1998 EPCRA 313 Q&A, Question # 273

273. Are listed toxic chemicals contained in paint that is used to paint processing equipment subject to threshold determination and release and other waste management reporting?
Yes. Paint used on process related equipment would not qualify for the structural component exemption. Amounts of listed toxic chemicals used to paint process related equipment must be considered toward threshold determinations and release and other waste management calculations.

Additional Details

Question # 273 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-273 Status Archived
Category 2. Exemptions Subcategory 2.B. Facility Maintenance and Structural Components
Keyword(s) Paint, Pipes, Structural Component Exemption
Updated Q&A Question Number 356
Prior Q&A [Archived] Question Number 95, 1998 Newly Added Industries
Prior Source: [Archived] Question Number 95, 1998 Newly Added Industries: Process; Structural Component Exemption; Threshold Determination; Waste. Addendum means that the source of the 1998 Q"A is the Addendum to the Guidance Documents for the Newly Added Industries (EPA 745-B-98-001). Type of Change: Minor - Minor edits are those edits which only involve non-substantive additions or deletions of words to provide clarity in the Question and Answer. Description of Substantive Edits: NA - NA indicates no substantive edits were made to the original Question and Answer.