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Empty Paint tins amount to hazardous waste?????
Rank: Forum user
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I am currently working overseas in Qatar and our clients environmental lead is insisting that all empty paint tins must be disposed of as hazardous waste .
I seem to remember when I last worked in UK around four years ago there was a simple rule of thumb that if the residue was less than 0.5% volume of the container it was classified as general waste. Can anyone point me in the right direction to confirm this or not?
Also I would appreciate it if anyone could give me a ball park figure of the different costs per tonne or volume between landfill and hazardous waste cell disposal.
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Rank: New forum user
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I agree with you. We scrape the tins out and then let them dry completely. We then squash them flat and they then can go in the general waste.
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Rank: Super forum user
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Packaging containing residues of or contaminated by dangerous substances waste code under thye list as waste regs and hazardous waste regs is 15 01 10* . These categories include such a broad range of potentially hazardous wastes that they should be considered under all the hazards "H1" to "H14", therefore ity is not accurate to state that if residue is less than 0.5%, then it is not hazardous waste as the threshold permitted depends upon the hazardous material.
For example, for "Hazard H7: Carcinogenic", if the concentration of any individual substance assigned R45 or R49 ≥ 0.1%, then it classified as Hazardous waste!
Please refer to:-
Appendix C - Hazardous Property Assessment
http://www.environment-a...ure/GEHO1105BJVU-e-e.pdf
Guide to hazardous waste
http://www.environment-a.../topics/waste/32200.aspx
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Rank: Super forum user
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Bill - always good to try and help those who do not know better, but depending on your relationship with the Environmental lead, If the client says Haz waste - then so be it
David
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Rank: Forum user
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Thank you for the quick responses gents, the two website links are very useful. Not quite sure about jumping through hoops just because the client says so. I am trying to arm myself with the relevant information to work it through together and come up with the correct decision.
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Rank: Forum user
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Consider a litre tin of your paint:
> More than 98% of it was spread over wood or metal surfaces in a thin film. Any volatile organics would quickly evaporate to the detriment of the environment, but nobody is bothered about that.
> Another 1% is washed off brushes, rollers, pads and kettles, perhaps using additional solvents. The resulting waste may have been pured into a drain, poured onto soil or otherwise disappears.
> An additional fraction of 1% will have splashed over the workman's overalls and the floor (when I'm painting this is far more than 1%, but I assume that you are dealing with professionals)
>> Now, you are worrying about the last remnants in the tin!
Bulk disposal is a necessary requirement and it is perhaps wrong, but understandable, that many will leave off the lid of pots of solvent-based paints to let them cure - to the detriment of the environment - before disposal as general, not hazardous, waste. After all, it is the volatile organics that are of concern and once they are gone the problem has largely resolved.
It is not right to defeat environmental protection in that way, but I understand that this is a commonly used and apparently legal loophole.
Perhaps these de minimis concentrations in otherwise empty tins really can be ignored
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Rank: Super forum user
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IanBlenkharn wrote:Consider a litre tin of your paint:
> More than 98% of it was spread over wood or metal surfaces in a thin film. Any volatile organics would quickly evaporate to the detriment of the environment, but nobody is bothered about that.
> Another 1% is washed off brushes, rollers, pads and kettles, perhaps using additional solvents. The resulting waste may have been pured into a drain, poured onto soil or otherwise disappears.
> An additional fraction of 1% will have splashed over the workman's overalls and the floor (when I'm painting this is far more than 1%, but I assume that you are dealing with professionals)
>> Now, you are worrying about the last remnants in the tin!
Bulk disposal is a necessary requirement and it is perhaps wrong, but understandable, that many will leave off the lid of pots of solvent-based paints to let them cure - to the detriment of the environment - before disposal as general, not hazardous, waste. After all, it is the volatile organics that are of concern and once they are gone the problem has largely resolved.
It is not right to defeat environmental protection in that way, but I understand that this is a commonly used and apparently legal loophole.
Perhaps these de minimis concentrations in otherwise empty tins really can be ignored
Interesting one this - As part of my company's 14001 certified EMS requirements we segregated empty paint tins (with the normal quantities of residue) from other waste streams and classified them as hazardous waste under EWC 08 01 11/12. The local LA told us not to treat empty paint tins as HW as they would be disposed of along with other 'domestic' waste streams. After discussions with SEPA it was confirmed that they would not seek to classify empty paint tins with minor quantities of residual content as HW under the EWC code mentioned and that the LA were correct. As a result, our empty paint tins are no longer segregated and are presumably just sent to landfill along with tattie peelings and empty crisp packets. EMS Inspectors questioned the situation but after a discussion with SEPA accepted our waste management arrangements were in line with the requirements of the regulatory body's instructions.
