February 1995

ainter's

hecklist

Lincoln-Lancaster County Health Department

3140 "N" St. Lincoln, NE 68510-1514

I. Introduction ....................................................................... 1

A. Who should use this booklet? ......................................................... 1

B. What is the purpose of this checklist? ............................................. 1

C. How should you use this checklist? ................................................ 1

D. Why Pollution Prevention? ............................................................. 2

II. Checklist ........................................................................... 5

A. Management Systems ..................................................................... 5

B. Worker Safety and Exposure Control .............................................. 8

C. Inventory Control ........................................................................... 10

D. Pollution Prevention Source Reduction ........................................... 13

E. Handling and Storage ..................................................................... 15

F. Spill Prevention, Counter Measurements, and Control .............................................................................. 19

G. Recycling ........................................................................................ 22

H. Disposal .......................................................................................... 24

III. References ............................................................................................ 25

February 1995 Painter's Checklist

A publication of the Lincoln-Lancaster County Health Department 31 40 “N” Street Lincoln, NE 68510-1514

February 1995

M. Jane Ford Health Director

Financing provided through the Waste Reduction and Recy- cling Incentive Grants Program, Nebraska Department of Environmental Quality.

Painter’s Checklist

A. WHO SHOULD USE THIS BOOKLET?

This booklet is designed for professional, residential, or commercial painters; painting decorating contractors; or interior/exterior decorative coating contractors or applicators.

Paint manufacturers, vehicle coating specialists, and industrial or speciality coating opera- tions are not the targets of this checklist, although some questions may be appropriate to those professions as well. More specialized assistance for these groups is available from the Lincoln-Lancaster County Health Department (LLCHD) Pollution Prevention/Air Quality Section.

B. WHAT IS THE PURPOSE OF THIS CHECK- LIST?

Using the checklist provided in this booklet may save you money. Pollution Prevention (P2) is one of the best ways to reduce your costs and simplify your special and hazardous- waste management efforts. Pollution Prevention occurs through source reduction — substi- tuting nonhazardous for hazardous input material — and changing production processes or waste handling methods to reduce the amount of waste generated.

Waste reduction decreases your liability and protects the environment. The checklist pro- vides you — the painter, painting/decorating contractor– with information that will help you reduce the amount of hazardous and special waste generated in your business. This informa- tion will also help your business come into or remain in compliance with most regulatory requirements.

This is not a regulatory document. Complete only the sections that apply to your operation, and keep it in your files for future reference.

C. HOW SHOULD YOU USE THIS CHECKLIST?

Follow the table of contents to guide you through the sections of the checklist that apply to your business. Read the introduction to each section carefully before completing it. Small,

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one-person operations may need to spend only a few minutes on the checklist while larger organizations will want to take more time due to their greater variety and volume of wastes. If you move, grow, or change your services, go over the checklist again to see if any new waste-reduction strategies or regulations will apply to your new situation.

This document describes some regulations that apply to painters and painting/decorating contractors. Contact the Lincoln-Lancaster County Health Department (LLCHD) at (402)441- 6238 for waste regulations specific to your business.

D. WHY POLLUTION PREVENTION?

Reducing the amount of hazardous waste generated will save you money and make it easier for you to comply with hazardous-waste regulations. Waste reduction can also reduce your liability in two important ways.

First, since you will not be producing as much waste, the chances for improper disposal or an accidental spill and the resulting environmental cleanup are decreased. Second, less waste can also mean less exposure to hazardous substances for your employees. Waste reduction, in conjunction with proper employee training and material substitution, will further increase your benefits. If your operation is large or complex, you may want to consider hiring a consultant to assist you in assessing and managing your waste.

To be successful, your waste-reduction program must be organized. It is not difficult to organize waste reduction, but it will take some time initially to get started. Keep in mind the principles of waste reduction listed on the next page.

(As you read through this checklist, you may notice that little is said specifically about lead paint. Leadpaint is a hazardous substance and caution must be used in handling, storing, abating, and disposing of it. Several existing andproposed federal and state laws regulate some of these activities. Agencies that offer advice and assistance include the Department of Housing and Urban Development [HUD], the Nebraska Department of Health [NDOH], and the Occupational Safety and Health Administration [OSHA]. The Lincoln-Lancaster County Health Department [LLCHD] has a great amount of informative material that dis- cusses lead-paint issues. Please contact the LLCHD at 441-8041 for further information.)

Painter’s Checklist

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Check the appropriate box or fill in the response below each question. If your answer is not the choice printed in bold, capital letters, refer to the right-hand column for information on how better to reduce or handle your waste products.

1. Are your employees trained in proper hazardous-waste handling and waste-disposal practices as well as cleanup techniques?

