Prepared for:
U.S. Environmental Protection Agency
Prepared by:
Pratt
Pratt Institute
Technical Assistance by:
ENSR Corporation
photography
5tal working
drawing
painting
ceramics
calligraphy
printing
OQ
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
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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.
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TABLE OF CONTENTS
FOREWORD AND ACKNOWLEDGEMENTS iv
SECTION 1.0 INTRODUCTION 1-1
1.1 Proper Waste Management and Disposal 1-1
1.2 Art Instructors' Obligations 1-1
1.3 Document Organization 1-2
SECTION 2.0 HAZARDOUS WASTE MANAGEMENT BASICS 2-1
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
SECTION 3.0 HAZARDOUS WASTE GENERATOR REQUIREMENTS/ ENSURING
TECHNICAL COMPLIANCE 3-1
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
SECTION 4.0 EXPANDING THE HEALTH AND SAFETY PROGRAM 4-1
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
SECTION 5.0 SOURCES OF POTENTIALLY HAZARDOUS WASTE IN ART STUDIOS 5-1
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
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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
SECTION 6.0 POLLUTION PREVENTION AND WASTE MINIMIZATION 6-1
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
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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
APPENDICES
A CHARACTERISTIC WASTES: D, AND LISTED HAZARDOUS WASTES: F, P,
ANDU
B BEST MANAGEMENT PRACTICES AND RECORD KEEPING CHECKLIST
FORMS
C POTENTIALLY REGULATED CHEMICALS
D LIST OF ART MATERIALS SUPPLIERS
E INTERNET RESOURCES
F SAFE HANDLING, TREATMENT AND DISPOSAL
G NEW YORK AND NEW JERSEY - REGULATORY DIFFERENCES SUMMARY
H LIST OF ACRONYMS AND DEFINITIONS OF KEY ENVIRONMENTAL
TERMS
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FOREWORD AND ACKNOWLEDGEMENTS
FOREWORD
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
Resources
"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
libraries.
"Safety isn't just one more thing. It's Everything!
General'Motors motto
ACKNOWLEDGEMENTS
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
IV
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SECTION 1.0
INTRODUCTION
<
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
Disposal
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
important.
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
include:
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;
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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
wastes.
1.3 Document Organization
The remainder of this document is organized
as follows:
Section 2.0 Hazardous Waste Management
Basics
Section 3.0 Hazardous Waste Generator
Requirements/ Ensuring Technical
Compliance
Section 4.0 Expanding the Health & Safety
Program
Section 5.0 Sources of Potentially Hazardous
Waste in Art Studios
Section 6.0 Pollution Prevention And Waste
Minimization
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.
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SECTION 2.0
HAZARDOUS WASTE MANAGEMENT BASICS
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
disposal;
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
environment.
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
disposal).
primary
ultimate
The
objective
program
ensure
hazardous
of this
is to
that
wastes
are handled in a
manner that
protects human
health and the
environment.
Consequently, the program deals with
hazardous waste generation and transportation,
as well as treatment, storage, and disposal.
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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
Waste
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;
and/or
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
F035);
Petroleum refinery wastewater treatment
sludges (F037 and F038); and
Multisource leachate (F039).
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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,
andF019).
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
criteria:
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
following:
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
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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.
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"
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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
characteristic.
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 nonregulated 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
include:
Hazardous waste batteries (e.g., rechargeable
nickel-cadmium, lithium);
Lead containing devices (e.g., cathode ray tubes,
lead acid batteries, printed circuit boards and
electronics);
Waste mercury-containing devices (e.g.,
thermometers, thermostats, barometers,
manometers, temperature and pressure gauges);
and
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
HAZARDOUS WASTE GENERATOR REQUIREMENTS/
ENSURING TECHNICAL COMPLIANCE
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
follows:
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
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wastes from the remote site in its generation
rate.
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
wastes.
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
landfill.
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
Labeling
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
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following are also recommended practices for
CESQGs:
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;
and,
Keeping containers that hold hazardous waste
closed, except when adding or removing
waste.
3.3.1 Storage Areas and Accumulation
Areas
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
waste;
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
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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
must:
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
personnel;
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
Prevention
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
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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
materials;
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
conditions.
Spill cleanup materials also need to be
disposed properly. If anything is
contaminated with hazardous waste, it needs
to be disposed using hazardous waste
procedures.
3.4.2 Emergency Response Incident
Command
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
stored:
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
department.
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
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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
reduced.
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
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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.
;zzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzz.
HAZARDOUS
WASTE
FEDERAL LAW PROHIBITS IMPROPER DISPOSAL.
IF FOUND. CONTACT THE NEAREST POLICE OR PUBLIC SAFETY
AUTHORITY OR THE U S ENVIRONMENTAL PROTECTION AGENCV
GENERATOR INFORMATION
NAME
EPA /MANIFEST
ID NO / DOCUMENT NO
ACCUMULATION
START DATE
EPA
_ WASTT NO
M
a
B
001 WOW* SHAPING NAME AND UN OR NA NO WITH PHffW I f
F* M
HANDLE WITH CARE!
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Sources:
Environmental Virtual Campus
Art Safety Training Guide, Princeton University,
http://web.princeton.edu/sites/ehs/artsafetv/index
.htm
Container Management/Transport, Campus
Consortium for Environmental Excellence,
http://www.c2e2.org/evc/LabConm.html
Darkrooms, Campus Consortium for
Environmental Excellence,
http://www.c2e2.org/evc/ArtDark.html
Hazardous Waste Requirements for Large
Quantity Generators, EPA530-F-96-032, June
1996
Health & Safety in the Arts, City of Tuscon,
http://www.ci.tucson.az.us/arthazards/home.html
Managing You Hazardous Waste: A Guide for
Small Businesses, EPA530-K-01-005, December
2001
New York State Department of Environmental
Conservation,
http://www.dec.state.ny.us/website/dshm/hzwst
man/hzwst.htm
3-7
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New Jersey Department of Environmental
Protection,
http://www.ni.gov/dep/enforcement/shwr.html
RCRA Orientation Manual, U.S. EPA530-R-02-
016, January 2003.
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SECTION 4.0
EXPANDING THE HEALTH AND SAFETY PROGRAM
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.
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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
below).
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
4-2
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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
requirements.)
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,
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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
exposure:
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.
NEVER-
have food or drinks (including coffee) in an
area where hazardous materials are being used;
store food in a refrigerator used for chemical
storage;
hold a paint brush or other tool in your mouth;
and
NEVER USE SOLVENTS TO CLEAN
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.
ALWAYS:
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,
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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
materials.
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
emissions.
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
oxides.
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
websites:
http://www.acgih.org/
http://www.cdc.gov/niosh/
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
chemical.
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.
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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,
carcinogens.
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
chemicals.
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
abrasion.
Stainless steel mesh protects against cuts and
lacerations.
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 -
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always wear approved safety eyewear with side
shields.
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
attention.
Ingestion
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
requirements:
Appendix A, Fit testing procedures (Mandatory)
Appendix B-l, User seal check procedures
(Mandatory)
Appendix B-2, Respiratory cleaning procedures
(Mandatory)
Appendix C, OSHA respirator medical
evaluation questionnaire (Mandatory)
Appendix D, Information for employees using
respirators when not required under standard
(Mandatory)
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SECTION 5.0
SOURCES OF POTENTIALLY HAZARDOUS WASTE IN ART
STUDIOS
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
disposal.
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
policy.
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
mouth.
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
contact.
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
hazardous.
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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
fetus.
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
carcinogens.
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
tetrachloride.
Wear protective clothing and cover your hands
and face, particularly when spraying or using
solvents.
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,
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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
scarring.
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
apparatus.
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
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be collected and disposed of as hazardous
waste.
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
test.
Glazes containing these metals are commonly
used in ceramics studios and classrooms as
follows:
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
spectrum.
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
authorities.
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 -
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and may be hazardous waste - when they are
discarded.
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
waste.
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
Usage
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
home.
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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
bats.
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,
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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
Usage
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
liquids.
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
enamels.
