Industry Overview Of Construction

EPA/530-SW-90-027j

If your operation is involved in the construction industry you might be subject to Resource Conservation and Recovery Act (RCRA) regulations covering the generation, transportation, and management of hazardous waste. Not all construction industry operations produce hazardous waste, but if you use materials such as strong acid or alkaline solutions, paints, solvents, or petroleum products, the waste generated during their use might be hazardous.

You are included in the construction industry if you provide services in the following areas:

• Heavy construction
  
• Plumbing, heating, and air conditioning
  
• Painting, paper hanging, and decorating
  
• Mobile home construction
  
• Prefabricated wood buildings and components
  
• Masonry, stonework, tile work, and plastering
  
• Carpentering and floorwork
  
• Concrete work
  
• Roofing and sheet metal work
  
• Glass and glazing work
  
• Wrecking and demolition.

Hazardous Wastes From Construction

Hazardous wastes that might be generated during construction fall into several major categories:

• Ignitable paint wastes generated by painting and other associated processes, including paint preparation and brush and spray gun cleaning
  
• Other ignitable wastes containing paint and varnish removers, paint brush cleaners, and epoxy resins and adhesives used during processes such as painting, cleaning, and degreasing
  
• Spent solvents from many processes, including painting, cleaning, degreasing, air conditioner maintenance, and fluxing
  
• Wastes containing toxic chemicals. Many products such as adhesives, paints, coatings, polishes, varnishes, thinners, and treated woods contain toxic chemicals. Wastes generated during the use of such products are hazardous wastes if they contain certain levels of toxic chemicals.
  
• Strong acid/alkaline wastes used in cleaning, degreasing, and plumbing operations.

If you have spent hear transfer boxes, contact your state hazardous waste management agency to determine your responsibilities.

In addition to these wastes, your operations might generate used oil. There are special provisions in the regulations for used oil. Currently most used oil is exempt from EPA hazardous waste regulations if it is recycled. If you recycle your oil, you are not required to use a Uniform Hazardous Waste Manifest. and you do not need to include used oil when determining your monthly hazardous waste generation rate. If, however, you are disposing of used oil yourself or are sending it offsite for disposal, you generally should handle it as hazardous waste because it is likely to be ignitable or toxic. Special requirements apply if you are burning used oil as fuel. EPA is currently developing new regulations for used oil. Some states regulate used oil differently than does EPA; contact your state hazardous waste agency for more information.

Table I lists typical processes/operations that use products that might contain hazardous materials and that probably generate hazardous waste. If you produce 100 kilograms (220 pounds or about half of a 55-gallon drum) or more of hazardous waste per month, you must fill out a Uniform Hazardous Waste Manifest when you ship hazardous waste off your property. The Manifest requires the proper Department of Transportation (DOT) description for each waste. Table 2 lists the proper DOT shipping description for a number of wastes that might be generated during equipment repair operations. Table 1 and Table 2 are not comprehensive lists. If you suspect that any waste you generate is hazardous, check with your state hazardous waste agency or EPA Regional office for more information.

Waste Minimization

An effective waste minimization program can reduce the costs, liabilities, and regulatory burdens of hazardous waste management, while potentially enhancing efficiency, product quality, and community relations. Waste minimization techniques that can help you reduce the amount of hazardous waste that you generate include:

• Production planning and sequencing
  
• Process/equipment adjustment or modification
  
• Raw material substitution
  
• Loss prevention and housekeeping
  
• Waste segregation and separation
  
• Recycling