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�,,., C13rpOrnte OttICEt <br /> t 'f P�: 1'J- 7329 Fntrzro Ave_ <br /> South M Morita,CA 91733,USA <br /> Phom:526-445-9274 Fax;626-444.0382 <br /> _ _- vavrvv_�rcilnatpafnt.corn <br /> To 1:'hom It May Concern: <br /> Cardinal faint&Powder does not intentionally utilize pigments or other ingredients which contain heavy metals listed <br /> in 22 CCR 66261.21. l have included a copy ofthe pertinent language ofthis regulation for your review. The question <br /> as to whether a waste is hazardous involves several issues. First is it a list waste? Federal and State authorities have <br /> designated certain materials as hazardous%vaste per se. Ifthe waste is not listed then you have to ask if it demonstrates <br /> the characteristic of a waste. These would be reactive,corrosive.,flammable,or toxic. <br /> Powder coatings are not reactive,corrosive or flammable. The State or California has developed a list ofrrmetals which <br /> ifpresent could render the waste hazardous,if not present the waste would not be considered toxic. I am forwarding <br /> copies of analysis performed on our powder coatings by an independent laboratory. If you compare the test resultivith <br /> the regulatory limit established in 77 CCR 66261 24 you will find that there are no constituents present that exceed <br /> regulatory limits. In cases where a particular constituent shows a result considerably above non detect we have also <br /> performed the STLC(soluable threshold limit concentration)analysis. This test result appears atthe bottont ofthe <br /> TTLC(total threshold limit concentration)testing. You may notice that barium sulfate has a higher result than other <br /> constituents. Pfyou look at 22 CCR 66261.24 the footnote marked++you will see that barium sulfate is specifically <br /> excluded from barium and or barium compounds. Despite this fact the STLC for barium has been performed and the <br /> result is listed at the bottom of the TTLC analysis. <br /> Barium sulfate has been delisted from the category"barium compounds"on the list oftoxie chemicals for which <br /> reporting is required under sec_313 of the Emergency Planning and Community R1GHT-T0-KN0W Act of 1986 <br /> (EPCRA)since.Tune 28, 1996. 40 CFR Part 372. <br /> In addition Cardinal has performed a Hazardous Waste Screen 13ioassy,(CAL)on each series of our powder products. <br /> In this analysis the product is fed to fish at various concentrations for various lengths of time. The results ofthis <br /> analysis shote that these coatings caused no death at any of the established intervals. These results show that these <br /> coatings are not harmful to aquatic life. <br /> The test data provided is from 2001. No changes have been made to these formulas since the analysis Nvereconducted_ <br /> I am including a copy of a recent test performed on powder coating materials contained in our dust collection system. <br /> This would bean aggregate of all the coatings we manufacture_ The results indicated no California metals present ai or <br /> near the regulatory limit. <br /> We strongly recommend that you perform similar analysis on the material of which you plan to dispose in order to <br /> certify that your waste does not contain heavy metals above the limits established in 22 CCR 66261.24. Ifyou have <br /> any further questions please call me at 626-937-6767. <br /> Sincerely <br /> Mike Shirey <br /> Laboratory Mans ger <br /> SOUTH EL NAONTE.CA.CITY OF INDUSTRY,Ch •*AN JOSE.CA . PHOENK AZ - DENVER,CO - HIGH POINT,K - ViDODIN€vlli.l<,ViA <br /> VIARPER PA - LjW0ALLE,IAN . MARYLAND HEIGHTS,Mil . DALLAS.TX - HONG KONG <br />