Nail Polish Remover Waste Characterization
Transcription
Nail Polish Remover Waste Characterization
Publication Number SQG-NAILS-1(9/03) rev. 4/06 April 2006 Final Report Nail Polish Remover Waste Characterization Alice Chapman, P.E. Local Hazardous Waste Management Program in King County Technical Assistance and Pollution Prevention Team Laurie Foster Local Hazardous Waste Management Program in King County Survey Team This report was prepared by the Local Hazardous Waste Management Program in King County, Washington. The program seeks to reduce hazardous waste from households and small quantity generator businesses in King County by providing information and technical assistance to protect human health and the environment. For more information or to order additional copies of this report contact: 130 Nickerson Street, Suite 100 Seattle, WA 98109 206-263-3050 TTY Relay: 711 Fax 206-263-3070 www.govlink.org/hazwaste/ Publication Number SQG-NAILS-1(9/03) rev. 04/06 Chapman, Alice and Foster, Laurie. Nail Polish Remover Waste Characterization, Final Report. Seattle, WA: Local Hazardous Waste Management Program in King County, 2006. Alternate Formats Available Voice: 206-263-3050 or TTY Relay: 711 PolishRemoverSummaryReportFinal.doc Printed on Recycled Paper CONTENTS Introduction and Research Objectives .........................................................................................1 Research Objectives...................................................................................................................1 Generating Nail Polish Remover Waste .......................................................................................2 Products Used to Remove Nail Polish .......................................................................................2 Process Description....................................................................................................................2 Regulatory Interpretation – Listed Solvent .................................................................................3 Discarded Chemical Product List ..............................................................................................3 Dangerous Waste Sources List ..................................................................................................3 Waste Designation for Ignitability ................................................................................................5 Waste Designation for Toxicity .....................................................................................................6 Book Designation ......................................................................................................................6 Potentially Toxic Ingredients ..............................................................................................6 Waste Measurements from a Simulation.............................................................................6 Waste Measurements from a Nail Technician.....................................................................6 Static Acute Fish Toxicity Test..................................................................................................7 Final Designation for Toxicity...................................................................................................7 Conclusions .....................................................................................................................................8 Summary of Research Findings .................................................................................................8 Recommendations for Nail Salons.............................................................................................8 Appendix A US EPA Interpretation of “Sole Active Ingredient” in Discarded Chemical Products.........................................................................................................................................11 Appendix B Letter from Department of Ecology to Lawrence Berkeley Laboratory ..........17 Appendix C Simulated Nail Polish Remover Waste, Toxicity Book Designation..................25 Appendix D Nail Academy Waste, Toxicity Book Designation...............................................37 Appendix E Sample Plan: Fish Bioassay..................................................................................49 Appendix F Static Acute Fish Toxicity Test Results ................................................................55 Bibliography..................................................................................................................................75 King County – Nail Polish Remover Waste Characterization i This page was intentionally left blank. ii King County - Nail Polish Remover Waste Characterization INTRODUCTION AND RESEARCH OBJECTIVES The Local Hazardous Waste Management Program in King County (LHWMP) provides education and technical assistance to small quantity generators1 (SQGs) of hazardous waste. SQGs generate less than 220 pounds of hazardous waste a month (or batch) and never accumulate more than 2,200 pounds. The limit is 2.2 pounds for certain wastes. The LHWMP’s Survey Team visits all businesses in selected geographic areas of King County to identify SQGs, observe their hazardous waste handling practices, answer questions, assess their needs and provide technical assistance. Data collected by the survey team are used to develop educational materials and to identify business types for future program efforts. Nail salons generate spent cotton balls or cotton cord saturated with nail polish remover. The Survey Team found that nearly all nail salons were disposing of spent saturated cotton to the regular garbage. The LHWMP needed to know whether these wastes designated as hazardous or dangerous under Federal and State regulations to determine whether disposal to the garbage was an acceptable practice. Technical research and sampling were needed to answer this question. This report presents the results of two small studies and regulatory research to characterize spent saturated cotton waste from nail salons in King County. In addition, the Survey Team developed a brochure and compiled an extensive file of resource materials related to nail salons and general information about the nail salon industry. Research Objectives Technical research focused on these two objectives: • What products are typically used to remove nail polish and how is spent saturated cotton waste generated? • How does spent saturated cotton waste designate under State and Federal hazardous waste regulations? A local nail academy provided product information and demonstrated how nail polish remover waste is generated. Spent saturated cotton was designated by gathering and quantifying generator knowledge, researching listed waste regulations, and conducting a fish bioassay for acute toxicity. 