NYMPP: Section 2 - Painting & Fiberglass Repair
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New York Sea Grant's
Marina Pollution Prevention Web Site

Section 2:
Painting & Fiberglass Repair
- Varnishing

Potential Environmental Impacts:

Spills of oil-based varnishes may be detrimental to the marine and aquatic environment. Since they are petroleum-based, spills may have similar impact as oil spills. Chemicals in varnishes can be highly flammable and potentially harmful to human health.

Best Management Practices:

Avoid the disposal problem of leftover varnish by mixing only as much as is needed for a given job. Consider sharing leftover varnishes with customers or setting up an exchange area for customers to swap unused items.

Use less hazardous, water-based varnishes which pose less of a threat to human health or the environment.

In case of spills of varnish on land, use absorbent material to clean it up, and collect any contaminated soils. Spills in waterways should be contained and mopped up with booms or pads that repel water but absorb petroleum.

Regulatory Issues:

Many varnishes are composed of hazardous materials. You must determine if your waste varnish is hazardous by either having the waste tested or utilize reliable "knowledge of process" information for the waste (if available) [40 CFR 262.11, click here] Such information could include testing by haulers, or studies by industry trade groups. For more information on New York hazardous waste testing requirements, click here. Varnish which is hazardous waste must either be recycled or disposed of via a permitted hazardous waste hauler. While stored on-site, it must be managed in accordance with hazardous waste storage requirements [40 CFR 262.11, click here]. For more information on New York's Hazardous Waste Regulations and storage requirements, click here.

If there is a stormwater discharge from your facility and you varnish outdoors, you may have to register for a General Permit for the Discharge of Storm Water Associated with Industrial Activity ("Storm Water General Permit"). For more information on stormwater permitting in New York, click here.