Printing with a Cleaner, Greener Image Videoconference

Transcription

PERFORMANCE
National Satellite Videoconference
Produced by the
University of Wisconsin-Extension
Printers’
National
Environmental
Assistance
Center
PNEAC
FOUNDATION OF
on behalf of
Flexographic
Technical
Foundation
PERFORMANCE
Order Form For
PNEAC / FTA Videoconference
Materials
High Performance Flexo:
Printing with a Cleaner, Greener Image
The following materials will be available after the videoconference to support your further training needs:
Videotape of High Performance Flexo videoconference. Includes VHS tape of entire 4/27/00 national
videoconference (2-1/2 hours), complete with course notebook. Price is $25 prepaid.
I would like to order ___________ Videotape(s) @$25.00 each.
Total enclosed $______________
High-Performance Flexo Workshop Packet: Includes videotape with case studies and
supporting written materials to help a facilitator guide discussion about how the ideas presented in the
case studies can be applied at participants= companies. An excellent resource for in-house
discussions/workshops at flexo printing companies. Price is $25 prepaid.
I would like to order ___________ Workshop Packet(s) @$25.00 each.
Name:__________________________________________________________________________
Organization:____________________________________________________________________
Street Address:___________________________________________________________________
City, State , Zip Code:_____________________________________________________________
Payment must accompany order. All orders will be shipped at the lowest U.S. Postal Service
rate unless payment is included for other shipping method. All foreign orders must add shipping.
Payment must be in U.S. funds. Make check payable to University of Wisconsin-Extension and mail to:
Kimberly Swanson
Solid & Hazardous Waste Education Center
610 Langdon Street, Room 535
Madison, WI 53703
phone: 608-262-0910
fax: 608-262-6250
This Page is Blank
PERFORMANCE
Acknowledgements
Development of this national videoconference has been made possible by the support
from the following sources:
Grant funding to the Printers’ National Environmental Assistance Center from:
EPA Office of Enforcement and Compliance Assurance
EPA Design for the Environment (DfE) Program
EPA Air Pollution Distance Learning Network
Additional labor contributed by the University of Wisconsin-Extension’s
Cooperative Extension Distance Education Unit
Extensive assistance in developing, promoting and producing this program was graciously
provided by the Flexographic Technical Association (FTA).
Promotional support provided by the Illinois Waste Management and Research Center and
the Graphic Arts Technical Foundation.
National and Regional Co-Sponsors
The development, promotion and delivery of this program nationally was made possible
through the collaborative efforts of the following organizations:
Flexographic Technical Association
Graphic Arts Technical Foundation
Illinois Waste Management and Research Center
National Pollution Prevention Roundtable
Printing Industries of America
Printers’ National Environmental Assistance Center
Small Business Development Centers
State Small Business Ombudsmen and Assistance Centers
University of Wisconsin Solid and Hazardous Waste Education Center
U.S. Environmental Protection Agency
We would also like to thank all those organizations who generously allowed us to reprint
portions of their materials, factsheets, or other documentation for use in this packet.
Graphics Arts Technical Foundation (GATF)
Design for the Environment Program
Office of Pollution Prevention, Pesticides and Toxics
i
INDIVIDUAL CREDITS:
EPA Project Officers
Ginger Gotliffe and Tracy Back, OECA;
Karen Doerschug and Bill Hanson, DfE
Program Design and Management
Wayne Pferdehirt and Keith West,
PNEAC/SHWEC/UWEX;
Doreen Monteleone, FTA
Downlink Network and Logistics
Kimberly Swanson, PNEAC/SHWEC
Videoconference Producer
Jim Leser, UWEX
Course Notebook Development
Keith West and Robert Gifford,
PNEAC/SHWEC/UWEX;
Doreen Monteleone, FTA;
Karen Doerschug, EPA.
World Wide Web Promotions
Robert Gifford, PNEAC/SHWEC/UWEX;
Todd Schumacher, PNEAC/WMRC
Videoconference Technical Support
Jeff Finlay, Donna Anderson and
Bill Lawrence, UWEX
Instructional Design Advisor
Nadeen Thompson, UWEX
PERFORMANCE
ii
PERFORMANCE
Order Form For
PNEAC / FTA Videoconference
Materials
Printing with a Cleaner, Greener Image
The following materials will be available after the videoconference to support your further training needs:
Videotape of High Performance Flexo videoconference. Includes VHS tape of entire 4/27/00 national
videoconference (2-1/2 hours), complete with course notebook. Price is $25 prepaid.
I would like to order ___________ Videotape(s) @$25.00 each.
