Prepared for:
U.S. Environmental Protection Agency

Prepared by:

Pratt Institute

Technical Assistance by:
ENSR Corporation
              5tal working
       Environmental Health & Safety in the Arts:

A Guide for K-12 Schools, Colleges and Artisans
          Proper Management of Waste and Residuals from Art Studios and Shop Practices
                                           ENSR AECOM

This information set forth herein is being furnished free of charge and is based on public domain information
that is believed to be reliable. The preparer makes no warranty as to the completeness or accuracy thereof.

This guidance does not constitute rulemaking by EPA and may not be relied on to create a substantive or
procedural right or benefit enforceable by any person.  EPA may take action at variance with this guidance
and  its internal procedures. Any variation between applicable  regulations and the information provided in
this document is unintentional and, in the case of such variations, the requirements of the regulations govern.

This document identifies governmental and non governmental resources that may be helpful to schools.While
EPA made  comments intended  to improve the document, EPA does  not endorse,  make any guarantee or
assume any liability with regard to any products, services or resources mentioned in this publication, including
the use of information from or recommendations made by resources provided in this document.  Mention of
trade names, products, or services does not convey official EPA approval, endorsement, or recommendation.

This compliance assistance project was undertaken in connection with a settlement of an enforcement action
taken by EPA against Pratt Institute for alleged violations of the regulations governing wastes.

                            TABLE OF CONTENTS

  1.1 Proper Waste Management and Disposal	1-1
  1.2 Art Instructors' Obligations	1-1
  1.3 Document Organization	1-2

  2.1 The Resource Conservation and Recovery Act	2-1
  2.2 RCRA's Hazardous Waste Program	2-1
  2.3 Material Knowledge/Material Safety Data Sheets	2-2
  2.4 Hazardous Waste Identification/How to Determine What Constitutes Hazardous Waste	2-2
  2.5 Universal Waste	2-5

  3.1 Hazardous Waste Generators	3-1
    3.1.1 Generator Categories	3-1
    3.1.2 Definition of a site (facility)	3-1
    3.1.3 Counting Monthly Waste Generation	3-2
    3.1.4Haz. Waste Identification Number	3-2
    3.1.5 Meeting the requirements	3-2
  3.2 Basic Requirements for CESQGs	3-2
  3.3 Hazardous Waste Storage and Labeling	3-2
    3.3.1 Storage Areas and Accumulation Areas	3-3
  3.4 Emergency Preparedness and Prevention	3-4
    3.4.1 Contingency Plan- Spills, Releases	3-5
    3.4.2 Emergency Response - Incident Command	3-5
    3.4.3 Transport and Disposal	3-6
    3.4.4 Inspection and Record Keeping	3-6
    3.4.5 Training	3-6
  3.5 Off-Site Shipping Requirements	3-6

  4.1 Know the Materials You Use and Store	4-2
  4.2 The Community's Right to Know and the Workers'Right to Know	4-2
    4.2.1 Your Community's Right to Know and Emergency Planning	4-2
    4.2.2 The Workers'Right to Know	4-3
  4.3 Minimizing Exposure	4-4

  5.1 Painting and Solvents Use	5-2
    5.1.1 Major Dangers	5-2
    5.1.2 Less Obvious Dangers	5-2
    5.1.3 Safety Suggestions	5-2
    5.1.4 Disposal	5-3
  5.2 Ceramics	5-4
    5.2.1 Major Dangers	5-4
    5.2.2 Less Obvious Dangers	5-4
    5.2.3 Safety Suggestions	5-6
    5.2.4 Disposal	5-6

  5.3 Jewelry Making and Small Metals	5-7
     5.3.1 Major Dangers	5-7
     5.3.2 Safety Suggestions	5-8
     5.3.3 Disposal	5-8
     5.3.4 Recommended Alternative Materials	5-8
  5.4 Photography	5-8
     5.4.1 Major Dangers	5-8
     5.4.2 Less Obvious Dangers	5-9
     5.4.3 Developing Process Awareness	5-9
     5.4.4 Safety Suggestions	5-11
     5.4.5 Disposal	5-11
  5.5 Printing and Printmaking	5-11
     5.5.1 Major Dangers	5-11
     5.5.2 Safety Suggestions	5-13
     5.5.3 Disposal	5-14
     5.5.4 Recommended Alternatives	5-14
  5.6 Metalworking and Foundry	5-14
     5.6.1 Major Dangers	5-14
     5.6.2 Less Obvious Dangers	5-15
     5.6.3 Safety Suggestions	5-16
     5.6.4 Disposal	5-16
  5.7 Design and Architecture; and Model Making	5-16
     5.7.1 Major Dangers	5-16
     5.7.2 Less Obvious Dangers	5-17
     5.7.3 Safety Suggestions	5-17
     5.7.4 Disposal	5-18
     5.7.5 Recommended Alternatives	5-18
  5.8 Drawing Materials and Pastels	5-18
     5.8.1 Safety Suggestions	5-18
  5.9 Sculpture	5-18
     5.9.1 Major Dangers	5-18
     5.9.2 Less Obvious Dangers	5-19
     5.9.3 Safety Suggestions	5-19
     5.9.4 Disposal	5-20
     5.9.5 Recommended Alternatives	5-20
  5.10 Woodworking	5-20
     5.10.1 Major Dangers	5-20
     5.10.2 Less Obvious Dangers	5-21
     5.10.3 Safety Suggestions	5-21
     5.10.4 Disposal	5-21
     5.10.5 Recommended Alternatives	5-22
  5.11 Audio/Video and Computer Labs	5-22

  6.1 Less is More	6-1
  6.2 Organic and Inorganic Wastes	6-1
  6.3 Standard Operating Procedures (SOPs)	6-2
  6.4 Good Housekeeping	6-3
  6.5 Waste Segregation	6-3
  6.6 Waste Minimization Program	6-3
  6.7 Waste Management Hierarchy	6-4
     6.7.1 Reusing	6-4
     6.7.2 Recycling	6-4
     6.7.3 Reclaiming	6-4

   6.7.4 Landfill Disposal	6-5
   6.7.5 Generator Responsibility and Liability	6-5
  6.8 Toxics Use Reduction	6-6
  6.9 Planning Ahead	6-6


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 Dear Educator for the Visual Arts,
 This  publication  has  been  prepared   as  a
 supplemental    environmental   project    in
 conformance with a compliance agreement with
 the  United  States  Environmental  Protection
 Agency  (U.S. EPA).  It  has  been prepared  to
 assist  you  in  complying with  the  Federal
 Hazardous Waste Management Regulations.
 Note: This document focuses on the federal hazardous
 waste  management  requirements.    State and local
 government  entities may have requirements that are
 different I more stringent than the Federal requirements; it
 is important to become familiar with,  and comply with,
 the state and local  requirements as well as those of the
federal government.
 The  intent  also  is  to  expand  the  focus  of
 educational  standards for the Arts  to include
 basic environmental, health and safety training
 information   on  the   hazardous  materials,
 hazardous  substances and  hazardous  waste
 found in various  art mediums and processes.
 Knowing and Using Arts Materials and
 "Students will be knowledgeable about and make use of
 the materials and resources available for participation in
 the arts in various roles."
 While every attempt has  been made to present
 complete   and   accurate   information   on
 applicable regulations, please be  aware that any
 inadvertent misrepresentations or omissions do
 not relieve  any  person   from  any regulatory
 compliance  requirements  of state, local  or
federal law.  The complete regulations may be
accessed online from  U.S.  EPA or NYSDEC
(websites are listed  in the appendices), and may
also be obtained in  hard copy from many public
"Safety isn't just one more thing. It's Everything!
                            General'Motors motto

Amy Snider
Pratt Institute of Art
Brooklyn, New York
Art Department Faculty and Technicians
Pratt Institute of Art
Brooklyn, New York
Eric Miles
Brooklyn Technical High School
Brooklyn, New York
Monona Rossol, MS, MFA
Industrial Hygienist
Arts, Crafts & Theater Safety, Inc. (A.C.T.S.)
Sheila Stember
F.H. LaGuardia High School of Music & Art
and the Performing Arts
National Art Education Association
Pratt Institute
with Technical Assistance from:
ENSR Corporation
EHS Compliance and Industrial Services
2 Technology Park Drive
Westford, Massachusetts 01886

This page intentionally left blank.

                                     SECTION 1.0
Numerous health hazards and environmental
risks are associated with the creation of art.
Art instructors are in a unique position to not
only prevent pollution by the careful selection,
use and management of art materials, but also
to pass on their knowledge to their students.
This document is intended to provide a basic
understanding of the potential hazards present
in various art materials and processes. Many
art  materials  contain  regulated  hazardous
substances which, by law, must be disposed of
properly.  As the  teacher  or  supervisor in
charge of the area, it is your responsibility to
provide  a safe  "workplace"  for  all  your
students and  to ensure that  all hazardous
waste is managed properly.

1.1 Proper Waste Management and

Proper  waste management and disposal  is
important for everyone. It is also required by
law. The  Environmental Protection  Agency
(EPA) was empowered by  Congress to  enact
rulemaking that  would protect the public
from improper waste  disposal. The Resource
Conservation  and Recovery  Act  (RCRA)
requires that  a  generator of hazardous waste
manages it "from cradle to grave".
 In order to ensure a safe future, personal
commitment  to  regulatory  compliance  is

1.2 Art Instructors' Obligations

In general, the obligation of art instructors is
to ensure a safe environment for everyone —
themselves,  their  students,  other  faculty
members  and visitors to  the classroom or
studio. This requires creating an environment
that encourages minimal use and exposure to
hazardous   materials   by,  for   example,
disposing of existing hazardous materials and
using     more      environmentally-friendly
materials,  and  educating  students  in  the
proper handling techniques and maintenance
of the area in a way that benefits everyone.
Legal  obligations  are discussed  in  further
detail later in this document.  Basically,  they
•   Creating and maintaining a safe environment;
•   Keeping an inventory of potentially hazardous
    art materials;
•   Informing others of the potential risks by:
    •   providing Material  Safety Data  Sheets
        (MSDSs) for review  by anyone who will
        be using the product;

    •   alerting   school   officials   and  other
        emergency responders to assist them in
        emergency response planning;
    •   Submitting annual reports to government
        agencies as required; and
    •   Ensuring proper disposal of hazardous

1.3 Document Organization

The remainder of this document is organized
as follows:

•   Section 2.0 Hazardous Waste Management
•   Section 3.0 Hazardous Waste Generator
    Requirements/ Ensuring Technical
•   Section 4.0 Expanding the Health & Safety
•   Section 5.0 Sources of Potentially Hazardous
    Waste in Art Studios
•   Section 6.0 Pollution Prevention And Waste
Appendices  contain  additional  information
that includes lists of regulated  chemicals  and
hazardous  wastes;  codes;  definitions   of
environmental  acronyms  and  terms;  record
keeping checklists; where to obtain additional
information  (including useful websites);  and
preferred, environmentally-friendly vendors.

                                     SECTION 2.0
2.1 The Resource Conservation and
Recovery Act

The Resource Conservation and Recovery Act
(RCRA) was enacted  in 1976  to deal with the
large quantities of municipal and industrial solid
waste,  as  well  as  hazardous waste  that  is
generated  throughout  the United States.  Under
RCRA, the EPA developed regulations to attain
the goals  listed below, in large part by setting
requirements at all levels of waste management
by  commercial, industrial  and governmental
facilities, to ensure  that such wastes would be
properly  managed.  These
regulations are contained in
Title  40  of  the   Code  of
Federal  Regulations  (CFR),
[Parts 240-282].
RCRA has four goals:
1.   To    protect   human
    health     and      the
    environment  from  the
    hazards posed by  waste
2.   To  conserve  energy  and natural resources
    through waste recycling and recovery;
3.   To reduce or eliminate the amount of waste
    generated, including hazardous waste; and
4.   To ensure that wastes are managed properly
    to  protect   human   health   and   the
RCRA contains three separate, yet related programs:
hazardous waste; solid waste; and, underground storage
tanks. However, for the purposes of this document, only
Subtitle C — Hazardous Waste Program is discussed.
2.2 RCRA's Hazardous Waste Program

The Hazardous  Waste Program under  RCRA
provides a system  to manage hazardous wastes
"from cradle  to   grave"  (i.e.,  from  initial
                          generation       to
                                    of  this
                                     is    to
                          are  handled  in  a
                          manner        that
                          protects     human
                          health   and    the
Consequently,   the    program   deals   with
hazardous waste generation and transportation,
as well as treatment, storage, and disposal.

2.3 Material Knowledge/Material Safety
Data Sheets

All art materials used or stored in the art studio
or  classroom and  shop areas should  have an
accompanying   Material   Safety  Data  Sheet
(MSDS).     An   MSDS  provides   detailed
information  about  the  product,   including
physical  data (such  as  boiling point, melting
point, and  flash point), toxicity, health risks,
reactivity,    necessary    personal    protective
equipment,   spill    cleanup,   disposal   and
recommendations for storage and handling.  It
is important to be familiar with the information
contained in the MSDS for each  chemical  that
you use. The MSDS  should be readily  available
for review by anyone having a need to know
about process raw materials.
2.4 Hazardous Waste Identification/How
to Determine What Constitutes Hazardous

Proper hazardous waste identification is critical.
Review  the  following   three  questions  to
determine   if   the  material  is  potentially
hazardous waste. (See Section 5.0. for a list of
potentially hazardous wastes that are commonly
found in art studios and shops.)
1.   Is the material a solid waste?
For a material  to  be considered a  hazardous
waste, it must first be considered  a solid waste.
Hazardous wastes are a subset of solid wastes.
As  strange as it may sound,  a solid waste does
not have to be a solid.   According to RCRA, a
solid  waste  is  defined  as any material that  is
discarded by being either abandoned, inherently
waste-like, or recycled.  As such, a "solid waste"
can be a solid, liquid or compressed gas.
2.   Is the waste excluded?
There are several exclusions under RCRA  that
apply  to   specific   waste  streams.     These
exclusions would not normally apply  to  an art
studio or  workshop, with  the  exception of
hazardous waste samples.  Specifically, samples
of hazardous wastes can be sent to a laboratory
to  aid in determining whether the waste  is a
hazardous waste.  These samples are  typically
taken and transported solely  for the purpose of
waste   characterization  and  are   regulated
differently than other hazardous waste.
3.  Is the  waste  a listed or  characteristic
    hazardous waste?
Once it has been determined that the waste is a
solid waste and not excluded, the next step is to
figure  out  whether  it  is  actually hazardous.
There  are two ways by which  a  waste can be
considered hazardous:
1)  It  can  be  listed   as  a hazardous  waste;
2)  It   can   exhibit   certain    characteristics
    particular to a hazardous waste.
Listed Hazardous Wastes
There  are four lists of hazardous wastes - F, K,
P, and U. Of these, F-wastes are generated from
generic processes,  K-wastes are  from specific
industrial sectors, and P- and U-wastes are unused
pure chemical products and formulations.  Of these,
U, P and several  K wastes may apply to art wastes.
Such wastes  are deemed  dangerous  based on their
origin,  and, consequently,  are  considered  listed
hazardous wastes. The lists are summarized below
(see Appendix A for entire lists).
•   F  List — This list includes  hazardous  wastes
    from  common  industrial and  manufacturing
    processes.   The processes  that generate such
    wastes can take place  in various sectors,  and,
    consequently, F-listed  wastes   are  known as
    wastes  from non-specific sources. There  are
    seven groups of wastes contained in the F list,
    which are as follows:
    •   Spent solvent wastes (waste codes F001
        through F005);
    •   Electroplating and  other  metal  finishing
        wastes (F006 through F012,  and F019);
    •   Dioxin-bearing wastes (F020 through F023,
        and F026 through F028);
    •   Chlorinated     aliphatic     hydrocarbons
        production wastes (F024 and F025);
    •   Wood preserving wastes  (F032, F-34, and
    •   Petroleum refinery wastewater   treatment
        sludges (F037 and F038); and
    •   Multisource leachate (F039).

    Of the above groupings, the two most likely
    to be found in  an art  studio  or shop are
    spent  solvent  wastes   (waste  codes  F001
    through F005), and electroplating and other
    metal finishing wastes (F006 through F012,
•   K List —  This list contains  wastes from very
    specific  industrial  and manufacturing sectors.
    Consequently, K  listed wastes  are known as
    wastes  from  specific  sources.   There  are  13
    categories  of industries that are covered in the K
    list, none  which would  apply  to  standard art
    related       classrooms        studios/shops.
    Consequently, this list is not discussed further in
    this document.
•   P and U Lists — These two lists cover pure and
    commercial  grade  formulations   of  certain
    unused  chemicals  that   are  being disposed.
    Unused  chemicals  can  become  wastes  for
    various reasons, such as being spilled, exceeding
    the expiration date,  change in activities that
    eliminate the need for the  material making them
    obsolete, or because they no longer meet the
    specifications necessary for their intended use.
    In order for a chemical waste to fall under the P
    or U lists, the waste must meet the following
    •   The listed chemical in the waste must be
        unused and the listed chemical in the waste
        must  be in  the  form  of a  commercial
        chemical product and  the  sole   active
        ingredient in the chemical formulation; or,
    •   A  residue  or  contaminated media that
        contains one of the chemicals listed on the
        P or U lists.
     P wastes  are  considered acutely hazardous
     wastes.    As such,  generating  or storing  a
     relatively  small  amount (1 kg, or 2.2 Ibs) can
     make you  subject to certain  large quantity
     generator    management    and    disposal
     requirements (see  Section  3.0).
    Note that a container that previously held a P
    waste is  also considered a  hazardous  waste,
    unless  it  is  triple-rinsed  (with  the  rinsate
    managed  as  a  P  waste).   However,  it is
    recommended that such a  container be managed
    and disposed of as a P waste, rather than rinsing
    out the  P waste contents, as this  is  generally
    safer and more cost-effective.
    Some examples of P and  U wastes that may be
    found in  art studios, classrooms  and  school
    buildings include, but are not limited  to, the

     •   P   wastes   -   cyanide   salts   used  in
         photography;  certain pesticides used in
         buildings  and  grounds;  some  chemical
         inventory found  in  chemistry classrooms
         and physics labs;  and,  epinephrine  and
         nitroglycerin in the nurses' station.

     •   U  wastes  —  acetone;  2-butanone;  ethyl
         acetate;  ethyl  ether;   dichloromethane;
         methyl ethyl  ketone;   certain  solvents;
         acrylamide; hydrofluoric acid; and, thiourea
         in jewelry making and photography.
Characteristic Hazardous Wastes
A characteristic hazardous waste is one that
exhibits  certain properties that indicate  that  it
poses  enough  of a  threat  to be  considered
hazardous.  A characteristic waste may or may
not also be a listed hazardous waste  (as defined
above).  If a waste is listed as a hazardous waste
and exhibits the characteristics  discussed below,
it   may   be   subject   to   more   extensive
requirements.   However, it is possible  for  a
waste to not  be a listed waste  (i.e., F, K, P, or
U), but still  exhibit  one or  more  hazardous
characteristics. In  order to determine whether
the solid waste exhibits  one  or  more  of the
following characteristics, a sample may need to
be sent to an authorized  laboratory for testing.
Alternatively, a chemical's MSDS often includes
relevant information,  such as the  flash point or
constituent concentrations, that may allow you
to make the determination without testing. It is
recommended   that,   in  either  case,  you
document the method used to make the waste
determination and keep the documentation; this
information will be  useful in  discussions with

your  waste   hauler,   during  inspections   by
regulators and for  use by other  staff members
who  may work  with  you  or succeed you in
management of particular waste streams.
There are four hazardous waste characteristics
established  by EPA:  Ignitability,  Corrosivity,
Reactivity and Toxicity.  If your waste meets any
one of these, it is  considered a hazardous waste:
•    Ignitability  -  This  characteristic  applies  to
    wastes that can  readily catch fire and sustain
    combustion.    Paints and  cleaners often  fall
    under this  category.  An ignitable waste can be
    either a liquid  or a non-liquid, though most tend
    to be in the  liquid form.  A laboratory will
    typically perform a flash point test to determine
    the lowest  temperature at which fumes from the
    waste will ignite when exposed to a flame. If the
     flash  point is  below 140 ฐF,  the  waste  is
    considered to be hazardous.
    Ignitable wastes have the waste code D001, and are
    some of the most common types of wastes generated.
•    Corrosivity - This  characteristic  applies  to
    wastes that are highly acidic or alkaline (basic).
    These wastes  are  typically  liquids,  and  can
    easily corrode/dissolve flesh, metal, or other
    materials.   Spent  sulfuric  acid is a common
    example  of a  corrosive waste.  There are two
    criteria that are used to  determine whether a
    waste falls under this category:
     •   pH test:  if the waste  has a pH less than or
        equal to 2, or greater  than or equal to 12.5,
        it is considered corrosive; and
     •   Steel test: if the waste can  corrode steel
        under  specific  conditions,  it is considered
     Corrosive wastes  have  the waste  code D002, and
     are commonly generated by art programs.
•   Reactivity — This characteristic applies to wastes
    that are unstable and easily explode or undergo
    violent reactions, or react to or  release  toxic
    gases, fumes or  vapors when mixed with water
    or  under  other conditions  such  as  heat or
    pressure. While such wastes are not as common
    in art as  other types of waste, it is still possible
    to find facilities that have these chemicals and
    do not know  they are reactive.  If you do not
    identify  these  reactive   chemicals,  you  risk
    inadvertently  storing them near, or allowing
    mixing    with,    incompatible     chemicals.
    Accordingly, it is important to check MSDSs or
other  sources   of technical  information  to
determine if the materials  stored or used in the
art department are, or could become, reactive
with age, inappropriate storage, or mixture with
other chemicals.
Materials  that  may be  reactive  include acetyl
chloride, chromic acid, cyanides, hypochlorites,
organic peroxides, perchlorates, permanganates,
and  sulfides.     Several  common  processes
involving   reactive  chemicals  are  described
below, though this is not an exhaustive list of art
processes that may use such chemicals:
•   Cyanides  -  Cyanide  compounds  can  be
    found in  art  departments  with  jewelry
    programs,  as well  as  occasionally in metal
    sculpture   departments,  that  have  small
    cyanide plating baths.   Users  are often
    aware that the  chemical can be dangerous,
    but don't often know that hydrochloric acid
    (and other acids)  should not be stored  on
    the  shelf  above   the  bath,  as  a   strong
    reaction can occur if these are mixed.  In
    addition,  the  hexacyanoferrates  used  in
    cyanotype, blue print, and in  Prussian blue
    pigment should be considered true cyanides
    in determining chemical compatibility.
•   Organic Peroxides — Organic peroxides are
    common curing agents for polyester resins
    used in sculpture and  several other types of
    two-component resin systems.
•   Perchlorates - Potassium perchlorate is used
    in printmaking departments  for an  etching
    process called Dutch Mordant.  Perchlorate
    should not be contaminated with organic
    substances  or acids.    Additionally,  in
    schools,  it  should  be stored  away from
    areas  with  general student access, as it can
    be used for making pyrotechnics.
•   Sulfides  -  Sulfides  are  used in  certain
    photographic  toners  and  pigments  (e.g.,
    cadmium sulfide, mercuric sulfide.)
^active wastes have the waste code D003.
Toxicity  -    EPA  developed    a   toxicity
characteristic to identify wastes that are likely to
leach   dangerous   concentrations   of  toxic
chemicals   into  underground  water   when
disposed  of  in landfills.   It is   based on  a
laboratory  procedure  known  as  the Toxicity
Characteristic  Leaching Procedure  (TCLP). It
recreates the leaching process and conditions to
determine how a waste will  act  in  a  typical
landfill. During this process, a liquid "leachate"

    is created from the waste (if it is a solid) in the
    laboratory.  If the waste  is a liquid, then the
    waste itself is considered  to  be the extract or
    leachate.  If the leachate contains one or more
    certain  hazardous  chemicals  in  concentrations
    that exceed corresponding regulatory limits, the
    original waste is deemed to exhibit the  toxicity
    Toxidty characteristic  wastes have the codes D004
    through D043.  Among the wastes regulated under
    the  toxicity characteristic are several solvents and a
    number of metals commonly  used in the visual arts
See  Appendix  A  for a  list  of the  hazardous
wastes  and the  corresponding codes.  Keep in
mind that the list is not exhaustive  and  some
"unlisted" or non—regulated wastes may still be
toxic  and/or pose  other  risks  of  harm if
improperly  handled,  such   as  glycol ethers,
epoxies,  plasticizers, lube  and  hydraulic  oils,
metal  shavings/borings,  silicas,  turpentine and
PCBs,  to mention  a  few.     The saying goes
"even if  it's not listed, if it will melt  metal or
plastic, it's probably not too good for you!"

2.5  Universal Waste

In order to promote the collection and  recycling
of   certain   widely  generated  hazardous
wastes,  known  as  universal  wastes,  EPA
developed   the   Universal   Waste  Program.
Through   this   streamlined  subset   of   the
hazardous waste regulations, EPA  has eased the
regulatory  burden  on facilities  that  generate
these   particular  ubiquitous  wastes.   Wastes
covered  under  the  universal  waste   program
•    Hazardous waste  batteries  (e.g., rechargeable
     nickel-cadmium, lithium);
•    Lead  containing devices (e.g., cathode  ray tubes,
     lead acid  batteries, printed  circuit boards  and
•    Waste   mercury-containing   devices    (e.g.,
     thermometers,     thermostats,    barometers,
     manometers,  temperature and pressure gauges);
 •    Hazardous waste bulbs (e.g., fluorescent lights,
     high  intensity discharge, neon, mercury  vapor,
     high  pressure sodium, and metal halide lamps -
     these usually contain mercury).

 Note that hazardous waste pesticides that are recalled or
 collected in  a pesticide  collection  program  are  also
 considered universal wastes, but are not typically used in
 art studios/shops.  However, pesticides from a school's
facility maintenance shop or agriculture program may fall
 under this program.
 See Section 3.0 for a discussion of obligations
 relative to  ensuring compliance with applicable
 Hazardous Waste Management regulations.

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                                     SECTION 3.0
3.1 Hazardous Waste Generators

Hazardous  waste  generators  are   broadly
defined as any person, by site, who creates or
produces or brings a hazardous waste into the
United States. Such generators and sites in the
art field could  include  individual artists  or
craftspeople working in their studios or shops,
art teachers or technicians in public or private
schools at the  high school or college level,
artists'  cooperatives  in  which  many artists
work together,  or businesses whose  products
are artistic works.

3.1.1 Generator Categories

Such   entities  are   classified  according  to
quantity of  hazardous waste  generated,  as
•   Large  Quantity Generators (LOGs): LQGs
    produce  more than 1,000 kg (2,200 Ibs) in a
    calendar month, or more than 1 kg (2.2 Ibs) of
    acutely hazardous waste in a calendar month;
•   Small  Quantity Generators (SOGs): SQGs
    produce  less than 1,000 kg  (2,200 Ibs)  but
    more  than  100 kg (220  Ibs) of hazardous
    waste  per month,  and  accumulate  less  than
    6,000 kg  (13,200 Ibs) of hazardous waste at
    any time; and
•   Conditionally   Exempt   Small   Quantity
    Generators  (CESOGs): CESQGs  are those
    that generate less than 100 kg  (220 Ibs) of
    hazardous waste in a calendar month and less
    than 1 kg (2.2 Ibs) of acutely hazardous waste
    in a calendar month. Additionally,  CESQGs
    must limit accumulation to less than 1,000 kg
    (2,200 Ibs) of hazardous waste, or 100 kg (220
    Ibs) of any residue from the cleanup of a spill
    of acute hazardous waste at any time.

3.1.2 Definition of a site (facility)
Determining which  category  you  fall  into
must  be done  on a facility-wide  basis. In a
school,  for example, it is not just the quantity
of  hazardous  waste  generated in  your  art
department that matters, but the total quantity
of hazardous waste  generated by the entire
school or facility that determines the  category.
Included  in  the  total  will be waste  from
building maintenance  and  cleaning, science
classes,  and all other departments.  In fact, for
purposes  of hazardous  waste management,
the definition of a  facility  is  based on  the
property  boundaries, rather than buildings.
For example,  a high school,  middle school
and district  administrative office on a single
parcel  of land would generally constitute  a
single  "site" or  "facility"  for  purposes  of
hazardous waste regulations. Alternatively, if
a school district has a maintenance facility or
administration building on  a  parcel  of land
that  is   not   contiguous  with  the  land
containing the  school,  the  former  would
constitute  a  separate   facility and  would
determine  its  waste  generation  rate  and
corresponding  level  of requirements based
solely on wastes generated  on that property;
similarly,  the high school would  not count

wastes from the remote site in its generation

3.1.3 Counting Monthly Waste Generation

Even if you only generate a small amount of
hazardous waste in your department, you are
subject  to  the  requirements  of the category
into which your whole facility falls.
While  art   cooperatives  and   art  business
owners   must   calculate   their   monthly
quantities and determine their categories, it is
not possible for a single art teacher in a school
to calculate the total waste accumulation for
the  entire  facility.  Instead,  the  school's
environmental  personnel, or  the school  or
district staff designated to manage your waste,
must  provide  you  with  the  category  into
which your facility falls.
It is possible for a facility to be in any of the
three  categories. Remember that, since these
categories are based on monthly generation
quantities, it is possible to be in one category
during  a  certain  month and  in  another
category during a different month. In general,
the more hazardous  waste a facility generates,
the more  strict the applicable  regulations.
Consequently, it is important to be constantly
mindful of the quantities of hazardous wastes
generated  in  your  area,  to  manage your
materials properly to keep  hazardous waste
generation  to a minimum  and to confer with
your environmental/waste management staff
on  a  regular basis. If  you are  in a situation
where the category changes from time to time,
for example between a CESQG and a SQG, it
might  be  simpler,  safer, and  provide  less
opportunities  for  errors  if you picked  the
SQG  category  and maintained compliance
with its requirements permanently.

3.1.4 Haz.  Waste Identification Number

The site (facility)  definition  is  also used  in
obtaining a unique hazardous waste generator
identification number from the  U.S. EPA or a
delegated state if the facility is a SQG or LQG
at any time. This  number, often referred  to
colloquially  as  a  "RCRA  ID",  is used   on
manifests  for  shipment  of all  hazardous

3.1.5 Meeting the requirements
Once you know the category into which your
facility  falls, this  booklet will  provide  the
requirements for proper handling and disposal
of your hazardous waste.
This section of the manual focuses on  the
requirements  for SQGs, though  certain
portions   (as  specified)  also  apply   to
CESQGs.    Additional requirements  for
LQGs are  also noted where applicable.

3.2 Basic  Requirements for CESQGs

If you are  a CESQG, there are three primary
requirements with which you must comply:
•   Account  for all  the  hazardous waste  you
    generate, and stay below the monthly, facility-
    wide thresholds of 100 kg of hazardous waste
    and 1 kg of acute hazardous waste;

•   Do  not  store  more than  1,000  kg  of
    hazardous waste at any one time; and

•   Ensure  that your hazardous waste  is sent to
    one of the following types of facilities:

    •   a permitted hazardous waste treatment,
        storage, or disposal facility;
    •   a facility that reuses, recycles or reclaims
        the hazardous waste; or,
    •   A  permitted  industrial  or   municipal
Note  that  some  states  may have additional
requirements  for  CESQGs.   Hence,  it is
important to check with your state to find  out
if you should be  doing something  more to
stay in compliance.

3.3 Hazardous Waste  Storage  and

Regardless  of what hazardous waste generator
category   you  are  in,  good   container
management helps protect  health  and  the
environment by preventing spills or releases.
While required for SQGs and/or LQGs,  the

following are also recommended practices for
•   Labeling containers  such that the contents
    (including anything that might be hazardous)
    are clear to those handling the materials;
•   Storage of incompatible compounds or wastes
    in separate containers;
•   Secondary containment  for waste containers;
•   Keeping containers that hold hazardous waste
    closed, except when  adding or  removing

3.3.1  Storage Areas and Accumulation
Satellite Accumulation Area
The hazardous waste regulations are written
using a "cradle-to-grave"  approach  to waste
management, ensuring that hazardous waste is
properly identified and safely managed from
the time  and place  at which  it becomes  a
waste until it is properly treated or disposed of
at a  permitted  facility.   The  first  step is
identification of  the  hazardous waste by the
generator (e.g., artist, teacher) and  collecting
the waste in an appropriate container within  a
satellite accumulation area, an area at or near
the point of generation where a SQG or LQG
can   store limited   quantities  of hazardous
waste.    As   such,  managing  a   satellite
accumulation area is the task most commonly
applicable  to art  teachers, art  students  with
studios  or  separate  work areas, or  artists
working in a commercial  environment  (i.e.,
not alone in a personal studio.)
Typically, facility maintenance, operations or
custodial staff will be responsible for moving
full containers to the hazardous waste storage
area  and   overseeing   offsite   shipment.
However, it  is important to  understand the
process,   and   know   who   within   your
organization is  responsible for each aspect of
waste management, so you can determine (in
consultation  with the  waste  management
personnel) the best  way  to  store,  package,
label  and otherwise  safely store your waste,
respond to a spill or unintended release, and
make arrangements for waste removal.
You are allowed to accumulate a total of up to
55  gallons  of  hazardous  waste  per waste
stream  or one quart  of acutely hazardous
waste (see P List in Appendix A) in  an area
that is:
•   At or near the point of waste generation;

•   Under the supervision of the person/operator
    overseeing  the process  that generated  the

•   The waste must  be moved to  the  facility's
    main centralized hazardous waste storage area
    within  three  calendar  days   after   the
    accumulation  of 55  gallons of hazardous
    waste  or 1  kg of acute hazardous  waste is
    exceeded (but it is recommended that smaller
    containers be moved to the storage area when
    they become full.)

