Introduction to Waste Management
for Artists and Schools

By Angela Babin, M.S.,
and Michael McCann, Ph.D., C.I.H.

Artists, art teachers, and students often produce solid waste and aqueous waste as a result of their art processes.  Much of this waste can be hazardous, leaving the problem of how to dispose of it safely and legally.  Some waste, while non-hazardous, can be bulky and use up space in  overloaded landfills.  See our booklet Waste Management and Disposal for Artists and Schools for more information on disposal methods for particular classes of art materials.
In the United States, the Environmental Protection Agency (EPA) regulates the disposal of hazardous waste under the Resource Conservation and Recovery Act (RCRA). Industrial wastewater discharges are not considered solid waste, and are regulated under the EPA Clean Water Act.

The Resource Conservation and Recovery Act (RCRA) was enacted in 1976 as an amendment to the Solid Waste Disposal Act, and can be found in Part 240-281 of Title 40 of the Code of Federal Regulations (40 CFR 240-281).  Subtitle C of RCRA regulates the management of hazardous waste through its "cradle-to-grave" system  of regulations for the identification of hazardous waste and generators, among other requirements.  This waste manifest system tracks hazardous waste through generation, transportation, and disposal.

The responsibility for administering RCRA rests with the individual state.  While most of the states' hazardous waste programs resemble RCRA, you should contact individual state environmental offices to elucidate any differences.
Hazardous Waste Generators
There are different categories of producers of hazardous waste, under RCRA, 40 CFR Part 261.  The basic distinctions center around the amounts of hazardous waste produced.  These categories are:
    1.    Large Quantity Generators (LQG): LQGs produce more than 1000 kilogram per month (kg/month), (2205 pounds) of hazardous waste, or more than 1 kg/month (2.2 pounds) of acutely hazardous waste.  LQGs must obtain a US EPA identification number from a state hazardous waste management agency or EPA regional office. They must comply with storage time, quantity, transportation, handling, and record-keeping (manifest) requirements.
    2.    Small Quantity Generators (SQG): SQGs produce more than 100 kg/month (22 pounds) and less than 1000 kg/month (2205 pounds) and accumulate less than 6,000 kg (13200 pounds).   Requirements for SQGs are similar to those for LQGs.

    3.    Conditionally Exempt Small Quantity Generators (CESQG) produce less than 100 kg/month (220 pounds) of hazardous waste, or less than 1 kg/month (2.2 pounds) of acutely hazardous waste.  They are "conditionally exempt" from Subtitle C, and the manifest system, including transportation requirements.  CESQGs must identify all hazardous waste, not accumulate more than 1000 kg (100 kg in NYS), and treat or dispose their waste onsite or make sure that the waste is sent to an approved facility.  Not all states recognize a difference in requirements for CESQGs. The above categories of hazardous waste generators represent industrial or "commercial" generators.  This would include an arts community group, printmaking studio, school district, college,  photography studio, or even professional artists if they produce hazardous wastes and meet the definitions of a CESQG, SQG, or even a LQG.   

    4.    Household Hazardous Waste (HHW): HHWs are exempted from federal hazardous waste regulations [40 CFR Part 261.4(b)(1)].  This exemption allows individual citizens, and home artists and hobbyists, to discard materials into municipal waste streams.  EPA states that the reason for this exemption does not mean these wastes aren't hazardous, rather that enforcement and management of wastes generated by consumers in their households isn't feasible.  Also, handlers of household hazardous wastes don't need to comply with the federal regulations when managing household wastes.  HHW collection programs are a good option for these generators.
Sewage System
The Clean Water Act of 1977 can restrict what may be dumped into the sewer system.  This act is directed at "significant industrial users," who discharge large amounts of wastewater on a daily basis.  Large photographic processing studios and large electroplating studios are examples of businesses that may need to be in compliance with this law.

All publicly-owned treatment works are required to develop local sewer use codes which regulate the concentration of hazardous substances in waste water.  These limits are designed to reflect the particular local  environmental conditions of the area. 

