Mr. Francis Quinn
Corpo Industries, Inc.
125 Roberts Road
Waltham, Massachussetts 02254
Dear Mr. Quinn:
As discussed in our telephone conversation on 1/20/80, paint wastes
(both from manufacture and use) have been temporarily suspended from the
lists of hazardous wastes (261.31 and 261.32) until further evaluation
is made on the hazardousness of these wastes. Therefore, as indicated
by 40 CFR 4614, January 16, 1981, (copy enclosed), all paint wastes except
as provided below which are hazardous* and which are used,
reused, recycled or reclaimed (UR3) are currently excluded from regulation under Parts 262 through 266 or Parts 122 through 124 and are not subject to the notification requirements of Section 3010 of RCRA. Exceptions to this are waste solvents which are still listed generically (F002 to F005) and which
if used, reused, recycled or reclaimed would be subject to a limited set of regulations (261.6(b)).
Please feel free to call me if you have any additional
Myles E. Morse
Environmental Protection Specialist
Waste Definition Program
Hazardous & Industrial Waste Division (WH-565)
* Each generator is still responsible to determine
whether his waste exhibits any of the characteristics of a hazardous waste
(i.e., ignitability, corrosivity, reactivity and EP toxicity), as provided
in 262.11 of the regulations.