Technically, if the product is being "used," it is not a waste. It is a raw
material for the art product. Therefore, it is not subject to regulation.
40 CFR 261.2(e)(1)(i) (doesn't classify as a solid waste, as it is not a
waste).

-----Original Message-----
From: ACS Division of Chemical Health and Safety
[mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Secretary, ACS Division of
Chemical Health and Safety
Sent: Tuesday, October 18, 2016 4:27 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] e-waste art projects

From: Monona Rossol
Re: e-waste art projects

I have a new problem. An art department program is built around a professor
with an "exciting and green" project which involves salvage and
reconstruction of decades old electronics. They break them down using
special hot desoldering guns, modify the parts by hand and reassemble them
with more lead solder. They even break into CRT tubes on occasion which are
full of powdered phosphors made with cadmium, barium and many rare earth
metals.

This is a popular course and is reportedly done by students working on open
tables with no special ventilation.

Now clearly, I can do all the OSHA lead standard and other occupational
stuff. But is this an acceptable use of e-waste? Keep ever in mind these
are art students.

Monona Rossol, M.S., M.F.A., Industrial Hygienist
President: Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012 212-777-0062
actsnyc**At_Symbol_Here**cs.com www.artscraftstheatersafety.org

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Health and Safety.
For more information about the list, contact the Divisional secretary at
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