Safe Handling of Tennis Court Coatings

Pointers for environmentally safe application, removal, storage, and disposal of tennis court surfacing materials

I. Application Hazards

Although crystalline silica (sand) is a respiratory hazard, it is wet and encapsulated during application by squeegee, roller, or brush. Only spray application would require spray mist respirators. Removal of dry films of our products should be by water blasting if possible. Workers doing shot blasting, sand blasting, or mechanical grinding should wear NIOSH-approved dust filter respirators capable of controlling dust exposures to less than 0.1 mg/m³. Wastes should be wetted and consolidated into landfill disposal where permitted by local regulations.

II. Minimizing Waste
Proper handling of empty and near-empty containers is not difficult if it is done on a routine basis. Follow these steps:
1. Thoroughly rinse containers when material is used at the job site.
2. Use the rinse water to make your dilutions.
3. This clean drum then becomes a saleable commodity.
4. Consolidate leftover material into full drums by type of material. Material should be used as soon as possible to avoid spoilage.
5. Intermixed colors can be used as a first coat on certain projects.
6. If material is unusable, it can be used to make concrete or disposed of according to local ordinance.

III. Storage
1. All drummed material should be stored under cover. Direct sunlight will significantly reduce shelf life of the product and may effect application properties. It can also affect application properties. Special additives are available for products that have been mishandled.
2. Keep temperature below 120°F (50°C).
3. Do not allow to freeze.
4. Do not mix material until just before you are ready to use it.
IV. Drum Disposal
To assist you in disposing of these empty containers, the following information provided to us by the National Barrel & Drum Association, which gives the EPA’s definition of an “Empty Container”:

With regard to most regulated residues, EPA’s 40 CFR 261.7 says: “A container. . . is empty if: (i) All wastes have been removed that can be removed using the practices commonly employed to remove materials from that type of container, e.g., pouring, pumping, and aspirating, and (ii) No more than 2.5 centimeters (one inch) of residue remain on the bottom of the container. . .” EPA has explained this rule, saying that “one inch of waste material is an overriding constraint and may remain in an empty container only if it cannot be removed by normal means. The rationale for this provision is that there are certain tars and other extremely viscous materials that will remain in the container even after the container is emptied by normal means.”

For residues of products specifically listed by name in 40 CFR 261.33 (e), EPA says the container is empty only “if the container. . . has been triple-rinsed using a solvent capable of removing” the products, or has been cleaned by another method shown to achieve equivalent removal.

Please note that the last paragraph (above) pertains to products such as our tennis court coating materials. Water is the appropriate solvent to use in the triple rinse process while the product is still in its liquid form. Heavy dry films of our coatings are not capable of being removed by triple rinsing with any organic solvent.

V. Spills
Steps to be taken in case materials are spilled:
1. Keep unnecessary people away from spill area since the area may become slippery. Use care to avoid falling.
2. Dike and contain materials with inert material (e.g. sand, earth).
3. Transfer liquid to containers for recovery or disposal and solid diking material to separate containers for disposal.
4. Recovered liquids can possibly be strained of foreign materials and added to intermediate or undercoats where a different colored layer won’t matter.
5. Keep spills and cleaning run-offs out of municipal sewers and open bodies of water.
VI. Wastes Containing Trivalent Chromium Oxide (Cr²O³)
From time to time, we are asked if our various green tennis court coatings are hazardous since they contain a chromium compound that is listed on our MSDS.

The EPA has determined that trivalent chromium oxide, which is the product used in all of our green coatings, is not hazardous waste as long as the waste is managed in non-oxidizing environments.

For your information, we are attaching a photocopy of the above-cited regulation for you to hand to your hazardous waste handlers.

VII. Safe Handling of California Concrete Preparer
The only corrosive material in our recreational product line is “California Concrete Preparer”, Product No. 4520. This concrete etching/treating compound is packaged in 5 gallon polyethylene carboys with an outer shipping carton. Please note that this product may not be shipped to comply with DOT regulations unless its cardboard outer carton is intact. Do not ship the plastic carboy unprotected by the outer carton. If, for some reason, the outer carton becomes damaged call our customer service line (Ext. 246) to request a replacement carton. We are enclosing a revised MSDS for this product with this Plexigram.

We recommend some special safe handling practices with this product. The use of rubber globes and splash goggles for eye protection while using this product even in its diluted form is necessary. Do not attempt to dilute this or mix or store it in unlined steel drums or galvanized metal pails since hydrogen gas can be generated which is highly flammable.

VIII. MSDS Availability
Material Safety Data Sheets for our products are available upon request from two sources:

1. Our distribution points (warehouses).
2. By request from Customer Service at:
Phone: 1-800-225-1141, extension 246
Fax: 1-978-623-9960

IX. Additional Questions
If you have additional questions about any of the topics covered in this application areticle, you can contact Ronald B. Child, Vice President Compliance & Regulatory Affairs at 1-800-225-1141 or 978-623-9980, ext. 223.