Non-toxic liquids (e.g. neutralized acids and alkalis), and small amounts of some hazardous, water-based solutions (e.g. dye solutions, photographic solutions) can be poured down the drain with lots of water if the sewage system has a wastewater treatment plant with a bacterial treatment stage that can detoxify small amounts of chemicals.  Septic tank systems are more sensitive since one doesn't want to kill off the septic tank bacteria.  Solvents should never be poured down the sink.
Types of Hazardous Waste
There are several categories of chemicals used by artists and schools that come under regulation as hazardous waste.  These include:
    1.    Toxic Waste Chemicals: e.g. solvents, formaldehyde, lead compounds, mercury, chromates, etc.
    2.    Flammable Waste: e.g. flammable and combustible liquids with a flashpoint of < 140ø F; solids that can cause fire through friction, absorption of moisture, or spontaneous combustion; ignitable compressed gases; and oxidizing substances like potassium chlorate and concentrated nitric acid.
    3.    Corrosive Waste: e.g. wastes with a pH < 2 or > 12.
    4.    Reactive Waste: e.g. cyanide or sulfide wastes which can generate dangerous amounts of toxic gases between pH 2 and 12.5, and unstable compounds such as methyl ethyl ketone peroxide.
    5.    Acute Hazardous Waste: e.g. arsenic compounds, hydrogen cyanide and cyanide salts, many pesticides, vanadium pentoxide, etc.
    6.    Leachable Toxic Waste: e.g.  materials that can leach into water more than specified levels of the following metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver.  In addition, leachable levels of other chemicals are regulated, including benzene, cresols, p-dichlorobenzene, methyl ethyl ketone, pentachlorophenol, perchloroethylene, trichloroethylene, and several pesticides.
    7.    Miscellaneous: Other classes of hazardous waste not normally encountered by artists may include radioactive materials and pathological (viral or bacteriological) waste.

Methods of Waste Management
There are a variety of methods of managing waste materials, including waste minimalization, recycling, treatment, pouring them down the drain, evaporation, ordinary landfills, and taking them to a waste disposal company.  Not all of these options apply to hazardous waste.
    1.    Waste Minimization: The amount of hazardous waste can be minimized by using less toxic substitutes, for example, using water-based instead of solvent-based screen printing inks.
    2.    Recycling: Many waste art materials can be reused.  For example, mineral spirits used for cleaning oil painting brushes can be allowed to settle, and then strained through cheesecloth to remove the solids.  The filtered solvent can then be reused.  Leftover art materials can be donated to an art center or secondary school.  Note that hazardous materials should never be donated to elementary schools, and highly toxic materials like lead glazes should not be recycled.
    3.    Evaporation: Small amounts of solvents or solvent-containing materials (less than a pint) can be evaporated if no other better alternative is available.  Evaporation should take place outside, or inside a local exhaust hood where no one will be exposed to the solvent vapors.
    4.    Landfill: Non-hazardous, solid waste materials can be placed in the regular trash for carting to a normal landfill.  Some toxic materials can also be placed in the trash, including clay, metals, paint residues, etc.  Glazed pottery can be placed in the trash if it doesn't leach toxic metals.
    5.    Treatment: Some materials can be treated to make them non-hazardous.  Neutralization of dilute acid and alkali wastes, and recovery of silver from photographic fixer solutions are examples of chemical treatment of hazardous waste that artists can do.
    6.    Hazardous Waste Disposal Transporters and Companies: Hazardous materials that can't be properly disposed of in other ways should be taken to a licensed hazardous waste disposal company.  Individuals and CESQGs, carting their own materials, are exempt from RCRA transportation regulations that require (often costly) pick-up by a licensed hazardous waste transporter.  Note that many fire departments restrict transportation of flammable liquids.  
    7.    Household Hazardous Waste Collection:  Household hazardous waste collection programs (HHWCPs), often organized by counties or municipalities, are intended to collect hazardous waste from homes.  To be eligibile for these programs, materials must be generated by individuals on the premises of a temporary or permanent residence.

There is a grey area surrounding the boundaries that define artists and their working scenarios.  For example, an artist who has a separate studio may not be eligible for disposal of unwanted materials at a household hazardous waste collection program.  Likewise, homeowners, gardeners, and artists who bring in suspiciously large amounts of materials to a household hazardous waste collection program may be turned away from services because their quantities resemble those of businesses, small farmers, and commercial art businesses.  CSA has produced a list of U.S. and Canadian collection programs that accept waste from both individual artists, and also from small "commercial" art businesses.  For this list, along with recycling and waste exchange program information, see our data sheet Health and Safety Resources for Artists.
Environmental Protection Agency. 40 CFR 260 to 267.  Hazardous Waste Management Regulations.  Government Printing Office, Washington DC. 1989.
Environmental Protection Agency. RCRA Orientation Manual. 1990 Edition. Office of Solid Waste, Washington D.C. 1990.
McCann M and Babin A.  Waste Management and Disposal for Artists and Schools.  CSA 1992.

Art Hazard News, Volume 15, No. 3, 1992

This article was originally printed for Art Hazard News, © copyright Center for Safety in the Arts 1992. It appears on nontoxicprint courtesy of the Health in the Arts Program, University of Illinois at Chicago, who have curated a collection of these articles from their archive which are still relevant to artists today.