Emergency Planning and Community Right-to-Know Act

Emergency Planning and Community Right-to-Know Act (EPCRA) was first written to reduce the likelihood of chemical related disasters in the U.S. The Community Right-to-Know provisions of EPCRA increase the public access to information about chemicals in their community. EPCRA has five major provisions, all of which could apply to an operation with PITs, and the most likely applicable requirements are found in the hazardous chemical storage reporting section (also known as Tier II).

The Tier II section of EPCRA requires facilities handling or storing any hazardous chemicals in an amount equal to or greater than their threshold levels to file an inventory report. EPCRA does not have a chemical list, rather it covers all hazardous chemicals as defined by OSHA, with some extremely hazardous substances (EHS) having lower reporting thresholds.

The fluid in parts washers should be considered for potential Tier II reporting. Depending on the number of parts washers and the ingredients in the cleaning solvent, these could require inclusion in Tier II reports. If the parts washer uses solvents with an EHS, the threshold quantity could be low and even a handful of parts washers could trigger reporting.

Regulatory citation(s):

• 40 CFR 350
• 40 CFR 355
• 40 CFR 370
• 40 CFR 372
• 40 CFR 355 Appendices A and B
• 29CFR 1910.1200(c)

Related Compliance Network subjects:

• CERCLA, SARA, EPCRA
• Hazardous Materials Table

Hazardous waste

Spent solvents and filters from parts washers are almost always hazardous wastes. In some industries, such as vehicle repair shops, these tend to be one of the largest hazardous waste streams. Spent parts washer cleaning solution is hazardous if one or more of the following applies:

• Flashpoint of less than 140ºF
• Contains a listed solvent
• pH less than 2 or greater than 12.5
• Contains toxic metals or organic chemicals above regulatory limits If the spent solvents are determined to be a hazardous waste, they must meet all the storage, labeling, management, and disposal requirements. Most facilities consider each parts washer to be a satellite accumulation area, and it therefore must meet container labeling and management (kept closed, in good condition, etc.) requirements found in 40 CFR 262.15.

Aqueous parts washers can be a waste reducing alternative to the older solvent technology. Often these systems significantly reduce hazardous waste and compliance requirements.

Regulatory citation(s):

• 40 CFR 262
• 40 CFR 262.15

Related Compliance Network subjects:

• Waste (SMS topics: hazardous waste, special waste)

Water programs

Nonhazardous spent aqueous cleaning solutions can be discharged into the sanitary sewer system if they meet local discharge limits or with permission from the local publicly owned treatment works (POTW). Before connecting a parts washer to the sanitary discharge system, contact the local POTW to find out their requirements.

Regulatory citation(s):

• 40 CFR 125

Related Compliance Network subjects:

• Water Programs (SMS topics: Publicly Owned Treatment Works, water permitting)

Hazard communication

The Occupational Safety and Health Administration’s (OSHA) hazard communication, or HazCom, standard (HCS) covers ‘‘any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.” The chemicals in parts washers are covered by the HCS, meaning they should be included in your HazCom plan, have compliant labeling, have a Safety Data Sheet (SDS) available, and be included in training.

Regulatory citations:

• 29 CFR 1910.1200

Related Compliance Network subjects:

• Hazard Communication

Air programs

Volatile emissions from parts washers are regulated at several levels, including federal, state, and local rules. Applicability of each regulation will be mostly dependent on the chemical in the unit but also can include equipment age, size, and design.

At the federal level, the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Halogenated Solvent Cleaning (40 CFR 63 subpart T) focuses on reducing the emissions of selected halogenated solvents used in parts cleaning. Owners and operators of degreasers using the chlorinated solvents such as methylene chloride, perchloroethylene, 111 trichloroethane, trichloroethylene, chloroform, or carbon tetrachloride, must consider best operating practices and pollution prevention techniques. Best practices to eliminate emissions include keeping parts washers closed unless adding or removing items and increasing dwell time to allow maximum drying. States and local authorities can also have programs that regulate emissions from parts washers.

Before installing a parts washer, facilities should verify that the equipment will not require permitting or registration.

Regulatory citations:

• 40 CFR 63 subpart T

Related Compliance Network subjects:

• Air programs (SMS topic: Air emissions)

OSHA Dip Tank Standard

OSHA has provided guidance that sink-on-a-drum style parts washers do meet the definition of a dip tank under the agency’s dipping and coating operation standard. Depending on the solvent used in these specific types of parts washers, the standard outlines requirements for ventilation, exhaust, first aid measures, etc.

Regulatory citations:

• 29 CFR 1910.122, 1910.123, 1910.124, 1910.125, and 1910.126

Related Compliance Network subjects:

• Hazardous Materials Safety - OSHA (SMS topic: dipping and coating)