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That depends on the paint.  Some "non-solvent" paints may be hazardous
waste.  I suggest that you perform a hazardous waste determination in accord
with 40 CFR 262, to determine if the waste is hazardous or not.  Useful
materials will include a detailed list of ingredients in the paint, an MSDS,
a review of how the paint is handled and used in your plant (what is added,
for example).  In particular, you should look to see if the paint includes
any of the RCRA constituents listed in 40 CFR 261.24.  If you are uncertain
how to adequately perform a RCRA hazardous waste determination, I suggest
you hire a consultant who is familiar with that process to walk you through
one and show you how to do it on your own in the future.

This is advice from a long-time management consultant on RCRA compliance
issues and is not legal advice, nor does it create any client relationship.


Ralph E. Cooper, Ph.D.
J.D. expected May 1999
Case Western University School of Law

14139 Woodstream
San Antonio, TX 78231
210-479-5490 (4)

-----Original Message-----
From: List Manager <listman@wmrc.hazard.uiuc.edu>
To: p2tech@great-lakes.net <p2tech@great-lakes.net>
Date: Tuesday, April 06, 1999 11:53 AM

>I am trying to switch my company from a solvent based paint to a water
>one. Even though water based paints have no VOC's, will I still have to
>ship the paint waste hazardous.
>Please advise.
>Lacy A. Meyer
>HTC X8678