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Maintenance and Renovation Projects: Paint Disposal

September 21, 2021

One of the hallmarks of 21st Century environmentalism is that almost anything you might use to clean, lubricate, or otherwise preserve your commercial or industrial facility & equipment is probably considered a hazardous waste if you have enough of it remaining after a project. 

Paint is a good example, which, per Webster, “…is a mixture of a pigment and a suitable liquid to form a closely adherent coating when spread on a surface in a thin coat,” as if that weren’t obvious to the most casual observer.

This blog will consider commercial or industrial paint disposal in three arbitrary categories: 

  1. Commercial/industrial disposal of latex paint
  2. Commercial/industrial disposal of oil-based paint
  3. Commercial/industrial disposal of industrial paint
  4. Commercial/industrial disposal of lead-based paint
  1. Industrial disposal of latex paints

Latex paints aren’t considered a hazardous waste by the EPA, so they’re typically unwelcome at hazardous waste TSDFs. Ironically, this can be more difficult to dispose of than oil- or lead-based paints, both of which shouldn’t be poured down the drain—literally speaking. 

For small quantities, the EPA suggests that you expose leftover latex paint to the air, or mix it with shredded newspapers, causing it to dry to a solid, and then just throw it away into your general waste stream, i.e. the garbage

But “small quantities” is the key term here, whereby the EPA is mostly talking about “household” amounts.  

To again invoke Webster, to most of us a “household” is prosaically “a social unit composed of those living together in the same dwelling.” But there’s nothing prosaic about EPA rules & guidance.

Per the EPA, “households” are “single or multiple residences, hotels, motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds, and day-use recreation areas.” 

So if yours is one of those, you’re golden. Otherwise, you need to get expert advice

Recycling latex paints

Latex paints are easily recycled—if you know the right people. (That would be us.) Solids are extruded from the paint, melted, and pelletized for use as colorants or additives in other recycled polymers. 

So there are companies eager to accept your leftovers, just to make them into something new that they can sell. To find a latex recycler near you, take a look here.

  1. Industrial disposal of oil-based paints

You’ve undoubtedly heard the term “oil-based paint.” It’s actually pigment particles suspended in oil. Its viscosity depends on solvents such as turpentine or white spirit; and varnish might be added to increase glossiness.

Relative to latex, oil-based paints dry to a smoother and glossier finish, with a harder enamel that’s more resistant to scratches and fingerprints. Viewed juxtaposed, many casual observers opine that the oil-based paint simply looks better than its latex counterpart.  

But there are problems.

Since the 1990s, the EPA has been focusing on “volatile organic compounds” (VOCs), which are found in things like glass cleaners, dishwasher & laundry detergents, fragrances, and other seemingly innocuous things.

VOCs such as mineral spirits, naphtha, lacquer thinners, and other stuff you wouldn’t think to imbibe are constituents of oil-based paints. And when wet oil-based paints dry, the VOCs vaporize, scurry up into the sky, and promptly begin depleting the ozone.

And by now you’ve undoubtedly heard the news about the ozone.

That’s why oil-based paints are nowadays relatively scarce, and/or only sold in small quantities (usually less than one quart). It’s also why it behooves you to treat any leftover oil-based paint as a hazardous waste. (Consider yourself behooved.)

To find a TSDF convenient to your worksite that handles oil-based paint, take a look here.

  1. Industrial Disposal of Industrial Paints

Industrial paints are pigmented liquids or powders for protecting substrates such as asphalt, ceramic, fiberglass, and metal. They provide heat resistance, rust prevention, waterproofing, fire-retardation, etc.

You’re probably conversant with industrial paints if you’re in the marine, medical, military, optical, pharmaceutical, semiconductor, or textile business. Ditto for aerospace, automotive, and electronics applications. 

If you’re using industrial paints, check out your leftover drums. If they say acrylic, epoxy, polyester, polyurethane, or polytetrafluoroethylene, then they belong to a gaggle of resins, solvents, additives, and pigments that are of existential interest to the EPA.