1 Under Federal regulations, SQGs are referred to as Conditionally Exempt Small Quantity Generators (CESQGs). King County - Nail Polish Remover Waste Characterization 1 GENERATING NAIL POLISH REMOVER WASTE Products Used to Remove Nail Polish During site visits to nail salons, the Survey Team found that acetone (also called 2propanone) was most often used to remove nail polish. Several other solvents, often as mixtures with acetone, were also used. Identified solvents were N-butyl acetate, isopropanol, ethyl acetate and methyl ethyl ketone. A few products marketed as “nonacetone” were reviewed and found to contain ingredients with equivalent or higher potential risks to safety, health or the environment than acetone. Nail salons should not assume that “non-acetone” products are more beneficial than acetone. A careful review of proposed alternatives is necessary before switching to non-acetone products. Process Description A local nail academy provided process information and allowed staff to observe a nail technician removing polish. Nail polish remover was stored in a small flip-top plastic bottle at the table. The table had a built-in downdraft fan with a small cloth bag filter for capturing particulates. The nail technician pulled a section of 100 percent cotton coil from a tabletop dispenser and applied nail polish remover. The technician did not wear gloves or any other protective clothing or equipment. The same piece of saturated cotton (now about 1/2 inch in diameter) was used to remove polish from all ten fingers of the customer. The cotton was rotated during use so that it was evenly soiled with removed nail polish when done. The spent cotton had no visible dry spots. The nail technician reported that when removing darker colors, more polish remover is used. The spent saturated cotton was put into a small garbage can next to the table. 2 King County - Nail Polish Remover Waste Characterization REGULATORY INTERPRETATION – LISTED SOLVENT Acetone is called a “listed solvent” because it is on two lists of hazardous wastes: discarded chemical products and dangerous waste sources. After reviewing Washington State’s Dangerous Waste regulations (Chapter 173-303, WAC) to determine whether nail salon waste designated as listed hazardous waste, it was concluded that spent nail polish remover waste is not listed waste. However, nail salons may sometimes generate other listed wastes. Discarded Chemical Product List Discarded chemical products (described at WAC 173-303-081 and listed at WAC 173303-9903) include commercial chemical products, off-specification products, containers (including inner liners & residue) that held a commercial chemical product, and residue or contaminated materials resulting from the cleanup of a spill of these items. Acetone present in spent cotton waste, when generated as described on page two, does not meet any of these criteria. However, nail remover product containing acetone as the sole active ingredient (see Appendix A for a clarification of this term) would designate as a listed hazardous waste (dangerous waste number U002) under either of the following conditions: • The nail salon decided to dispose of a container (either completely or partially filled) of unused acetone. • Sorbents, rags, wash water, contaminated soil or other residues were generated while cleaning up a spill of unused acetone. Dangerous Waste Sources List Dangerous waste sources (described at WAC 173-303-082 and listed at WAC 173-3039904) include dangerous waste number F003, spent nonhalogenated solvents (including acetone) generated under certain circumstances. A review of regulations and resources provided by Washington’s Department of Ecology determined that spent acetonesaturated cotton waste is not F003 dangerous waste. The basis for this interpretation is provided in Appendix B, a letter from Washington’s Department of Ecology to Lawrence Berkeley Laboratory, under the heading “Step 4”. Like the KimWipe and methanol cleaning agent discussed in the letter, nail technicians use a mixture of solvent and cotton material to remove polish. Often the solvent is a mixture of several ingredients. In order to meet the F003 listing description, nail polish remover before use would need to contain only F003 solvent (i.e., no cotton material). Some nail salons may use acetone to remove acrylic nails applied onto natural nails, soaking the customer’s fingers in a container of acetone until the acrylic nail softens. This King County - Nail Polish Remover Waste Characterization 3 waste acetone would meet the F003 listing description and designate as dangerous waste (DW). A nail salon could not absorb the spent acetone with cotton to avoid the F003 listing. 4 King County - Nail Polish Remover Waste Characterization WASTE DESIGNATION FOR IGNITABILITY Acetone is a listed discarded chemical product and dangerous waste source because it is ignitable. In this section, the characteristic of ignitability was evaluated based on the definitions from WAC 173-303-090(5). Separate ignitability evaluations are made based on whether the waste is liquid, not a liquid, an ignitable compressed gas, or an oxidizer. The nail salon spent saturated cotton waste is not a liquid, so WAC 173-303-090(5)(ii) was reviewed: It is not a liquid and is capable, under standard temperature and pressure, of causing fire through friction, absorption of moisture or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard; Cotton saturated with acetone does not meet that definition, so is not ignitable dangerous waste. Spent liquid acetone used to soak and soften acrylic nails was evaluated for ignitability based on WAC 173-303-090(5)(i): It is a liquid, other than an aqueous solution containing less than 24 percent alcohol by volume, and has a flash point less than 60 degrees C (140 degrees F), as determined by a Pensky-Martens Closed Cup Tester... The Closed Cup flash point test result for acetone (see JT Baker MSDS online at http://www.jtbaker.com/msds/englishhtml/A0446.htm ) is - 20 degrees C (- 4 degrees F). Therefore, spent liquid acetone and is ignitable dangerous waste (DW) with waste code D001. King County - Nail Polish Remover Waste Characterization 5 WASTE DESIGNATION FOR TOXICITY Nail salon spent saturated cotton waste was designated for toxicity using three methods: book designation with waste measurements from a simulation, book designation with waste measurements from waste generated by a nail technician, and a static acute fish toxicity test of waste generated by staff volunteers. Through book designation, the waste designated as toxic but was so close to the regulatory limit that further testing was needed to confirm the designation. Based on the results of the more definitive fish test, the waste did not designate as dangerous waste for toxicity. The same nail polish remover, provided by the nail academy volunteer, was used for all designation methods. Book Designation Potentially Toxic Ingredients The nail polish remover used in the study contained three ingredients (acetone, isopropyl alcohol and methyl ethyl ketone) that classify as Toxic Category D according to the Toxic Category Table at WAC 173-303-100(b)(i). Waste Measurements from a Simulation A simulation was done to obtain the waste measurements needed to compute the concentration of toxic category D constituents. Other constituents in the waste were dried nail polish and cotton. To simulate the process, a nail-shaped