Waste disposal is a significant part of keeping your facility compliant, efficient and environmentally friendly. And if you have a paint-heavy operation, paint waste can be a huge component of that. It can be liquid, solid or sludge and may very well be a hazardous material, so you’ll need to know how to handle it.
A waste disposal service can make your job much easier by taking the guesswork out of critical regulation-based procedures. Paint is just one form of waste that we at ERC can collect and dispose of. We can take paint waste that is oil-based, water-based or not paint at all — we’ll also take care of contaminated substances, wastewater and containers. Paint waste disposal and hazardous waste can be complicated components of running your business. In this article, we discuss some key strategies to make your paint waste disposal procedures easier and keep your business compliant.
What exactly is paint? It has many components, and it isn’t without its hazards. Liquid paint is a chemical-filled material that comes in many different formats, some more dangerous than others, which can have significant impacts on our health and the environment. As far as the Environmental Protection Agency (EPA) is concerned, if you produce hazardous waste or cause hazardous waste to become subject to regulation, you are a generator. A generator has specific responsibilities to know what they are working with and take care of the materials appropriately. This responsibility includes being aware of the hazardous or nonhazardous nature of the paint you’re using.
1. Defining Hazardous Wastes
The EPA offers three categories of hazardous waste that a substance can fall under. Each category has different requirements for disposal and care. To fall under the description for any of these, however, it must first be considered solid waste. Some materials are always considered solid wastes, like dioxin-containing wastes.
Even though paint is a liquid, the EPA still considers it solid, as is sludge and dried paint on another surface. Solid waste is any garbage or refuse from several different operations and activities. It is any material discarded in any of the following ways:
- Abandoned: Thrown away, including disposal, burning, incineration or sham recycling.
- Discarded military munitions: Ammunition and components produced for or used by the U.S. Department of Defense or Armed Services are considered solid wastes under certain circumstances.
- Recycled in certain ways: If the material is used, reused, reclaimed or used in particular ways, such as for disposal, burning for energy recovery or accumulating speculatively.
Some state regulations are more strict than federal rules, so be sure to check your state’s policies. Once determined that a product is, in fact, solid waste, it is considered hazardous if it fits one of the following three categories.
A waste described in one of the EPA’s four lists in the Code of Federal Regulations (CFR) is considered hazardous. These lists include common wastes from manufacturing and industrial processes such as solvent wastes, metal finishing wastes, dioxin-bearing wastes and multisource leachate. It also includes wastes involved in specific industries such as pesticide manufacturing and petroleum refining, as well as pure and commercial grade formulations of specific unused chemicals.
This type of hazardous waste can cover many different paints. Part of your responsibility as a generator is to determine whether or not your waste is hazardous. A paint that has any of the following attributes is hazardous and must be disposed of accordingly.
- Ignitability: This includes non-liquids that can cause a fire under specific conditions, liquids with a flashpoint below 60℃, oxidizers and ignitable compressed gases. These substances must be handled appropriately, as they run the risk of starting fires. Improper disposal of one of these could have devastating results for your facility.
- Corrosivity: Materials considered corrosive include aqueous wastes with a pH of 2 or lower, a pH of 12.5 or higher or based on whether the liquid can corrode steel. Corrosivity determines how quickly and aggressively the material will eat through another substance, particularly pipes and fixtures.
- Reactivity: Reactive hazardous waste is dangerous because it can change its behavior based on other conditions. These substances may release toxic gases, react with water, be unstable under normal conditions or be capable of explosion or detonation under either normal or heated conditions. Some paints contain harmful gases called volatile organic compounds (VOCs) that release as the paint is applied and dries. You must treat VOCs with care, but we’ll discuss them in more detail below.
- Toxicity: A toxic waste is harmful when ingested or absorbed by the body. The pollutant concern of paint is significant because of its toxicity, especially when it is allowed to leach into the ground and pollute soil and groundwater. Paint that contains metal can be particularly dangerous, as this toxicity is where lead paint gets its adverse effects. Though lead paint is generally no longer in use, other paints that contain materials like chromium are sometimes used in applications like aerospace and automobile manufacturing.
Mixed Radiological and Hazardous Waste
This type of waste is hazardous waste that also contains radioactive material and is regulated by both the EPA and the Department of Energy or the Nuclear Regulatory Commission. Working with paint isn’t likely to overlap here.
