Construction Industry Overview If your operation is involved in the construction industry you might be subject to Resource Conservation and Recovery Act (RCRA) regulations covering the generation, transportation, and management of hazardous waste. Not all construction industry operations produce hazardous waste, but if you use materials such as strong acid or alkaline solutions, paints, solvents, or petroleum products, the waste generated during their use might be hazardous. You are included in the construction industry if you provide services in the following areas: Heavy construction Plumbing, heating, and air conditioning Painting, paper hanging, and decorating Mobile home construction Prefabricated wood buildings and components Masonry, stonework, tile work, and plastering Carpentering and floorwork Concrete work Roofing and sheet metal work Glass and glazing work Wrecking and demolition. Hazardous Wastes From Construction Hazardous wastes that might be generated during construction fall into several major categories: Ignitable paint wastes generated by painting and other associated processes, including paint preparation and brush and spray gun cleaning Other ignitable wastes containing paint and varnish removers, paint brush cleaners, and epoxy resins and adhesives used during processes such as painting, cleaning, and degreasing Spent solvents from many processes, including painting, cleaning, degreasing, air conditioner maintenance, and fluxing Wastes containing toxic chemicals. Many products such as adhesives, paints, coatings, polishes, varnishes, thinners, and treated woods contain toxic chemicals. Wastes generated during the use of such products are hazardous wastes if they contain certain levels of toxic chemicals. Strong acid/alkaline wastes used in cleaning, degreasing, and plumbing operations. Some businesses generate spent heat transfer boxes that con- tain PCBs. PCBs are not regulated under RCRA; they are, how- ever, regulated under the Toxic Control Substances Act (TSCA). If you have spent heat transfer boxes, contact your state hazardous waste management agency to determine your responsibilities. In addition to these wastes, your operations might generate used oil. There are special provisions in the regulations for used oil. Currently most used oil is exempt from EPA hazardous waste regulations if it is recycled. If you recycle your oil, you are not required to use a Uniform Hazardous Waste Manifest, and you do not need to include used oil when determining your monthly haz- ardous waste generation rate. If, however, you are disposing of used oil yourself or are sending it offsite for disposal, you gener- ally should handle it as hazardous waste because it is likely to be ignitable or toxic. Special requirements apply if you are burning used oil as fuel. EPA is currently developing new regulations for used oil. Some states regulate used oil differently than does EPA; contact your state hazardous waste agency for more information. Table 1 lists typical processes/operations that use products that might contain hazardous materials and that probably generate haz- ardous waste. If you produce 100 kilograms (220 pounds or about half of a 55-gallon drum) or more of hazardous waste per month, you must fill out a Uniform Hazardous Waste Manifest when you ship hazardous waste off your property. The Manifest requires the proper Department of Transportation (DOT) description for each waste. Table 2 lists the proper DOT shipping description for a number of wastes that might be generated during equipment repair operations. Table 1 and Table 2 are not comprehensive lists. If you suspect that any waste you generate is hazardous, check with your state hazardous waste agency or EPA Regional office for more information. Waste Minimization An effective waste minimization program can reduce the costs, liabilities, and regulatory burdens of hazardous waste manage- ment, while potentially enhancing efficiency, product quality, and community relations. Waste minimization techniques that can help you reduce the amount of hazardous waste that you generate include: Production planning and sequencing Process/equipment adjustment or modification Raw material substitution Loss prevention and housekeeping Waste segregation and separation Recycling. Training and supervision of employees implementing waste minimization techniques is an important part of your successful program. Call the RCRA/Superfund Hotline toll-free at 800-424- 9346 (or TDD 800-553-7672 for the hearing-impaired) for waste minimization information and publications. EPA/530-SW-90-027J Printed on recycled paper ------- Table 1 Typical Construction Operations: Materials Used and Hazardous Wastes that Might be Generated Waste Type SPENT SOLVENTS AND Ethylcne Dlchloridc* Benzene* Eihyl Benzene Chlorobenzene* Meihyl Ethyl Ketone* Methyl Isobutyl Ketone Chloroform* Carbon Tefiachloridc* Hexaehloroethane* Mcthylcnc Chloride Trtehloroirifluoroethane Process/ Materials Used General Types of Operation Waste Generated Paint Preparation Paint thinners, enamel Ignitable wastes and Painting