Powder Coating Facilities

A spill or release during receipt of raw materials, including solvents, pretreatment chemicals, etc., or removal of wastes or wastewater could result in an environmental condition.

Chemicals such as acids, iron phosphate, zinc phosphate, chromates, etc., are used in pretreatment processes. Typically, this process involves immersing metal parts in a series of tanks. Leaks or spills from the tanks and lack of or failure of secondary containment systems could result in the migration of chemicals to floor drains, beneath facility floors, or outside the facility, leading to potential impacts to soil, groundwater, or surface waters or upsets to the sanitary sewer.

Pretreatment processes can generate hazardous and non-hazardous wastes, including sludges and wastewater. These wastes and wastewaters require proper handling and storage. Spills from storage areas can cause environmental cleanup liability and pose health hazards to third parties. Improperly segregated and disposed of wastes can result in regulatory fines and lead to cleanup and environmental tort liability.

Powder coatings are typically applied in a spray booth. The dust from spraying powder coatings can be combustible when the dust-to-air ratio is elevated. Any spark can cause a fire. A fire at the facility could emit toxic fumes and smoke from the materials stored at the site or from a mix of materials resulting from the fire. Firefighting solutions such as water or foam could create contaminated run-off that spreads to nearby storm drains or properties, resulting in environmental cleanup and tort liability.

Transportation of process chemicals, wastes, or wastewater presents additional pollution risks and public exposures. A release during transit could lead to environmental liability risks for the powder coating facility as the generator, even if a third-party carrier is used.

Abrasive blasting, the process where abrasive material is propelled against a surface under pressure, may be used to clean off surface contaminants from metal parts to be powder coated, such as oils, oxides, and grease. If sands are used as the abrasive material, they contain crystalline silica. Breathing silica dust can cause silicosis. Dust generated from abrasive blasting operations can contain contaminants, and if not adequately controlled, they can impact third parties.

Powder coating operations produce dust. Triglycidyl isocyanurate (TGIC) is a chemical compound formulated in some powder coatings as a curing agent. TGIC is a skin sensitizer, eye irritant and can cause allergic contact dermatitis and asthma. Inadequate or poorly maintained ventilation systems can lead to third-party bodily injury exposures from contact with dust from powder coatings.