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Wood Furniture Manufacturing: Reasons for Change
Table of Contents
Background and Overview
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Facts about NESHAP for Wood Furniture Finishing
Describes how National Emission Standard for Hazardous Air Pollutants (NESHAP) affects wood furnitur...

Final Standards for Hazardous Air Pollutant Emissions from Wood Furniture Manufacturing Operations; ...
Federal Register Notice - promulgates standards that limit the emissions of hazardous air pollutants...

RCRA in Focus - Furniture Manufacturing and Refinishing
Provides an overview of the federal regulations and the wastes that are likely to be hazardous. It a...

Wood Furniture: The Clean Air Act Amendments of 1990 and Pollution Prevention Opportunities
Details requirements of the Wood Furniture NESHAP and provides information on using P2 techniques to...


There are a number of reasons why facilities change their operating practices and implement pollution prevention techniques and technologies. These include cost savings, improved worker health and safety, decreased liability, and reduced regulatory burdens.

Cost Savings

One of the greatest drivers for facilities in implementing pollution prevention projects is cost savings. These can be achieved by the following:
  • reducing coating use
  • reducing or eliminating waste treatment and/or disposal costs
  • improving productivity
  • reducing liability and insurance premiums
  • reducing regulatory burdens
Traditional nitrocellulose-based sealers and topcoats are 25 percent solids or less, meaning that 75 percent or more of the coating purchased evaporates and is wasted even if the transfer efficiency (TE) is 100 percent. A low-solids content combined with typical spray gun TEs results in only a small percentage of the coating actually remaining on the finished piece. For example, a 25 percent solids coating applied with a TE of 25 percent results in only 6 percent of the original gallon of coating ending up on the finished piece and 94 percent wasted to evaporation and overspray. Increasing TE, increasing solids content of the coating, and/or switching to alternative coatings can reduce operating costs by reducing virgin material purchase and waste management costs.

Worker Health and Safety

Harmful chemicals are released into the air when solvent-based coatings are used. If a gallon of paint weighs 8 pounds, and it is 75 percent solvents by weight (i.e., 25 percent solids), then by the time that gallon is used, 6 pounds of solvents have gone into the air for employees and neighbors of the facility to breath. Some finishes, such as stains, can contain less than 5 percent solids, so more than 95 percent of the original weight of each gallon ends up in the air. The most commonly used wood finishing chemicals, such as toluene, xylene, methyl ethyl ketone (MEK), methyl isobutyl ketone (MIBK), methanol, and methylene chloride can affect the central nervous system. Exposure to these chemicals can cause dizziness, headaches, nausea, confusion, sleepiness, and loss of coordination. These symptoms can decrease productivity and increase worker injury rates. Long-term effects can include cancer and reproductive problems, or damage to the liver, kidneys or brain. Increasing the solids content of the coatings and/or switching to alternative coating can reduce the potential impact on workers safety and health.

Liability

Solvent-based coatings are flammable and as such their use results in high insurance rates and severe restrictions on storage conditions. Storage and use of harmful chemicals and hazardous waste creates the risk of spills therefore increasing the risk of worker exposure, environmental contamination, and subsequent cleanups.

Regulations

Use of harmful chemicals is regulated, as is the waste generated, creating recordkeeping and reporting burdens, often along with permit fees. Minimizing the quantity of hazardous materials used, waste generated, and air emissions can reduce or eliminate certain regulatory requirements as well as improve worker health and safety, and reduce liability.

NOTE: Vendors often suggest switching to so-called "compliant coatings" as a way to avoid air regulations. However, chemicals in "compliant coatings" could still be subject to regulation under many state air toxics programs. Therefore, switching to so called "compliant coatings" does not automatically mean there are no regulatory obligations or that the coatings are non-toxic. For example, "compliant coatings" are often formulated using acetone. Exposure to acetone can be harmful to human health. Acetone is more flammable than many other solvents, increasing fire and explosion hazards and most likely, fire insurance rates. Acetone is also more volatile than most other solvents creating potential quality problems because the coating dries too quickly. Furthermore, the smell of acetone is not pleasant for employees. Just because a coating is called a "compliant coating," does not necessarily mean there are no concerns with its use.

Air Emission Regulations

Many solvents used in the wood coating industry are primarily made up of one or more volatile organic compounds (VOCs). VOCs combine and interact with other pollutants in the air to form ground-level ozone, the main component of smog. In order to help reduce formation of ground-level ozone, VOC emissions are regulated under the federal Clean Air Act through a control technology guideline (CTG). Many individual VOCs are associated with harmful effects to human health. Under the 1990 Clean Air Act Amendments (CAAA), the United States Environmental Protection Agency (U.S. EPA) identified a list of 188 hazardous air pollutants (HAPs), many of which are VOCs. U.S. EPA has also promulgated a National Emission Standard for Hazardous Air Pollutants (NESHAP) specific to the wood furniture industry that contains work practice standards and sets limits on the HAP content of coatings. Many states have adopted their own VOC and HAP regulations specific to the wood furniture industry. States can also regulate use of chemicals that are not VOCs or HAPs, such as acetone, under state air toxics regulations. Each state can have its own unique air pollution control requirements and should be consulted to determine the regulations that apply to a particular facility.

Hazardous Waste Regulations

Hazardous wastes commonly generated by wood finishers, and their corresponding waste codes are listed in the table below. Note this is not an exhaustive list. There could be other wastes generated at a facility that might also be of concern.

Table: Commonly Generated Hazardous Wastes

General Waste Stream Usual Waste Code Likely Hazardous Properties
Thinner, cleanup solvents, still bottoms D001
D004
F003
F005
Typically ignitable, petroleum-based solvents that contain toxic constituents.
Stains, sealers, lacquers D001
D004
F003
F005
Often have ignitable solvents that may contain toxic constituents such as methyl ethyl ketone (MEK).
Paints, paint-related materials D001
D004
F003
F005
Often have ignitable solvents or >5% petroleum content that contain toxic constituents. Some colored paints may be toxic for metals.
Lacquer dust, spraybooth filters D001
D004
Could be ignitable and/or contain toxic constituents. Perform hazardous waste characterization tests.
Parts cleaning solvents D001
D004
F001
Typically ignitable, petroleum-based solvents that contain toxic constituents.

Generally, wastes from the wood finishing process are characteristic hazardous wastes because of ignitability and/or toxicity. In addition to the types of waste generated, the quantity of hazardous waste generated each month also affects how a facility is regulated. Generators of small amounts of hazardous waste (under 220 pounds per month) are often subject to less stringent regulation than facilities generating larger quantities. Each state can have its own unique hazardous waste regulatory requirements and should be consulted to determine the regulations that apply to a particular facility.

The safe storage, transportation and disposal of hazardous wastes can reduce environmental liability. The cost of cleaning up an accidental release is much higher than the cost of proper hazardous waste management.


 

The Topic Hub™ is a product of the Pollution Prevention Resource Exchange (P2Rx)

The Wood Furniture Manufacturing Topic Hub™ was developed by:

Northeast Waste Management Officials' Association
Northeast Waste Management Officials' Association
Contact email: abray@newmoa.org

Hub Last Updated: 1/8/2013