From the archives of the Enforcement and Compliance Listserv for Hazardous Waste Generators
May 16, 2006
Non-Aerosol Paint Waste
Almost every business generates non-aerosol paint waste at some point. It is important to make an informed choice when purchasing paint to avoid generating unnecessary hazardous waste.
First, choose the right paint for the job. Latex paints have greatly improved over the years. Today's latex paints are suitable for many applications that were traditionally reserved for oil-based paints. If possible, try to avoid oil-based paints as they contain solvents and usually must be disposed of as a hazardous waste. Also, if your business has latex paint that is over 20 years old it may contain lead. Certain specialty paints can contain toxic metals, so generator knowledge and information from the paint cans should be used to make any hazardous waste determination.
Second, only buy the amount of paint that you need. Painting projects require about one gallon of paint to cover approximately 400 square feet of smooth surface. You can save money and avoid waste by buying the right amount of paint. Although paint is often priced so that the gallon is the best deal per unit, when buying paint you should factor in future disposal costs.
If you do end up with left-over paint you have several options. Your best choice would be to return unopened paint to the store where it was purchased. As long as the paint is still useable, you may be able to sell or donate the paint. Many theater groups, churches, schools, Habitat for Humanity, or similar organizations accept donated paint (check Earth 911 for information on local donation contacts). Leftover paint can also be used as a primer for other paint jobs.
Finally, if you do end up with waste paint then you must determine if the paint is a hazardous waste. If you determine the paint is a non-hazardous waste then the paint can be disposed of at a permitted landfill. Paint must NEVER be poured down the drain, down the sewer, on the ground, in a stream, etc. Landfills in Missouri do not accept liquids so paint must be solidified before disposal. Latex paint can be solidified by mixing equal amounts of an absorbent (cat litter, sawdust, mulch, etc.) with the paint and allowing the paint to dry. Paint and hardware stores also sell a product called Waste Paint Hardener that can be added to gallon containers to solidify paint.
If you determine the paint is a hazardous waste, it must be handled as a hazardous waste. For help determining if your waste is hazardous, please visit the archived list-serv on Determining a Hazardous Waste and the EPA Hazardous Waste Types (remember, there are state specific regulations that the EPA document does not address). If the paint waste is a change or addition to your businesses waste code information, be sure to update that information under the Description of Regulated Waste Activity section of your Notification of Regulated Waste Activity 780-1164 form. Conditionally Exempt Small Quantity Generators are not required to submit a Notification of Regulated Waste Activity, see Management of Conditionally Exempt Small Quantities of Hazardous Waste, Fact Sheet--PUB128 .
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If you need further assistance, please email or contact the Department of Natural Resources' Hazardous Waste Program at 573-751-7560 or 800-361-4827.
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