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by Ron Joseph

February, 2001

Compliance With State and Local Regulations

Q. How do we find out if the products we use in our our company are in fact approved by the EPA? We have the MSDS's on all the products listing federal regulations, but we don't know what it means??

I should explain what it is we do so that will help you help us. We are a company that repairs and restores leather, vinyl, fabric on car seats, leather jackets, leather furniture on a mobile basis. We fix cuts, tears, scratches, and dye color faded or worn items. We use water based dye pigments and acrylic emulsions as our base. We use small amounts typically between 2-5 ounces of dye/mix to dye seats or a particular item and spray the item(s) with a touch-up spray gun.

I also am listing our website information so that if you need to, you can refer to our website for further information about what our company actually does. www.CreativeColorsIntl.com

We have other water based adhesives that we use to fix fabric and other items.

We also wanted to find out about properly disposing of our products? For example, not pouring certain things down the drains and if so what quantities are acceptable or not acceptable.

A. Thanks for your e-mail. I did in fact visit your website and it looks impressive. Based on what I saw, you have branches (or franchises) in many cities across the US. Are you responsible for all of your centers, or only for one?

The reason for asking is that the state and local regulations differ for each location, and to determine status of compliance you need to understand under which regulations you are subject.

On the one hand, the fact that you use water-based products makes it more likely that you are in compliance with state and local regulations. However, many water-based products also contain some VOC and perhaps even some HAP. The more difficult part is to take the information from the MSDS and calculate your compliance status. This is not something I can do in a few minutes.

I can offer you some solutions to your problem. If you can wait until the second week of September, we are offering a 4-day environmental training program in Williamsburg, VA in which we teach all of the calculations that are required to calculate compliance, and also go through the regulations, what they mean and how to interpret them.

Second, we can help you on a consulting basis. To do this we would need to know where the offices are that may be affected by state or local regulations. Then we would need copies of all your MSDS. We would obtain all of the air quality regulations that affect your operations and perform the calucations to get you straight.

You are obviously not obligated to use our services, and can retain a environmental consulting firm that is familiar with coatings, dyes, etc.

I wish I could be of more help right now, but you have posed a question that requires considerably more effort than I can commit on a "gratis" basis


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