A Guide for Fiberglass Operations

A Guide for Fiberglass Operations

Why should fiberglassers pay attention to their products and wastes?

Fiberglassers across Washington State regularly use products that are hazardous or dangerous to workers. For example, the laminating process uses resins and catalysts that are flammable. Tool cleanup also often involves using a flammable solvent, like acetone.

Fiberglassing activities also generate a steady stream of potentially hazardous air emissions, spent solvents, and other wastes that can impact the environment. With over a thousand fiberglassers in the state, it is important that each one do their part to minimize impacts to human health and the environment.

This means that you play an important role! By correctly managing your wastes, you will ensure that you are in compliance with federal, state and local environmental regulations and avoid costly penalties. Better yet, by reducing your use of hazardous products and generation of wastes, you can:

Reduce the costs for waste disposal, permits, and materials management.

Reduce administrative, compliance-related costs by dropping below regulatory thresholds for reporting.

Gain customers who know they have made a wise choice in selecting a business that helps protect the environment

What regulations typically apply to fiberglass operations?

A number of regulations can apply to fiberglass operations. These regulations stem from the types of products used and types of wastes generated by the industry. Table A lists typical fiberglass processes, products and wastes. The regulations, referenced in the table, protect worker health and safety, community rights and the environment.

Worker Health & Safety

The state's Department of Labor and Industries implements worker health and safety regulations. If you employ one or more people in your shop, you must ensure that:

Workers have access to appropriate safety and protective gear, like gloves and respirators.

Workers understand any hazards associated with their job. Hazardous products must be identified and labeled, and information about the product must be kept on-site.

Workers are not exposed to excessive levels of air-borne pollutants, like styrene.

Labor and Industries has an assistance program to help you understand health and safety issues. Contact them at 1-800-423-7233.

Table A -- Typical Fiberglass Processes, Products Used and Wastes

^Process Process & Primary Products Used¹ Primary Wastes²

Mold Preparation Release Agent -- Nonhazardous wax or a polymer coating. Dirty Rags -- usually nonhazardous; often recycled through industrial laundry.

Air Emissions -- styrene and other volatile organic compounds (VOCs) and toxic air pollutants (TAPs) are commonly regulated by local air authorities.

Overspray Solids, Trim-ends, & Cut-outs - Nonhazardous; often disposed in landfill, although some progress has been made toward recycling options.

Spent Solvent & Still Bottoms - Often Hazardous if the solvent product was flammable or toxic. Nonhazardous waterbase products are often managed through local sewer (contact local sewer utility first).

Waste Paints, Thinners, Adhesives, Foaming Agents, or Still-bottoms - Often Hazardous because of low flash-point or halogen content.

Solvated or Residual Resin, Out-dated Materials, Spilled Materials or Wastes, Spent Filters -- Can be Hazardous if the product(s) were hazardous.

Gelcoating & Laminating Resin -- Often Hazardous because it is flammable and contains styrene monomer.

Initiators & Catalyst - Often Hazardous because they're flammable and explosive due to peroxide content.

Reinforcement - Nonhazardous glass fiber; aramid and carbon fibers are also sometimes used.

Tool or Equipment Clean-up Solvent - Often Hazardous because of low flash point or chlorine content. Acetone, toluene, xylene, and various alcohols are flammable. Emulsifiers and citrus-base solvents may be toxic, and chlorinated solvents ARE toxic.

Finish Lines³ Paints & Stains, Thinners, Adhesives, & Foaming Agents -- Often Hazardous because of low flash point, halogen content, or metals content.

Secondary Systems⁴ NONE -- Materials are not actually "used", but are "managed".

1 -- If the product is referenced as being hazardous, then regulations may apply to worker health and safety, fire risk, and "Community Right-to-Know".
2 -- If the waste is referenced as being hazardous, then it is regulated by the state's Dangerous Waste Regulations (WAC 173-303). Water quality standards may also apply; if nonhazardous waste is to be discharged to the septic system, the local sewer utility should be contacted first.

3 -- Painting, mold making, upholstery, and foam manufacturing lines.

4 -- Materials storage and delivery, air ventilation systems, and waste management systems.

Worker Safety -- Fire Risk

Local fire codes regulate flammable products, like acetone and resins. These codes define how much product you can have on site. They also define how products should be stored and/or "processed" in your shop. For example, peroxide catalysts must be stored in an explosion-proof cabinet. Contact your local fire marshall to determine which, if any, fire codes apply to your shop.

Community Right-to-Know

Title III of the Superfund Amendments and Reauthorization Act (SARA), known as the "Community Right-to-Know" law, requires businesses to report their use of hazardous chemicals.

This federal law affects your shop if you use over 10,000 lbs of any solvent and/or over 50,000 lbs of resin per year. Acetone was recently removed from SARA's regulated list, but other solvents like toluene and xylene remain 'listed' and are regulated.

