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printreg, November, 2000
Re: TCLP film


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From:SSchuler(SSchuler@PIMN.ORG)
Date:Thu, 9 Nov 2000 09:54:17 -0600


Dear KDP, whoever you are. Let's use a little common sense here. First of all, we all know that the photographic film commonly used in the printing industry contains silver halides. Secondly, we all know that some of that silver remains on the film after developing and some ends up in the spent fixer. I never questioned the fact that silver does leach from scrap film. This is known to occur, although every batch of scrap film will leach silver at different levels because the developed film itself is so variable as to how much remains on the film's surface. This is why the film manufacturers that I have talked to will not certify that their film leaches at less than 5ppm, or at any other level. Maybe I missed something in my reply, but exactly where in my reply did I say that based on my or anyone else's knowledge that silver does not leach? I am afraid that you are misunderstanding what I was trying to say. We also know that there is marginal recycling value in scrap film and spent photo fixer. Therefore, it simply makes sense that one would be wise to simply declare those wastes to be hazardous wastes based on one's own knowledge of those wastes in order to avoid the costs of sending those wastes off periodically to be TCLP'd at an analytical laboratory. Please educate me on where it says in the federal regulations that one must absolutely run a TCLP test on scrap film and spent photo fixer. The Code of Federal Regulations in my world reads as follows: CFR 40 Part 262.11 - A person who generates a solid waste, as defined in 40 CFR 261.2, must determine if that waste is a hazardous waste using the following method: (c) For purposes of compliance with 40 CFR part 268, or if the waste is not listed in subpart D of 40 CFR part 261, the generator must then determine whether the waste is identified in subpart C of 40 CFR part 261 by either: (1) Testing the waste according to the methods set forth in subpart C of 40 CFR part 261, or according to an equivalent method approved by the Administrator under 40 CFR 260.21; or (2) Applying knowledge of the hazard characteristic of the waste in light of the materials or the processes used." Now when I read the word "either," I interpret it to mean that the generator has the option to either test the material or apply their knowledge of the waste. Maybe I am mistaken here. If you believe I am mistaken, please explain why you see this differently. Lastly, I went to the time and the trouble of including the specific regulatory language in my reply that I found to pertain to the initial question. This took considerable time and effort to help my peer at the expense of my employer. There is no benefit to me or my employer in assisting a fellow EHS professional. I do give something back to the people on the listserv from time to time because I have used it in the past with questions I have been unable to answer. I included the specific regulatory citations because I know how easy it is to apply my own knowledge and experiences when interpreting the rules. With the exact language of the rules, one can apply their own knowledge and experiences to their interpretation of the rules. You have done this and I would expect that Sherry would do this also. Of course I did not include all of the sections of the hazardous waste rules because of their length and because of the amount of time it would have taken to cut and paste those sections into an email. I think what this really demonstrates are the limitations of trying to assist people through the email venue. I think that in the future I will simply call the individual requesting assistance. This will minimize the time needed to help someone out and will enable me to pass along much more information than can be contained in an email. I also would have called you directly to respond to your complaint on my reply so as not to burden the other listserv participants with my email that should be private between you and me. Unfortunately, you did not include your name, affiliation, address, or phone number in your response, so I have to send this email to everyone on the list serve in order for you to receive it. I think it would be a common courtesy to others participating on the listserv to include all of this information on the signature line in your future emails. Thanks you for taking the time to help educate me on the federal hazardous waste rules. Sincerely, Scott Schuler Environmental Director Printing Industry of Minnesota, Inc. 2829 University Avenue SE, Suite 750 Minneapolis, MN 55414-3222 Main Number: (612) 379-3360 Direct Number: (612) 379-6006 Fax: (612) 379-6030 e-mail: sschuler@pimn.org website: www.pimn.org



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