template was used to paint glass beakers with one, two or three coats of nail polish. Cotton balls saturated with nail polish remover cleaned the polish off ten “nails” on the beakers. Mass measurements of the clean beakers, beakers with nail polish, clean cotton balls and used cotton balls (wet) were recorded to calculate the concentration of toxic category D constituents. Several important factors in the simulation differ from actual conditions (e.g., painted surface porosity). Details of this simulation are provided in Appendix C. The mass percent of toxic category D constituents ranged from 24 to 65 percent. Equivalent concentration (see WAC 173-303-100(b)(ii)) ranged from 0.002 to 0.006. The simulated wastes designated as DW, WT02 because the equivalent concentration exceeded 0.001 (see WAC 173-303-100(b)(iii)). One question raised by the simulation was whether the amount of solvent actually used by technicians was equivalent to that used in the simulation. If the amount of solvent used in the field were significantly lower than the simulation, waste might not designate; if the amount were equivalent or higher, waste would more likely designate. Waste Measurements from a Nail Technician A nail academy volunteered to remove nail polish from two volunteers and demonstrate standard practices. The process was observed and mass measurements were recorded to 6 King County - Nail Polish Remover Waste Characterization calculate the mass percent of toxic category D constituents. See Appendix D for a full description of this short study with measurements. This observation showed that nail technicians fully saturate the cotton with nail polish remover. Typically, one piece of saturated cotton is used to remove polish from all ten nails. The spent cotton is heavily soiled with polish and saturated with solvent. The mass percent of toxic category D constituents in the waste was 51 to 69 percent. The equivalent concentrations were from 0.005 to 0.007. The waste designated as DW, WT02 because the equivalent concentration exceeded 0.001 (see WAC 173-303100(b)(iii)). Static Acute Fish Toxicity Test Because the book designation process indicated that concentrations of toxic constituents were near the regulatory limit, a static acute fish toxicity test (Method DOE 80-12) was conducted to obtain a more definitive designation. Several volunteers wearing nail polish removed it using the nail technician procedure. This generated heavily soiled and solvent-saturated cotton which was collected in a sample container. See Appendix E for the sample plan and a description of the waste generating process. The sample was analyzed by the King County Environmental Laboratory (see Appendix F.) According to the fish bioassay, the spent saturated cotton waste did not designate as dangerous waste (neither DW, WT02 nor EHW, WT01). The percent survival of the rainbow trout was 100 percent. Final Designation for Toxicity According to designation procedures (see WAC 173-303-100(d)); bioassay data is used to designate a waste when bioassay data do not agree with book designation. Therefore, spent saturated cotton waste is not dangerous waste and may be managed as regular garbage. King County - Nail Polish Remover Waste Characterization 7 CONCLUSIONS Summary of Research Findings Washington State’s waste designation process (see WAC 173-303-070) was followed to determine whether spent saturated cotton waste from nail salons was dangerous waste. A combination of process knowledge and testing was used to complete designation. The waste clearly did not designate for characteristics (ignitability, corrosivity, reactivity or toxicity) or for state persistence criteria. After a detailed review of regulations for listed discarded chemical products and dangerous waste sources, it was determined that the waste was not listed waste. Although book designation indicated the waste was DW, WT02, the fish bioassay determined that the waste was not toxic under Washington State criteria. According to designation procedures, bioassay data is used to designate a waste when the bioassay data do not agree with the book designation. Therefore, spent saturated cotton waste is not dangerous waste and may be managed as regular garbage. Recommendations for Nail Salons Table 1 on the next page summarizes recommendations for several types of nail salon wastes based on the study results. The LHWMP Survey Team will provide this guidance to nail salons that have a similar process for nail polish removal. Shops with significant variations in nail polish remover processes or products may need to conduct a separate designation. For more help, contact: 8 • Business Waste Line, 206-296-3976. Ask any question about nail salon waste and for a copy of the Hazardous Waste Directory “Yellow Book” with local vendors who recycle or dispose of hazardous waste and solvent. Also ask for the short fact sheet titled Nail Salons: How to Handle Nail Salon Wastes in King County. • IMEX, Industrial Materials Exchange, 206-296-4899. Exchange excess materials (such as unused acetone or polish remover) with other businesses. • LHWMP Small Business Web Site. Online versions of the Hazardous Waste Directory“Yellow Book” and the fact sheet Nail Salons: How to Handle Nail Salon Wastes in King County. http://www.govlink.org/hazwaste/business/index.cfm King County - Nail Polish Remover Waste Characterization Table 1. Nail Salon Wastes and Recommendations Waste Acetone: liquid in partially or completely full containers, unused Designation U002, discarded chemical product Recommendation D001, ignitable Locate another business that needs unused acetone, so it is product (not waste). WT02, state toxic dangerous waste Recycle or dispose using a permitted hazardous waste vendor. Acetone: sorbents, rags, washwater, contaminated soils or other residues from cleaning up a spill of unused acetone U002, discarded chemical product Recycle or dispose using a permitted hazardous waste vendor. Acetone: used to soak customer’s fingers to remove acrylic nails F003, listed solvent Recycle or dispose using a permitted hazardous waste vendor. D001, ignitable Cannot be put in the regular garbage, even if absorbed with cotton. Cannot go down the drain. WT02, state toxic dangerous waste WT02, state toxic dangerous waste Nail polish remover with a mixture of solvents (may or may not include acetone) D001, ignitable WT02, state toxic dangerous waste Locate another business that needs unused acetone so it is product (not waste). Recycle or dispose using a permitted hazardous waste vendor. Removers with low acetone concentrations, or “acetone-free” formulas, contained toxic and ignitable solvents. Nail polish remover: sorbents, rags, washwater, contaminated soils or other residues from cleaning up a spill of unused remover with a mixture of solvents (may or may not include acetone) WT02, state toxic dangerous waste Recycle or dispose using a permitted hazardous waste vendor. Nail polish remover: spent saturated cotton after removing polish from nails Not dangerous waste Dispose to the regular garbage. Use a metal container with a tight-fitting lid for garbage collection. King County - Nail Polish Remover Waste Characterization 9 This page was intentionally left blank. 