By Angela Babin, M.S., and Michael McCann, Ph.D., C.I.H.





Hazardous Waste Generators

Sewage System

Types of Hazardous Waste

Methods of Waste Management


For Further Information



Artists, art teachers and students often produce solid waste and aqueous waste as a result of their art processes. Much of this waste can be hazardous, leaving the problem of how to dispose of it safely and legally. Some waste, while non- hazardous, can be bulky and use up space in our overloaded landfills. See our booklet Waste Management and Disposal for Artists for more information and details on the disposal methods for particular classes of art materials.



In the United States, the Environmental Protection Agency (EPA) regulates the disposal of hazardous waste under the Resources and Conservation Recovery Act (RCRA). Industrial wastewater discharges are not considered solid waste, and are regulated under the EPA Clean Water Act. The Resources and Conservation Recovery Act (RCRA) was enacted in 1976 as an amendment to the Solid Waste Disposal Act. RCRA regulations are found in Part 240 of Title 40 of the Code of Federal Regulations (40 CFR 240). Subtitle C of Part 240 regulates the management of hazardous waste through its "cradle-to-grave" system of regulations for the identification of hazardous waste and generators, amongst other requirements. This waste manifest system tracks hazardous waste through production, transportation, and disposal.

The responsibility for administering RCRA rests with the individual states. While most of the states' hazardous waste programs directly resemble RCRA, contact individual state environmental offices to elucidate particular differences.


Hazardous Waste Generators

There are different categories of producers of hazardous waste, according to 40 CFR Part 261.5. The basic distinctions center around the amounts of hazardous waste produced. These categories are:

1. Large Quantity Generators (LQG): LQGs produce more than 1000 kilogram per month (kg/month) of hazardous waste, or more than I kg/month of acutely hazardous waste. LQGs must obtain a US EPA identification number from state hazardous waste management agency or EPA regional office. They must comply with storage time, quantity, handling and record-keeping (manifests) requirements.

2. Small Quantity Generators (SQG): SQGs produce more than 100 kg/month and less than 1000 kg/month, and accumulate less than 6,000 kg. Requirements for SQGs are similar to those for LQGs.

3. Conditionally Exempt Small Quantity Generators (CESQG) produce less than 100 kg/month (220 pounds) of hazardous waste, or less than I kg/month (2.2 pounds) of acutely hazardous waste. They are "conditionally exempt" from Subtitle C, and the manifest system. Notwithstanding, CESQGs must identify all hazardous waste, never accumulate more than 1000 kg, must treat or dispose of their waste onsite or make sure that the waste is sent to an approved facility. Not all states have a CESQG status.

4. Household Hazardous Waste (HHW): HHWs are exempted from federal hazardous waste regulations [40CFR Part 261.4(b)(1)]. This exemption allows individual citizens, and home artists and hobbyists, to discard materials into municipal wastestreams. EPA states that the reason for this exemption doesn't mean these wastes aren't hazardous, rather there is Congressional interest that wastes generated by consumers in their households be exempt from federal hazardous waste regulations. Also, handlers of household hazardous wastes don't need to comply with the federal regulations when managing household wastes.

Categories 1, 2 and 3 of hazardous waste generators represent industrial or "commercial" generators. This would include an arts community group, printmaking studio, school district, college, a photographic studio, or even professional artists if they produce hazardous wastes in enough quantity to meet the definitions of a CESQG, or even a SQG.


Sewage System

The Clean Water Act of 1977 can restrict what may be dumped into the sewer system. This Act is directed at "significant industrial users," who discharge large amounts of wastewater on a daily basis. Large photographic processing studios and large electroplating studios are examples of businesses that may need to be within compliance within this law. All publicly owned treatment works are required to develop local sewer use codes which regulate the concentration of hazardous substances in waste water. These limits are designed to reflect the particular local environmental conditions of the area.

Non-toxic liquids (e.g. neutralized acids and alkalis), and small amounts of some hazardous, water­based solutions (e.g. dye solutions, photographic solutions) can be poured down the drain with lots of water if the sewage system has a wastewater treatment plant with a bacterial treatment stage that can detoxify small amounts of chemicals. Septic tank systems are more sensitive since you don't want to kill off the septic tank bacteria. Solvents should never be poured down the sink.


Types of Hazardous Waste 

There are several categories of chemicals used by artists and schools that come under the heading of hazardous waste. These include:

1. Hazardous Waste Chemicals: solvents, formaldehyde, lead compounds, mercury, chromates, etc.

2. Ignitable Waste: flammable and combustible liquids, solids capable of causing fire through friction, absorption of moisture, or spontaneous combustion, ignitable compressed gases, and oxidizing substances like potassium chlorate and concentrated nitric acid.

