HazardousWasteMinimizationChecklist andAssessment ManualforAuto Paint Shops

CALIFORNIA DEPARTMENT OFTOXIC SUBSTANCES CONTROL

JULY 1992

ACKNOWLEDGEMENTS

This document was prepared by the California Department of Toxic SubstancesControl. The Department expresses appreciation to J. Rodney Marsh, Julio Nuno, andCarol Votaw of SCS Engineers for preparation of the “Waste Audit Study-Automo-tive Paint Shops”.

DISCLAIMER

The mention of commercial products, commercial services, their sources and/or theiruse in connection with material reported herein is not to be construed as actual orimplied endorsement of such products or services.

TABLE OF CONTENTS

I.I. IntroductionHazardous waste has become a major issue throughout the nation. Problems ariseduring its generation, transportation, and disposal. The preferred method of hazardouswaste management is one that takes into account pollution prevention. Pollutionprevention is simply an ethic that says the hazardous waste manager should controlreleases of polluting elements to the environment as much as possible. This includesthe air, water, and land.

Waste minimization is an aspect of pollution prevention. Waste minimization in-cludes source reduction and recycling. This means finding ways to generate lesswaste and then recycling the remaining wastes whenever possible. The purpose ofthis handbook is to provide the information auto paint shops need to minimize theirhazardous waste. It intends to promote voluntary waste minimization and pollutionprevention. However, many benefits can arise from implementing the suggestions inthis handbook.

Waste minimization can help your company achieve compliance with regulatoryrequirements, lessen time and money spent in managing hazardous wastes, anddecrease short- and long-term liabilities. In some instances, it might even allow smallquantity generators to drop out of the regulatory loop altogether.

The waste streams that are addressed in this handbook are the major wastes generatedin auto paint shops. They include:

solvents (including thinners),paint wastes,catalysts, and,other wastes including freon and antifreeze.

This handbook is intended to be used by the auto paint shop manager and shared withthe shop’s employees. It is organized in two parts. The first part of the handbook isintended for all shop personnel. It consists of the Waste Minimization Checklistwhich includes general suggestions for reducing hazardous waste. To emphasize theuse of the checklist, the shop manager may wish to make copies of this section anddistribute them to the employees.

The second part is to assist the manager or foreman in conducting a more in-depthanalysis of possible waste minimization options. It consists of an Economic AnalysisWorksheet and Technical Options Worksheet.

The implementation of ideas set forth in this manual may aid in decreasing yourwaste management costs by using sound environmental practices.

Il.Il. Waste Minimization Checklist for Auto Paint ShopsSOURCE REDUCTION

Source reduction means generating less hazardous wastes by preventive means. If lesshazardous waste is generated, then there will be less hazardous waste to manage. Forauto paint shops, source reduction can be achieved using several approaches:

l controlling inventory and material usagel employee trainingl storing waste properlyl modifying equipment

The preferred answers are in bold printand comments are provided nextto the checkmark.

Controlling Inventory andMaterial Usage:

1. Do you purchase onlywhat you need so that youdon’t end up with expiredmaterials?

2. Do you have a “first-in,first-out” material usagepolicy?

3. Do you conduct periodicinspections of materials instorage?

4. Are material inventoriescomputerized? Do youtrack the usage of rawmaterials?

a Purchase only the amount of materials that you knowyou will be using in the near future. Taking advantageof volume discounts for material purchases can lead tostockpiling of hazardous materials. These materials inturn may require costly hazardous waste disposal.Keeping only necessary materials on hand also helpsencourage careful use.

a Using materials that have closing expirationdates first will allow you to avoid needing todispose of outdated materials.

a Periodic inspections will help you detectcorroding containers and avoid expiring materials.

a Tracking is a good tool for hazardous materialsmanagement. It will help you order only what isnecessary, use the materials with the oldest expira-tion dates first, and make inefficient operationsand use of materials more obvious.

5. Do you limit raw materialaccess?

6. Are employeesencouraged to promotegood housekeepingpractices?

7. When cleaning your spraygun, do you save theunused paint from the gunand feed tube?

8. Do you followmanufacturer-suggestedmethods for cleaning andusing your spray gun?

a Limiting access to raw materials can help toencourage conservation of material use. It willalso give the shop foreman an opportunity tomonitor material use. However, in smaller shopswhere the foreman or owner can monitor theemployees, access to materials does not necessar-ily need to be limited. The foreman or owner canmake verbal or written comments on materials useand suggested limits.

a Preventing and controlling leaks, carefulproduct transfer, and careful drum transport aregood housekeeping methods that are all effectivemeans of waste minimization. Employees shouldbe encouraged to handle and maintain materialsand equipment conscientiously.

a The method for saving the paint left in thespray gun depends on the type of gun you use. Ingeneral, if you are using a suction-feed gun, youcan loosen the cap, close the spray hole, and thenpull the trigger to force paint back into the can.Whether you have a suction-fed or pressure-fedgun, you should be able to return the unused paintby “blowing back”. This is important because itsaves thinner that is used to clean the spray guns.(It also saves a little paint.)

a It is important to follow manufacturer’s sug-gested procedures. They are intended to maximizeefficiency and minimize waste.

