Ordinance No. 20222 - Laserfiche WebLink

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:1 n 11 26. Many paints contain up to 15 ingredients which can be solvents, pigments, defoamers, or resins. The user cannot tell from the MSDS which of these ingredients are solvents and! or may fall into the "characteristic" category. Furthermore, the aggregate flash point of the total mixture may fall below the 1400 F threshold for ignitability or it may be above 1400 F. We need some specific guidelines on how to report solvent-based paints and their ingredients. f,i ~l i , r'11'. 1 QUESTION: Do we report the individual ingredients (if listed) when the flash point of the mixture is greater than 1400 F? : 1'., .. ANSWER: Only report listed individual ingredients with flash points less than 1400 F when they are removed from the mixture during the process, so as to become ignitable. , QUESTION: Can we report the entire mixture without listing individual ingredients if the flash point is less than 1400 F? , 1 ANSWER: Only when the individual ingredients are unknown. Known hazardous ingredients of mixtures should be reported individually. Remaining quantities of mix- tures, if the remainder is known to be hazardous (characteristic) but the ingredients are not known, should be reported under the appropriate generic characteristic substance category. ! 1 : r ~ I .. j QUESTION: Are we required to report unlisted solvents which have a flash point of less than 1400 F even though the total mixture has a flash point greater than 1400 F? ANSWER: No, unless you have documentation that the solvent has a flash point less than 1400 F, and the solvent leaves the mixture so as to become ignitable during process- ing. In the future, the Toxics Board will develop a list of reportable characteristic sub- stances. D. MANUFACTURING vs. MAINTENANCE USES General guidelines: Hazardous substances that are on a site, but whose use is not directly related to manufacturing or related research and development, are not reportable. This area is subject to considerable interpretation, mostly concerning maintenance and operation of equip- ment. In general, the Toxics Board has drawn a distinction between substances used for cos- metic purposes (not reportable) and those used for necessary maintenance (reportable); and between the maintenance of actual manufacturing equipment (reportable) and equipment with non-manufacturing purposes (not reportable). The board has also drawn a distinction between materials used to maintain and operate motorized vehicles (e.g., forklifts) and those used to operate and maintain non-motorized vehicles (e.g., carts). Materials in the former category are not reportable, while those in the latter are. F-9