2. Types of Substances
We can’t understand waste disposal without first identifying the components of what you are actually disposing. Many different substances are involved in the process of paint disposal that you’ll need to be aware of so you can be compliant, efficient and environmentally friendly.
Parts of Paint
Shockingly enough, we have to talk about paint. Paints are made up of several different substances that can affect its toxicity and how it behaves in specific environments. Knowing how can help you make the right decisions when disposing of them.
- Pigment: This is what provides paints with their vibrant, attractive colors. It can also be responsible for adding certain properties like opacity or glossiness. Most pigments will be in a powdered form. Titanium dioxide is almost universally used throughout the paint industry for a bright white color due to its high opacity. A high opacity in paint means it is great for coverage and requires few coats to cover a surface completely. Colored pigments can come from a variety of sources, including coal tar, plants and ground minerals such as ochre and sienna. Pigments can be organic, meaning they contain carbon, or inorganic, which tend to be brighter and last longer. Other pigment options include metallic oxides and clay.
- Binder: A binder or resin is what holds everything together — the glue of paint. It allows the paint to adhere to surfaces. Water-based paints tend to use acrylic emulsion polymers. Latex paint has a polymer binder that resembles latex rubber. After applying the paint, water evaporates from it, leaving behind a film of pigment and binder. Oil-based paints tend to use natural, vegetable-based oils like linseed oil, soybean oil, or, more commonly, synthetic resins called alkyds. Alkyds dry harder and faster than other oils.
- Solvent: The solvent carries the pigment and the binder around. It evaporates after you apply the paint to the surface. Mineral spirits are often used. You can also use mineral spirits as a thinner and in cleaning applications. Other petroleum-based solvents include alkanes or isoparaffins, xylene and acetone. Non-petroleum-based solvents can be turpentine or citrus oil. In water-based paints, you are still likely to find a small amount of solvents.
- Additives: This is where specific characteristics are added to paint, depending on the application. They can include biocides to prevent bacterial growth, silicones to improve resistance to weather and driers to accelerate the drying process.
If working with oil-based paints, you’ll likely need to use solvents to clean equipment and strip or thin paint. These substances tend to be hazardous materials. Their flammability and toxic chemical makeup usually make them a subject of the EPA’s guidelines. The first thing you can do when working with solvents is to reuse them as much as possible. You can reuse solvents by allowing the paint solids to settle. Then you can strain them out and use this for part of your cleaning process. Though, it is probably a good idea to stick to completely clean solvent for the final wash.
You can also distill your solvent on- or off-site. Distilling solvents works by heating the solvent. As it warms, it starts to evaporate. The vapors are then collected and returned to a liquid as clean material. This process, of course, diminishes the return each time you run it, but can still save you some solvent in the long run.
Rags and towels that become contaminated with solvent cannot typically be thrown into the trash. If you want to do that, you’ll need to prove that they are not hazardous, which they often are. If that’s the case, you’ll need to dispose of them properly or clean and reuse them appropriately.
Any water runoff that comes from cleaning brushes, sprayers and other equipment is also subject to regulation. You cannot discharge industrial wastewater into the ground, storm sewers or on-site septic systems. Any leaching chemicals could impact water supplies or soil if you do this. If you are generating wastewater at your main business location, such as through equipment cleaning, you have a couple of options.
You may want to try contacting your public wastewater treatment plant if your facility is connected to one. They may be able to accept wastewater, but could also require you to perform a pretreatment process. This process would remove the materials that the plant is not designed for, such as metals and chemicals. You will want to obtain permission before generating the wastewater. Another approach is to collect your wastewater in a holding tank and dispose of it through a waste disposal company.
Both of these are services we offer. ERC can process any nonhazardous wastewater you have with a three-stage dissolved air flotation system. Our facility can handle over 110,000 gallons of liquid waste per day and sends the resulting waste to a Subtitle C landfill.
Paint Booth Filters
If your operation uses paint booths to cover projects, you probably go through quite a few paint filters. These filters catch large amounts of aerosol particles and keep them from getting out into the surrounding environment. That means that they become contaminated with potentially hazardous material. However, these are often considered nonhazardous, and you may be able to simply throw them away. You’ll have to check your paints and be sure to dispose of your filters appropriately. If your paints use heavy metal pigments, like lead, chromium or cadmium, the filters may be hazardous, depending on how much is present in the filter.
3. Contaminated and Unused Product
Paint waste disposal includes more than getting rid of actual paint. Residual paint waste may be present in your containers. You’ll need to make sure you properly dispose of any containers that hold or previously held paint.