Avoid resins and adhesives that release
formaldehyde
Avoid cyanide plating systems for surface
treatments.
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.
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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
conditions.
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
preparation.
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
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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
avoided.
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
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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
waters.
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.
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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
pneumonia.
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
small.
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
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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
etch.
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
needed.
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
adhesives.)
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.
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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
operation.
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
silver;
Haze and emulsion removers and printing plate
cleaners containing toxic and/or flammable
organic solvents, such as acetone, xylene and
toluene;
Spent corrosive acid solutions used in etching;
and,
Obsolete inks, etching grounds and cleaning
materials.
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
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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
metals.
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
done.
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
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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
avoided.
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
toxic.
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
silicosis.
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
worn.
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.
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5.7 Design and Architecture; and Model
Making
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
thoroughly.
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
pollutant.
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
clothing.
Wear an NIOSH approved and appropriate
respiratory protection mask when spraying or
working close-up.
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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
hands.
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
modeling.
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
ventilation.
Use oil/wax pastels, rather than dry
pastels, which eliminates the dust hazard
and only requires good hygiene to be used
safely.
If soft, dry pastels are used, follow several
simple procedures:
work in a studio separate from your home;
wear a respirator or provide special
ventilation;
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
material.
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
equipment.
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-
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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
information.)
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
inhaled.
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
appropriate.
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
Usage
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.
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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
solutions.
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
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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
formaldehyde.
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
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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
material
Use water-based glues whenever possible but be
mindful that they may be hazardous and handle
carefully.
Use water-based finishes; they may take a few
minutes longer to dry but it is well worth the
wait.
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
apparent.
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
glass.
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
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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: / /www.epa.gov/epaoswer/hazwaste /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:
http://www.epa.gov/epaoswer/hazwaste/id/lu
nivwast/statesof.htm
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SECTION 6.0
POLLUTION PREVENTION AND WASTE MINIMIZATION
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
reasons.
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
6-1
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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
6-2
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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
possible.
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
trash.
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
waste.
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
container.
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.
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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
disposal.
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: //www.mfta.org/home.php) 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
processes.
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
6-4
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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
containers.
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
added.
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
containers.
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
6-5
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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
determination.
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.
Use:
nontoxic and biodegradable cleaners and
degreasers,
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
explore).
The table in Appendix F presents examples of
possible Waste Treatment and Disposal
Technologies and some basic precautions,
comments, and suggestions.
6-6
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APPENDIX A
CHARACTERISTIC WASTES: D AND
LISTED HAZARDOUS WASTES: F, P, AND U
RCRA LISTS OF HAZARDOUS WASTES "D" CODES
TOXICITY CHARACTERISTIC CONSTITUENTS AND
REGULATORY LEVELS (TCLP)
EPA Waste No.
D001
D002
D003
D004
D005
D006
D007
D008
D009
D010
D011
D012
DOB
D014
D015
D016
D017
D018
0019
D020
D021
Constituent
Ignitability
Corrosivity
Reactivity
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Endrin
Lindane
Methoxychlor
Toxaphene
2,4-D
2,4,5-TP (Silvex)
Benzene
Carbon Tetrachloride
Chlordane
Chlorobenzene
CAS Number
na
na
na
7440-38-2
7440-39-3
7440-43-9
7440-47-3
7439-92-1
7439-97-6
7782-49-2
7440-22-4
72-20-8
58-89-9
72-43-5
8000-35-2
94-75-7
93-72-1
71-43-2
56-23-5
57-74-9
108-90-7
Regulatory Level
(mg/L)
Flash Pt. < 140 F
Ph<2.0or>12.5
Any material that
will react under
normal conditions
to cause an
explosion or fire
or release a toxic
gas.
5.0
100.0
1.0
5.0
5.0
0.2
1.0
5.0
0.02
0.4
10.0
0.5
10.0
1.0
0.5
0.5
.03
100.0
A-l
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EPA Waste No.
D022
D023
D024
D025
D026
D027
D028
D029
D030
D031
D032
D033
D034
D035
D036
D037
D038
D039
D040
D041
D042
D043
Constituent
Chloroform
o-Cresol
m-Cresol
p-Cresol
Cresol
1,4-Dichlorobenzene
1,2-Dichloroethane
1,1-Dichloroethylene
2,4-Dinitrotoluene
Heptachlor (and its hydroxide)
Hexachlorobenzene
Hexachloro- 1,3-butadiene
Hexachloroethane
Methyl ethyl ketone
Nitrobenzene
Pentachlorophenol
Pyridine
Tetrachloroethylene
Trichloroethylene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Vinyl chloride
CAS Number
67-66-3
95-48-7
108-39-4
106-44-5
1319-77-3
106-46-7
107-06-2
75-35-4
121-14-2
76-44-8
118-74-1
87-68-3
67-72-1
78-93-3
98-95-3
87-86-5
100-86-1
127-18-4
79-01-6
95-95-4
88-06-2
75-01-4
Regulatory Level
(mg/L)
6.0
200.0
200.0
200.0
200.0
7.5
0.5
0.7
0.13
0.008
0.13
0.5
3.0
200.0
2.0
100.0
5.0
0.7
0.5
400.0
2.0
0.2
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40 C.F.R. ง 261.31
CODE OF FEDERAL REGULATIONS
TITLE 40-PROTECTION OF ENVIRONMENT
CHAPTER I-ENVIRONMENTAL PROTECTION AGENCY
SUBCHAPTERI-SOLID WASTES
PART 261-IDENTIFICATION AND LISTING OF HAZARDOUS WASTE
SUBPART D-LISTS OF HAZARDOUS 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
Hazard
Code
Generic
F001
F002
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.
(T)
(T)
A-3
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Industry and
EPA hazardous
waste No.
Hazardous waste
Hazard
Code
F003
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.
(I)
[Fna]
F005
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.
A-4
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40 C.F.R. ง 261.33
CODE OF FEDERAL REGULATIONS
TITLE 40-PROTECTION OF ENVIRONMENT
CHAPTER I-ENVIRONMENTAL PROTECTION AGENCY
SUBCHAPTERI-SOLID WASTES
PART 261-IDENTIFICATION AND LISTING OF HAZARDOUS WASTE
SUBPART D-LISTS OF HAZARDOUS 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
section.
(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.
A-5
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[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
A2213
Acetonitrile
Acetophenone
2-Acetylaminefluarone
Acetyl chloride
l-Acetyl-2-thiourea
Acrolein
Acrylamide
Acrylonitrile
Aldicarb
Aldicarb sulfbne
CAS Name
Ethanimidothioic acid, 2-(dimethylamino)-N-
hydroxy-2-oxo-, methyl ester
Same
Ethanone, 1-phenyl-
Acetamide, N-9H-fluoren-2-yl-
Same
Acetamide, N-(aminothioxomethyl)-
2-Propenal
2-Propenamide
2-Propenenitrile
Propanal, 2-methyl-2-(methylthio)-, O-
[(methylamino)carbonyl] oxime
Propanal, 2-methyl-2- (methylsulfonyl) -, O-
[(methylamino) carbonyl] oxime
Cas No.
