What is "Applied Knowledge"?

Ever heard the term "Applied Knowledge"? It means "practical experience combined with the ability to read an MSDS and draw a conclusion". It’s also another way of saying "assumption". Federal and state guidelines tell you to "make disposal decisions based on applied knowledge OR run TCLP testing". That is a rather open-ended guidance. Oh, and by the way, the field inspectors will tell you that it "isn't their job to tell you of your responsibility to determine if your waste is hazardous or not".

John Q. Bodyman has been running a collision repair shop for 20 years. He can call a tint from 30 paces; he can customize, pearlize and terrorize along with the best of them. He can smell a paint and tell you who makes it. He can read an MSDS sheet and know if the stuff in the can will be okay or if it will show up on satellite images. John read his MSDS and decided that there wasn't anything harmful in that paint, ergo nothing harmful in the spray booth filter or the still bottoms.

Based on his "applied knowledge", John decided to put those items in his shop dumpster. What his 20 years experience and "applied knowledge" WON'T do for him is stand up in court or protect him from unbelievably large fines after the local inspectors get done digging in his dumpster.

Poor John. He's a good man with a lot of experience and a sterling reputation - the only thing that will protect him from falling between the cracks is having TCLP test results on file and keeping good records in his office. Its a one-time test – unless John changes paint lines. Which one is cheaper….. the price of a TCLP test or a EPA fine?

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