10 King County - Nail Polish Remover Waste Characterization APPENDIX A US EPA INTERPRETATION OF “SOLE ACTIVE INGREDIENT” IN DISCARDED CHEMICAL PRODUCTS King County - Nail Polish Remover Waste Characterization 11 This page was intentionally left blank. 12 King County - Nail Polish Remover Waste Characterization RCRA Online Database Page 1 of 1 RCRA Online Contact Us | Print Version EPA Home > Wastes > Information Sources > RCRA Online > Document Record Detail Document Record Detail Full Document: Title: RCRA Online Number: Date: To: From: Organization of Recipient: Description: Regulatory Citation(s) : Statutory Citation(s): Topic(s): Approximate Number of Hardcopy Pages: EPA Publication Number: RPPC Number (if applicable): OSW Policy: COMMERCIAL CHEMICAL PRODUCT DEFINITION IN §261.33 13530 03/01/1992 NA NA NA Discarded unused commercial chemical product (CCP) with two active ingredients cannot be P-listed or U-listed waste because the listed chemical is not the sole active ingredient. Functionally inert components are not active ingredients. 261.33(e), 261.33(f) NA Read US Code 42, Chapter 82 Chemicals (RCRA); Hazardous Waste; P-wastes; U-wastes 1 530-R-92-014C 9444.1992(01) No EPA Home | Privacy and Security Notice | Contact Us http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/4d8560047ac... 6/21/2005 This page was intentionally left blank. Page 1 of 2 Faxback 13530 9444.1992(01) RCRA/Superfund/OUST Hotline Monthly Report Question March 1992 2. Commercial Chemical Product Definition in 261.33 A manufacturer intends to discard an unused formulation which contains two chemicals that serve as active ingredients. Only one of the chemicals is listed in 40 CFR 261.33. A comment in 261.33(d) states that "[t]he phrase 'commercial chemical product or manufacturing chemical immediate having the generic name listed in...' refers to a chemical substance which is manufactured or formulated for commercial or manufacturing use and which consists of the commercially pure grade of the chemical, any technical grades of the chemical that are produced or marketed, and all formulations in which the chemical is the sole active ingredient." (Emphasis added.) Does the term "sole active ingredient" refer only to chemicals which are listed in 261.33(e) and (f)? If a product contains two active ingredients, only one of which is listed, would the discarded product be regulated as a P- or U-listed waste? The discarded formulation would not be regulated as P- or U-listed waste when discarded. In order to be regulated as a P- or U-listed waste, a waste must meet all of the listing criteria. The listings in 261.33 do not include chemical mixtures where the listed chemical is not the sole active ingredient, and do not apply to chemicals that have been used for their intended purpose (54 FR 31335; July 28,1989). In the scenario described above, while the discarded formulation meets the criterion of being unused, it contains more than one active ingredient. It is not necessary for a chemical to be listed in 261.33(e) or (f) in order to meet the definition of an active ingredient. An active ingredient is defined as a component or mixture that performs the function of the product. "Sole active ingredient" means the active ingredient is the only chemically active component for the function of the product. If a formulation has more than one active ingredient, the formulation, when discarded, would not be within the scope of the listing in 261.33, regardless of whether only one or both active ingredients are listed. Generators, however, must be sure to correctly determine http://yosemite.epa.gov/OSW/rcra.nsf/Documents/F8CBB27E5144E241852565DA006F0... 6/21/2005 Page 2 of 2 whether a particular constituent performs the function of the product, or only serves an ancillary function, such as mobilizing or preserving the active ingredient. For example, fillers, solvent carriers, propellants, and other components with no pesticidal role are functionally inert in pesticide formulations and therefore are not active ingredients. In cases where a hazardous constituent from 261.33(e) or (f) is a functionally inert component of a commercial chemical product, e.g., a solvent carrier, its presence does not prevent the formulation containing another P- or U-listed constituent as the sole active ingredient from being a P- or U-list waste (internal Agency memorandum dated May 3, 1989). http://yosemite.epa.gov/OSW/rcra.nsf/Documents/F8CBB27E5144E241852565DA006F0... 6/21/2005 APPENDIX B LETTER FROM DEPARTMENT OF ECOLOGY TO LAWRENCE BERKELEY LABORATORY King County - Nail Polish Remover Waste Characterization 17 This page was intentionally left blank. 18 King County - Nail Polish Remover Waste Characterization APPENDIX C SIMULATED NAIL POLISH REMOVER WASTE, TOXICITY BOOK DESIGNATION King County - Nail Polish Remover Waste Characterization 25 This page was intentially left blank. 26 King County - Nail Polish Remover Waste Characterization Simulated Nail Polish Remover Waste Toxicity Book Designation Study June 7, 2001 Objectives A nail salon nail polish removal process was simulated and resulting wastes were characterized. The Washington State toxicity criteria were applied to see if waste cotton balls designated as toxic dangerous waste. Reference Washington Dangerous Waste Regulations WAC 173-303-100(5)(b), book designation procedure for toxic dangerous wastes, Ecology Publication No. 92-91, Amended June 2000 Registry of Toxic Effects of Chemicals (RTECs), October 2000 SAX Dangerous Properties of Industrial Materials, entry ABC750 Project Date, Staff and Roles 3/19/01; around 12:30 pm to 1:30 pm and 3/20/01; around 2 pm to 4:30 pm Alice Chapman: set up project, recorded data, and authored report Laurie Foster: obtained nail supplies, removed polish, and operated balance Equipment and Setup The following items were used to conduct this study: • 12 50 ml glass beakers • Parade Isopropyl Rubbing Alcohol, 16 fluid oz container • Plastic nail template made from a plastic “Day-Timer” desk-sized page locator. • Ohaus Precision Standard Digital Model T5400D (mass balance) • Nail polish label information, “Street Wear Nail Color, Revlon 12 fluid ounces, Formaldehyde and toluene free – flammable, 6134 Schmutz 23” • Johnson & Johnson First Aid Cotton Balls, Sterile • Gena Polish Remover N/A, Gena Laboratories, Inc., material safety data sheet attached. Product sample obtained from a beauty school. • Aluminum weighing pans Local Hazardous Waste Management Program in King County Page 1 of 4 Setup Each glass beaker was turned upside down and wiped clean with a paper towel dampened with rubbing alcohol. The clean, dry beakers were weighed individually. A pre-punched keyhole-shaped hole on the plastic page locator was enlarged with scissors to the approximate size of a thumbnail. This template was placed over the end of the beaker and painted with nail polish. For the first round, each beaker was painted with one “nail”, two coats of polish and allowed to dry overnight. For the second and third rounds, the beakers did not require cleaning with