Does old playground equipment have lead paint?
The 1978 ban dates the paint you can buy, not the paint on the equipment. CPSC staff told owners how to sort one from the other in 1996, and the method still holds.
Short answer
Often, if it was painted before 1978. CPSC staff found lead above the federal limit on equipment at 20 of 26 older playgrounds they tested. Assume any surface not repainted since 1977 contains lead, and treat later repaints as suspect unless records show lead free paint. Intact paint is monitored. Flaking paint is sampled for a laboratory, and deteriorating paint at 0.5 percent lead or more gets controlled first.
On this page
The short answer
If the equipment was painted before 1978, it probably has lead paint, and the first paint on it is the one to worry about. CPSC staff tested older equipment at 26 public playgrounds in 13 cities in 1996 and found paint above the federal 0.06 percent limit at 20 of them. Sixteen had paint at 0.5 percent lead or more, ranging from 0.62 to 8.76 percent, with a median of 1.47 percent1. Where its age was reported, the equipment was 14 or more years old, and in four of five cities it was 25 to 45 years old1.
The rule CPSC staff gave owners is the one to use: any painted surface that has not been repainted after 1977 should be assumed to contain lead. A repainted surface stays suspect unless records show lead free paint was used, because the original coat is still underneath1.
Lead in the paint is not yet a hazard. Staff did not consider intact paint in good condition one. It becomes a hazard when sunlight, heat, moisture and wear break it into chips and dust that children six and under get on their hands and then into their mouths1. So condition, not just age, decides what you do.
Why "after 1978" does not settle it
One answer says the 1978 ban makes anything newer safe; another says lead turns up on equipment of any age. The second is closer to right.
The ban itself is broad. It covers paint for consumer use, toys and other articles intended for children, and paint used in "parks, playgrounds, and public buildings or other areas where consumers will have direct access to the painted surface", for products made after February 27, 19783. CPSC staff named playground equipment as one of the children's articles it covers1. How that ban sits beside the voluntary playground standards is set out in CPSC, ASTM and the standards.
What the date cannot tell you is what is on the structure now. A frame from 1970 repainted in 1990 has lead free paint over leaded paint, and the old layer becomes reachable again as the new one peels. That is why CPSC staff treat repaints as suspect without records1. Nor is a fresh coat proof. A 2016 survey of public playgrounds in south west England found lead in 102 of 242 painted surfaces, up to 152,000 micrograms per gram, in both flaking paint and paint that appeared recently applied9.
| Paint history | Treat it as |
|---|---|
| Original paint, structure built before 1978 | Contains lead |
| Repainted after 1977, no records of the paint | Suspect: leaded layer likely underneath |
| Repainted after 1977, records show lead free paint | Lower risk; original layer may still be leaded |
| Original factory paint, built after February 27, 1978 | Subject to the federal ban |
| Unknown age or history | Contains lead until a laboratory says otherwise |
Colors give a hint, not an answer. CPSC staff found red, orange, yellow, green and brown the colors most likely to contain lead1, and the English survey found its highest lead levels mostly in yellow and red paints9.
Which lead number applies
Mixing up these figures is why owners get conflicting answers from testers.
| Figure | What it is | Source |
|---|---|---|
| 0.009% (90 ppm) | Most lead allowed in consumer paint and children's products since August 14, 2009 | 16 CFR 130334 |
| 0.06% (600 ppm) | The limit from 1978 to 2009, used in the 1996 playground study | 16 CFR 13033 |
| 0.5% by weight, or 1.0 mg/cm² | "Lead-based paint" for hazard control; the CPSC staff priority level | 40 CFR 745.1036 |
| 400 ppm in bare soil | Soil-lead hazard in a play area | 40 CFR 745.657 |
The 0.5 percent figure comes from the 1992 Residential Lead-Based Paint Hazard Reduction Act; CPSC staff used it because EPA and HUD do1. Paint can be 50 times over the 90 ppm consumer limit and still sit below 0.5 percent, which matters when you read a test result.
