Complying with regulations, protecting worker health and safety, and facility management need to be considered when making a decision to use a traditionally toxic material or finding a less toxic, less regulated process material.
Listed below are some general regulations that may apply to the raw materials and processes used at a typical fiberglass facility:
Worker Health and Safety
OSHA and other state level worker protection authorities set permissible exposure levels (PELs) for certain chemicals and hazardous exposures.
The offenders - styrene, acetone, volatile organic compounds (VOC) in resin, gel coat and
aesthetic finishing materials, tool and equipment cleaning solvents, toluene in some mold release agents, dimethyl phthalate in some catalysts.
Facilities Management
Local fire codes regulate flammable products, like acetone. These codes define how much raw material can be stored on site. They also define how products should be stored and/or "processed" in your shop. For example, peroxide catalysts must be stored in an explosion-proof cabinet.
The offenders - acetone, other equipment and mold cleaning solvents, catalysts
Air Quality
Federal, state and local air authorities are all concerned about the impact of this industry on the quality of air. Styrene is a listed Hazardous Air Pollutant (HAP), and a suspected carcinogen, an experimental poison by ingestion and inhalation, and an eye and skin irritant.
The "Boat rule" under the National Emission Standards for Hazardous Air Pollutants (NESHAP) is applicable to fiberglass resin and gel coat operations, carpet and fabric adhesive operations. This MACT rule requires all major sources to meet HAP emission standards reflecting the application of the maximum achievable control technology (MACT).
The offenders - styrene, acetone, VOCs in resin and gel coats, toluene in some mold release agents, dimethyl phthalate in some catalysts, aesthetic finishing materials, equipment cleaning solvents
Water Quality
Spent solvents or other wastes should never drain onto the ground or into a septic system, storm drain, surface water or any other drain not connected to a sanitary sewer. Improper disposal or releases can have an adverse affect on groundwater, surface water and sediments.
Hazardous Waste
Hazardous wastes are determined by characteristics (flammable, reactive, corrosive or toxic) or by laboratory test of the particular waste.
The offenders - resins, initiators, catalysts, cleaning solvents, paints, stains, thinners, spent filters
Solid Waste
Overspray solids, unused products, solidified resins, trim-ends and cutouts typically are not regulated. However, some landfills do impose restrictions on pick-up and disposal. Contact your local landfill to determine if restrictions apply.
Community Right-to-Know
The Superfund Amendments and Reauthorization Act (SARA) promulgated the "Community Right-to-Know" law, requiring businesses to report use and releases of hazardous chemicals. This federal law affects facilities that use over 10,000 lbs of any solvent and/or over 50,000 lbs of resin per year. Acetone was recently removed from SARA's regulated list, but other solvents like toluene and xylene remain listed and are regulated.
Many businesses only account for waste disposal costs rather than considering all of the associated costs with using toxic raw materials and polluting, energy or water-consuming processes, and inefficient technologies. Total cost accounting ensures that certain management, engineering, and overhead costs are tagged to cost considerations for environmental operations.
Examples of potential cost and savings opportunities associated with improving environmental performance can include:
Raw Materials Reduction in Quantity or Toxicity
Storage and inventory
Spill prevention
Secondary containment
Container labels
Water Use Reduction
Water use
Sewer and discharge fees
Wastewater treatment
Sludge handling and disposal
Solid and Hazardous Waste Reduction
Waste collection and containers
Labels and labeling
Onsite management
Recycling and reuse opportunities (and avoided purchase of new or virgin materials)
Disposal
Transportation
Air Pollution Reduction
Inspection and monitoring
Ventilation and filtration
Pollution control equipment
Sampling, monitoring, and testing
Discharge fees
Management and Overhead Costs to Consider
Permit preparation and maintenance
Regulatory impact analysis
Hazard analysis and communication
Product/vendor research
Emergency planning
Spill response procedures and equipment
Right-to-know, emergency, and other safety and health training for staff
Sampling and testing
Inspections and audits
Information and tracking systems
Regulatory reporting
Insurance and legal fees
Penalties and fines for non-compliance
Future liability