Empty containers can only be considered empty if they meet one of the following criteria set by the Resource Conservation and Recovery Act (RCRA) of the EPA:
- All wastes have been removed using standard industry-wide methods, such as pouring and pumping.
- No more than 1 inch of material remains in the container or liner.
- No more than 3% by weight of the container remains for containers 110 gallons or less and no more than 0.3% for containers greater than 110 gallons.
Once your container is considered RCRA empty, you can dispose of it like regular solid waste and chuck it in the trash. Or, a more environmentally thoughtful approach would be to recycle it as scrap metal.
About 80 million gallons of paint — 10% of all household paint — goes unused each year. And that’s just within the home. Businesses generate their own share of unused paint. There are several ways you can reduce, reuse and recycle your unused paints.
First, reduce the amount of paint you buy. Only purchase what you need. If you still end up with extra, unopened paints, return them to the vendor. They can often resell these and avoid even making them waste in the first place.
For the smaller amounts of leftover paint, you can also reuse it by keeping some around and using it for touch-ups or as a primer. If your application isn’t too picky on color, you may even be able to recycle latex paint by combining paints and mixing them thoroughly. If none of those apply, try donating it. See if any organizations need that extra flamingo pink paint you’ve got. Churches, schools, shelters and Boys & Girls Clubs are good places to start.
If none of these options work, you’ll have to make sure you dispose of the paint properly. The easiest way to do this is by letting a skilled industrial waste facility come to collect it. An environmentally conscious company with experienced, trustworthy team members and over 30 years in the industry would be a great choice if you’re in the Mid-Atlantic area.
Remember that you cannot just throw your leftover paint away or pour it down the drain — it needs to go to an authorized waste facility.
You can turn your paint into regular solid waste, but these methods are only practical in smaller amounts and are simpler with latex-based paints.
- You can take a surface like cardboard or plastic and paint thick layers onto it. Once it is dry, you can throw it out like anything else.
- Fill up a box or your paint container with newspaper scraps or kitty litter along with your excess paint. Mix it all up and let it dry. After it dries, this too can be thrown away as solid waste.
- Purchase waste paint hardener, which will dry up your paint while it is still in a larger batch for easy disposal.
At large facilities, aerosol cans can account for almost 40% of retail items that are managed as hazardous waste. These cans must be disposed of by an authorized hazardous waste management facility unless they are RCRA-empty. Achieving this is a little more difficult with aerosols, which must meet the following criteria:
- They cannot contain any compressed propellant.
- They must have the product completely dispensed.
- They can have no more than 3% of the original capacity of the full container or 1 inch of residue remaining.
If all materials have been emptied from the can, they can be thrown out or collected as scrap metal. Due to their nature, emptying and depressurizing aerosol cans can sometimes be a delicate process. The best approach is to leave it to professionals, like ERC, who have the devices needed to perform this procedure safely.
If you have materials sitting around and waiting to be disposed of by an authorized facility, you’ll need to store them appropriately until then. Ensure tight-fitting lids are on all paint cans and you’ve labeled them correctly. Any container you store material in must be suitable for the content, meaning that a substance that corrodes plastic should not be placed in a plastic container. Pay attention to warning labels and the temperature the material will be stored in.
Your labels need to be maintained appropriately and consistently across your operation. Be sure to include the following information on any hazardous waste labels:
- The label “Hazardous Waste”
- The accumulation date, or when you started collecting the waste — this ensures you aren’t storing the waste for longer than permitted
- The generator’s name and address information
- The composition and physical properties of the waste
- Warning statements that apply to the waste, such as flammable or toxic
- Manifest document number, for when it is collected
Paint and the Environment
While meeting regulations is a necessity for your business, it is also a valuable part of helping the planet. Even if you meet compliance standards, sometimes there is still more that you can do for sustainability efforts. Increasing sustainability can provide your business with a green reputation to increase your customers’ trust. Understanding how your operations affect the environment is a great first step.
1. Paint Stewardship
In efforts to reduce the amount of paint being disposed of and the burden on household hazardous waste programs, nine states and the District of Columbia have passed paint stewardship laws. These laws work through extended producer responsibility, which requires paint companies to develop and manage paint stewardship programs.
A small fee is now attached to the sales of paint in areas with paint stewardship legislation. This fee goes toward the leftover paint management. If your operation is on a very small scale, you may be able to use the additional drop-off locations to your advantage, but don’t overload these facilities.