How to test, and why kits mislead
Laboratory analysis of paint chips is the method CPSC staff recommend, by an accredited laboratory using a standard method for total lead1. Collect from several locations, one sample for each type and color of paint, and ask the laboratory whether a trained professional must take the samples1.
| Method | What it can tell you | Limit |
|---|---|---|
| Accredited laboratory | Lead content, percent by weight | Needs chip samples, so a small area is disturbed |
| Portable XRF analyzer | A screening reading | CPSC staff (1996): unreliable on curved surfaces; confirm with a laboratory |
| EPA-recognized kit | That paint is not at 0.5% or more | Wood and steel only; trained user; never confirms lead |
Kits are where advice splits. In 1996 CPSC staff found they did not reliably tell leaded from lead free paint1, and CPSC did not recommend them on playground equipment2. EPA now recognizes three kits, but only for a negative result, only in the hands of a trained professional or certified renovator, and two of them only on wood and ferrous metal. No kit has met EPA's standard for positive results5.
So on a steel frame, a recognized kit can tell you the paint is probably below 0.5 percent. It cannot show the paint is below 90 ppm, cannot confirm lead, and is not recognized on aluminum. If the answer will decide money or sanding, pay for the laboratory.
What to do with the result
The CPSC staff strategy is a short decision tree1.
- Paint intact, no chips or dust, no repairs planned. Monitor it by visual inspection, folded into your regular safety checks, or test it. Staff did not think testing intact paint was necessary. If testing confirms lead, keep monitoring.
- Paint deteriorating. Sample it and send it to the laboratory.
- Deteriorating paint at 0.5 percent lead or more. Control it, as the priority.
- Between 0.06 and 0.5 percent. Owners "may consider" controls; staff called this a reduced priority, but important.
On a public site, monitoring fits the inspection schedule you already run: daily and weekly checks catch fresh flaking, and the annual audit records each painted component's condition. File the laboratory reports with the equipment, as records and documentation describes.
For parents, the CPSC release gave three steps: look for deteriorating paint, ask the owner to test it, and keep children's hands out of mouths and washed thoroughly afterward2. Cleaning and sanitizing covers the hand washing habit, and checking a playground as a parent the rest of the walk.
Cover it, strip it, or replace it
CPSC staff split the controls into interim and permanent1.
Interim: cover it. Stabilize the surface and coat it with lead free paint or an encapsulant, for equipment due for replacement within a few years. Outdoors it wears through, so it needs monitoring for life. Encapsulants were developed for interiors, and on metal prone to rust they are generally not effective without a corrosion-control primer1. If the frame is already rusting, read corrosion and rust first.
Permanent: remove the paint. Use a professional who is trained, certified or licensed for lead removal, because doing it badly spreads chips and dust across the play area. Repaint with paint inside the CPSC limit1, which is now 0.009 percent4.
Permanent: replace the equipment. CPSC staff call this the most definitive way to remove the risk1. Run the comparison in replacement or renovation, and ask the state or local health department or environmental agency about disposal rules first1.
At home, a pre-1978 metal frame with flaking paint is usually a removal, which moving or removing a playset covers. If you are shopping, add paint to the checks in buying a used playset.
The ground under it
CPSC staff tell inspectors to check for paint chips under the equipment1. Where chips have been falling for years, the loose fill or soil below has been collecting them. EPA treats 400 ppm of lead or more in bare soil in a play area on residential property, or at a child-occupied facility, as a soil-lead hazard, and 1,200 ppm averaged over the rest of the yard7. Only a soil test tells you which side you are on. Replace fill with chips in it rather than raking it in; surfacing upkeep covers replacing fill.
