JUL 28 1988
Mr. T. Wayne Vickers
V.P., Marketing and Sales
Columbus Industries, Inc.
P.O. Box 257
Ashville, Ohio 43103-0257
Dear Mr. Vickers:
I am responding to your letter dated June 27, 1988, in which you requested information regarding the disposal of paint filters and our opinion on the veracity of an advertisement for paint spray booth filters. Specifically, your questions deal with an advertisement for a styrofoam paint spray booth filter appearing in the April, 1988 issue of FINISHER'S MANAGEMENT magazine.
We can not comment on the veracity of the advertisement, but we can offer some information regarding the disposal and hazardous waste classification of related wastes.
Used paint filters are not a RCRA listed hazardous waste (i.e., not listed in 40 CFR 261.31-33). However, they may be characteristically hazardous if they exhibit any of the four hazardous waste characteristics (ignitability, corrosivity, reactivity, or extraction procedure (EP) toxicity - see 40 CFR 261.21-24).
The advertisement claims that the filter is soluble in paint thinner for easy disposal. If the thinner is one or more of the solvents covered by the EPA hazardous waste listings, F001-F005, and the thinner has been used for its solvent properties (i.e., to solubilize or mobilize another material such as in a cleaning operation or in dissolving the paint filter), then the resultant solution of the paint filter and the thinner will become a listed hazardous waste on disposal.
I hope this information will be useful to you.
Devereaux Barnes, Director
Characterization and Assessment Division