Factsheet: Furniture Refinishers - Regulatory Requirements

Board of Public Works
HTM Office
City of Los Angeles

In order to protect individuals and the environment, control measures have been established at all levels of government regarding toxic materials use and hazardous waste generation. The following information is intended to benefit persons in the furniture refinishing industry to comply with environmental regulations and prevent costly operating delays or violations. The objectives are:

  1. The prevention of the generation of hazardous waste at its source
  2. Proper hazardous material and waste management.

Background

The furniture refinishing industry is composed of mainly small businesses employing one to ten people. The majority of the furniture being refinished is made of wood, but metal furniture also requires refinishing. The secret in achieving a fine finish, whether transparent or opaque, depends upon surface preparation and the subsequent finishing process.

Every furniture business has developed its own unique and customized procedures for refinishing. Depending on the job, a method to refinish the article will be chosen. The basic steps in all finishing processes are practically identical. The steps are:

  1. The finish on the old piece is removed
  2. The raw surface is sanded, stained and bleached
  3. The pores are filled
  4. A sealer is applied
  5. Several coats of transparent or colored film are applied for protection and appearance.

There are two commonly used methods to remove an old finish: the mechanical method utilizes such tools as the hand scraper, sandpaper and the electric sander, while the chemical method used either caustic or solvent solutions. The solvent solutions are the most popular and includes such chemicals as methylene chloride, acetone, and alcohol. The wood must be gently sanded after chemical treatment to remove any remaining stain. Many of the chemicals used by the furniture refinishing industry contain materials that are regulated by various agencies. Most coatings used in refinishing contain Volatile Organic Compounds (VOC). VOC coatings are regulated and concentration limits are defined in South Coast Air Quality Management District's (SCAQMD) Rules 1136 and 1171.

Stains should penetrate the wood well, dry in a reasonable time and become the desired color when applied on the wood. Some stains are solvent borne such as penetrating oil and alcohol, while other stains are water borne.

Fillers are required to level the wood by filling the wood pores. Paste fillers and diluted paste filler using solvents can be used to level open grained and closed grained surfaces, respectively.

Sealers and transparent films are either shellacs, varnishes, or lacquers. Shellac is a natural resin which is combined with a solvent such as alcohol. Varnished are slow drying coatings which are generally polyurethane. Solvents found in varnishes include turpentine, varnalene, and xylol. Solvents used in lacquers include acetone and ethyl alcohol. Thinners used in lacquers including toluene, benzene and xylene.

Table 1 [(see source document)]

South Coast Air Quality Management District Rules 1136 And 1171

The South Coast Air Quality Management District (SCAQMD) is responsible for controlling air pollution and attaining federal and state air quality standards in the greater Los Angeles area. This is done by limiting the emission of hazardous and toxic chemicals into the air. If you expect to start a furniture refinishing business, expand or relocate an existing operation, you must obtain an air quality permit through the SCAQMD. Permits are also required for any equipment or process that emits or controls air contaminants unless specifically exempted. Permits for new or modified facilities must be obtained before any construction begins.

Proper application equipment is required when applying coatings. The SCAQMD allows for the following application equipment.

  1. Electrostatic application
  2. Flow coat
  3. Dip coat
  4. High-volume, low pressure (HVLP) spray
  5. Paint brush
  6. Hand roller
  7. Roller coater

SCAQMD Rule 1136 limits use of high VOC coatings that are used on wood products. A coating cannot be applied which exceeds the limits in Tables 1, 2, or 3. A list of exempt chemical can be found in Table 4. The Group II Exempt Compounds are currently under review by the SCAQMD.

Restrictions on the use of Group Ii compounds may apply due to their toxicity, potential toxicity or their effect on ozone depletion. The amount of VOC coating used at your facility must be recorded to demonstrate the quantity of emissions from your facility. An exemption exists for facilities that apply coatings via aerosol containers 16 fluid ounces or less in volume or if the total volume of VOC containing coating applied per day does not exceed one (1) gallon. Coating usage records must be kept to verify the exempt status.

Rule 1171 regulates solvent cleaning of application equipment. The rule states that a solvent shall not have a VOC content greater than 950 grams per liter of material and a VOC composite partial pressure of 35 mm Hg or less at 20ºC (68ºF). Common VOC's found in cleaners are tricholorethane, methyl ethyl ketone, methylene chloride and acetone. Allowed cleaning processes include systems that totally enclose the equipment of flushes the part in a controlled manner. Wipe cleaning and cleaning with spray bottles with a maximum container of 16 fluid ounces is also allowed.

Hazardous Waste Generation

Do I Generate Hazardous Waste and If So, What Is It?

Table 2. Rule 1136 (August 1994) [(see source document)]

Typical wastes generated in the wood refinishing industry include solvent cleaning waste, coating waste and paint stripping waste. Hazardous waste is defined as any solid, liquid, or contained gaseous by-product that may pose a threat to human health or the environment if not managed properly. Hazardous wastes are currently regulated by federal, state, and local public health and environmental protection agencies. There are two ways a waste may be brought into the hazardous waste regulatory system: by listing or characteristic.

Listed Wastes - Your waste is considered hazardous if it appears on any of the state or federal lists, such as in Title 22 of the California Code of Regulations.

Characteristic Wastes - Even if your waste does not appear on one of these lists, it is considered hazardous if it exhibits any of the following characteristics: ignitability, reactivity, corrosivity, or toxicity. For more information on these criteria, refer to the California Code of Regulations, Title 22, section 66261.22, or the Code of Federal Regulations, Title 40, Part 261.