High-Performance Flexo Workshop Packet: Includes videotape with case studies and
supporting written materials to help a facilitator guide discussion about how the ideas presented in the
case studies can be applied at participants= companies. An excellent resource for in-house
discussions/workshops at flexo printing companies. Price is $25 prepaid.
I would like to order ___________ Workshop Packet(s) @$25.00 each.
Name:__________________________________________________________________________
Organization:____________________________________________________________________
Street Address:___________________________________________________________________
City, State , Zip Code:_____________________________________________________________
Payment must accompany order. All orders will be shipped at the lowest U.S. Postal Service
rate unless payment is included for other shipping method. All foreign orders must add shipping.
Payment must be in U.S. funds. Make check payable to University of Wisconsin-Extension and mail to:
Kimberly Swanson
610 Langdon Street, Room 535
Madison, WI 53703
phone: 608-262-0910
fax: 608-262-6250
This Page is Blank
PERFORMANCE
Acknowledgements
Development of this national videoconference has been made possible by the support
from the following sources:
Grant funding to the Printers’ National Environmental Assistance Center from:
EPA Office of Enforcement and Compliance Assurance
EPA Air Pollution Distance Learning Network
Additional labor contributed by the University of Wisconsin-Extension’s
Cooperative Extension Distance Education Unit
Extensive assistance in developing, promoting and producing this program was graciously
provided by the Flexographic Technical Association (FTA).
Promotional support provided by the Illinois Waste Management and Research Center and
the Graphic Arts Technical Foundation.
National and Regional Co-Sponsors
The development, promotion and delivery of this program nationally was made possible
through the collaborative efforts of the following organizations:
Graphic Arts Technical Foundation
Illinois Waste Management and Research Center
National Pollution Prevention Roundtable
Printing Industries of America
Printers’ National Environmental Assistance Center
Small Business Development Centers
State Small Business Ombudsmen and Assistance Centers
University of Wisconsin Solid and Hazardous Waste Education Center
We would also like to thank all those organizations who generously allowed us to reprint
portions of their materials, factsheets, or other documentation for use in this packet.
Graphics Arts Technical Foundation (GATF)
Design for the Environment Program
Office of Pollution Prevention, Pesticides and Toxics
i
INDIVIDUAL CREDITS:
EPA Project Officers
Ginger Gotliffe and Tracy Back, OECA;
Karen Doerschug and Bill Hanson, DfE
Program Design and Management
Wayne Pferdehirt and Keith West,
PNEAC/SHWEC/UWEX;
Doreen Monteleone, FTA
Downlink Network and Logistics
Kimberly Swanson, PNEAC/SHWEC
Videoconference Producer
Jim Leser, UWEX
Course Notebook Development
Keith West and Robert Gifford,
PNEAC/SHWEC/UWEX;
Doreen Monteleone, FTA;
Karen Doerschug, EPA.
World Wide Web Promotions
Robert Gifford, PNEAC/SHWEC/UWEX;
Todd Schumacher, PNEAC/WMRC
Videoconference Technical Support
Jeff Finlay, Donna Anderson and
Bill Lawrence, UWEX
Instructional Design Advisor
Nadeen Thompson, UWEX
PERFORMANCE
ii
Table of Contents
PERFORMANCE
I.
Program Goals and Agenda
II.
Speakers’ / Program Notes
· Doreen Monteleone, Environmental Issues: Land Mines or Leverage for
Improvements
· Ink Management / Inside Flexo Video
· Case Study: Highland Supply Corp.
· Wayne Pferdehirt: Solvents, Wipes and Towels: Issues and Choices
· Case Study: Anagram International, Inc.
· Jim O’Leary: Update on Management of Used Shop Towels and Wipes
· Flexo Platemaking: Making Sense of Current Choices
1.
Dan Owenby, Solvent & Aqueous Plate Processing
2.
Brad Taylor, Digitally-Imaged Plates
· Case Study: OEC Graphics, Inc.
III.
Supplementary Fact Sheets and Articles
IV.
Biographical Sketches of Presenters and Panelists
V.
Additional Sources of Information and Assistance
PHONE NUMBERS TO USE DURING THE PROGRAM
Live Question and Answer Period:
1-800-442-4613
Fax Number:
1-800-348-9529
iii
iv
Goals
PERFORMANCE
·
·
·
·
·
Review and explain environmental compliance issues that directly
affect flexo printers.
Explore how flexo printers are using innovative techniques and
recent technological advances to expand and improve their quality
while eliminating environmental headaches.
Reveal how flexo printers are decreasing hazardous waste costs,
improving indoor air quality, and reducing air permit problems by
cutting down on solvent use, changing ink systems and evaluating
their prepress technology.
Provide a guided investigation by flexo printing industry experts of
recent and future technological breakthroughs that can improve dayto-day business while at the same time enhancing the environmental
quality of operations.
