Page 54
The most advanced and versatile rework system available.
The MBT 350 has three handpiece channels that are active simultaneously. The system is fully programmable and can be password protected.
The Hi-Flo dual-purpose vacuum/pressure pump and delivery system features PACE’s patented SNAP-VAC Technology, providing the most vacuum available for desoldering applications.
MBT 350
1-877-882-7223
paceworldwide.com
Compliance testing in the lab. Solutions and systems for soldering, rework and repair of electronics
recognize the new definitions of solid waste that create exemptions for materials generated by the electron- ics assembly industry. Many waste streams are gener-
ated by electronics assemblers, many of which are process-dependent. Each stream must be classified under the RCRA regulations and handled accordingly. In almost all cases, these materials are not haz- ardous wastes when they are recy- cled. Lead-bearing and lead-free sol- der dross from wave soldering is not considered a hazardous waste (or waste if reclaimed, despite exhibiting a hazardous characteristic, because they are considered byproducts under 40 CFR 261.2(c)(3). Byprod - ucts that exhibit a hazardous charac- teristic are not considered solid (or hazardous) wastes if they are reclaimed. To an electronics assem- bler, this means that solder dross can be shipped to a recycling facility without using a hazardous waste manifest or hazardous waste trans- porter.
Containers of lead-bearing and
lead-free solder paste products, whether off-specification or partially empty, are also exempt from being considered hazardous when re - claimed because they may be consid- ered a commercial chemical product, provided that the constituent target materials meet the appropriate qual- ifications. Empty containers are exempt from being considered as hazardous waste, and do not require recycling or hazardous waste treat- ment if they have less than 2.5mm (0.98-in.) layer of residue on the bot- tom of the container or 3 percent by weight remains in the container, per 40 CFR, 261.7(b). Solder-contaminated wastes
such as presaturated and/or dry wipes, contaminated swabs, gloves, rags, and other materials of the sort are considered spent materials under 40 CFR 261.1(c)(1). Spent materials that exhibit a hazardous characteris- tic are hazardous wastes, even if they
2008 DSW rules, unless the waste was generated in a state that has adopted these rules. Since almost every state man-
ages its own RCRA program, and the regulations in many states differ in important ways from the federal RCRA regulations, it is easy to make a mistake when transporting wastes from one state to another. The EPA has taken the position that generators and transporters must obey the regu- lations of each state through which the waste passes during shipment. Thus, even if the state in which waste, such as Paste & Wipes, is recycled does not regulate the material as haz- ardous waste, if the state in which the material was generated regulates it as hazardous, or any state through which the transporter carries it regu- lates it as hazardous, it must be shipped using a Licensed Hazardous Waste Trans porter and a Hazardous Waste Manifest. In the specific case of Contaminated Trash, the only situa- tions where these materials could potentially be legally shipped without a manifest would be intrastate ship- ments within the states of Pennsyl - vania, New Jersey, or Illin ois, ship- ments between New Jersey and Pennsylvania (which are contiguous), and shipments by Small Quantity Generators in or through states which exempt the materials. Even then, with no Federal rulings, recyclers that operate out of these states are using their own interpretations of the law to conclude that their handling of these wastes is legal. Many generators of electronic
waste materials do not understand the requirements for interstate ship- ment of these materials, and may be in jeopardy of violations and fines if their records are inspected by a state or federal RCRA inspector familiar with these materials. An attorney or state RCRA office should be contact- ed for accurate information if there is any doubt. “Sham recycling” is regulatory
Continued on next page
www.us-tech.com
July, 2014
Understanding Management of Solder Waste...
Continued from previous page
materials. The revision, called the “2008 Definition of Solid Waste,” was further revised in 2011. The contro- versial rule created many exemp- tions to which environmentalists, including the Sierra Club, took exception and sued the EPA in response. But only a few states (Pennsylvania, New Jersey, and Illinois) have adopted these rules, and these are the only states with waste management programs that
are recycled. Unless the generating site is a Conditionally Exempt Small Quantity Generator, generators out- side of the three states that have adopted the 2008 DSW rules must ship these materials to a recycler using a hazardous waste transporter and a hazardous waste manifest. The generator’s state has jurisdiction over the classification of any waste stream generated in the state, and it is therefore illegal to classify these waste streams as exempt under the
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60 |
Page 61 |
Page 62 |
Page 63 |
Page 64 |
Page 65 |
Page 66 |
Page 67 |
Page 68 |
Page 69 |
Page 70 |
Page 71 |
Page 72 |
Page 73 |
Page 74 |
Page 75 |
Page 76 |
Page 77 |
Page 78 |
Page 79 |
Page 80 |
Page 81 |
Page 82 |
Page 83 |
Page 84 |
Page 85 |
Page 86 |
Page 87 |
Page 88 |
Page 89 |
Page 90 |
Page 91 |
Page 92 |
Page 93 |
Page 94 |
Page 95 |
Page 96