Furthermore, for hazardous waste containers
in the satellite storage area, you must:
•   Label   each  container  with   the  words
    "Hazardous Waste" and with  other words
    that identify the contents;
•   Use containers that are made  of materials
    compatible with the waste to  be stored;
•   Keep  containers  that hold  hazardous waste
    closed, except when  adding or removing
    waste; and,
•   Maintain the containers in good condition.
In  addition  to  the  accumulation  requirements
above, it is recommended that you do not open,
handle  or  stack containers  such that they may
rupture, leak or fall and that you do not mix wastes
that are incompatible.
Even though you are  allowed to  store up  to
55  gallons in a satellite accumulation  area,  as
previously noted,  it  is  a  good and safer
practice to  use smaller containers (e.g., 500
ml, 5  gallon.)  and move each to the main
central storage area when it is full.

Centralized Container Storage Area
There   are  generally  two   categories   of
centralized hazardous waste storage areas: less
than 90 days storage for LQGs and less than
180 days storage for SQGs (or 270 days if the
SQG must ship the waste 200  miles or more).
Note that these  time limits  are based  on

calendar  days  and not  business days.   In
addition,  the  accumulation  start date begins
when the waste container is placed in storage
(either directly or when moved from a satellite
storage area).
A centralized hazardous waste storage area is
similar  to a waste  warehouse. It is  the main
storage  facility  for  the  hazardous  waste
generator and, as  such, it is in this location
that the waste removed from studio and lab
satellite accumulation areas are placed pending
off-site disposal.
For hazardous waste containers  placed in the
centralized hazardous  waste storage  area, you
•   Mark the container with the date on which it
    is placed in storage;
•   Label  the  container  with   the   words
    "Hazardous Waste" and with any other words
    that will specifically identify the contents of
    the container.   For example,  use "Acetone
    and Toluene" rather than "Organic Solvents,"
    which is not specific enough ;
•   Ensure  that  the  maximum   storage  time
    allowed is not exceeded;
•   Provide    enough   aisle    space   between
    containers,  or rows of containers, to  allow
    inspection  of  the  label and  container
    condition, as well as  enough space to  allow
    access to the area to investigate or respond to
    a release or other emergency; and,
•   Inspect the storage area  at least  weekly to
    ensure that container leaks and deterioration
    are prevented.
In addition, it is recommended that the facility:
•   Note  the  address, as  well as  the specific
    location, where  the waste was  generated (for
    example, Art Studio, Room 222).
•   Permanently mark  any  container of  110
    gallons or less to be used for transportation of
    hazardous waste with the  standard red and
    white, or  red and yellow, hazardous waste
    label (shown at the end of this section.)
SQG and LQG facilities that store hazardous
waste  must  have  the  following equipment
(unless  none  of the  hazards posed by the
waste handled at the  facility could  require a
particular kind of equipment specified below):
•   An internal communications or alarm system
    capable  of providing  immediate  emergency
    instruction   (voice  or  signal)   to  facility

•   A  device, such as a telephone ( immediately
    available  at  the  scene of operations)  or a
    hand-held   two-way   radio,   capable   of
    summoning  emergency assistance  from local
    police departments, fire departments, or State
    or local emergency response teams;

•   Portable   fire  extinguisher,   fire   control
    equipment  (including   special  extinguishing
    equipment, such as that using foam, inert gas,
    or dry chemicals), spill control equipment, and
    decontamination equipment; and

•   Water at adequate volume  and pressure to
    supply water hose streams, or foam producing
    equipment, or automatic sprinklers, or water
    spray systems.
    The  above equipment, where required, must
    be tested and maintained  as  necessary to
    ensure proper working order in the event of
    an emergency.
In addition,  all personnel in  the process of
handling  hazardous  waste   must   have
immediate access  to  an  internal  alarm  or
emergency  communication device.   These
facilities  (SQGs and LQGs) are also required
to maintain aisle  space  in the  centralized
hazardous waste storage  area  to ensure  the
unobstructed movement of  personnel  and
emergency equipment.
3.4 Emergency Preparedness and

Emergency  preparedness   and   prevention
means having procedures in place to prevent,
prepare for, and respond to spills and releases
that could occur in the classroom, lab, shop or
studio.  Everyone who uses the facility needs
to know what they should do, how to do it,
and who  to  call.   LQGs are responsible for
complying    with    "preparedness     and
prevention"  requirements  in  the event  of
emergencies,  including preparing  a written
contingency  plan and  training employees in
hazardous waste  management and emergency

response.;  while  this  would  generally  be
handled by, or in  conjunction with, a facility
manager,  it  is useful  to  understand  the
purpose and  scope of such planning.  It may
also be useful for your facility, even if not an
LQG, to perform this task.
This section  outlines the components  of an
emergency response system that needs to be
in place in the event of a spill or release.

3.4.1  Contingency Plan - Spills, Releases

Spill Response Plan
If one does not already exist, a spill response
plan needs to be developed for the materials
you use in the classroom,  studio  or  shop.
When   preparing   a  spill  response  plan,
consider the following:
•   Type and quantity of materials handled;
•   Toxicity of and dangers associated with the
•   Ease of release into the environment; and,

•   Each responsible individual's role (see Section
    2.4.2, below)
The MSDS for a substance is a good place to
begin gathering information  needed  for spill
response;  it  contains  recommendations  for
cleanup procedures and personal  protective
equipment (e.g., gloves,  respirators, protective
clothing).   Consult  the  manufacturer,  waste
disposal   broker,   and/or   other  chemical
engineering   sources    for   recommended
cleanup materials and methods.
A Spill Kit  is a  collection  of spill control
materials used to contain spills anticipated in
the spill control  plan.   It generally includes
absorbents and other spill control methods,
for  example:  Vermiculiteฎ,  spill   pillows,
personal protective  equipment,  neutralizing
materials,  and cleanup tools.  Create cleanup
kits  for the  major  substances used  in  the
studio  or shop  and  label  them   clearly.
Indicate what PPE should be used under what
Spill  cleanup  materials  also  need  to  be
disposed   properly.       If   anything  is
contaminated with hazardous waste, it needs
to  be   disposed  using  hazardous   waste
3.4.2  Emergency Response — Incident
The emergency  response  system for  your
classroom,  shop,  studio  or   lab   should
conform to the one  for  your entire facility.
Familiarize  yourself  with   your  facility's
emergency  action   plan,   including   the
evacuation plan and  who to contact  in  an
emergency.  All LQGs and SQGs are required
to  have,  and  CESQGs   should have,  the
following information posted next to  each
telephone closest to where hazardous waste is
generated (i.e., satellite accumulation areas) or
•   The  name  and telephone  number  of the
    emergency coordinator/contact;
•   Locations of fire extinguishers,  spill  control
    kits, and the fire alarm pull stations; and
•   The  telephone  number  of the local  fire
In the event of an emergency, alert everyone
in the area of the spill or release and evacuate
the area if necessary.  In the event of a fire or
medical emergency, call 911.   Follow the spill
response plan.  By having the right equipment
ready and accessible, knowing what chemicals
are used  at a  location and their associated

risks, having procedures in place to respond
and knowing each person's role in the  event
of a spill or other accident, the potential for
such an event to cause harm can be greatly

3.4.3  Transport and Disposal

If any spill materials  need to be transported
and  disposed,  keep  records  of  the  date,
transporter,   and  quantity.     Complete  a
manifest   for  regulated   hazardous   waste
shipments   and    employ   only   licensed
hazardous  waste   transporters  and   TSD
facilities (facilities that treat,  store or dispose
of hazardous wastes).

3.4.4  Inspection and Record Keeping

It is very important  to keep records of the
materials you have in storage.  Keep track of
the chemicals you have, how old they are, and
where they are located.
Conduct  regular inspections  of storage  areas
and, though not required, maintain records of
those inspections. Included in Appendix  E are
examples of weekly inspection checklists  for
"Satellite  Accumulation  Areas"  and  "90-
Day/180-Day Storage  Areas."   While  the
former is not required to be  inspected,  it is a
good idea  to do  so  weekly  to  ensure that
wastes are labeled, containers are closed and
other requirements  and  safe  practices  are
being followed, and that any previously  noted
concerns have been promptly corrected.

3.4.5  Training

Train those who are in the area regularly (staff
and  students),  as  well  as   anyone who  is
responsible   for   identifying   or   managing
hazardous waste,  on the handling of any
hazardous  materials  or  hazardous  wastes.
Make sure they know which materials are used
in the studio or lab, as well as the appropriate
methods to handle spills and releases.
Training should occur at least at the beginning
of each school year and whenever new  types
of potentially hazardous materials are  added
to your inventory. Staff and  students should
also  be  trained   in  the  use  of  personal
protective  equipment  during  handling  of
hazardous materials  or wastes. For  activities
that produce excessive dust, vapor or fumes,
staff  and students must be  trained in  the
fitting of and  use of  face masks  or  other
respiratory protective equipment.
Keep training records  that indicate who was
trained, the  content of the  training, and the
date of the training. Because such training is
specifically     required     for     LQGs,
documentation  of  the  training   of   each
employee, along with  a description of  their
job duties (including any duties that involve
waste determination and/or hazardous waste
management) must be kept on site for at least
three  years.  While not required for SQGs and
CESQGs, similar procedures should be  used
in case  the facility becomes an LQG, if only
for a short period, in the future.

3.5 Off-Site Shipping Requirements

EPA   has  adopted   the  Department   of
Transportation's (DOT's) packaging, labeling,
marking and placarding regulations to ensure
the safe transportation  of  hazardous waste
from  its  point of generation to  its   final
disposal site.
Proper  packaging  is  essential  to  prevent
leakage  of hazard waste during transport or in
the event of even a minor accident, such as a
container falling over.
Labeling, marking and placarding of the waste
containers   must   correctly   identify    the
hazardous characteristics of the waste and any
risks in  storing and transporting the waste.
If you are a CESQG, you are not required to
use a manifest when shipping hazardous waste

off site, but careful identification and tracking
of the waste is strongly recommended. Since
LQGs and SQGs are required to ensure that
hazardous waste is transported to a permitted
hazardous waste treatment or disposal facility,
or to a facility that reuses, recycles or reclaims
the hazardous waste [40 CFR261.5(g>(3)], the
manifest provides tracking documentation to
prove  that  you  have managed your waste
"from cradle to grave."

If you, as a CESQG, decide on a bill of lading
as shipping documentation,  obtain and keep
receipts  and  records from  any hazardous
waste contractors that list the EPA or  state
identification numbers of the transporter and
the facility to which the waste is taken.
SQG and  LQG facilities  are  required  to
consign hazardous waste solely to transporters
and hazardous  waste management  facilities
that have  EPA  identification  numbers  [40
CFR 262.12(c)],  and must use  the  uniform
waste manifest.
SQGs may  be  excused  from the  manifest
requirement  in the  following  circumstances:
[40 CFR 262.20 (e)J
•   If the waste is reclaimed under a contractual
    agreement pursuant to which:
    1.   The  type  of waste and  frequency  of
        shipments are specified in the agreement;
    2.   The vehicle used to transport the waste
        to  the  recycling facility and to deliver
        regenerated  material   back   to   the
        generator is owned and  operated by the
        waste reclaimer; and
•   The waste generator maintains  a copy of the
    reclamation agreement in his files for a period
    of at least three years after termination or
    expiration of the agreement.
Included  as Appendix  G is a table summarizing
regulatory   differences   and   select   basic
requirements for New York and New Jersey.
          001 WOW* SHAPING NAME AND UN OR NA NO WITH PHffW      	I  f
F*                                        M

Environmental Virtual Campus

Art Safety Training Guide, Princeton University,

Container Management/Transport, Campus
Consortium for Environmental Excellence,

Darkrooms, Campus Consortium for
Environmental Excellence,

Hazardous Waste Requirements for Large
Quantity Generators, EPA530-F-96-032, June
Health & Safety in the Arts, City of Tuscon,

Managing You Hazardous Waste: A Guide for
Small Businesses, EPA530-K-01-005, December

New York State Department of Environmental

New Jersey Department of Environmental

RCRA Orientation Manual, U.S. EPA530-R-02-
016, January 2003.

                                     SECTION 4.0
A. leading environmental organisation once suggested
that  our planet  could  use  CPR:  "Conservation,
Preservation and Restoration". Everyone can help!
If your art  classroom program  "produces"
something, in other words a piece of artwork
such as a painting,  sculpture, jewelry  etc.  you
Should  understand  that clean  up materials,
paints/solvents, metal shavings or process rinse
waters   may  fall  into  the  hazardous  waste
management  category.  Painting,   ceramics,
photography, jewelry, printing and printmaking,
metalworking, welding,  and  woodworking, as
well  as the  associated buildings, studios  and
storage space, are some activities that commonly
use   materials    that   are
hazardous and may  therefore
become regulated waste. For
home/personal  use  (unless
you're   a professional  artist
who  qualifies  as  a   small
business), the recreational art
materials  and  residuals that
you  dispose  in the  trash are
exempt from hazardous waste
regulations. But teaching good
habits   early  on  in  an art
students career  is something
an educator should strive for.
Students  should  be  made
aware that although  they may
be technically exempted from
regulation they should attempt  to use  some or
all of the Best Management Practices  that you
will find presented here.  Why?
It  has   been  conservatively  estimated  that
approximately   1%   of  trash  collected   is
potentially hazardous waste. This is a significant
threat to the environment. If your community
or county has a Household  Hazardous  Waste
Collection Day,  this  a great opportunity  if you
qualify  as a CESQG or generator of  HHW
(Household  Hazardous Waste) to dispose  of any
unwanted or obsolete hazardous art materials.
The Collection  Center may  also  accept such
wastes from schools  or commercial studios if
they  are   CESQG   with   prior  approval.
Alternately,  if the  materials are still good and
could be reused by another artist, craftsperson
               or school, find an organization
               that can use these materials.
               Hazardous wastes need  to be
               properly managed in order to
               ensure that they will not pollute
               the land, air, or water. Through
               your efforts and your students'
               efforts to reduce toxic materials
               usage and minimize hazardous
               waste  generation  in  your  art
               classroom programs, you will
               be    making    a    significant
               contribution to providing for a
               cleaner,   safer  and  healthier
               planet and further  ensure that
               you will have a safe studio and
               classroom to work in.

4.1 Know the Materials You Use and Store

Read the label. Read the directions prior to use. These
are important  concepts to  stress with  your
students. Many people,  young and old,  do not
read the directions until whatever it is that they
are using does not seem to be doing what they
thought it should do. In order to manage your
art materials, it is important to understand their
chemical and physical properties, and potential
health and environmental hazards.
Creating a Comprehensive Chemical and
Hazardous Materials Inventory
Anyone who has ever moved recognizes how
easy it is to accumulate "stuff. Just look around
your art classroom(s). There are probably a lot
of items that can or should be disposed of. Make
an inventory list of all the art materials you have,
and  determine  whether the  material  is  still
usable; check the quality and expiration dates.
If you  have very old paints  and pigments, you
may have what the EPA considers "abandoned"
or "orphaned" hazardous waste materials. ANY
containers that are unlabelled or unmarked, or
are in any way unidentifiable, need to be  dealt
with — do not keep  them around! You should
arrange  for  their proper disposal or, if you are
exempt from  hazardous waste management
requirements  as  a  generator   of  Household
Hazardous Waste (and in some  cases CESQG),
bring them  to the next Household Hazardous
Waste   Collection Day in  your  region  or
community, if they  will  accept such  wastes.
Determining if a material is hazardous  takes a
scientific approach.  Do not sniff anything to
determine what  it is!  It  is unscientific  and
potentially dangerous. Some dyes and catalysts
used in fabrics, and plasticizers may contain
reactive or explosive organic peroxides; don't try
to unscrew the tops of bottles that have crystals
around the edges - the friction alone can cause
them to explode.  Always start with the safety
data information provided by the manufacturer
or  contact  the supplier to get  the  correct
information on  the product.  If  these  aren't
available (i.e., labels are missing or illegible) you
may have  to have a sample analyzed to  get the
information you need.
                                               Use  your  final  materials  inventory  list  to
                                               determine which  materials  to  dispose,  and
                                               which materials to replace with  safer versions
                                               (see   Appendix   D   for  a  list  of  some
                                               environmentally friendly products and vendors).
                                               The   information   you   collect   regarding
                                               hazardous materials will need to be shared with
                                               your coworkers, students and local officials (see

                                               4.2  The Community's Right to Know and
                                               the Workers' Right to Know

                                               Everyone has the Right to Know (RTK) under
                                               federal  Occupational  Safety  and  Health Act
                                               (OSHA)  regulations, all there is to  know about
                                               the  risks  and hazards of the  materials  and
                                               processes they will  be  expected  to  use.  In
                                               addition, each  community has  the Right  to
                                               Know under  federal Environmental Protection
                                               Agency  (EPA) regulations.  These  regulations
                                               have numerous implications.

                                               4.2.1 Your Community's Right to Know and
                                               Emergency Planning
                                               EPA   regulations  require   that   emergency
                                               response information is available  for emergency
                                               response personnel. Generally, the  regulations
                                               apply to any  facility  that  has an inventory  of
                                               hazardous  materials   in  excess  of  certain
                                               quantities, some of which can be very small for
                                               extremely hazardous  substances  (see  Section
                                               5.0).   If  you  store   certain items  in  these
                                               quantities, a list of the hazardous substances will
                                               need to  be completed  and a Tier II report filed
                                               that will  include information on the quantities
                                               kept at the  facility,  such  as  where they are
                                               located  and   if  they   are  flammable, toxic,
                                               reactive,  etc.   This report will  be submitted
                                               annually   (due  March   1)   and  must   be
                                               accompanied  by a Material  Safety Data  Sheet
                                               (MSDS) for each item listed in the report.  The
                                               report is distributed  to your local emergency
                                               planning commission  (LEPC), your local Fire
                                               Department, and the State Emergency Response
                                               Commission (SERC). The Fire Department also
                                               commonly has specific  requirements  on  the
                                               storage and use of flammable and  combustible
                                               liquids,   compressed    gas   and   hazardous

materials. Depending on the type and quantity
of materials stored you may need to register the
activity and obtain a Certificate of Fitness for
the process or materials used. In any emergency
situation at your facility, they will have basic
safety  information  on how to best plan  their
response  action  to  protect  the surrounding
community and themselves. (Note: For those in the
New York City area, this regulation may be particularly
applicable for your art curriculums. The NYCDEP has
established kwer   threshold  quantities  for  certain
chemicals and chemical categories used or stored in the
city; the reporting and distribution are similar to federal
If  your  art  materials  are  hazardous   (and
especially if you are not sure whether they are
hazardous),  bring your  inventory list to  the
attention   of   the   school   administration,
chemistry department,  and/or the  local  fire
department  to  help you determine  what you
have  and what your  legal  obligations  are  in
respect   to  ensuring   the   safety  of   the
environment and the students, your coworkers
and yourself. Check out  the web resources and
links provided  in the appendices  and look for
compliance assistance information and contacts
from  the  NYCDEP,   NYSDEC  and  EPA
Region  II. There is a lot  of good  and useful
information to be found.

4.2.2  The Workers' Right to Know
OSHA ensures that  all employers  provide their
employees with a safe workplace. One  of the
key  provisions  for worker  safety is  that
Employees have a "Right to  Know" all there is
to know  about the risks  and hazards of the
materials  and  processes  that they will  be
expected to use.  Employers comply with this
Hazard   Communication   Standard   [29   CFR-
1910.1200] by  formally  identifying  all of the
potential health risks to workers from materials
and processes that they would be  expected to
use.  After this job hazard analysis the employer
needs    to    develop   a    written    hazard
communication  program and provide  training
for its  employees. A critical  element  of the
program is to make Material Safety Data Sheets
(MSDSs) available to their workers.
As the teacher, you become the technical person
and supervisor in charge of your art classroom
and facility  area.  Furthermore, as part of the
management  structure,   it   is   now   your
responsibility  to  fulfill  the  duty  of  your
employer in providing a safe "workplace" for all
your students.  You should  train  students to
recognize materials that can cause  fire, adverse
chemical    reactions,   health    risks    and
environmental threats. They  must  be prepared
to act accordingly in the event of an emergency
such as fire or spill.
In order to help you in communicating the
hazards  identified,  you  should   contact  the
manufacturer or supplier and request a copy of
the MSDS for each product used  or stored in
the classroom or  studio  space  you  manage.
Keep  in  mind  that this  will  only be basic
training.  There is an important point to make
here  in  how you   present  the  information
provided.    How  you  present  this  safety
information is critical; make sure it is displayed
neatly  and in  an appropriate  place.  An artist's
material may contain a hazardous chemical and
that artist should use and store it according to
the manufacturer's  recommendation.  We  can
not stress the importance of clearly and simply
communicating risk  to your staff and students.
Some  people are afraid of  being exposed to
materials that have  any amount of hazardous
ingredients.  You  need to consider  both  the
perception of risk and actual risk and potential
consequences for each material before  using it
in the classroom. Use the MSDS as  a start,
which  should contain a variety of information
about  the  product,  including  the following:
information about the hazardous  ingredients;
their concentrations or percent composition for
mixtures; physical and chemical information; its
state (solid, liquid or gas); how it enters the body
(i.e., routes of exposure, inhalation, eye  contact,

skin absorption, and ingestion); suggestions for
keeping within permissible exposure limits; and,
first aid measures if adverse health effects occur
from excessive or accidental  exposures.   The
manufacturer can also provide basic information
for safe  transportation and disposal as well as
ecological  information  and  recommendations
for safe handling, use and storage.
After ensuring that you have an MSDS for every
hazardous  material on  your list, it  is your
obligation  to  post the information where it is
readily available to anyone who wishes to view
it. (See Appendix  E for a listing of resources
where you  can obtain copies  of MSDS's.)
It is  important  that  you know  the chemical
composition of each item to determine if any of
the scrap  or waste  is,  by definition,   RCRA
hazardous waste.
4.3 Minimizing Exposure

There  are  three  major  categories  of hazard
control measures that you can use to minimize
1.  Engineering  controls,  which may  include
    process modification  or substitution of a
    less hazardous material or process;
2.  Isolation of the  hazard by enclosing it  or
    using exhaust and local ventilation  systems
    to remove the hazard at the source; and
3.  Administrative controls, which include:
    •   reducing the  amount of time the person
        spends  with hazardous materials  or in a
        hazardous area;
    •   using safe, standard operating procedures;
    •   training; and
    •   using personal protective equipment. This
        includes eye protection, hand protection,
        and clothing (e.g., aprons, lab coats, safety
        shoes, goggles).
Careful   review    of   the    manufacturers'
recommendations  will   help   you  determine
which control methods to use.
In  general,  good  personal  hygienic  and safe
work practices will help  you to avoid or reduce
most exposures to toxic art materials.

•   have food  or  drinks   (including coffee) in  an
    area where hazardous materials are being used;
•   store food  in a refrigerator  used for chemical
•   hold a paint brush or other tool in your mouth;
    YOUR SKIN. Avoid all skin contact with these
    materials. They not only can defat the skin but
    can have chronic health effects on the central
    nervous  system and target organs such as the
    heart  and  liver.  Pregnant  women  should
    minimize all exposure to the extent possible to
    prevent injury to an unborn fetus.

•   wash hands  frequently when working with any
    chemicals (especially prior  to eating, drinking or
    smoking or using the bathroom);
•   use soap and  water with scrubby mitts or a
    loofah to clean hands and splatters;
•   wear protective gloves when using solvents to
    clean    surfaces,   then   follow   with    a
    decontamination wash with hot soapy water and
    rinse off thoroughly with clean water;

•   know what to do in an emergency; and
•   Be a good role model. Your students look to
    you for guidance, if you are careless, they will be
    careless, too.

There are a number of general precautions and
some useful  advice  that should  be  followed
when using any hazardous material. First, know
as much as you  can about the  materials you
have  chosen to create your  masterpiece. Then,

ask yourself some basic questions, starting with
what happens when I take the  lid off the jar?
And what should I do if I spill some on me?
Routes  of Exposure and  Personal Protective
Equipment are  two primary  considerations  in
reducing the risk of using or handling hazardous
There   are  potentially many  ways  a  toxic
substance can enter the body;  these pathways
are called Routes  of Exposure  and  are further
described as:
•   Inhalation
•   Skin Contact
•   Eye Contact
•   Ingestion
And  then you have  to  also  consider both
physical and  ergonomic hazards of the process
or techniques used to create "the product" (e.g.,
lifting,  bending, twisting,  repetitive   motion,
sharp edges, tools.)

Inhalation Risks
Regardless of the type of art work you do, the
materials   and   processes  can  generate  air
Uncontrolled emissions  from  woodworking,
welding and  ceramics  studios become  readily
visible and obvious in  very short order.  Aside
from the visible particulate emissions (i.e., dust,
mists and smoke fumes) you have to be  aware
of the non-obvious hazards, such as heavy metal
If you are a  painter, printer or photoprocessor
the  emissions   are  not  always   visible  but
generally more likely to be detected by  smell.
These air contaminants can cause adverse health
effects at  concentrations well below established
odor thresholds.
There are basically two ways to defend yourself
against  overexposure.  One is to provide  for
adequate exhaust ventilation and the second is
to mechanically filter out the contaminant using
a personal protective device.
If  you   have   obtained  the  manufacturer's
material safety information, one of the sections
will recommend providing adequate ventilation,
which  translates  into  making sure you have
sufficient air change in the room you're working
in by opening windows, installing fans or using
HVAC  make-up  air systems.  In some  cases,
manufacturers  recommend  providing  local
exhaust, which translates into providing a means
to capture the contaminants at the point  of
generation so that they do not saturate a room.
Air  emissions can  be  a  mixture  of  many
different chemical constituents, some hazardous
and some labeled as a nuisance.
OSHA  has  established  permissible  exposure
limits   for  a  long  list  of  chemicals  and
intermediaries, as well as  nuisance particulates.
ACGIH and NIOSH are also good sources  of
information  on  acceptable  or  recommended
exposure  levels, which can  be  found at their
Process   contaminant   categories   can   be
established following the waste listing codes.
•   D codes are the characteristic wastes and exhibit
    a hazard based on the nature of the material or a
    specific chemical compound.
•   F codes that may apply to artwork are  for the
    solvent type of waste processes.
•   P & U codes  are for  acutely hazardous waste
    and commercial chemical products, respectively,
    so if you're starting with a process material that
    is on either of the lists, you know that it exhibits
    one of the characteristics  or contains  a toxic
In printmaking,  for  example, you  might use
volatile  haze  removers or press  wash solutions
that can release flammable and toxic vapors into
the air.  In surface finishing using aerosol spray
paints you could release  a lot of listed volatile
toxic organics. These  solvent-based  emissions
are health risks  due to overexposure and can
lead  to  blindness, or brain or central nervous
system damage. They can also damage the heart,
liver and kidneys.  Photoprocessing and acid etch
solutions  are, or  can  be,  both  toxic  and
corrosive. Breathing in mists can cause  severe
respiratory discomfort and long term damage.

Certain pigments  present  in powders  used in
printmaking, ceramics and sculpture can contain
chromate   constituents   that   cause   nasal
ulceration  and  are  known, or  suspected as,
For the  toxic substances that may be  present,
always  provide  a  means to  minimize  the
potential   for   exposure   using   engineering
controls  such as local exhaust. Examples include
welding  fume  extractors,  spray paint  booths,
acid bath fume  hoods and laboratory chemical
fume hoods.
For   flammables  and  combustibles,   always
ensure adequate dilution ventilation in the room
by using fans or make-up air systems to prevent
the build up of contaminants to unsafe levels in
air in order to minimize the potential  for fire
and explosions.
Particulate  emissions,   such   as   dust  from
printmaking,  ceramics  and   sculpture,  may
contain silica powders, lead chromate pigments
or carbon black, all of which can cause adverse
health effects.  Even plain woodworking dust
generated by cutting or sanding operations can
be harmful and explosive if allowed to build up.

Skin Contact
The skin can act as a sponge and readily absorbs
toxics present in solvents that can  cause serious
damage to target organs. It also is easily  irritated
and burned by aggressive chemical compounds.
Wearing a lab or shop coat or apron to  prevent
exposure is  strongly  recommended  for two
reasons.  First,  it  helps  to prevent  you from
immediately getting overexposed.   Second,  it
prevents   your   clothing  from   becoming
contaminated, in  which case you might  have
inadvertently  taken  contaminants  home  on
clothing,  potentially exposing  your  family  or
pets. This would be of particular importance  if
using materials  having  any concentration  of
lead. When using or handling chemicals, always
wear appropriate approved chemically resistant
gloves   to  minimize   the   risk  of   injury.
Recommended gloves  for  a particular task can
be determined  from manufacturer information,
industry   trade  groups,  or  other  reference
sources.    OSHA's  Office  of  Training and
Education cites the following common types of
gloves and their rated use.
•   Norfoil   laminate   resists   permeation   and
    breakthrough by an array  of toxic/hazardous
•   Butyl provides the highest permeation resistance
    to gas  or water vapors; frequently used for
    ketones  (M.E.K.,  Acetone)  and  esters  (Amyl
    Acetate, Ethyl Acetate).
•   Viton is  highly resistant  to  permeation  by
    chlorinated and aromatic solvents.
•   Nitrile provides protection against  a wide variety
    of solvents, harsh chemicals, fats and petroleum
    products and also  provides excellent resistance
    to cuts, snags, punctures and abrasions.
•   Kevlar  protects   against cuts,  slashes,  and
•   Stainless steel mesh protects against cuts  and
Often  overlooked  is  foot protection.  Never
wear open-toed shoes or sandals when using or
working around hazardous materials. Chemicals
used in photoprocessing, acid etching, jewelry
acid pickle solutions and building maintenance
masonry cleaners, for example, are all corrosive
and can severely damage  intact  skin.  If you
have an accident, flush the skin  surface with
copious  amounts  of water and seek  medical
attention. Some acid exposures, such as Nitric
and Hydrofluoric acids, do not always  provide
immediate warning of overexposure until hours
after use.  Hydrofluoric is particularly dangerous
in that, while you might think it was  flushed
from the  skin's surface, it  absorbs through  the
skin only to attack the calcium in bone.
Dry powders can also release chemicals, such as
chromates in lamp black pigments in inks used
in  printmaking.  UV  lights  used  in  certain
developing processes can also damage the skin.

Eye contact
There are no second chances when we're talking
about eye injury.  If you're using any equipment
or material that has a potential to fragment —
sending  out  sparks, chips  or other debris -

always wear approved safety eyewear with side
When working with or  around hazardous fine
powders  or  corrosive   liquids,  wear  safety
goggles and face  shields  for full eye protection.
Remember  to thoroughly wash  your  hands
before touching the eyes. If the area or activity
you are doing causes you to perspire, wipe your
face  frequently using a  clean towel to prevent
absorption through the eyes.

Rules of the road -DON'T TAKE CHANCES!
•   Wear suitable eye protection. Eye and face PPE
    purchased  after July 5, 1994 must comply with
    ANSI Z87.1-1989, American National Standard
    Practice for Occupational and Educational Eye and
    face Protection,  and must be distinctly marked to
    facilitate identification  of the manufacturer.
•   Know  the  location  of  emergency  eye wash
    stations and safety showers.
•   Flush  the  eyes  with  copious  (lots  and  lots)
    amounts of water.
•   Report the accident  and seek  proper medical
Toxic and hazardous substances can be ingested
primarily   due  to  poor  housekeeping  and
inadequate personal hygiene. If you  are using
such materials or are in an area where they are
routinely used, never eat, drink or smoke in the
area, and never do so elsewhere without  first
washing your hands. Proper decontamination of
work tables, floors and  the surrounding  area
after you have completed your work is essential.
You  can  not  always see  or  smell process
residuals and the next person that comes along
- or even you - could inadvertently come  into
contact with them and put  a piece of gum in
your mouth or have lunch shortly after without
realizing what you may be exposing yourself to.
This reminds us  to repeat two key points:
•   Wash your hands frequently.
•   Wear approved PPE.
Physical / Ergonomic Hazards
Certain  types   of  equipment   and  materials
storage and handling activity can result in having
to lift heavy or bulky items. Always ask for help.
Organize  work  stations  to minimize  pinch
points or  risks  of being exposed to  chips,
sparks, open  flames,  welding arcs, fumes or
mists.  Avoiding  repetitive   motions  over  a
prolonged period of time and providing proper
seating with  support  for the  lower lumbar
region are  recommended.  Keep  the work area
clean and  free from any  accumulation  of oils
and  debris to minimize the  potential for slips,
trips and falls.  If you are  doing elevated work,
such  as with  sculpture  projects,  use a  proper
ladder or  work platform.   Follow electrical
safety  rules, use properly  grounded  equipment
and   receptacles   and  minimize  the  use  of
extension  cords.  If  the  equipment or  tools
create  noise, wear hearing  protection devices
such as ear plugs, canal caps or muffs.
•   OSHA 1910.132(d) requires that if all  feasible
    engineering and work practice controls  are in
    place,  but  employees  are still  exposed to
    potential hazards, PPE must be provided.
•   See Checklist B  in  OSHA Publication  3151,
    Assessing the Need for PPE, A Guide for Small
    business Employers, to assess the need for PPE.
•   See also General Industry (29 CFR 1910)
•   1910 Subpart I, Personal protective equipment
•   1910.134, Respiratory protection

Please note that a covered facility must have
a  written  Respiratory Protection Program
that includes  as a minimum  the following
•   Appendix A, Fit testing procedures (Mandatory)
•   Appendix  B-l,  User  seal check  procedures
•   Appendix B-2,  Respiratory  cleaning procedures
•   Appendix   C,  OSHA  respirator  medical
    evaluation questionnaire  (Mandatory)
•   Appendix D, Information  for employees using
    respirators  when not required under standard

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                                    SECTION 5.0
This section lists some  of the  more common
artwork methods and materials, and the primary
and less obvious risks associated with each, in
addition  to suggestions for safe  usage  and

5.1 Painting and Solvents Use

5.1.1 Major Dangers
Inhalation of dusts, sprays  and  solvent vapors:
Powdered  pigments (dust),  spray  mist,  and
vapors are easily inhaled,  often without being
noticed. Just opening a container of solvent and
breathing in can cause damage. The  strength of
the smell is not a reliable indicator of potential
danger.  Always ensure that you have adequate
ventilation  in the  class  area  and  studios.  Use
personal  protective  equipment  (PPE)   and
clothing.   Follow   the     recommendations
suggested  in the manufacturer's Material Safety
Data  Sheets  (MSDS's)  and product  safety
literature,  and follow the   safety  guidelines  in
your  school  department  or studio guidance
Accidental  ingestion of paints, pigments,  and
solvents: No one  would take a spoon full  of
paint  or solvent intentionally;  however, it is
relatively  easy  to   accidentally  swallow small
amounts  of hazardous  materials  simply  by
eating, drinking, or smoking in  your studio.
Skin will also absorb chemicals; as such,
precautions  should  be  taken  to  minimize
contact,  especially with  the  eyes, nose  and
Do not  allow eating, drinking or smoking  in
your studio.  Each of these activities can not
only a provide  a pathway for  exposure, if the
food, drinks or  cigarettes,  respectively,  were
exposed  to paint, pigments, solvents or residue
of these materials, but can provide a more direct
pathway  for chemicals to reach  the  digestive
tract or respiratory system (and thereby to the
bloodstream) than passive exposure.

