Item 3: Ordinance Adopting Hazardous Substance Tracking Instructions

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Attachment B. report it as a trade secret because it is not YOUR trade secret; it is someone elses. Businesses are not required to seek additional information from suppliers. 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 140 degrees Fahrenheit threshold for ignitability or it may be above 140 degrees Fahrenheit. We need some specific guidelines on how to report solvent-based paints and their ingredients. QUESTION: Do we report the individual ingredients (if listed) when the flash point of the mixture is greater than 140 degrees Fahrenheit? ANSWER: Only report listed individual ingredients with flash points less than 140 degrees Fahrenheit 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 140 degrees Fahrenheit? ANSWER: Only when the individual ingredients are unknown. Known hazardous ingredients of mixtures should be reported individually. Remaining quantities of mixtures, 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. QUESTION:unlisted Are we required to report solvents which have a flash point of lessgreater than 140 degrees Fahrenheit even though the total mixture has a flash point than 140 degrees Fahrenheit? ANSWER: No, unless you have documentation that the solvent has a flash point less than 140 degrees Fahrenheit, and the solvent leaves the mixture so as to become ignitable during processing. - 62-