Contact ECS Refining     Protecting you, your company...and your future.            [   Residues We Process  | Products We Sell  | Metals We Recycle  | About Us  | More Information          ]       Photo-Waste        Pureflow® Recovery Service        Silver Recovery Equipment        Pureflow® Technology     Precious Metal Residues     Electronic Scrap        Description        Slide Show     Tin & Lead Residues        Description        FAQs        Slide Show        Kester Solder Recycling Program     Get a Quote     High Temperature Alloys Page Last Updated:  5/11/2005   Residues We Process->Tin & Lead Residues->FAQs     Tin & Lead Residues TIN & LEAD SOLDER PASTE AND WIPES Frequently Asked Questions (FAQs) Doesn’t the fact that metal value is recovered from the solder paste and wipes mean that it is not a hazardous waste? Does mixing the paste and wipes with my solder dross make the entire waste a by-product? What if my solder paste and wipes waste stream passes the U.S.E.P.A. Toxicity Characteristic Leaching Procedure (TCLP)? What if the state I am sending my paste and wipes considers those materials to be non-hazardous? Q. Doesn’t the fact that metal value is recovered from the solder paste and wipes mean that it is not a hazardous waste?      [back ^] A. There are no exclusions or exemptions from the hazardous waste regulations based on the fact that metal value is recovered.  The recovery of metal from the waste means that the recycling is legitimate. Q. Does mixing the paste and wipes with my solder dross make the entire waste a by-product?      [back ^] A. No.  Mixing a hazardous waste (e.g., paste and wipes) with a non-hazardous by-product (e.g., solder dross) does not make the mixture non-hazardous. Mixing the two results in a container that is now considered to be a hazardous waste. Q. What if my solder paste and wipes waste stream passes the U.S.E.P.A. Toxicity Characteristic Leaching Procedure (TCLP)?      [back ^] A. If a representative sample is taken of the solder paste and wipes and it passes the TCLP extraction and analysis procedure (e.g., Lead < 5.00 mg/L TCLP), then the waste stream is not considered a hazardous waste.  It would be considered a non-hazardous material and can be discarded with other non-hazardous materials. It is important to remember that the State of Texas has several different categories of non-hazardous (Class 1, 2 and 3). Each has their own requirements and limitations.  Representative samples are very difficult to acquire on materials of this nature because of the inconsistencies in homogeneity. The burden of proof remains on the generator. It is "ECS" experience that solder paste and wipes do not pass TCLP extraction and analysis for lead. Q. What if the state I am sending my paste and wipes considers those materials to be non-hazardous?      [back ^] A. Generators are required to comply with the laws in the state in which they are located.  The Texas Commission on Environmental Quality (TCEQ) has interpreted the solder paste and wipes waste stream to be a "spent material" and a hazardous waste if it fails the TCLP procedure. Please make note that some interpretations from other state agencies are not consistent with U.S.E.P.A. guidelines. Improper classification of a companies waste stream, specifically solder paste and wipes, may put a company at risk for violations and financial penalties. Home   |   Residues We Process   |   Products We Sell   |   Metals We Recycle   |   About Us   |   Site Map   |   Audit Packages   |   Sign In BEFORE you use this site, please read our terms of use, privacy policy, copyright, and trademark notice. Your use of this site means that you have read and accept these terms. ©2005-2008   ECS Refining Texas, LLC   All rights reserved.     Contact ECS Refining     © 1998-2008  Hosted by Web Alchemy Incorporated