5.1.2  Less Obvious Dangers
Skin  contact with paints and solvents:  Skin
absorbs chemicals  quickly - minimize  or avoid
Oil  and  solvent based  paints,  cleaners  and
thinners: Many  oils and solvents can be readily
absorbed into the body by inhalation.
Water-Based paints:  They may seem  harmless
but they may still contain toxic metal pigments
such as  cadmium, chromium, lead as well  as
toxic organics such as formaldehyde, isocyanates
and glycol ether solvents.
Low-odor solvents: Odorless is not synonymous
with safe. If it  can  melt plastic, assume it is

5.1.3  Safety Suggestions

•   Pigments,   paints,  mediums,   solvents   and
    varnishes all may contain toxic chemicals; some
    even contain lead and arsenic, as well as other
    toxic "heavy" metals. The solvents in varnishes
    and thinners are particularly dangerous  because
    of their volatility - they transition from a liquid
    state to a vapor state and can quickly permeate
    throughout   a  room,   creating  unsafe   and
    unhealthy   concentrations.  Keep  containers
    tightly closed  except when  adding or removing
    material and waste. Seemingly harmless  supplies
    such  as  water-based paint can  contain trace
    amounts  of  formaldehyde,  isocyanates   and
    ammonia. Nearly all can cause dizziness, blurred
    vision, nerve damage, eventual kidney and liver
    damage or,  in extreme cases, chronic poisoning
    and death.
•   Consider using the  new water  washable  oil
    paints  that do not  require  the use  of  any
    solvents.  Other  solvent-free  paints  include
    acrylics, gouache and watercolors.
•   Buy paints that list the pigments and avoid those
    containing cadmium, chromium,  lead,  barium,
    mercury  (e.g.,   cadmium   mercuric  sulfate,
    mercuric  sulfate),  selenium   (e.g.,  cadmium
    seleno-sulfide),  and  arsenic;   waste   paints
    containing these  metals  and wastes containing
    these  paints   may  be  toxic  characteristic
    hazardous waste.   Also consider avoiding paints
    containing  antimony,  cobalt,  manganese  and
    nickel.    Similarly  avoid  paints  and  gessos
    containing lead-pigments,  such as flake white.
    Pregnant  women  in particular  should  not  use
    any lead pigments  or products.
•   Water-based products are  not necessarily  the
    safest;  they  may contain  toxic metals. Pay close
    attention to the labels.   Other metals that may
    be present in  some paints may be regulated in
    waste water and storm drain releases, including
    copper,  zinc,  cobalt, nickel  manganese,  and
    others.  Local regulations should be checked to
    compare contents of your  paints with  what is
    allowed down sinks and floor drains.
•   Try to replace turpentine  and other  aggressive
    solvents   with solvents   that  are  less  toxic,
    volatile,   and   flammable.  This  will  require
    learning  about  air quality limits, evaporation
    rates, and flash points  (See  Glossary.) These
    concepts should be included in classroom health
    and  safety  training.  Some products  on  the
    market  are  significantly  less toxic, volatile  and
    flammable than turpentine, such as some of the
    better "turpenoids" or turpentine substitutes. All
    the solvents can be damaging to the developing
•   Ensure  proper  ventilation.  Classrooms  and
    studios should have a rapid exchange of air if
    solvents are used. Spray products require local
    exhaust, such  as  spray booths. High solvent
    painting techniques,  such  as  solvent  washes,
    should also be done in local exhaust.
•   Use pump spray bottles rather than spray paints.
    The result will be less  paint use due  to better
    transfer efficiency and loss due to overspray. If
    you do use spray painting  techniques upgrade
    your spray guns  to  high volume  low pressure
    HVLP  styles.  This  will  also  help  you  to
    minimize paint waste as overspray.
•   Avoid    spray-paints    that   contain   known
•   While  not common  in  painting,  benzene and
    carbon tetrachloride  are  banned  in consumer
    products by the U.S. Consumer Product Safety
    Commission.  Accordingly,  it is  worth  noting
    that, while they  can be  ordered  by chemistry
    departments, art departments should never buy
    solvents  that  include   benzene  or  carbon
•   Wear protective clothing  and cover your hands
    and face, particularly when spraying  or using
•   Do not eat, drink or smoke in your classroom
    work spaces or personal studio.
•   Do not leave open  containers  of solvents  or
    varnish - they will evaporate quickly and create
    unsafe  and   unhealthy  working conditions.
    Before you put the covers on clean the edges so
    that you get a good seal and close the lid tightly.
    Remember  that  if  the container is  a waste
    material you  could  be  in violation  of  the
    hazardous waste regulations  for illegal treatment
    and disposal  of hazardous waste if the material
    is not properly contained.
•   Baby  oil or  vegetable  oil  can  be  used  for
    cleaning brushes and knives  that are coated with
    oil based paint formulations
    Clean-up and disposable rags may also be used
    to wash off pallets and wipe brushes  clean. If
    they contain  concentrated  levels  of pigments
    containing   metals    defined   as    regulated
    hazardous  waste, the rags  are also  regulated
    hazardous  waste.  They  need to  be  collected,

    segregated, placed in the area designated for the
    hazardous waste container, and picked up in a
    timely manner. Other materials with paints or
    pigments  on them  should also be placed in a
    designated hazardous  waste container, rather
    than be thrown in the regular trash.
    In addition, if linseed  oil, citrus  oil/d-limone,
    tung oil, or any other setting oil is present on the
    rags, a safety  container must be  used  because
    these  rags can spontaneously combust if left
    exposed to the air.

5.1.4 Disposal
Typical EPA Regulated hazardous  wastes  from
painting classes and studio work include  paint
pigments  and colorants that may contain  toxic
heavy  metals  (e.g., cadmium,  chromium,  lead,
barium, selenium, mercury.) Paint  thinners and
reducers and cleaners may contain  toxic  and/or
flammable organic solvents containing toluene,
xylene  and  acetone,  and many  others  not
specified. You must know the materials  you are
working with to  ensure  proper disposal either
from product knowledge or analytical testing.
5.2 Ceramics

5.2.1  Major Dangers

Inhalation of dusts and glazes: Free silica poses
the biggest threat to artists using  this medium
because of its large  presence  in clay. Repeated
inhalation of free silica dust over  an  extended
period can lead to silicosis, or a form of lung
fibrosis  that causes  shortness of breath, an
increased susceptibility to infections,  and lung
Everything in ceramics involves some form of
powder and  water.  These are mixed to make
clay or glazes - when they dry out, dust results.
Often  the dusts involved are very fine and once
in the air they are  not  always  visible, which
makes   it  much  easier  to  inhale    them
accidentally. As well as  silica,  other  hazardous
particulates such as kaolin  clays may be present.
Low-fire and slip-casting clays also contain talcs,
which  may be contaminated with trace amounts
of asbestos. Asbestos can cause lung cancer and
lung scarring.
Always wear appropriate respiratory protection
when doing anything that puts powder or dust
into the  air  and  try  to  work with  wetted
materials whenever possible, and never sweep in
the shop as it will just stir up the dust, wet mop
or sponge off surfaces. For a thorough cleaning
of dusty areas  use  a vacuum cleaner  equipped
with   high  efficiency   particulate  filtration
5.2.2  Less Obvious Dangers
Clays:  Clays  usually  do  not  contain  either
regulated  or unregulated  toxic  metals.  Often
they can be released to floor drains or put out
with ordinary trash. The exception is when clays
are specially colored (e.g., black  clays colored
with   manganese  compounds,  green   clays
colored with chromium compounds)
The dust  from all clays, however, is hazardous
to inhale because clays contain minerals such as
silica,  talc and kaolin.   To  avoid  inhaling the
dust, it is  safest to buy clays premixed and clean
up  potteries by wet  mopping and/or using a
HEPA vacuum.
Glazes: Glazes, whether sold premixed or mixed
from raw ingredients by the potter, may contain
almost any known metal.
You need to consult the  MSDSs  and other
specific information from the manufacturer to
find out  exactly which  ones are present. For
example,  if barium, cadmium, chromium, lead,
selenium or silver are present, wastes containing
these glazes may be RCRA-regulated and these
waste glazes must be disposed of as hazardous
waste.  Spills and debris containing these glazes,
whether from floors or work surfaces, must also

be  collected and disposed  of  as  hazardous
While  MSDS  can  be  valuable  sources  of
information,  they are only required to  include
chemical   components   that   "have   been
determined  to  be health hazards, and  which
comprise  1% or greater of the composition,
except...chemicals identified  as  carcinogens."
Because some of these metals may be present at
less than 1%, but still above the TCLP limit, the
fact that a metal (or other chemical) is not listed
on the MSDS  does not ensure  that it  is not
present at levels  that might  fail  a TCLP  test.
Manufacturers should be able  to identify which
glazes would be hazardous waste if disposed of.
However,  because  glazes   containing   these
metals are commonly found to be hazardous, it
may be simpler and less expensive to treat these
wastes as hazardous than to perform a  TCLP
Glazes containing these  metals are  commonly
used  in  ceramics  studios  and classrooms as
•   Arsenic  -  a contaminant of a number of
    colorant  oxides such as copper, cobalt, and
    cadmium oxides, carbonates, and sulfates.
•   Barium - a major flux for medium and high
    fire glazes.  This  means it will be found in
    much greater  amounts  than if it were a
    colorant. It is  not  uncommon  for  glaze
    formulas to contain 25% or more barium.
•   Cadmium - a common colorant in low fire
    commercial  glazes  in  the yellow  to red
•   Chromium   -  used  in  many  forms  and
    compounds as a green colorant. It can be a
    chromate, oxide, carbonate, etc.
•   Lead  -  Many  formulators of  their own
    glazes use lead  frits and nearly every glaze
    company that sells low fire premixed glazes
    has at least some lead formulations in their
    catalogs.  These are still frequently found in
    ceramic   studios  and   school  ceramic
    programs.  Teachers, students and  artists
    often cannot use lead if  they fire at high
    temperatures, at which lead will  burn off.
    However, if there  are electric kilns on the
    premises, these kilns are often used for low
    fire work involving lead. You can always tell
    if lead is present if you see  certain  bright
    reds and oranges in exhibited work, as it is
    often  difficult to  get  distinctly bright reds
    without  lead  fluxes   in  the  glaze,   in
    combination  with  cadmium  and selenium
    colorants.   China  painters  and  slipware
    casters/decorators  still  commonly use all-
    lead glazes.
•   Mercury - not common except in  specialty
    work involving certain old lustre glazes. The
    mercury from these old glazes, which were
    based on  mercury amalgams of real silver
    and gold, would fire off in the kiln, leaving
    the metal lustre on the glaze surface.  Old
    stocks of these still exist.
•   Selenium  - The "new"  reds, yellows  and
    oranges    touted     by    many     glaze
    manufacturers    rely    on    selenium
    compounds,  often  used by potters who
    want to avoid cadmium reds and yellows.
•   Silver -  used  in luster glazes for decorating
    glazed   ware  by   re-firing  at  a  lower
    temperature or for lustre effects in  a fast
    firing method called "raku." A majority of
    ceramic   programs   in   schools    and
    universities fire some  raku and, if  they do,
    are likely to have silver lustre glazes or silver
    compounds,  such  as  silver nitrate, hidden
    away to get these effects.
Glazes also may  contain many metals  that are
not regulated under RCRA, but which are toxic
under  certain  conditions   including  cobalt,
copper,  zinc,  manganese,   antimony,  nickel,
lithium, boron,  and bismuth. Some of these
metals  may be regulated  by local waste water
and storm  drain regulations and should not be
put down sink or floor drains. Check with local
Glaze Chemicals: Potters who mix glazes from
raw  ingredients  are likely  to be using some
regulated chemicals. Glaze chemicals that are, or
that  contain,  regulated metals  must  also  be
subject to  a hazardous waste determination -

and may be  hazardous waste - when they are
In addition to  the RCRA toxicity characteristic
metals  listed  above,  a  common  colorant,
vanadium pentoxide, used as a  yellow high fire
colorant, is regulated as a  hazardous waste when
disposed  of.   Excess or off-spec  vanadium
pentoxide  (CAS  No.  1314-62-1)  is  regulated
under RCRA  as an "acute hazardous waste"
and, as such, it must be  manifested  using the
waste code P120 and it may raise the facilities
hazardous   waste   generator   category   (see
explanation in  Section  3.) Vanadium  pentoxide
is often sold  to potters in a paper sack with the
name  of  the  chemical  hand-written  with  a
marker on the sack.
Use of Glazes:  Glazes should be applied in ways
that do not create air-borne particles such as by
spraying or by dusting on dry glaze powders.
Such  methods should only be done in local
exhaust such  as  a  spray booth. Spray booth
filters and scrapings  must be treated as regulated
hazardous  waste  if  they  contain the regulated
metals.  State or local air quality permits may be
required for the spray booth, so  check with  state
and local officials.
Floors and surfaces contaminated  with spills,
small splashes  or dust from glazes should be
cleaned with methods that capture  the  glaze
waste. If  regulated metals  are  present,  this
material  should be  disposed of as hazardous
If liquid  glazes  are used or  stored  or large
containers   (e.g.,  buckets  containing  several
gallons or  more)  containment trays are needed
under the containers to capture potential spills
or leaks. Containers of liquid glaze should not
be present in  areas in which  there  are  floor
drains into which a spill could seep.
Firing: Potentially toxic fumes and gases may be
emitted during the  firing process  in ceramics.
Exposure  to  carbon  monoxide  and  carbon
dioxide causes headaches,  dizziness and  can
deplete oxygen levels  to  unsafe levels. Sulfur
dioxide and  formaldehyde fumes are only two
examples   of  hazardous  air  contaminants
resulting   as  byproducts   of   combustion
processes.  They are toxic and  carcinogenic  -
avoid  any  exposure in  any  amount.  Always
ensure the exhaust system is on and operating
properly during ceramic firing operations.  State
or local air  quality permits may be required for
the kilns, so check with state and local officials.
Do  not look  directly  into the kiln when  in
operation.  This  can cause  cataracts or  other
damage to your eyes due to infrared radiation.
Wear protective goggles  if you have to  work
with  the  kiln  and  must visually inspect  the
combustion chamber.

5.2.3  Safety Suggestions

•   Do not  use glazes containing lead or cadmium.
    There  are  substitutes  for  these  very toxic
    materials. Pregnant women and nursing mothers
    should never use lead  in any form and should
    consider avoiding exposure to any of the toxicity
    characteristic metals.

•   Buy premixed clays rather than mixing from dry
    powder  unless you have a local  ventilation
    system for the glaze mixing area.   In a related
    matter, ensure that the work area has proper
    ventilation   for  kilns,  glaze  spraying   and
    processes in which clay or glaze dusts are raised,
    such as mixing glazes from powdered chemicals.

•   If you make items for  use with food, consult a
    laboratory about regular testing for leaching of
    toxic metals from your glazed ware.

•   Dust masks or respirators can be worn to reduce
    exposure to dusts and sprays if you, your school
    or employer comply with the OSHA respiratory
    protection rules.

•   Work with clays and glazes when they are wet to
    reduce exposure to dust.

•   Never sweep floors. Use  a HEPA vacuum or
    wet mop  and sponge surfaces.  If regulated
    metals are present in floor and surface debris,
    the mop water and/or the HEPA filter must be
    disposed of as regulated hazardous waste.

•   Wash hands and  skin thoroughly after working
    with clay  or glazes.  Keep  soiled  shoes  and
    smocks  in the studio rather than wearing them

•   Wear  eyewear  rated  for  infrared  radiation
    protection whenever it is necessary to look into
    glowing hot kilns.

•   There  are  many other  safety  and   health
    precautions. For more complete lists, see other
    safety books in the resource list.

5.2.4 Disposal
Recycle glazes by  collecting  spills  and  debris
from spray booth  walls  and  filters. Mix this
waste with water and test fire. Often these are
acceptable  glazes  or  can  be  adjusted  with
colorants  to make  good glazes.  If they  are
unattractive,  use  the waste glazes  for unseen
surfaces such as the insides of hollow pieces not
intended for food use.
Clay  is  not normally  a regulated hazardous
waste. However, it can be dangerous to recycle
clay if you use a  mechanical clay mixer or pug
mill and  adjust the  texture with the addition of
dry clay. One safer way to recycle clay is  to
make a slurry by  adding water to chunks of dry
waste clay and drying the slurry out on plaster
Typical EPA- and state-regulated hazardous
wastes from  a  ceramic  classroom would  be
premixed commercial  glazes  and raw  glaze
chemicals. Some  potters also  use certain  lustre
glazes or paints,  which contain flammable and
toxic solvents that dry to look like glazes.
5.3 Jewelry Making and Small Metals

5.3.1  Major Dangers
Soldering: Silver soldering is a common practice
in jewelry making, but even the lowest melding
silver contains at  least 30% cadmium. Cadmium
fumes can cause chemical  pneumonia  from a
single exposure.   Some  silvers  also  contain
antimony, which  is  highly  toxic by inhalation
and can cause vomiting and irregular heart beat.
Chronic exposure to antimony fumes can lead
to  birth  defects.   Fluoride  fluxes are  also
commonly  used  and  are  strong respiratory
irritants; borax fluxes are much safer. Soldering
is  also dangerous due to metal melting hazards
(see below.)
Contact with cleaning agents: The pickles used
to clean metals in jewelry making are corrosive
to the  skin as well as being eye and respiratory
tract irritants. Inhaling the fumes of the primary
ingredient, sodium bisulfate, can even lead to
corroded  teeth.  In addition to pickles, alcohol
and acetone  solutions are  sometimes  used for
cleaning   and  finishing.   For  all  hazardous
materials    involved,    personal   protective
equipment and appropriate clothing should be
used. Follow the recommendations suggested in
the manufacturer's material safety data sheet or
product safety literature, and ensure classroom
safety guidelines exist and are adhered to.
Enamels: These are powders  of colored glass-
like materials  that fuse with heat onto metals.
Some enamels are lead-bearing, but there are
now  lead-free  enamels  commonly available.
Enamels  cannot  be  made  completely  safe
because some of  the colorants are  hazardous.
For   example,  opaque   yellows  usually  are
cadmium  pigments.  Opaque  white pigments
usually are arsenic compounds. And so on.
Silica:   Sources  of  inhalable   silica  include
polishing compounds  (e.g., tripoli),  dust from
investment molds, and dust from grinding and
polishing of many types of gem stones.
Wax:  Certain  types of hot  and  burning wax
release formaldehyde, acrolein and other toxic
fumes. If this is  the  case in your  studio  or
classroom, provide ventilation for burn out kilns
and other hot wax processes.
Inhalation and skin contact with fumes during
melting and casting: When metals are  melted,

many release toxic fumes. Inhaling these fumes
can  lead  to metal fume fever,  a condition with
severe  flu-like  symptoms.  The  fever  usually
appears a few hours after  exposure  and lasts
roughly thirty-six hours; however, it can lead to
chronic impairment..
Lead fumes are very dangerous; these fumes can
be released when  certain types  of bronze  are
melted. Always be alert for  lead exposure when
using bronze.
Always  provide  adequate  local exhaust  and
ventilation  in  the  jewelry  workspace,  wear
protective clothing when melting metals and use
an approved respirator.
Lead: Lead is extremely dangerous, even in  its
solid form. Protective  clothing; and   gloves
should be worn, as organic lead compounds can
be absorbed into  skin.  Clean up carefully after
use.  Pregnant women  have  been  advised  to
avoid all  situations  that may result in exposure
or contact with lead based materials.
Inhaling particulates while grinding or polishing:
Wear  a  mask  to  avoid  breathing  in  toxic
particulates released during these processes.

5.3.2  Safety Suggestions

•   Ensure proper ventilation.
•   Dust  masks or respirators can  be worn if you,
    your  school  or employer  comply with  the
    OSHA respiratory protection rules.
•   Wear  eye protection rated  for impact when
    grinding or chipping materials. Wear  eyewear
    rated  for chemical splash when working with
•   Pregnant women  should work neither with
    solders, metals  or  enamels  that contain lead,
    cadmium, or  antimony,   nor  with  solvent-
    containing products.
•   Avoid  lead-containing metals,  solders,  and
•   Avoid  resins   and   adhesives  that   release
•   Avoid  cyanide  plating  systems  for   surface
•   Use patinas and  other surface treatments safely
    (see the foundry section)
5.3.3 Disposal

One common EPA  regulated waste stream from
jewelry making is  pickle solutions. These are acidic
and corrosive. If the solution has been  used  for
regulated metals such  as those containing silver, lead,
chromium, or cadmium, and if these metals are in
the solution  at  levels  above  characteristic  waste
levels,  then the  pickle waste will require off-site
disposal as hazardous waste. If, instead, the solution
has only been used of other metals such as copper or
zinc, and if the levels of metals in solution will  not
exceed the local water treatment  plant's  discharge
limits, the solution can be neutralized and put down
the sink.  Neutralization  can  be  done by  adding
baking soda until the solution reaches a pH of 7,
then mixing  with water in  the  ratio of  1  part
neutralized solution to 5 parts water.
Typical EPA regulated hazardous waste  from
jewelry making  classes and studio work may
include toxic heavy metals such as cadmium,
chromium, lead, barium,  and silver, as well as
hazardous organic  solvents, such as  acetone,
flammable liquids, corrosive cleaning solutions,
etc. If you  are  unsure about  the constituents
contained in the  waste  resulting  from your
project work, ask to have samples analyzed so
that you can properly  identify any  hazardous
waste and ensure that it is handled and disposed
of in a proper manner.

5.3.4 Recommended Alternative Materials

•   Provide  ventilation  for  soldering,  grinding,
    polishing, pickling and other processes   that
    produce air contaminants.
•   Olivine sand  or synthetic  amorphous  silica  can
    be used to replace the very toxic crystalline silica
    (e.g., cristobalite)  in lost wax casting investment
    molding compounds.
•   Borax and chloride fluxes may be toxic, and  can
    cause throat and nose irritation, but can be used
    to replace the even more toxic fluoride fluxes.
•   Use  detergent solutions  for cleaning metals
    instead of solvent-based or acid solutions
•   Use  lead- and cadmium-free  enamels,  solders
    and metal alloys.

5.4 Photography

5.4.1  Major Dangers
Inhalation of Chemical Vapors:  Be aware that
many  of the  individual  chemical  substances
which are  be  present  in photo  processing
solutions either have their own particular odors
or  react in  the photodeveloping process to
release  odorous  chemicals. These  odors can
provide a warning that they are in the air. But
people's ability to detect odors varies, so odors
alone are never a good indicator of hazardous
Other indicators  that  hazardous  substances
become airborne in the process can be seen in
the rusting and  etching of metals  in the room.
In  fact,  some  of these chemicals  are  strong
enough to etch and ruin the glass  on enlargers.
Imagine what these chemicals could do to lungs
and tissues.
Ventilation  is  necessary  in  all  types  of
photography work,  as well as a keen awareness
of what is happening while you are mixing and
using  the   chemicals.  Always  use  personal
protective  equipment  and wear  appropriate
clothing.     Follow  the   recommendations
suggested in the manufacturer's material safety
data sheet or product safety literature and follow
the safety  guidelines in your  class or school
safety guidance policy.
If breathing ever becomes difficult  leave the
darkroom and get fresh air immediately.
Skin  Contact  with Chemicals:  Many  photo
developing chemicals and liquids are corrosive
and/or sensitizing  to  the skin, or will  cause
irritation;  some  have  the  potential  to  be
absorbed through your skin. Wear impervious
chemically resistant gloves at all times, use  tongs
to move prints  in and between baths, and avoid
wiping your face or eyes while in the darkroom.
Wash  hands  and  skin  thoroughly after any
contact with chemicals.

5.4.2  Less Obvious Dangers
Metals:  The only  clinical  condition  that  is
known in humans to be associated with  long-
term  exposure  to silver  is argyria, a medically
benign but permanent bluish-gray discoloration
of the skin, typically resulting from ingestion of
pharmacologic  preparations  contained  silver.
However, repeated dermal contact with  silver
may, in some cases, lead to contact dermatitis
and  a generalized  allergic  reaction to  silver.
Additionally,  exposure of open cuts  to  silver,
such  as  silver nitrate  used in  some  of the
historic  processes, can result in a non-harmful
black color remaining in the scar. Accordingly,
putting your  unprotected hands in fixing baths
or any chemical solution should be avoided, and
hands and other potentially exposed skin should
be  washed thoroughly  after  working in the
darkroom or upon contact with any chemical
5.4.3 Developing Process Awareness
Mixing photochemicals: This is the first step in
the  developing   process.  Always  purchase
photochemicals  in  liquid  form  rather than  as
powdered chemicals to avoid exposure to highly
concentrated  chemical dusts.  Although   the
liquid  photochemical  concentrates  are safer,
they still  should  be handled  and diluted with
water carefully to avoid skin  and eye contact.
Eyewear  rated for protection  from chemical
splash  should always be  worn  when working
with photo chemicals  and eye wash stations
should be installed in every darkroom.
The liquid concentrate for one of the baths (the
stop bath)  requires  special  warnings.  Some
photographers make these solutions by diluting
concentrated  "glacial"  acetic  acid  which  is

99.8% pure.  Glacial acetic  acid  is flammable,
must be stored alone because it is reactive with
both other acids and  solvents, and can cause
instant burns to the  skin  and  eyes.   When
diluting this,  or any acid, add  the acid  to the
water — never the other way around.
Storing & using photochemicals:  Store  the
chemicals in  clearly labeled  and sealed bottles.
Place   large    containers,   dispensers   and
cubitainers in  containment  trays to  control
spills. Non-flammable chemical sorbants should
be  in  all  storage  areas  and  darkrooms for
emergencies to absorb spills quickly. All photo
darkroom emergency response procedures for
chemical spills  or accidents should be posted
and  rehearsed.  This  is  especially important
because   emergency   response   may   be
complicated  by low  lighting  or  by  restricted
access  to  darkrooms  through light-tight doors
or baffles.
Chemical  dispensers   of  regulated  chemicals
should not be placed above sinks where an open
spigot  or  spill will direct  the chemical straight
into  the  drain.  One  good solution  to  this
problem  is   to  place  dispensers with  pump
systems in them in  containment  trays on the
floor under the sink. Then the chemicals can be
pumped up into developing trays in the sink and
siphoned back down again without risking large
spills to the drain.
Black & white processing. There are three basic
chemical   baths   used   in   sequence    in
photoprocessing: Developing solutions to bring
up the image, stop baths to keep the print from
over  developing, and  fixers  to  wash  the
dissolved  silver  out  of  the   film. All these
solutions are toxic  and/or  sensitizing in their
own ways and  skin and eye contact should be
The  solutions usually have sulfite compounds  in
them,  as  preservatives, which release  sulfur
dioxide gas to  the air.  This gas  is a common
trigger for allergies including asthma and is also
irritating to the respiratory system and eyes. The
air in the darkroom will contain some acetic acid
vapors from the stop bath and small amounts  of
other chemicals from the process.
Silver.  The major regulated waste in darkroom
chemicals is the  spent fixer  which  contains
dissolved silver. Sometimes there also is silver at
levels  of concern  in  the  stop bath  and any
additional wash water rinses as well.
One way to manage silver-containing waste is to
collect it all in containers and have it taken off
site by either toxic waste disposal companies  or
by other photo companies  that will reclaim the
silver and sell it.
Another way to handle this waste is to contract
with companies that provide silver reclaiming
machines which will filter the  silver  from the
solutions. Once silver wastewater has been run
through one of these units, it can be put down
the drain. Periodically, the company services the
machine,  removes   the  collected  silver,  and
provides a fresh filtering cartridge.
Some areas of the country, including New York
City, have specific requirements for wastewater
containing silver. In NYC, for example, a facility
that releases silver  to the drain would need  to
develop and write a Best Management Practices
Plan, conduct periodic testing of the effluent
(discharged   wastewater)   and   record   the
quantities of spent solutions generated.
The method you  choose  will  depend on the
quantity  of chemicals  used, frequency of use,
local  sewer  requirements,  staffing resources,
space limitations, and other factors.   Keep  in
mind that for a small photo department, it is
often more economical to simply collect the
solutions  and  have   them   recycled  by  a
commercial  vendor, rather than buy  or  lease
silver recovery units.
Color processing: Most color developing is now
done in color processing machines so exposure
to  the  solutions  only  occurs  when they are
mixed, put into and taken out of the processor.
Many of the hazards are the same as black and
white  chemicals  with  the addition  of  some
unusual  and esoteric  chemicals   about which
little is known.
Toning:  This  is a  process by which  silver is
removed from the print  and replaced   with
another metal or substance of a different color.
Some  of the  metals  used to  replace  silver

include selenium, copper, platinum, palladium,
uranium, and iron. Sulfide toning replaces silver
with brown-colored silver sulfide. Some of the
common  emissions from these  processes are
sulfur  dioxide and hydrogen sulfide.  However,
there are  many toning processes and  the  ones
you use must be assessed for their hazards and
the types of waste they generate.
Historic  processes: There  are  far  too  many
historic processes to cover all  the   regulated
chemicals that could be involved. Artisans doing
historic  processes must  carefully assess  the
chemicals  they   use   for  hazards   both  to
themselves and to the environment.
For  example, some  of the processes employ
hydrochloric acid, which is  a  strong  corrosive.
Other processes  use potassium and ammonium
dichromates, and other chromium compounds,
which are regulated as hazardous wastes if they
are spent, obsolete or disposed  of. Potassium
ferricyanide   and  the   other   ferri-   and
ferrocyanides are particularly hazardous because,
when  heated or allowed to  mix with  acidic
solutions,  they   release  hydrogen cyanide gas
which is  deadly by  inhalation.  They also are
known to release cyanide under both alkaline
and acid soil  conditions in the environment.
UV  Light Sources: UV light looks wonderful,
but it is  intense  radiation;  exposure  to it can
cause  burns, cataracts, and  blindness. Do not
look directly at  the light  source,  and  keep skin
exposure to a minimum.

5.4.4  Safety Suggestions

•   Provide appropriate ventilation for each process.
    Usually   general  or   dilution   ventilation   is
    adequate  for black and white processing. Mixing
    of  chemicals,  toning,   and   some  historic
    processes will need local ventilation  such as a
    sink with a built-in exhaust slot opening at the
    splash  board.  Color  processors can now  be
    purchased with a local exhaust opening and duct
    build  in.  If  the facility  conducts  an  OSHA
    respiratory protection program, users may also
    choose to wear respiratory  protection with a
    cartridge that filters organic vapors,.
•   Purchase  black and white  and  color processing
    chemicals premixed in liquid form rather than
    dry powders.
•   Purchase acetic acid for stop baths in a diluted
    form (e.g., 50%) rather than as glacial acetic acid.
•   Evaluate the formulas of all toners and historic
    chemicals  to determine if they are potentially
    toxic to you or regulated in toxic waste or waste
•   Use gloves, tongs or photoprocessing machines
    rather than putting your hands in contact with
    the chemicals.
•   Always wear eyewear rated for chemical splash
    when using photochemicals.
•   Follow all general hygiene procedures, such as
    washing hand  thoroughly  after any exposure,
    not eating in the  darkroom and  cleaning  up
    spills promptly.
•   Set up emergency procedures  to deal  with
    potential  spills,  accidents or  illnesses.  Post
    information in  readily visible locations (such as
    in the darkroom and just outside the entrance to
    the darkroom) and rehearse procedures.
•   Pregnant women  should  not work with  any
    material  that  contains lead  or   solvents  in
    particular.  Many of the complex photochemicals
    have never been evaluated for the effects on the
    fetus and caution should be used.

