DIY vs. Professional Waste Disposal: Which is Right for Your Cabinetmaking Business?

Hazardous waste disposal for cabinetmakers isn’t optional—it’s essential if you want to avoid fines, fires, and environmental headaches. From solvent-soaked rags to paint thinners, cabinet shops generate multiple types of hazardous waste requiring proper handling, storage, and disposal to stay compliant and safe. Q&As in this blog entry include:

1. What hazardous waste is most common to cabinetmaking?
2. What other hazardous wastes are common to cabinetmaking?
3. What is meant by “RCRA empty?”
4. How should hazardous waste be managed in cabinetmaking factories?
5. Does hazardous waste from cabinetmaking need to be classified?
6. What are the EPA labeling requirements for hazmat at cabinetmaking factories?
7. What are the DOT labeling requirements for hazmat at cabinetmaking factories?
8. What are the storage requirements for hazmat at cabinetmaking factories?
9. What are some do’s & don’ts for safe chemical storage in cabinetmaking factories?
10. Does a cabinetmaking company really need professional hazardous waste disposal services?

1. What hazardous waste is most common to cabinetmaking?

The hazardous waste most common to cabinetmaking includes solvents and finishing products. Among other environmental peccadillos, these are respiratory & skin irritants, flammable, and—should they find their way into the water table—harmful to aquatic life. They also smell bad, releasing toxic fumes into the immediate and greater atmosphere. Naming names, these bad actors include:

• Paints, stains, and varnishes that are oil-based and/or contain volatile organic compounds (VOCs)
• Paint thinners, lacquers, and strippers that contain toluene, xylene, acetone, or butanone [aka methyl ethyl ketone (MEK)]
• Adhesives and glues (especially solvent-based types)

2. What other hazardous wastes are common to cabinetmaking?

Perhaps the kinds of things you might never think of.

• Spray booth filters that are saturated with solvents and paint particles are flammable, and they can leach hazardous chemicals into the environment if disposed of improperly.
• Contaminated rags and wipes used with solvents or finishes take flammability one step further. Left in a pile, they can spontaneously combust, probably when nobody’s around to put out the fire.
• Airborne wood dust is a known occupational hazard and can be of interest to your friends at OSHA. Besides being highly combustible and a respiratory irritant, dust from hardwoods such as oak, mahogany, or teak can be carcinogenic; and treated or composite woods such as MDF and plywood can contain formaldehyde and/or other chemicals (see source).
• Used containers are considered a RCRA waste if they contain residues of paints, stains, varnishes, thinners, lacquers, strippers, adhesives, glues, etc. (see Q.1). In this regard, a container is not truly empty unless OSHA considers it “RCRA empty” (see Q.3). Otherwise, it’s a hazardous waste. We’re talking here about metal or plastic cans, along with tubes, drums, and partially empty aerosol cans.
• Batteries and electronics from cordless tools can contain lithium-ion, nickel-cadmium, or lead-acid batteries. These are toxic heavy metals that are characteristic wastes, in this case reactive and flammable.

3. What is meant by “RCRA empty?”

If a container that held hazmat is not “empty” per EPA standards, it’s considered a hazardous waste itself and must therefore be managed as such (an unnecessary expense). Let us explain:

The EPA prescribes three different “emptiness” standards that are necessary and sufficient to avoid hazardous material removal regulations. One is simply for “hazardous waste,” another for “acute hazardous waste,” and a third for “compressed gas hazardous waste.” Here, the conversation is limited to the first, “hazardous waste,” as that’s what’s most common in the small-to-medium world of cabinetmaking.

Under this standard, a hazardous waste container (or its inner liner) is considered RCRA empty after all possible waste has been removed from it by pouring, pumping, or suction so that no more than one inch of residue remains. This is prosaically referred to as the one-inch rule. But there’s more:

• For containers (or inner liners) up to and including 119 gallons capacity, applicable rules for hazardous material disposal still apply if what’s left represents more than three percent of the hazmat by weight.
• For containers (or inner liners) greater than 119 gallons capacity, applicable rules for hazardous material disposal still apply if what’s left represents more than three tenths (0.3) of a percent of the hazmat by weight.

These RCRA standards are also typically applicable where the residual hazardous waste is a mixture of both solid and liquid. However, as in all matters regarding hazardous material disposal, it’s crucial to get expert advice. (See source.)

