Why is F019 a Problem for Auto Manufacturers - Brief Article

Automotive Finishing, Summer, 2001 by Beverly A. Graves

The BMW Manufacturing Corporation in Greer, South Carolina, has petitioned the U.S. EPA to exclude or delist aluminum from its hazardous wastewater, even though the waste generated meets the definition of F019 (Wastewater treatment sludges from the chemical conversion of aluminum except from zirconium phosphating in aluminum can washing). BMW, however, does not believe its waste meets the criteria for F019 wastewater sludges, since aluminum is only a minimal amount of the metal it processes. This is not an isolated case. Automotive manufacturers all over the country are encountering this problem.

The problem arises when you try to run aluminum parts through the cleaning and phosphating system prior to painting. Once you mix in any aluminum with the steel, no matter how small the aluminum part, the waste is considered F019 and therefore hazardous. BMW's conundrum occurred when it decided it wanted to fashion hoods from aluminum. However, it also had to decide whether or not handling the F019 was worth having aluminum hoods on its cars. Thus, the delisting petition ensued.

The American Automobile Association (AAA) also petitioned the EPA to look at this overall issue and write an interpretive ruling that would "fix" it. The AAA provided EPA with information on 40 assembly plants, including risk assessment information, which required years to accumulate. The U.S. EPA claimed that it didn't have time to review the information and passed it over to Region 5 for evaluation. Region 5 claimed that the data was not adequate. This was quite frustrating to the members of the AAA, since they were following procedures agreed upon with the federal U.S. EPA.

The major problem with the rule is that when it was enacted, the EPA was looking at the use of hexavalent chromium and cyanide as used in paint pretreatment processes. It was not really considering aluminum. Many plants don't use hexavalent chromium in their pretreatment processes, and cyanide is nearly a thing of the past. But aluminum is still on the list, and therefore, still regulated.

So, plants are still undergoing individual delisting processes while the AAA is trying to work with EPA to get a general delisting ruling. These individual delistings can take years to go through and require a lot of time, money and paperwork. Much the same as any shop that wants to delist any type of waste. This is the only option open to them, until something can be worked out on a national level.

The law, as it is written now, actually gives the automobile manufacturers no incentive to get rid of hexavalent chromium form their shops. If the aluminum is delisted from the wastewater, there would be a major incentive to get rid of the chromium and use alternative pretreatments, which are already available. Then the companies would not have any hazardous waste to deal with. Obviously, the EPA is not looking at the big picture.