Metal Finishing Guide Book

2012 Organic Finishing Guidebook Issue

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Occupational Safety and Health Administration (OSHA) rulings, the Resource Conservation and Recovery Act (RCRA), and the Comprehensive Environmen- tal Response Compensation and Liability Act (CERCLA), as well as under state and local regulations aimed at controlling emissions. Fortunately, these regulations are manageable because a great deal of assistance is available to help companies reach full compliance. The following are the federal regulations governing the chlorinated solvents (see Table II). The Clean Air Act Amendments (CAAA) of 1990 legislated the phase- out of 1,1,1-trichloroethane as an ODS as of December 31, 1995. VOC regulations under the Act apply to TCE and limit its emissions, partic- ularly in ozone-nonattainment areas, in order to reduce smog formation. Exact requirements vary by state but generally include obtaining a permit allowing a specific amount of VOC emission from all sources within a facility. The CAAA also calls for MEC, PCE, and TCE to be regulated as hazardous air pollutants (HAPs), but a complete set of regulations has not yet been issued for their control. EPA has, however, issued National Emission Standards for Haz- ardous Air Pollutants (NESHAP) for solvent cleaning with chlorinated solvents (Federal Register, Vol. 59, No. 231, 61801-61820). Other NESHAPs have been is- sued governing dry cleaning with PCE and the use of MEC in aerospace manu- facture and rework, while NESHAPs governing the use of chlorinated solvents in wood furniture manufacture and asbestos brake cleaning are still awaited. Clean Water Act. The Federal Clean Water Act defines chlorinated solvents as toxic pollutants and regulates their discharge in to waterways. The Occupational Safety and Health Administration (OSHA) has set permissible ex- posure limits (PELs) for chlorinated solvents based on an 8-hour time-weighted average (TWA). The PEL for MEC is 25 parts per million (ppm), for PCE 100 ppm, and for TCE 100 ppm. OSHA also specifies a minimum element of training for people working with the solvents. This includes how to detect the presence or release of a solvent, the hazards of the solvent, and what protective measures should be used. OSHA's Hazard Communication (HAZCOM) standard regulates the labeling of all hazardous chemicals. Labels must contain a hazard warning, the identity of the chemical, and the name and address of the responsible party. Guidelines are provided by an OSHA compliance document [OSHA Instruction No. CPL- 2-2.38 C (1990)] and by the American Standards Institute (ANSI) publication on precautionary labeling (ANSI Z129.1-1994). Under the federal Resource Conservation and Recovery Act (RCRA), wastes con- taining chlorinated solvents from solvent cleaning operations must be consid- ered hazardous waste. Generators, transporters, and disposers of such hazardous waste must obtain an EPAID number. According to the Comprehensive Environmental Response, Compensation and Li- ability Act (CERCLA or Superfund), if are portable quantity of a chlorinated sol- vent is released into the environment in any 24-hr period, the federal, state, and local authorities must be notified immediately. Reportable quantities are 1,000 lb of MEC and 100 lb of PCE or TCE. This is only a checklist of regulations. It is important to confer with your en- vironmental consultant or your legal counsel to determine just how these regu- lations apply to your business. Other sources of help and advice are also available. For example the CAAA man- dated a Small Business Ombudsman under EPA and a Small Business Assistance 20

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