Paint - Oil & Solvent Based

 Must include # of drums & 1 stop charge in the purchase  

Paint - Oil & Solvent Based



This profiles covers solvent based paints that are unused or out of specification.  Do not mix aluminum roof paints with other solvent based paints.  Stains and other oil based coating are typically acceptable to combine.  


Generator Knowledge 
  1. Generators can generally use the knowledge clause in RCRA to determine that these paints are ignitable (DOO1) 
  2. Generators can generally use the knowledge clause in RCRA to determine that these paints are not corrosive (DOO2)
  3. Generators can generally use the knowledge clause in RCRA to determine that these paints are not reactive (DOO3)
  4. Generators can generally use the knowledge clause in RCRA to determine that these paints do not contain regulated levels of pesticides
  5. Generators can generally use the knowledge clause in RCRA to determine that these paints are not a a K, U, or P listed waste.  Paint is not listed on the U or P RCRA List.
Common Analytical Parameters for this Waste Stream
  • Generators should use testing & analysis to determine if the paints have leachable concentrations of metals (DOO4 thru D011) or organic constituents (D012 thru D043) excluding pesticides and herbicides.  
  • Flash point if the generator requires  confirmation that the paints are ignitable (D001).  

Do and Don't
  • 1 & 5 gallon paint cans can be consolidated into 55 gallon drums without triggering a RCRA treatment activity.  
  • Virgin and spent solvents are not paints and should not be consolidated with paints when consolidating small containers. 
  • The empty small paint cans can be recycled or disposed of as solid waste as long at they are RCRA Empty.
  • Water and oil based paints should be containerized separately.  The water content lowers the fuel content of this material. 
  • Do not mix aluminum roof paints with other solvent based paints.  Solvents based paints are used for energy recovery and the firms that use this fuel have problems with the aluminum content.   The aluminum paints tend to float to the top of the drum and can be obvious even in small quantities.   
  • Do not put the empty containers in the drum.  Generator will incur surcharges for empty containers in a fuels drum.  
  • Generators are required to have an EPA ID to ship Hazardous Waste.
  • Paints are flammable and OSHA requires these materials to be stored in flammable liquid cabinets.
  • Keep the inventory low.  These materials are a hazardous waste and are subject to RCRA storage limitations.  An excess inventory of these material is an easy ticket for a regulatory inspector to punch.  
  • These cans can be dry packaged in a drum but liquid paint cannot be placed in the drum.   In a dry pack situation, 16 each 1 gallon paint cans is the maximum per drum.  If the cans are emptied that number rises to increases to 50 gallons per drum.
  • The solid paint content in the drum should be limited to 20% to eliminate surcharges from the disposal facility.  
Related EPA Enforcement Actions

ENSAT Service Area
  • Disposal Services are services are limited to clients in Maryland & Virginia at this time.