12.1 Component Replacement

Replacement is the most complete method — and it is still abatement

Quick Answer: Abatement includes the replacement of painted surfaces or fixtures when the work is designed to permanently eliminate lead-based paint hazards, with dust-lead taken below the action levels, plus all preparation, cleanup, disposal, and post-abatement testing (40 CFR 745.223). HUD's Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing, Chapter 12, treats building component replacement as the most desirable abatement method for the particular component because the LBP leaves the building. It is not a dust-free carpentry job. Scoring, unscrewing, and prying still load the room. Restricted practices in 745.227(e)(6) still apply. The old sash is waste, not salvage for another unit.

Chapter 5 already sorted design: this chapter is the method. Replacement means you take the LBP component out and, in almost every occupied dwelling, install a new lead-free component. The owner may choose to remove certain components without putting anything back if the code still allows the opening — a rotting LBP shutter can come off and stay off — but the exam picture is a new window, a pre-hung door, or new trim. The method is permanent because the painted surface is gone, not because someone promised to watch it for 20 years.

Enclosure (Section 12.2) and encapsulation (Section 12.3) leave the LBP in place behind a barrier. Paint removal is Chapter 13. Do not strip a friction sash in this chapter's work order just because the crew owns a heat gun. Choose replacement when the surface will keep grinding, slamming, or taking teeth after any coating you leave behind.

HUD Chapter 12 is a documented methodology under 745.227(a)(3) for how to take a component out. It does not rewrite 745.223. Wallpaper, ordinary paint, and contact paper are not replacement, not enclosure, and not encapsulant-as-abatement. Grass and mulch are not this chapter; they fail permanent covering of soil (Chapter 15).

Why friction, impact, and chewable surfaces prefer replacement

Chapter 6 defined the three special paint-lead hazards. Replacement is how you retire the machine that makes the dust, not just the film on one face.

Windows are the jobsite picture. A double-hung sash slides in painted jambs. Dust drops onto the interior window sill and into the trough. Encapsulating an operable friction pair asks the sash to sand the encapsulant off. Wet-scraping the sash and leaving the jamb in service reloads the sill the first time someone opens the window for air. Component replacement — full unit, or new sash plus enclosure/wrap of remaining jamb with back-caulk — is the method that stops the abrasion.

Read the inspection report the way Section 5.2 taught: sash, head, jamb, sill or stool, trough, and casing are separate components. Replacing sashes and leaving an LBP trough is a different job from replacing the assembly. The work order that says "do the windows" is not a method until you unpack those pieces.

Doors. Typical replacement is a pre-hung unit. HUD notes the old jamb is often left and enclosed by the new jamb after back-caulking, with coil stock or extensions covering any remaining face. If a pre-hung unit is not allowed (code or historic rules), remove and replace the original jamb so no LBP friction surface remains. If the jamb cannot come out, the stop comes out and the old jamb is stripped — that strip is Chapter 13, not a reason to torch the hinges free.

Trim. Baseboards, casings, stools, aprons, chair rails, and crown are named components. They are the chewable and impact zone at child height. Replacement is straightforward carpentry: score, pry, wrap, vacuum the void, install lead-free trim. Back-caulk new trim that lands on enclosed walls so dust cannot migrate through the joint.

Worked example — living-room double-hung. Risk assessment: operable LBP sashes, sill wipe reportable, teeth marks on the soft-wood stool. Methods: (1) encapsulant on the sash — unsuitable friction and chewable; (2) wet-scrape sash and jamb, ordinary latex — interim, and the pair still grinds; (3) replace the window unit and the stool. (3) is the abatement that matches the hazard. Containment still goes up. Clearance still happens.

Worked example — kitchen remodel paper. Owner wants energy windows in a 1968 duplex with no permanent-elimination contract. That is not this method under 745.223 paragraph (4); it is remodel (Chapter 5). The same physical window swap is replacement-as-abatement when the contract is designed to permanently eliminate the friction hazard and take dust below action levels.

Replacement still makes dust at the cut and the screw

Do not sell replacement as "no lead work because we are not scraping paint." HUD's step list is the dust-control sequence a supervisor runs:

1. Prepare the work area (Chapter 10 interior / Chapter 11 exterior). Plan how the new component will go in — energy-efficient windows and doors when feasible.
2. Turn off and disconnect electrical circuits inside or near the piece. Do not mist a live or even a just-de-energized cavity with water.
3. Lightly mist the component if circuits are not nearby.
4. Score all painted seams with a sharp knife so the pry bar has a path and the film does not tear in sheets.
5. Remove screws, nails, and fasteners.
6. Pry with a flat bar and hammer at each fastener, using a pad so adjoining plaster is not wrecked.
7. Bend back or pull remaining nails. Wrap and seal bulk components in puncture-resistant plastic. Walk them out on plastic-covered paths to a covered truck or a locked waste area.
8. Vacuum the void immediately — there is often more dust behind a casing than on its face. Shovel debris. Bring new lead-free parts into the room only after at least one vacuuming of the dust-generating work.
9. Cleanup (Chapter 14) and clearance by a certified inspector or risk assessor (Chapter 18). Interior action levels on or after January 12, 2026 remain 5 / 40 / 100 µg/ft² (floors / interior sills / troughs).

Restricted practices are not suspended because the scope says "replace, don't scrape." 745.227(e)(6):

Worked example — torch on a painted sash. The crew cannot get a 1928 window out. Someone lights a propane torch on the painted parting bead "just to loosen it." That is open-flame burning of LBP, prohibited on an abatement. Score, mist, pry, or cut the bead. If paint must come off a remaining jamb, that is a Chapter 13 removal with the same restrictions — not a torch.

Same-day door and window swap is HUD's security advice: an empty opening overnight is a theft and weather problem and an occupant-protection problem. Temporary barriers if you cannot finish the opening that day. Exterior window replacement with only exterior clearance still needs polyethylene protecting the interior (HUD Figure 12.2 logic).

The old component is waste — Chapter 17 preview

Replacement does not make the LBP disappear. It moves it. HUD: discarded architectural components must be managed; store them in a secure, locked area; do not sell or release them to anyone who might reinstall them in another dwelling unless all LBP is removed first. Wrapping in durable plastic and taping is the field control that keeps chips off stairs and the truck bed.

Off-site stripping of a removed door or railing is a legitimate paint-removal path (Chapter 13), not a way to skip this chapter's containment. Tell the stripper that LBP is present before it ships. Tag doors so they return to the right opening. Clean all surfaces before reinstall. Off-site chemical sludge and chips are a worker-protection and waste issue — TCLP / D008 and household-exclusion rules live in Chapter 17. Residential LBP architectural debris may qualify for the household exclusion in some jurisdictions; non-residential does not, and states may be stricter. Never dump, never open-burn, never let a salvage dealer pick a painted sash off the lawn.

Kitchen and bath cabinets. Remove them like trim: tape the perimeter, do not wreck the wall LBP you are not replacing, vacuum immediately. Railings (caps, balusters, newels) are chewable and impact components; replace in kind with lead-free stock, or take metal grillwork off-site for contained blasting and reinstall. Exterior siding identified as a lead hazard is more often enclosed (Section 12.2) than ripped off; if you do replace it, protect soil, walkways, window air conditioners, and the interior.

When to choose replacement instead of enclosure or encapsulant

Official sources: 40 CFR 745.223 (abatement includes replacement of painted surfaces or fixtures); 40 CFR 745.227(e)(6) (restricted practices); HUD Guidelines Chapter 12 (building component replacement) as a documented methodology under 745.227(a)(3).