30558^3-1
75_05_8
98-86-2
53-96-3
75-36-5
591-08-2
107-02-8
79-06-1
107-13-1
116-06-3
1646-88^
HW Code
U394
U003
U004
U005
U006
P002
POOS
U007
U009
P070
P203
A-6
-------
Common name
Aldrin
Allyl alcohol
Aluminum phosphide
5-(Aminomethyl)-3-isoxazolol
4-Aminopyridine
Amitrole
Ammonium vanadate
Aniline
Arsenic acid
Arsenic pentoxide
Arsenic trioxide
Auramine
Azaserine
Barb an
Barium cyanide
Bendiocarb
Bendiocarb phenol
Benomyl
Benz[c]acridine
Benz [a] anthracene
Benzal chloride
Benzene
Benzidine
Benzo [ajpyrene
CAS Name
1,4,5,8-Dimethanonaphthalene, 1,2,3,4,10,10-
10-hexachloro-l,4,4a,5,8,8a-hexahydro-
(larpha,4alpha,4abeta,5alpha,8alpha,8abeta)-
2-Propen-l-ol
Same
3(2H)-Isoxazolone, 5-(aminomethyl)-
4-Pyridinamine
lH-l,2,4-Triazol-3-amine
Vanadic acid, ammonium salt
Benzenamine
Arsenic acid H3 AsO4
Arsenic oxide As2 O5
Arsenic oxide As2 O3
Benzenamine, 4,4'-carbonimidoylbis [N,N-di-
methyl
L-Serine, diazoacetate (ester)
Carbamic acid, (3-chlorophenyl) -, 4-chloro- 2-
butynyl ester
Same
l,3-Benzodioxol-4-ol, 2,2-dimethyl-, methyl
carbamate
1 ,3-Benzodioxol-4-ol, 2,2-dimethyl-,
Carbamic acid, [1- [(butylamino) carbonyl]-
lH-benzimidazol-2-yl] -, methyl ester
Same
Same
Benzene, (dichloromethyl)-
Same
[l,l'-Biphenyl]-4,4 1-diamine
Same
Cas No.
309-00-2
107-18-6
20859-73-8
2763-96^
504-24-5
61-82-5
7803-55-6
62-53-3
7778-39^
1303-28-2
1327-53-3
492-80-8
115-02-6
101-27-9
542-62-1
22781-23-3
22961-82-6
17804-35-2
225-51^
56-55-3
98-87-3
71^3_2
92-87-5
50-32-8
HW Code
P004
POOS
P006
P007
POOS
U011
P119
U012
P010
P011
P012
U014
U015
U280
P013
U278
U364
U271
U016
U018
U017
U019
U021
U022
A-7
-------
Common name
p-Benzoquinone
Benzotrichloride
Benzyl chloride
Beryllium powder
Bromoacetone
Bromoform
4-Bromophenyl phenyl ether
Brucine
Cacodylic acid
Calcium chromate
Calcium cyanide
Carbaryl
Carbendazim
Carbofuran
Carbofuran phenol
Carbon disulfide
Carbon oxyfluoride
Carbon tetrachloride
Carbosulfan
Chloral
Chlorambucil
Chlordane
isomers)
Chlornaphazin
Chloroacetaldehyde
CAS Name
2,5-Cyclohexadiene-l,4-dione
Benzene, (trichloromethyl)-
Benzene, (chloromethyl)-
Same
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
ester
7-Benzoฃuranol, 2,3-dihydro-2,2-dimethyl-,
methylcarbamate
7-Benzo furanol, 2,3-dihydro-2,2-dimethyl-
Same
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-
octachloro-2,3,3a,4,7,7a-hexahydro-
Naphthalenamine, N,N'-bis (2-chloroethyl)-
Acetaldehyde, chloro-
Cas No.
106-51^1
98-07-7
100^4-7
7440^1-7
598-31-2
75-25-2
101-55-3
357_57_3
75-60-5
13765-19-0
592-01-8
63-25-2
10605-21-7
1563-66-2
1563-38-8
75-15-0
353_50^
56-23-5
55285-14-8
75_87-6
305-03-3
57-74-9
494-03-1
107-20-0
HW Code
U197
U023
P028
P015
P017
U225
U030
P018
U136
U032
P021
U279
U372
P127
U367
P022
U033
U211
P189
U034
U035
U036
TI036
U026
P023
A-8
-------
Common name
p-Chloro aniline
Chlorobenzene
Chlorobenzilate
p-Chloro-m-cresol
2-Chloroethyl vinyl ether
Chlorofonn
Chloromethyl methyl ether
beta-Chloronaphthalene
o-Chlorophenol
l-(o-Chlorophenyl)thiourea
3-Chloropropionitrile
Chrysene
Copper cyanide
Creosote
Cresol (Cresylic acid)
Crotonaldehyde
m-Cumenyl methylcarbamate
Cyanides (soluble salts and
complexes) NOS*
Cyanogen
Cyanogen bromide
Cyanogen chloride
2-Cyclohexyl-4,6-
dinitrophenol
Cyclopho sphamide
2,4-D
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-
Same
Copper cyanide CuCN
Same
Phenol, methyl-
2-Butenal
Phenol, 3-(methylethyl)-, methyl carbamate
Ethanedinitrile
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.
106^7-8
108-90-7
510-15-6
59-50-7
110-75-8
67-66-3
107-30-2
91-58-7
95-57-8
5344-82-1
542-76-7
218-01-9
544_92-3
1319-77-3
4170-30-3
64-00-6
460-19-5
506-68-3
506-77-^
131_89-5
50-18-0
94_75_7
HW Code
P024
U037
U038
U039
U042
U044
U046
U047
U048
P026
P027
U050
P029
U051
U052
U053
P202
P030
P031
U246
P033
P034
U058
U240
U240
A-9
-------
Common name
Daunomycin
DDD
DDT
Diallate
Dibenz [a,h] anthracene
Dibenzo [a,i]pyrene
l,2-Dibromo-3-
chloropropane
Dibutyl phthalate
o-Dichlorobenzene
ni-Dichlorobenzene
p-Dichlorobenzene
3,3'-Dichlorobenzidine
l,4-Dichloro-2-butene
Dichlorodifluoromethane
1,1-Dichloroethylene
1,2-Dichloroethylene
Dichloroethyl ether
Dichloroisopropyl ether
Dichloromethoxy ethane
Dichlorornethyl ether
2,4- Dichlo rophenol
2,6-Dichlorophenol
Dichlorophenylarsine
1,3-Dichloropropene
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-
chloro-
Benzene, l,l'-(2,2,2-trichloroethylidene)bis [4-
chloro-
Carbamothioic acid, bis(l-methylethyl)-, S-(2,3-
dichloro-2-propenyl) ester
Same
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.
20830-81-3
72-54-8
50-29-3
2303-16^
53_70-3
189-55-9
96-12-8
84-74-2
95-50-1
541-73-1
106^6-7
91-94-1
764^1-0
75-71-8
75-35^
156-60-5
\\\-M-4
108-60-1
111-91-1
542-88-1
120-83-2
87-65-0
696-28-6
542-75-6
HW Code
U059
U060
U061
U062
U063
U064
U066
U069
U070
U071
U072
U073
U074
U075
U078
U079
U025
U027
U024
P016
U081
U082
P036
U084
A-10
-------
Common name
Dieldrin
1 ,2: 3,4-Diepoxybutane
Diethylarsine
Diethylene glycol,
dicarbamate
1,4-Diethyleneoxide
Diethylhexyl phthalate
N,N'-Diethylhydrazine
O,O-Diethyl S-methyl
dithiophosphate
Diethyl-p-nitrophenyl
phosphate
Diethyl phthalate
O,O-Diethyl O-pyrazinyl
phosphoro-thioate
Diethylstilbesterol
Dihydrosafrole
Diisopropylfluorophosphate
(DFP)
Dimethoate
3,3'-Dimethoxybenzidine
p-Dimethylamino azobenzene
7,12-
Dimethylbenz [a] anthracene
3,3'-Dimethylbenzidine
Diniethylcarbamoyl chloride
1 , 1 -Dimethylhydrazine
1,2-Diniethylhydrazine
CAS Name
2,7: 3,6-Dimethanonaphth [2,3-b] oxirene,
3,4,5,6,9,9-hexachloro-la,2,2a,3,6,6a,7,7a-
octahydro-
,(laalpha,2beta,2aalpha,3beta,6beta,6aalpha,7be
ta,7aalpha)-
2,2'-Bioxirane
Arsine, diethyl-
Ethanol, 2,2'-oxybis-, dicarbamate
1,4-Dioxane
1,2-Benzenedicarboxylic acid, bis(2-ethylhexyl)
ester
Hydrazine, 1,2-diethyl-
Phosphorodithioic acid, O,O-diethyl S-methyl
ester
Phosphoric acid, diethyl 4-nitrophenyl ester
1,2-Benzenedicarboxylic acid, diethyl ester
Phosphorothioic acid, O,O-diethyl O-pyrazinyl
ester
Phenol, 4,4'-(l,2-diethyl-l,2-ethenediyl)bis-,(E)-
1,3-Benzodioxole, 5-propyl-
Phosphorofluoridic acid, bis(l-methylethyl)
ester
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.
