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Previous by Date: Subject: Re: [DCHAS-L] Biosafety reference list? Date: Wednesday, October 19, 2016 at 9:25:09 AM Author: Mary Beth Koza <mbkoza2**At_Symbol_Here**GMAIL.COM> |
Next by Date: Subject: Re: [DCHAS-L] e-waste art projects Date: Wed, 19 Oct 2016 10:11:50 -0400 Author: Samuella B. Sigmann |
OK, Dave, that may be true for EPA, but I found out there are big fines for doing this in this state.
Without naming names I described what what is happening in the class to the enforcement people and they said for this to be occurring in a school, they need two permits. One is for being a collection point/transporter of e-waste (which they have) and the other -- a very expensive special permit with lots of rules and reporting and training -- is for dismantling or recycling the waste in any way. This rule applies directly to employees such as the teacher.
The way the rule works for students is this: The students effectively become regulated as e-waste dismantlers once they start experimenting or creating with e-waste that they've collected from others. If it's their own electronic devices from their own living room, there's a loophole that lets them out of most of the checklist requirements since they are simply the household generator of that material. But even a household generator could not use a desoldering gun if that involves applying heat to the electronic device. No heat or chemical treatment of e-waste is allowed in that state without that very expensive permit.
I'm not identifying this state, but does anyone on the list know what the rules are in other states. I need to write about this because I know other schools are doing such crazy things.
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This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety.
For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org
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
-----Original Message-----
From: Dave Einolf <dave**At_Symbol_Here**ENDEAVOUREHS.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Tue, Oct 18, 2016 8:17 am
Subject: Re: [DCHAS-L] e-waste art projects
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 <actsnyc**At_Symbol_Here**cs.com>
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
---
This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical
Health and Safety.
For more information about the list, contact the Divisional secretary at
secretary**At_Symbol_Here**dchas.org
---
This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety.
For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org
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