4. How should hazardous waste be managed in cabinetmaking factories?

Foremost, you want to ensure that you have a disposal stream for hazmat that’s separate from the rest of your garbage.

This isn’t only for the obvious ecological and legalistic reasons. Separate waste streams are essential because any non-hazardous waste that you haphazardly mix with a hazardous one itself becomes a RCRA hazardous waste. And the more hazardous waste you generate, the more money you need to invest in hazardous waste management (in this case, unnecessarily).

For example, paint waste can be disposed of into your municipal waste stream if it’s of the latex variety. (The EPA’s high-tech suggestion is that you mix it up with some shredded newspapers and stick it in the trash. Easy enough.) But if your airless-sprayer jockey innocently dumps ten gallons of latex glop in with some adhesive wastes (e.g., formaldehyde and/or resins), such will increase your amount of RCRA hazardous waste by exactly that amount.

To see how such largess can play out monetarily, note that the average cost-per-gallon to dispose of toxic, reactive, and/or regulated substances (e.g., PCBs) is about $10 to $50+ per gallon. Doing the math, looking at the midpoint of that range ($30), that’s $300 you wouldn’t have had to spend.

Guessing that you’re an entrepreneur operating a small-to-medium cabinetmaking manufactory—and not the COO for IKEA—that’s serious money. So, unless you have money to burn (which, BTW, might yield a hazardous waste), keep your nonhazardous waste as far away from its hazardous counterparts as practical.

Another consideration: Haplessly inflating the amount of hazmat you generate can bump you from one generator category up to another, commensurately adding unnecessary costs & complications to your hazardous waste management efforts. By way of review:

• You’re considered a VSQG if you generate 220 lbs. or less of hazardous waste per month…
• An SQG if you generate between 220 and 2,200 lbs. of hazardous waste per month; or maximally 2.2 lbs. of acutely hazardous waste per month…
• And an LQG if you generate more than 2,200 lbs. of hazardous waste per month, or more than 2.2 lbs. of acutely hazardous waste per month.

5. Does hazardous waste from cabinetmaking need to be classified?

Yes, and with good reason.

Concentrated amounts of hazmat resulting from cutting, gluing, sanding, and/or finishing wood can be chemically reactive. This means that juxtaposed, they do not play nice together. What follows are some ill-advised combinations and their respective consequences, each of which is guaranteed to ruin your whole day. And they are:

• Acidic cleaners or strippers + alkaline cleaners (e.g., ammonia) = violent neutralization reactions, heat, fumes
• Oil-based paint or stain waste + oxidizers (e.g., bleach, peroxides) = fires and explosions
• Solvent-based adhesives or thinners + strong acids (e.g., muriatic acid) = flammable vapors and exothermic reactions
• Aerosol cans (e.g., spray lacquer) + heat or direct sunlight = explosions due to pressure build-up
• Wood dust + finishing solvents (lacquers, MEK) = risk of dust ignition
• Hydrogen peroxide (for bleaching wood) + organic solvents (e.g., acetone) = fires and potential explosions
• Metal dust (e.g., from hardware grinding) + strong oxidizers = fire and potential explosions

6. What are the EPA labeling requirements for hazmat at cabinetmaking factories?

A container used for chemical hazmat storage must be marked with the words “Hazardous Waste.” It must also exhibit the starting date for its accumulation along with information about its contents (e.g., toxic, reactive, ignitable, or corrosive).

If you’re reusing a container, make sure to remove old labels. And whether new or used, make sure to place a label on a container the very first moment that a hazardous waste is placed inside it. Otherwise, you’re out of compliance.

Note that EPA labeling requirements differ depending on the amount of chemical hazmat you generate. In this regard, the EPA specifies two categories: Bulk packaging and Non-bulk packaging.

Loosely speaking, non-bulk packaging dictates a maximum capacity of 119 gal. for a liquid waste (450 L); a maximum of 882 lbs. for a solid waste (400 kg); or a water capacity of 1,000 lbs. for a gaseous waste (454 kg). Thereby, bulk packaging is anything that exceeds these quantities.

As in all things involving the EPA, it’s crucial to get expert advice.

7. What are the DOT labeling requirements for hazmat at cabinetmaking factories?

Per the DOT, hazmat containers must be clearly labeled with this notice: HAZARDOUS WASTE—Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.

