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| Kester Solder Recycling Program |
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Kester Solder / ECS Refining
Frequently Asked Questions (FAQs) |
| Kester Introduces Lead-Free Connection™ |
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| Q. |
What about Pails for my Dross? |
[back ^] |
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| A. |
Silver is recovered from photo labs, graphic art houses, printers, dentists, radiology labs and circuit shops in the form of liquid wastes, recovery column, flake and other silver bearing wastes. Our equipment and processes are designed to ensure efficient, environmentally sound recycling of silver bearing materials.
Pails can be obtained by contacting Customer Service at or by calling 800.637.6161. |
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| Q. |
What about recycling lead free dross? |
[back ^] |
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| A. |
ECS accepts nearly all Tin and Tin & Lead residues. "The major issue will be maintaining strict separation of the tin & lead and lead-free solder dross to avoid contaminating the lead-free solder dross." To learn more about " lead-free recycling," visit ecsrefining.com/leadfreepaper. |
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| Q. |
How do I know my materials are being handled properly? |
[back ^] |
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| A. |
ECS Refining maintains a proactive approach to environmental management of its facilities. We are committed to maintaining the cleanest and most environmentally sound facilities our industry, as well as a policy that dictates 100% recycling wherever possible, thereby ensuring that our clients will not incur any long term liability for hazardous waste disposal.
All operations are fully permitted with respect to federal, state, and local regulations, which provide clients assurance of regulatory oversight. An open invitation is always available to audit our facilities and view our processes. |
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| Q. |
Solder Paste (Full Jars) |
[back ^] |
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| A. |
Solder paste consists of fine particles of a metal alloy (generally tin and lead) that have been bound into a cream or paste using a non-hazardous organic binding agent. These binding agents may include terpineol, rosin, or a high-boiling alcohol. Some solder paste can contain up to 2% silver.
Solder paste is used to surface mount electronic components on printed circuit boards. The solder paste has a shelf-life (due to the organic content and companies discard partially used jars or even whole jars that have passed their expiration date.
The metal value from solder paste may be recovered pyrometallurgically. Therefore, solder paste is a recyclable material. According to the interpretation of the U.S.E.P.A. regulations, off-specification commercial chemical products that exhibit a characteristic of a hazardous waste (e.g., lead) are exempt from the classification of a solid waste if they are reclaimed.1 Consequently, off-specification commercial chemical products do not have to be manifested and may travel by common carrier on a bill of lading.
1. A notice in the Federal Register (50 FR 14219) extends the exemption in 40 CFR 261.2)(3) to characteristic chemical products (in addition to listed chemical products) that are reclaimed. |
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| Q. |
Empty Solder Paste Jars and Wipes |
[back ^] |
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| A. |
A related waste stream produced by companies engaged in the printed circuit board manufacturing using surface mount technology is empty solder paste jars and textile wipes that are contaminated with solder paste. These items do not fall under any regulatory exemption if they are recycled and must be analyzed to determine if they are hazardous waste.
The empty solder paste jars and wipes are presumed to fail the U.S.E.P.A. Toxicity Characteristic Leaching Procedure (TCLP) for lead and, therefore, are classified as a characteristically hazardous spent materials or hazardous waste (D008). Generators may choose to have their waste stream analyzed to confirm this. If proper sampling and analysis of the material indicates that the waste leaches less than 5.0 mg/L TCLP of lead, then the material is not considered a RCRA hazardous waste (but may be a class 1 non-hazardous industrial waste in the State of Texas). Without analytical proof, however, these wastes are considered characteristically hazardous.
In Texas, facilities that recycle hazardous waste may do so without a RCRA Part B permit if the proper notification procedures have been followed.2 ECS Refining Texas has made the proper notification and recycles these wastes without prior storage. The metals are recovered for reuse in the solder industry.
The precious metal exemption does not fit any of the materials discussed above. First, the precious metals industry has established a standard that only those precious metals with a positive metal value should be considered for the exemption. Secondly, 40 CFR 266.70 states that the precious metal value should be "economically significant" in order to apply the precious metal exemption. The above criterion has been used by regulators to differentiate between legitimate and illegitimate ("sham") recycling operations. There are recycling opportunities for these materials; however, the material should be managed as regulated.
2. These notification procedures are presented in Title 30 Texas Administrative Code, Section 335.6. |
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| Q. |
What does the solder paste and wipes waste stream consist of? |
[back ^] |
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| A. |
Tin/lead solder paste is a finely divided mixture of tin/lead alloy with an organic binder (usually a glycol or rosin) used in the manufacturing of printed circuit boards by surface mount technology (SMT). This technology uses a template or screen to serve as the pattern to guide where the solder paste will be applied to the printed circuit board. The excess solder paste is wiped off the board using textile or cotton wipes saturated with isopropyl alcohol or some other suitable solvent. Partially full to empty solder paste jars and syringes are discarded once they have exceeded their shelf life or have been exposed to the air for a certain amount of time.
Consequently, the solder paste and wipes waste stream consists of empty to partially full paste jars, textile or paper wipes contaminated with solder and associated debris (such as protective gloves).
Although the waste stream may have small amounts of alcohol associated with it, it will not be considered a "flammable" waste if the wipes are generally dry by the time the drum is sealed for removal to the recycling facility. |
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| Q. |
How is this material classified according to State of Texas and the U.S.E.P.A. regulations? |
[back ^] |
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| A. |
Solder paste and wipes are considered a "spent material". The State of Texas and U.S.E.P.A defines a spent material as "any material that has been used and as a result of contamination can no longer serve the purpose for which it was produced without processing." [40 CFR 261.1(c)(1)]
Spent materials that are recycled or reclaimed are still considered hazardous waste [40 CFR 261.2(c)(3)]. Although there are exclusions from classification as a solid waste (and, hence, a hazardous waste) for recycled materials that are by-products or off-specification commercial chemical products, there is no such exclusion for spent materials. |
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| Q. |
Why can’t solder paste and wipes meet the exclusion as "an ingredient in an industrial process to make a product"? [40 CFR 261.2(e)(1)(i)] |
[back ^] |
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| A. |
This regulation states "materials are not solid waste when they can be shown to be recycled by being used or reused as an ingredient in an industrial process to make a product, provided the materials are not being reclaimed.
"A material is reclaimed if it is processed to recover a usable product, or if it is regenerated." [40 CFR 261.2(c)(4)]
In order for solder paste and wipes to qualify for this exclusion, the solder paste and wipes would have to substitute for a raw material in a production process that did not first have to be reclaimed for reuse. Recovering the metal from the solder paste and wipes is defined as reclamation and does not meet this exclusion. |
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