GC
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Rank: Super forum user
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IanBlenkharn wrote:Consider a litre tin of your paint:
Bulk disposal is a necessary requirement and it is perhaps wrong, but understandable, that many will leave off the lid of pots of solvent-based paints to let them cure - to the detriment of the environment - before disposal as general, not hazardous, waste. After all, it is the volatile organics that are of concern and once they are gone the problem has largely resolved.
It is not right to defeat environmental protection in that way, but I understand that this is a commonly used and apparently legal loophole.
Perhaps these de minimis concentrations in otherwise empty tins really can be ignored
Up until recently I might have concured with Ian, that is until I read through the three MSDS's for the paint tins in front of me. All three state to be disposed of as hazardous waste including empty tins. They all contain carcengenic compounds and hence the reason for the instruction to trat as Haz Waste.
Therefore in reply to the original posting, obtain the MSDS's for your tins of paint as they will give guidance as to how to dispose (at least the better ones will).
Badger
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Rank: Forum user
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That is an extremely uncritical approach.
Is the MSDS correct?
Does it refer to a drop of paint as a carcinogen (who on earth would that be on sale?), or a can full? What is the significant route of exposure? And why is it OK to smear it over surfaces in the home and ofice environment, and elsewhere, without constraint of restriction?
And if, just if, it is a carcinogen is that carcinogen mobile? Thus, does it leach from the paint, from painted surfaces or from ladnfilled tins?
Does the carcinogen - if there is one - cause further concerns in the environment or is the dilution factor and leachate management suffcient.
What if it is incinerated? Are the combustion products safe?
Some paints may have and MSDS that suggests they contain carcinogens. It seems unlikely, and may be an over-reaction to concern oneself without some proper evidence.
In the meantime, I expect that the government and its agencies will immediately close all B&Q stores, with a wide police cordon around their sites - last time I went there they were full of the stuff and peddling it to all and sundry without a word of caution!
And as for the manufacturers', I havent heard of any probems, but might expect that they would be dropping like flies by now.
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Rank: Super forum user
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I have been told that certain paints, in industrial settings, do contain carcinogenic or highly toxic ingredients. I have been told that many of the yellow paints contain lead chromate - the phrase used was 'don't chew an oil rig'.
However, paints approved for sale to the general public are, I am sure, more benign.
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Rank: Super forum user
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The question that needs to be addressed is not what the paint contains, but at what level is it bioavailable. Stainless steel is technically chrome-nickel-steel, i.e. contains two of our most common sensitisers. Yet stainless steel does not usually cause an allergic reaction, even in those who are already sensitised. The reason is that these chemicals are so tighly bound in the alloy that no molecules are being released. There is thus no significant exposure.
The fact that the safety data sheet shows the presence of a hazardous substance does not, of itself, indicate that this is bioavailable. I had to investigate a case of supposed occupational allergic contact dermatitis to a sensitiser in an epoxy impregnated carbon fibre mat in an aerospace plant. The investigation revealed that this was not bioavailable and thus not the cause of the skin problem, which was due to something else and not occupational.
Of course, it may not be bioavailable in the product as supplied, but may become so by virtue of what happens when it is used.
This is one reason why we need to treat safety data sheets with caution!
Chris
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Rank: Super forum user
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"empty" paint tins are not waste they are valuable scrap, about £2000 a tonne for stainless.
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Rank: Super forum user
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IanBlenkharn wrote:That is an extremely uncritical approach.
Is the MSDS correct?
Does it refer to a drop of paint as a carcinogen (who on earth would that be on sale?), or a can full?
And as for the manufacturers', I havent heard of any probems, ....
In response to my and Ian 's earlier comments the paints have been acquired as 'professional paints' as opposed to water base joe public types and one of the tins comes from company with D and a dog as part of their branding. As for the MSDS being correct the last update is shown as Dec2009.
Badger
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Rank: Forum user
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I would not change my opinion
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Rank: Super forum user
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They are not hazardous waste if they are empty or hasresidue in the bottom. If that was the case then when you decorated your house you would need to separate.
Even the fact that a company may use quite a lot it would still not be collected as hazardous it maybe collected under recycalable.
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Rank: Super forum user
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Providing there are no specific hazardous materials in the paint, such as lead or chromates, then cured paint is not hazardous in the European Waste Catalogue. Allowing small amounts of waste paint to dry out is far preferable to filling valuable hazardous waste sites with paint containers.
Householders themselves are not subject to the legislation - it is up to the LA team to deal with as the first person controlled by legislation to handle the domestic waste stream.
Having said that if the client is adamant then by all means charge the costs back to him as appropriate, subject to contract clauses though
Bob
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Empty Paint tins amount to hazardous waste?????
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