Paints and Thinners
Are paints and thinners properly contained and marked when not in
Yes--Paints and thinners are stored in containers that
are labeled with the contents of the container, are closed with lids
tight when not in use, and contained in such a way that a spill would
not reach a drain or otherwise leave the facility.
No--Paints and thinners are not stored and labeled as
NA--Facility does not have paints and thinners onsite.
Does facility use low VOC paints?
Paint labels, or product data sheets (or MSDSs) should contain the VOC
content of the paint. In general, VOC content greater than or equal
to 5 lbs/gallon is high, while low is considered between 4 and 5 and
very low is below 4.
Yes--Paints are labeled or MSDS indicates that paint VOC
content is less than 5 lbs/gallon.
No--Labeling indicates VOC content is 5 lbs/gallon or
N/A--Facility does not conduct painting. If N/A is
circled, skip to Section 4.
Does facility determine whether paints are considered hazardous
This is a repeat of question 1 of the checklist, now applied to
Yes--Facility has determined whether paints are
hazardous waste before disposing of them. Facility would know this by
reading labels to see if there are any hazardous ingredients
(identified by warning labels on the paint) or if the paints are
No--Facility has not made that determination.
How are used paints, thinners, and solvents disposed?
Reuse--Left over paints and thinners are given away
to customers, employees, or at "paint swaps."
Recycle--Items are recycled by a paint, solvent, or
thinner recycler. (Generally this will apply to solvents or thinners).
Mix with other fluidsMaterials are mixed with other
fluids, such as new solvent or used oil.
Landfill--Materials are disposed at the municipal or a
hazardous waste landfill.
Does facility mix paint amounts according to need?
Yes--Facility mixes paint by the job, as opposed to in large batches,
thus reducing potential paint waste.
No--Facility mixes paints in large batches.
Does facility use newer, "high transfer efficiency" spray applications?
These are spray painting guns that look very similar to lower efficiency guns. High
sprayers should be labeled HVLP on the gun. This is not yet a federal regulatory
(although it is required in some states).
Yes--Facility uses guns that are labeled "HVLP," or can provide other
evidence (e.g., manufacturer information), or tells inspector they know the gun is high
No--Guns are not labeled "HVLP," and facility can not provide evidence
that the guns are HVLP.
If hazardous paints are used, are spray paint booth air filters disposed of properly as
Yes--Hazardous filters are disposed by a hazardous waste hauler and
ultimately landfilled or burned in an EPA permitted facility. Facility should have records
indicating where hazardous filters are sent and records should include hauler and disposal
facility EPA identification numbers.
No--Hazardous filters are disposed with normal trash.
If filters are not hazardous, how are they disposed?
Recycled--Sent to a recycling facility.
Landfilled--Sent to a landfill.