Paint accumulation as a VSQG
Our facility is considered a VSQG. We have a small room that we keep our waste in until it is ready for pick up. We’ve been using that room to also store half empty gallons of paint, so it can dry out and we can just throw them in the trash. Is there anything wrong with doing that? We can accumulate quite a bit of paint at one time, and I just want to make sure we’re not doing something that would look bad to an inspector.
Answers
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Paints may be regulated as a “hazardous waste” when disposed of, depending on the formulation. Water-based paints are generally not regulated since they are nonflammable. So, in this case if you are disposing of water-based paints (that do not contain any regulated metals) allowing it to air dry before disposal is ok. However, it’s been my experience that an inspector will typically be looking at quantities since this method of disposal is approved for small quantities of water-based paint. You’ll also want to pay attention to the location. For drying purposes, the paint should be dried in a well-ventilated area. Keep in mind, oil-based paints cannot be dried and placed in the general trash.
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Dependent on your area, there may be requirements under the Clean Air Act. In Arizona, drying water-based paints as described is acceptable with RCRA regulators. However, Air regulators take a dim view of allowing VOCs to evaporate; any VOC-containing material needs to be in a closed container. Water-based paints contain a small percentage of VOCs.
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