I routinely monitor enforcement actions being taken by the NJDEP to see who they are citing and what the citations are. I ran across one recently and thought it was a great reminder about maintaining a log on the amount of hazardous waste you are generating each month. Painters typically use a solvent to clean their guns each day. While the amount used is small, it does add up.
In the enforcement action taken by NJDEP the cited company employed a small 2-gallon solvent recycling unit. Where the company got into trouble was failing to create a log inventorying the amount of waste solvent that is generated each day. Creating a log and recording the amount of solvent generated each day would be a simple solution, right? No, because you must think about the repercussions. Let’s say that you have the log, and you diligently record daily solvent usage. Your total at the end of the month before recycling is over 220 pounds. Guess what…you’re regulated as a small quantity hazardous waste generator, even though you have no hazardous waste on site because you diligently recycled your solvent waste every day. And since you are a small quantity generator, NJDEP would expect you to comply with all the hazardous waste regulations that apply to a small quantity generator including personnel training, emergency preparedness, periodic notifications to NJDEP and other regulations that apply to that category.
So, you have a decision to make, start keeping the log and make sure you have all the requirements in place or alternatively switch solvents. The solvents typically used by painters have a flashpoint below 140-degrees (F). Does it have to be so low? Can you use a higher flashpoint solvent well above the 140-degree threshold? Will making this switch keep you out of trouble…maybe! You still need to determine if the paint used is listed or has hazardous waste characteristics.
Compliance Over Penalties. By the way, the company was fined $3500.00 for not having the log in place. At enviroCOP we are here to help you with your permitting and compliance concerns, let us know if you have a compliance concern that needs our help! If you have any questions, contact us today at www.enviroCOP.com or by calling (609) 304-9662.
