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EPA & OSHA: Common Misconceptions, Part 2

Jan 1, 2005 12:00 AM


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"I can throw away my used shop towels or cleaning pads."

Fact: Cleaning solvents are the most common hazardous waste products generated by small printers. Because the solvent is typically used with a shop towel, cotton pad or press cleanup mat, these wastes also can be classified as hazardous. All states have adopted a policy for reusable shop towels that lets users avoid classifying the towels as hazardous waste if a policy is followed. While requirements vary by state, users generally can't saturate towels with solvent, are required to keep towels in closed containers, and must have a contract with a launderer under which the launderer uses its own truck to pick up and return the towels. Some states require the containers to be labeled, and at least one requires notification.

Did you know? If solvent is present, disposable towels can't simply be thrown away as trash—they must be collected and handled as a hazardous waste. EPA has a proposed regulation that will address both reusable and disposable towels. Assuming the regulation is finalized as proposed, this means that disposable towels can be thrown away without violating any regulations—if the towels meet certain requirements, such as the amount of solvents on them and the absence of certain EPA-identified solvents.

"I can dump my waste fountain solution or camera waste down the drain. No one ever told me I couldn't, and besides, my salesman says it's biodegradable."

Fact: Printers are responsible for all wastes generated, even wastewater discharges. If the printer discharges wastewater to the drain, the local sewer authority must be contacted to determine whether the waste is acceptable. Permission must be obtained prior to discharging. The local sewer authority will determine what is acceptable. Most sewer authorities have a "sewer code" that sets the limits regarding the types and concentrations of pollutants acceptable for treatment.

Permission forms can include a letter from the pretreatment coordinator, test data indicating the effluent meets the sewer code limits, or a discharge permit. Some states and local sewer authorities require their industrial dischargers —which includes all printers, regardless of size—to obtain a wastewater discharge permit.

If permission is granted to discharge wastewater to the sewer, then silver recovery is usually required for printers using film or silver-halide-based direct imaging plate systems to meet the silver discharge limit. If the printer has adopted a digital workflow and is directly imaging plates, many of these systems have developers that exceed a pH of 12.5, which makes them a hazardous waste. The plate effluents must be neutralized prior to discharge. The typical acceptable pH range set by sewer authorities is six to nine.

Under no circumstances can any industrial wastewater be discharged to a septic system. Septic systems are designed to treat sanitary wastes only.

Clearing the air


"EPA only regulates the big printers."

Fact: Because all sizes of printers are classified as manufacturers, virtually every EPA regulation applies. The degree in which the regulations apply depends on factors including geographical location and the thresholds set under each regulation. Also, many states and local government agencies directly regulate small printers.

The most common regulations that must be met include:

  • Clean Air Act | Regulates emissions of air pollutants. The most common air pollutants emitted by printers are volatile organic compounds (VOCs) and hazardous air pollutants (HAPs) which include inks, fountain solutions, coatings, varnishes, adhesives, blanket washes, plate cleaners, metering roller cleaners, other cleaning solvents, and ink jet and other digital ink systems.
  • Clean Water Act | Regulates discharges of industrial wastewater and contaminated stormwater. Under the stormwater regulations, all printers regardless of size, who own their own building or lease a standalone building must either complete and submit a "no exposure certification" or file for a stormwater discharge permit.
  • Resource Conservation and Recovery Act | Regulates hazardous waste, nonhazardous waste, universal waste and underground storage tanks. Most small printers are Conditionally Exempt Small Quantity Generators, which means they generate less than 220 lbs. (about half of a 55-gallon drum), or Small Quantity Generators, which means they generate more than 220 lbs. but less than 2,200 lbs. (about four to five 55-gallon drums) per month. The most common hazardous wastes generated by small printers are waste cleaning solvents.
  • Emergency Planning and Community Right-to-Know Act | Requires the reporting of releases of certain hazardous substances above the applicable reportable quantity, submission of annual inventory reports for materials stored above specific thresholds, and annual emission reports for a specific list of chemicals used about specific thresholds. While most small printers do not store or use enough chemicals to trigger reporting under these regulations, the threshold for lead under the Toxic Release Inventory reporting is only 100 lbs. If a printer is still melting and casting lead, then this threshold is easily exceeded, triggering the annual report, that is due every July 1.
  • Comprehensive Environmental Response Compensation and Liability Act (Supervened) | Regulates the cleanup of abandoned contaminated property. All parties who are identified as contributing waste, even if it was legal to dispose of it at the facility being cleaned up, are response for the cleanup costs associated with the contaminated property. Currently, there are about 25 small printers involved with the cleanup of a site in New Jersey called Pittsburgh Metals. Pittsburgh Metals recycled a variety of metals and each printer now involved had sent the company lead type and dross during the 1970s and 1980s. Each printer is facing a bill of at least $5,000 up to $50,000, depending upon how much lead and dross were shipped for recovery.