9. Do you have set methodsfor cleaning paintingequipment such as nozzles?Are they cleaned immedi-ately after completing thetask? Is there a scheduledmaintenance and cleaningprogram?

10. Do you plan your paintmixing so that you will onlyuse the necessary paintsand solvents?

Employee Training:

11. Have the shop’semployees received wasteminimization and wastemanagement training?

Waste Containment andStorage:

12. Do you collect leakingoils, antifreeze, and otherfluids from automobiles?

a In some instances, having a scheduled mainte-nance and cleaning program for nozzles and otherpainting equipment (and parts) can have a pro-found impact on reducing hazardous wastes.Painting equipment should be cleaned immediatelyin order to reduce the amount of solvent that willbe necessary to clean the part.

a Planning is the key to using paints in an effi-cient manner. Plan your mixing so that you useonly the necessary paints and thinners. A properlysized container will also reduce waste.

a Employees need to be trained in how to handlehazardous materials in a way that minimizes waste.Written instructions remind employees of wasteminimization and allow them to review the instruc-tions when necessary. Letting employees know oftheir specific responsibilities will also help themunderstand their role in waste minimization. Theyshould be made aware of the importance of pollu-tion prevention. In some cases, chemical suppliershave training films that can be used for employeetraining.

a Use drip pans and containment areas so that youwill not have to use an absorbent to soak up spills.Absorbent contaminated with oil or other hazardousfluids must be handled and disposed as a hazardouswaste. Collecting and containing any leaking fluidsalso means that you will not have to wash a spillinto the drain which can pollute water.

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13. Do solvent, thinner, and a Significant amounts of materials can evaporatewaste containers have when lids are left off cans and drums. Mosttightly fitting lids to preventevaporation?

solvents and thinners evaporate much faster thanwater. When these materials evaporate, theypollute the air.

14. Are the proper tools andprocedures available tomove drums safely?

a Powered equipment or handtrucks should beused to move drums so as to prevent damage orpunctures. Under no circumstances should drumsbe tipped or rolled, even when empty. Negligenttransport procedures will cause drum damage,particularly to seams, which could lead to leaks orruptures during future use. Drums should also becapped tightly before they are moved.

15. Are the different wasteskept separated?

a Keep wastes segregated so that they may bemore easily recycled. Two or more types ofwastes that are separately recyclable may not berecyclable if they are mixed during storage. In thiscase, you will have to dispose of them as hazard-ous waste at a much higher cost to you. Addition-ally, commingling of wastes may be illegal, ormay cause a chemical or thermal reaction if thewastes are incompatible.

16. Do you have a plan forstoring your hazardouschemicals?

a Keep hazardous chemicals segregated byhazard classes in order to minimize fire danger.Use the appropriate containers in order to mini-mize leaks. Build concrete dikes around thestorage area or use other types of secondarycontainment to ensure that leaks will be con-tained.

17. Do you give away yourexcess paints to customersfor touchups?

a Passing along small amounts of excess paint forcustomer touch ups will not only make yourcustomer happy, it will reduce the amount ofwaste that you will have to dispose.

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Equipment modification:

18. Do you have a varietyof sprayer cup sizes toprevent overmixing?

19. Have you consideredusing electrostatic paintguns or low volume, highpressure paint guns toreduce the amount ofoverspray?

20. Do you pay attention toadjusting your paint mix tothe proper sprayingviscosity before applyingthe coats?

a Using the proper cup size allows more completeuse of materials. It also means that you have toclean a smaller cup, thereby using less thinner.

Using an efficient sprayer can help you savepaint, reduce costs, and reduce the amount ofpollutants that escape into the air.

a Proper viscosity is vital to achieving a goodfinish. This will mean less repainting and thereforeless waste.

RECYCLINGThe majority of waste products generated by theauto body and painting industry are reusable orrecyclable. These wastes include paint and thinnerwastes, used oil, car batteries, and soiled rags.Paints used in this industry contain pigments whichare compounds of cadmium, chromium, zinc, andlead. Contaminated thinner containing paint sludgeis generated from paint operations as a result ofequipment cleanup, spills, off-spec paints, andexcess paint.

1. Are thinners and other a Some spent thinners and solvents can be usedsolvents saved and reused directly for other purposes before being sent to awhenever possible? recycler. For example, color-contaminated thinner

may be reused as an undercoating paint thinner.Also, some spent solvents may be used for equip-ment and parts cleaning. These solvents may be

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2. Do you reuse paints?