Contact the Department of Ecology's Hazardous Substance Information Office at 1-800-633-7585 to see if your shop is regulated by the law.

Air Emissions

The Department of Ecology or local Air Pollution Control Authorities regulate businesses that release volatile organic compounds (VOCs) and/or toxic air pollutants (TAPs). These compounds can create smog, damage the Earth's ozone layer, impact human health and affect the environment. In your shop, you may be able to smell VOCs in the form of styrene or solvent emissions.

Fiberglassers must obtain an air operating permit if they emit 10 tons or more of any one federally designated hazardous air pollutant (HAP) like styrene, or 25 tons or more of all HAPs combined, and/or 100 tons of any regulated pollutant like acetone. Also, businesses that plan to build or expand should check with their local air authority to determine if a "new source" review and permit is necessary.

Solid Wastes

Overspray solids, unused products, solidified resins, trim-ends and cutouts typically are not regulated. However, some landfills do impose restrictions on pick-up and disposal. Contact your local landfill to determine if restrictions apply.

Water Releases

Spent solvents or other wastes should never drain onto the ground or into a septic system, stormdrain, surface water or any other drain not connected to a sanitary sewer. This type of improper disposal can have an adverse affect on groundwater, surface water and sediments.

If you want to discharge non-hazardous wastes to the sewer, contact your local sewer district to obtain authorization before releasing wastes.

Businesses that plan to build or expand should check with the Department of Ecology's Water Quality Program to determine if they need a discharge permit. A permit also may be required if activities take place outside where pollutants could leave the site in stormwater runoff. Contact the closest Ecology Regional Office with questions.

Hazardous Wastes

Some fiberglassing wastes are regulated because they are hazardous. For example, spent acetone is regulated because it is ignitable, and spent emulsifier is sometimes regulated because it is toxic to fish.

The State's Dangerous Waste Regulations (WAC 173-303) define the different types of hazardous wastes. They also explain how to store, transport and dispose of these wastes. The regulations also guide how wastes should be managed when recycled.

Businesses that generate more than 220 lbs of hazardous waste per month (about half a 55-gallon dnmn) are regulated by Ecology's Hazardous Waste and Toxics Reduction Program. These businesses need to obtain a RCRA Identification Number, and should contact Ecology for more information about the regulations.

Businesses that generate less waste are regulated by local government Moderate Risk Waste (MRW) Programs. These programs provide assistance to small quantity generators, and can help guide the proper disposal of hazardous wastes.

How can fiberglassers most effectively deal with regulations?

One of the most effective ways to deal with regulations is to get out of their way! You may be able to effectively avoid regulations, or at least reduce paperwork burdens, by preventing pollution. By moving to the source of problems you can:

Reduce your use of hazardous products and your generation of wastes.

Improve worker health and safety.

Reduce costs associated with waste management and product purchases.

Reduce fire hazards, spill problems, and other liabilities.

Many fiberglassers have found that it isn't as hard to prevent pollution as they thought. Try using the following four-step process:

Walk through your shop and determine where hazardous products are used and where wastes are generated. Table A lists some of those sources.

Review your operating practices and line operations, then match them to the reduction or recycling options offered later in this guide. Ask these key questions:
- Where can I reduce the use of hazardous products? Could alternative, less hazardous products be used?
- How can I reduce my waste? Could air emissions, evaporation losses, or spills and leaks be reduced?
- What waste can I recycle? Could waste solvent be distilled, or solid wastes reused? Recycling waste is much better than sending it to be burned or landfilled, but it is less beneficial than reducing it. A lot of resources are required to properly collect and manage wastes for recycling. Those resources and costs can be cut by reducing the amount of waste generated in the first place.

Evaluate pollution prevention opportunities for their technical and economic merit. Does the "new" solvent work in each application? Do workers accept the change? Is it affordable, or worth the cost because it results in reduced risk or improved quality?

Set goals and timelines to help keep you on target. How will the changes save money or improve quality? And, when can you expect results?

Can you improve your Operating Practices?

Good operating practices can not only help prevent pollution, they can help you comply with various regulations. Use the following checklist to review your operating practices.

Storage and Housekeeping

Keep lids on products and wastes, and store them so they can be easily inspected for leaks.

Keep labels on products and wastes to quickly identify them and to prevent accidental mixing.

Use curbs, pans or buckets to catch any possible leaks or spills.

Keep work areas and walkways free of tripping hazards and obstructions.

Stack containers so they can't tip, puncture or break.

Store empty drums and containers in a place where they won't collect rainwater.

Inventory Control

Have Material Safety Data Sheets (MSDSs) available in case of an emergency.

Buy and store only the amount of product that is needed.

Purchase products in rinsable, recyclable containers with a minimal amount of packaging.

Ration solvents or other products to minimize use.