60-57-1
1464-53-5
692^2-2
5952-26-1
123-91-1
H7_8i_7
1615-80-1
3288-58-2
311-15-5
84-66-2
297-97-2
56-53-1
94_58-6
55-91^
60-51-5
H9_90^
60-11-7
57-97-6
H9_93_7
79^4-7
57-14-7
540-73-8
HW Code
P037
U085
P038
U395
U108
U028
U086
U087
P041
U088
P040
U089
U090
P043
P044
U091
U093
U094
U095
U097
U098
U099
A-ll
-------
Common name
alpha,alpha-
Dimethylphenethylamine
2,4-Dimethylphenol
Dimethyl phthalate
Dimethyl sulfate
Dimetilan
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Dinoseb
Di-n-octyl phthalate
1,2-Diphenylhydrazine
Di-n-propylnitrosamine
Disulfoton
Dithiobiuret
Endosulfan
Endothall
Endrin
T-, , , ,.
Epichlorohydrin
Epinephrine
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
N)C(S)]2NH
6,9-Methano-2,4,3-benzodioxathiepin,
6,7,8,9,10,10-hexachloro-l,5,5a,6,9,9a-
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-
hydro-,(laalpha,2beta,2abeta,3alpha,6alpha,
6abeta,7beta,7aalpha)-
Oxirane, (chloromethyl)-
1,2-Benzenediol, 4-[l-hydroxy-2-
(methylamino) ethyl]-, (R)-
Carbamic acid, ethyl ester
Cas No.
122-09-8
105-67-9
131_1 1_3
77-78-1
644-64^1
534-52-1
51-28-5
121-14-2
606-20-2
88-85-7
117-84-0
122-66-7
621-64-7
298-04^1
541-53-7
H5_29-7
145_73_3
72-20-8
106-89-8
51^3^
51-79-6
HW Code
P046
U101
U102
U103
P191
P047
P047
P048
U105
U106
P020
U017
U109
Ulll
P039
P049
P050
P088
P051
P051
U041
P042
U238
A-12
-------
Common name
Ethyl cyanide
Ethylenebis dithio carb amic
acid
Ethylenebis dithio carb amic
acid, salts and esters
Ethylene dibromide
Ethylene dichloride
Ethylene glycol monoethyl
ether
Ethyleneimine
Ethylene oxide
Ethylenethiourea
Ethylidene dichloride
Ethyl methacrylate
Ethyl rnethanesulfonate
Famphur
Fluoranthene
Fluorine
Fluoroacetamide
Fluoroacetic acid, sodium salt
Formaldehyde
Formetanate hydrochloride
Formic acid
Formparanate
Glycidylaldehyde
Heptachlor
CAS Name
Propanenitrile
Carbamodithioic acid, 1,2-ethanediylbis-
Ethane, 1,2-dibromo-
Ethane, 1,2-dichloro-
Ethanol, 2-ethoxy-
Aziridine
Oxirane
2-Imidazolidinethione
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
Same
Same
Acetamide, 2-fluoro-
Acetic acid, fluoro-, sodium salt
Same
Methanimidamide, N,N-dimethyl-N'-[3-
[[(methylamino) carbonyl]oxy]phenyl]-,
monohydrochloride
Same
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-
heptachloro-3a,4,7,7a-tetrahydro-
Cas No.
107-12-0
Hl_54_6
106-93^1
107-06-2
110-80-5
151_56^
75-21-8
96^5-7
75-34-3
97-63-2
62-50-0
52-85-7
206^4-0
7782-41^
640-19-7
62-74-8
50-00-0
23422-53-9
64-18-6
17702-57-7
765-34^1
76^4-8
HW Code
P101
U114
U114
U067
U077
U359
P054
U115
U116
U076
U118
U119
P097
U120
P056
P057
P058
U122
P198
U123
P197
U126
P059
A-13
-------
Common name
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachlorophene
Hexachloropropene
Hexaethyl tetraphosphate
Hydrazine
Hydrogen cyanide
Hydrogen fluoride
Hydrogen sulfide
Indeno [1 ,2,3-cd] pyrene
Isobutyl alcohol
Isodrin
Isolan
Isosafrole
Kepone
Lasiocarpine
Lead acetate
Lead phosphate
Lead subacetate
Lindane
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
Same
Hydrocyanic acid
Hydrofluoric acid
Hydrogen sulfide H2 S
Same
1-Propanol, 2-methyl-
1 ,4,5,8-Dimethanonaphthalene, 1 ,2,3,4,1 0,1 0-
hexachloro-l,4,4a,5,8,8a-hexahydro-
,(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)-
l,3,4-Metheno-2H-cyclobuta[cd]pentalen-2-
one, l,la,3,3a,4,5,5,5a,5b,6-
decachlorooctahydro-
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-
[lalpha(Z),7(2S*,3R*),7aalpha]]
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.
118-74-1
87-68-3
77^7^
67-72-1
70-30^
1888-71-7
757-58^
302-01-2
74_90-8
7664-39-3
7783-06^
193_39_5
78-83-1
465-73-6
H9_38-0
120-58-1
143_50-0
303-34-1
301-04-2
7446-27-7
1335-32-6
58-89-9
HW Code
U127
U128
U130
U131
U132
U243
P062
U133
P063
U134
U135
U137
U140
P060
PI 92
U141
U142
U143
U144
U145
U146
U129
A-14
-------
Common name
Maleic anhydride
Maleic hydrazide
Malononitrile
Manganese
diniethyldithiocarb amate
Melphalan
Mercury
Mercury fulminate
Methacrylonitrile
Methapyrilene
Methiocarb
Methornyl
Methoxychlor
Methyl bromide
Methyl chloride
Methyl chlorocarbonate
Methyl chloroform
3-Methylcholanthrene
4,4'-Methylenebis(2-
chloro aniline)
Methylene bromide
Methylene chloride
Methyl ethyl ketone (MEK)
Methyl ethyl ketone peroxide
Methyl hydrazine
Methyl iodide
Methyl isocyanate
CAS Name
2,5-Furandione
3,6-Pyridazinedione, 1,2-dihydro-
Propanedinitrile
Manganese, bis (dimethylcarbamodithioato-
S,S')-,
L-Phenylalanine, 4- [bis (2-chloroethyl) aminol] -
Same
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)-
,methylcarbamate
Ethanimidothioic acid, N-
[[(methylamino)carbonyl]oxy]-, methyl
Benzene, l,l'-(2,2,2-trichloroethylidene)bis [4-
methoxy-
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
2-Butanone, peroxide
Hydrazine, methyl-
Methane, iodo-
Methane, isocyanato-
Cas No.
108-31-6
123-33-1
109-77-3
15339-36-3
148-82-3
7439-97-6
628-86^1
126-98-7
91-80-5
2032-65-7
16752-77-5
72^3-5
74-83-9
74_87-3
79_22-l
71-55-6
56^9-5
101-14-4
74_95_3
75-09-2
78-93-3
1338-23^1
60-34^1
74-88^
624-83-9
HW Code
U147
U148
U149
P196
U150
U151
P065
U152
U155
P199
P066
U247
U029
U045
U156
U226
U157
U158
U068
U080
U159
U160
P068
U138
P064
A-15
-------
Common name
2-Methyllactonitrile
Methyl methacrylate
Methyl parathion
Methylthiouracil
Metolcarb
Mexacarbate
Mitomycin C
MNNG
Naphthalene
1,4-Naphthoquinone
alpha-Naphthylamine
beta-Naphthylamine
alpha-N aphthylthiourea
Nickel carbonyl
Nickel cyanide
Nicotine
Nitric oxide
p-Nitro aniline
Nitrobenzene
Nitrogen dioxide
Nitroglycerin
p-Nitrophenol
2-Nitropropane
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-
thioxo-
Carbamic acid, methyl-, 3-methylphenyl ester
Phenol, 4-(dimethylamino)-3,5-dimethyl-,
Azirino[2',3':3,4]pyrrolo[l,2-a]indole-4,7-
dione,6-amino-8-[[(aminocarbonyl)oxy]methyl]-
l,la,2,8,8a,8b-hexahydro-8a-methoxy-5-
methyl-, [laS-(laalpha,8beta,8aalpha,8balpha)]-
Guanidine, N-methyl-N'-nitro-N-nitroso-
Same
1,4-Naphthalenedione
1-Naphthalenamine
2-Naphthalenamine
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.