rubbing alcohol, because they had been cleaned with polish remover and wiped off with two dry cotton balls. For the second round, the beakers were repainted with 3 coats of nail polish, using the “nail” template. For the third round, the beakers repainted with 2 “nails” per beaker, 3 coats each, using the “nail” template. The second and third rounds were allowed to air dry and checked for dryness. These changes were made to save time. Before each mass measurement, the balance was checked to see if it read “0.000” and reset if it did not. Weighing pans were only used for the wet cotton balls, to avoid leaving solvent or polish residues on the balance. Polish Removal Process and Observations First, the beakers with dry nail polish were weighed individually. The cotton balls were also weighed individually. A separate weighing pan was put on the balance for each cotton ball and tared. A small amount of polish remover was poured into another weighing pan, in this case used only as a container – not for weighing. Polish remover was soaked up into a cotton ball and immediately used to clean as many “nails” off the glass beakers as possible. The number of beakers cleaned was recorded. However, we decided that nail salons were unlikely to transfer a partly used cotton ball from one customer to another, so only ten “nails” were cleaned per cotton ball later. Three cotton balls removed 10 “nails”, 1 removed 12 “nails”, 1 removed 4 “nails”, and 1 removed 1 “nail.” After use, the cotton ball was immediately transferred to the pre-tared weighing pan on the balance and the mass recorded. This process was repeated for 6 cotton balls. Cotton ball C was discarded because it was accidentally used in round one to clean beaker “1” before the beaker had been weighed with polish applied. Cotton ball A absorbed little polish remover and was spent after just one “nail” was removed. After use, it was still white and fluffy, with one area of red polish visible. Cotton balls B, D, E and F easily cleaned from 10 to 12 “nails” with 2 or 3 coats. These cotton balls were well-saturated with solvent and could have cleaned more nails if possible. However, it was also well-saturated with removed polish which left red residues on the safety gloves worn during the experiment. The coolness of evaporating solvent could also be felt through the gloves. Cotton ball G was used to clean only the 4 remaining “nails” on 2 beakers at the end of the experiment. Local Hazardous Waste Management Program in King County Page 2 of 4 Raw Data and Calculations The attached Excel spreadsheet lists the raw data and calculations for equivalent concentration. The material safety data sheet (MSDS) for Gena Polish Remover N/A identified the hazardous components as: • 75% acetone, Chemical Abstract Service Number (CAS#) 67-74-1; • 10% isopropyl, CAS# 67-63-0 • 5% methyl ethyl ketone, CAS# 78-93-3 The CAS# listed for acetone (67-74-1) is not a valid CAS#. The correct CAS# for acetone is 67-64-1. “Isopropyl” is an incomplete chemical name. The CAS# listed next to this phrase (67-63-0) is for isopropanol, also called isopropyl alcohol. Methyl ethyl ketone is correctly identified on the MSDS. The following data were collected from a search of the RTECS database, Sax, and a DOW Chemical MSDS for synthetic acetone and evaluated for state toxicity criteria using book designation. For acetone, conflicting toxicity data was found depending on the source. Chemical CAS# Acetone 67-64-1 Isopropyl alcohol 67-63-0 Methyl ethyl ketone 78-93-3 Acute Toxicity Data (RTECS unless otherwise noted) oral rat LD50: 5800 mg/kg (RTECS and Sax) oral rat LD50: >5800 mg/kg (Dow MSDS) skin rabbit LDLo: 20 mL/kg (RTECS) skin rabbit LD50: 20,000 mg/kg (Dow MSDS) skin rabbit LD50: 20 g/kg (Sax) oral rat LD50: 5045 mg/kg skin rabbit LD50: 12800 mg/kg oral rat LD50 2737 mg/kg skin rabbit LD50: 6480 mg/kg Local Hazardous Waste Management Program in King County State Toxic Category D D D Page 3 of 4 Conclusions and Discussion of Results All spent cotton balls designated as toxic dangerous waste, WT02, DW. The equivalent concentrations were from 2 to 6 times greater (0.002 to 0.006) than the regulatory level (0.001). It’s possible that the cotton balls in this study were more saturated with solvent and used longer than would normally be seen in a nail salon. Nail salon employees probably would not want polish residues on their bare hands and therefore might not turn over a cotton ball to use all sides. Simple observation of practices in a nail salon could confirm this. When the final mass percent of all toxic category D constituents is 10% or greater, the waste cotton balls designate as dangerous waste (assuming that no constituents of toxic category X, A, B, or C are present). In this study, the mass percent of toxic category D constituents ranged from 24 to 65 percent. Local Hazardous Waste Management Program in King County Page 4 of 4 Simulated Nail Polish Remover Waste, Toxicity Book Designation Study Raw Data and Calculations Mass Measurements (in grams) of Clean Beakers and Beakers with Dry Nail Polish Applied Beaker Number 1 2 3 4 5 6 7 8 9 10 11 12 Clean Beaker 29.760 28.626 29.195 29.086 29.129 29.045 29.381 28.742 29.360 28.706 29.403 28.867 Round 1 Round 2 Round 3 1 nail per beaker, 2 coats polish each no data 28.637 29.209 29.102 29.146 29.064 29.393 28.765 29.370 28.718 29.418 28.881 1 nail per beaker, 3 coats polish each 29.781 28.649 29.213 29.112 29.152 29.072 29.402 28.765 29.382 28.728 29.421 28.887 2 nails per beaker, 3 coats polish each 29.807 28.672 29.244 29.123 29.171 29.081 29.432 28.793 29.403 28.754 29.441 28.904 Local Hazardous Waste Management Program in King County Page 1 of 3 Simulated Nail Polish Remover Waste, Toxicity Book Designation Study Raw Data and Calculations Mass Measurements of Cotton Balls (Clean and Used) with Process Data Round Cotton Ball ID Clean Cotton Ball Mass (g) Beaker Numbers from which Polish was Removed 1 A 0.316 2 0.448 Conditions Simulated 1 nail, 2 coats each 1 B 0.327 3 through 12 1.335 10 nails, 2 coats each 1 C 0.319 1 NA 2 D 0.346 1 through 12 1.429 3 E 0.303 1 through 5 1.511 3 F 0.297 6 through 10 1.875 3 G 0.268 11 and 12 1.011 Local Hazardous Waste Management Program in King County Used Cotton Ball Mass (g) na 12 nails, 3 coats each 10 nails, 3 coats each 10 nails, 3 coats each 4 nails, 3 coats each Comments Lightly soiled, partly dry Had more realistic amount of solven beakers cleaned easily, last 2 beak needed more rubbing and were har clean, cotton ball was still wet but re well-used Discarded because it was used on beaker 1 before the beaker was we Red, well-used cotton ball, still wet, all 12 beakers easily Cotton ball very soiled, completely r None Used less solvent than others, med soiled Page 2 of 3 Simulated Nail Polish Remover Waste, Toxicity Book Designation Study Raw Data and Calculations Calculations Waste solvent remaining on cotton ball = used cotton ball - polish removed - unused cotton ball Polish removed = beakers cleaned - clean beaker mass Equivalent Concentration = sum of mass % of toxic category D constituents/10,000 Waste is not toxic if the equivalent concentration is less than 0.001. Cotton Ball Identifier A B C D E F G Polish Removed (grams) 0.011 0.152 NA 0.264 0.221 0.229 0.075 Waste Solvent Mass % Acetone Mass % (grams) (D) Isopropanol (D) 0.121 20.3 2.70 0.856 48.1 6.41 NA NA NA 0.819 43.0 5.73 0.987 49.0 6.53 1.349 54.0 7.19 0.668 49.6 6.61 Local Hazardous Waste Management Program in King County Mass % MEK (D) 1.35 3.21 NA 2.87 3.27 3.60 3.30 Equivalent Concentration 0.002431 0.005771 NA 0.005158 0.005879 0.006475 0.005947 Desi WT WT WT WT WT WT Page 3 of 3 This page was intentionally left blank. APPENDIX D NAIL ACADEMY WASTE, TOXICITY BOOK DESIGNATION King County - Nail Polish Remover Waste Characterization 37 This page was intentially left blank. 