3. Corrosive Waste: wastes with a pH <2 or> 12.

4. Reactive Waste: cyanide or sulfide wastes which can generate dangerous amounts of toxic gases between pH 2 and 12.5, unstable compounds such as methyl ethyl ketone peroxide.

5. Acute Hazardous Waste: arsenic compounds, hydrogen cyanide and cyanide salts, many pesticides, vanadium pentoxide,etc.

6. Leachable Toxic Waste: materials that can leach into water more than specified levels of the following metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver. In addition, leachable levels of other chemicals are regulated, including benzene, cresols, p­dichlorobenzene, methyl ethyl ketone, pentachlorophenol, perchloroethylene, trichloroethylene, and several pesticides.

7. Miscellaneous: Other classes of hazardous waste, not normally encountered by artists, include radioactive materials and pathological waste.


Methods of Waste Management

There are a variety of methods of managing waste materials, including waste minimalization, recycling, treatment, pouring it down the drain, evaporation, ordinary landfills, and taking it to a hazardous waste disposal company. Not all of these options apply to hazardous waste.

1. Waste Minimalization: The amount of hazardous waste can be minimalized by using less toxic substitutes, for example using water-based screen printing inks instead of solvent-based ones.

2. Recycling: Many waste art materials can be reused, or used by someone else. For example, mineral spirits used for cleaning oil painting brushes can be allowed to settle, and then strained through cheesecloth to remove the solids. The filtered solvent can then be reused. Leftover art materials can be donated to an art center or secondary school. Note that hazardous materials should never be donated to elementary schools, and highly toxic materials like lead glazes should not be recycled.

3. Evaporation: Small amounts of solvents or solvent-containing materials (less than a pint) can be evaporated if no other better alternative is available. Evaporation should take place outside, or inside a local exhaust hood where no one will be exposed to the solvent vapors.

4. Landfill: Non-hazardous, solid waste materials can be placed in the regular trash for carting to a normal landfill. Some toxic materials can also be placed in the trash, including clay, metals, paint residues, etc. Glazed pottery can be placed in the trash if it doesn't leach toxic metals.

5. Treatment: Some materials can be treated to make them non- hazardous. Neutralization of dilute acid and alkali wastes, and recovery of silver from photographic fixer solutions are examples of chemical treatment of hazardous waste that artists can do to make it non-hazardous.

6. Hazardous Waste Disposal Companies: Hazardous materials that can't be properly disposed of in other ways should be taken to a licensed hazardous waste disposal company or picked up by a licensed hazardous waste transporter. Often this can be expensive. If you are considering transporting the hazardous waste yourself, you should be aware that many fire departments restrict the transportation of flammable liquids, and RCRA regulates transporting hazardous waste.

7. Household Hazardous Waste Collection: Household hazardous waste collection programs (HHWCPs), often organized by counties or municipalities, are intended to collect hazardous waste from homes. To be eligibile for these programs, materials must be generated by individuals on the premises of a temporary or permanent residence.

There is a grey area surrounding the boundaries that define artists and their working scenarios. For example, an artist who has a separate studio may not be eligible for disposal of unwanted materials at a household hazardous waste collection program. Likewise, homeowners, gardeners and artists who bring in suspiciously large amounts of materials to a household hazardous waste collection program may be turned away from services because their quantities resemble those of businesses, small farmers, and commercial art businesses. CSA has produced a list of U.S. and Canadian collection programs that accept waste from both individual artists, and also from small "commercial" art businesses. For this list, along with recycling and exchange program information, see our data sheet Health and Safety Resources for Artists.



Environmental Protection Agency. 40 CFR 260 to 267. Hazardous Waste Management Regulations.
Government Printing Office, Washington DC. 1989.

Environmental Protection Agency. RCRA Orientation Manual 1990 Edition. Office of Solid Waste,
Washington D.C. 1990.

McCann M and Babin A. Waste Management and Disposal forArtists. CSA 1992.


For Further Information. . .

Written and telephoned inquiries about hazards in the arts will be answered by the Art Hazards Information Center of the Center for Safety in the Arts. Send a stamped, self-addressed envelope for a list of our many publications. Permission to reprint this data sheet may be requested in writing from CSA. Write:

Center for Safety in the Arts
5 Beekman Street, Suite 1030
New York, NY 10038
Telephone 212-227-6220

This data sheet was produced with the assistance of the Environmental Protection Agency. CSA is also partially supported with public funds from the National Endowment for the Arts, the New York State Council on the Arts, the New York City Department of Cultural Affairs, and the NYS Department of Labor Occupational Safety and Health Training and Education Program.

© Copyright Center for Safety in the Arts 1992