5.4.5 Disposal

Certain photo processing wastes  —  from black
and  white, color  and toning - are hazardous
waste because they contain  significant levels of
RCRA  toxic  metals  (e.g., silver,  selenium,
cadmium,  chromium, lead, barium)  or because
they  release  sulfides  or  cyanides.  The  most
common is waste  silver solution, which is often
generated  in  concentrations  above 5 mg/L,
thereby  being  a regulated hazardous  waste
requiring proper treatment or disposal.
Check to  see if solutions  containing metals
other than the RCRA metals are  restricted  by
local   waste   water   and   storm   discharge
regulations; as mentioned previously in  regard
to silver,  if pretreatment or recovery of  the
metals is  needed to keep  them  from being
discharged  to   sewers,  it  is  often   more
economical for small programs to simply collect
the wastes  for recycling or  disposal  through a
commercial vendor,   rather   than  using onsite
recovery equipment.

Corrosive liquids (pH <2 or >12.5) are also
hazardous  waste and  need  proper  treatment
and/or disposal.
Any unused film, aerosol spray cans such as for
surface  mount  adhesives, and any toners and
developers that are obsolete should be sent off
site for proper treatment and disposal.
5.5 Printing and Printmaking

5.5.1  Major Dangers
Inhalation: Vapors and gases from evaporating
solvents  and acids,  spray mists  from  power
washing  of screens and  aerosol products, and
dusts  from powdered materials  such  as talc
(French  chalk)   abound  in  printmaking. It is
necessary to evaluate procedures which produce
toxic  airborne contaminants and determine the
proper type of ventilation needed to  reduce  or
eliminate   these  exposures.  The  ventilation
systems   can  range  from  dilution   room
ventilation to local  exhaust systems such  as
chemistry fume hoods for acid etching baths
and flexible duct systems for cleaning  presses
with solvents.
Be  aware that  some of the solvents used  in
printmaking have very low odor warning levels
or may even smell good (e.g., lithotine.) Such
solvents  may cause  damage  before you  are
aware   that  you   have  been   overexposed.
Headaches  and  lightheadedness  are   acute
symptoms of solvent over exposure which may
also be  silently causing chronic damage to the
nervous  system, liver and kidneys. Acids can
cause  respiratory irritation which varies  with
exposure from  a little sore throat to chemical
Skin  contact:   Some   substances   used   in
printmaking  are associated with  skin  cancer,
such as chromate  pigments,  carbon  black and
lamp  black  pigments  in  inks  and   Tusche
(crayons), and UV light used for exposing photo
etching plates.
In addition, many substances absorb through
the skin, such  as  certain solvents,   including
hexane, toluene, and the glycol ethers in some
water-based printmaking inks.  Lead  pigments
and lead metal may also be absorbed  though
skin. The lead pigments include chrome yellow
and chrome green (both lead chromates), milori
green,  and molybdate orange. Lead metal and
the compounds formed on the surface of lead as
it oxidizes (turns dark)  also absorb through the
skin. Setting lead type is one way this exposure
can occur.
Eye  contact: There are a number of solvents
and acids  used in etching and lithography that
can cause serious eye damage. Eyewear rated for
protection  against chemical  splash should be
worn when working with acids  and eye wash
stations should be located in the areas where
acids are used and stored. If acids (or bases) are
used, an  emergency  shower should  also be
installed and may be required by OSHA  or  a
state counterpart.
Lead exposure: Printmaking is likely to  expose
artisans to lead, which  is a possible carcinogen
and  causes  both  acute  and  subtle  chronic
damage,   such  as   loss   of mental   acuity,
neurological  damage,  and  kidney and  liver
damage. Printmakers using lead  also may be
putting their  children  at risk  from  the  lead
contamination they inadvertently bring home on
clothing, shoes, skin and hair. Pregnant women,
in particular, should never be exposed  to any
amount of lead that can be  avoided,  however
Printmaking techniques: All of these techniques
can  be made  safer with  proper ventilation,
wearing gloves, and thorough washing of hands
and  exposed skin after processes.   However,
each process may also  have specific  concerns

based  on  the  materials  used.   There  are too
many techniques to cover them all, but  some of
the major ones are discussed below.
Intaglio: Traditional etching employs nitric acid,
hydrochloric   acid,   and   Dutch   Mordant
(hydrochloric acid plus  potassium perchlorate.)
These  are highly hazardous etches, which many
schools and printmakers have replaced with the
much  safer ferric  chloride  solutions.  Some
printmakers add citric acid to the ferric  chloride
which  makes the solution almost as  acidic as
hydrochloric acid.  It  is  better  to use  ferric
chloride alone even though  it takes longer to
The resists or  "grounds" often contain  toxic
solvents; accordingly, ventilation may be needed
when using them. Powdered  rosin, which is a
strong  respiratory  sensitizer associated  with
asthma, is used in the aquatint  process.  When
the rosin dust  is concentrated in the air  in the
aquatint box, it is  also explosive.  Sources of
flame,  electricity, and. static electrical discharges
should be kept away from the rosin box.
Lithography: All  of  the  same  acids  used in
intaglio,  plus phosphoric acid,  are commonly
used  in lithography.  Although  the acids are
usually  used  in  very  small  (eye  dropper)
amounts, eye  protection and gloves  are  still
 Litho  presses  usually  need a  local  exhaust
system  because  acids  and  solvents often are
used to modify the  surface of the  litho stone
while it is on the press.
Silkscreen:  Solvent-based silk screen is not often
done   today.  Instead,  safer  water-based  silk
screen materials can be used. However, they will
also contain  pigments,  some of which may
contain toxic and regulated metals.  The  resists
to make the  stencils are usually solvent-bearing.
Diazo photo emulsions are usually safer.
Cleaning, screens with power spraying will result
in a water mist containing the potentially toxic
inks getting airborne. Either ventilation should
be  provided  for  this  process or inexpensive
screens can be used and discarded to save time
and the cost of ventilation. Alternatively, if your
facility has a respiratory protection  program in
place,  mist-filtering  respirators  can  be  used
during screen cleaning.
Photoetching. It is important to obtain the MSDSs
on the solvents used in this process, since some
will be very toxic glycol ethers.
Typesetting.  Setting  old  fashioned lead type for
letter press work can expose you to lead by skin
absorption.  The lead type  also  "sheds" small
particles of lead  oxides  which   end up  on
surfaces  throughout  the   pressroom.   This
contamination  can be transferred to the skin, to
the mouth by hand-to-mouth contact, and taken
home on shoes and clothing.
The inks also may contain lead and other  toxic
pigments. Ventilation should be used for the
presses if solvents are used  to clean the press
and the type.

5.5.2  Safety Suggestions

•   Ensure proper  ventilation, even  if you  don't
    smell anything  or  if  you  like  the  smell.
    Remember   that  pleasant  odors  are  not
    necessarily from safe sources.
•   Wear protective clothing, including gloves, when
    using oil-based products.
•   Try to substitute safer  pigments for all the lead
    pigments. Typesetting with lead  type  can be
    replaced with digital methods.
•   If lead is used,  get regular blood  lead tests  for
    yourself  and any young  children  at  home.
    Pregnant women should  never  use lead or
    solvent products.
•   Since pigments and solvents must  sometimes be
    used, select the safest ones.
•   Use the safer etches such as ferric chloride.
•   Use water-based silk screen and monoprint inks
    when possible.
•   Do not use spray products  unless there is a
    proper  spray  booth  available.  Many  spray
    products can be replaced (e.g., adhesive contact
    paper or double sided tapes  can  replace  spray
•   Assess each printmaking process, press cleaning,
    etching  and  other  activity in terms  of the
    airborne contaminants  created and provide the
    proper ventilation  for that process.
•   If  you  use  acids or solvents,  provide eye
    protection rated for chemical splash protection.

    If the amounts of  acid  present  are  in  pint
    quantities or more, provide emergency  (deluge)
    showers.  Make sure  that you,  and all students
    and/or artists  working in  the space,  know the
    location  of emergency eyewash  stations  and
    emergency  showers  and are familiar  with their
•   Locate  aquatint boxes containing  powdered
    rosin away  from all sources of potential ignition
    and provide ventilation for the escaping rosin
    dust when  the door is opened.  If a spray booth
    is  available, aerosol  spray aquatinting can be
    done which is safer.
•   If lithography is done, wear steel-toed  shoes.
•   Follow all  sensible hygiene rules such as not
    bringing food or drink into the studio, washing
    hands before leaving,  cleaning up properly, etc.
•   Clean-up and disposable rags may also be used
    to wash off plates.  If they contain concentrated
    levels of chemical residues that can be  defined as
    regulated hazardous  waste, the  rags may be
    regulated hazardous waste and, as such, must be
    collected, segregated, placed in an appropriate
    container in the satellite accumulation area and
    picked up in a timely manner.
•   If linseed oil,  citrus oil, tung oil, or  any  other
    setting oil  is  also  present on  the  rags, the
    container must be  air  tight because  these rags
    can spontaneously  combust if left exposed to
    the air.
•   If you are uncertain as to whether waste  is
    hazardous,  it may  be  advisable  to manage all
    materials with inks or chemical residue on them
    as hazardous waste, rather than throwing them
    into the regular trash. Unless you generate large
    volumes, it may be  cheaper  and simpler to
    manage all  of  these wastes as hazardous rather
    than conduct TCLP tests on all of the material.
5.5.3 Disposal

Typical  EPA  regulated   hazardous   waste  from
printing and printmaking classes and studios include
the following:
•   Inks, dyes and pigments containing toxic metals,
    such as cadmium, chromium, lead, barium and
•   Haze  and emulsion removers and printing plate
    cleaners  containing  toxic  and/or  flammable
    organic  solvents, such as  acetone, xylene and
•   Spent corrosive acid solutions  used in etching;
•   Obsolete inks,  etching  grounds and  cleaning
•   Lead  metal from old  type  can  be  sold to
    recyclers rather than disposed of as toxic waste.
5.5.4 Recommended Alternatives

•   Water-based inks and monoprint paints.
•   Zinc  plates, whose  dissolved  metals  are less
    toxic in the environment than copper.
5.6 Metalworking and Foundry

5.6.1  Major Dangers
Inhalation  of metal  fumes: When  metals are
heated to a liquid state, many release potentially
toxic  fumes   (tiny  metal  oxide   particles.)
Processes   during  which   metals   are   melted
include  welding,  cutting   and  casting.  Metal
fumes inhaled during such activities  can cause
"metal fume fever", a temporary condition that
appears a few hours after exposure  as severe flu-
like  symptoms and a  dry,  hoarse throat.   It
generally lasts from  24 to  48 hours,  with  all
symptoms  generally clearing within four  days.
The fever  usually  appears  a  few hours  after
exposure and  all symptoms .  However, severe
cases can leave permanent damage.
An especially toxic metal fume is from lead such
as when casting lead  objects or casting bronze
alloys that contain lead.
Welding: The fumes created during welding and
brazing  are   released  from  the  ingredients
present in the  metal being welded  or cut, in the

welding  rods  or wire  feed stock,  or in the
brazing rods. Check the MSDS for each of these
items to determine  which  metals will release
fumes. Common toxic metals found in welding
fume include  manganese,  nickel,  chromium,
zinc, copper, and vanadium. Decorative brazing
may also employ silver, antimony,  and  other
Welding  also produces gases  such as  nitrogen
oxides and  ozone which are  damaging to the
respiratory system.
The best protection from welding fumes is local
ventilation to remove the plume  of fumes and
gases to  the outside. Alternatively, air-purifying
respirators can be used. If respirators are  used,
a proper OSHA respiratory protection program
should be provided and cartridges  should be
selected  for   your   type   of   respirator   in
consultation  with an industrial  hygienist or
someone familiar with the available  cartridges,
based on the specific task to be performed.
In addition  to  fumes  and gases, welding also
produces ultraviolet  radiation (UV) which can
cause painful temporary burns to the eyes called
"welding  flash"  and  which may   lead  to
permanent eye  damage. Protection is provided
by welding  eyewear  or shields which must be
matched  to  the specific type of welding being
Foundry  work: Avoid inhalation of metal fumes
created during  melting and pouring of metals
and inhalation of toxic emissions from heating
and  burning of wax.  Ventilation  should be
provided for the crucible, the pouring area, wax
pots,  and burnout kilns. Respirator  filters can
protect workers from metal fumes as part of a
proper OSHA respiratory protection program.
Forming and breaking of molds should be  done
with  ventilation  or  respiratory  protection to
protect workers  from silica dusts  which can
cause permanent lung damage (silicosis.)  Most
investment molds, often called "plaster" molds,
actually  contain  mostly  silica  (usually in the
cristobalite form.)  Silica in  this form can  cause
silicosis  a progressive and often deadly  lung
disease. Foundry sand molds can be used which
release silica when  they  are  broken  off cast
objects. The resin adhesive in sand molds also
may release formaldehyde, ammonia,  and/or
phenolic   compounds    depending   on   its
composition. Less  toxic  ceramic  shell casting
mold methods which can be used, but they also
employ sand.
It is possible to use more expensive  olivine or
amorphous  silica sands for some of these mold
processes.  These minerals  are not   associated
with silicosis.
Heat:  Pouring  hot  metal  involves  obvious
dangers of  burns.  Special protective clothing,
gloves  and shoes, as well as face shields, should
be worn for this process.
Other People: Always be aware of the processes
going on around you, and use or wear  protective
equipment when you feel you are being exposed
to fumes, participates or other hazards.

5.6.2  Less Obvious Dangers
Junk   Metals:  A  dangerous  practice   often
overlooked  in metalworking is the use of junk
or  found  metals.  There  are  no MSDSs or
ingredient information available for such metals
and it is impossible  to tell  if junk metals contain
toxic  components,  such as nickel, chromium,
cobalt, lead  and more. For example, a  metal that
appears  to   be   ordinary  mild   steel can  be
cadmium-coated,   while   some   non-ferrous
metals   can  contain  extremely toxic  beryllium;
the cadmium-coated metals and beryllium alloys
are too toxic to use in ordinary art studios.
Avoid  using junk metals;  the  only safe way to
work  with   them  is  to  have  perfect  local
ventilation systems  installed which completely
prevents exposure to airborne fumes and dusts.
Patinas:   Patinas   contain  chemicals   which
darken, age, or change the color of metal. One
of the  most  common patinas  which darken
metals   is  potassium sulfide.  It  releases  toxic
hydrogen  sulfide  gas,  in the process.  Most
patinas are  sulfides, chlorides,  bromides, or
fluorides of a wide variety of metals such as
selenium,  antimony, copper, or tellurium.  Most
also  release  toxic gases when they  are  used.
Some are  applied cold while others are applied
to  heated  metals.   The  hot  process  patinas
usually  release   the  largest amounts  of  toxic

substances, but ventilation should be provided
for both types of patinas.  Wear an appropriate
respirator, gloves and protective clothing when
doing any patina work.
Other surface treatments: Plating surfaces with
cyanide solutions should always be avoided (see
the jewelry section) . Enamels can be applied to
metal surfaces with heat. Metal  priming paints
also can  be  used, but  this  type  of paint is
exempt from consumer paint lead laws and may
contain lead. Those containing lead should  be
Metal dusts:  Grinding,  abrading, wirebrushing,
and polishing produce small particles  of metal
into the air that can be inhaled and settle on the
skin.  Some  grinding processes  also  heat  the
metal enough to generate a  small amount  of
metal fume (see above)
Grind  wheels,  abrasive  blasting,  grit,  and
polishes  (e.g., rouge  and  tripoli) may  contain
silica and/or other mineral abrasives' that are
released   during  use  and  can  be  inhaled.
Grindwheels  and  grits  can be made  of safer
abrasives  such  as carborundum  or aluminum
oxide. Grits  made of glass beads  are  also less

5.6.3  Safety Suggestions

•   Get MSDSs  on all  stock metals, welding  and
    brazing rods; and wire. Almost all metals contain
    some  toxic  ingredients. Even mild  steel  will
    contain manganese. Avoid coated metals such as
    galvanized (zinc  coated) or  metals coated with
    cadmium, or other toxic metals.
•   Get MSDSs on the ingots for all foundry metals.
    Avoid  any  bronze  or other casting metal
    containing lead, cadmium,  beryllium,  nickel,
    antimony, or other very toxic metals.
•   Replace crystalline  silica in  mold and  casting
    materials  when possible with amorphous silica,
    olivine or other minerals not associated  with
•   Provide ventilation appropriate for each type of
    welding  or   foundry  work  and  for  surface
    treatment application such as patinas and for the
    making and breaking of molds and investments.
•   Use  respiratory  protection  if needed  with a
    proper OSHA program. Be aware that there  are
    no  approved  respirator  cartridges  for some
    substances created in foundry and welding work,
    such  as  ozone,  nitrogen  oxides, hydrogen
    sulfide, wax emissions (e.g., acrolein), etc.
•   Wear protective eyewear and clothing. Provide
    eye protection for welding appropriate for each
    types of welding to protect from UV radiation.
    Proper  clothing,  shoes,  gloves   and  face
    protection for welding and foundry should  be
•   Follow all sensible hygiene  rules  such  as not
    bringing food or drink into the welding areas or
    foundry, washing hands before leaving, cleaning
    up properly, etc.
•   Always be aware of other activity in the shop.
5.6.4 Disposal
Typical   EPA  regulated   hazardous waste   from
welding and foundry classes or shops include:
•   Grinding waste;
•   Welding and brazing rods;
•   Oils and lubricants containing metals;
•   Used abrasive blasting grit;
•   Toxic and flammable organic solvents found in
    surface coatings and degreasers;
•   Aerosol paint and marking cans; and,
•   Spent corrosive liquid  solutions used in etching
    and patinas
MSDSs on all metals products should be checked for
the presence  of RCRA metals,  including barium,
cadmium, chromium,  lead, mercury, selenium,  or
silver. If these are in the alloys used, they will also be
in the waste.

5.7 Design and Architecture; and Model

5.7.1  Major Dangers
Inhalation  of  dusts,  fumes  and  mists  when
fabricating models,  architectural plan  drawing
using solvent based  inks and  markers, adhesive
bonding, and surface Finishing.  Markers, glues,
spray paints and adhesives all  have  the potential
to produce hazardous vapors. As modeling and
drawing require close-up  work, you are  even
more  likely  to  be  at  risk  for  exceeding
permissible  exposure levels.  Good  ventilation
while   using   these   types  of   products   is
imperative, especially when your work requires
prolonged periods of exposure. The fumes from
the  chemicals  involved,   particularly  volatile
organics such  as  those  present in paints and
solvents,   can  cause  nerve   damage   and
respiratory irritation.
Any  sprayed-on  surface   coating  should  be
performed in  a spray booth  with  an adequate
exhaust  system.  Solvent  cleaning should  be
performed with a system equipped  with local
mechanical  exhaust.  If these  are  not available
follow   the   manufacturer's   recommended
guidelines for safe use and handling to minimize
exposure to yourself and others.
Inhalation  of  resins,  silica, and cast molding
materials: Some  molds  contain formaldehyde
resins,  which   are  strong   lung  irritants.
Formaldehyde exposure can lead to asthma and,
possibly, cancer. During  the casting  process,
these resins may thermally decompose to  allow
the release of toxic formaldehyde, phenolic, and
ammonia fumes,  all of which are  potentially
harmful. Unlike the  investment casting plasters
used in foundries, the plaster used for making
models and for cold  casting of sculpture pieces
usually does not contain significant amounts of
silica.   However,  if  it does contain silica, see
Sections  4.2   and  4.6   for   information  on
minimizing  silica exposure and corresponding
health concerns. Always  provide  for adequate
ventilation and wear respiratory  protection  if
warranted by the material being used.
Skin contact with glues, sprays, and fillers: While
modeling,  avoid contact  with glue  or  filler.
Because  of the close-up nature  of the work,
extreme care needs to be taken in the use and
handling   of   these   materials.   Wear  the
appropriate,    protective     clothing,    wear
impervious nitrile  or  other  approved chemical-
resistant   gloves  when  using   solvent-based
materials, and wash your hands  frequently and

5.7.2  Less Obvious Dangers

Modeling materials:
•   Wood  - MDF  (glue),  plywood, and  other
    laminated/compressed wood products contain
    formaldehyde and other wood additives that can
    bring on  asthma and  can lead to  cancer.  See
    Section 4.10.1 for more information on working
    with wood and wood additives.
•   Foam  -   toxic   gases   due   to   thermal
    decomposition  are released  when cutting foam
    with hot wire; provide adequate local exhaust.
•   Rubber Cement - commonly used for modeling
    and thinning, contains n-hexane. Hexane may
    cause  chronic  systemic  and nerve damage  if
    exposure  occurs over long periods.   Rubber
    cement   that  contains   heptane,   which  is
    significantly  less  neurotoxic  than hexane,  is
    much safer.  However, as  with most solvent
    based  materials,  it  can   cause  respiratory
    irritation.  Both are flammable

Ink Markers: Working with several Ink markers
at once can result in high levels of exposure to
solvent vapors. They can be irritating to the eyes
and respiratory  tract,  and  can cause dizziness,
headaches  and nausea. Alcohol-based markers
are much safer than ones containing xylene or
toluene; water-based markers are even safer and
not  an  air  contaminant  or hazardous  air

5.7.3  Safety Suggestions

•   Eliminate the use of turpentine and turpentine-
    based products.
•   Avoid pressure treated wood.
•   Avoid the use of oil-based resins or spray paints.
•   Ensure proper  ventilation and  wear protective
•   Wear  an  NIOSH  approved and appropriate
    respiratory protection mask when spraying or
    working close-up.

•   Use rubber, nitrile or vinyl gloves with solvent
    based stains and other products.
•   Use water or alcohol-based markers rather than
    those containing toxic and flammable solvents.
•   Use non-aerosol spray paints and adhesive.

•   Use  soap and  water  (not  solvents)  to wash

5.7.4 Disposal
Don't wash anything down sinks. Typical EPA
regulated hazardous wastes include: inks; paints
containing toxic heavy metals, such as cadmium,
chromium, lead,  barium and  silver;  cleaning
solvents;  spent  ink  markers;  aerosol,   spray
paints;  and, glues/adhesives  containing  toxic
and or flammable organic solvents.

5.7.5 Recommended Alternatives

•   Choose Rubber Cement that  contains heptane
    instead of hexane.
•   Rock  Putty is  a  safe  adhesive for   wood
•   Wood glue  and white craft adhesive product are
    available with a variety of extra strength glues
    suitable for modeling.
•   Use water-based paints for coloring models.
•   Choose Permanent Markers that do not contain
    toxic   and   flammable  organics..  They  are
    available and are a safer alternative.
5.8 Drawing Materials and Pastels

Drawing   materials   include   pencils,  conte
crayons, charcoal sticks, oil and  dry pastels, and
more.  When  these materials are intended for
archival  art work, they can contain the  same
toxic  pigments that are  in  artists' paints.   Of
particular concern in  this area  is that  drawing
materials produce dust when used, especially the
soft pastels, which produce significant  amounts
of dust containing exceedingly small particles of
pigments and carriers. This  dust can be inhaled
and will settle  all  over surfaces, clothing, shoes
and hair.
5.8.1 Safety Suggestions

•   Use pencils, conte crayons, chalk and
    charcoal, whose particles are larger and
    easier to control with good clean up and
•   Use oil/wax pastels, rather than dry
    pastels, which eliminates the dust hazard
    and only requires good hygiene to be used
•   If soft, dry pastels are used, follow several
    simple procedures:
    •    work in a studio separate from your home;
    •    wear   a   respirator  or  provide  special
    •    leave work clothing and shoes in the studio;
    •    clean with a HEPA vacuum;
    •    avoid  pastels  colored  with highly  toxic
         pigments,  such   as  those  containing
         cadmium, chromium or cobalt; and,
    •    spray fixative in a spray booth or  according
         to the manufacturer's recommendations for
         use  and  handling. Also be advised that
         spent aerosol cans may be regulated waste
5.9 Sculpture

5.9.1  Major Dangers
Inhalation: Dusts and free  silica:
Always  be  mindful  of  the dust
created when sculpting;  wear eye
protection    and    appropriate
respiratory     protection,      if
warranted by  the  material.   If
respiratory protection is needed,
filters  appropriate to  the  material  should be
used, users should be fit-tested  to ensure that
the equipment is properly sized and shaped, and
users should be trained in use  of and  care of the
•   Plaster dust, also known as calcium sulfate, is an
    eye and respiratory tract irritant.
•   Clay dust contains free silica. Inhalation of free
    silica leads  to  silicosis, a  form of lung fibrosis
    that causes shortness  of breath, an  increased
    susceptibility  to  infections  and lung scarring.
    The chance of inhaling the dust is greater when
    mixing dry powders rather  than wet  clay. Oil-

    based clays  are significantly less hazardous for
    this reason. Keep in mind that oil is a source of
    water pollution and is regulated in waste water
    discharges so it has to be used carefully in the
    mixing process so it doesn't go down the drain.
    It can also create slip and fall hazards in the class
    area if it is spilled or there's poor housekeeping
    in the storage and handling areas. Requirements
    for  storing flammable  and combustible liquids
    apply here as well. (See Ceramics section 4.2 for
    more detailed information.)
•   Sawdust from wood is the biggest single hazard
    when working with wood. It can cause cancer
    and   chronic    respiratory    diseases.   (See
    Woodworking section  4.10 for more  detailed
•   Stone dust can also contain free silica that can
    lead to  silicosis.  There  are many stones  that
    contain  large amounts  of free  silica,  such as
    quartz,  granite,  sandstone,  brownstone,  slate,
    jasper,  opal, amethyst,  onyx  and  soapstone.
    Soapstone,  serpentine   and  greenstone   also
    contain  asbestos, which is  also  harmful  if
•   Heating and melting of waxes and sheet plastics:
    Always avoid overheating and burning of waxes
    and plastics as it can result in the release of toxic
    gases  from decomposition  (e.g.,  monomers,
    plasticizers)   of  the   chemical  components.
    Overheating  of  wax   can  be  a  common
    occurrence in wax sculpture, but heating it to a
    point where it  becomes flammable  incurs the
    risk  of emitting vapors that  are  respiratory
    irritants. Also, chlorinated waxes are extremely
    dangerous as the  toxic components can lead to
    skin  disease,  liver   damage   and   possible
    reproductive damage  as  well.  For this  reason,
    they should never be  used.  Be  wary of using
    solvents near plastics as  they  will often  melt
    upon   contact  and  release  vapors.   Always
    ventilate well when  working  with wax  and
    plastic processes, and wear a respirator when
•   Foam:  Never  heat,  burn,  or  expose   foam
    (polystyrene, Styrofoam  etc.) to solvents. It can
    decompose the foam and release toxic fumes.
•   Laminating and casting with resins:  Resins are
    highly dangerous. Resins emit toxic  fumes and
    are  hazardous when they contact  skin.  Methyl
    methacrylate  is a common material used for
    casting and laminating. It is a skin irritant and its
    vapors  can  cause  nausea,  headaches   and
    lowering of blood pressure.  Additives used in
    the laminating process usually contain fiberglass,
    which is irritating to the skin  and can cause fine
    cuts,  aiding  in  further  exposure  to  other
    chemicals.   Glass   fibers  can  also  become
    airborne and  cause  respiratory complications.
    Always use an approved respirator, and wear eye
    protection  and impervious gloves  when using
    resins and glass cloth. Some catalysts used  may
    contain methyl ethyl ketone peroxide. Because it
    can become shock sensitive with age, it should
    be logged in and out, and evaluated for age and
    condition when  it is   used.   This  is  highly
    flammable   and  reactive, and  a  potentially
    explosive organic peroxide as well.

5.9.2  Less Obvious Dangers
Plaster: Plaster looks harmless, but in addition
to  the  dust  hazard, there  may be potassium
sulfate, potassium aluminate and borax present,
which are all slightly toxic by ingestion.  It  also
contains calcium oxide, or burnt lime, which is
moderately corrosive by skin contact and highly
toxic by inhalation or ingestion.
Glues,   cements  and  solvents:   Glues   and
cements used to bond plastics usually contain
toxic chemicals as well. When working close-up
while gluing, be  even more aware of exposure
levels; avoid all  skin  contact, wear protective
clothing and ventilate  the area.  Solvents, which
are  used  to remove  wax,  usually contain  a
variety  of  toxic  chemicals.  (See the  Painting
Section for details on solvents.)

5.9.3  Safety Suggestions
•   Ensure proper ventilation.
•   Use dust masks, respirators and eye protection,
    and wear protective clothing.
•   Use spray booth for all  spray operations.  If
    booths   are   not   available,   follow   the
    manufacturer's     use      and     handling
    recommendations  to  minimize   exposure to
    yourself and others.
•   Clean dusty areas with a HEPA vacuum rather
    than sweeping, which makes dust airborne.
•   Select stone that  contains the  least amount of
    free silica.

•   Be aware of what others are doing and protect
    yourself from their activities.
•   Never use chlorinated waxes.
•   Use a kneaded eraser to remove wax instead of
    toxic solvents.
•   Work with commercially available or "finished"
    plastic whenever possible. "Producing" plastic
    involves the use of many toxic chemicals.
•   Thoroughly wash skin that has been exposed to
    dust, with soap and water.

5.9.4 Disposal

Typical EPA regulated hazardous wastes  from
sculpture class  and studios include: paints and
coatings  containing toxic heavy metals, such as
cadmium, chromium, lead, powders containing
barium, and silver; aerosol paints and adhesives;
paint  booth   filter   media;  toxic   and/or
flammable organic solvents used in paint related
cleaning  and thinning processes; rags  or wipes;
and,   corrosive    cleaning   and   degreasing

5.9.5 Recommended Alternatives

•   Non  Toxic carving wax.
•   Non  Silica Art Plaster.
•   Balsa wood foam product rather than  Styrofoam
•   Select Aqua-based resins and adhesives
5.10 Woodworking

Every year,  7 in every 10,000 mod workers contract
nasal  cancer.   Always   ensure   that   proper
respiratory protection is used.
5.10.1  Major Dangers
Chronic  inhalation  of sawdust  is  the  biggest
chronic  hazard involved  in  woodworking.  It
causes cancer and chronic respiratory diseases. 7
in  10,000   woodworkers   annually   contract
adenocarcinoma, a particular  type  of  nasal
cancer.  All  sawdust  can  cause  respiratory
damage.    Symptoms   include    nosebleeds,
shortness of breath, sweating, fever and chills,
and heart disturbance.
Many wood species contain natural toxins, while
others are not toxic  by  themselves, but are
sensitizers that may make people more reactive
to allergens present in other woods. Research
the particular species you plan to work with; use
the less toxic varieties whenever possible. Wear
protective clothing, eye protection,  and a mask
when doing anything that will create  sawdust.
Inhalation, ingestion.  and skin  contact with
wood glues: Many glues potentially contain toxic
substances and must be used carefully. Plywood
glues, for example, often contain formaldehyde
resins which  are highly toxic by inhalation, eye
contact and  ingestion.  Skin  contact should be
avoided,   as    formaldehyde   is   a   known
carcinogen.  Dry casein glues are highly toxic by
inhalation and ingestion, as they contain sodium
fluoride and  alkalis.  Contact adhesives  contain
hexane, which is not only highly flammable, but
also  toxic through inhalation, causing nerve
damage.  Adhesives may contain harmful levels
of toxic  organic   solvents.  Epoxy glues are
moderately toxic by inhalation, and through eye
and skin contact. They include amine hardeners,
bisphenol  A-type resins,  and  trace  levels of
epichlorohydrin, which cause   skin  allergies,
asthma and respiratory problems. Cyanoacrylate
glues  are moderately toxic through eye and skin
contact.  Water-based  glues  are  slightly  toxic
through skin contact and inhalation. Try to use
less  toxic glues,  always  ventilate  well,  and
thoroughly wash hands after use.
TIP** If you receive a stack  of "fresh" material
remove the plastic sheathing or shrink wrap and
store  the material in a well ventilated  area for a
few days to allow the bonding materials used in
the manufacturing process to dissipate which

will  help to  minimize  exposures  during the
cutting and sanding procedures.
Paint strippers and Finishes: These materials can
be   extremely  hazardous  to   your  health
(methylene  chloride,  and  corrosives).  Paint
strippers manufactured using toxic or flammable
solvents  should  be permitted for use only if the
proper  engineering  controls are  available and
enforced to ensure safe working conditions.
There are many  formulations available now that
are less toxic or nontoxic. If you have a project
that  requires  the  use of a paint  stripper,  also
consider the  type  of paint  being  removed (for
example,  it could  contain lead), and how that
needs to be managed. Shellac used for finishing
wood usually  contains ethyl alcohol and methyl
alcohol, which are flammable and toxic.   They
evaporate quickly  - only  use in a well ventilated
area  and keep  containers  tightly closed.
Other people: Be aware  of what others are
doing; use and wear protective equipment when
sawdust   or   vapors  are   being   created. Be
considerate of the health and safety of people
around you - communicate any known chemical
or physical hazards that your project has the
potential to create.