3. Are oils and antifreezecollected and recycled?

4. Do you make use of a“milkrun” recycler?

5. Do you use reusablecontainers?

6. Is there an opportunity torecover your solvents bydistilling them?

used in a counter-current rinsing system. The ideais to use the more contaminated solutions to cleandirty equipment and the less contaminated solventsto get relatively clean equipment ready for theirnext use.

a Compatible leftover paints can be mixed andused as undercoating.

a These liquids should be collected, kept sepa-rated, and recycled. All can be recycled back intouseable products. (Refer to the Waste ExchangeDirectory or recyclers directory.)

a There may be a company in your area thatspecializes in recycling oils, antifreeze, or otherautomotive fluids. Check your local yellow pagesunder “recycling”, or order a copy of the CaliforniaWaste Exchange’s “Directory of Industrial Recy-clers” from the Department of Toxic SubstancesControl. (See the last page of this handbook forordering information.)

a Disposable containers with hazardous materialresidues (other than paint cans with a thin drycoating of paint) must be disposed as hazardouswastes.

a Distillation is a well-established process forrecycling solvents. For some shops, it is economi-cal to do this onsite. See the economic evaluationworksheet (p. 11) to determine the benefits andcosts for your company.

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7. Have you consideredreclaiming your solvents bygravity separation?

8. Do you review wasteexchange catalogs to seeif there are materials yourshop uses that are anotherindustry’s waste product?

9. Do you send usedbatteries to a recycler?

a Gravity separation is an inexpensive form ofresource recovery that is relatively easy to imple-ment. This may be done onsite or offsite. Thinnersreclaimed using this process can be used as a washthinner. Wash thinners can be used for primercoats, undercoating, or for equipment cleaning.

a One industry’s waste can be another industry’sinput material, and is usually available at reducedcosts or free. For example, you may be able to pickup a solvent from an electronics manufacturer thatmay be considered unusable by the electronicsindustry, but very usable for parts and paint equip-ment cleaning. In this way, you can do your part toprotect the environment and save money at the sametime.

a Used batteries contain lead oxides and sulfuricacid, both of which are hazardous. These batteriescan be recycled by having them picked up bybattery suppliers, or you can bring them to batterywholesalers yourself without hazardous wastemanifesting or special registration.

III.III. Technical Options WorksheetAfter working through the checklist, use this worksheet to evaluate your options. Asyou can see, we have left the cost-effectiveness factor up to you. The values that havebeen pre-assigned are our best judgement of the proposed technique. You should feelfree to change these based upon your specific needs and situation. Use the EconomicWorksheet in the next section to assist you in estimating cost effectiveness. Werecommend that you use your final calculation for the payback period as your primaryguide for rating the cost effectiveness. Use a rating from one to five. Give the “CostEffectiveness” a high rating if you decide that the option you are considering will payback in a short period of time. If you decide that it is not cost-effective or would taketoo long to pay back, give it a low rating. Add the lines to total the rating for eachtechnique you investigate. Use these ratings to help you decide which techniques aregood for your company by selecting the ones with the highest ratings for final consid-eration.

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IV. Economic WorksheetThis worksheet can be used to calculate rough estimates of projected costs, savings,and payback periods associated with each waste minimization option. Theseworksheets do not take into account amortization, depreciation, or tax factors.

Waste Minimization Option:EquipmentInstallation lmplementation Costs=

UtilitiesProduction Down TimeConstruction Materials Capital lnvestment

OtherImplementation Costs: Annual Operating Cost Savings

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V. Additional Publications

Handling and Transport of Spent Lead-Acid Storage Batteries for Recycling (1991)Used Oil Filters: Handling, Storage, and Transport for Recycling (1992)Directory of Industrial Recyclers (1992)Used Oil: Handling, Storage, and Transport for Recycling (1992)

VI. Further Information

For further information write or call:

Department of Toxic Substances ControlP.O. Box 806Sacramento, CA 95812-0806(916) 324-1807

For information about your regulatory requirements, contact the DTSCRegional Office nearest you:

Region 1 Sacramento (916) 855-7700

Fresno (209) 297-3901

Region 2 Berkeley (5 10) 540-2122

Region 3 Burbank (8 18) 567-3000

Region 4 Long Beach (213) 590-4868

The Federal government also regulates hazardous wastes. For information call:

Environmental Protection AgencyRegion IX75 Hawthorne StreetSan Francisco, CA 94105(415) 744-1500

In addition to the State and Federal agencies listed above, some local agencies havejurisdiction over certain aspects of hazardous materials and waste management. Theseinclude sanitation districts, air quality management districts, regional water pollutioncontrol boards, and fire departments.

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