2. Disposal Methods
We’ve learned a lot about environmental impact since the days of throwing hazardous waste into the ocean. While disposal methods aren’t without their difficulties, they do allow us to get rid of waste in ways that aren’t as damaging to the planet. There are often tradeoffs, however, with benefits and drawbacks to each method.
Landfills are precisely what you picture — large piles of waste over a vast area. A significant concern about waste landfills, either hazardous or municipal, is the leaching of chemicals and waste material into the soil and environment. A landfill too close to an underground water supply could easily expose the water to unfavorable chemicals, endangering wildlife and any communities that rely on the water.
To prevent impacting the water health, hazardous waste landfills are double layered with a nonporous material, like high-density polyethylene resin (HDPE) or clay and equipped with leachate collection and removal systems. They also have leak detection, as well as run on, runoff and wind dispersal controls. These landfills are maintained after closure as well, with covers, leachate monitoring, groundwater monitoring and other benchmark testing.
An incinerator, boiler or industrial furnace uses combustion to dispose of materials. They are not sufficient for waste that contains metal, which does not combust. Some of these devices can be used for energy recovery in addition to waste management. Controlled combustion can recover energy from steam or heated gases, leading to a typical rate of 550 kilowatt-hours of energy per ton of waste. Though they’ve had a reputation in the past of being heavy pollutants, the Clean Air Act now regulates hazardous waste combustors. Harmful air pollutants are controlled and minimized through this legislation.
In an injection well, fluid is deposited underground into porous geological formations, such as deep sandstone or a shallow layer of soil. These wells can vary in complexity based on the geography and the type of material being deposited. This method is relatively safe and inexpensive and can be used to store carbon dioxide, as well as a variety of other purposes. The design of more complicated injection wells can provide multiple layers of protection through casing and cement. Some materials can be injected into other geologic repositories such as underground caves or mines.
3. Land Disposal Regulations
As a generator of waste, you may be subject to the land disposal regulations (LDRs). These apply to many generators that generate, treat, store or dispose of hazardous waste.
The LDRs spell out a few things you can and cannot do when disposing of your hazardous waste. The regulation requires waste undergo specific treatments before it is disposed of on land. These treatments include methods to remove certain hazardous characteristics, such as combusting the material to remove any ignitability. Mixed debris types or contaminants need to be treated for each type of debris or contaminant present. The dilution prohibition restricts waste handlers from diluting a hazardous substance instead of treating it. Impermissible dilution occurs when an ineffective treatment is applied that does not destroy, remove or permanently immobilize hazardous components. This definition does not include wastes that are aggregated or mixed during a legitimate treatment process.
The storage prohibition disallows extensive storage in place of proper disposal. Temporary storage is allowed to accumulate an amount sufficient for facilitating appropriate treatment, recovery or disposal. Materials must be stored in a tank, container or containment building. Anything held past one year must have evidence that storage is necessary for proper handling.
4. Lead-Based Paint
Lead-based paint was previously used for its strong, opaque color and water resistance. Before legislation banning it in 1978, lead paint was commonplace throughout homes and businesses and can still be a risk to anyone living or working in those environments. Today, very few industry-specific applications use it, such as on the hulls of ships due to its moisture resistance.
Lead is known to cause damage to the nervous system, including weakness in fingers, wrists and ankles. It can also cause a decrease in learning, memory and attention, as well as anemia, kidney damage and increased blood pressure. Children are especially vulnerable because of their developing nervous systems. They can see problems in mental development and stunted growth. Reproductive issues can also occur due to lead. Lead poisoning can be acute or chronic. Industrial environments see more chronic poisoning due to a gradual buildup, though particularly strong exposure in a work environment could lead to acute symptoms too.
The danger of lead is most pronounced when working on older structures where you will disturb the paint, such as by stripping it. It can also be present in chipping, peeling or flaking paint which commonly occurs in areas with high activity, such as a window that is opened and closed frequently.
As for environmental risks, lead can travel far in the air and does not break down, adhering to soil particles — 90% of lead dust in surface soil will remain for up to 200 years. Lead can also reach groundwater, harming wildlife and drinking water.
Most hazards with lead are exposed when it is disturbed, such as through chips or sanding. Here are some best practices to follow when working with lead:
- Cordon off the area. Wherever you’re working, you’ll need to make sure that you don’t spread lead paint around. You’ll want to cover any objects that you can’t move, including machinery or furniture. Seal off the work area with plastic sheeting and use your ventilation systems correctly. The goal is not to spread any lead dust around.
