From: ACTSNYC**At_Symbol_Here**CS.COM
Subject: Re: [DCHAS-L] Overspray from screen print cleaning
Date: February 1, 2012 5:13:54 PM EST
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: <7a81.dbfe801.3c5b1322**At_Symbol_Here**>

Unregulated by EPA in waste water DOES NOT EQUAL non-hazardous to people. 

Those are not FDA batch-apparoved food dyes and pigments.  If you really think those art pigments are non-hazardous after looking at their structures some of which are azos which can be anticipated to metabolize to release aniline, toluidine, benzidine, chlorinated benzenes, etc., then there is a car I want to talk to you about. 

Monona Rossol

In a message dated 2/1/2012 11:42:21 AM Eastern Standard Time, brucev**At_Symbol_Here**BRIGHT.NET writes:

Debbie - If the water spray and particulates are non-hazardous and there is no potential for occupational exposure, have you considered educating the shop manager to alleviate his/her concerns?  A famous quote is "the dose makes the poison" and it just seems to me that we should be educating people to be concerned about the hazards that are indeed hazardous and satisfy them with those issues that are not, maybe a little training could go a long way.

Ron - Waste has to be profiled to meet EPA discharge regulations or disposal regulations.  Debbie was speaking of an occupational exposure governed by OSHA, not EPA.  Different standards/criteria, an apples to oranges comparison.  You stated that your discharge is a non-hazardous waste.  How was the information presented to the city?  Was the waste stream properly characterized for disposal?  Characterization is required to be performed by a lab that is probably outside of your company, but certified by your state/Fed EPA.  Homeowners or retail consumers have always been and always will be exempt from EPA compliance requirements, while we are not.  Your city was/is right in that they have the final say in what they will accept into their wastewater treatment facility and if not sufficiently defended with analytical results.  Your city does  not want to treat a hazardous waste or be classified as a Treatment, Storage or Disposal Facility (TSDF)?  You can make this a win-win situation.  Do you have a permit, maybe even an industrial wastewater discharge permit from your city? 

If not I would recommend that you investigate the requirements and obtain one.  Either way you will need the lab analytical results to present to them.  Yes, this will require initial laboratory analytical confirmation, continued on a recurrent basis, for them to continue to accept the wastewater discharge into their sewer system and that is the point, that=E2=80™s compliance and yes, violations can/will lead to expensive fines/penalties in California or anywhere else. 

The location is irrelevant they are implementing the federal law!   


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