Monona,
This is a good conversation, thanks for bringing it up.
Maybe treatment, ... it depends on the constituents and concentration of
any regulated constituents in
the paint - but don't blame the kit manufacturer. It is only illegal treatment of hazardous waste without
a permit if the material meets the criteria of a hazardous waste before adding aluminum sulfate and hydrated lime. I haven't seen the directions, but regardless of what they imply, the burden of determining how to manage the waste is that of the generator,
not the vendor or firm selling or producing this kit.
If there is a RCRA regulated constituent, it is the burden of the generator to determine if the regulated constituent is above the regulatory limit and
thus if the waste generated is EPA hazardous or non-hazardous.
The lime can make the pH as high as 11.5, but would not carry an EPA waste code for corrosive characteristic until pH 12.
on the Benzadine dyes, they are banned from production stateside, but can still be imported, and the EPA has put forth a Benzidine Dyes Action Plan, however it seems more geared toward textiles as this is the highest risk of exposure to humans.
I am interested in this topic. Please let us know if you hear back from EPA on this, but I think you might be less than satisfied with their response, I hope I am wrong.
What do all these schools do with the paint before this kit or those that do not buy and use this kit. Don't blame the kit, blame the generator, or the manufacturers of the paint for not closing the loop.
be well,
James
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> on behalf of Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Sent: Friday, September 8, 2023 11:52 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Subject: [DCHAS-L] Waste treatment question
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I need some advice.
I was just blown away by a product used in the art schools now. It is for disposing of liquid waste from acrylic paints. Be aware, that some of these paint pigments contain regulated metals such as cadmium, chrome VI, and
more. There are also benzidine pigments and a lot of azo organics.
The product is designed to eliminate toxic waste from these paints. Since these are acrylics, the waste consists of water and acrylic paint. The instructions are to use a special bottle, that can deliver measured amounts
of two different chemicals, and add each separately with stirring and settling time until there is clear water and schmutz at the bottom. There is filter paper and a colander so you can filter out the schmutz and throw it in your trash and then pour the clear
water down the drain.
Sounds like waste treatment to me. Wadda all'y'all think?
Monona
M. Rossol
ACTS
181 Thompson St., #23
New York NY 10012
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