5.10.2  Less Obvious Dangers
Wood  preservatives   and  plywood:   Toxic
preservatives also  cause  harm to woodworkers.
In particular,  pentachlorophenol,  creosote and
arsenic compounds have all been banned in the
U.S.  because  they are extremely  hazardous to
people and the environment. However, they can
still  be  found  in  some  older   woods.  For
example, until recently arsenic was present in all
pressure-treated  lumber.  Most ply products still
contain formaldehyde, which can  cause  asthma
and  cancer. Wash your hands thoroughly after
using either wood and consider using gloves in
handling  the  wood.  If  your project involves
outside work using wood treated with creosotes
or asphalt compounds, like railroad ties, keep in
mind  that these  compounds  also have the
potential to release toxic  organics during cutting
or handling.   None  of these materials  treated
with  preservatives should  ever  be used  in  a
fireplace or wood stove, or used as feedstock
with a wood burning kit or laser cutter.
Foam: Toxic  gases  are  released when  cutting
foam with hot wire; ventilate properly. Never
expose  foam to solvents. Thermal or chemical
decomposition  can   allow  the   release  of
carcinogens and hazardous air pollutants  such as
styrene,     acrylonitrile,     butadiene     and

5.10.3  Safety Suggestions
•   Ensure proper  ventilation; have  air blowing
    from behind NOT towards you.
•   Wear  an approved  and properly  maintained
    mask or respirator.
•   Wear protective clothing.
•   Use appropriate, disposable latex or vinyl gloves
    when using finishing products.
•   Avoid working with  woods that are preserved
    with toxic chemicals.
•   When buying wood, particularly old wood, find
    out about it and protect yourself accordingly.
    The  wood  may have been  in contact with
    contaminants; find out what it was used for and
    where it was stored previously.
•   Avoid glues that contain formaldehyde
•   When  using  paints,  coatings, adhesives  or
    solvents containing volatile compounds that will
    evaporate readily, always  open the lids only
    while  actively   removing  material   and then
    replace the lids carefully to ensure a tight, fitting
    seal when you are finished.
•   Properly store all paints, finishes, solvents, etc.
    in accurately labeled, sealed containers
•   Don't eat, drink or have open food containers in
    the shop.
•   Wash hands  thoroughly with  soap  and water
    after handling wood and glues.

5.10.4 Disposal

Typical EPA Regulated hazardous waste from
woodworking shop class and   studio;  paints,
coatings, toxic heavy metals such as cadmium,
chromium, lead,  barium, silver, paints, spray
paint booth  filter  media, brushes, rags, wipes
used  in  staining  or  shellac   using  finishes
containing toxic  and  or  flammable organic

solvents,  aerosol  paint  and  adhesive  cans,
solvent  cleaners    and   thinners,   machine
lubricants, corrosive cleaners and degreasers.

5.10.5 Recommended Alternatives

•   "White glue" and putty  product is available that
    is a safe wood glue and filler alternative
•   Rock Putty can be used as a filler and bonding
•   Use water-based glues whenever possible but be
    mindful that they may be hazardous and handle
•   Use water-based finishes; they may take a few
    minutes longer  to dry but it is  well worth the
5.11 Audio/Video and Computer Labs

All electronic and  mechanical devices require a
certain  amount of  routine maintenance. For
example, you may discover that lab technicians
in  audio/video   and   computer  class  areas
routinely solder connections on printed circuit
boards,  use  aerosol  spray  cans  of  solvent
cleaners, and  touch  up  paint  scratches  on
enclosures. Additionally,  equipment  upgrades
also make  some  equipment obsolete  and this
obsolete equipment  can contain  materials that
are  hazardous,  requiring  proper  treatment
and/or disposal. EPA  estimates that 57 million
computers  and televisions are sold just in the
U.S. each year.  When you realize that CRTs or
TV screens can contain as much as 8 pounds of
lead, the scope  of the problem becomes readily
These materials  are  potentially  regulated as
hazardous or universal waste and  should not be
disposed of as normal trash. There are  a lot of
asset  recovery programs available to you from
computer  manufacturers  and  also  recycling
companies    that    deconstruct   electronic
equipment for beneficial reuse.
Among   the   potentially   RCRA-regulated
materials   contained   in  waste   consumer
electronics, personal computers  (PCs), laptops,
hand  held  devices and monitors, the  primary
concerns   involve    toxic   heavy    metals.
Specifically, if any of these types of electronic
devices become  obsolete or inoperable  they
need  to  be  disposed.  For  example,  power
supplies   in  electronic  equipment  may  use
batteries  that contain nickel,  cadmium, lead,
mercury and lithium; printed  circuit  boards  in
hard drives may have lead solder joints; and
even the PC monitor "CRT"  cathode ray tube
(like TV screens) contains lead shielding in the
The big picture goal is not to  let them get into
the local landfills where the toxic heavy metals
could leach into the water table and contaminate
groundwater   supplies.    The   predominant
contaminants  of  concern can  include  the
following: lead shielding, mercury switches and
relays; cadmium-plated components  and solders;
nickel-cadmium batteries; or lithium batteries  in
two way  radios  or cameras;  lead-acid battery
packs in emergency lighting; or silver oxide  or
mercury  oxide  button  power  cells.  They're
everywhere! And if you were to decide to simply
treat old  computers, TVs, VCRs,  stereos, fax
machines, copiers, or even cell  phones as regular
trash you could  be putting yourself and your
school in violation of waste management laws.
Most states have household  hazardous waste
collection days where you can properly dispose
of these items.  What happens to them is that
they are mined for metals, glass and plastic. The
units are  demanufactured  and the metals are
reclaimed   for   reuse.  There  are   actually
companies  that  upgrade  and  refurbish PC
equipment  and  make them  available  to  low
income  or  underprivileged children,  a much
better alternative to throwing them out.
Non-hazardous equipment or  components may
also have  recyclable salvage value  as scrap metal
for the aluminum frames, copper wire, etc.
Fortunately,  there  are  a  number  of  asset
recovery  programs  available,   from  computer
manufacturers  to  computer   collection/reuse
programs, as well as recycling companies that
deconstruct electronic equipment for beneficial
reuse. The  rules  regarding resale or reuse  of
electronic   equipment   are   fairly   simple.
Electronic products, including monitors  and
PCs,  that are either  donated  or resold for
continued use are not considered to  be waste.
Similarly,  non-working  electronic   equipment

that  is  serviced  by a  repair  shop and then
returned to the  user, or serviced  for reuse by
another  person  or  organization,  is  also not
considered to be a waste. However, all  other
nonworking    electronic     products     and
components that are not intended  for repair or
reuse must be managed as waste, with a proper
hazardous  waste determination conducted to
determine  if  they  or  their  components are
regulated   materials.   Several   states   have
additional rules regarding some  of these items,
such as New Jersey and six other states allowing
electronics to be managed as  universal  waste,
and  several  states  have  adopted  increasingly
stringent  rules   regarding  electronics  waste
disposal   and   even   non-hazardous   waste
batteries. There is currently a movement in the
U.S that will require electronics manufacturers
to take back equipment at the end of its useful
life cycle. This is already  happening in  some
European Union countries.

Further information on electronics recycling can
be found at EPA's eCycling web page at:
http: / / /recyc
le /ecvcling/index.htm
To  determine  if  your  state   allows  waste
electronics to be managed  as universal  waste,
see  EPA's   state-by-state   Universal   Waste
summary at:

                                     SECTION 6.0
 Pollution prevention and waste minimisation is good for
you and good for the environment.

 6.1 Less is More

 Use  of less  toxic  alternatives  and  smaller
 amounts of hazardous materials decreases your
 exposure to potentially harmful chemicals in the
 studio or shop. Additionally, it helps protect the
 environment from the disposal of hazardous
 wastes.  Waste minimization  also decreases our
 reliance on landfills and other disposal methods.
 Reducing  the  use  of toxic  or hazardous  art
 supplies can help save you money.
 Both   pollution   prevention   and   waste
 minimization can reduce costs and improve  the
 working conditions.   That  can be  important
 around budget time as well as to your long term
 health. The EPA's Pollution Prevention website
 will show you real case histories that have saved
 a lot of companies money.  Pollution prevention
 and waste minimization  reduce  the  risk  to
 workers,  the  liability  for  an environmental
 cleanup, fines  and  penalties, health care costs,
 workers compensation costs,  and safety costs to
 install and maintain  engineering  controls  to
 ensure a safe work place.
 There  are a  number  of  ways  to  prevent
 pollution and minimize waste in your studio  or
 shop.  This section provides guidelines and best
 management practices, including:
•   standardizing regular studio or shop activities;
•   understanding  the hazards  and  obtaining only
    what you need; and
•   appropriately segregating and handling waste.

6.2 Organic and Inorganic Wastes

Proper disposal of hazardous wastes is required
by law.  Many chemicals used in your studio or
shop  should  not be  put into the sewer system
and or thrown away in the trash  for numerous

Organics: These include solvents and oils. They
can contaminate groundwater supplies  such that
they will be unfit for drinking for decades or
even centuries.  Organic solvents are one of the
most commonly used chemicals in the
workplace. NIOSH estimates that, in the United
States, three million women and six million men
are occupationally exposed to solvents  that may
be present in  inks, cleaning products,
degreasers, paints and paint thinners, enamels
and lacquers,  adhesives, resins, and marking
fluids. If your art work requires the use of
adhesives, paints, resins, plastics, and dyeing and
printing materials, look for suitable non toxic
water based substitutes, they are out there.
Understand fully that overexposure may cause
adverse health effects such as contact dermatitis,
respiratory irritation, pulmonary edema and
kidney failure. Chlorinated solvents, such as

trichloroethylene and perchloroethylene were
once very popular as degreasing and cleaning
fluids and widely used in manufacturing and in
dry cleaning. This category of solvent was found
to cause many forms of cancers. They have
largely been replaced with non chlorinated or
water based systems. Pregnant women are even
more at risk if overexposed. Studies have found
a higher probability for major birth defects.
Inorganics   (metals):   Some   are   persistent,
bioaccumulative and  toxic or  neurotoxic  if
ingested. Lead and mercury are  two examples.
Other RCRA characteristic metals are listed for
the same reasons. The entire food chain can be
affected:  contaminated soil  can  contaminate
plants that are then eaten by animals  that
humans eat.
The inorganics present physical and chemical
risks  to  human   health.     Some   oxidizing
substances  can react with organic waste  and
spontaneously combust.
6.3 Standard Operating Procedures (SOPs)

The best way to manage hazardous waste is to
eliminate it or minimize at the  source.   First,
purchase only the supplies you will need.  When
ordering supplies for your classroom  shop or
studio, determine how much you need for the
number of students using the  supplies before
purchasing   them.   Also    consider    just
demonstrating  techniques  that use  hazardous
materials  rather   than   have   30   students
experiment  with   hazardous  materials   and
generate 30 more times the waste. Use Standard
Operating Procedures (SOPs) for each product
and ensure that each student knows the quantity
to use and how to  safely handle  the materials.
For example, it is important to have an SOP for
brush cleaning  that specifies  size  of containers
and amount of solvent  to  be  used based on
brush size, and that further  specifies how the
spent solvent will either be reused or disposed.
Art materials can contain very toxic substances.
For example,  art  materials are exempt from
consumer paint  lead  laws. Lead,  cadmium,
chromium,  and  many  other  toxic  metal
compounds and pigments are commonly found
in paints, ceramic glazes, and other art materials.
In 1988, a special labeling
law for art materials was
passed.  The law, which
is  enforced by  the  U.S.
Consumer Product Safety
Commission,    requires
that      a      certified
toxicologist evaluate  the
formula of each product
to    determine    what
warnings, if any, need to
be   on    their   labels.
Guidance for the toxicologist is found in a
chronic  toxicity  labeling  standard  of  the
American  Society of Testing  and  Materials
called ASTM D-4236.
Always look for the statement  "Conforms to
ASTM D-4235."  It is  illegal to sell any  art
material  in  the  United  States that does  not
reference  this standard.  The  presence  of the
statement  does  not  mean  the material   is
inherently  safe;  rather, it  means  that,  in the
opinion of a toxicologist, any warnings  on the
label are sufficient for safe use.
One of the serious deficiencies of this law is that
substances  requiring  labeling must be known to
cause  chronic  effects,  such  as  cancer,  birth
defects or other long term  harm.  However,
many  art material  ingredients,  especially the
organic pigments,  have never been  tested for
chronic hazards.  Some of these  pigments are
members  of  classes  of  chemicals  that  are
suspected of causing cancer or other long term
harm,  yet products  containing these untested
chemicals can be labeled "nontoxic."
Use  all  art materials with  common  sense
precautions,  even ones  that  are  labeled  in
conformance with ASTM D 4236.  Such items
will  contain  information  from a certified
toxicologist on any  known health hazards for
that    material.      Read   and   follow  the
recommended  procedures  for  the  hazards
identified for all of the materials used.
If it presents a  risk to your health, it may be a
hazardous waste.  Prior to disposing of any potentially

hazardous items or items containing a RCEA-regulated
hazardous  constituent  —  using MSDS  information,
toxicokgist warnings and any other available technical
product information  -  be  sure  to  conduct  a  proper
hazardous waste determination and manage the waste
accordingly. Relying on product safety information akne
will not be  adequate.  OSHA  only requires that an
MSDS list hazardous ingredients only if they are present
in quantities at or above 1 % and a lesser value of '0.1%
if the material is a listed carcinogen! So, for example, if
the  artist color product  label you buy  does not  list
cadmium because it is only present at let's say 0.50%
and after you used it a  couple  of times decided it wasn 't
quite what you were looking for and you just let it sit
around for awhile and it "globbed up" and was therefore
no longer suited for the purpose intended. You have ended
up  with a potentially hazardous waste  requiring proper
waste  management  and disposal.  Why?? because  the
characteristic waste limit for land disposal of cadmium is
established at  1.0 ppm or mg/L.  which amounts to a
concentration  % by  weight of  0.000100%  -  several
orders of magnitude less than what is in the colorant.
We  have  included  a   listing  of Art  Suppliers  in
Appendix D.  The list is not exhaustive  nor  does it
suggest that if a company is not listed that they provide a
less preferable product.  Some  companies not listed may
have simply chosen not to label products non —toxic for a
variety of reasons even though,  technically, they  could.
Read product labels carefully and try to choose the ones
that  are best for you  and the environment whenever

6.4 Good Housekeeping

Be aware exactly where the material will be used.
Keep the following in mind:
•    If the shop or studio has floor drains, cap them
     off. (Once a spill is in  the drain, you can't do
     much about it except to report it and pay for an
     expensive cleanup.)
•    Avoid using water to clean floors contaminated
     with paints, oils or solvents.
•    Do not store chemicals or oils outside.
•    Have spill absorbents immediately available  for
     accidental  spills   during  material  transfers,
     including shipping and receiving activities.
6.5  Waste Segregation

Keeping wastes in separate containers based on
their  individual  hazards   reduces   costs   and
increases safety.
•    If regular trash is mixed with hazardous waste,
     the whole mixture becomes hazardous waste.
•    Follow the  same compatibility  rules used  for
     storing new chemicals. It can  be dangerous to
     mix chemicals: toxic vapors may form and fires
     or explosions can result
•    Segregate  wastes according to  the categories
     defined by federal regulations.
•    Ensure that you have separate, labeled containers
     for each type of waste.
•    Remember that  swabs, rags, or other saturated
     materials  may be considered hazardous waste
     that, by law, cannot be disposed of as regular
•    Containerize to  prevent solvent evaporation  -
     evaporation of regulated  volatiles is  illegal.
     Do  not leave  funnels in the tops of materials
     such as acetone; this constitutes illegal disposal.
•    Waste containers should have  tight fitting tops
     and only be opened when adding or removing

To ensure compliance, your facility can be inspected by
the  EPA. A  violation  will  result  in  a  "notice  of
noncompliance" and can incur fines of up to  $32,500
per day.
For everyone's safety, and to ensure  that the
material  is properly managed, waste containers
must  be labeled  as  Hazardous  Waste  with
specific information on the description  of its
contents as soon as the material is put into the
6.6 Waste Minimization Program

Having  a waste  minimization  program  will
reduce  both  the  volumes  and  toxicity  of
generated waste streams.
Less waste and toxics means reduced costs, risks
and liability, and a healthier environment.
•    Recycle to reduce hazardous waste.
•    Do a pollution control check routinely.
•    Maintain segregation of wastes.

•   Enlist top management support if you feel your
    concerns are not being taken seriously.
•   Encourage others to help.

6.7 Waste Management Hierarchy

 EPA hierarchy of waste disposal preferences:
1.   Reducing
2.   Reusing
3.   Reclaiming
4.   Recycling
5.   Landfill disposal or treatment

These    priorities   reduce   dependency   on
landfilling.     It  is  usually  environmentally
beneficial to follow the above hierarchy and to
avoid  the  need  for treatment or disposal of
hazardous waste; however, the regulations are
very detailed and extensive on requirements for
proper management when recycling,  reclaiming
and    even    reusing   a   hazardous   waste.
Accordingly, it is  important that a  generator
confirm  the regulatory acceptability  of on-site
recycling and  reclamation  before  beginning an
on-site program.

 6.7.1 Reusing

Many art materials  that are seemingly waste can
sometimes be  reused in the studio or used by
another person or group.  For example, mineral
spirits used for cleaning oil paint brushes can be
allowed  to settle,  then  either  decanted  or
strained  through  cheesecloth to  remove the
solids, with the  filtered solvent being reused.
This  type  of  recycling  is  often  very cost
effective. There are also commercially available
cleaning units  that  have  a built in pump and
filter system that will  extend the  useful life of
the cleaning solvents  used.   Note that  sludge
removed from the cheesecloth, filter,  bottom of
the container or from a solvent recovery system
might    be    hazardous    waste;   a   waste
determination would have to be made prior to
removal  of the sludge from the equipment for

 6.7.2 Recycling
  One person's trash may be another person's treasure.
Waste materials  generated  during  a  project
should  not  be  automatically   thrown   out.
Evaluate  for   possible  reuse  or   recycling,
including  outside your classroom,  studio or
shop. For example, leftover art materials can be
donated to an art center, children's museum or
another  school.  In   New  York   City,  the
"Materials    for   the   Arts"   organization
(http: // takes excess
arts materials for distribution to other programs
that need similar material.
Many  other   organizations   welcome   such
donations.   However, several factors must first
be considered:
•   Before  you offer it, determine  that it can be
    safely and beneficially reused.
•   Do   not  donate   hazardous  materials  to
    elementary schools, or other organizations for
    use by young children.
•   Highly  toxic  materials, like  lead glazes, should
    never be recycled.
•   Hazardous waste  may never  be  donated to
    another  individual  or organization to  avoid
    regulatory requirements; it may only be sent for
    disposal or recycling at  an approved facility,
    unless it can be used as  a substitute for new
    product  without   further   processing   (e.g.,
    through a waste exchange.)

 6.7.3 Reclaiming

There are  licensed  companies  who reclaim
hazardous   wastes.    For    example,    some
companies pick  up, launder and return solvent
or oil-soaked  rags from large printing facilities
for reuse.  They use  the reclaimed  solvents as
fuel in their boilers to produce steam and hot
water in their commercial laundries.
There are  also  designated  materials recycling
companies that take solvents, fluorescent lamps,
computer equipment and metals, as  well  as a
variety of waste exchanges. They may have an
interest in your waste as a raw material for their
Look online for more information and to locate
recycling companies. You can contact your state
environmental  agency  (e.g.,  New York  State
Department   of  Conservation,  New  Jersey

Department  of Environmental Protection)  for
more detailed information on  recycling.  Many
states  can  provide  a  listing  of  recycling
companies  serving  the  region.  The  EPA's
website   is  another  source   for   pollution
prevention and waste recycling information (see
Appendix E)

 6.7.4 Landfill Disposal

If you generate hazardous waste from  your
classroom, studio or shop that  cannot be reused
or recycled,  it  must  be handled by  a licensed
hazardous waste disposal company or picked up
by a licensed hazardous waste transporter.
The licensed disposal company will know  the
land disposal restrictions, and how and where to
dispose of the  waste based on the information
you  provide  to them by completing a generator
waste material profile sheet for the waste stream
to be disposed.  They will also be  familiar with
record    keeping,    labeling,    transportation,
packaging and other requirements for the waste
and  can  help  you  make   the best  decision
regarding disposal.
Your contracted waste company or transporter
will  give  you information  about the types of
containers they require and how  to label  the
•   You may reuse glass bottles containing the waste
    from the  same chemicals that were purchased in
    them.  Keep the original labels intact and add  a
    hazardous waste  label  describing the waste
•   Before  using  a  container   for  a  different
    substance, be certain that the new material  will
    not be incompatible with any remaining residues
    of the original material and re-label the container
    to reflect its new contents. If using the container
    to store hazardous waste, remember to label the
    containers clearly as hazardous waste and with  a
    specific description of the waste material.
•   Glass or plastic containers are usually preferred
    for corrosive materials, as metal containers may
    corrode.  However, you must first conform that
    the container is compatible  with the material.
    Hydrofluoric acid,  for example, will  eat through
    glass  and must, therefore, be stored in plastic
•   Ensure that the waste will not react harmfully
    with the  container or be placed in packaging
    where two  or more different materials  could
    react together, creating a hazardous condition.
    In   addition,   the   US   Department   of
    Transportation (DOT) has specific packaging
    requirements  for  hazardous  materials  and
    hazardous waste based on the material's hazard
    classification.   Refer  to  the  Shipping Tables
    found at 49 CFR 172.101
Land Disposal Restrictions
The Land Disposal Restrictions (LDR) program
imposes    hazardous    waste    treatment
requirements that make the waste safe for land
disposal.  The LDR program  was created by
Congress  in  1984  to  minimize  potential
environmental  threats  resulting   from  land
disposal of hazardous wastes.  Since  then, the
LDR   program   has  developed  mandatory
treatment standards that must be  met before
hazardous waste is placed in a landfill.
To be  subject to the land disposal restrictions, a
waste  must first be a RCRA hazardous waste
(i.e., unless  a waste meets the definition of a
solid and hazardous waste, its disposal will not
be  subject  to the  LDR  program.)   If your
hazardous   wastes   are  subject   to   LDR
requirements, either the waste transporter or the
treatment  or  disposal  facility will   typically
provide you with information on the treatment
standard  and  a   form  that  specifies  the
corresponding treatment or disposal method  to
be used.
 6.7.5 Generator Responsibility and Liability
While reliable hazardous waste transporters and
hazardous waste treatment, storage and disposal
facilities help to simplify many aspects of waste
management,    responsibility    for    proper
management  of the waste  remains  primarily
with the generator. Accordingly, it is important
to adhere  to  the federal  and  state regulatory
requirements,   conduct  due  diligence  on  all
companies  with  whom   you   contract   for
hazardous waste services and educate yourself as
much as possible on the requirements for waste

generated from your studio or classroom.  If
this  responsibility  is  assigned to  a  teacher,
facility   operations   staff   member,   district
manager,  custodian  or other  staff  member,
rather than to you, be sure to provide them with
complete, detailed  information on all  of the
potentially hazardous wastes that  you generate
and familiarize them with your operations.
It is important to remember that if hazardous
waste  from  your  facility  is misidentified  or
otherwise  mismanaged,   your   facility  will
typically bear the liability for enforcement and
potential penalties,  regardless of whether your
staff or a waste hauler's  staff made the waste
If you have  questions,  you can call your state
environmental  agency,  a  U.S. EPA  regional
hazardous  waste office or your  professional
society    or    organization    for   assistance;
alternatively,   you   can   often   find   useful
information  on these organizations' respective
websites.  (See Appendix E for links  to  useful
organizations and websites.)
A well  managed  hazardous  waste  program
contributes to a safer working environment and
reduces the  both  the  risk  of spills  and  the
likelihood    of   hazardous   waste    being
mismanaged, thereby protecting human  health
and  the  environment,  while  reducing  your
organization's potential liability.

6.8 Toxics Use Reduction

The amount of hazardous waste  from your
classroom, shop or studio can be minimized by
using less toxic substitutes, for example:
•   substituting water-based silkscreen printing inks
    for  solvent-based inks;
•   using cadmium-free paint; and
•   using lead-free glazes instead of leaded glazes
    for ceramics, which results in less lead entering
    the  environment from  kiln exhaust  and from
    throwing  away the waste material.
To minimize the use of toxics, first understand
the hazards  present in the  materials  you use.
Then, research and experiment with similar but
less toxic materials.
See  Appendix  D  for  a  list  of alternative
products suppliers and vendors.
6.9 Planning Ahead

To reduce waste, you will need to do a materials
accounting of what you generate. Evaluate each
waste-generating activity and consider how the
waste management  hierarchy - reduce,  reuse,
recycle   —  may  apply  and  whether   your
purchasing  and  materials  management  are
optimal for your organization.  While this may
require   some   exploration   of  alternatives
recommended   by    professional    societies,
consultants, regulators or similar organizations
who have had some success in this area, you will
also  likely  discover  a  few easy steps  that will
produce  less waste  and  be cost effective.  For
example, centralizing purchasing to ensure that
you  don't  overbuy  chemicals or   purchase
redundant   materials  can  reduce  both  the
upfront    purchasing   costs    and    waste
management expenses. The following are just a
few  other  common  examples   of   product
substitutions and process  changes  that may
prove useful.
•   nontoxic   and   biodegradable  cleaners  and
•   cadmium free fluxes,
•   lead free solders,
•   adhesives and sealants without volatile organic
    chemicals (VOC's),
•   solvent distillation units,
•   printmaking screen washout equipment,
•   nontoxic pigments, and
•   water-based nontoxic paints.

Use  the web for research on  products that are
promoted   as   environmentally-friendly   (see
Appendix D for some suggested web sites to
The  table in Appendix F presents  examples of
possible   Waste  Treatment   and   Disposal
Technologies   and  some  basic  precautions,
comments, and suggestions.

                        APPENDIX A



EPA Waste No.
2,4,5-TP (Silvex)
Carbon Tetrachloride
CAS Number
Regulatory Level
Flash Pt. < 140 F
Any material that
will react under
normal conditions
to cause an
explosion or fire
or release a toxic

EPA Waste No.
Heptachlor (and its hydroxide)
Hexachloro- 1,3-butadiene
Methyl ethyl ketone
Vinyl chloride
CAS Number
Regulatory Level

                                40 C.F.R. ง 261.31
                       CODE OF FEDERAL REGULATIONS
                         SUBCHAPTERI-SOLID WASTES
                     Current through August 17, 2004; 69 FR 51014
ง 261.31 Hazardous wastes from non-specific sources.

(a) The following solid wastes are listed hazardous wastes from non-specific sources unless they are
excluded under งง 260.20 and 260.22 and listed in Appendix IX.
Industry and
EPA hazardous
waste No.
Hazardous waste
The following spent halogenated solvent used in degreasing:
Tetrachloroethylene, trichloroethylene, methylene chloride,
1,1,1-trichloroethane, carbon tetrachloride, and chlorinated
fluorocarbons; all spent solvent mixtures /blends used in degreasing
containing, before use, a total of ten percent or more (by volume)
of one or more of the above halogenated solvents or those solvents
listed in F002, F004, and F005; and still bottoms from the recovery
of these spent solvents and spent solvent mixtures.
The following spent halogenated solvents:
Tetrachloroethylene, methylene chloride, trichloroethylene, 1,1,1-
trichloroethane, chlorobenzene, 1,1,2-trichloro- 1,2,2-
trifluoroethane, ortho-dichlorobenzene, trichlorofluoromethane,
and 1,1,2-trichloroethane; all spent solvent mixtures /blends
containing, before use, a total often percent or more (by volume)
of one or more of the above halogenated solvents or those listed in
F001, F004, or F005; and still bottoms from the recovery of these
spent solvents and spent solvent mixtures.

    Industry and
  EPA hazardous
     waste No.
                      Hazardous waste
The following spent non-halogenated solvents:
Xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl
isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; all
spent solvent mixtures/blends containing, before use, only the
above spent non-halogenated solvents; and
 all spent solvent mixtures /blends containing, before use, one or
more of the above non-halogenated solvents, and, a  total of ten
percent or more (by volume) of one or more of those solvents listed
in F001, F002, F004, and F005; and still bottoms from the recovery
of these spent solvents and spent solvent mixtures.	
The following spent non-halogenated solvents:
Toluene, methyl ethyl ketone, carbon disulfide, isobutanol, pyridine,
benzene, 2-ethoxyethanol, and 2-nitropropane; all spent solvent
mixtures/blends containing, before use, a total often percent or
more  (by volume) of one or more of the above non-halogenated
solvents or those solvents listed in F001, F002, or F004; and still
bottoms from the recovery of these spent solvents and spent
solvent mixtures.
FNa (I,T) should be used to specify mixtures containing ignitable and toxic  constituents.

                                     40 C.F.R. ง 261.33
                          CODE OF FEDERAL REGULATIONS
                      TITLE 40-PROTECTION OF ENVIRONMENT
                             SUBCHAPTERI-SOLID WASTES
                        Current through August 17, 2004; 69 FR 51014
ง 261.33 Discarded commercial chemical products, off-specification  species, containers, and spill
residues thereof.
The following materials or items are hazardous wastes if and when they are discarded or intended to
be discarded as described in ง 261.2(a)(2)(i), when they are mixed with waste oil or used oil or other
material and applied to the land for dust suppression or road treatment, when they are otherwise
applied to the land in lieu of their original intended use or when they are contained in products that
are applied to the land in lieu of their original intended use, or when, in lieu of their original intended
use, they are  produced for use as (or as a component of) a fuel, distributed for use as a fuel, or
burned as a fuel.
(a) Any commercial chemical product, or manufacturing chemical intermediate having the generic
name listed in paragraphs  (e) or (f) of this section.
(b) Any  off-specification commercial  chemical  product or manufacturing  chemical intermediate
which, if it met specifications,  would have  the generic name listed in paragraphs (e) or (f)  of this
(c) Any residue remaining in a container or in an  inner liner removed from a container that has held
any commercial chemical product or manufacturing chemical intermediate having the generic name
listed in paragraphs (e) or (f) of this section, unless the container is empty as defined in ง 261.7(b) of
this chapter.

[Comment: Unless the residue is being beneficially used  or reused, or legitimately recycled or
reclaimed; or being accumulated, stored, transported or treated prior to such use, re-use, recycling or
reclamation, EPA considers the residue to be intended for discard, and thus,  a hazardous waste. An
example of a legitimate re-use of the residue would be where the residue remains in the container and
the container is used  to hold the same commercial chemical product or manufacturing chemical
intermediate it previously held. An example of the discard of the residue would be where the drum is
sent to a drum reconditioner who reconditions the drum but discards the residue.]
(d) Any residue or contaminated soil, water  or other debris resulting from the cleanup of a spill into
or on any land or water of any commercial chemical product or manufacturing chemical intermediate
having the generic name listed in paragraph (e) or (f) of this section, or any residue or contaminated
soil, water or  other debris resulting from the cleanup of a spill, into or on any land or water, or any
off-specification  chemical product  and manufacturing chemical  intermediate  which,  if  it met
specifications, would have the generic name listed in paragraph (e) or (f) of this section.

[Comment:  The  phrase  "commercial  chemical product or  manufacturing chemical intermediate
having the generic name listed in ..." refers  to  a chemical  substance which  is manufactured or
formulated for commercial or manufacturing use  which consists of the commercially pure grade of
the chemical, any technical  grades  of the  chemical  that  are  produced or  marketed,  and  all
formulations in which the chemical is the sole  active ingredient. It does not refer to a material, such
as a manufacturing process waste, that contains any of the substances listed in paragraphs (e)  or (f).
Where a manufacturing  process waste is deemed to be a hazardous waste  because  it contains a
substance listed in paragraphs  (e) or (f), such waste will be listed in either งง 261.31 or 261.32 or will
be identified as a hazardous waste by the characteristics set forth in Subpart C of this part.]
(e) The commercial chemical products, manufacturing  chemical intermediates  or off-specification
commercial chemical products or manufacturing chemical intermediates referred to in paragraphs (a)
through (d)  of this section, are identified as acute hazardous wastes (H) and are subject to be the
small quantity exclusion defined in ง 261.5(e).
[Comment: For the convenience of the regulated community the primary hazardous  properties of
these materials have been indicated by the letters T (Toxicity), and R (Reactivity). Absence of a letter
indicates that the compound only is listed for acute toxicity.]
f)  The commercial chemical products, manufacturing chemical intermediates,  or off-specification
commercial chemical products referred to in paragraphs  (a) through  (d) of this section, are identified
as toxic wastes (T), unless otherwise  designated  and are subject  to the small quantity generator
exclusion defined in ง 261.5 (a) and (g).