75-86-5
80-62-6
298-00-0
56-04-2
1129-11-5
315_18^
50-07-7
70-25-7
91-20-3
130-15^
134_32-7
91-59-8
86-88^1
13463-39-3
557-19-7
54-11-5
10102-43-9
100-01-6
98-95-3
10102^4-0
55-63-0
100-02-7
79^6-9
HW Code
P069
U162
P071
U164
P190
P128
U010
U163
U165
U166
U167
U168
P072
P073
P074
P075
P075
P076
P077
U169
P078
P081
U170
U171
A-16
-------
Common name
N-Nitrosodi-n-butylamine
N-Nitrosodiethanolamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitroso-N-ethylurea
N-Nitroso-N-methylurea
N-Nitroso-N-methylurethane
N-Nitrosomethylvinylamine
N-Nitrosopiperidine
N-Nitrosopyrrolidine
5-Nitro-o-toluidine
Octamethylpyrophosphorami
de
Osmium tetroxide
Oxamyl
Par aldehyde
Parathion
Pentachlorobenzene
Pentachloroethane
Pentachloronitrobenzene
(PCNB)
Phenacetin
Phenol
Phenylmercury acetate
Phenylthiourea
Phosgene
Phosphine
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
ester
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)-
Same
Mercury, (acetato-O)phenyl-
Thiourea, phenyl-
Carbonic dichloride
Same
Cas No.
924-16-3
1116-54-7
55-18-5
62-75-9
759-73-9
684-93-5
615-53-2
4549^0-0
100-75^
930-55-2
99-55-8
152-16-9
20816-12-0
23135-22-0
123-63-7
56-38-2
608-93-5
76-01-7
82-68-8
62^4-2
108-95-2
62-38^1
103-85-5
75^4-5
7803-51-2
HW Code
U172
U173
U174
P082
U176
U177
U178
P084
U179
U180
U181
P085
P087
P194
U182
P089
U183
U184
U185
U187
U188
P092
P093
P095
P096
A-17
-------
Common name
Phorate
Phthalic anhydride
Physostigmine
Physostigmine salicylate
2-Picoline
Potassium cyanide
Potassium silver cyanide
Promecarb
Pron amide
1,3-Propane sultone
n-Propylamine
Propargyl alcohol
Propham
Propoxur
Propylene dichloride
1,2-Propylenimine
Prosulfocarb
Pyridine
Reserpine
Resorcinol
Saccharin
Q 1 U
CAS Name
Phosphorodithioic acid, O,O-diethyl S-
[(ethylthio)methyl] ester
1,3-Isobenzofurandione
Pyrrolo[2,3-b]indol-5-01, l,2,3,3a,8,8a-
hexahydro-l,3a,8-trimethyl-,methylcarbamate
(ester), (3aS-cis)-
Benzoic acid, 2-hydroxy-, compd with (3aS-cis)
-l,2,3,3a,8,8a-hexahydro-l,3a,8-
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
carbamate
Benzamide, 3,5-dichloro-N-(l,l-dimethyl-2-
propynyl)-
1,2-Oxathiolane, 2,2-dioxide
1-Propanamine
2-Propyn-l-ol
Carbamic acid, phenyl-, 1-methylethyl ester
Phenol, 2-(l-methylethoxy)-,methylcarbamate
Propane, 1,2-dichloro-
Aziridine, 2-methyl-
Carbamothioic acid, dipropyl-, S-
(phenylmethyl) ester
Same
Yohimban-16-carboxylic acid, 11,17-
dimethoxy- 18- [(3,4,5- trimethoxybenzoyl) oxy] -
smethyl
ester,(3beta,16beta,17alpha,18beta,20alpha)-
1,3-Benzenediol
l,2-Benzisothiazol-3(2H)-one, 1,1-dioxide
Cas No.
298-02-2
85^4-9
57^7-6
57-64-7
109-06-8
151_50-8
506-61-6
2631-37-0
23950-58-5
1120-71-1
107-10-8
107-19-7
122^2-9
114_26-1
78-87-5
75-55-8
52888-80-9
110-86-1
50-55-5
108^6-3
81-07-2
HW Code
P094
U190
P204
P188
U191
P098
P099
P201
U192
U193
U194
P102
U373
U411
U083
P067
U387
U196
U200
U201
U202
TT909
A-18
-------
Common name
Safrole
Selenium dioxide
Selenium sulfide
Selenourea
Silver cyanide
Sodium cyanide
Streptozotocin
Strychnine
1,2,4,5-Tetrachlorobenzene
1,1,1,2-Tetrachloroethane
1 ,1 ,2,2-Tetrachloroethane
Tetrachloroethylene
Tetraethyldithiopyrophosphat
e
Tetraethyl lead
Tetraethyl pyrophosphate
Tetranitromethane
Thallic oxide
Thallium (T) acetate
Thallium(I) carbonate
Thallium(I) chloride
Thallium(I) nitrate
Thallium selenite
Thallium(I) sulfate
Thioacetamide
Thiodicarb
CAS Name
1,3-Benzodioxole, 5-(2-propenyl)-
Selenious acid
Selenium sulfide SeS2
Same
Silver cyanide Ag(CN)
Sodium cyanide Na(CN)
D-Glucose, 2-deoxy-2-
[[(methylnitrosoamino)carbonyl]amino]-
Strychnidin-10-one
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
Ethanethioamide
Ethanimidothioic acid, N,N'-[thiobis
[(methylimino) carbonyloxy]] bis-, dimethyl
Cas No.
94-59-7
7783-00-8
7488-56^1
630-10^1
506-64-9
143_33_9
18883-66^1
57-24-9
95-94-3
630-20-6
79_34_5
127-18^1
3689-24-5
78-00-2
107^19-3
509-14-8
1314_32-5
563-68-8
6533-73-9
7791_12-0
10102-45-1
12039-52-0
7446-18-6
62-55-5
59669-26-0
HW Code
U203
U204
U205
P103
P104
P106
U206
P108
P108
U207
U208
U209
U210
P109
P110
Pill
P112
P113
U214
U215
U216
U217
P114
P115
U218
U410
A-19
-------
Common name
Thiofanox
Thiomethanol
Thioph an ate-me thyl
Thiophenol
Thio s emicarb azide
Thiourea
Thiram
Tirpate
Toluene
Toluenediamine
Toluene diisocyanate
o-Toluidine
o-Toluidine hydrochloride
p-Toluidine
Toxaphene
Triallate
2,4,6-Tribromophenol
1,1,2-Trichloroethane
Trichloroethylene
Trichloroniethanethiol
Trichloromonofluoromethane
Triethylamine
1,3,5-Trinitrobenzene
Tris (2,3-dibromopropyl)
phosphate
CAS Name
ester
2-Butanone, 3,3-dimethyl-l-(methylthio)-, 0-
[(methylamino)carbonyl] oxime
Methanethiol
Carbamic acid, [1,2-phyenylenebis
(iminocarbonothioyl)] bis-, dimethyl ester
Benzenethiol
Hydrazinecarbothio amide
Same
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-
Same
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.
