From: Steven Noble(Snoble@pmai.org)
Date: Fri, 03 Aug 2001 12:24:44
We have seen it discussed in literature. Our experience is that the company cannot/will not provide TCLP data to support that the material will pass the TCLP test once the fixer is added. I originally saw it marketed to small print shops.
Considering the cost of having a TCLP test done on the material to prove it is truly non-haz (absent that data from the mfg), there are other methods to properly handle this waste that make better economic sense. Consider that in the dental community there are few stand alone dental shops so they can usually combine forces to get a hauler to do a "milk run" for a number of facilities in one location/city and it becomes more cost effective. From a purely environmental viewpoint, our preference for small generators is to have it hauled off-site to have the silver recovered and put back into the industrial cycle rather than forcing additional mining to get new silver out of the ground.