Hazardous Waste Generator Responsibilities

Hazardous waste generators must comply with the following requirements:

Hazardous Waste Management Requirements

You must handle your hazardous waste properly on-site, while accumulating adequate volume to ship to a permitted hazardous waste facility. In addition, all generators that would like to dispose of their waste must use permitted hazardous waste facilities. Some of the requirements for hazardous waste handling are listed below:

Hazardous Material Use

Hazardous Materials Business Plan

California law requires business handling gallons, 500 lbs., or 200 cubic feet for Hazardous Materials and any quantity of Acutely Hazardous Materials to implement a Hazardous Materials Business Plan. In the City of Los Angeles, Hazardous Material Business Plans are reviewed by the City of LA Fire Department. Among the information required are an inventory of the hazardous material handled on-site, a site map, emergency contact, emergency procedure and employee training records. For more information, see the contact list below.

Table 3. Rule 1136 (August 1994) [(see source document)]

Inventory & Certificate Of Disclosure

Inventory disclosure of all hazardous substances is required by the City of LA Fire Department. Division 8 of the Los Angeles City Fire Code requires that all businesses that store, handle, or process any hazardous substances must file an application for a "Certificate of Disclosure of Hazardous Substances". To obtain a form contact the Hazardous Materials Section of the Los Angeles City Fire Department. You must mail your completed application to the City Clerk within 30 days.

Zoning - Occupancy

Generators of hazardous waste may be required under City of Los Angeles Department of Building and Safety regulations to follow specific guidelines for occupancy. For detailed information consult Chapter 9 of the City of Los Angeles Municipal Code.

Industrial Wastewater Discharge Permit

The City of Los Angeles, Department of Public Works, Bureau of Sanitation enforces the Federal Water Pollution Control Act through their application, inspection and reporting requirements.

The purpose is to prohibit discharge of certain pollutants and maintain optimum wastewater quality. The agency also sets forth limits for the discharge of hazardous materials in the wastewater.

Storm Water Permit

The State Water Resource Control Board requires designated industrial facilities to have a storm water permit. The permit requires that non-storm water discharges such as chemical leaks and spills be prevented from entering the storm water system. If you have any chemical storage outside, you may have to file for a permit through your local Regional Water Quality Control Board and/or the City of Los Angeles, Bureau of Engineering, Stormwater Management Division.

Worker Safety And Health

Furniture refinishing poses a number of health and safety risks for the workers in such environments. The California Occupational Safety and Health Administration (CAL/OSHA) is responsible for insuring compliance with the applicable labor code and specifically Title 8 of the General Industry Safety Orders including the new requirements of Section 3203 (SB 198, Effective July 1991). This require employers to establish, implement, and maintain an effective safety plan, and injury and illness prevention program IN WRITING.

SB 198 requires:

A written safety plan

  1. A System for identifying and evaluating work plan hazards
  2. Methods and procedures for correcting hazards at the workplace, reporting of hazards by employees, and actions to correct it
  3. Occupational training covering hazards
  4. Communication system
  5. System to ensure employee compliance with safety
  6. A record keeping system

Right To Know

All employees have a legal RIGHT TO KNOW what hazardous substances and materials they are near or in contact while at the work place. Employees are entitled to ask employers for a Materials Safety Data Sheet (MSDS) for all hazardous substances on the premises. It is the employers responsibility to help the employees understand them. The employees should also know how to recognize the hazardous substances, safety precautions that should be taken when using any hazardous substances, and what the emergency and first aid procedures are for the particular substance the employees may come in contact with.

Table 4. [(see source document)]

Group II Exempt Compounds

methylene chloride
1,1,1-trichloroethane (methyl chloroform)
trichlorotrifluorethane (CFC-113)
dichlorodifluorethane (CFC-12)
Trichlorofluoromethane (CFC-11)
dichlorotetrefluoroethane (CFC-114)
chloropentafluoroethane (CFC-115)

Where To Turn For Help

For additional information on the regulations that impact your operations, contact the following:

Business Plans and Certificate of Disclosure:
Los Angeles Fire Department
200 N. Main Street
Los Angeles, CA 90012
Tel: (213) 485-8080

Certificate of Disclosure fees:
Elias Martinez, City Clerk
P.O. Box 30626
Terminal Annex
Los Angeles, CA 90030

Industrial Wastewater Discharge Permit:
City of Los Angeles
Public Works Department, Bureau of Sanitation
Industrial Waste Operations
Tel: (213) 485-5886

California Regional Water Quality Control Board
Stormwater Unit
Tel: (213) 266-7500

City of Los Angeles, Bureau of Engineering
Stormwater Management Division
Tel: (213) 847-6350

State Fees/Taxes on Waste Generation (If you generate > 5 tons per
year or land dispose > 500 lbs per year):
State Board of Equalization
Tel: (916) 739-2582

EPA ID No.:
Cal-EPA Dept. of Toxic Substances Control
P.O. Box 806
Sacramento, CA. 94234-7320
Tel: (800) 618-6942 ID number
(916) 323-5871 tiered permitting

Air Quality Permits/Small Business Air Quality Permits Assistance
South Coast Air Quality Management District
Public Advisors Office
21865 East Copley Drive
Diamond Bar, CA. 91765
Tel: (909) 396-3225

Generator Public Health License for Hazardous Waste:
Los Angeles County Fire Department
Health Hazardous Materials Division
5825 Rickenbacker Road
Commerce, CA. 90040
Tel: (213) 890-4045

Generator/Waste Reduction Assistance:
City of Los Angeles Hazardous & Toxic Materials Office
200 N. Spring Street, Room 353
Los Angeles, CA. 90012
Tel: (213) 237-1209

Pollution Prevention Tips

[(see source document)]


Last Updated: November 13, 1995