Facility Regulatory Tour
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Carpenter Shop Image

General Description

This may be referred to as the carpenters shop.

Summary of Federal Requirements


Painting and varnishing operations typically are performed at wood shops within federal facilities. Many paints and varnishes, as well as paint strippers and varnish removers contain organic solvents that are hazardous to human health and the environment and are regulated by RCRA as a hazardous waste. A few of these hazardous chemicals are: acetone, benzene, methanol, methylene chloride, petroleum distillates, toluene, trichloroethane, and xylene.


Also potentially regulated by RCRA are cleaning solvents and degreasers used performing machinery maintenance operations. Traditional solvents often contain toxic chemical compounds that may qualify the waste product as hazardous waste.

Hazardous Material Storage

Wood Shops use a variety of hazardous materials such as solvents, stains, and adhesives. Depending on the volume of hazardous materials or extremely hazardous materials stored on site, federal facilities must submit notifications of their activities. If the metal shop is a part of a larger facility, the volume of materials is based on the amount of materials total in the larger facility.

The regulatory impacts of hazardous materials stored and/or used at wood shops are outlined in the Laboratories -> Hazardous Materials Storage section of the Facility Regulatory Tour.

Hazardous Wastes

Wood shop managers may be required to perform compliance related activities when disposing of waste paints, varnishes, paint strippers, varnish removers, degreasers, or cleaning solvents. The amount of waste generated at a site is a major factor that determines the extent to which regulations may apply. Visit the Hazardous Waste Storage section to find out how to determine if your waste is considered hazardous according to RCRA and what generator classification your facility falls within.


Used or spent rags containing listed hazardous wastes or exhibiting hazardous characteristics, are common to many wood shops. Improper management of recyclable or disposable spent rags can result in RCRA penalties for any violator, including federal facilities. A spent rag is one that has been used and is no longer fit for use without being regenerated, reclaimed, or otherwise reprocessed. Perhaps the most important factor in identifying spent rags as hazardous waste is that the sole responsibility lies with the generator or user of the rag. Oil contaminated rags are hazardous based on whether the rags exhibit a characteristic and/or contain a listed material. Whether the rags are shipped off-site for disposal or to an industrial laundry, any accumulation of hazardous rags on-site prior to shipment must be done in compliance with the requirements for the accumulation of hazardous waste rules.


There is no specific regulation that mandates wood recycling. However, wood scraps should be recycled whenever possible. Some products incorporating wood scraps:

  • recycled pulp and paper products
  • reconstituted panelboard
  • fiber-composite applications
  • animal bedding
  • interim road beds
  • mulch and soil amendments
  • bulking agents for compost production
  • chemical derivatives
  • processed fuel pellets or blends
  • biomass combustion.

Summary of State Requirements

States may regulate emissions from the sawdust collectors found in wood shops. Depending on the classification of the facility, states may also require the facility to consider the emissions from paints, stains, and cleaners in their calculations as part of a CAA Title V permit submission.

Laws and Statutes

Clean Air Act
The Resources Conservation and Recovery Act

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Regulatory Sources
29 CFR 1910.101
Occupational Safety and Health Standards, Subpart H: Hazardous Materials – Compressed Gases

29 CFR 1910.106
Occupational Safety and Health Standards, Subpart H: Hazardous Materials – Flammable and Combustible Liquids

40 CFR 260
Hazardous Waste Management System: General

40 CFR 262
Standards Applicable to Generators of Hazardous Waste

40 CFR 264
Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities
Last Updated: July 27, 2017