39196-18^1
74-93-1
23564-05-8
108-98-5
79-19-6
62-56-6
137-26-8
26419-73-8
108-88-3
25376^15-8
26471-62-5
95-53^1
636-21-5
106^19-0
8001-35-2
2303-17-5
118-79-6
79-00-5
79-01-6
75_70-7
75_69^1
121^14-8
99-35^1
126-72-7
HW Code
P045
U153
U409
POM
P116
U219
U244
P185
U220
U221
U223
U328
U222
U353
P123
U389
U408
U227
U228
P118
U121
U404
U234
U235
A-20
-------
Common name
Trypan blue
Uracil mustard
Vanadium pentoxide
Vinyl chloride
Warfarin
Warfarin
Warfarin salts, when present
at concentrations less than
03%
Warfarin salts, when present
at concentrations greater than
03%
Zinc cyanide
Zinc phosphide
Zinc phosphide
Ziram
CAS Name
2,7-Naphthalenedisulfonic acid, 3,3'- [(3,3'-
dimethyl[l,l'-biphenyl]-4,4'-diyl)bis(azo)]-bis[5-
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-
4)-
Cas No.
72-57-1
66-75-1
1314_62-1
75-01^1
81-81-2
81-81-2
557_2l-l
1314-84-7
1314-84-7
137-30^1
HW Code
U236
U237
P120
U043
U248
P001
U248
P001
P121
P122
U249
P205
FN1 CAS Number given for parent compound only.
A-21
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-------
APPENDIX B
BEST MANAGEMENT PRACTICES
Container Management
RECORD KEEPING CHECKLIST FORMS
Hazardous Waste / Universal Waste Storage Area Checklists
(CESQG; LQG 90-day and SQG 180-day)
Satellite Accumulation Areas
B-l
-------
Hazardous Waste / Universal Waste Storage Area Checklist
Bldg. Name:
Room/ Area
Dept. or Unit:
90-day Hazardous Waste Storage Area
Inspector
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
anytime.
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:
No
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:
Yes
No
Containers are in good condition (not leaking or corroding)?
If no, describe finding:
Yes
No
Containers are compatible with contents (refer to compatibility table)?
If no, describe finding:
Yes
No
B-2
-------
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:
B-3
-------
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
generated.)
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
Dept.
Phone
Date: Time
B-4
-------
Satellite Point Checklist Form
Bldg. Name: Date:
Room/Area
Name/No.: Time:
Room/Area
Description: Auditor:
Insp.
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:
Training
Personnel have received EH&S Chemical Waste Disposal training? Yes No
If no, describe finding:
B-5
-------
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
No
No
No
No
No
6) are aware of the contents and location of Cornell's General Chemical Waste Rules? Yes
If no, describe finding(s):
Correct _
Correct _
Correct
Correct,
Correct _
No
Did area perform a self-audit? Yes
No
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:
No
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:
No
Were any perishable chemicals observed beyond their expiration date? Yes
If yes, describe finding:
No
Are other types of "inherently waste-like" or speculatively accumulated containers present? Yes
If yes, describe finding:
No
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
Dept.
Phone
Level II
Level
B-6
-------
APPENDIX C
POTENTIALLY REGULATED CHEMICALS
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
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.
Aluminum
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
disease.
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
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inhalation and skin cancer from ingestion. Poisoning can result from chronic, low-level exposures. Acute
arsenic poisoning causes severe stomach damage and death.
Asbestos+
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
compounds.
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
carcinogen.
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
rats.
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.
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Chloroform**x
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
carcinogen.
Chromium**x
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
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**x
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.
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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
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**x
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
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
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**x
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.
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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.
Silica
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
ingestion.
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
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**
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
LIST OF ART MATERIALS SUPPLIERS
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 http://www.danielsmith.com 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 http://www.kremer-pigmente.com. Orders can be placed using the order form on the web
site.
Hyatt's
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
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Liquitex
Liquitex offers a student line of relatively non-toxic paints and art supplies intended for educational
use.
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: http://www.liquitex.com/products/retailers.cfm
List of Retailers in New York that Sell Liquitex Products
Ai Friedman
44 West 18th Street
New York, NY 10011
212-243-9000
Art Station
307 7th Ave
New York, NY 10001
212-807-8000
Arthur Brown
2 West 46th Street
New York, NY 10036
212-575-5555
Blaker & Kooby
1204 Madison Ave 88th Street
New York, NY 10028
212-369-8308
Columbia Omni Corp
14 West 33rd Street
New York, NY 10001
212-279-6161
Empire Artist Materials
851 Lexington Avenue
New York, NY 10021
212-737-5002
Exec. Accessories DBA Arts & Letter
21 West 38th Street
New York, NY 10017
212-687-5841
Irving Berlin
14 East 37th Street
New York, NY 100 16
212-532-3600
Janoffs Type & Stationery
2870 Broadway/ 11 1st
New York, NY 10025
212-866-5747
Joseph Fischl
1397 3rd Ave
New York, NY 10021
212-288-0633
Lee's Art Shop
220 West 57th Street
New York, NY 100 19
212-247-0110
New York Central Supply
62 Third Avenue @llth Street
New York, NY 10003
212-47-7705
New York Central Supply -
Warehouse
130 East 12th Street
New York, NY 10003
212-477-0400
Pearl @ School of Visual Arts
207 East 23rd Street
New York, NY 100 10
212-59-2179
Pearl Paint
308 Canal Street
New York, NY 10013
212-431-7932
Plaza Artist Materials
173 Madison Avenue
New York, NY 10016
212-689-2870
Sam Flax Corp
425 Park Ave At 55th Street
New York, NY 10011
212-620-3000
Sam Flax Corp
12 West 20th Street
New York, NY 10022
212-620-3000
The Art Store
1 - 5 Bond Street
New York, NY 10012
212-533-2444
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Golden Artist Colors, Inc.
188 Bell Road
New Berlin, NY 13411-9527 USA
607-847-6154
800-959-6543
Fax: 607-847-6767
Goldenart@Goldenpaints.Com
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
E-mail: gamblin@.gamblincolors.com
Web-site: http://www.gamblincolors.com
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: http://www.gamblincolors.com/stores.html.
Dick Blick Art Materials
P.O. Box 1267
Galesburg, IL 61402-1267
E-mail infofSldickblick.com
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.
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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 (www.dickblick.com).
Please see attached for pricing information.
Windsor and Newton
http://www.winsornewton.com/index2.php
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
http://www.binney-smith.com/
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
website: http://www.crayola.com/store/search.cfm?&DID=6&search=portfolio%20series
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.
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APPENDIX E
INTERNET RESOURCES
EDUCATIONAL 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".
Cornell
http://cfe.cornell.edu/cfe/greening.cfm
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
http://www.webdirectory.com/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: / /www.c2e2.org/evc/home.html
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: / /www.naaee.org/npeee/
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)
http://www.edfacilities.org/rl/art.cfm
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
http://www.plu.edu/~libr/web/art.html
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.
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Princeton University Environmental Health and Safety
http: / /web.princeton.edu/sites /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
Arts.
University of Scranton - Greening Across the Chemistry Curriculum
http: / /academic.scranton.edu/faculty/CANNMl /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.
GOVERNMENT RESOURCES
HAZMAT Safety
http: / /hazmat.dot.gov/hazhome.htm
A general informational website with links to other sites relating to HAZMAT Safety.
National Institute for Occupational Heath and Safety (NIOSH)
http: / /www.cdc.gov/niosh/topics /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)
http://www.cdc.gov/niosh/npptl/topics/respirators/
All pertinent information and links to other sites regarding respirator use.
National Institute for Occupational Health and Safety (NIOSH)
http: / /www.cdc.gov/niosh/ipcs /icstart.html
International Programme on Chemical Safety Information on International Chemical Safety Cards (ICSCs).
National Paint and Coatings Association (NPCA)
http: / / www.paint.org/hmis /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
http://www.nrdc.org/health/kids/qleadsch.asp
This FAQ website addressed the topic of lead paint in schools.
NOAA - The Chemical Reactivity Worksheet
http://www.response.restoration.noaa.gov/chemaids/react.html
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.
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U.S. Department of Energy
http: / / www.eere.energy.gov/
A gateway to hundreds of websites and thousands of online documents on energy efficiency and renewable
energy.
U.S. Department of Energy - Clean Cities
http: / / www.eere.energy.gov/cleancities /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: / /www.rebuild.org/index.asp
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: / /www.energy.gov/engine/content.do
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: / /www.nyc.gov/html/dep /
The official DEP website for NYC.