Don't overlook liquid automatic blanket wash waste
Have you evaluated your blanket wash waste lately? Many new presses feature automatic blanket washes. Because the waste blanket wash typically is hazardous, the amount being generated per month could change printers' status from Conditionally Exempt to Small Quantity and from Small Quantity to Large Quantity Generator. Printers who have overlooked increased blanket wash waste also could inadvertently fail to comply with the additional requirements of the next highest classification. Several printers have been inspected and given notices of violation.


Catching up on compliance issues
AMERICAN PRINTER is pleased to be the publication sponsor for the 10th annual National Environmental, Health and Safety Conference (NEHS) for the Graphic Communications Industries. The conference will be held March 6-8, 2005, at the Renaissance Tampa Hotel Intl.'s Plaza (Tampa, FL).

Major topics to be addressed include:

  • Establishing EHS policies.
  • Air permitting.
  • Common OSHA violations.
  • Recycling universal waste.
  • Ergonomics.
  • Facility security issues.
  • Establishing a safety culture.

The NEHS Conference is a combined effort of the Specialty Graphic Imaging Association (SGIA), Printing Industries of America/Graphic Arts Technical Foundation (PIA/GATF), Flexographic Technical Association (FTA), Gravure Association of America (GAA), and the National Association of Printing Ink Manufacturers (NAPIM).

For more information contact Jim Workman at (800) 910-4283 or see www.nehsconference.org.


Ergonomics: a print-specific program
In 2001, Congress halted the Occupational Safety and Health Administration (OSHA) of the U.S. Dept. of Labor's proposed ergonomic standard, prompting OSHA to work with associations such as GATF/PIA (Sewickley, PA) and SGIA (Fairfax, VA) to share best practices and industry knowledge. (See "Material handling: the bindery's best-kept secret," September 2002.) OSHA provided GATF/PIA with grant money to create The Ergonomics Training Program, which focuses on specific problems and solutions for the graphic-arts industry. The $79 kit, published this past September, includes "The Ergonomics Guidebook," a Leadership Guide, pocket cards, fact sheets, a CD-ROM and a video, "Work Smarter, Not Harder."

Most ergonomic solutions are practical, inexpensive methods of readjusting workstations or modifying behaviors to reduce risk of injury. The GATF guidebook walks managers and safety personnel from front-office tasks through postpress activities, suggesting ways to prevent injuries from contact stress, vibration, and awkward postures or motions. The video illustrates ergonomic concerns and simple actions for prevention as well as avoidance of stresses, strains and other physical problems that can develop over time.

For more information or to order The Ergonomics Training Program, call (800) 662-3916 or visit the online bookstore at gain.net.


Gary Jones has been manager, Environmental Health and Safety Affairs for PIA/GATF for more than 17 years. Contact him at (412) 741-6860 or garyjgatf@aol.com.

Part 1 | Part 2