Training and Awareness

Train workers about regulations, emergency procedures, health and safety issues, and reduction alternatives.

Follow routine procedures for mixing, transferring, and applying gelcoats and laminates, and for cleaning tools.

Use proper insulation of electric circuitry, and inspect it regularly.

Have first aid supplies, spill equipment, and emergency phone numbers accessible for use.

Have respirators, gloves, and other personal protective gear available to workers.

Information Resources

Contact vendors to determine which products are hazardous and to find other, less hazardous products.

Contact trade groups to get the most current information about fiberglassing issues.

Contact regulatory authorities to determine which laws apply and to get assistance.

Can you improve your gelcoating and/or laminating activities?

There are many possible reduction opportunities for gelcoating and laminating, primarily focused on reducing the use of resins and catalysts and generation of air emissions.

Spray Guns -- Reduce overspray and the amount of product used by:

Properly training operators to hold gun perpendicular to the surface and trigger gun at the beginning and end of each pass.

Using air-assisted airless spray guns in place of air-spray guns.

Using high volume/low pressure (HVLP) guns.

Catalysts -- Reduce emissions and product use by:

Using benzoyl peroxide (BPO) in place of MEKP.

Using higher amounts of cobalt & DMA in place of MEKP.

Using higher amounts of inert filler.

Engineering Controls -- Reduce product use by:

Installing gelcoat timing equipment.

Reducing laminate thickness to engineered minimum.

Using heaters in production area to improve process efficiency.

Alternative Processes -- Reduce emissions and product use by:

Installing closed-mold system (resin transfer molding).

Installing impregnator system.

Installing resin rollers.

Installing vacuum-mold or infusion system (SCRIMP).

Using ABS-backed acrylic sheets in place of fiber lay-up.

Alternative Resins -- Reduce emissions and product use by:

Using resin with lower styrene content.

Using heat to reduce viscosity.

Using UV-cured, vapor-suppressed or vinyl toluene resins.

Can you improve your tool & equipment clean-up activities?

Rollers, transfer hoses, drums, spray guns, and other tools and equipment that come into contact with resins must be solvent washed immediately after each run to avoid polymerization. Historically, acetone was the solvent of choice, but recently other solvents like emulsifiers and citrus-based cleaners have gained in popularity.

Ecology's Toxics Reduction Unit, product vendors, and trade groups can offer more information about pollution prevention alternatives, including the following:

Use and Practice

Allow solvent to become dirtier before disposing or recycling.

Install additional spray lines to reduce the need for clean-out.

Install disposable liners in buckets.

Install gun cleaning tank/unit.

Install two-bucket wash; one clean and one dirty.

Keep lids on soaking buckets.

Ration solvent or other material.

Reduce the number of cleaning buckets.

Remove solid resin by hand prior to solvent wash.

Use disposable rollers or brushes.

Alternatives to Acetone

Use citrus-based solvent.
Use diacetone alcohol.
Use dibasic acid ester.
Use emulsifiers.
Use ethyl ethoxypropionate.
Use isopropanol.
Use propylene carbonate.
Use uncatalyzed resin to flush lines.

Waste Management

Decant and reuse spent solvent.

Install on-site distillation unit, and then grind and reuse still bottoms in "putty".

Separate and reuse scrap fiberglass through Amour Fiber Core.

Common Definitions

Every industry has its own jargon that is shared by those who work or serve that industry. The fiberglassing industry is no exception. The following defines some of the key terms used by this group:

BPO -- "Benzoyl Peroxide" catalyst used for curing unsaturated polyester and vinyl ester resins at elevated temperatures.

Catalyst -- Substance added to gel coat or resin to initiate the curing, or cross-linking, process.

Closed Molding -- Process using two matched molds to render a good inside and outside surface.

Curing -- A polymerization process transforming liquid resin to a solid, creating the maximum physical properties attainable from the materials.

FRP – "Fiber Reinforced Plastics".

Gel coating -- Colored resin is sprayed, along with catalyst to the most /visible surface of the object being manufactured. Gel coating provides a cosmetic, often shiny surface and environmental protection for the fiberglass laminate.

Hand Lay-up (laminating) -- Resin and catalyst are applied on top of the gelcoat along with reinforcing fiber. Resin is brushed on with catalyst and then a fiber mat is laid down over the resin. Successive layers of resin and fiber are added until the desired product thickness is achieved. Once the reinforcement is in place, hand rollers are used to remove voids, smooth the surface and insure proper integration of resin and reinforcing material.

MEKP – "Methyl Ethyl Ketone Peroxide" is the most popular catalyst in use in the industry. It is a clear colorless liquid with a slightly pungent odor and is a potential explosive hazard. It is incompatible with very strong acids, bases, and oxidizers, and presents various potential health hazards.

Open Molding -- An open mold provides a surface for applying "sprayed lay-up" or "hand lay-up' materials.

