Date: Wed, 22 Apr 1998 09:16:08 -0400
Greetings,
Has anyone had any experience or insights in this area?
It seems to me the tubes and residual paste from the screen can be
classified as a commercial chemical product because it is un-usable because
it is not in the proper dispenser anymore, not because of contamination. We
could then relatively easily recycle it along with our dross and ship it as
solder paste rather than hazardous waste.
I can't see a way out with the rags even though they could be recycled.
What are other folks doing with this stuff?
Any insights would be appreciated.
Date: Wed, 22 Apr 1998 11:27:12 -0500
Dan, there are recycling companies. I'd suggest you repost your message on the
TechNet and you'll probably get several recommendations. Jack
Jack Crawford, IPC Project Manger - Assembly
Date: Wed, 22 Apr 1998 12:33:37 -0400
My thoughts only,
Date: Wed, 22 Apr 1998 17:02:23 -0400
Interestingly enough, I have recently spoke with U.S. EPA folks on this
issue. It appears that RCRA contains an "empty container" exclusion found
at 40 CFR Sec. 261.7. That section states that "any hazardous waste
remaining in....an empty container...is not subject to regulation" under
RCRA Subtitle C. In other words, "empty" solder paste tubes are not
hazardous waste. Now, how is "empty" defined? According to preliminary
discussion with EPA, it appears that you must illustrate that "all wastes
have been removed that can be removed using the practices commonly employed
to remove materials from the container..."
I like to use a toothpaste tube analogy -- a solder paste tube would be
empty much as a toothpaste tube is empty. In other words, squeezing the
tube yields little if any useful amounts of paste.
I have a call-in to EPA to verify the legality of my interpretation (so
typical legal disclaimer --- do not rely on this preliminary advice) but
my follow-up question to the original question is, is anyone currently
using this exemption?
Thanks in advance for any insight you can provide.
Regards,
Holly Evans,
Date: Wed, 22 Apr 1998 18:07:30 -0500
Charles Barker@I-O INC
We have an arrange with our bar solder/solder paste supplier to pick up our
dross as well as lead bearing wipes , paste containers and waste paste and
return it to the originator for recycling. As a recycled material, it does
not get a hazardous materials rating.
I also deal with our haz waste disposal so I have to keep up with those
regs too.
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From: "Kallin, Dan" Dan_Kallin@BOSE.COM
Subject: Solder Paste
I am curious as to how folks are managing solder paste as its use seems to
be increasing. We apply paste using a screen and generate empty, or nearly
so, tubes from the paste and unusable paste from cleaning off the screen and
contaminated rags. We would like to recycle this material rather than
dispose as a hazardous waste.
My thoughts only, .
Dan Kallin Dan_Kallin@Bose.com.
Environmental Engineer .
Bose Corporation
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From: Jack Crawford
Subject: Re: Solder Paste
X-To: Dan_Kallin@BOSE.COM
2215 Sanders Road, Northbrook IL 60062-6135
crawja@ipc.org http://www.ipc.org
847-509-9700 x 393
fax 847-509-9798
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From: "Kallin, Dan"
Subject: Re: Solder Paste
X-To: Jack Crawford
Finding the recycling company is not the problem. I am more concerned about
the compliance aspects and shipping requirements.
Dan Kallin
Dan_Kallin@Bose.com
Environmental Engineer
Bose Corporation
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From: Holly Evans
Subject: Re: Solder Paste
X-To: "Kallin, Dan"
In-Reply-To: <9DDA1967DFDDD011B41300A0C95C38136D3B56@juno.bose.com>
Dear Compliancenetters:
Director of Environmental and Safety Programs, IPC
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From: Charles Barker
Subject: Re: Solder Paste
X-To: Dan_Kallin@BOSE.COM
04/22/98 06:07 PM
Dan,