YES The amount of waste can be reduced if employees are trained to handle and store hazardous materials properly. (The Occu- pational Safety and Health Administration [OSHA] requires this employee training. In addition, NDEQ requires separate training for businesses generating 220 pounds [about 25 gal- lons/ or more of hazardous waste in a month.) Some consult- ing firms offer employee training as a part of their package of services for hazardous-waste management. Check with trade associations and hazardous-waste haulers for training infor-

February 1995

mation.

5

no

2. Are your employees aware of the principles of Pollution Pre- vention (P2)?

YES Employees who know the goals and purpose of P2 are much more likely to participate in developing and implementing P2 solutions to business problems than those who do not have such knowledge.

3a Has your business adopted a written policy promoting P2?

YES Commitment from the top is essential to sustain a viable P2 program. A written policy statement is one way for top-level management to show that P2 is important.

3b. Is a written policy promoting P2 prominently displayed?

All employees should be aware of and know about this P2 commitment. One way to communicate the commitment is to put the policy on a plaque and post it in your office and work-

the opportunity to be involved in the P2 program?

Making permanent changes in behavior and attitude is more complicated than simply issuing a policy. Each employee’s attitude really determines the program’s success. Since their daily activities generate waste, it is vital that your employees support the program. Employees feel committed to P2 when they are encouraged to help develop company goals and ob- jectives, review processes to determine how and where toxic substances are used, and recommend ways to eliminate wastes at their source. Employee involvement helps establish a posi-

5. Do you include waste-manage- ment costs when bidding a job?

Often, waste-management costs are overlooked in bidding a job. However, some contractors count them as overhead. In

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(Continued)

Painter’s Checklist

no

no

YES no

place.

4. Do all of your employees have

YES no

tive atmosphere and solicit worthwhile suggestions.

YES no

NOTES:

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Check the appropriate box or fill in the response below each question. If your answer is not the choice printed in bold, capital letters, refer to the right-hand column.

1. Are all employees trained on how to use and store chemicals safely-including what to do in case of a hazardous spill or other accident?

YES Properly trained employees are less likely to misuse costly products and generate unnecessary waste. The Occupational Safety and Health Administration (OSHA) requires that every individual who is in contact with any hazardous chemical(s) be comprehensively trained on proper chemical-handling pro- cedures, how to read a MSDS, what to do in case of an emer- gency, and the health hazards associated with each chemical with which they come in contact. In addition, hazardous-waste handling training for small- and large-quantity generators of hazardous waste is required by NDEQ. The employer should document this training for future reference.

8 Painter's Checklist

no

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Check the appropriate box or fill in the response below each question. If your answer is not the choice printed in bold, capital letters, refer to the right-hand column for information on how to better reduce or handle your waste products.

10

The frequency with which you check stock of supplies may vary with the nature of the supplies and the projects or work you are engaged in. It is important to avoid overstock of per- ishable materials such as latex paint that might freeze. Small projects could involve an inventory during the start up and final cleanup, for example.

Painter’s Checklist

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NOTES:

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Check the appropriate box or fill in the response below each question. If your answer is not the choice printed in bold, capital letters, refer to the right-hand column.

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NOTES:

14 Painter’s Checklist

Check the lines that apply to your storage area(s). If your response is not in bold capital letters, refer to the right-hand column.

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16 Painter’s Checklist

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~

NOTES:

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Check the lines that apply to your spill prevention and control measures and policies. If your re- sponse is not in bold capital letters, refer to the right-hand column.

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20 Painter’s Checklist

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Check the lines that apply to your recycling programs and policies. If your response is not in bold capital letters, refer to the right-hand column.

22 Painter’s Checklist

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Check the appropriate box or fill in the response below each question. If your answer is not the choice printed in bold, capital letters, refer to the right-hand column.

NOTES:

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For answers to questions about this checklist, specific waste types, the storing or handling of wastes, or treatment alternatives contact:

Lincoln Lancaster County Health Department Division of Environmental Health Pollution Prevention Section 3140 N St. Lincoln, NE 68510-1514 Technical Assistance (402) 441 -8145 Special Waste (402) 441 -6238 Air Pollution (402) 441 -8021

For answers to questions about state or federal small and large quantity generator regulations or hazardous waste disposal and treatment contact:

The Nebraska Department of Environmental Quality P. O. Box 98922 301 Centennial Mall South Lincoln, NE 68409-8922 (402) 471-421 7

US. EPA Region VII 726 Minnesota Avenue Kansas City, KS 661 01

U. S. EPA, RCRA Hotline (800) 424-9346

(91 3) 551 - 7051

For information regarding OSHA requirements and Worker Right-to-Know contact:

The State of Nebraska Department of Labor Division of Safety 301 Centennial Mall South Lower Level Lincoln, NE 68.509 (402) 471-471 7

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