38 King County - Nail Polish Remover Waste Characterization Nail Academy Waste Designation Study Toxicity Book Designation August 13, 2001 Objectives Nail polish was removed from two subjects at Cascade Nail Academy and resulting wastes were characterized. The Washington State toxicity criteria were applied to see if waste cotton designated as toxic dangerous waste. Pollution prevention ideas for removal of artificial nails were also recorded. Reference Washington Dangerous Waste Regulations WAC 173-303-100(5)(b), book designation procedure for toxic dangerous wastes, Ecology Publication No. 92-91, Amended June 2000 Registry of Toxic Effects of Chemicals (RTECs), October 2000 SAX Dangerous Properties of Industrial Materials, entry ABC750 NIOSH Pocket Guide to Chemical Hazards, U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, June 1997. Project Date, Staff and Roles 5/15/01; around 1:30 pm to 4:00 pm Location: Cascade Nail Academy, 17060 116th Ave SE Renton, WA 98058, phone 425-226-2457 Alice Chapman: study subject, recorded data, operated balance and authored report Laurie Foster: collaborated with the academy to conduct study, study subject, recorded data and operated balance, reviewed report Linda Newman: Cascade Nail Academy owner, collaborated with LHWMP to conduct study, provided supplies and background information, applied and removed nail polish Equipment and Setup The following items were used to conduct this study: • Basecoat: Color Madness, Luscious Nail Lacquer, clear, contains butyl acetate, ethyl acetate, nitrocellulose, dibutyl phthalate, polyester Local Hazardous Waste Management Program in King County Page 1 of 5 • • • • • • Color coat: Cotton Candy (pale iridescent pink) Topcoat: clear Ohaus Precision Standard Digital Model T5400D (mass balance) Intrinsics 100% cotton coil, extra thick, economy pack, Barnhardt Mfg, 800-2770377, www.intrinsics.net Ziploc sandwich bag, with locking strip torn off (plastic used as a “weighing pan”) Polish Remover (Green) manufactured by Styling Technology, material safety data sheet attached, dispensed using a flip-top plastic bottle. Setup Ms. Newman applied nail polish to Ms. Foster first, then Ms. Chapman. Ms. Foster had a small amount of old polish already on her nails and this was simply painted over. Several coats were applied: one basecoat, two color coats, and one topcoat. Basecoat functions as a “primer” to improve adherence of the subsequent layers. Topcoat protects the color coats and provides the final finish. Nail polish dried quickly between coats and after the final topcoat was applied so the flow of work was virtually uninterrupted. The mass balance was set up on an adjacent ventilated table and sandwich bags prepared for use as makeshift weighing pans to protect the balance. The bags also contained a paper label inside to identify the cotton ball resting on top. Before each mass measurement, the balance was checked to see if it read “0.000” and reset if it did not. Polish Removal Process and Observations A section of cotton coil was pulled from a tabletop dispenser and weighed. Nail polish remover was applied to the cotton. The solvent-saturated cotton was used to clean all ten nails on the subject and weighed. A total of two sections of cotton were used (A and B), one for each subject. The used cotton was allowed to dry. To speed drying, the cotton was placed first under a lamp, then directly on the ventilated area of the table with the fan turned on under a lamp. Cotton waste was confirmed dry when mass measurements over a period of 10 to 15 minutes were identical. Cotton A was less saturated with solvent than Cotton B. Cotton A is typical of what is used to remove light colored polish, while the amount of solvent on Cotton B represents what is used to removed darker-colored polish. Cotton B required a much longer drying time. As nails were cleaned of polish, the cotton was turned and compressed through use until it formed a compressed wad. Nail technicians directly contact the solvent and removed polish on the cotton. If color gets on the technician’s fingers, the same piece of cotton is rotated and used to clean them. The table ventilation is not used to control solvent fumes from polish application or removal. The ventilated table has an open grate in the top. A fan in the table draws air down through the grate and through a small cloth bag attached Local Hazardous Waste Management Program in King County Page 2 of 5 to the end of the duct. The bag collects sanding dust when acrylic nails are applied. The bag is periodically emptied and replaced. Pollution Prevention Ideas for Artificial Nail Removal Artificial nail application and removal was outside the scope of this study. However, the academy owner reported an effective pollution prevention technique for this process and during a visit to another nail salon in August, Ms. Foster learned of a second technique. At most nail salons, the customer’s fingers are immersed in an open container of pure acetone for several minutes to loosen the acrylic nails. The acetone is disposed of after each use because it is not reused on other customers for hygiene reasons. However, the LHWMP survey team has seen some nail salons that reuse the same container of acetone for all customers and never dispose of acetone. The customer and nail technician are exposed to acetone through vaporization and skin absorption. A successful pollution prevention alternative reported by Ms. Newman was to apply a few drops of acetone to a small section of cotton coil (or a cotton ball), pressed onto each nail and each nail is individually wrapped in foil. After a few minutes, the nail adhesive was loosened sufficiently that the foil, cotton and acrylic nails could be removed. Virtually no acetone remained. Solvent evaporation was significantly reduced and the customer’s direct contact exposure was reduced. No hazardous waste was generated and the cost of purchasing acetone was reduced because less was used. A nail salon visited by Ms. Foster in August reported a similar technique. Again, a few drops of acetone were applied to cotton and pressed onto each nail. Instead of wrapping each finger in foil, the entire hand was placed inside mitts normally purchased for pedicures. This salon noted that the nails they apply are very thin and one application of acetone works to remove nails. However, many customers have come in with acrylic nails applied too thick at other salons and the nail