General Description
This may be referred to as the carpenters shop.
Summary of Federal Requirements
Coatings
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.
Cleaners
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.
Rags
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.
Recycling
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
