Thanks for the feedback Dave!
We haven't identified any new sources of halogenated compounds since the study. The ones that did come up (from product MSDSs) are:
- parachlorobenzotrifluoride (PCBTF), CAS 98-56-6, solvent used in low-VOC paints; however this compound is not expected to remain in a paint filter (all the ones we tested were quite dry & dusty, no significant solvent residues). Ironically, these can legally vent up the stack of the paint booth in our area, as long as the booth is registered with the local air agency.
- binder resin used in paint booth filter, "synthetic anoinic colloidal emulsion of vinyl chloride copolymer in water" with residual vinyl chloride monomer
- binder used in paint booth filter, "halogenated polymer, incorpoating Spo-Ax, an antimicrobial additive"... "burning characteristics: flame retarded, self-extinguishing"
- paint pigments: diarylide or phthalocyanine pigments, for example, hexadecachlorophthalocyanine, Pigment Green 7, Pigment Green 36, Pigment Yellow 12 and tetrachlorisonsolinone yellow
Washington regulates HOCs due to their environmental persistence. It's a very broad definition and captures lots of compounds not typically regulated in other states. Here are a couple of snips from Washington's Dangerous Waste Regulations
WAC 173-303-040, Definitions
"Persistence" means the quality of a material that retains more than half of its initial activity after one year (365 days) in either a dark anaerobic or dark aerobic environment at ambient conditions. Persistent compounds are either halogenated organic compounds (HOC) or polycyclic aromatic hydrocarbons (PAH) as defined in this section.
"Halogenated organic compounds" (HOC) means any organic compounds which, as part of their composition, include one or more atoms of fluorine, chlorine, bromine, or iodine which is/are bonded directly to a carbon atom. This definition does not apply to the federal land disposal restrictions of 40 CFR Part 268 which are incorporated by reference at WAC 173-303-140 (2)(a). Note: Additional information on HOCs may be found in Chemical Testing Methods for Designating Dangerous Waste, Ecology Publication #97-407.
WAC 173-303-100, scroll down to section (6) for concentrations at which they are designated dangerous waste.
Alice I. Chapman, PE
Local Hazardous Waste Management Program in King County
130 Nickerson St, Suite 100
Seattle, WA 98109-1658
From: Salman.Dave@epamail.epa.gov [mailto:Salman.Dave@epamail.epa.gov]
Sent: Thursday, May 27, 2004 5:41 AM
To: Chapman, Alice
Cc: Hickok, Dave; Tomchick, Laurel; firstname.lastname@example.org; email@example.com
Subject: RE: alternatives to lead in autobody work
Thank you for sharing this very informative study.
I have two questions.
1] In the few months since the report was published, have you found any more specific infomration about the use of halogenated compounds in dry paint filters? (e.g., chlorinated or brominatred flame retardant
2] Can you explain to me what the environemtnal concerns are for the halogenated compounds in general and as they appear in used dry paint filters? I am not sure if it has to do with the potential for them leaching into groundwater, the hazards of potential reaction or combustion by-products, etc., and whether these concerns differs for liquid waste (e.g., waste halogenated solvent) verus a flame retardant coating that contains halogens.
As I started looking through the report, I was trying to guess what the source of the halogenated compounds could be. I never would have thought of flame retardant chemicals before I saw it in the report.
Coatings and Consumer Products Group
US EPA OAQPS
Mail Code C539-03
RTP NC 27711
tel (919) 541-0859
fax (919) 541-5689