These wastes and their corresponding EPA Hazardous Waste Numbers are:
Common name
Acetyl chloride
Aldicarb sulfbne
CAS Name
Ethanimidothioic acid, 2-(dimethylamino)-N-
hydroxy-2-oxo-, methyl ester
Ethanone, 1-phenyl-
Acetamide, N-9H-fluoren-2-yl-
Acetamide, N-(aminothioxomethyl)-
Propanal, 2-methyl-2-(methylthio)-, O-
[(methylamino)carbonyl] oxime
Propanal, 2-methyl-2- (methylsulfonyl) -, O-
[(methylamino) carbonyl] oxime
Cas No.
HW Code

Common name
Allyl alcohol
Aluminum phosphide
Ammonium vanadate
Arsenic acid
Arsenic pentoxide
Arsenic trioxide
Barb an
Barium cyanide
Bendiocarb phenol
Benz [a] anthracene
Benzal chloride
Benzo [ajpyrene
CAS Name
1,4,5,8-Dimethanonaphthalene, 1,2,3,4,10,10-
3(2H)-Isoxazolone, 5-(aminomethyl)-
Vanadic acid, ammonium salt
Arsenic acid H3 AsO4
Arsenic oxide As2 O5
Arsenic oxide As2 O3
Benzenamine, 4,4'-carbonimidoylbis [N,N-di-
L-Serine, diazoacetate (ester)
Carbamic acid, (3-chlorophenyl) -, 4-chloro- 2-
butynyl ester
l,3-Benzodioxol-4-ol, 2,2-dimethyl-, methyl
1 ,3-Benzodioxol-4-ol, 2,2-dimethyl-,
Carbamic acid, [1- [(butylamino) carbonyl]-
lH-benzimidazol-2-yl] -, methyl ester
Benzene, (dichloromethyl)-
[l,l'-Biphenyl]-4,4 1-diamine
Cas No.
HW Code

Common name
Benzyl chloride
Beryllium powder
4-Bromophenyl phenyl ether
Cacodylic acid
Calcium chromate
Calcium cyanide
Carbofuran phenol
Carbon disulfide
Carbon oxyfluoride
Carbon tetrachloride

CAS Name
Benzene, (trichloromethyl)-
Benzene, (chloromethyl)-
2-Propanone, 1-bromo-
Methane, tribromo-
Benzene, l-bromo-4-phenoxy-
Strychnidin-10-one, 2,3-dimethoxy-
Arsinic acid, dimethyl-
Chromic acid H2 CrO4, calcium salt
Calcium cyanide Ca(CN)2
1-Naphthalenol, methylcarbamate
Carbamic acid, lH-benzimidazol-2-yl, methyl
7-Benzoฃuranol, 2,3-dihydro-2,2-dimethyl-,
7-Benzo furanol, 2,3-dihydro-2,2-dimethyl-
Carbonic difluoride
Methane, tetrachloro-
Carbamic acid, [(dibutylamino) thio] methyl-,
2,3-dihydro-2,2-dimethyl-7-benzofuranyl ester
Acetaldehyde, trichloro-
Benzenebutanoic acid, 4- [bis (2-
chloroethyl) amino] -
4,7-Methano-lH-indene, 1,2,4,5,6, 7,8,8-

Naphthalenamine, N,N'-bis (2-chloroethyl)-
Acetaldehyde, chloro-
Cas No.

HW Code



Common name
p-Chloro aniline
2-Chloroethyl vinyl ether
Chloromethyl methyl ether
Copper cyanide
Cresol (Cresylic acid)
m-Cumenyl methylcarbamate
Cyanides (soluble salts and
complexes) NOS*
Cyanogen bromide
Cyanogen chloride
Cyclopho sphamide
2,4-D, salts, esters
CAS Name
Benzenamine, 4-chloro-
Benzene, chloro-
Benzeneacetic acid, 4-chloro-alpha-(4-
chlorophenyl)-alpha-hydroxy-, ethyl ester
Phenol, 4-chloro-3-methyl-
Ethene, (2-chloroethoxy)-
Methane, trichloro-
Methane, chloromethoxy-
Naphthalene, 2-chloro-
Phenol, 2-chloro-
Thiourea, (2-chlorophenyl)-
Propanenitrile, 3-chloro-
Copper cyanide CuCN
Phenol, methyl-
Phenol, 3-(methylethyl)-, methyl carbamate

Cyanogen bromide (CN)Br
Cyanogen chloride (CN)C1
Phenol, 2-cyclohexyl-4,6-dinitro-
2H-l,3,2-Oxazaphosphorin-2-amine, N,N-
bis (2-chloroethyl)tetrahydro-, 2-oxide
Acetic acid, (2,4-dichlorophenoxy)-

Cas No.



HW Code

Common name
Dibenz [a,h] anthracene
Dibenzo [a,i]pyrene
Dibutyl phthalate
Dichloroethyl ether
Dichloroisopropyl ether
Dichloromethoxy ethane
Dichlorornethyl ether
2,4- Dichlo rophenol
CAS Name
5,12-Naphthacenedione, 8-acetyl-10-[(3-amino-
2,3,6-trideoxy- alpha- L-lyxo-
hexopyranosyl)oxy]-7,8,9,10-tetrahydro- 6,8,11-
trihydroxy-1-methoxy-, (8S-cis)-
Benzene, l,l'-(2,2-dichloroethylidene)bis [4-
Benzene, l,l'-(2,2,2-trichloroethylidene)bis [4-
Carbamothioic acid, bis(l-methylethyl)-, S-(2,3-
dichloro-2-propenyl) ester
Benzo [rstjpentaphene
Propane, l,2-dibromo-3-chloro-
1,2-Benzenedicarboxylic acid, dibutyl ester
Benzene, 1,2-dichloro-
Benzene, 1,3-dichloro-
Benzene, 1,4-dichloro-
[l,l'-Biphenyl]-4,4)-diamine, 3,3'-dichloro-
2-Butene, 1,4-dichloro-
Methane, dichlorodifluoro-
Ethene, 1,1-dichloro-
Ethene, 1,2-dichlrol-, (E)-
Ethane, l,l'oxybis[2-chloro-
Propane, 2,2'-oxybis [2-chloro-
Ethane, l,l'-[niethylenebis(oxy)]bis[2-chloro-
Methane, oxybis [chloro-
Phenol, 2,4-dichloro-
Phenol, 2,6-dichloro-
Arsonous dichloride, phenyl-
1-Propene, 1,3-dichloro-
Cas No.
HW Code

Common name
1 ,2: 3,4-Diepoxybutane
Diethylene glycol,
Diethylhexyl phthalate
O,O-Diethyl S-methyl
Diethyl phthalate
O,O-Diethyl O-pyrazinyl
p-Dimethylamino azobenzene
Dimethylbenz [a] anthracene
Diniethylcarbamoyl chloride
1 , 1 -Dimethylhydrazine
CAS Name
2,7: 3,6-Dimethanonaphth [2,3-b] oxirene,
Arsine, diethyl-
Ethanol, 2,2'-oxybis-, dicarbamate
1,2-Benzenedicarboxylic acid, bis(2-ethylhexyl)
Hydrazine, 1,2-diethyl-
Phosphorodithioic acid, O,O-diethyl S-methyl
Phosphoric acid, diethyl 4-nitrophenyl ester
1,2-Benzenedicarboxylic acid, diethyl ester
Phosphorothioic acid, O,O-diethyl O-pyrazinyl
Phenol, 4,4'-(l,2-diethyl-l,2-ethenediyl)bis-,(E)-
1,3-Benzodioxole, 5-propyl-
Phosphorofluoridic acid, bis(l-methylethyl)
Phosphorodithioic acid, O,O-dimethyl S-[2-
(methylamino)-2-oxoethyl] ester
[l,l'-Biphenyl]-4,4'-diamine, 3,3'-dimethoxy-
Benzenamine, N,N-dimethyl-4-(phenylazo)-
Benz [a] anthracene, 7,12-dimethyl-
[1 ,1 '-Biphenyl] -4,4'-diamine, 3,3'-dimethyl-
Carbamic chloride, dimethyl-
Hydrazine, 1,1-dimethyl-
Hydrazine, 1,2-dimethyl-
Cas No.
HW Code

Common name
Dimethyl phthalate
Dimethyl sulfate

Di-n-octyl phthalate

T-, , • , ,.

Ethyl carbamate (urethane)
CAS Name
Benzeneethanamine, alpha,alpha-dimethyl-
Phenol, 2,4-dimethyl-
1,2-Benzenedicarboxylic acid, dimethyl ester
Sulfiiric acid, dimethyl ester
Carbamic acid, dimethyl-, 1- [(dimethylamino)
carbonyl]-5-methyl-lH-pyrazol-3-yl ester
Phenol, 2-methyl-4,6-dinitro-

Phenol, 2,4-dinitro-
Benzene, l-methyl-2,4-dinitro-
Benzene, 2-methyl-l,3-dinitro-
Phenol, 2-(l-methylpropyl)-4,6-dinitro-
1,2-Benzenedicarboxylic acid, dioctyl ester
Hydrazine, 1,2-diphenyl-
1-Propanamine, N-nitroso-N-propyl-
Phosphorodithioic acid, O,O-diethyl S-[2-
(ethylthio)ethyl] ester
Thioimidodicarbonic diamide [(H2
hexahydro-, 3-oxide
7-Oxabicyclo [221]heptane-2,3-dicarboxylic acid
2,7: 3,6-Dimethanonaphth [2,3-b] oxirene,
3,4,5, 6,9,9-hexachloro-la,2,2a,3,6,6a,7,7a-octa-

Oxirane, (chloromethyl)-
1,2-Benzenediol, 4-[l-hydroxy-2-
(methylamino) ethyl]-, (R)-
Carbamic acid, ethyl ester
Cas No.
131_1 1_3


HW Code




Common name
Ethyl cyanide
Ethylenebis dithio carb amic
Ethylenebis dithio carb amic
acid, salts and esters
Ethylene dibromide
Ethylene dichloride
Ethylene glycol monoethyl
Ethylene oxide
Ethylidene dichloride
Ethyl methacrylate
Ethyl rnethanesulfonate
Fluoroacetic acid, sodium salt
Formetanate hydrochloride
Formic acid
CAS Name
Carbamodithioic acid, 1,2-ethanediylbis-

Ethane, 1,2-dibromo-
Ethane, 1,2-dichloro-
Ethanol, 2-ethoxy-
Ethane, 1,1-dichloro-
2-Propenoic acid, 2-methyl-, ethyl ester
Methanesulfonic acid, ethyl ester
Phosphorothioic acid, O-[4-
[(dimethylamino)sulfonyl]phenyl] O,O-di-
methyl ester
Acetamide, 2-fluoro-
Acetic acid, fluoro-, sodium salt
Methanimidamide, N,N-dimethyl-N'-[3-
[[(methylamino) carbonyl]oxy]phenyl]-,
Methanimidamide, N,N-dimethyl-N'-[2-
methyl-4- [[(methylamino)
carbonyl] oxy] phenyl] -
Oxiranecarboxy aldehyde
4,7-Methano-lH-indene, 1,4,5,6,7,8,8-
Cas No.

HW Code

Common name


Hexaethyl tetraphosphate
Hydrogen cyanide
Hydrogen fluoride
Hydrogen sulfide
Indeno [1 ,2,3-cd] pyrene
Isobutyl alcohol

Lead acetate
Lead phosphate
Lead subacetate

CAS Name
Benzene, hexachloro-
1,3-Butadiene, 1,1,2,3,4,4-hexachloro-

1,3-Cyclopentadiene, 1,2,3,4,5,5-hexachloro-

Ethane, hexachloro-
Phenol, 2,2'-methylenebis [3,4,6-trichloro-
1-Propene, 1,1,2,3,3,3-hexachloro-
Tetraphosphoric acid, hexaethyl ester
Hydrocyanic acid
Hydrofluoric acid
Hydrogen sulfide H2 S
1-Propanol, 2-methyl-
1 ,4,5,8-Dimethanonaphthalene, 1 ,2,3,4,1 0,1 0-
,(lalpha,4alpha,4abeta,5beta, 8beta,8abeta)-
Carbamic acid, dimethyl-, 3-methyl-l-(l-
methylethyl)-lH-pyrazol-5-yl ester
1,3-Benzodioxole, S-(l-propenyl)-
one, l,la,3,3a,4,5,5,5a,5b,6-
2-Butenoic acid, 2-methyl-,7-[[2,3-dihydroxy-2-
(1 -methoxyethyl) -3-methyl- 1 -
oxobutoxyjmethyl] -2,3,5,7a-tetrahydro- 1H-
pyrrolizin-1-yl ester, [1S-
Acetic acid, lead(2+) salt
Phosphoric acid, lead(2+) salt (2:3)
Lead, bis (acetato-O)tetrahydroxytri-
Cyclohexane, 1,2,3,4,5,6-hexachloro-,
(lalpha,2alpha,3beta,4alpha, 5alpha,6beta)-
Cas No.




HW Code



PI 92


Common name
Maleic anhydride
Maleic hydrazide
diniethyldithiocarb amate
Mercury fulminate
Methyl bromide
Methyl chloride
Methyl chlorocarbonate
Methyl chloroform
chloro aniline)
Methylene bromide
Methylene chloride
Methyl ethyl ketone (MEK)
Methyl ethyl ketone peroxide
Methyl hydrazine
Methyl iodide
Methyl isocyanate
CAS Name
3,6-Pyridazinedione, 1,2-dihydro-
Manganese, bis (dimethylcarbamodithioato-
L-Phenylalanine, 4- [bis (2-chloroethyl) aminol] -
Fulminic acid, mercury (2+) salt
2-Propenenitrile, 2-methyl-
1,2-Ethanediamine, N,N-dimethyl-N'-2-
pyridinyl-N'- (2-thienylmethyl) -
Phenol, (3,5-dimethyl-4-(methylthio)-
Ethanimidothioic acid, N-
[[(methylamino)carbonyl]oxy]-, methyl
Benzene, l,l'-(2,2,2-trichloroethylidene)bis [4-
Methane, bromo-
Methane, chloro-
Carbonochloridic acid, methyl ester
Ethane, 1,1,1-trichloro-
Benz [j] aceanthrylene, l,2-dihydro-3-methyl-
Benzenamine, 4,4'-methylenebis [2-chloro-
Methane, dibromo-
Methane, dichloro-
2-Butanone, peroxide
Hydrazine, methyl-
Methane, iodo-
Methane, isocyanato-
Cas No.
HW Code

Common name
Methyl methacrylate
Methyl parathion
Mitomycin C
alpha-N aphthylthiourea
Nickel carbonyl
Nickel cyanide

Nitric oxide
p-Nitro aniline
Nitrogen dioxide
CAS Name
Propanenitrile, 2-hydroxy-2-methyl-
2-Propenoic acid, 2-niethyl-, methyl ester
Phosphorothioic acid, O,O-dirnethyl O-(4-
nitrophenyl) ester
4(1 H) -Pyrimidinone, 2,3-dihydro- 6-methyl-2-
Carbamic acid, methyl-, 3-methylphenyl ester
Phenol, 4-(dimethylamino)-3,5-dimethyl-,
methyl-, [laS-(laalpha,8beta,8aalpha,8balpha)]-
Guanidine, N-methyl-N'-nitro-N-nitroso-
Thiourea, 1-naphthalenyl-
Nickel carbonyl Ni(CO)4, (T-4)-
Nickel cyanide Ni(CN)2
Pyridine, 3-(l-methyl-2-pyrrolidinyl)-, (S)-

Nitrogen oxide NO
Benzenamine, 4-nitro-
Benzene, nitro-
Nitrogen oxide NO2
1,2,3-Propanetriol, trinitrate
Phenol, 4-nitro-
Propane, 2-nitro-
Cas No.

HW Code


Common name
Osmium tetroxide
Par aldehyde
Phenylmercury acetate
CAS Name
1-Butanamine, N-butyl-N-nitroso-
Ethanol, 2,2'-(nitrosoimino)bis-
Ethanamine, N-ethyl-N-nitroso-
Methanamine, N-methyl-N-nitroso-
Urea, N-ethyl-N-nitroso-
Urea, N-methyl-N-nitroso-
Carbamic acid, methylnitroso-, ethyl ester
Vinylamine, N-methyl-N-nitroso-
Piperidine, 1-nitroso-
Pyrrolidine, 1-nitroso-
Benzenamine, 2-methyl-5-nitro-
Diphosphoramide, octamethyl-
Osmium oxide OsO4, (T-4)-
Ethanimidothioc acid, 2-(dimethylamino)-N-
[[(methylamino)carbonyl]oxy]-2-oxo-, methyl
1,3,5-Trioxane, 2,4,6- trimethyl-
Phosphorothioic acid, O,O-diethyl O-(4-
nitrophenyl) ester
Benzene, pentachloro-
Ethane, pentachloro-
Benzene, pentachloronitro-
Acetamide, N-(4-ethoxyphenyl)-
Mercury, (acetato-O)phenyl-
Thiourea, phenyl-
Carbonic dichloride
Cas No.
HW Code

Common name
Phthalic anhydride

Physostigmine salicylate

Potassium cyanide
Potassium silver cyanide
Pron amide
1,3-Propane sultone
Propargyl alcohol
Propylene dichloride
Q 1 • U

CAS Name
Phosphorodithioic acid, O,O-diethyl S-
[(ethylthio)methyl] ester
Pyrrolo[2,3-b]indol-5-01, l,2,3,3a,8,8a-
(ester), (3aS-cis)-
Benzoic acid, 2-hydroxy-, compd with (3aS-cis)
trimethylpyrrolo [2,3-b]indol-5-yl
methylcarbamate ester (1:1)
Pyridine, 2-methyl-
Potassium cyanide K(CN)
Argentate(l-), bis(cyano-C)-, potassium
Phenol, 3-methyl-5-(l-methylethyl)-, methyl
Benzamide, 3,5-dichloro-N-(l,l-dimethyl-2-
1,2-Oxathiolane, 2,2-dioxide
Carbamic acid, phenyl-, 1-methylethyl ester
Phenol, 2-(l-methylethoxy)-,methylcarbamate
Propane, 1,2-dichloro-
Aziridine, 2-methyl-
Carbamothioic acid, dipropyl-, S-
(phenylmethyl) ester
Yohimban-16-carboxylic acid, 11,17-
dimethoxy- 18- [(3,4,5- trimethoxybenzoyl) oxy] -
l,2-Benzisothiazol-3(2H)-one, 1,1-dioxide

Cas No.



HW Code




Common name
Selenium dioxide
Selenium sulfide
Silver cyanide
Sodium cyanide

1 ,1 ,2,2-Tetrachloroethane
Tetraethyl lead
Tetraethyl pyrophosphate
Thallic oxide
Thallium (T) acetate
Thallium(I) carbonate
Thallium(I) chloride
Thallium(I) nitrate
Thallium selenite
Thallium(I) sulfate
CAS Name
1,3-Benzodioxole, 5-(2-propenyl)-
Selenious acid
Selenium sulfide SeS2
Silver cyanide Ag(CN)
Sodium cyanide Na(CN)
D-Glucose, 2-deoxy-2-

Benzene, 1, 2,4,5- tetrachloro-
Ethane, 1,1,1,2-tetrachloro-
Ethane, 1,1,2,2-tetrachloro-
Ethene, tetrachloro-
Thiodiphosphoric acid, tetraethyl ester
Plumbane, tetraethyl-
Diphosphoric acid, tetraethyl ester
Methane, tetranitro-
Thallium oxide T12 O3
Acetic acid, thallium(l+) salt
Carbonic acid, dithallium(l+) salt
Thallium chloride T1C1
Nitric acid, thallium(l+) salt
Selenious acid, di thallium (1+) salt
Sulfuric acid, dithallium(l+) salt
Ethanimidothioic acid, N,N'-[thiobis
[(methylimino) carbonyloxy]] bis-, dimethyl
Cas No.

HW Code


Common name

Thioph an ate-me thyl
Thio s emicarb azide
Toluene diisocyanate
o-Toluidine hydrochloride
Tris (2,3-dibromopropyl)
CAS Name
2-Butanone, 3,3-dimethyl-l-(methylthio)-, 0-
[(methylamino)carbonyl] oxime
Carbamic acid, [1,2-phyenylenebis
(iminocarbonothioyl)] bis-, dimethyl ester
Hydrazinecarbothio amide
Thioperoxydicarbonic diamide [(H2 N)C(S)]2
S2, tetramethyl-
l,3-Dithiolane-2-carboxaldehyde, 2,4-di-
methyl-, O-[(methylamino) carbonyl] oxime
Benzene, methyl-
Benzenediamine, ar-methyl-
Benzene, 1,3-diisocyanatomethyl-
Benzenamine, 2-methyl-
Benzenamine, 2-methyl-, hydrochloride
Benzenamine, 4-methyl-
Carbamothioic acid, bis(l-methylethyl)-, S-
(2,3,3-trichloro-2-propenyl) ester
Tribromophenol, 2,4,6-
Ethane, 1,1,2-trichloro-
Ethene, trichloro-
Methanethiol, trichloro-
Methane, trichlorofluoro-
Ethanamine, N,N-diethyl-
Benzene, 1,3,5-trinitro-
1-Propanol, 2,3-dibromo-, phosphate (3:1)
Cas No.

HW Code


Common name
Trypan blue
Uracil mustard
Vanadium pentoxide
Vinyl chloride
Warfarin salts, when present
at concentrations less than
Warfarin salts, when present
at concentrations greater than
Zinc cyanide
Zinc phosphide
Zinc phosphide
CAS Name
2,7-Naphthalenedisulfonic acid, 3,3'- [(3,3'-
amino-4-hydroxy-, tetrasodium salt
2,4- (1 H,3H) -Pyrimidinedione, 5- [bis (2-
chloroethyl) amino] -
Vanadium oxide V2 O5
Ethene, chloro-
2H- 1 -Benzopyran-2-one, 4-hydroxy-3- (3-oxo-
1-phenylbutyl)-, when present at
concentrations less than 03%
2H- 1 -Benzopyran-2-one, 4-hydroxy-3- (3-oxo-
1-phenylbutyl)-, when present at
concentrations greater than 03%-

Zinc cyanide Zn(CN)2
Zinc phosphide Zn3 P2, when present at
concentrations greater than 10%
Zinc phosphide Zn3 P2, when present at
concentrations of 10% or less
Zinc, bis(dimethylcarbamodithioato-S,S')-,(T-
Cas No.

HW Code
FN1 CAS Number given for parent compound only.

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                APPENDIX B

               Container Management


           Hazardous Waste / Universal Waste Storage Area Checklists
           (CESQG; LQG 90-day and SQG 180-day)
           Satellite Accumulation Areas

             Hazardous Waste / Universal Waste Storage Area Checklist
Bldg. Name:
Room/ Area
Dept. or Unit:

90-day Hazardous Waste Storage Area


Type of wastes located in the area and general description: Reference specific Waste Profiles or internal Codes.

Hazardous Waste Storage Standards

Completing this checklist on a weekly basis will provide compliance assurance for all classes of generators.

     •   Large Quantity Generator (LOG) - LQGs produce more that 1,000 kg (2,200 Ibs) in a calendar month,
         or more than 1 kg (2.2 Ibs) of acutely hazardous waste in a calendar month.

Apply to the storage of hazardous waste that is generated on site, for a period not exceeding 90  days. Storage of
liquid  hazardous  waste may not exceed  8,800 gallons  unless  the area  meets the secondary  containment
requirements of NYS 373-2.9(f)(1).

     •   Small Quantity  Generator (SQG) - SQGs  produce less than LOG quantities  but more  than  100 kg
         (220 Ibs) of hazardous waste, and accumulate  less than 6,000 kg (13,200 Ibs)  of hazardous waste at

     •   Conditionally Exempt Small Quantity Generator (CESQG) - CESQGs are those that generate less
         than 100 kg (220 Ibs) of hazardous waste in a calendar month, or less than 1  kg  (2.2 Ibs) of  acutely
         hazardous waste in a calendar month. Additionally, CESQGs must limit storage/accumulation  to less
         than 1,000 kg  (2,200 Ibs) of listed and / or characteristic hazardous waste, or 1  kg (2.20  Ibs) of acute
         hazardous waste at any time.
Containers are marked with the words "Hazardous Waste" and other words identifying the contents?  Yes 	   No
If no, describe finding:	
The accumulation start date is clearly marked and visible for inspection on each container?         Yes

If no, describe finding:	
Prior to shipment, containers are marked and labeled in accordance with DOT requirements?       Yes 	   No

If no, describe finding:	
A label or sign stating "Hazardous Waste" is posted in the area?

If no, describe finding:	
Containers are in good condition (not leaking or corroding)?

If no, describe finding:  	
Containers are compatible with contents (refer to compatibility table)?

If no, describe finding:	

Containers are closed (containers must be kept closed except when adding or removing waste)?
Yes 	    No 	        If no, describe finding:	
Containers holding ignitable or reactive waste are located at least 50 feet from the facility property line?
Yes 	      No 	       If no, describe finding:	
Adequate precautions are taken to prevent the accidental ignition or reaction of ignitable or reactive waste? "No Smoking"
signs are conspicuously placed (if there is a hazard from ignitable or reactive waste)?
Yes  	      No 	      Not Applicable 	 If no, describe finding:	
Incompatible wastes and materials are properly segregated, separated (by dike, wall, berm, etc.) and managed?
Yes  	    No 	        If no, describe finding:	
Sufficient aisle space is provided between containers to allow the unobstructed movement of personnel, fire protection
equipment, spill control equipment, and decontamination equipment?         Yes 	     No 	
If no, describe finding:	

Storage area is inspected at least weekly to identify leaking containers and deterioration of containers and containment
system? Records of inspections are maintained (recommended)?           Yes	      No 	
If no, describe finding:	

All hazardous wastes are shipped off site to a state approved and federally authorized treatment, storage, or disposal facility in
90 days or less? (LQG)

All hazardous wastes are shipped off site to a state approved and federally authorized treatment, storage, or disposal facility in
180 days or less? (SQG)

Yes 	     No 	        If no, describe finding:	
Posted Emergency Response Information at  Hazardous Waste Storage area: Yes 	    No 	
            Name of Emergency Coordinator and designated alternates; Telephone:  Work / Home / Mobile
            The location of fire extinguishers, alarm systems, spill abatement, containment and cleanup equipment
            Internal emergency incident notification procedures
            External emergency response procedure and resources  (Fire, Police, Emergency Response Contractor)

The following equipment is readily accessible, tested, and maintained:
Internal communication  or alarm system to provide immediate emergency instruction to personnel?  Yes 	   No
Device (such as telephone or two-way radio)  capable of summoning emergency assistance?        Yes 	   No
Portable fire extinguishers, spill control equipment, and  decontamination equipment?               Yes 	   No
Water at adequate volume and pressure, or foam-producing equipment, or automatic sprinklers?     Yes 	   No
If no, describe finding:	

2.1.1  The emergency response procedures and information will be kept current and updated in the facility Hazardous Waste
emergency contingency plan.

Universal Waste Storage (Universal waste may be accumulated for up to one year from the date the universal waste is


Containers holding universal waste are closed, structurally sound, compatible with the contents, and lack evidence of leakage,

spillage, or damage?   Yes	      No	       NA	

If no, describe finding:	

Universal waste is properly marked or labeled?     Yes	      No	
If no, describe finding:	

Universal waste is accumulated for no more than one year (unless facility has demonstrated that more time is needed to
accumulate sufficient quantities as necessary to facilitate proper recovery, treatment, or disposal?
Yes	    No 	       If no, describe finding:	
2.1.1 Training

Personnel involved with the accumulation point are aware of the applicable requirements?   Yes	           No

If no, describe finding:
Other Issues

Are there other issues of concern, such as chemical management / handling, air quality, wastewater discharges?

Yes  	    No 	       If no,  describe finding:
Weekly Inspection Risk Classification:              Level I - Major	 Level II - Moderate	  Level III - Minor_
Level I - Major: Significant risk for spill, fire, explosion or technical non compliance with waste management requirements.

Level II - Moderate: risk for spill, fire, explosion or technical non compliance with waste management requirements.

Level III - Minor:  risk for spill, fire, explosion or technical non compliance with waste management requirements.
Inspection results conveyed to:                           Name


                                                      Date:                       Time

Satellite Point Checklist Form
 Bldg. Name:       	         Date:
 Name/No.:       	         Time:
 Description:       	       Auditor:

 PI or Unit:         	      Contact:

 Type of waste streams and general description of satellite accumulation points:	
Hazardous Waste Point of Generation Accumulation Standards - apply to up to 55 gallons of hazardous waste or one
quart of acutely hazardous waste in containers at or near any point of generation where wastes initially accumulate, which is
under the control of the operator of the process generating the waste.

Satellite container(s) are marked with the words "Hazardous Waste" and other words identifying the contents?
Note: EH&S waste label properly completed will fully comply with this requirement.
Yes 	    No 	      If no, describe finding:
All wastes at or near the point of generation?
Yes 	    No 	       If no, describe finding:
Container(s) are in good condition (not leaking or corroding)?    Yes 	  No
If no, describe finding:	
Container(s) are compatible with contents?    Yes 	   No
If no, describe finding:
Container(s) are closed (containers must be kept closed except when adding waste)?   Yes 	   No
If no, describe finding:	
If more than 55 gallons of hazardous waste, or one quart of acutely hazardous waste, are in storage, container(s) holding the
excess accumulation are marked with the date the excess amount began accumulating?
Yes 	    No 	      If no, describe finding:	
Personnel have received EH&S Chemical Waste Disposal training?   Yes 	       No
If no, describe finding:	

Personnel involved with waste generation and accumulation:
      1) are aware of the accumulation limitations and proper procedures ?  Yes
      2) treat waste in lab?                                            Yes
      3) dispose of chemicals to the sanitary sewer?                      Yes
      4) dispose of chemicals into the trash?                             Yes
      5) dispose of chemicals through EH&S?                            Yes
      6) are aware of the contents and location of Cornell's General Chemical Waste Rules?  Yes
If no, describe finding(s):	
                                     Correct _
                                     Correct _
                                     Correct _
Did area perform a self-audit?  Yes
Don't know
Universal Waste Standards - apply to certain batteries, pesticides, mercury thermostats, and fluorescent lamps.
Universal wastes are properly marked with waste name and initial accumulation date? Yes 	    No 	    NA_
If no, describe finding:	
Personnel are adequately trained in the proper identification of universal waste?  Yes
If no, describe finding:	
Waste batteries, pesticides, thermostats, and fluorescent lamps are managed in a way that prevents releases to the
environment?    Yes 	    No 	       If no, describe finding:	
Other Issues
Are chemical containers in storage in good condition? Yes
If no, describe finding:	
Were any perishable chemicals observed beyond their expiration date? Yes
If yes, describe finding:	
Are other types of "inherently waste-like" or speculatively accumulated containers present? Yes
If yes, describe finding:	
Are there other issues of concern, such as chemical management / handling, air quality, wastewater discharges?
Yes  	    No 	       If no, describe finding:	
Inspector Classification:        Level I 	
Inspection results conveyed to:        Name
         Level II

                                      APPENDIX C
  x     EPA Regulated Hazardous Waste
  +     EPA Known Carcinogen
  **    Persistent Bio-Accumulative Toxins (PBT's) PBT's are a class of toxins that accumulate in fatty tissue.
        Even low-exposure to PBT's are hazardous as the health effects develop and increase over time.
1,1,1 Trichloroethane**x
1,1,1 Trichlorethane is a chlorinated solvent that is non-flammable in liquid form but can explode when
ignited in vapor form. It is a skin and mucous membrane irritant and can depress the central nervous system
and respiratory track. Inhaling vapors can cause dizziness, suffocation and skin and eye burns. It is also an
ozone depleting substance and is banned for use.

Acetate is a colorless liquid or solid with a pungent, vinegar-like odor that is manufactured from petroleum
for industrial use.  Acetate can depress the central irritation to the eyes, dermatitis and skin ulcers.

Acetone  x
Most commonly found in nail polish remover, it is also used as a solvent. Acetone is a clear liquid with a
sweet, pungent odor. Chronic low exposures usually do not pose a high risk, but in high concentrations it
can cause eye and mucous membrane irritation, headaches and dizziness. Ingestion brings about diabetes-
like symptoms. Some people are allergic to acetone by skin contact and will develop dermatitis.

The most abundant metal  in the earth's crust,  aluminum does  not dissolve readily in neutral water.
Exposure to aluminum dust can lead  to lung disease. Through ingestion, it can cause kidney damage.
Although not yet proven, it is widely believed that aluminum is a factor in the development of Alzheimer's

Ammonia x
Ammonia is a colorless gas, less dense than air, with a strong odor. At high concentrations, it can be
explosive in the air. It is a skin, eye and respiratory tract irritant. Ingestion can cause corrosive effects to the
mouth, throat and stomach.  Inhaling concentrated ammonia fumes may be toxic and lead to asphyxiation.
Direct eye contact with concentrated ammonia gas or liquid will cause  immediate, serious, irreversible
damage.  Generally ammonia solutions are alkaline corrosives.

Antimony **
Antimony is a silvery-white metal that  is often alloyed with other metals to form compounds. It is a highly
acute toxic that causes skin rashes, eye conjunctivitis and gastrointestinal damage if ingested. Chronic
exposure to antimony will result in respiratory and cardiovascular damage,  such as shortness of breath and
increased blood pressure.

Arsenic **x
Arsenic is a metallic-like substance that is processed to a white powder. Its toxicity depends on its form,
with inorganic arsenic being more toxic than organic arsenic. Arsenic and selenium are antagonistic toxins;
exposure to one reduces the adverse effects  of the other. The most dangerous effects are lung cancer from

inhalation and skin cancer from ingestion. Poisoning can result from chronic, low-level exposures. Acute
arsenic poisoning causes severe stomach damage and death.

Asbestos is a NY State regulated waste  (EPA Toxic Substances Control Act/ Clean Air Act NESHAPS
[National Emission Standards for Hazardous Air Pollutants]). Asbestos is a broad term applied to a group
of naturally occurring fibrous compounds. The fibers are small, odorless and can be suspended in the air to
travel long distances. The main route of exposure is inhalation and can cause lung and bowel cancer as well
as non-cancerous lung diseases.

Barium Carbonate x
Barium is a silvery-white, shiny metal that burns in the air and reacts violently with water. Due to its high
reactivity, it is often found as a compound. If barium is absorbed it can cause strong and prolonged muscle
contractions, including  the digestive tract and the heart. Barium chloride is the most toxic of the barium

Benzene +x
Benzene is a clear, highly volatile, colorless liquid that is widely distributed in air and water. Dangerous
chemical reactions result when it is mixed with oxidizing agents  such as chlorine, liquid oxygen and
sodium peroxide. Exposure can lead to respiratory tract irritation, dermatitis and eye irritation. If benzene is
aspirated into  the lungs it can cause the lungs to hemorrhage. Acute exposure through ingestion or
inhalation depresses the nervous system and can cause death. EPA classifies benzene as a known human

Cadmium+ **x
Cadmium is a  soft,  silvery metal that maintains  its luster when exposed  to the environment. At high
concentrations, inhaled  cadmium is associated with lung cancer. Chronic exposure to low-levels can lead to
severe lung, heart, kidney and liver disease as well as skeletal weakening. Ingestion of food heavily
contaminated with cadmium causes vomiting, diarrhea and occasionally shock.