Prepreg Fiber Reinforcement -- "Prepregs' are presatttratcd with resin and allow for close control of fiber to resin ratios, reduced air emissions, and reduced clean-up and disposal of wastes.

Resin -- Either'natural or synthetic products, generally having high molecular weight. Most uncured resins used in open molding are liquids. Generally, resins are used to surround, cross-HA, and hold fibers to create a composite material with high mechanical properties.

RTM -- 'Resin Transfer Molding' is carried out in a closed mold at room temperature. Get coat is applied to one or both sides of the mold, and reinforcing materials are placed in the bottom half of the mold. The mold halves are closed and clamped, and catalyzed resin is injected into the mold.

SCRIMP -- "Seemann Composite Resin Infusion Molding Process", infusion process that provides high fiber to resin ratios with virtual elimination of air entrapment and void.

Sprayed Lay-up (laminating) -- Resin and catalyst are sprayed onto the gelcoat surface using airless, air-assisted, or high volume/low pressure (HVLP) spray guns. In some cases short chopped fibers are also introduced into the spray pattern with the resin and catalyst. In large parts where structural strength is critical, fiber-reinforcing sheets are used instead of chopped fibers. These sheets are placed in the mold and sprayed with catalyzed resin. Once the reinforcement is in place, hand rollers are used to remove voids, smooth the surface and insure proper integration of resin and reinforcing material.

Styrene -- An unsaturated hydrocarbon used in plastics. In polyester resin it serves as a solvent and as a co-reactant in the polymerization process that occurs during curing.

Vacuum Bag Molding -- After gel coat, reinforcement and resin is applied to mold, the exposed area is covered with plastics which are scaled to the edges of the mold. Before the resin begins to cure, a vacuum is drawn through the system. The vacuum ensures full distribution of resin, labor is reduced (no rolling), and emissions and other wastes are reduced.

This information can be found in A Guide for Fiberglass Operations" Publication Publication # 96-430 (this publication is currently is under revision).

Resources and Contacts

Trade Groups

Composites Fabricators Association

Contact: John Schweitzer

(703) 525-0511

Oregon Reinforced Plastics Association

Contact: Jim Watts

(503) 228-3387

National Marine Manufacturers Association

Contact: John McKnight

(202) 721-1604



^Process	Process & Primary Products Used¹	Primary Wastes²
Mold Preparation	Release Agent -- Nonhazardous wax or a polymer coating.	Dirty Rags -- usually nonhazardous; often recycled through industrial laundry. Air Emissions -- styrene and other volatile organic compounds (VOCs) and toxic air pollutants (TAPs) are commonly regulated by local air authorities. Overspray Solids, Trim-ends, & Cut-outs - Nonhazardous; often disposed in landfill, although some progress has been made toward recycling options. Spent Solvent & Still Bottoms - Often Hazardous if the solvent product was flammable or toxic. Nonhazardous waterbase products are often managed through local sewer (contact local sewer utility first). Waste Paints, Thinners, Adhesives, Foaming Agents, or Still-bottoms - Often Hazardous because of low flash-point or halogen content. Solvated or Residual Resin, Out-dated Materials, Spilled Materials or Wastes, Spent Filters -- Can be Hazardous if the product(s) were hazardous.
Gelcoating & Laminating	Resin -- Often Hazardous because it is flammable and contains styrene monomer. Initiators & Catalyst - Often Hazardous because they're flammable and explosive due to peroxide content. Reinforcement - Nonhazardous glass fiber; aramid and carbon fibers are also sometimes used.
Tool or Equipment Clean-up	Solvent - Often Hazardous because of low flash point or chlorine content. Acetone, toluene, xylene, and various alcohols are flammable. Emulsifiers and citrus-base solvents may be toxic, and chlorinated solvents ARE toxic.
Finish Lines³	Paints & Stains, Thinners, Adhesives, & Foaming Agents -- Often Hazardous because of low flash point, halogen content, or metals content.
Secondary Systems⁴	NONE -- Materials are not actually "used", but are "managed".
1 -- If the product is referenced as being hazardous, then regulations may apply to worker health and safety, fire risk, and "Community Right-to-Know". 2 -- If the waste is referenced as being hazardous, then it is regulated by the state's Dangerous Waste Regulations (WAC 173-303). Water quality standards may also apply; if nonhazardous waste is to be discharged to the septic system, the local sewer utility should be contacted first. 3 -- Painting, mold making, upholstery, and foam manufacturing lines. 4 -- Materials storage and delivery, air ventilation systems, and waste management systems.



	Composites Fabricators Association
	Contact: John Schweitzer
		(703) 525-0511

	Oregon Reinforced Plastics Association
	Contact: Jim Watts
	(503) 228-3387
National Marine Manufacturers Association
				Contact: John McKnight
			(202) 721-1604