Printech Archive, April, 2000
Re: Used photographic chemical disposal regulations

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Date: Mon Apr 17 2000 - 09:24:43 CDT

There are no regulations that specifically address used film processing
chemistry and film. The regulations governing the classification, handling,
and disposal requirements for hazardous wastes are contained in 40 CFR 260,
261, and 262. For silver bearing wastestreams such as used fix and film, the
specific regulation is 40 CFR 261.24, characteristic of toxicity. According
to this section of the regulations, any silver bearing wastestream with more
than 5 ppm is classified as a D011 hazardous waste.

In order to determine the amount of silver in a wastestream, the waste needs
to be tested using the Characteristic Toxicity Leaching Procedure (TCLP).
TCLP is a specific test that simulates what would occur to the waste if it
was disposed in a landfill without treatment.

Typically, waste fix will be classified as hazardous because it can contain
up to 3,000-5,000 ppm silver. Waste fix that has been subject to silver
recovery will contain less silver and the amount depends upon the type of
recovery used. Uncontaminated waste developer should not be a hazardous
waste. Waste film will usually pass TCLP and most film vendor's have
performed this testing and will share the results with you.

Since untreated fix is classified as a hazardous waste, you need to determine
if a permit is required for any silver recovery activity. Most state and EPA
do not require a permit, but some have extensive permitting requirements.

In addition, if the waste fix (after silver recovery) and developer are
discharged to a sewer treatment works with their permission, then the amount
of fix is not counted as a hazardous waste toward your generator status.
Again, check with your state on this one, as they may differ in their
regulations, but EPA does not require counting it.

For more information on determining hazardous wastes in printing operation,
see the PNEAC Fact Sheet What is a Hazardous Waste.

Gary Jones
Graphic Arts Technical Foundation
200 Deer Run Road
Sewickley, PA 15143
412/741-6860 x608 - Phone
412/741-2311 - Fax

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