Carbon Black
Carbon black is a powder that is nearly pure carbon, most often used in newspaper ink. There are no health
hazards involved with inhaling or ingesting small amounts  of  carbon black. However, simultaneous
exposure to aromatic hydrocarbons can lead to health problems. Studies have shown it causes cancer in

Carbon Tetrachloride x
Carbon tetrachloride is a clear,  colorless liquid with a sweet smell. It was removed from the  consumer
market once information about  its toxicity was known. However, it is still present  in industry. Adverse
effects are seen through inhalation, ingestion or skin contact with the  liver, kidneys and lungs most affected
by overexposure. Inhalation of high doses can be fatal.  Liquid carbon tetrachloride splashed in the eye
causes painful but minimal damage.  EPA  considers carbon tetrachloride a probable human carcinogen.
Although not yet proven, it is widely believed that pregnant women exposed to carbon tetrachloride vapors
may risk damage to the  fetus.

Chlorine x
Chlorine is greenish-yellow gas with a pungent smell. It is very reactive, combining with most elements to
form compounds. In high concentrations, chlorine is a strong irritant to mucous membranes in the eyes,
nose,  throat and lungs.  It can cause coughing, headaches and dizziness. Severe  exposure  can be fatal by
causing the airways to close.  Chlorine solutions may be alkaline corrosive.

Chloroform is a liquid solvent that smells and tastes sweet. It is not volatile and evaporates quickly. At very
high doses, chloroform is a narcotic. Chronic exposure to high but not life-threatening levels can lead to
fatigue, blurred  vision,  and liver and kidney damage.  EPA  considers chloroform a probable human

Chromium is a naturally occurring element in soil and volcanic dust. Exposure occurs from inhalation and
ingestion. In small amounts, chromium is believed to be essential for a proper diet. However, there  are
various types of chromium and some are known carcinogens.

Cobalt is a shiny, gray metal that occurs in nature. Everyone  is exposed to cobalt at low levels in the  air,
water and food.  It is  not unhealthy in these small amounts,  but high level exposure can cause  asthma,
pneumonia and vomiting. Cobalt has been shown to cause cancer in animals.

Creosote x
Creosote is a flammable, heavy, liquid with a sharp smell. Direct skin contact and exposure to vapors can
cause burning, itching, discoloration and ulcers. Acute exposure can cause headaches, vomiting, respiratory
difficulties and even death. EPA considers creosote a probable  human carcinogen.

Cyanide x
Cyanide is often found as a compound and in vapor form, especially with hydrogen. It is toxic by inhalation
and  ingestion. Acute high-level  exposure causes depression  of the central nervous, respiratory and
cardiovascular systems. Brief low-level exposure will cause changes in breathing and convulsions. People
who are chronically exposed to cyanide can suffer deafness,  vision loss and muscle damage.

Ethylene Glycol - NY State Regulated
Also known as  ethylene alcohol,  ethylene glycol is a clear, colorless liquid with a sweet taste. At room
temperature, ethylene  glycol is not a serious health threat, but when heated it produces harmful vapors. It
causes no significant skin  irritation but is extremely dangerous  when swallowed. If the exposure is large
enough, through inhalation or ingestion, convulsions and coma will occur.

Formaldehyde x
Formaldehyde is a colorless gas that has  a pungent odor. It is a strong eye and respiratory track irritant.
Acute  exposure  to formaldehyde vapors  can cause abdominal pain, depression of the  nervous  system,
convulsions and coma. The EPA considers formaldehyde a probable human carcinogen.

Hydrofluoric Acid x
Fluoride  is a highly reactive, yellowish green gas. Hydrofluoric acid causes  severe burns on contact, and
will penetrate the skin to attack underlying bone calcium. It also may cause severe respiratory damage if
inhaled and eye irritation.

Hydroquinone x
Hydroquinone is a white, crystalline phenol. Ingestion can lead to ringing in the ears, nausea, dizziness,
difficulty breathing and  other ailments. A large dose is lethal.  Repeated skin contact with hydroquinone
causes dermatitis. Chronic exposure can lead to discoloration of the eyelids and iris. It has been found to
cause bladder cancer in animals. It is widely used in some photo processing chemicals.

Lead is a soft, grayish metal that  is transported mainly through the atmosphere. Lead affects the  nervous
system, kidneys, reproductive system, and production of blood cells. Blood and the nervous system are the
most often affected from exposure. Children and pregnant women have the greatest risk for lead poisoning.

Lithium x
Lithium is a soft, silvery-white metal that turns yellow when exposed to the air or moisture. It is flammable
and can cause violent combustions. Lithium is toxic by inhalation and ingestion causing  damage to the
respiratory and gastrointestinal tracks. It is also corrosive to the eyes and skin.

Manganese is an odorless, silvery, hard metal that when in  dust or powder form is highly flammable. It is
commonly found as a compound. Manganese causes irritation to the eyes, nose, throat and respiratory tract
if inhaled for a short  term.  Chronic exposure can cause damage to the central nervous system  with
symptoms similar to Parkinson's disease.

Mercury is a heavy, silvery-white metal. It is the only metal that is  in liquid form at room temperature.
Inhaled mercury vapor causes damage to the nervous system, memory  loss and emotional instability.
Liquid mercury also affects the nervous system, especially in developing fetuses.

Methanol x
Methanol  is a colorless liquid that explodes when exposed  to an open flame. It is toxic by inhalation and
skin absorption and can cause headaches, sleep disorders and optic nerve damage. If ingested, methanol can
cause damage to the central nervous system.

Methylene Chloride (synonym: Dichloromethane) x
Methylene chloride is a colorless, volatile liquid that decomposes into carbon monoxide in the body. Once
inhaled, it is readily absorbed inside the lungs where it is distributed throughout the body and crosses the
blood-brain barrier. Absorption through ingestion and skin contact is much slower but can cause skin burns.
Acute  exposure can cause fatigue, nausea, and  liver and  nervous system damage.  The EPA  classifies
methylene chloride as a probable human carcinogen.

Mica is an odorless, often transparent solid. There are no health hazards associated with acute, short-term
exposure. However, chronic exposure can cause lung irritation and scaring.

N-hexane x
N-hexane  is a flammable, colorless liquid with a mild gasoline-like odor. Inhalation of n-hexane can cause
mild central nervous system damage and skin and mucous membrane irritation. Chronic exposure can lead
to muscle weakness, blurred vision and headaches.

Nickel is a hard, silvery metal. Some people are allergic to nickel and symptoms will occur through skin
contact. Inhalation  of nickel can also be harmful.

Nitric Acid  x
Nitric acid is corrosive and poisonous. In vapor form it a strong irritant to the mucous membranes of the
eyes and the respiratory tract. It is also a skin irritant causing burns. It may be fatal if inhaled, swallowed or
even absorbed through the skin.

Pentachlorophenol  is a colorless crystal that is extremely toxic by ingestion causing circulatory  and heart
failure which  can  cause death. Chronic exposure leads to  damage of the  respiratory tract, liver, blood,
kidneys, eyes, nose and skin. EPA considers pentachlorophenol as a probable human carcinogen.

Phenol x
Phenol is a toxic chemical by all routes of exposure including dermal exposure. It is highly corrosive to the
skin and a strong irritant to the eyes, nose, throat and tissue.

Selenium* *x
Selenium is a metalloid that is required in small amounts for human health, but in large quantities it can be
toxic. Selenium has anticancer properties and can also reduce the toxicity of cadmium and mercury.  After
a few hours exposure it can cause nausea, vomiting and diarrhea; acute poisoning of selenium is rare.

Silicon dioxide is one of the most common materials found in the earth's crust. It accounts for roughly sixty
percent of the elements in clay. Through inhalation, it causes silicosis, a chronic, disabling disease of the
lungs. It can also cause lung cancer.

Styrene x
Styrene is a colorless, oily liquid with a sweet odor. It is readily absorbed  through all routes of exposure
and tends to store in fatty tissues. Acute exposure causes eye and mucous membrane irritation, dizziness,
and even death due to respiratory system paralysis.

Sulfuric Acid x
Sulfuric acid is an oily liquid that irritates and burns the skin. Upon contact with the  eyes  it can cause
blindness. Inhaling sulfuric acid will irritate the lungs and, if the exposure is  especially high, cause liquid to
build up in the lungs. Chronic exposure can lead to bronchitis, emphysema and erosion of the teeth.

Toluene x
Toluene is  flammable and may cause irritation of the skin, respiratory tract and eyes.  It is also toxic by

Trichlorethylene x
Trichlorethylene is a colorless, volatile, nonflammable liquid with a sweet odor. It is easily absorbed when
inhaled and once it is  in the bloodstream it is distributed  throughout the  body concentrating in the  fat,
kidneys, lungs and brain. It is a narcotic at high doses and produces headaches, dizziness and fatigue after
inhalation. At extremely high concentrations, it can cause death. It is easily transferable to the fetus.

Turpentine is a colorless  liquid with a strong odor. On contact it irritates the eyes. If turpentine is inhaled,
coughing and wheezing will result. Chronic exposure to turpentine causes skin allergies and lung irritation.

Xylene x
Xylene is a flammable  solvent. If inhaled it may cause headaches and nose  and throat irritation. It is toxic
by ingestion and can cause central nervous system depression. Contact can cause skin and eye irritation.

Zinc is a soft, bluish-white metal that combines with other metals to form alloys. Although it is required for
human health at  certain  levels,  over consumption may impair heart  function. When heated, zinc oxide
fumes are created that if inhaled can lead to metal fume fever.

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                                     APPENDIX D


Note: This list is provided to assistjou in locating vendors who carry art materials that are marketed as less toxic and,
therefore, more "environmentally-friendly." The list is not exhaustive  and does not mean  that other products are less
preferable. There are many companies that simply choose not to label products as non-toxic for a variety of reasons.

Daniel Smith
P.O. Box 84268
Seattle, WA 98124-5568
Tel (800) 426-6740
Fax (206) 224-0404

Daniel  Smith  offers non-toxic paints, primers and  other art supplies with an AP rating that have
passed certified toxicity tests.  Their website has product information
relating to general information (paints, colors, etc), with very little emphasis on toxicity.
 More specific product information relating to toxicity can be found in their catalog.
Orders  can be placed on-line or by calling 1-800-426-7923.

Kremer Pigments Inc.
228 Elizabeth Street
New York NY 10012
Tel: 1-800-995-5501 or (212) 219 2394
Fax: (212) 219 2395

Kremer Pigments offers raw art supplies and  products  that  require mixing by a trained professional,
this line of product is not intended generally for school  use.  Further information can be found at the
web-site Orders can be  placed using the  order form on the web

910 Main Street, Buffalo, NY 14202
(716) 884-8900 x637
(716) 884-3943
art@hyatts .com
The only non-toxic line of paints and primers  that Hyatt's carries is Temptrapaint (poster paint).
Product Questions & Orders:
Customer Service Department: USA & Canada Toll-Free: Phone 1-800-234-9288 ext 301

Liquitex offers a student line of relatively non-toxic paints and art supplies intended for educational
Robert Anderson (888 4ACRYLIC X 7725) is the technical information specialist at Liquitex. He is a
good resource for information  on the toxicity of the paints and art supplies in The Basics Student
line, and other Liquitex products.
Liquitex makes a companion paint for metals that is metal free. For example, a "cobalt blue hue"
color is identical to the cobalt blue color as found with the metal cobalt blue. The "hue" on the end
of the name indicates  that it is metal  free and non-toxic. This type  of nomenclature is common
throughout the Liquitex Basics Student Line for paints that have metals associated with them.
A list of retailers of Liquitex (including the Basics Student, Basics Matt Student, and Glossies Enamel
Color lines)  in New York is listed  below. To find other retailers in New York or in other parts of the
county, visit their site:
List of Retailers in New York that Sell Liquitex Products
Ai Friedman
44 West 18th Street
New York, NY 10011
Art Station
307 7th Ave
New York, NY 10001
Arthur Brown
2 West 46th Street
New York, NY 10036
Blaker & Kooby
1204 Madison Ave 88th Street
New York, NY 10028
Columbia Omni Corp
14 West 33rd Street
New York, NY 10001
Empire Artist Materials
851 Lexington Avenue
New York, NY 10021
Exec. Accessories DBA Arts & Letter
21 West 38th Street
New York, NY 10017
Irving Berlin
14 East 37th Street
New York, NY 100 16
Janoffs Type & Stationery
2870 Broadway/ 11 1st
New York, NY 10025
Joseph Fischl
1397 3rd Ave
New York, NY 10021
Lee's Art Shop
220 West 57th Street
New York, NY 100 19
New York Central Supply
62 Third Avenue @llth Street
New York, NY 10003
New York Central Supply -
130 East 12th Street
New York, NY 10003
Pearl @ School of Visual Arts
207 East 23rd Street
New York, NY 100 10
Pearl Paint
308 Canal Street
New York, NY 10013
Plaza Artist Materials
173 Madison Avenue
New York, NY 10016
Sam Flax Corp
425 Park Ave At 55th Street
New York, NY 10011
Sam Flax Corp
12 West 20th Street
New York, NY 10022
The Art Store
1 - 5 Bond Street
New York, NY 10012


Golden Artist Colors, Inc.
188 Bell Road
New Berlin, NY 13411-9527 USA
Fax: 607-847-6767
www. Goldenpaints. Com

Golden Artist Colors, Inc. offers a line of heavy body paints and glazes that they sell for educational
purposes. There are MSDS's available for all the colors upon request.
You can order  a catalogue packet complete with complete information on their products. On-line
pricing and ordering is not available through the website; pricing and ordering information can only
be obtained through the catalog.

Gamblin Artists Colors Co.
P. O. Box 625
Portland, OR 97207 USA
Telephone: 503.235.1945
Fax: 503.235.1946

Gamblin Artist Colors primarily sells  oil-based paints for fine arts  and oil painting mediums.
Gamblin sells artist grade oils, varnishes, solvents, art sketching oils, and etching inks targeted more
for the  professional  artist than  for educational purposes.  A list of stores that the sell  Gamblin
products is available via the internet:

Dick Blick Art Materials
P.O. Box 1267
Galesburg, IL 61402-1267
Phone (800) 828-4548
Fax (800) 621-8293
Customer Service (800) 723-2787
Product Info (800) 933-2542
International (309) 343-6181

Dick Blick offers a line of art supplies called Grumbacher Academy Acrylics that is ideal for the art
student, offering near professional quality at a uniform and affordable price.
All 24 colors  are certified AP Non-Toxic by the Art and Creative  Materials Institute.

Dick Blick stores are located in Connecticut, Georgia, Illinois, Indiana, Iowa, Michigan, Minnesota,
Missouri, Nebraska, Nevada, Ohio, and Pennsylvania. There are no stores located in New York.  In
addition, Grumbacher Acrylic's can be ordered through the Dick Blick website (
Please see attached for pricing information.

Windsor and Newton
Windsor and Newton sells art supplies targeted for the professional artist, not typically intended for
educational use.
Binney and Smith
Corporate Headquarters
1100 Church Lane
Easton, Pennsylvania 18044-0431
Phone:  (610) 253-6271
Fax:    (610) 250-5768
Portfolio Series, one of Binney & Smith's newest brands, is designed to help future art professionals
(students and amateur artists)  who are developing their portfolios learn the basics of working with
different mediums.
Portfolio Series products offer high performance, color excellence, ease of use and safety and were
designed specifically with older students in mind. The line includes drawing and coloring pencils, oil
pastels and acrylic paints. Students and teachers appreciate this line  of high quality products from a
name that has been trusted for years: Crayolaฎ.  The Portfolio  Series can be ordered through the
Crayolaฎ products can also be purchased on this website at the above address as well.
Note that in more detailed information about the Portfolio Series, there in no  mention of non-toxic or AP Approval.

                                       APPENDIX E

                               INTERNET RESOURCES

Campus Safety Heath and Environmental Management Association (CSHEMA)
http: / 7www.cshema.ofg/
A website  dedicated to the CSHEMA vision  of "excellent  health, safety,  and environmental protection
understood and integrated into teaching, research, and service throughout higher education".

Cornells' "Greening of the Campuses" website contains links to Cornell's statement of the environment,
Sustainable Development  on  Campus,  Second  Nature,  Education  for  Sustainability,  National  Wildlife
Federation, Campus Ecology, EELink: Environmental Education on the Internet as well as the Environmental
Organization Web Directory, K-12 Education.

Environmental Organization Web Directory - Education
A large database on environmental information and  links, some of which are  specifically targeted towards
education at middle school, high school and college levels.

MIT - Environmental Virtual Campus
http: / /
MIT has developed an "Environmental Virtual Campus" ("EVC") to assist students, staff, and researchers with
campus environmental management  practices, including both regulatory compliance and non-regulatory
"green" environmental practices. The site is organized  around nine typical areas on a campus that are normally
subject to environmental regulations.

North American Association for Environmental Education (NAAEE)
http: / /
The North American  Association for Environmental Education (NAAEE) is  a network of professionals,
students, and volunteers working in the field of environmental education throughout North America and in
over 55 countries around  the world.  This website is dedicated to this mission and provides information for
interested citizens.

National Clearinghouse for Educational Facilities  (NCEF)
This website has NCEF's resource list of links, books, and journal articles on the design and planning of school
art facilities, including resources on funding and art supply safety issues.

Pacific Lutheran University Art and Architecture
A website by the Pacific Lutheran University,  this is a resource for all information relating to architecture,
artists, museums, photography, sculpture, schools and miscellaneous other art information.

Princeton University Environmental Health and Safety
http: / / /ehs /arts afety /
This training guide provides basic information for working safely with chemicals and operations in Visual Arts.
The guide is intended to supplement, but not replace, the safety orientation for faculty and students in Visual

University of Scranton - Greening Across the Chemistry Curriculum
http: / / /organic.html
Green chemistry has gained a strong foothold in the areas of research and development in both industry and
academia.  This website focuses on the history of green chemistry as well as the curriculum.

http: / /
A general informational website with links to other sites relating to HAZMAT Safety.

National Institute for Occupational Heath and Safety (NIOSH)
http: / / /chemical-safety/default.html
A comprehensive website containing  information  and  links to chemical information, specially relating to
NIOSH databases, Personal Protective Equipment, MSDS's, and links to other government agency regulations.

National Institute for Occupational Health and Safety (NIOSH)
All pertinent information and links to other sites regarding respirator use.

National Institute for Occupational Health and Safety (NIOSH)
http: / / /icstart.html
International Programme on Chemical Safety— Information on International Chemical Safety Cards (ICSCs).

National Paint and Coatings Association (NPCA)
http: / / /index.cfm
The NPCA Hazardous Materials  Identification  System (HMISฎ) is a result of a unique effort on the part of
health and safety managers in the chemical and coatings industries to combine their collective experiences to
design a practical, effective warning system that ensured "recognition at a glance"  of the hazards associated
with materials used every day in industry. The NPCA HMISฎ program, warnings, and training have been the
"Gold Standard" in the field. This website contains information about the NPCA.

National Resources Defense Counsel
This FAQ website addressed the topic of lead paint in schools.

NOAA - The Chemical Reactivity Worksheet
The Chemical Reactivity Worksheet is a free program you can use to find out about the reactivity of substances
or mixtures of substances (reactivity is the tendency  of substances  to undergo chemical change). This website
contains a database of reactivity information as well as a way for you to virtually "mix" chemicals.

U.S. Department of Energy
http: / /
A gateway to hundreds of websites and thousands of online documents  on energy efficiency and renewable

U.S. Department of Energy - Clean Cities
http: / / /vbg/
A "Vehicle Buyers Guide" with information relating to  energy efficiency and renewable energy in terms  of
alternative fuel vehicles.

U.S. Department of Energy - Energy Efficiency and Renewable Energy
http: / /
Rebuild America is a  growing network  of community-driven  voluntary partnerships that foster  energy
efficiency and renewable energy in commercial, government and public-housing buildings. At the federal level,
it is the largest, most established technology deployment program within DOE's Office of Energy Efficiency
and Renewable Energy (EERE). The program's goals are to: conserve energy, accelerate use of the  best energy
technologies, save money, reduce air pollution, lower U.S. reliance on energy imports, help revitalize aging city
and town neighborhoods, and create "smart energy" jobs. This informational website describes in detail the
Rebuild America program.

U.S. Department of Energy - Science Education Initiative
http: / /
Multiple links  targeted for kids,  adults, educators, researchers and consumers on such topics  as national
security, energy sources, energy efficiency, and the environment.

U.S. Department of Environmental Protection - NYC
http: / / /
The official DEP website for NYC.

U.S. Department of Homeland Security - Federal Emergency Management Agency
http: / /
Links to disaster communities, emergency personnel, education  and training, and news media are covered
under this website.

U.S. Department of Housing and Urban Development - Homes and Communities
http: / / /
Map your community using GIS with this website

U. S. Department of Labor - Occupational Safety and Health Administration (OSHA)
http: /
OSHA's mission is to  assure the safety and health of America's workers  by setting and enforcing standards;
providing training, outreach, and education; establishing partnerships; and encouraging continual improvement
in workplace safety and health. This official  OSHA website contains all pertinent information about the

U.S. Department of Labor - Occupational Safety and Health Administration - Hazard
Communication documentPp table=STANDARDS&p id=10099&p text
The purpose of this website is to ensure the hazards of all chemicals produced or imported are evaluated, and
that  information concerning their hazards is transmitted to employers and employees. This transmittal  of
information  is  to be accomplished by means of comprehensive hazard communication programs, which are  to
include container labeling and other forms of warning, material safety data sheets and employee training.

U.S. EPA - Colleges and Universities
http: / / s /colleges /

U.S. EPA - Compliance and Enforcement
http: / /
A resource in compliance assistance, compliance incentives and auditing, and compliance monitoring for the
environment. Working in partnership with state governments, tribal governments  and other federal agencies,
EPA ensures compliance with the nation's environmental laws. There are a series of links associated with this
site that contain other important environmental information relating to compliance issues.

U.S. EPA - Design for the Environment (DfE)
This publication presents the methods and  resources needed to conduct a Cleaner  Technologies Substitutes
Assessment (CTSA), a methodology for evaluating the comparative risk, performance, cost, and resource
conservation of alternatives to chemicals currently used by specific industry sectors.  The CTSA methodology
was  developed  by the U.S.  Environmental Protection Agency  (EPA) Design for  the  Environment (DfE)
Program, the University of Tennessee Center for Clean Products and Clean Technologies, and other partners
in voluntary, cooperative, industry-specific pilot projects.

U.S. EPA and colleges  and  universities  work together to  achieve sector-wide environmental gains through
innovative actions. The Sector Strategies  point-of-contact is working with six Colleges  and Universities sector
Partners to  develop  sector-specific  approaches  to assist  colleges  and universities in advancing the use of
environmental management  systems, reduce  regulatory performance barriers, and measure environmental

U.S. EPA - EnviroFacts query |ava.html
This website contains information on  the Resource Conservation  and Recovery Act.  The Hazardous Waste
Query  Form allows you to retrieve  selected data  from the  Resource Conservation  and Recovery  Act
Information (RCRAInfo) database in Envirofacts. Specify a facility using any combination of facility name,
geographic location, and standard industrial classification.

U.S. EPA - EnviroSense
Enviro$en$e, part of the U.S. EPA's  website, provides a single repository for pollution prevention, compliance
assurance, and enforcement information  and databases. This search engine searches  multiple websites (inside
and outside the EPA), and offers assistance in preparing a search.

U.S. EPA - Global Warming Site
http: / /
Information on climate, emissions, impacts, actions, news and events, where you live as well as a series of other
useful links to  global warming for  concerned citizens and educators as well as for small businesses  and

U.S. EPA - Healthy School Environments
The Healthy School Environments Web  pages are intended to serve  as a gateway  to online resources  to help
facility managers, school administrators, architects, design engineers, school nurses, parents, teachers and staff
address environmental health issues in schools.

U.S. EPA - Information Sources
A large database of environmental information and links relating to hot lines and clearinghouses.

U.S. EPA - Laws and Regulations
A website with more than a dozen major statutes or laws that form the legal basis for the programs of the
Environmental Protection Agency.

U.S. EPA Memorandum - RCRA Policy Statement:  Clarification of the Land Disposal Restrictions'
Dilution Prohibition and Combustion of Inorganic Metal-Bearing Hazardous Wastes
This memorandum  sets out a Statement of Policy under the Resource Conservation and  Recovery Act
clarifying the application of the Land Disposal Restrictions (LDR) prohibition on dilution to combustion of
certain inorganic metal-bearing hazardous wastes.

U.S. EPA - Pollution Prevention
http: / /
This website provides  general information about  Pollution  Prevention  practices, describes the array  of
Pollution Prevention programs and initiatives administered by EPA and other organizations, and provides
contacts for further information.

U.S. EPA - RCRA Online
Topic search for RCRA Information.

U.S. EPA - RCRA, Superfund and EPCRA Call Center
The RCRA, Superfund  and EPCRA  Call Center is a publicly accessible service that provides  up-to-date
information  on several Environmental Protection Agency (EPA) programs. The Call Center responds  to
factual questions on  federal EPA regulations.

U.S. EPA - Wastes
This booklet will help you determine if you are subject to the requirements under the Resource Conservation
and Recovery Act (RCRA) for notifying authorized state agencies or EPA of your regulated waste activities.

U.S. EPA - Waste and Recycling
Provides information on how to reduce waste, where it goes, how waste affects the environment, and the laws
that regulate waste and its cleanup.

U.S. EPA — Waste Minimization
http: / / /
The National Waste Minimization  Program supports efforts that promote a more sustainable society, reduce
the amounts of waste generated, and lower the toxicity and persistence of those wastes that are, of necessity,
generated. This website contains information about this program.


Artist's Materials
http: / / /materials.htm
Primarily information from the book entitled Art Hardware by Steven Saitzyk, pertaining to artist's materials.

Binney & Smith
http: / / /
Portfolio Series, one of Binney & Smith's newest brands, is designed to help future art professionals who are
developing their portfolios learn the basics of working with different mediums. The website contains more
information on the Portfolio Series as well as links to ordering information.

Crayola  markers.cfm
A supplier of Crayola art and paint supplies. Also contains links  for arts and crafts ideas, lesson plans  and
coloring ideas targeted for educational purposes.

Daniel Smith
http: / /
A supplier of paint and art supplies for adults and children.  Contains links to hobbies and arts and crafts ideas
as well. Products can be ordered online or through the catalog.

Gamblin Artist Colors
A supplier of paint and art supplies for the professional artist.

Genesis Artists Colors
http: / /www. / Genesis / artis tcolors .htm
A line of odorless and non-toxic paint and art supplies for educational purposes.

Golden Artist Colors, Inc.
Golden Artist Colors, Inc. offers a line  of heavy body paints and glazes that they sell for educational purposes,
however, not all the supplies are non-toxic.  There are MSDS's available for all the colors upon request.  On
the website, there is product information and supplies can  be ordered online.

Grumbacher Academy Acrylics
info (
Grumbacher Academy Acrylics are available through the Dick Blick Art  Materials website.  Grumbacher's  line
is  ideal for the art student, offering near professional quality at a uniform and  affordable price. All 24 colors
are certified AP non-toxic by the Art and Creative Materials Institute.

art(g),hyatts .com
A manufacturer of paint and art supplies.  The only line of paints and primers that  Hyatt's carries that is non-
toxic is Temtrapaint (poster paint), but there are other lines of products that Hyatt produces that are targeted
for the intermediate artist.

Kremer Pigments
A manufacturer of art and paint supplies in New York.  Mineral and organic pigments ordering information
online or through the catalog.

Liquitex offers BASIC, a student line of paints and art supplies  that are non-toxic and intended for educational
use. The website offers  more in-depth  information about this product line and contains ordering information
as well. There are a number of stores located within the New York area (see Appendix D).

http: / / 7manufactufefs.htm
An alphabetical listing of links to manufacturers of artist and framing materials.

National Association of Printing Ink Manufacturers
http: / /
This website provides information on pigment and ink suppliers with membership information and scheduled

New Pig - Absorbents for Oil Spill Cleanup  re
New Pig Corporation manufactures the world's largest selection of industrial absorbents for oil spill cleanup:
absorbent  pads and mats, also known as sorbents, plus socks, oil booms, pillows, pans, wipes, and spill kits. In
addition to sorbents for cleaning up oil spills and leaks, they also offer a huge selection of innovative products
and industrial supplies.  This website contains  ordering information as well as general information on these

Pigments Through the Ages
An informational webpage about paintings (oil paint and linseed oil, how to make your own oil paint, types of
oil paint, consistence of oil paint, etc.).

Sherwin-Williams Company
A manufacturer of paints and art supplies.

Windsor and Newton
Windsor and Newton sells art supplies targeted for the professional artist, not typically intended for educational

Environmental Advocates of New York
Environmental Advocates of New York is the voice of New York State's environmental community, devoted
to the protection of the  state's wildlife,  land  and people.  This  official  informational website provides all
information about this program.

New York City Department of Cultural Affairs main.shtml
Headquartered in a spacious warehouse in Long Island City, MFTA collects reusable items from a host of
reliable donors, and  distributes  them free of charge to non-profit arts organizations, city agencies, public
schools, and social, health  and community service organizations that have arts programs in New York City.

New York City Department of Environmental Protection
This website is an educational resource for students and teachers on protecting the environment in the New
York City area.  There are links to guided field trips, and environmental resources. DEP has developed a wide
variety of materials to encourage and stimulate environmental education that are included on the website.

New York City Fire Department legal/rcny final.shtml
Contains a comprehensive listing of the Title 3 rules of New York City for FDNY.

New York City Major's Office of Environmental Coordination
City Environmental Quality Review,  or CEQR, is a process by which agencies and other instrumentalities of
the New York City review proposed discretionary actions  for  the purpose of identifying the effects those
actions may have on the environment. This website provides information on this effort for the interested

New York Love Business - Pollution Prevention and Recycling  Energy and Environment/Environmental Assistance/pollution p
A list of main services that are offered relating to pollution prevention and recycling.

New York State Art Teachers Association
http: / /
The New York State Art Teachers Association (NYSATA) is a non-profit professional organization founded in
1948 for the purpose of advancing the cause of art education. This website is dedicated to this organization and
provides  relevant information for interested citizens.

New York State Department of Environmental Conservation
New York State's informational website on spill response and remediation; contains frequently asked questions.

New York State Department of Environmental Conservation - Dismantlers and Recyclers of Used
Contains a  list of contact information for dismantlers and recyclers of used electronics, compiled as a public
service on this website for the New York area.

New York State Department of Environmental Conservation - Fluorescent or HID Lamp Recyclers
A list  of fluorescent lamp  recyclers  that New  York  State Department of Environmental Conservation
(NYSDEC) maintains for the purpose of public education.

New York State Department of Environmental Conservation - Rules and Regulations
http: / / /website /regs /index.html
An online resource for the environmental rules and regulations in New York State with links  to  the Chapter
Index and the Regulations Index.

New York State Department of Labor  ny/employer responsibilities /safety/coderule.htm
A list of the regulations that come under the jurisdiction of the Division of Safety and Health.


Alliance to Save Energy
This website presents  information  about the Green  School Program - about using energy efficiency to
strengthen schools.  To help free up more resources for education while strengthening academic learning, the
Alliance's Green Schools Program engages students in  creating energy-saving activities in their schools, using
hands-on, real-world projects.

Building Green
This website contains such information as policy and content, land use and community, site and water, energy,
resources and materials,  and  environmental  indoor air  quality. Building Green received the 2004 Lewis
Mumford Award for the Environment.

A database and internet searching tool allowing the user to  research a specific chemical for information and
links on its biochemistry, heath effects, MSDS's, physical properties, regulations, structure, chemical exchange
and usage.

Electronics Exchange System
This site is a free buy/sell/trade listing system for  electronics, computer and telecommunication items, with
links to such items  as used computers and electronics, electronics  scrap recovery, phone recycling and used
telephones, as well as used TV, cable and video equipment.

Energy Star index
"Energy management is an important aspect of environmental management which will show healthy dividends
for your business. ENERGY STAR has the strategies to make you a leader and set your organization apart."

Environmental Yellow Pages America/Panama/7772b48a6b7b6464d53a35424c61a84b/
Search engine to links for environmental work/businesses/industries. Over 350,000 listings worldwide.

General Safety and Health Standards of Toxic Substances  code/300.html
A website containing comprehensive general and specific information relating to safety and health standards of
toxic and hazardous substances.

http: / /
GUILD, the leading source for original art and fine crafts, direct from the studios of artists nationwide. From
studio furniture to art glass vases, from ceramics and jewelry to prints and oil paintings, inspirations.

Health and Safety in the Arts
http: / / tucson. /arthazards /medium.html
Contains a searchable database of health and safety information for artists.

Health and Safety Introduction
This site contains an article by Monona Rossol, M.S., M.F.A., Industrial Hygienist, Health and Safety Business
Representative about health and safety in the workplace. There are a series of links to other health and safety
information at the end of the article that are informative as well.

HSIA - Solvent Applications
An informational website on solvent applications.

Joint Service Pollution Prevention Technical Library  Opportunity Handbook/alpha sec.html
Alphabetical listing of topics relating to pollution prevention.

Kodak Environmental Services
A search engine for MSDS's to provide guidance on chemical safe use and disposal.

