PreTox Systems, when used correctly, comply with all current applicable federal, state, and local regulations.
To ensure that there were no regulatory barriers to the use of PreTox System, NexTec, Inc. sought the approval of the EPA. While the EPA will not endorse specific products, it will render an interpretation of applicable regulations.
Comments and Copy of Letter from EPA:
In the early stages of PreTox development, NexTec, Inc. was known as Progressive Technologies, Inc. To ensure that there were no regulatory barriers to the use of the PreTox System, NexTec, Inc. sought the approval of the EPA. While the EPA will not endorse specific products, it will render an interpretation of applicable regulations. As you can see in the letter from the EPA, if a waste passes the TCLP test, it is non-hazardous for disposal, regardless of removal process. The PreTox System is part of the removal process. The EPA goes on to say, "that wastes must continue to pass the TCLP test". The PreTox System is the superior choice for lead paint removal because it prevents lead leachibility indefinitely.
The EPA, in the letter goes on to say, "CERCLA liability is independent of any hazardous waste determination that may be made". This means that CERCLA (Superfund) liability is inescapable, no matter where your waste is landfilled.
Finally the EPA states, "for the purposes of hazardous waste generation, the term "generator" may refer to both the paint abatement contractor and to the owner of a building or a superstructure and they are considered "co-generators" of the waste. A generator of a waste has joint and several unlimited liabilities under CERCLA (Superfund). Does that get your attention?
Certainly, it makes more sense to generate a non-hazardous waste in all situations. It's the right thing to do for the environment and for your company.
PreTox 2000 Fast Dry
PreTox 2000FD contains flammable solvents. Ensure that adequate ventilation and personal protective equipment compatible with solvent coatings are used during application and curing.
PreTox 7000 Paint Stripper
Safety goggles and butyl rubber or neoprene gloves are recommended. Maintain adequate ventilation in confined areas. If misting is expected use NIOSH approved organic vapor chemical cartridge respirator.
PreTox 2000 Demolition
PreTox 2000 Demo contains combustible solvents. Ensure that adequate ventilation and personal protective equipment compatible with solvent coatings is used during application and curing.
PreTox 8000 Paint Stripper Blast Enhancer
Safety goggles and butyl rubber or neoprene gloves are recommended. Maintain adequate ventilation in confined areas. If misting is expected use NIOSH approved organic vapor chemical cartridge respirator.
The above procedures are presented as guidelines for the obtaining of waste samples, Other methods that insure a uniform sample is taken, can be used at the discretion of the the contractor for testing. The EPA requires well documented techniques for waste sampling and collection. Additional information can be obtained through the EPA manual SW-846 or ASTM standard D75. For further assistance, please call a NexTec, Inc. representative 1-800-338-8296.
By obtaining a control sample and testing PreTox application rates prior to starting a project, the application of PreTox can be optimized. The following represents an example of the optimization procedure:
Three identical samples are needed, two to send to the lab and the other for you to retain. Sample bottle must be full. Please fill out the label for each bottle and the chain of custody form completely.