TCLP testing, as it applies to painting operations, is performed to determine the level of metals contained in used spraybooth filters, prep deck filters, still bottoms, and shop dust. In this context, TCLP testing measures Arsenic, Barium, Cadium, Chromium, Lead, Mercury, Selenium and Silver. Performing full spectrum TCLP analysis would be appropriate only for those bodyshops using paint products that contain herbicides and pesticides. One exception to this test range is the Total Toxic Organics (TTO) testing performed on waste from water-wash spray booths.

Once testing is performed, the results are evaluated against the Federal Toxicity Characteristic (TC) Constituents and Regulatory Levels as published in the Federal Register (3/29/90). All waste products with results falling within the acceptables metals levels as set forth by the EPA do not need to be handled, stored, transported or disposed of as hazardous waste.

-- Tara L. Munro (dlhe1@aol.com), July 26, 1997