reducers, paints, enamels, Toxic wastes lacquers, epoxies, Spent solvents acrylics, primers, Paint wastes solvents Carpentering and Adhesives, solvents, Spent solvents Floorwork polishes and varnishes, Toxic wastes treated wood Other Specialty Adhesives, paints, Ignitable wastes Contracting coatings, polishes, Toxic wastes Activities varnishes, solvents, Spent solvents petroleum products Heavy Motor oil and other Used oil Construction petroleum products, Asphalt wastes asphalt Wrecking and Wreckage and debris that Demolition may contain ignitable or toxic substances Used oil Vehicle and Degreasers and cleaners, Spent solvents Equipment motor oil and other Acid/alkaline wastes Maintenance for petroleum products, Ignitable wastes Construction solvents, rust removers Toxic wastes Activities Used oil Table 2 Construction Waste Descriptions1 Designations/Trade Names DOT Shipping Name IGNITABLE OR TOXIC WASTES CONTAINING: Ethylene Bichloride, 1,2- Waste Ethylene Dichloride Dichloroethane Benzene Waste Benzene (benzol) Ethyl Benzene Waste Ethyl Benzene Chlorobenzene, Monochlorobenzene, Waste Chlorobenzene Phenylchloride Methyl Ethyl Ketone, MEK, Methyl Waste Methyl Ethyl Ketone Acetone, Meetco, Butanone, Ethyl Methyl Ketone Shell MIBK Waste Flammable Liquid NOS Chloroform Waste Chloroform Perchloromethane, Tetraform, Waste Carbon Tetrachloride Carbona, Halon 104 Hexachloroethane Waste Hexachloroethane Aerothene MM, Narkotil Waste Dichloromethane or Methylene Chloride Fluorocarbon 113, Freon 113, Ucon Hazardous Waste, Liquid, NOS Hazard Class Flammable Liquid2 Flammable Liquid Flammable Liquid Flammable Liquid Flammable Liquid Flammable Liquid OEM-A ORM-A ORM-A ORM-A ORM-E UN/NA ID Number UN1184 UNI 114 UNI 175 UNI 134 UNI 193 UN1993 UN1888 UN 1846 NA9037 UN1593 NA9189 Toluene Xylcnc 113, Freon TF. Frigen 113 113TR-T, Areton 63 Toluol, Methercid, Methyl Benzene, Methylbenzol, Phenylmethane, Antisol IA Xylene, Xylol Waste Toluene (toluol) Waste Xylene (xylol) Flammable Liquid Flammable Liquid UN 1294 UNI 307 ------- I 3D86 Z (continued) Construction Waste Descriptions1 Waste Type Kerosene Cresols* Trichloroethylene* Mineral Spirits Acetone Designations/Trade Names DOT Shipping Name Hazard Class Kerosene, Fuel Oil #1 o-Cresol, m-Cresol, p-Cresol, (m,p)- Cresol, (o,m,p)-Cresol TCE, Gemalgene, Lanadin, Lethurin, Nialk, Perm-a-Chlor White Spirits, Naphtha Acetone Waste Kerosene Waste Cresol Waste Trichloroethylene Waste Naphtha Waste Acetone Combustible Liquid3 Corrosive Material OSM.-A Flammable Liquid Flammable Liquid UN/NA ID Number UN1223 UN2076 UN1710 UN2553 UN1090 - STRONG ACID/ALKALINE WASTES Ammonium Hydroxide Hydrobromic Acid Hydrochloric Acid Hydrofluoric Acid Nitric Acid Phosphoric Acid Potassium Hydroxide Sodium Hydroxide Sulfuric Acid OTHER WASTES Ignitable Wastes, NOS Used Oil Asphalt Hazardous Waste, NOS Ammonium Hydroxide, NH4OH, Spirit of Hartshorn, Aqua Ammonia Hydrobromic Acid, HBr Hydrochloric Acid, HC1, Muriatic Acid Hydrofluoric Acid, HF, Fluorohydric Acid Nitric Acid, HN02, Aquafortis Phosphoric Acid, H3P04, Orthophosphoric Acid Potassium Hydroxide, KOH, Potassium Hydrate, Caustic Potash, Potassa Sodium Hydroxide, NaOH, Caustic Soda, Soda Lye, Sodium Hydrate Sulfuric Acid, H2S04, Oil of Vitriol Ignitable Wastes, NOS4 Various petroleum products Asphalt Waste Ammonium Hydroxide (containing not less than 12% but not more than 44% ammonia) (containing less than 12% ammonia) Waste Hydrobromic Acid Waste Hydrochloric Acid Waste Hydrofluoric Acid Waste Nitric Acid (over 40%) (40% or less) Waste Phosphoric Acid Waste Potassium Hydroxide Solution Dry Solid, Flake, Bead, or Granular Waste Sodium Hydroxide Solution Dry Solid, Flake, Bead, or Granular Waste Sulfuric Acid, Spent Waste Flammable Liquid, NOS Waste Combustible Liquid, NOS Waste Flammable Solid, NOS Waste Petroleum Oil, NOS Waste Petroleum Oil, NOS Waste Asphalt, at or above its flashpoint Waste Asphalt, cut back Hazardous Waste, NOS Corrosive Material ORM-A Corrosive Material Corrosive Material Corrosive Material Oxidizer Corrosive Material Corrosive Material Corrosive Material Corrosive Material Corrosive Material Corrosive Material Corrosive Material Flammable Liquid Combustible Liquid Flammable Solid Combustible Liquid Flammable Liquid ORM-C Flammable Liquid Combustible Liquid ORM-E NA2672 NA2672 UN1788 NA1789 UN1790 UN2031 NA1760 UNI 805 UN1814 UN1813 UN1824 UN1823' UN1832 UN1993 NA1993 UN1325 NA1270 NA1270 NA1999 NA1999 NA1999 UN9189 * Toxicity Characteristic constituent. Any waste that results in a TCLP extract containing a Toxicity Characteristic constituent equal to or above regulatory levels is hazardous. 1 These-descriptions may change given variations in waste characteristics or conditions. Note that the DOT shipping'name, hazard class, and UN/NA ID number do not directly correspond to RCRA hazardous waste categories. 2 A flammable liquid, has a flash point below 100°F. 3 A combustible liquid has a flash point between 100°F and 200°F. 4 NOS - Not otherwise specified. ------- For further information call the RCRA/Superfund Hotline 1-800-424-9346 ------- |