 states and several counties in 15 other states, limit the phosphorous content of household laundry products to 0.5% (this is assumed to be a virtual ban). The Material Safety Data Sheet (MSDS) from Rhone-Poulenc1 states; “Do not flush material into public sewer system or any water way.”2

2. TSP leaves a phosphate film on surfaces that if not thoroughly rinsed will cause adhesion failure and/or blistering of new paint or encapsulant. Experiences with workers performing lead abatement activities in residential properties suggest that it is very difficult to have them clean every surface. Imagine also requiring the complete rinsing at all surfaces to remove the difficult to rinse phosphate residue so that new paint or encapsulant will adhere.

3. Phosphate mixed with lead can form a compound known as lead-phosphate –Pb3(PO4)2. Any of the many slightly soluble lead compounds can react with phosphate in solution to form lead-phosphate which can precipitate out of solution as a residue. The Merck Index 11th edition states about lead-phosphate; “This substance may reasonably be anticipated to be a carcinogen.”3

4. Skin, eye or respiratory contact with tri-sodium phosphate is hazardous. The hazardous material identification system rates hazards as follows:




Tri-sodium phosphate, TSP or tri-basic, is rated 3 high/serious4 (sodium phosphate anhydrous is also rated 3, high/serious).

The section “Effects of single overexposure” on the sodium phosphate anhydrous MSDS5 reads in its entirety:


Precaution: Persons attending the patient should avoid direct contact with heavily contaminated clothing and vomitus. Wear impervious gloves while decontaminating skin and hair.
Swallowing: Symptoms of swallowing are burning pain from mouth to stomach. May cause irritation or corrosion of the mouth, throat, esophagus and stomach, including blistering of the mucous membranes. Aspiration of the swallowed product or vomitus can cause severe pulmonary complications.
No information is available regarding absorption of the product through the skin, but deep penetrating burns are caused by contact with the product.
Inhalation: Inhalation of dust may cause irritation or burns to the nose, throat or respiratory tract, resulting in cough, chest pain and difficult breathing.
Contact with the dry solid or solutions may cause severe irritation or burns if not washed or removed from the skin promptly. Irritation is likely to be severe if the skin is moist or wet. Contact with concentrated solutions may cause severe irritation or burns depending on the concentration of the product and duration of the contact.
Contact with the dry solid or solutions may cause severe irritation or burns. The possibility of severe eye damage exists if concentrated solutions are splashed into the eyes and not promptly and properly treated.


 5. The MSDS sheet for Cascade automatic dishwashing detergent states that the product contains sodium phosphates. The MSDS assumes “normal handling procedures.”6 In a call to Procter and Gamble’s consumer service number on 10/23/96 about Cascade, the consumer service technician stated that P&G “Definitely does not recommend the use of Cascade dish-washing detergent in the cleaning of a home or any use outside its intended use in a dish-washer receptacle or for soaking dishes.”

6. Based on the experience of many contractors, and a study by the Canada Mortgage and Housing Corporation, using phosphates for lead clean-up is not necessary. In fact, using a lead-specific cleaner proved more effective.

The following are summaries of the four protocols tested in the Canadian Study Evaluation of the Clean-up of Lead Paint Dust in Houses.7


Method 1
Floor swept then, Vacuumed with utility vacuum cleaner
Method 2
Floor vacuumed with household vacuum cleaner then, Mopped with “Mr. Clean” using a sponge mop in a single bucket

Method 3
Floor vacuumed with a utility vacuum cleaner then, Mopped with Ledizolv® (LSZ, Inc., New York) using a sponge mop in a single bucket

Method 4
Floor cleaned with a HEPA vac then, Mopped with TSP applying the TSP with a garden sprayer and the mop head wrung out in a separate bucket then, The floor rinsed with mop using water applied with garden sprayer and mop then, Again vacuum floor with HEPA vac



The following conclusions are made based on the data collected in this project.

  1. “Cleaning of lead paint dust by either i) broom cleaning and a utility vacuum, or ii) household vacuum, followed by mopping with a household cleaner, will not meet either the current or proposed HUD clearance criteria.” These two methods represent the cleaning procedures commonly available to householders.
  2. “Cleaning of lead paint dust by either i) a utility vacuum followed by LEDIZOLV® and rinsing, or ii) HEPA vacuum cleaning, TSP cleaning, rinsing, and HEPA vacuuming, will likely reduce floor concentrations of lead levels to levels below both the current and proposed HUD clearance criteria c.”

NOTE: Using LEDIZOLV®( method 3) achieved the same standard as method 4 in spite of the fact that:

  1. Method 3 used a utility vac, method 4 used a HEPA vac
  2. Method 3 vacuumed once, method 4 vacuumed twice
  3. Method 3 contaminated detergent by wringing out mop in detergent, method 4 kept detergent uncontaminated by applying it with a garden sprayer.
  4. Method 3 rinsed with one bucket, method 4 used garden sprayer to rinse


1 Published summary of Phosphate Legislation from the Soap and Detergent Association dated 3/20/96

Rhone-Poulenc Basic Chemicals Company, 1 Corporate Drive, Box 881, Stelton, CT 06484 (203) 925-3300 — MSDS dated July 13, 1992

Fourth Annual Report on carcinogens (NTP 85-002) page 121

Rhone-Poulenc Basic Chemicals Company, 1 Corporate Drive, Box 881, Stelton, CT 06484 (203) 925-3300 — MSDS dated July 13, 1992

Lidochem, Inc., 20 Village Court, Nazlet, NJ 07730 (908) 888-8000 — MSDS dated 1/14/92

Procter and Gamble, laundry & cleaning products division, Ivorydale Technical Center, Cincinnati, Ohio 54217 5/93

7 “Evaluation of the Clean-up of Lead Paint Dust in Houses,” Canada Mortgage and Housing Corporation, Research Division, 700 Montreal Road, Ottawa Ontario, Canada K1A-OP7, May 5, 1995