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Waste From Arts 

Background

See Resource Conservation and Recovery Act — General and Resource Conservation and Recovery Act — Solid and Hazardous Wastes.
                    

Key Concepts

See Resource Conservation and Recovery Act — General and Resource Conservation and Recovery Act — Solid and Hazardous Wastes.

Does this apply to my campus?

Yes. Some activities conducted in the studio and performing arts generate solid and hazardous wastes. Resource Conservation and Recovery Act (RCRA) regulations govern the management of these wastes, from the point of generation in the studio until the time of disposal. These regulations apply to all hazardous wastes, regardless of volume.

For example, wet chemistry photography wastes will include silver-bearing solutions. Federal RCRA allows for recovery of the silver under certain specific conditions. Silver recovery processes may require notifications and analyses. Get specific guidance before implementing any RCRA exemptions. However, RCRA regulations specifically cover silver recovery in 40 CFR 266.70.

Painting and lithography studios may generate flammable or corrosive wastes. Some inks, pigments, glazes, and paints contain toxic heavy metals. Experimental and art restoration processes may generate other kinds of hazardous wastes.

What do I have to do?

Perform hazardous waste determinations on all solid wastes generated by the various studio and performing arts activities.

Next, implement waste management practices prior to offsite disposal of waste. For instance, you might choose to accumulate wastes in the studios that generate them or move them to accumulation areas.

Also, you might include treatment as part of the studio operation or neutralize corrosive wastes in the studio or nearby. Conditionally exempt small-quantity generators (CESQGs) may perform other treatments to reduce hazard and volume of waste. Beyond elementary neutralization of corrosive wastes and treatment by CESQGs, most treatment options either require a permit or at least consultation with the state or federal RCRA enforcement agency.

The hazardous waste regulations also allow drain disposal of small amounts of wastes under specific conditions. The local sanitary sewer authority (publicly owned treatment works or POTWs) may have an ordinance that limits this practice. Land disposal restriction notifications may also apply. See Clean Water Act — Sewer Use (POTW).

Under federal rules, up to 55 gallons of waste may be stored in each Satellite Accumulation Area (SAA) in individual studios. You might decide that moving waste to accumulation areas more often makes studios safer and more efficient.

Activities in studios vary as new products and processes become part of the curriculum. Personnel change routinely, and new and visiting faculty may add new wastes to the existing list of waste streams. Update your management plan as needs change.

In any event, waste containers must remain closed, in good condition, and compatible with the wastes they hold. Containers must have labels that indicate their contents. You must dispose of studio and arts waste before applicable accumulation time limits pass.

Hazardous Wastes Typically Found in Arts

Art-Related Hazardous Wastes

Regulatory Description

Waste Codes

Solvents, thinners, paint and lacquer removers, aerosol can residues, perchlorate etches, etc.

Ignitable: Flash point < 140 ºF

D001

Acids, acid washes, etches, metal pickling brines, some photo chemicals, gum arabic, etc.

Corrosive: pH < 2 or pH > 12.5

D002

Sulfide toners, cyanide plating baths, aerosol cans, organic peroxides

Reactive: cyanides, sulfides, compressed gasses, materials that react spontaneously or with water

D003

Heavy metal pigments in dyes and paints, spent fixer, some photographic toners, ceramic glazes and frits, solders, fluxes, etc.

Toxic

D004–D043

Thinners and cleaning solvents, including methylene chloride, carbon tetrachloride, xylene, acetone, alcohol, etc.

Solvent waste: See 261.25 for specific list of solvents and solvent mixtures

F001–F006

Outdated products, including photographic chemicals, excess solvents, acids, etc.

Outdated or excess products in which the listed chemical is the sole active ingredient

U001–U409

Outdated cyanides

P001–P205 (acute hazardous)

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