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RE: alternatives to lead in autobody work

Hi Alice,
Very interesting results regarding lead content in paint booth filters. And I like the way TCLP testing is tied to a review of paint composition. It provides a motivating factor to not use certain products and it requires the users to be aware of what they are using. As for your HOC problem, it's probably driven by the VOC limits on paint.  Switching from a VOC to a HOC gets you under the pound per gallon VOC limit.
Now normally, the HOCs would just evaporate over time as the excess paint cures, but other air quality regs force the shop to bag or drum the filters as soon as they are removed from the booth. This is done to cut down on air emissions. Other regs then force the user to manage this waste as hazardous.  Another example of how compliance with one rule suddenly subjects you to others. I think that someone once tried to sue the air agencies over this issue but lost.  The view was that the air agencies had no right to control evaporative loss from the overspray since these emissions were already permitted back at the spray gun. I'm sure others have more insight into this. Thanks for the info.

Mike Callahan, PE
Jacobs Engineering
1111 S. Arroyo Parkway
Pasadena CA 91105
Business: (626) 568-7005
Fax: (626) 578-3550

-----Original Message-----
From: owner-p2tech@great-lakes.net [mailto:owner-p2tech@great-lakes.net]On Behalf Of Chapman, Alice
Sent: Tuesday, May 25, 2004 8:50 PM
To: p2tech@great-lakes.net
Cc: Hickok, Dave; Tomchick, Laurel
Subject: RE: alternatives to lead in autobody work

Hello P2 Tech'ers,
Our program recently completed a study of spent autobody paint booth arrestor filters, accessible on the web at:
A prior study was completed in 1994 (unfortunately not on the web, but I can send a copy by snail-mail to anyone interested.)  The 1994 study tested autobody masking waste and sanding dust also, but neither designated as hazardous waste.
In both studies for paint filters, TCLP lead did not exceed regulated concentrations, but TCLP chromium did.  The overall concentrations of metals in the recent study dropped quite a bit compared to the 1994 study.  For example, in 1994 46% of samples had detectable TCLP lead, while in 2004 only 13% of samples had detectable lead.  Here's a quick summary of chromium data:
Based on these study results, the Waste Characterization programs of Public Health - Seattle & King County and the Kitsap County Health District no longer require TCLP metal testing for all autobody paint booth filters being considered for disposal to the garbage.  Testing is only required if the shop is using a zinc chromate primer or other heavy-metal bearing paint (shops requesting clearance to put filters in the garbage have to check paint ingredients).
The real hot topic of the 2004 study was the presence of halogenated organic compounds (HOCs) at widely varying concentrations in paint booth filters.  HOCs are state-regulated dangerous waste in Washington.
Hope this sheds some light on your question.  It appears that paint & auto manufacturers have already made strides toward reducing heavy metals such as chromium and lead. 

Alice I. Chapman, PE
Local Hazardous Waste Management Program in King County
130 Nickerson St, Suite 100
Seattle, WA  98109-1658

206-263-3058, phone
206-263-3070, fax


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