(1) If a sanitary sewer serving a paint processing
operation discharges to a government-operated sewage
The use of respiratory protection equipment does NOT
treatment plant (STP), notify the STP operator of the
waive the requirement for engineering control measures.
approximate additional loadings of total organic carbon,
The ventilation design specifications for spray paint
biochemical oxygen demand, and total processing
booths are in TB MED 514.
operation prior to discharge.
d. Preferred Paints.
Whenever possible, Type II or Type III aliphatic
(2) If a sanitary sewer serving a paint processing
polyurethane paints (PUP) should be substituted for
operation discharges to privately owned treatment works,
Type I since they contain no lead or chromate. Non-lead-
pretreatment of wastewaters may be required by local
containing primers should be used when available.
The installation environmental
e. Warning Labels.
coordinator should determine such cases with public
Warning labels are required on products containing lead
government installations. Pretreatment regulations have
been summarized by the USAEHE Water Quality
20. MEDICAL SURVEILLANCE General. Medical
Information Paper No. 13.
surveillance to detect adverse health effects will be
determined by the installation medical authority (IMA)
22. SPECIFIC HAZARDS
based on the specific constituents of the coating. In
general, medical surveillance is required for anyone who
works more than 30 days per year in either a paint
spraying operation or in a brush or roller application
Coatings should not be applied at temperatures
when respiratory protection is required. Personnel
involved in painting at direct support, general support,
below 50'F (10C) as they will not cure properly.
and depot levels of maintenance will normally require
surveillance. Vehicle/equipment operators and unit
b. Equipment Hazards.
maintenance section personnel usually do not perform
enough brush touchup painting to warrant medical
Mask intake and exhaust parts, breathers, etc.,
carefully to prevent dust, solution, water, or
metal conditioner from entering the engines of
Unserviceablepaints including aliphatic polyurethane
paint (PUP)/epoxy polyamide enamel (EPE) blend must
Do not use solvents on electronic equipment as
be discarded as a hazardous waste according to AR
they may cause changes in performance.
420-47. Note that because they contain ignitable
solvents, these unusable blends of PUP are defined as
Do not use petroleum based products on natural
hazardous wastes by the Resource Conservation and
rubber as they are destructive agents.
Recovery Act (RCRA) of 1976 as amended by the
Hazardous and Solid Waste Amendments of 1984.
Do not use spray equipment containing any
Unserviceable component B is a hazardous waste per
aluminum components to apply coatings
RCRA due to ignitable solvent content; not because it
formulated with 1,1,1 trichloroethane (such as
MIL-C-46168, Type m).
b. Method of Disposal.
The method used to dispose of this waste stream
23. OTHER PUBLICATIONS
depends on the types of paint used. When the paints
Additional safety information is contained in the
contain no hazardous heavy metals, the liquid portion of
the waste stream may be able to be discharged into the
a. AR 40-5, Preventive Medicine.
sanitary sewer and the sludge disposed of in a sanitary
b. CFR 1910, OSHA Safety and Health Standards.
landfill. The environmental coordinator should be
c. DODI 4145.19-R-1, Hazardous Materials
contacted to ensure state and local ordinances are not
Handling and Storage Criteria.
violated. If heavy metal-based paints have been used,
d. TB MED 502, Occupational and Environmental
samples of the liquid and sludge should be analyzed for
Health Respiratory Protection Program.
the characteristic of extraction procedure (EP) toxicity
(heavy metals) and disposed of accordingly.