Chemgon® FAQs
What is Chemgon®?
Chemgon® is a patented formula that converts hazardous, silver-laden x-ray and photo processing fluids into a non-hazardous solid, safe for disposal with regular trash.
How does Chemgon® work?
Chemgon® solidifies, encapsulates, chelates, absorbs and binds processing chemicals through the application of coordination chemistry, converting your hazardous waste to a non-hazardous solid waste safe for regular trash disposal. Standard toxicity testing (Toxicity Characteristic Leaching Procedures, TCLP) demonstrates that the Chemgon® treated waste tests well below the regulatory levels established by the EPA. Chemgon® treated waste results in a nonhazardous, non-biodegradable polymer safe for regular trash disposal.
Do I need to treat my fixer or photographic chemistry before disposal?
YES. The concentration of silver in used photo-processing chemicals is typically between 160-350 Parts per Million (PPM). Mixing with developer reduces the silver PPM by nearly half, between 80 – 175 PPM. The Federal EPA Hazardous Waste RCRA Regulations define hazardous amounts of silver as greater than 5 PPM. This means used, untreated processing chemicals are hazardous. Spent processing waste treated with Chemgon® reduces the PPM below the regulatory limit of 5 PPM and converts it from a liquid to a “solid” non-pourable, non-hazardous waste, safe for regular trash disposal. See EPA Document Table 1. Fines for improper disposal could be as much as $22,000 PER OCCURRENCE. In other words, each time silver-laden processing chemicals or silver reclamation unit liquid residue wastes are poured down the drain, the fine could cost you $22,000.
How many Chemgon containers can I use each month and still be considered a Small Quantity Generator (SQG)?
In order to be considered an SQG, you must not generate more than 220 lbs. of waste each month. Therefore, you can fill ten (10) Chemgon containers each month. Fixer weighs about (8) lbs. per gallon, so (25) gallons of fixer is the approximate threshold. Since fixer is mixed in equal parts with developer (non hazardous liquid waste) you can utilize (10) Chemgon containers for a total of 50 gallons of fixer/developer each month and still be considered an SQG. Small Quantity Generators are usually exempt from obtaining a treatment permit.
How do I use Chemgon®?
Simply pour equal amounts of fixer and developer into the Chemgon® container. It can be filled over time, so staging or other storage is not required. Once full, tighten the lid and place in your regular trash. Equal parts of fixer and developer are required so that a neutral pH is achieved.
What are the benefits of using Chemgon®?
1. Customers often save 75% compared to hazardous waste collection costs.
2. More convenient than collection or silver recovery; simply fill over time and dispose of the solidified contents when full.
3. Conveniently purchased from your supply partner, eliminates contracts, separate invoices and unnecessary interruptions to your practice.
The two biggest advantages are cost-savings and convenience. Customers using Chemgon® save up to 75% compared to hazardous waste collection costs.
With Chemgon® there is no need to maintain ‘manifests' your supply invoice is all you need as proof of compliance. We also have an online ‘Disposal Log' available if you choose to record your usage. Chemgon® provides peace of mind because hazardous liquids are rendered non-hazardous onsite and safe for regular trash disposal.
I only have my spent fixer, I understand equal parts fixer and developer must be used in order for Chemgon® to work; what do I do?
Purchase new developer to mix with your spent fixer. Pour equal amounts of the "new" developer and spent fixer into the Chemgon® container. We would prefer not to "waste" new developer but this is still more cost effective and better for the environment than using a collection service.
What products are not for use with Chemgon?
Electrostatic chemistry, fountain solutions, etches and blanket washes.
Is Chemgon® able to be used in all States?
Yes
California is the only state we are aware of that requires Small Quantity Generators to obtain a hazardous waste treatment permit to treat silver-laden photo-processing waste, with Chemgon.
What testing has been done to verify the effectiveness of Chemgon®?
Chemgon® treated waste passes the Paint Filter test, TCLP test for Metals and the California 96-Hour Acute Aquatic Toxicity test (the "Fish Test").
How do I get a permit in California?
To apply for a hazardous waste treatment permit or ‘Standardized Permit’ to treat hazardous silver fixer/activator waste in your office using Chemgon, generators located in California should visit the California Certified Unified Program Agency (CUPA) directory here: http://cersapps.calepa.ca.gov/Public/Directory/. Once there, click on County to find the contact for your area. Contact your county CUPA and ask for the hazardous waste specialist responsible for generator authorization for onsite treatment of this hazardous waste.
Who is Responsible for the “Determination of Hazardous Waste”
The generator is responsible for determining whether their waste is hazardous or non-hazardous. (See Code of Federal Regulations Title 40 CFR 262.11) Federal Regulations allow generators to make that determination by either testing via Toxicity Characterization Leachate Procedure (TCLP); or applying knowledge of the hazard characteristic in light of the materials and/or the processes used. This means you have the option to use documented waste analysis results of treatment, such as our testing results . Click here for Federal Regulations regarding maximum allowable concentration for silver in TCLP results: 40 CFR 261.24 Toxicity Results Table 1
What is General or Acceptable Knowledge?
Acceptable knowledge is broadly defined to mean an understanding of the resulting hazardous characteristic of the waste in light of the materials used and/or the treatment process used, including film processing waste test results post-treatment. Knowledge of the hazardous characteristic of film processing waste post-treatment can include detailed information about the waste obtained from existing or documented waste treatment analysis and/or studies conducted on wastes generated by processes similar to that which generated the waste in question. This means your “Acceptable Knowledge” includes TCLP toxicity test results provided by the manufacturer for the treatment product used. Click here for toxicity testing results of film processing waste treated using Chemgon: TCLP Reference: 40 CFR 262.11 (c)(2)
I need a SDS for Chemgon.
Chemgon Safety Data Sheet