Where this stops applying
The 1996 study covered older equipment at 26 sites, and 0.5 percent is a priority line, not a safe line1. Its finding that a tenth of a square inch of the median paint, swallowed daily for 15 to 30 days, could reach a level of concern was set against 10 micrograms per deciliter1. CDC's reference value is now 3.5, and CDC says no safe blood lead level in children exists8. The English survey is not a US figure9. Bare galvanized steel, powder coat and plastic are other questions (steel, wood and plastic compared), as is arsenic in old treated wood (CCA treated playsets).
What to do next
Walk the structure and date every painted surface. If any of it predates 1978 and the paint is sound, add it to the inspection list and leave it alone. If it is flaking, keep children off it, send chips to a laboratory, and get a quote for replacement alongside the quote for professional removal before anyone picks up a scraper.
Frequently asked questions
Was lead paint banned on playground equipment in 1978?
Yes. The CPSC ban that took effect for products made after February 27, 1978 covers paint for consumer use, toys and other articles for children, and paint used in parks and playgrounds. CPSC staff named playground equipment as one of those children's articles. The date does not clear a structure, though: a repaint sits over the original coat, so CPSC staff treat later repaints as suspect unless records show lead free paint.
Can I use a home lead test kit on a metal swing set?
Only to rule lead out, and only on steel or iron. EPA recognizes two kits for ferrous metal, when used by a trained professional, and only for a negative result at the 0.5 percent level. No kit has met EPA's standard for positive results, and none is recognized for aluminum. A kit cannot tell you whether paint meets the 90 ppm consumer limit. Use a laboratory if the answer will drive a decision.
Is intact lead paint on a playground dangerous?
CPSC staff do not consider intact lead paint in good condition a hazard. The risk starts when it deteriorates into chips and dust that young children pick up on their hands. That is why the recommended control for sound paint is regular visual monitoring, folded into the safety inspections you already do, and why sanding or scraping it is the worst thing you can do.
Can I just paint over lead paint on old play equipment?
Only as a stopgap. CPSC staff class covering lead paint with lead free paint or an encapsulant as an interim measure, suitable when the equipment will be replaced within a few years. Outdoor weathering and play wear it through, it needs monitoring for life, and preparing the surface by sanding or scraping spreads the lead you are trying to contain.
Should I worry about the soil under an old painted swing set?
Look first. CPSC staff tell inspectors to check for paint chips under the equipment. If chips are there, the soil and loose fill have been receiving them, and a soil test is the way to know how much. EPA defines a soil-lead hazard as 400 ppm or more in bare soil in a play area on residential property or at a child-occupied facility.
Sources
- 1CPSC Staff Recommendations for Identifying and Controlling Lead Paint on Public Playground Equipment. US Consumer Product Safety Commission staff, October 1996Testing of 26 older playgrounds in 13 cities; assessment and control strategy
- 2CPSC Finds Lead Poisoning Hazard for Young Children on Public Playground Equipment. US Consumer Product Safety Commission, October 1, 1996Release 97-001; advice to parents
- 316 CFR 1303.1, Scope and application. Code of Federal Regulations, via Cornell Legal Information InstituteThe ban on lead-containing paint, its products, dates and limits
- 4Lead in Paint. US Consumer Product Safety CommissionCurrent 0.009% limit for children's products and consumer paint
- 5Lead Test Kits. US Environmental Protection AgencyRecognized kits, surfaces and performance criteria
- 640 CFR 745.103, Definitions. Code of Federal Regulations, via Cornell Legal Information InstituteDefinition of lead-based paint
- 740 CFR 745.65, Lead-based paint hazards. Code of Federal Regulations, via Cornell Legal Information InstituteSoil-lead hazard levels for play areas and the rest of the yard
- 8Update of the Blood Lead Reference Value, United States, 2021. CDC, Morbidity and Mortality Weekly Report 70(43), 2021Reference value lowered from 5 to 3.5 micrograms per deciliter
- 9Lead and other toxic metals in playground paints from South West England. Turner, Kearl and Solman, Science of the Total Environment 544, 2016Field XRF survey of 242 painted playground surfaces