Labeling must be durable, clearly visible, and written in English. It must be displayed on a contrasting color background and not be obscured by other labels, attachments, or advertising.

Additionally, the container must clearly show your company’s name, EPA identification number, and manifest tracking number. There might be additional requirements for bulk packaging containers.

8. What are the storage requirements for hazmat at cabinetmaking factories?

As a small-to-medium size cabinetmaking enterprise, you’re probably a VSQG or an SQG. That said:

• A VSQG can store up to 2,205 pounds of non-acute hazardous waste or 2.2 pounds of acute hazardous waste onsite at any time. Additionally, VSQGs must meet monthly generation limits of less than 220 pounds of non-acute hazardous waste and less than 2.2 pounds of acute hazardous waste.
• An SQG can store up to 13,200 pounds of hazardous waste onsite, or 2.2 pounds of acutely hazardous waste, but the accumulation time limit is 180 days, unless the waste needs to be transported more than 200 miles. In such a case, it can be stored for up to 270 days. As an SQG, you must have an EPA Identification Number (see Q.10).

9. What are some do’s & don’ts for safe chemical storage in cabinetmaking factories?

We were hoping you would ask that:

• Check regularly for spills, leaking containers, improper temperatures, etc.
• Dispose of expired chemicals, following hazardous waste removal rules.
• Ensure that all incompatible chemicals are segregated by hazard class codes.
• Label all chemicals with Material Safety Data Sheets (MSDSs).
• Never store chemicals on the floor, nor any higher than eyelevel.
• Post appropriate signs (e.g., No Smoking, Flammable Liquids, Acids, Corrosives, Poisons, Chemical Storage, etc.).
• Shelves should be firmly anchored to walls and have anti-roll lips.
• Store similar chemicals together, but away from others that might react if mixed.
• Store liquids in unbreakable or double-contained vessels, or in a storage cabinet that can contain the spill should the container fail.
• Use storage cabinets designed specifically for flammables.

10. Does a cabinetmaking company really need professional hazardous waste disposal services?

DIY hazmat management—sounds dangerous, doesn’t it?—could be feasible if your business is a VSQG that only uses non-hazardous and/or low-toxicity materials.

You should also have a dedicated safety/environmental compliance officer onboard, as well as someone who’s conversant with the relevant legal, transportation, and safety issues that come courtesy of OSHA, the DOT, the EPA, and their respective state & local cohorts.

Otherwise, hiring a professional hazardous waste management company is the better and safer choice—especially if you’re generating even moderate quantities of hazardous waste or don’t have in-house environmental expertise.

Here’s what a professional hazardous waste management service will do for your cabinetmaking enterprise:

• Regulatory compliance. Properly licensed & certified hazardous waste management companies are well-versed in EPA, OSHA, DOT, and local environmental regulations, all of which reduce the probability of mistakes in labeling, storage, or manifest documentation, which can result in fines or liability.
• Proper disposal and tracking. Even minor errors in disposal or tracking can be a major liability. Properly licensed & certified hazardous waste management companies will handle manifest creation, transportation, disposal, and—most crucial for audits or inspections—recordkeeping.
• Reduced risk. A properly licensed & certified hazardous waste management company will provide efficient and cost-effective services for fulfilling your EPA “cradle-to-grave” responsibilities, all carefully vetted for financial references, insurance, letters‑of-credit, employee-training, licensing, and more.
• Cost efficiency. While it might seem more expensive upfront, hiring a properly licensed & certified hazardous waste management company can help reduce your long-term compliance costs, as well as show you ways to reduce hazmat generation in the first place (e.g., via recycling/reuse programs).
• Convenience. Juggling compliance, transport, documentation, and disposal for hazmat is time consuming and error prone. Scheduling regular pickups, audits, or emergency spill response through a properly licensed & certified hazardous waste management company simplifies operations and mitigates risk.

Hazardous Waste Experts is a technology-enabled waste management service provider. We supply a one-stop solution for hazardous and regulated waste removal, transportation, and disposal.

We offer nationwide coverage and unsurpassed expertise managing a wide variety of hazardous materials to help your cabinetmaking enterprise meet its EPA “cradle-to-grave” responsibilities for hazmat removal, transportation, disposal, and recycling.

Contact us today—or call us at our new number: 425.414.3485.

And thank you for reading our blog!