An interesting question arose in a shop I was called to recently to take waste product samples for TCLP testing. The shop owner told me that they keep a barrel for paint waste disposal in their shop and that their commercial recycler comes twice a year to remove the barrel. This revelation came right on the heels of three bodyshops in the same state being found in violation of "storing hazardous waste on the premises for 90 days without a permit". When I shared this with the shop owner, the response was a very surprised "My commercial recycler never told me that !!" My sources tell me that a generator would have to exceed a certain volume in order to fall prey to a violation of that nature. Two other questions immediately came to my mind. A) What is the volume threshold to avoid and B) What else are the commercial recyclers NOT telling their customers?" Our team is researching this issue to determine what it means to the shop in question but its certainly worth investigating to prevent a shop owner from being blindsided.

-- Tara L. Munro (dlhe1@aol.com), July 23, 1997