U.S. Department of Homeland Security - Federal Emergency Management Agency
http: / /www.fema.gov/
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: / /hud.esri.com/egis /
Map your community using GIS with this website
U. S. Department of Labor - Occupational Safety and Health Administration (OSHA)
http: / 7www.osha.gov/
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
administration.
U.S. Department of Labor - Occupational Safety and Health Administration - Hazard
Communication
http://www.osha.gov/pls/oshaweb/owadisp.show documentPp table=STANDARDS&p id=10099&p text
version=FALSE
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.
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U.S. EPA - Colleges and Universities
http: / / www.epa.gov/sectof s /colleges /
U.S. EPA - Compliance and Enforcement
http: / / www.epa.gov/compliance/
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)
http://www.epa.gov/dfe/pubs/pdf/tools/ctsa/index.html
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
progress.
U.S. EPA - EnviroFacts
http://www.epa.gov/enviro/html/rcris/rcris 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
http://es.epa.gov/
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: / /yosemite.epa.gov/oar/globalwarming.nsf/content/index.html
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
industries.
U.S. EPA - Healthy School Environments
http://cfpub.epa.gov/schools/index.cfin
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
http://www.epa.gov/epahome/hotline.htm
A large database of environmental information and links relating to hot lines and clearinghouses.
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U.S. EPA - Laws and Regulations
http://www.epa.gov/epahome/laws.htm
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
http://www.epa.gov/epaoswer/ha2waste/combust/general/memorcra.txt
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: / /www.epa.gov/p2/
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
http://yosemite.epa.gov/osw/rcra.nsf/topics?OpenView&count=5000
Topic search for RCRA Information.
U.S. EPA - RCRA, Superfund and EPCRA Call Center
http://www.epa.gov/epaoswer/hotline/index.htm
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
http://www.epa.gov/epaoswer/hazwaste/data/form8700/forms.htm
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
http://epa.gov/highschool/waste.htm
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: / /www.epa.gov/wastemin /
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.
ART AND PAINT SUPPLY MANUFACTURERS
Artist's Materials
http: / /www.trueart.info /materials.htm
Primarily information from the book entitled Art Hardware by Steven Saitzyk, pertaining to artist's materials.
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Binney & Smith
http: / /www.binney-smith.com /
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
http://www.crayola.com/educators/techniques/specialty 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: / /www.danielsmith.com
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
http://www.gamblincolors.com/howtp.html
A supplier of paint and art supplies for the professional artist.
Genesis Artists Colors
http: / /www. arttalk.com / Genesis / artis tcolors .htm
A line of odorless and non-toxic paint and art supplies for educational purposes.
Golden Artist Colors, Inc.
www.goldenpaints.com
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 (Sldickblick.com
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.
Hyatt's
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
http://www.kremer-pigmente.de/englisch/homee.htm
A manufacturer of art and paint supplies in New York. Mineral and organic pigments ordering information
online or through the catalog.
Liquitex
www.liquitex.com
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).
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Manufacturers
http: / /www.trueart.info 7manufactufefs.htm
An alphabetical listing of links to manufacturers of artist and framing materials.
National Association of Printing Ink Manufacturers
http: / /www.napim.org/
This website provides information on pigment and ink suppliers with membership information and scheduled
meetings.
New Pig - Absorbents for Oil Spill Cleanup
http://www.newpig.com/splashPage.jhtml:jsessionid=FYSQ44XVQlFU2CTGIQVSFEQKM2CCWJVC? re
questid=29148
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
products.
Pigments Through the Ages
http://webexhibits.org/piements/intro/paintings7.html
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
http://www2.sherwin.com/IM/default.asp
A manufacturer of paints and art supplies.
Windsor and Newton
http://www.winsornewton.com/index2.php
Windsor and Newton sells art supplies targeted for the professional artist, not typically intended for educational
NEW YORK CITY/STATE RESOURCES
Environmental Advocates of New York
http://www.envirolink.org/external.html?www=http%3A//www.eany.org&itemid=20011023101449488121
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
http://www.nyc.gov/html/dcla/html/mfta/mfta 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
http://www.nyc.gov/html/dep/html/educres.html
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.
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New York City Fire Department
http://nyc.gov/html/fdny/html/fcny 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
http://www.nyc.gov/htnil/nioec/htnil/resource.html
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
citizen.
New York Love Business - Pollution Prevention and Recycling
http://www.nylovesbi2.com/Productivity Energy and Environment/Environmental Assistance/pollution p
revention.asp
A list of main services that are offered relating to pollution prevention and recycling.
New York State Art Teachers Association
http: / /www.nysata.org/
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
http://www.dec.state.ny.us/website/der/spills/spillfaqs.htmlfeeporting
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
Electronics
http://www.dec.state.ny.us/website/dshni/hzwstman/disniantl.htm
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
http://www.dec.state.ny.us/website/dshni/hzwstman/laniprecy.htm
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: / /www.dec.state.ny.us /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
http://www.labor.state.ny.us/business ny/employer responsibilities /safety/coderule.htm
A list of the regulations that come under the jurisdiction of the Division of Safety and Health.
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OTHER WEB RESOURCES
Alliance to Save Energy
http://www.ase.ofg/section/pfogratn/gfeenschl
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
http://www.buildinggreen.com/index.cfm
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.
Chemfinder
http://chemfinder.cambridgesoft.com/
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
http://electronics.exchangesystem.net/
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
http://208.254.22.6/index.cfm?c=business.bus 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
http://www.enviroyellowpages.com/listings/Central 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
http://www2.state.id.us/dbs/safety code/300.html
A website containing comprehensive general and specific information relating to safety and health standards of
toxic and hazardous substances.
GUILD
http: / /www.guild.com/
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: / /www.ci. tucson. az.us /arthazards /medium.html
Contains a searchable database of health and safety information for artists.
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Health and Safety Introduction
http://www.usa829.org/USA/health.html
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
http://www.hsia.org/applications.htm
An informational website on solvent applications.
Joint Service Pollution Prevention Technical Library
http://p21ibrary.nfesc.navy.mil/P2 Opportunity Handbook/alpha sec.html
Alphabetical listing of topics relating to pollution prevention.
Kodak Environmental Services
http://msds.kodak.com/ehswww/external/index.jsp
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
products.
MSDS Search 2004
http://www.msdssearch.com/
A comprehensive website with links to all pertinent information on MSDS's.
National Center for Manufacturing Sciences - Solv DB
http://solvdb.ncms.org/solvdb.htm
A large database of solvent information.
National Toner Recycling and Supply
http: / /www.nationaltoner.com/
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: / /www.recycle.net/
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: / /www.paintquality.com/library/index.html
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.
Scorecard
http: / /www.scorecard.org/
Answers questions about pollution control. Topics include (Air, Water, Agriculture, Environmental Justice,
and Health Hazards).
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Scorecard
http: / / www.scofecafd.org/ 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: / /www.smallbiz-enviroweb.org/Default.htm
A webpage dedicated to helping small businesses access environmental compliance and pollution prevention
information.
This to That
http://www.thistothat.com/index.shtml
A website with instructions for gluing various items to other items; provides recommendations for successful
adhesion.
Toxics Use Reduction Institute (TURI)
http: / /www.turi.org/
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
http://www.seas.columbia.edu/earth/wtert/
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
General
Category
Ceramics
Subcatearory
Examples
Precautions
Clay
Glazes
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
Hazardous
Not hazardous
waste
Hazardous waste
determination must
be performed to
identify the
presence of
regulated chemical
constituents
Treatment and Disposal
Recommendations/
Comments
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.
Drawing
Pastels
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
constituents
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
constituents
Obsolete or abandoned material
containing listed metals should be
managed as hazardous waste.
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Treatment and Disposal
General
Category
Subcatearory
Pen and Ink
Examples
Spray Fixatives
Precautions
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
organics.
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
Hazardous waste
determination must
be performed to
identify the
presence of
regulated chemical
constituents.
Hazardous waste
determination must
be performed to
identify the
presence of
regulated chemical
constituents.