 Although any one of these chemical constituents mightn’t be a listed hazardous waste per the EPA, it could nonetheless be considered a characteristic waste if it possesses one or more noxious “characteristics” such as corrosivity, ignitability, reactivity, and/or toxicity. 

The danger here is that it’s up to you to figure out whether your leftover industrial paint is a characteristic hazardous waste: a requirement you must meet within a specified timeframe so that the paint “characteristics” don’t change over time.

Also, you can’t make this determination if the paint has been inadvertently mixed with some other waste, which would make it an entirely new & different toxic muck requiring more-complicated chemical analyses.

Clearly—as in all things regarding hazardous waste (in specific) and the EPA (in general): you need to get expert advice.

  1. Industrial disposal of lead-based paint

Up until 1978, lead was used as an additive to paints and primers to speed drying, increase durability, maintain a fresh appearance, and resist corrosive moisture. You might think that anything so useful would be an environmental pariah, and you would be correct—in spades.

Odorless, tasteless, invisible, and highly toxic, lead dust disperses into indoor air undetected. Thus, you can be breathing lead dust and absorbing it through your skin. And the health dangers are serious and lifelong.

As well as in homes & apartments, lead poisoning is a problem in offices, factories, and other commercial spaces, which is why OSHA has extensive rules regarding how much lead dust an employee can be exposed to during a workday (S.N. 1926.62).  

BTY, lead paint is still used for road markings, military equipment, and other heavy-duty applications. So be on the lookout. It’s still around.

Lead-based paint removal entails special procedures

The EPA Lead Renovation, Repair and Painting (RRP) Rule establishes regulations for contractors, property managers, and others who disturb painted surfaces while performing renovations on properties constructed before 1978. 

This is because the chipping, scraping, and sanding required to remove deteriorated lead-based paint from walls (to prepare them for latex paint) creates toxic dust, chips, flakes, and wastewater that must be properly managed and contained.

The work must be done by hand, without power tools, and the area must be isolated to minimize dust created and dispersed into the air. Carpeting, furniture, and fixtures need to be protected with poly covering. Warning signs should be posted; and there are specific cleanup procedures. 

This RRP rule includes education, training, and work-practice mandates, as well as requiring lead-paint certification for any person, firm, or sole proprietorship paid to perform work that disturbs paint in any pre-1978 houses, apartments, schools, or childcare centers. 

Caveat: lead paint in good condition isn’t actually dangerous 

Because there’s no lead dust to consider, in-tact & well-maintained lead paint isn’t a problem; and it’s unlikely anyone’s going to eat it off the wall. You can just paint over it with modern latex paint when it’s time to redecorate. But lead dust is a significant problem during renovation or demolition of buildings. 

Chances are a building contains lead paint if it was built prior to 1978. That’s 40+ years ago. And since older buildings are the logical targets of renovation & demolition, lead-paint disposal is a significant tactical challenge to contractors, remodelers, renovators, etc.

Non-residential lead-paint might require hazardous waste disposal

Interestingly enough, lead-paint waste disposal is excluded from EPA hazardous waste management regulations if the waste comes from a residential household project. 

But lead-paint waste from commercial or industrial sources that are a consequence of renovation, abatement, or whole-building demolition projects might be subject to state and federal hazardous waste management rules. 

To make this determination, one must assay the lead-paint waste for lead toxicity, using the  Toxicity Characteristic Leaching Procedure (TCLP). This is a chemical analysis that simulates landfill leaching to yield a rating. 

The rating indicates the amount  of listed contaminants present in the lead-paint waste and thus likely to be absorbed by soil and groundwater. In the case of lead, 5.0 mg/liter or more indicates the waste has significant lead toxicity and thereby requires hazardous waste disposal.

The upshot

Regulations about industrial paint disposal are plentiful, evolving, and challenging to track. Ignoring or misunderstanding them can subject you to significant financial consequences.

If you have leftover paint and are unsure whether it requires hazardous-waste disposal, don’t take chances. Get expert advice

And thank you for reading our blog!

Disposal of hazardous waste doesn’t have to be painful.