technician needs to use this technique two or three times to remove the nails. Raw Data and Calculations The attached Excel spreadsheet lists the raw data and calculations for equivalent concentration. The business owner contacted her local supplier for a copy of the polish remover MSDS. The copy she received was out of date. The listed manufacturer, Gena Laboratories, Inc. is now called Styling Technology (phone number 480-609-6000). Also, the same MSDS lists “Polish Remover (Green)” as product name and “Gena Polish Remover N/A” as trade name. When updated MSDSs were received from Styling Technology, it was clear that these were two separate products with different formulations, one with acetone and one without. The container in the shop listed “2-propanone”, a synonym for acetone, on Local Hazardous Waste Management Program in King County Page 3 of 5 the label and the product was green, so “Polish Remover (Green)” correctly identifies her product. Copies of these MSDSs are attached. The material safety data sheet (MSDS) for Polish Remover (Green) identified the hazardous components as: • 75% acetone, Chemical Abstract Service Number (CAS#) 67-74-1; • 10% isopropyl, CAS# 67-63-0 • 5% methyl ethyl ketone, CAS# 78-93-3 The CAS# listed for acetone (67-74-1) is not a valid CAS#. The correct CAS# for acetone is 67-64-1. “Isopropyl” is an incomplete chemical name. The CAS# listed next to this phrase (67-63-0) is for isopropanol, also called isopropyl alcohol. Methyl ethyl ketone is correctly identified on the MSDS. Another problem area on the MSDS was under the heading “Toxicity Data.” Toxicity data usually refers to chronic or acute exposure data known to cause injury or death to test subjects (for example, oral rat lethal dose, inhalation rat lethal dose, skin rabbit lethal dose, etc.) The concentrations listed under this heading on the MSDS are not toxicity data, but are exposure limits. Exposure limits are concentrations intended to be protective of human health and prevent injury or death. Concentration alone is not sufficient to describe an exposure limit; the organization that established the limit and relevant time factor (for example, whether the limit is for short-term exposure, timeweighted average (TWA), etc.) are also necessary. Organizations in the United States that may establish exposure limits are the National Institute for Occupational Safety and Health (NIOSH), Occupational Safety and Health Administration (OSHA) or American Conference of Governmental Industrial Hygienists (ACGIH). Multiple organizations based in countries around the world also establish exposure limits. For example, acetone has a NIOSH TWA of 250 ppm, OSHA TWA of 1,000 ppm, ACGIH threshold limit value TWA of 500 ppm and ACGIH threshold limit value shortterm exposure limit (STEL) of 750 ppm. Washington State requires employers to meet NIOSH exposure limits. This MSDS lists ACGIH TLV-TWA data for isopropyl alcohol and methyl ethyl ketone, and ACGIH TLV-STEL for acetone. An employer using information from this product MSDS would not know the Washington State standards. This MSDS data review highlights the difficulties small businesses experience in getting reliable information about potentially hazardous products that they use. Local Hazardous Waste Management Program in King County Page 4 of 5 The following data were collected from a search of the RTECS database, Sax, and a DOW Chemical MSDS for synthetic acetone. The data were evaluated for state toxicity criteria using book designation. For acetone, conflicting toxicity data were found depending on the source. Chemical CAS# Acetone 67-64-1 Isopropyl alcohol 67-63-0 Methyl ethyl ketone 78-93-3 Acute Toxicity Data (RTECS unless otherwise noted) oral rat LD50: 5800 mg/kg (RTECS and Sax) oral rat LD50: >5800 mg/kg (Dow MSDS) skin rabbit LDLo: 20 mL/kg (RTECS) skin rabbit LD50: 20,000 mg/kg (Dow MSDS) skin rabbit LD50: 20 g/kg (Sax) oral rat LD50: 5045 mg/kg skin rabbit LD50: 12800 mg/kg oral rat LD50 2737 mg/kg skin rabbit LD50: 6480 mg/kg State Toxic Category D D D Conclusions and Discussion of Results Cotton waste A and B designated as toxic dangerous waste, WT02, DW. The equivalent concentrations (0.005 and 0.007) were 5 and 7 times greater than the regulatory level of 0.001. When the final mass percent of all toxic category D constituents is 10 percent or greater, the waste cotton designates as dangerous waste (because no constituents of toxic category X, A, B, or C are present). In this study, the mass percent of toxic category D constituents was 51 to 69 percent. Nail technicians don’t keep polish remover or polish off their own hands. The cotton is fully saturated with polish remover and used to clean all of the customer’s fingers at once. Local Hazardous Waste Management Program in King County Page 5 of 5 This page was intentionally left blank. Nail Academy Waste Designation Study Raw Data and Calculations Mass Measurements (in grams) Cotton ID Clean Cotton Mass (g) Used (Wet) Used (Dry) Cotton Mass (g) Cotton Mass (g) Comments A 0.278 1.063 0.455 Less solvent, dried in about 50 minutes; dropped on the and forgot to use plastic on the balance for the used (w measurement B 0.364 1.938 0.443 More solvent, dried in about 95 minutes Cotton ID A B Polish Removed (grams) 0.177 0.079 Waste Solvent Mass % Acetone Mass % (grams) (D) Isopropanol (D) 0.608 42.9 5.72 1.495 57.9 7.71 Local Hazardous Waste Management Program in King County Mass % MEK (D) 2.86 3.86 Equivalent Concentration 0.005148 0.006943 Desi WT WT Page 1 of 1 This page was intentionally left blank. APPENDIX E SAMPLE PLAN: FISH BIOASSAY King County - Nail Polish Remover Waste Characterization 49 This page was intentially left blank. 50 King County - Nail Polish Remover Waste Characterization Sample Plan: Nail Polish Remover Waste Fish Bioassay Project Description Small amounts of waste are generated in nail salons when old nail polish is removed. The waste consists of cotton saturated with solvent-based polish remover and old nail polish. In a prior book designation study, the solvent concentrations were just high enough to designate as Washington State toxic waste. This study will designate the waste with a fish bioassay. Sampling Objectives • Designate acetone-based nail polish remover waste with results from a static acute fish toxicity test. • Project participants will receive a lab tour and informal training about fish bioassay testing from the Environmental Lab Aquatic Toxicity section. Project Organization and Responsibilities Alice Chapman and Laurie Foster coordinate the sampling project and generate waste. Staff volunteers from the Local Hazardous Waste Management Program in King County will generate polish remover waste. Fran Sweeney manages testing for the Aquatic Toxicity section at King County’s Environmental Lab. Staff Volunteers: Chris Guardiano, Lisa Niehaus, Debra Oliver, Will Perry, Liz Tennant Waste Generating Process The nail technician gathers a small amount of cotton from a supply of cotton coil, applies polish remover to the cotton and wipes the polish from all ten fingers of the client. The technician turns and compresses the cotton as it was used