Treatment and Disposal
Recommendations/
Comments
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
materials.
Textile -Dyes
Powders
Avoid creating dust, use dyes in liquid or paste
forms.
Solutions
Mordant baths
Hazardous waste
determination must
be performed to
identify the
presence of
regulated chemical
constituents.
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.
F-2
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Treatment and Disposal
Disposal as Treatment and Disposal
General Hazardous Recommendations/
Category Subcategory Examples Precautions Waste Comments
Jewelry
Soldering
Enameling
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
constituents.
Collect solder dross, silver for
metal salvage /recycling.
Enamels containing toxic metal
pigments or flammable or toxic
organics require hazardous waste
treatment and disposal.
F-3
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Treatment and Disposal
General
Category
Metal Shop
Welding
Metalworking
Subcatearory
Examples
Precautions
Metals
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
Hazardous waste
determination must
be performed to
identify the
presence of
regulated chemical
constituents.
Spent or obsolete
solutions having
corrosive properties
i.e., acidic (pH < 2)
or alkaline (pH >
12.5) are regulated
Treatment and Disposal
Recommendations/
Comments
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
constituents.
2. Beryllium powder is an acutely
hazardous waste.
3. Metallic Mercury is a hazardous
waste.
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.
F-4
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Treatment and Disposal
General
Category
Subcatearory
Patinas/Metal
Compounds
Examples
Precautions
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
Hazardous waste
determination must
be performed to
identify the
presence of
regulated chemical
constituents
Treatment and Disposal
Recommendations/
Comments
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
Paints,
Enamels, Stains,
Varnish
Water-based Coatings
Paints, varnishes, stains,
finishes, sealants
Follow manufacturer's recommendations for
safe use and handling. Provide adequate local
exhaust.
Hazardous waste
determination must
be performed to
identify the
presence of
regulated chemical
constituents
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.
Solvent-based
Coatings
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
constituents
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.
F-5
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Treatment and Disposal
General
Category
Subcatearory
Watercolors
Examples
Precautions
Acrylic Paints (Water-
Emulsion)
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
Hazardous waste
determination must
be performed to
identify the
presence of
regulated chemical
constituents
Treatment and Disposal
Recommendations/
Comments
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
material
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
constituents
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.
F-6
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Treatment and Disposal
General
Category
Subcatearory
Oils n.o.s. as vehicle
for paint formulations
Solvents and thinners,
cleaners, degreasers.
Examples
Linseed oil, safflower oil,
tung oil
Turpentine, acetone,
mineral spirits, methyl ethyl
ketone, xylene, toluene,
glycol ethers
Precautions
Oils and oil-soaked rags are combustible and
create the potential for spontaneous
combustion.
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
Hazardous waste
determination must
be performed to
identify the
presence of
regulated chemical
constituents.
Hazardous waste
determination must
be performed to
identify the
presence of
regulated chemical
constituents.
Treatment and Disposal
Recommendations/
Comments
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.
Photography
Photochemicals
Obsolete and abandoned or
off specification
photochemical solutions,
powders, toners, fixers,
developers
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
constituents
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.
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Treatment and Disposal
Disposal as Treatment and Disposal
General Hazardous Recommendations/
Category Subcategory Examples Precautions Waste Comments
Printmaking
Sculpture
Oxidizing Agents
Ink Pigments
Other pigments
Etching (Acids)
Photoetching
Lithography
Screen Printing
Plaster
Dichromates, chlorates,
chromates, hypochlorites,
nitric acid (concentrated),
periodates, permanganates,
persulfates
Solvents
Mineral spirits, toluene
Highly reactive materials; use with extreme
caution.
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
PPE.
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
goggles.
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
constituents.
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
regulated.
Not hazardous
waste.
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
bags.
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Treatment and Disposal
General
Category
Subcatearory
Plastics/Plastic Resins
Examples
Organic Peroxides
Methyl ethyl ketone
peroxide, benzoyl peroxide
Precautions
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
life.
Disposal as
Hazardous
Flammable and
toxic organics are
regulated. These
include epoxy,
methyl
methacrylate,
phenol- or urea-
formaldehyde,
polyester and
polyurethane.
Flammable, toxic
and reactive
materials are
regulated.
Treatment and Disposal
Recommendations/
Comments
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
waste.
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
risk.
Woo dworking
Ordinary wood or
wood waste
Wood that has been
treated with wood
preservatives such as
chromated copper
arsenate or other toxic
chemicals
Glues and Cements
Not hazardous
waste
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
constituents.
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
regulated.
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
NEW YORK AND NEW JERSEY - REGULATORY DIFFERENCES
SUMMARY
Contact
Information
NEW YORK
Department of Environmental
Conservation
Division of Solid and Hazardous Materials
50 Wolf Road
Albany, NY 12233-7251
518-489-8988
www. dec. s tate.nv.us
NEW JERSEY
Department of Environmental
Protection
Solid and Hazardous Waste Management Program
401 E. State Street, P.O. Box 414
Trenton, NJ 08625-0414
609-633-1418
www.state.nj.us /dep
Hazardous Waste Management Program Requirements Summary
Program
Description
Generator
Status
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 &
Finance.
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-
3.3(b)).
The Hazardous Waste Generator categories, identification numbers and notification requirements for
New York and New Jersey are the same as the federal ones.
Universal
Waste
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
CESQG
SQG
LQG
< 100 kg month
100 to 1,000 kg month
> 1,000 kg month
same
same
same
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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
counties:
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
applicable.
Same as federal.
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Waste Shipments
Rejected
Loads
Licensed
Transporters
(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
followed.
procedures must be
SQG/LQG - Required (NJAC7.26G-6.1(c)(4)).
Regulatory Allowances for On Site Waste Minimization
Domestic
Sewage
Exclusion
Elementary
Neutralization
Recycling
Treatment in
Accumulation
Containers
Small Boilers
and Industrial
Furnaces
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.
See6NYCRR371.1g3.
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
LIST OF ACRONYMS AND DEFINITIONS OF KEY
ENVIRONMENTAL TERMS
Agency/Term
Agency for Toxic Substances and Disease Registry
American Council of Governmental Industrial
Hygienists
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
Pollutants
National Institute for Occupational Safety and Health
National Pollutant Discharge Elimination System
New York City Department of Environmental
Protection
Occupational Safety and Health Administration
Parts Per Million
Permissible Exposure Limit
Acronym/Definition
ATSDR
ACGIH
ANSI
ASTM
CWA
CFR
CERCLA
CERCLIS
CESQG
DOT
EPCRTK
EPA
FEMA
FFA
LDR
LQG
LEPC
MSDS
MDF
NAAQS
NESHAP
NIOSH
NPDES
NYCDEP
OSHA
PPM
PEL
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Agency/Term
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
1986
Threshold Limit Value
Toxic Substances Control Act
Toxicity Characteristic Leaching Procedure
Ultraviolet
U.S. Department of Transportation
U.S. Food and Drug Administration
CAS Registry Number
LDso and LCso (species and routes)
pH
Flashpoint (ฐQ and Method
Flammable Limits in Air
Acronym/Definition
PPE
RCRA
SDWA
SQG
SOPs
SEPC
SARA
TLV
TSCA
TCLP
uv
DOT
FDA
This number is given to a chemical by the Chemical
Abstracts Service Division of the American Chemical
Society.
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).
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Agency/Term
Acronym/Definition
Incompatibility
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)
Ingestion
Injection with a needle or cuts from contaminated
glassware
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
effect.
C, or Ceiling
The maximum allowable human exposure limit for an
airborne substance; not to be exceeded, even
momentarily. Also see "PEL" and "TLV."
Concentration
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
solution.
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
mixture.
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Agency/Term
Acronym/Definition
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.
mg/m3
Milligrams per cubic meter of air; a unit for measuring
concentrations of particulates in the air (a weight per
unit volume).
Neutralize
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.
PEL
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.
NIOSH
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
research.
ppm
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.
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Agency/Term
Acronym/Definition
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.
TLV-
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.
TWA-
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
"PEL."
UEL or UFL
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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