- Use a high-efficiency particulate air (HEPA) vacuum. A HEPA vacuum uses specially designed filters to keep the air free of any harmful particles.
- Strip paint safely. Chemical stripping will create less dust than sanding or grinding. Be sure to work wet by spraying down the surface, catch all the scrapings and dispose of them properly. Check your state’s regulations to see where that is.
- Keep workers isolated from the dust with disposable coveralls, goggles and full-face respirators.
- Have employees follow hygienic practices. They should maintain proper hand-washing procedures. Employees should also shower and change clothes before leaving the workplace to avoid bringing lead contaminants into the home.
- Do not allow any eating, drinking or smoking in these areas. These activities can more readily expose workers to the inhalation and ingestion of lead particles.
Symptoms of acute lead exposure include fatigue, headaches, irritability, metallic taste in the mouth and an upset stomach. Be on the lookout for these behaviors if working in a lead-exposed environment.
Those volatile organic compounds that we mentioned before are one of the primary reasons that you must treat oil-based paints so carefully. VOCs are harmful gases released by various materials during application and for some period after that. The solvents in oil-based paints usually have high quantities of VOCs, which evaporate into the air. Once there, VOCs react with nitrogen oxides and sunlight to produce ozone, a major component of smog in the lower levels of the atmosphere. Ozone is also damaging to the lungs.
Other solvents, like mineral spirits for cleaning and pigments or additives, can add VOCs to a paint. VOCs have seen growing regulation through National Volatile Organic Compound Emission Standards put in place by the EPA. These standards cap VOC limits on specific products.
ERC offers a complete turnkey solution to your paint waste disposal needs. We have a variety of removal services that include waste and sludge recycling, waste removal and sludge incineration. We have high-end supplies and expertly trained staff members who can dispose of paint in an efficient and environmentally conscious way. Here are a few of our tried and true methods.
1. Waste Drum Disposal
If you can put your hazardous or nonhazardous waste into a compliant disposal container, ERC’s waste drum disposal and recycling services can take it off your hands. Our collection, waste transportation and processing services apply to bulk and non-bulk containers. You can safely dispose of anything from a single tote to an entire truck full of waste drums. We can take all types of containerized waste, liquid or solid, in totes, drums, barrels, pails and any other DOT-compliant waste disposal container.
2. Facility Shutdown Services
A facility shutdown is a crucial component to keeping your operation running smoothly. You can’t correctly clean most machines unless you shut them down completely, and while not enjoyable, this step is vital in keeping your facility moving. ERC can employ dependable, efficient practices to perform the cleanup tasks needed in your facility shutdown. Some of these can include:
- Power vacuuming
- Line jetting
- Liquid waste removal
- Bulk solid waste removal
- Foundry sand removal
- Paint removal
- General industrial cleaning waste removal
The resources that ERC can provide are numerous. These include certifications like HAZwoper and confined space entry, top-of-the-line industrial cleaning machines and options for alternative waste treatment options.
3. Line and Pipe Hydro Jetting
One form of waste removal that we offer is line jetting, also called hydro jetting, water jetting or pipe jetting. This process is efficient for clearing clogged industrial drain lines and works by attaching a high-pressure water jet to your drain lines. It blows out any sludge, grease, scale, silt and other forms of debris. ERC has the equipment necessary to make this process fast and effective. While we can come to the rescue when you’ve encountered a massive clog that shuts down production, it is a smart move to prevent this in the first place. We can schedule regular visits and clear out the pipes before the sludge and debris has a chance to slow down your production.
4. Tank Cleaning
Whether you have a tank for water, chemicals, cargo, fuel or something else that needs cleaning, ERC offers safe and efficient service. We can clean out your tanks, keeping their capacity full and ensuring compliance. Then, we can dispose of any generated waste. We also offer industry-recognized frac tank cleaning so you can return it in the expected condition without any surprises.
Start Using ERC’s Waste Management Services Today
With the complex nature of national regulations and the chemistry of these dangerous materials, waste management can be a stressful task. Thankfully, ERC has expert technicians on hand and can give you the peace of mind you need to focus on what you do best. We’ll handle the messy stuff.
ERC offers full-service, dependable waste management services so your business can reach sustainability goals while staying compliant and safe. We can address all streams of residual waste — paint is far from our only area of expertise. To find out how we can help your Mid-Atlantic facility run more smoothly, contact a representative today.