until it formed a compressed wad. Nail technician’s fingers directly contact the cotton, solvent and removed polish; no gloves are used. If polish color gets on the technician’s fingers, the same piece of cotton is rotated and used to clean them. The amount of solvent applied to the cotton may be greater when dark polish is removed than if light polish colors are removed. Constituents of Concern/Preliminary Designation The constituents of concern are acetone, isopropyl alcohol, and methyl ethyl ketone. Because polish remover solvent is applied to cotton before use, the waste is not listed F003 solvent waste. Prior LHWMP studies on this waste were done by weighing the amount of polish remover used and book designating for Washington State toxicity (see WAC 173-303-100(5)). The June 2001 LHWMP study determined that polish remover constituents are toxic category D. The August 2001 LHWMP study found that waste generated at a nail salon had an equivalent concentration of 0.005 to 0.007 and book designated as DW, WT02. If the equivalent concentration were less than 0.001 the waste would not designate as hazardous. Local Hazardous Waste Management Plan in King County Alice Chapman, 206-263-3058 page 1 of 3 7/29/02, revised 8/7/03 Analytical Method The method is: Department of Ecology Biological Testing Methods, Publication #80-12, Static acute fish toxicity test. Rainbow trout (Oncorhynchus mykiss) are the test organism. First the sample is extracted. Then the trout will be exposed to two concentrations (10 mg/L and 100 mg/L). The test provides an estimated 96-h LC50 value (the estimated concentration at which half of the exposed rainbow trout are expected to die). If the result is less than or equal to 10 mg/L, the waste is EHW, WT01. If the result is less than or equal to 100 mg/L, the waste is DW, WT02. If the result is greater than 100 mg/L, the sample is not classified as regulated waste. Quality Assurance Objectives Testing will be conducted in accordance with the method, including quality assurance requirements for test validity. Sampling Log and Chain of Custody A Sample Background Information form will be completed to document actual sampling activities. The Environmental Lab’s Laboratory Work Order form will also be completed, including the chain of custody documentation. Sampling Equipment • Johnson & Johnson cotton balls • acetone-based nail polish remover (Polish Remover (Green) manufactured by Styling Technology) and material safety data sheet • solid volatiles sampling jar • balance to confirm sample quantity is sufficient (about 20 grams) • Nail polish (3 types) • basecoat (not found) • color coat • topcoat Sampling Procedure • To save time it is preferred that staff sampling volunteers apply nail polish prior to the sampling date. If necessary, nail polish may be applied and removed on the sampling date. • Standard practice for a professional manicure is to apply one basecoat, two color coats, and one topcoat. Basecoat functions as a “primer” to improve adherence of the subsequent layers. Topcoat protects the color coats and provides the final finish. • Weigh the pre-labeled empty sample jar and record tare weight. • Pull a small portion of cotton from the cotton coil. It should weigh approximately 0.3 grams when unused (in a prior study the range was 0.28 to 0.36 grams). Local Hazardous Waste Management Plan in King County Alice Chapman, 206-263-3058 page 2 of 3 7/29/02, revised 8/7/03 • • • • • • Apply a small amount of polish remover to the cotton coil, sufficient to wet it thoroughly. Using the same piece of wetted cotton, remove all layers of nail polish from all ten fingers of one person. Place all the used cotton waste from all participants into one VOA sample jar and close the lid immediately. Avoid reopening the jar to add more sample, as this will allow acetone vapors to escape. Only one sample is to be analyzed with the bioassay. Weigh the filled sample jar to ensure sufficient waste has been generated to meet test requirements (6 grams minimum). Package the sample jar in a cooler with ice and deliver to the Environmental Lab sample receiving area. Complete the chain of custody form. The aquatic toxicity section will provide a short tour of their operations. Sampling Notes Sampling occurred on the morning of July 31, 2002. Samplers applied polish on the following dates: one on 7/24/02, three on 7/29/02 and three on 7/30/02. Polish colors used were clear, fire engine red, white pearl, moonlight and roses, iridescent lavender, fuschia, and wet and wild iridescent purple. A total of five decals had been applied. Five samplers used a clear topcoat product as a substitute for basecoat (these tended to peel easily) and two samplers used no basecoat. Five samplers applied two coats of color, one applied three coats of color and one applied no color. All seven samplers applied one coat of clear topcoat, with an additional topcoat added onto decals. A 40 ml volatile organic analysis sample container was filled with polish remover and used to apply solvent to cotton balls. Four samplers were not able to remove all the polish with a single well-saturated cotton ball. After polish removal, color residues were still visible on the samplers’ fingers so additional cleaning with a fresh cotton ball was necessary. All saturated cotton waste and removed decals were collected in one sample jar (tare weight 157.8 grams). The final sample weight exceeded 20 grams. The sample was placed in a cooler with ice and transported to the lab immediately after sample collection. References Chapman, Alice I. Nail Academy Waste Designation Study Local Hazardous Waste Management Program in King County, August 13, 2001. Chapman, Alice I. Nail Polish Remover Waste Designation Study Local Hazardous Waste Management Program in King County, June 7, 2001. Washington Department of Ecology Chemical Testing Methods for Designating Dangerous Waste, Publication # 97-407 February 1998. Washington Department of Ecology Dangerous Waste Regulations Chapter 173-303 WAC, Publication No. 92-91 amended June 2000. Local Hazardous Waste Management Plan in King County Alice Chapman, 206-263-3058 page 3 of 3 7/29/02, revised 8/7/03 This page was intentionally left blank. APPENDIX F STATIC ACUTE FISH TOXICITY TEST RESULTS King County - Nail Polish Remover Waste Characterization 55 This page was intentially left blank. 56 King County - Nail Polish Remover Waste Characterization BIBLIOGRAPHY Lewis, Richard J. Sax’s Dangerous Properties of Industrial Materials, Ninth Edition. New York, NY: Van Nostrand Reinhold, 1996. National Institute for Occupational Safety and Health (NIOSH). Registry of Toxic Effects of Chemicals (RTECs), Washington, DC: U.S. Government Printing Office, 2000. Washington Department of Ecology. Washington Dangerous Waste Regulations Chapter 173303 Washington Administrative Code, Publication No. 92-91, Amended June 2000. Olympia, WA: Department of Ecology, 2000. Washington Department of Ecology. Publication 80-12, Part A: Static Acute Fish Toxicity Test Protocol, Revised August 1999. Olympia, WA: Department of Ecology, 1999. King County - Nail Polish Remover Waste Characterization 75