Defective Design of Recycled Safety-Kleen 105 Solvent
The recycled Safety-Kleen 105 Solvent is defective, for at least two reasons:
First, it contains high levels of toxic and carcinogenic chlorinated solvents which do not exist in virgin mineral spirits. Indeed, toxic chlorinated compounds accumulate and concentrate in the solvent as these toxic chemicals are introduced into the solvent stream by automotive customers at a rate greater than they are removed by carry-off and evaporation.
Second, the benzene content of the recycled solvent is substantially greater than the benzene content of virgin mineral spirits, due to introduction of benzene-containing gasoline into the solvent by customers.
The Safety-Kleen 105 Solvent Recycling Process
Safety-Kleen collects used Safety-Kleen 105 Solvent from its California customers and supplies them with recycled solvent. The used solvent is transported to the local service center, where it is put in a storage tank with used solvent from other customers. The solvent is then pumped into a tanker truck and shipped to Safety-Kleen's recycle center in Reedley, California.
At the recycle center, the used solvent is pumped into a settling tank, where water, dirt and heavy oils settle to the bottom of the tank and are removed. The rest of the material is pumped into a crude evaporator. As the evaporator is heated in a vacuum, volatile chemicals evaporate, rise, and go into a condensation unit where they cool and re-condense. The first components to evaporate are low-boiling aromatics, including benzene. When benzene recondenses on the other side of the column it could be extracted from the solvent by various means, but Safety-Kleen does not extract benzene or any of the other toxic contaminants of the product. Safety-Kleen just continues heating the liquid in the evaporator until all the volatile components evaporate and recondense. The recondensed material, which is called recycled solvent (and improperly called "clean" solvent) is then delivered to customers.
The process continues on and on in what has been described as a "closed-loop" system. However, not all of the solvent or its carcinogenic contaminants remains in the "closed-loop" system." Unfortunately, large amounts of the solvent and its carcinogenic components is inhaled into the lungs of operators of the parts washer machines and is absorbed through their skin into their bloodstream.
Defective Design of the Safety-Kleen Recycling Process
Due to the removal of water and sediment from the used solvent, toxic volatile organic compounds are more concentrated in the recycled solvent than in the used solvent. Additionally, high-boiling chlorinated solvents accumulate as they contaminate the product from further customer use. Thus, it is paradoxical that recycled ("clean") Safety-Kleen solvent is actually more toxic than the used ("dirty") solvent. Safety-Kleen's recycling process creates this anomaly as the result of major design defects.
In the early 1990s, Paul Dittmar, Safety-Kleen's Product and Process Development Manager, was assigned the task of determining the extent of the solvent contamination problem and identifying remedial technologies. In a memo addressed to the company's general counsel, Mr. Dittmar concluded that the solvent contamination problem was a major problem. He determined that a number of different technologies existed to resolve the problem, but that the best and simplest technology was fractional distillation -- technology which has been used to refine crude oil since the turn of the century.
Mr. Dittmar determined that the use of such technology would totally eliminate benzene from the recycled product and reduce the chlorinated content of the solvent by 90%. Mr. Dittmar, who is not only a chemist but also holds a Masters Degree in Business Administration, then proceeded to determine the cost of implementing fractional distillation technology at Safety-Kleen's domestic recycling centers. He determined that the cost of installation of the fractional distillation equipment would only be about $1 million for each of the company's half-dozen recycling facilities and that the additional cost of processing the solvent would be about 2 to 4 cents per gallon.
Although Safety-Kleen was aware that its recycling process was defective and that it could be easily remedied for a capital expenditure of $1 million for each of its half-dozen recycling facilities (about ½ of one percent of its annual gross revenues) and a cost of about 3 cents per gallon (which could easily have been passed on to its customers), Safety-Kleen did not install fractional distillation equipment at its recycle centers.
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