Medical Dictionary - Definitions, Medical Terms, Disease, Treatment, Drugs and Pharmaceuticals
http: / /www.books .md/index.html
This medical dictionary provides detailed information including medical definitions, specific medical terms, and
descriptions of any disease and its treatment.  Also  included  is  information  on  drugs and pharmaceutical

MSDS Search 2004
A comprehensive website with links to all pertinent information on MSDS's.

National Center for Manufacturing Sciences - Solv DB
A large database of solvent information.

National Toner Recycling and Supply
http: / /
This website stocks products at a discounted price for thousands of different  machines  including but not
limited to: Epson, Apple, Brother, Canon, HP, IBM, NEC, Sharp and Xerox.

Recycler's World
http: / /
A list of recyclable objects and relevant information — a  trading site for  information related  to recyclable
commodities, by-products, used and surplus items.

Rohm and Haas Paint Quality Institute
http: / /
The  PQI Paint Resource Library has extensive information on paints  and painting to help in achieving success
in painting projects, solving paint-related problems, and answering your questions  about paints  and coatings.
An extensive glossary and information on the ingredients  of paint and impacts on paint performance are all
included in the comprehensive section.

http: / /
Answers questions about pollution control.  Topics include (Air, Water, Agriculture, Environmental Justice,
and Health Hazards).

http: / / chemical-pro files /other-web-
sites. tclPedf substance id=7439%2d92%2dl&edf chem name=LEAD
Other websites that offer searchable chemical databases, recommended by Scorecard.

Small Business Environmental Home Page
http: / /
A webpage dedicated to helping small businesses access environmental compliance and pollution prevention

This to That
A website with instructions for gluing various items to other items; provides recommendations for successful

Toxics Use Reduction Institute (TURI)
http: / /
The  Toxics  Use Reduction  Institute  (TURI)  provides  toxics  use  reduction resources for  industries,
communities and institutions to make Massachusetts a safer place to live and work. Website provides links for
reducing use, sector programs, calendar and information about TURI.

Waste to Energy Research and Technology (WTERT) Counsel
The WTERT Council is concerned with energy recovery from solid wastes, as well as all other means used in
the Integrated Management of Wastes, such as waste reduction and recovery of materials by recycling.  This
website contains pertinent information on the Waste to Energy Program.

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                                                                      APPENDIX F
                                         SAFE HANDLING, TREATMENT AND DISPOSAL
                                                                     Treatment and Disposal
                    Premixed clays are commercially available,
                    avoid creating dust; minimize hammering dry
                    clay; wet materials to clean up or vacuum with
                    HEPA vac.
                                                  When applying glazes, wear appropriate PPE,
                                                  apply in a spray booth if available, follow
                                                  manufacturer's recommendations for safe use
                                                  and handling.
                                                                                                  Disposal as
                             Not hazardous
                                                               Hazardous waste
                                                               determination must
                                                               be performed to
                                                               identify the
                                                               presence of
                                                               regulated chemical
    Treatment and Disposal
Place in normal trash in sealed
plastic bags to minimize dust
exposures. Clay is not listed as a
RCRA hazardous waste
                                                  Glazes containing toxic metal
                                                 pigments or flammable or toxic
                                                 organics require hazardous waste
                                                 treatment and disposal.
                 Pencils, Graphite,
                 Charcoal, and Chalks
                                                  Colorants and pigments containing toxic
                                                  heavy metals are hazardous by ingestion or
                                                  inhalation, avoid creating dust.
                                                               Hazardous waste
                                                               determination must
                                                               be performed to
                                                               identify the
                                                               presence of
                                                               regulated chemical
                                                 Obsolete or abandoned material
                                                 containing listed metals should be
                                                 managed as hazardous waste.
                                                  Colorants and pigments containing toxic
                                                  heavy metals are hazardous by ingestion or
                                                  inhalation, avoid creating dust. Water-based
                                                  drawing gums are available as a preferred
                                                  alternative to  solvent-based gums
                                                               Hazardous waste
                                                               determination must
                                                               be performed to
                                                               identify the
                                                               presence of
                                                               regulated chemical
                                                 Obsolete or abandoned material
                                                 containing listed metals should be
                                                 managed as hazardous waste.

                                                                         Treatment and Disposal
                  Pen and Ink
                  Spray Fixatives
                                                     Do not apply solvent based inks using spray
                                                     application techniques such as air brushing.
                                                     Use alcohol or water based markers instead of
                                                     those containing flammable and or toxic
                                                     When applying fixative or surface mount
                                                     adhesives, wear appropriate PPE, apply in a
                                                     spray booth if available, follow manufacturer's
                                                     recommendations for safe use and handling
                                                                                                      Disposal as
                                                                  Hazardous waste
                                                                  determination must
                                                                  be performed to
                                                                  identify the
                                                                  presence of
                                                                  regulated chemical
                                                                  Hazardous waste
                                                                  determination must
                                                                  be performed to
                                                                  identify the
                                                                  presence of
                                                                  regulated chemical
    Treatment and Disposal
                                                    Flammable and toxic organic
                                                    solvent-based inks are hazardous
                                                    waste materials when disposed.
                                                    Ensure aerosol spray cans are
                                                    completely empty. Spray cans with
                                                    residues are fire and explosive
                                                    hazards and are regulated waste
Textile -Dyes
                     Avoid creating dust, use dyes in liquid or paste
                  Mordant baths
                              Hazardous waste
                              determination must
                              be performed to
                              identify the
                              presence of
                              regulated chemical
If dye powders do not contain
listed hazardous constituents, place
in normal trash in sealed plastic
bags to minimize dust exposures.
                                                                                                  Spent or obsolete
                                                                                                  solutions having
                                                                                                  corrosive properties
                                                                                                  i.e., acidic (pH < 2)
                                                                                                  or alkaline (pH >
                                                                                                  12.5) are regulated.
                                                                                        Determine if your local sewer
                                                                                        authority accepts neutralized dye
                                                                                        solutions or spent baths at the
                                                                                        concentration levels to be
                                                                                        discharged. Concentrated corrosive
                                                                                        solutions and those with regulated
                                                                                        listed metals should be managed as
                                                                                        hazardous waste.
                                                                                                                    Chromium is
                                                                                                                    regulated as a
                                                                                                                    hazardous waste.
                                                                                                                        Baths or spent mordents
                                                                                                                        containing dichromates require
                                                                                                                        hazardous waste disposal.

Treatment and Disposal
Disposal as Treatment and Disposal
General Hazardous Recommendations/
Category Subcategory Examples Precautions Waste Comments



Conduct soldering operations with adequate
ventilation, switch to lead-free solders and non
cadmium fluxes.

Certain enamels may contain arsenic, barium,
cadmium, chromium, lead, nickel, or selenium.
Avoid creating dust or mist. If spraying, use a
spray booth. Follow manufacturer's
recommendations for safe use and handling.
Acid Pickle solutions are corrosive and
generate toxic fumes. Use appropriate PPE.
Obsolete lead-
containing solder
wire, cadmium and
silver wire/fluxes
are regulated.
Hazardous waste
determination must
be performed to
identify the
presence of
regulated chemical
Collect solder dross, silver for
metal salvage /recycling.

Enamels containing toxic metal
pigments or flammable or toxic
organics require hazardous waste
treatment and disposal.


                                                                         Treatment and Disposal
Metal Shop
                  Acid Etching/
                  Photo Etching)
                                                     Wear appropriate PPE, i.e., gloves, goggles,
                                                     protective apron; and NIOSH approved
                                                     respiratory protection for acid gas and mist.
                                                                                                      Disposal as
                                                                   Hazardous waste
                                                                   determination must
                                                                   be performed to
                                                                   identify the
                                                                   presence of
                                                                   regulated chemical
                                                                   Spent or obsolete
                                                                   solutions having
                                                                   corrosive properties
                                                                   i.e., acidic (pH < 2)
                                                                   or alkaline (pH >
                                                                   12.5) are regulated
Treatment and Disposal
                                                    Recycled metals exemption exists
                                                    for material that would otherwise
                                                    be hazardous waste due to the
                                                    presence of listed metals, i.e., lead,
                                                    cadmium, chromium.
                                                    1. Metals not collected for salvage
                                                    or reclamation may be considered
                                                    hazardous waste if they FAIL
                                                    TCLP analysis for metal
                                                    2. Beryllium powder is an acutely
                                                    hazardous waste.
                                                    3. Metallic Mercury is a hazardous
                                                    4. Scrap solders/welding rods
                                                    containing lead, cadmium or silver
                                                    are considered hazardous waste
                                                    unless recycled or reclaimed.
                                                    5. Non RCRA ferrous and non
                                                    ferrous metals  and alloys may be
                                                    placed in the trash, or recycled
                                                    through a conventional metal
                                                    recycling program, e.g., municipal
                                                    collector (unless they are coated
                                                    with hazardous [lead containing]
                                                    paints, in which case they must be
                                                    managed as hazardous waste).
                                                    Determine if your local sewer
                                                    authority accepts neutralized dye
                                                    solutions or spent baths at the
                                                    concentration levels to be
                                                    discharged. Concentrated corrosive
                                                    solutions and those with regulated
                                                    listed metals should be managed as
                                                    hazardous waste.

                                                                         Treatment and Disposal
                                                     Avoid solvent degreasing, use safer alternative
                                                     mineral spirits and/or detergent solutions.
                                                     Properly dispose of older materials containing
                                                     antimony/ arsenic/cyanide/ or mercury.
                                                     Newer products are available that have low
                                                     toxicity or are non toxic. Use appropriate
                                                     PPE. Materials containing sulfates or sulfites
                                                     may produce toxic sulfide fumes; avoid adding
                                                     strong acids, and provide adequate local
                                                     exhaust. Follow manufacturer's
                                                     recommendations for safe use  and handling.
                                                     Pay close attention to chemical
                                                     incompatibilities. Avoid creating dust or mist
                                                     when using these materials.
                                                                                                       Disposal as
                                                                           Hazardous waste
                                                                           determination must
                                                                           be performed to
                                                                           identify the
                                                                           presence of
                                                                           regulated chemical
                          Treatment and Disposal
                                                                    1. Obsolete commercial chemical
                                                                    products containing Arsenic
                                                                    oxides, arsenic acid, phenyl
                                                                    mercuric acetate, strontium sulfide,
                                                                    and vanadium pentoxide are
                                                                    acutely hazardous wastes. 2.
                                                                    Calcium chromate, lead acetate,
                                                                    lead phosphate, selenious acid,
                                                                    selenium dioxide, and selenium
                                                                    sulfide are toxic hazardous wastes
                                                                    when not used for their intended
                                                                    purposes, e.g., unused product.
                                                                    3. Metallic compounds are
                                                                    hazardous waste if they can not
                                                                    pass the acid leaching tests
                                                                    specified by EPA for arsenic,
                                                                    barium, cadmium, chromium, lead,
                                                                    nickel, or selenium
Surface Coating
Enamels, Stains,
Water-based Coatings
Paints, varnishes, stains,
finishes, sealants
Follow manufacturer's recommendations for
safe use and handling. Provide adequate local
Hazardous waste
determination must
be performed to
identify the
presence of
regulated chemical
1. Uncured wet paints containing
lead, cadmium, chromate
pigments, or mercury preservatives
should be disposed of as
hazardous waste.
2. Other water-based paints and
coatings should be allowed to dry,
and then placed in the trash.
                                                     Some oil or solvent based coatings may
                                                     contain cadmium, chromium, lead, nickel or
                                                     selenium. Avoid creating dust or mist. If
                                                     spraying, use a spray booth. Follow
                                                     manufacturer's recommendations  for safe use
                                                     and handling.
                                                                           Hazardous waste
                                                                           determination must
                                                                           be performed to
                                                                           identify the
                                                                           presence of
                                                                           regulated chemical
                                                                    1. Solvent-based materials should
                                                                    be disposed of as hazardous waste.
                                                                    2. Stains containing wood
                                                                    preservatives such as arsenic or
                                                                    phenol derivatives may be
                                                                    hazardous waste.

                                                                         Treatment and Disposal
                  Acrylic Paints (Water-
                  Oil Paints
                                                Follow Manufacturer's recommendations for
                                                safe handling and use. Avoid creating dust or
                                                mist. If spraying, use a spray booth.
                                                                                                  Disposal as
                                                                   Hazardous waste
                                                                   determination must
                                                                   be performed to
                                                                   identify the
                                                                   presence of
                                                                   regulated chemical
    Treatment and Disposal
                                                    Uncured wet paints containing
                                                    lead, cadmium, chromate
                                                    pigments, or mercury preservatives
                                                    should be disposed of as
                                                    hazardous waste.
                                                    Other water-based paints and
                                                    coatings should be allowed to dry,
                                                    and then placed in the trash.
                                                                                                                    Oil based paints should be
                                                                                                                    managed as regulated waste
                  Aerosol Spray Paints
                                                Avoid creating dust or mist. If spraying, use a
                                                spray booth. Follow manufacturer's
                                                recommendations for safe use and handling.
                                                                                        Ensure aerosol spray cans are
                                                                                        totally used up until completely
                                                                                        emptied. Cans may then be placed
                                                                                        in the trash or sent off as
                                                                                        recyclable metal.
                                                                                        Spray cans with paint and
                                                                                        propellant residues are fire and
                                                                                        explosive hazards and are also
                                                                                        regulated waste Spraying any
                                                                                        unused material to empty
                                                                                        containers constitutes improper
                                                                                        and illegal disposal.
                  Paint Strippers
                  Removal/ Cleaning
                    Calcium hydroxide (slaked
                    lime), calcium oxide (lime),
                    lithium oxide, potassium
                    hydroxide (caustic potash),
                    potassium carbonate
                    (potash), sodium carbonate
                    (soda ash, washing soda),
                    sodium hydroxide (caustic
                    soda), sodium silicate,
                    trisodium phosphate.
                     Most paint strippers are corrosive and toxic.
                     Follow manufacturer's recommendations for
                     safe use, storage and handling.
                              Hazardous waste
                              determination must
                              be performed to
                              identify the
                              presence of
                              regulated chemical
Some formulations are extremely
corrosive due to concentrated
alkalis. They also may contain toxic
organic s such as methanol and
dichloromethane and are
considered hazardous. Test
coatings removed for the presence
of characteristic levels of lead or
other toxic metals to determine
proper disposal method.

                                                                         Treatment and Disposal
                  Oils n.o.s. as vehicle
                  for paint formulations
                  Solvents and thinners,
                  cleaners, degreasers.
                        Linseed oil, safflower oil,
                        tung oil
                        Turpentine, acetone,
                        mineral spirits, methyl ethyl
                        ketone, xylene, toluene,
                        glycol ethers
                             Oils and oil-soaked rags are combustible and
                             create the potential for spontaneous
                             Volatile organic s (flammable liquids) are
                             readily absorbed by the body from all routes
                             of exposure. Always use with adequate
                             ventilation. Keep all ignition sources away
                             from area. Keep containers tightly closed.
                                                                                                      Disposal as
                                              Hazardous waste
                                              determination must
                                              be performed to
                                              identify the
                                              presence of
                                              regulated chemical
                                              Hazardous waste
                                              determination must
                                              be performed to
                                              identify the
                                              presence of
                                              regulated chemical
                          Treatment and Disposal
                      Oil- or solvent-soaked rags may be
                      cleaned at commercial laundry
                      operations. The oil and organics
                      are reclaimed for reuse or energy
                      recovery and therefore are not
                      considered hazardous waste.
                      Oil-soaked rags (but not solvent-
                      soaked rags) may be hung up to
                      dry individually so that heat cannot
                      accumulate, and then reused.
                      Flammable and toxic organics are
                      regulated hazardous waste.
Obsolete and abandoned or
off specification
photochemical solutions,
powders, toners, fixers,
Purchase and use liquid solutions when
possible. When mixing dry powders, avoid
creating dust. Provide for adequate ventilation.
Wear an approved respirator and PPE. Ensure
safe chemical mixing and handling areas, i.e.,
have emergency eyewash and shower available.
Avoid direct skin contact with
photoprocessing solutions. If solution splashes
onto skin or in eyes, rinse immediately with
copious amounts of water;
Cover all baths when not in use; make sure
acid is always added to water when diluting; do
not add acid to, or heat, hypochlorite bleaches.
Keep potassium persulfate away from
flammable substances. Install ground fault
circuit interrupters in electrical outlets.
Hazardous waste
determination must
be performed to
identify the
presence of
regulated chemical
Neutralize working solutions and
rinse to drain if discharge is
managed in a CWA authorized
Publicly Owned Treatment system
and concentrations are at or below
acceptable sewer discharge limits.
Spent fixatives must be managed
to prevent the release of sulfide gas
and silver
Silver in concentrations greater
than 5 mg/L is  a regulated
hazardous waste and must be
treated to less than 5 mg/L by
silver  recovery or collected for off-
site reclamation/disposal.
Discharges of silver halide
wastewaters  are regulated by
municipal sewer authorities.

                                                          Treatment and Disposal
Disposal as Treatment and Disposal
General Hazardous Recommendations/
Category Subcategory Examples Precautions Waste Comments

Oxidizing Agents
Ink Pigments
Other pigments
Etching (Acids)
Screen Printing
Dichromates, chlorates,
chromates, hypochlorites,
nitric acid (concentrated),
periodates, permanganates,

Mineral spirits, toluene

Highly reactive materials; use with extreme
Use ready-made water based acrylics or non
toxic inks.
Use ferric chloride solutions rather than nitric
acid whenever possible. Refer to MSDS for
chemical incompatibilities. Wear appropriate
Purchase and use pre-sensitized plates;
provide for local exhaust ventilation; wear
appropriate PPE. Be aware of UV radiation
reflection, avoid carbon arcs, wear welding
Follow manufacturer's recommendations for
safe use, storage and handling. Consider the
use of water-based screen printing inks; Avoid
skin contact with solvents. Perform
airbrushing in spray booth.
Wear an approved dust mask. Avoid the
creation of dust; work with wetted materials
when possible; clean up dust by wet mopping
or vacuuming with a HEP A vac.
Spent or obsolete
solutions having
corrosive properties
i.e., acidic (pH < 2)
or alkaline (pH >
12.5) are regulated.
Hazardous waste
determination must
be performed to
identify the
presence of
regulated chemical
Spent or obsolete
solutions having
corrosive properties
i.e., acidic (pH < 2)
or alkaline (pH >
12.5) are regulated.
Flammable and
toxic organics are
regulated. These
include ether
acetate, xylene and
butyl cellosolve.
Flammable and
toxic organics are
Not hazardous
Collect obsolete product or
concentrated solutions and manage
as regulated waste.
Uncured wet screen printing inks
containing lead, cadmium,
chromate pigments or mercury
preservatives should be disposed
as hazardous waste.
Other water-based acrylics and
coatings should be allowed to dry,
and then placed in the trash.
Keep baths covered. Neutralize
working solutions and rinse to
drain if discharge is managed in a
CWA authorized Publicly Owned
Treatment system and
concentrations are at or below
acceptable sewer discharge limits.
Volatile and flammable liquids
must be kept in tightly closed
containers except when adding or
removing material.

Place in the trash, in sealed plastic

                                                                        Treatment and Disposal
                  Plastics/Plastic Resins
                  Organic Peroxides
                        Methyl ethyl ketone
                        peroxide, benzoyl peroxide
                                                    Volatile and reactive materials require local
                                                    exhaust. Highly reactive and flammable
                                                    materials. Some resins contain listed
                                                    carcinogens. Follow manufacturer's
                                                    recommendation for safe use and handling.
                     Organic peroxides can bum or explode if
                     heated. They become unstable over time and
                     can be extremely reactive. Rotate inventory
                     regularly and avoid storing beyond its shelf
                                                                                                     Disposal as
                                                                  Flammable and
                                                                  toxic organics are
                                                                  regulated. These
                                                                  include epoxy,
                                                                  phenol- or urea-
                                                                  polyester and
                              Flammable, toxic
                              and reactive
                              materials are
    Treatment and Disposal
                                                   Excess and obsolete resins should
                                                   be reacted with a compatible
                                                   catalyst to form a solid plastic,
                                                   which can then be placed in the
                                                   normal trash.
                                                   Plasticizers, resins and catalyst
                                                   should be disposed as hazardous
                                                   Solid plastics are not considered
                                                   hazardous waste.
Follow manufacturer's
recommendations for safe use,
storage and handling. Keep
minimal quantities on hand.
Consider eliminating use to avoid
Woo dworking
Ordinary wood or
wood waste
                  Wood that has been
                  treated with wood
                  preservatives such as
                  chromated copper
                  arsenate or other toxic
                  Glues and Cements
                                                                  Not hazardous
                                                   Can be recycled, burned as a fuel,
                                                   or placed in the trash.
                                                    Avoid inhaling dust, wear PPE when cutting
                                                    or sanding.
                                                                  Hazardous waste
                                                                  determination must
                                                                  be performed to
                                                                  identify the
                                                                  presence of
                                                                  regulated chemical
                                                   Do not burn these materials in a
                                                   fireplace, or woodstove.
                                                    Most solvent-based glues are flammable; keep
                                                    away from sparks, flames, or other ignition
                                                                  Flammable, toxic
                                                                  and reactive
                                                                  materials are
                                                   Dry water-based glues and
                                                   cements, and place in trash.
                                                   Small amounts of solvent-based
                                                   glues and cements must be
                                                   handled as hazardous waste.

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                    APPENDIX G


Department of Environmental
Division of Solid and Hazardous Materials
50 Wolf Road
Albany, NY 12233-7251
www. dec. s

Department of Environmental
Solid and Hazardous Waste Management Program
401 E. State Street, P.O. Box 414
Trenton, NJ 08625-0414
609-633-1418 /dep

Hazardous Waste Management Program Requirements Summary
Same as federal with the addition of PCB
wastes. Incorporates 40 CFR260 through
273 by reference* (6NYCRR 370. l(e)),
except as noted.
Same as federal with the addition of PCB
wastes (NYCRR 371.4 (e)).
Generators also subject to quarterly tax
assessment, NYS Dept. of Taxation &
Same as federal. Incorporates 40 CFR 260-266, 268
& 270 by reference* (NJAC 7.26G-Subchapters 4
through 12, respectively), except as noted.
Same as federal except Appendix to Part 262
Uniform Hazardous Waste Manifest & Instructions
for EPA form 8700-22 (NJAC 7.26 G-6.1(b) & (c))
only. Must use specified state instructions when
completing a manifest (NJAC7.26G-6.2(a)) and
facilities filing a biennial report (LQG'S) are subject
to a manifest processing fee program (NJAC7.26G-

The Hazardous Waste Generator categories, identification numbers and notification requirements for
New York and New Jersey are the same as the federal ones.

Allows generators (NYSDEC
Commissioner's MOU 5/8/06) of mercury
containing equipment to follow federal
Universal Waste Rules until state rules are
promulgated. (40 CFR 273 & NYCRR
374-3). Net result is the same list of
universal wastes as federal.
Universal waste handlers are subject to regulation
under (NJAC 7.26 A- 7). Adds oil-based finishes and
consumer electronics, including computers, in
addition to the federal list.

Waste Generation Limits
< 100 kg month
100 to 1,000 kg month
> 1,000 kg month

Accumulation Quantities and Time Limit Conditions for Exemption from Permitting
All Categories

Same as federal: with the exception that it
allows SQG's and LQG's to manage some
wastes from offsite CESQG's (6 NYCRR
Limits LIQUID hazardous waste storage to
8,800 gallons or less without a permit.
(6NYCRR 373-1. l(D)(l(iii)).
For facilities located in the following
• Kings
• Nassau
• Queens
• Suffolk
Or, over the Schenectady /Niskayuna
Aquifer system in the following counties:
• Schenectady
• Saratoga
• Albany
Or, over the Clinton St./Ball Park Valley
Aquifer system in the following counties:
• Broome
• Tioga
Regulations require secondary containment
if hazardous waste accumulated exceeds:
LQG — 185 gallons or any amount
in tanks;
SQG - 185 gallons liquid in
containers and/or tanks, or any
liquid in underground storage tanks
CESQG — storage in excess of
1000 kg
(6NYCRR 373-1. l(d)(l(iv))
LQG's in the geographic areas specifically
referenced above are advised to review
6NYCRR 373-1. l(d) in its entirety to
ascertain if additional requirements may be
Same as federal.


Waste Shipments
(6 NYCRR 372.2(b)(2 (iii)) Requires
generator to contact DEC.
SQG/LQG Required - (6 NYCRR-364)
CESQG' s may transport their waste under
specified conditions (<100kg./month).
(NJAC7.26G-6.3) Specific
procedures must be
SQG/LQG - Required (NJAC7.26G-6.1(c)(4)).
Regulatory Allowances for On Site Waste Minimization
Treatment in
Small Boilers
and Industrial
Exempts sanitary wastes/ industrial
wastewater treatment discharges.
See 6NYCRR 371.1 el.
Acid/ alkaline buffering.
See 6NYCRR 371.1 d 1 xii.
Lead batteries, scrap metals on site reuse
reclaim and recycle systems.
See 6NYCRR 373.1.1dl ix.
See 6NYCRR 374-1.8 i.
Incorporates by reference
found at 40 CFR 261.
See NJAC 7.26G-5.1.
Incorporates by reference
found at 40 CFR 270.
See NJAC 7.26G-12.1.
Incorporates by reference
found at 40 CFR 261.
See NJAC 7.26G-5.1.
federal requirements
federal requirements
federal requirements
Conforms with EPA interpretation.
Incorporates by reference
found at 40 CFR 266 with
See NJAC 7.26G-10.1.
federal requirements
specified changes.
* What is "incorporated by reference"?
Incorporation by reference allows state agencies to refer to documents already vetted and published elsewhere,
such  as  federal  regulations  or ASTM  standards, in lieu of writing duplicative language.   This  is often
accompanied  by additional  statements  citing applicable  differences from or additions  to the  referenced
requirements.  The legal effect of incorporation by reference is that the referenced material is treated like any
other state-issued rule, having the force and effect of law.  In the items cited above, the result is that the federal
regulations listed apply equally as state requirements, with further state requirements added for facilities within
that state.

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               APPENDIX H

Agency for Toxic Substances and Disease Registry
American Council of Governmental Industrial
American National Standards Institute
American Society for Testing and Materials
Clean Water Act
Code of Federal Regulations
Comprehensive Environmental Response,
Compensation and Liability Act (Superfund)
Comprehensive Environmental Response,
Compensation, and Liability Information System
Conditionally Exempt Small Quantity Generator
Department of Transportation
Emergency Planning and Community Right to Know
Environmental Protection Agency
Federal Emergency Management Agency
Federal Facility Agreement
Land Disposal Restriction
Large Quantity Generator
Local Emergency Planning Commission
Material Safety Data Sheet
Medium Density Fibreboard
National Ambient Air Quality Standards
National Emission Standards for Hazardous Air
National Institute for Occupational Safety and Health
National Pollutant Discharge Elimination System
New York City Department of Environmental
Occupational Safety and Health Administration
Parts Per Million
Permissible Exposure Limit

Personal Protective Equipment
Resource Conservation and Recovery Act
Safe Drinking Water Act
Small Quantity Generator
Standard Operating Procedures
State Emergency Planning Commission
Superfund Amendments and Reauthorization Act of
Threshold Limit Value
Toxic Substances Control Act
Toxicity Characteristic Leaching Procedure
U.S. Department of Transportation
U.S. Food and Drug Administration
CAS Registry Number
LDso and LCso (species and routes)
Flashpoint (ฐQ and Method
Flammable Limits in Air
This number is given to a chemical by the Chemical
Abstracts Service Division of the American Chemical
These are the concentrations of a chemical which is
expected to cause the death of 50 percent of an
animal test. LDso applies to a single dose of solids and
liquids, normally given in a mass of chemical to mass
of body ratio. LCso applies to gases and corresponds
to the concentration of the gas in the air that killed 50
percent of the population in the time indicated.
This is a numerical expression on a scale from 0 to 14
of the extent of acidity or alkalinity of a product:
This is the minimum temperature, under specified test
circumstances (closed-cup or open-cup), at which a
liquid product gives off enough vapor to ignite in the
presence of a source of ignition such as an open flame
or spark. For a given test method, the lower the
flashpoint, the more flammable the material.
These are the upper (maximum) and lower
(minimum) concentrations of a gas or vapor in air
between which an explosion or propagation of flame
will occur when an ignition source is present. The
Upper Flammable Limit (UFL) is sometimes known
as the Upper Explosive Limit (UEL) and the Lower
Flammable Limit (LFL) is sometimes known as the
Lower Explosive Limit (LEL).

Two substances are incompatible if, on combination,
they react dangerously and produce toxic or corrosive
by-products, excessive heat or explosion. Such
chemicals should be stored apart and handled so as to
minimize the likelihood of contact with each other.
Hazardous Decomposition Products
This is a listing of dangerous products that may be
released if the substance is exposed to aging, heating,
burning or other chemical reactions. An example
would be the formation of peroxides with the aging
of various ethers and unsaturated cyclic compounds.
Route of Entry
A chemical can enter the body by several routes:
Inhalation (breathing)
Contact with skin or eyes (localized irritation)
Absorption through the skin and eyes (systemic)
Injection with a needle or cuts from contaminated
Exposure Limits
These are the legislated or recommended limits of an
airborne substance to which a worker is allowed to be
exposed. These limits generally represent conditions
in which it is believed that nearly all workers may be
repeatedly exposed day after day without adverse
C, or Ceiling
The maximum allowable human exposure limit for an
airborne substance; not to be exceeded, even
momentarily. Also see "PEL" and "TLV."
The amount of a substance in a stated unit of a
mixture or solution. Example: 2 parts per million
hydrogen sulfide in air, or a 50 percent caustic
Effects of Overexposure
Clinical signs and symptoms that may occur or be
experienced when one has been overexposed to
concentrations of a particular substance above
established exposure limits.
Exposure Limit
Limit set to minimize occupational exposure to a
hazardous substance. Recommended occupational
exposure limits used are American Conference of
Governmental Industrial Hygienists (ACGIH)
Threshold Limit Values (TLVs). Mandatory limits are
the Occupational Safety and Health Administration
(OSHA) Permissible Exposure Limits (PELs).
Flash Point
The minimum temperature at which a liquid gives off
sufficient vapor to form, with air, an ignitable

A solid, liquid, or compressed gas that exhibits a
"characteristic of ignitability," as defined by the
Resource Conservation and Recovery Act (RCRA),
and may be regulated (by the Environmental
Protection Agency) as a hazardous waste.
Local Exhaust
A system for capturing and removing airborne
contaminants (gases, particulates) at the point at
which they are released. Not to be confused with
general exhaust.
Milligrams per cubic meter of air; a unit for measuring
concentrations of particulates in the air (a weight per
unit volume).
To render chemically neutral or harmless; neither acid
nor base; to counteract the activity or effect of. The
addition of a base (sodium hydroxide) to an acid
hydrochloric acid) results in water and a salt (sodium
chloride); thus the acid has been "neutralized" or
rendered harmless.
Permissible Exposure Limit: an exposure limit
established by OSHA's regulatory authority. May be a
time weighted average (TWA) limit or a ceiling
concentration exposure limit.
National Institute for Occupational Safety and
Health. Part of the Centers for Disease Control and
Prevention in the U.S. Department of Health and
Human Services (DHHS); a Federal agency which, in
addition to other activities, tests  and certifies
respiratory protective devices and air sampling
detector tubes, recommends occupational exposure
limits for various substances, and assists OSHA in
occupational safety and health investigations and
Parts per million: a unit for measuring the
concentration of a gas or vapor in contaminated air.
Also used to indicate the concentration of a particular
substance in a liquid or solid.
Protective Cream (Barrier Cream)
A protective skin cream provides an invisible flexible
protection for the hands from soils, solvents, dusts,
powders, oils, greases, paints, epoxies, resins, inks,
and irritants. It can be easily removed by washing with
any cleansing product.

Reactivity -
The tendency of a substance to undergo a chemical
change with the release of energy. Reactive chemicals
are liable to cause fire or promote an explosion.
Undesirable effects (pressure buildup, temperature
increase, formation of noxious, toxic, or corrosive by-
products) may occur because of a reaction to heating,
burning, direct contact with other materials, or other
conditions when in use or in storage.
Respiratory Protection
Devices for use in conditions exceeding the
permissible exposure limits, which, when properly
selected, maintained, operated, and worn by the user,
will protect the user's respiratory system from
exposure to airborne contaminants by inhalation.
Target Organ Effect -
Damage caused in a specific organ following exposure
to certain chemicals. For example, a "neurotoxin" is a
chemical, such as mercury, that product is its primary
toxic effect on the nervous system.
Threshold Limit Value: a term used by the American
Conference of Governmental Industrial Hygienists
(ACGIH) to express the airborne concentration of a
material to which nearly all persons can be exposed
day after day, for a normal 8-hour workday or 40-
hour work-week, without  adverse effects.
Toxicity -
Basic biological property of a material reflecting its
inherent capacity to produce injury; adverse effects
resulting from overexposure to a material, generally
via the mouth, skin, eyes, or respiratory tract.
Time Weighted Average exposure; the airborne
concentration of a material to which a person is
exposed, averaged over the total exposure time,
generally the total workday (8 to 12 hours). It is
calculated by multiplying measured concentration
levels times the duration of exposure (in hours),
adding these values together, then dividing by the
total sampled time (in hours). Also see "TLV" and
Upper Explosive Limit or Upper Flammable Limit -
The highest concentration of a flammable vapor or
gas in air (usually expressed in percent by volume)
above which propagation of a flame will not occur in
the presence of an ignition source. Also see "LEL."

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