Q: We lease out a 7,500-sq-ft building to a company that does powder coating. They have asked permission to build a small building next to the current 7,500-sq-ft building to sandblast products prior to powder coating. (So they can sandblast in a contained area.)
What kind of issues should be discussed with the lessees to be sure they are not contaminating the building or the land around the building? What questions would I need to know to have someone inspect to see if all is OK? What kind of inspector?
A: These are excellent questions. Here are some issues to consider:
- What type of media will your tenant be using? Will it be a mineral or a plastic? Plastics are generally non-toxic. Crystalline silica (i.e., sand) is a respiratory carcinogen but not a land contaminate. Aluminum oxide is rather benign.
- What type of coatings will your tenant be stripping? Old industrial coatings can contain heavy metal pigments such as lead oxides, chrome oxides, cadmium, and molybdenum compounds, all of which can contaminate the environment. If the stripping will only involve reprocessing powder-coated parts, chances are there will be no heavy metals in the powder coatings; the North American powder industry has shunned the use of these materials.
- Will your tenant be stripping corroded metals? Some metals or plating contain heavy metals (chromium, etc.).
- How will the blasting media be contained? Will the blasting cabinet be sufficiently secure to avoid airborne leakage into the atmosphere?
- How will the spent media be disposed of? Local regulations may impact how the waste media is handled. If modern-day powder coatings are the only coating being stripped, then the waste material may be easily disposed of at the landfill.
Who should inspect this process? Good question. Your choices include: a local representative from your state’s Environmental Protection Agency (EPA), an independent powder consultant, or possibly a representative from your insurance company.
The larger insurance companies have environmental experts that offer their services as part of your insurance coverage. I have had success using them through the years. Some state EPAs will inspect processes and render recommendations (maybe more like mandates) for the handling of emissions and effluents.