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by Ron Joseph

December, 2005

Hazardous Waste Disposal of Paint

Q. I am working with a company in New York that paints metal products and they recently asked me if all paint waste has to go in their hazardous waste container. They understood that paint residues from spray gun cups, cleaning solvent /paint mixtures and anything other than residuals left in the coaing product cans/drums should go in the haz waste drum. However the question came up about unused portions of 2 part catalyzed clear coats that react and harden quickly. While the gun washings mixed with solvent are clearly hazardous, would a few ounces of clear coat pored off into a paper cup to harden be considered a hazardous waste?

A. The only true method for determining the answer is to send a sample of the cured paint to a laboratory and have them perform the TCLP test procedure. If the sample fails, then they will be required to send the cured paint off to the hazardous waste site. My guess is that because the solid cured paint will entrap solvents that cannot get out immediately, but will evaporate slowly through the surface of the coating, it should be considered a hazardous waste.

Best wishes,

Ron Joseph


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