The answer to this question is being sought by the Environmental Protection Agency (EPA) as they focus enforcement efforts on universities and colleges across the country. Of course, art departments aren’t the only generators of hazardous waste in an educational environment. The list also includes chemistry and biology labs, print and graphics shops, as well as maintenance departments and medical facilities. However, all areas will get attention if EPA targets the institution for an inspection.
If hazardous wastes are generated, are they being managed and disposed of according to legal requirements? If the answer to this question is no, it could cost your institution tens or hundreds of thousands of dollars if the deficiencies aren’t fixed. One university recently agreed to pay the EPA close to $50,000 and conduct environmental improvements well over $150,000 to settle claims for violating federal and state hazardous waste management laws.
To guard against these consequences, art department staff and students need to know the disposal requirements for each material they work with. Wastes need to be classified as either hazardous or non-hazardous at the time they are generated. According to an EPA source, this awareness seems to vary greatly between schools. It is not uncommon to find that some hazardous wastes in Art Departments are routinely poured down the drain and others co-mingled with non-hazardous trash.
Many schools think they don’t need to worry about the waste disposal problem because they only use products certified as “non-toxic” or AP Certified. In fact, these assurances only apply to health hazard assessment. They do not coincide with any potential waste disposal hazards.
Inorganic and organic-metallic hybrid pigments derive their color from the metals they contain. The amount of metal required in these pigments varies from a couple percent, as is the case with copper in phthalo colors, to almost 90%, as is the case with some cadmium pigments. Some metals are regulated, others are not. Under the Resource Conservation and Recovery Act (RCRA), EPA regulates the amount of soluble Arsenic, Barium, Cadmium, Chromium, Lead, Mercury, Selenium and Silver in solid wastes. Solubility is determined with an acid filtration test and attempts to predict how stable a material will be in a landfill. In addition, local wastewater authorities regulate the total amount of certain metals in the wastewater stream. These typically include Arsenic, Barium, Boron, Cadmium, Chromium, Copper, Lead, Mercury, Nickel, Silver and Zinc. As indicated on our Pigment Identification Chart, different GOLDEN colors derive their hue from Barium, Cadmium, Chromium, Selenium, Copper, Nickel and Zinc.
If your school has a program that guards against improper disposal, Golden Artist Colors’ Safety and Compliance office can assist your efforts to assure you are discarding our products safely. If your school does not have a current program in place, the best alternative is not to bring those colors into the institution in the first place. Click Here for a list of GOLDEN colors and products that are certified to comply with the Federal requirements of D 4236 for safe use. We’ve indicated which of these products contain no metals of concern for waste disposal. We’ve further delineated the list of the metal-containing products in order that informed choices may be made as part of a waste management program.
Schools may choose any one or a combination of practices to avoid problems. These may include banning certain colors from the curriculum, waste avoidance, educating staff and students, segregating and managing waste, and testing wastewater prior to disposal. As always, we will gladly field any questions that customers may pose. For more information, contact your local Environmental Protection authorities, Sewage Treatment Plant, and Ben Gavett, Director of Safety and Compliance, Golden Artist Colors.