Identify valuable contacts and resources for future information needs
and technical assistance.
Agenda
Printing With a Cleaner, Greener Image
(Times listed are Central Daylight Time)
9:00
Registration
9:15
Welcome and Introduction
Local Host
9:30
National Broadcast Begins
Welcome and Introductory Remarks
Michael McCabe , Deputy Administrator, US EPA
Bill Dowdell, President, FTA
Wayne Pferdehirt, Co-director, PNEAC
9:39
Environmental Issues: Land Mines or
Leverage for Improvements?
Doreen Monteleone, Director, Environmental Affairs, FTA
This overview explores the key environmental management
issues that flexographic printers should be aware of and how
these concerns can create either liabilities or opportunities to
improve overall business performance.
1-800-442-4613
Fax Number:
1-800-348-9529
I-1
9:49
PERFORMANCE
Ink Management
This session will concentrate on how important ink selection and
management are when it comes to successfully reducing air
emissions and hazardous wastes at flexo printing facilities.
Footage will feature excerpts from Inside Flexo: A Cleaner Run
for the Money, produced by US EPA DfE Program.
Case Study: Highland Supply Company, Highland, IL
Get a glimpse into one flexographic printer’s journey into
successfully converting to water-based inks. This practical, realworld case study will give participants a realistic view of the
challenges involved in making the switch.
10:08 Pause for Developing Questions by Fax or Phone
A brief pause will allow downlink sites to develop questions on
the preceding sessions that can be faxed or phoned into the
studio for the panel’s response.
10:10 Live Question-and-Answer Session
Participants can use this opportunity to ask follow-up questions
of Mike Klemme, Highland Supply Company; Doreen
Monteleone, FTA; and Keith West, PNEAC. The panel will also
include Dave Argent of Progressive Ink and Karen Doerschug of
US EPA DfE.
10:24 Solvents, Wipes and Towels
Wayne Pferdehirt, Co-director, PNEAC
The selection and management of solvents along with the choice
and management of shop towels or wipes is an important
environmental concern. This session will take a look at the key
issues every flexo printer should consider in order to make an
informed decision.
10:32 Case Study: Anagram, Inc., Eden Prairie, MN
Anagram, Inc. is a flexographic printer of Mylar balloons. Go
inside the plant and see how the company improved the
management of its solvent-based inks and cleanup solvents,
drastically reducing emissions and hazardous wastes, while at
the same time saving money.
1-800-442-4613
Fax Number:
1-800-348-9529
I-2
PERFORMANCE
10:43 Update on Regulation and Management of Used Shop Towels
and Wipes
Jim O’Leary, Senior Policy Analyst, US EPA
This is the perfect opportunity to get the latest news on the US
EPA’s efforts to develop national guidelines on the management
of used shop towels and wipes - an issue that flexo printers are
faced with daily. Jim O’Leary leads the US EPA’s drive to
evaluate the need for national policy and regulations on this
issue. He will present the up-to-the-minute developments
regarding recent and pending regulatory changes and how they
are likely to affect your day-to-day operations.
10:57 Pause for Developing Questions by Phone or Fax
the preceding sessions that can be faxed or phoned in to the
11:01 Question-and-Answer Session/Discussion
of industry experts including Sigmond Singramdoo, Anagram,
Inc.; Jim O’Leary, US EPA; Dave Argent, Progressive Ink;
Doreen Monteleone, FTA; and Wayne Pferdehirt, PNEAC.
11:16 Flexo Platemaking: Making Sense of Current Choices
This informative overview of flexo platemaking will reflect on
the relative benefits of the technology with a special eye toward
the impact on emissions and wastes. Some of the methods
considered:
·
·
·
Solvent-washed Plates: Dan Owenby, Chemence
Water-washed Plates: Dan Owenby
Digitally-imaged Plates: Brad Taylor, DuPont
11:31 Case Study: OEC Graphics, Oskosh, WI
This progressive flexo platemaker is developing digitally-imaged
plates for day-to-day operations. See how he has helped flexo
printers to improve quality and performance while reducing
photochemical and film wastes.
1-800-442-4613
Fax Number:
1-800-348-9529
I-3
11:38 Pause for Developing Questions by Phone or Fax
PERFORMANCE
the preceding sessions that can be faxed or phoned in to the
11:40 Question-and-Answer Session/Discussion
of panelists Tom Underwood, OEC Graphics; Dan Owenby,
Chemence; Brad Taylor, DuPont; Doreen Monteleone, FTA; and
Wayne Pferdehirt, PNEAC.
11:55 Program Wrap-up and Evaluation
12:00 National Broadcast will end at Noon, Central Time.
Local follow-up presentations and discussion where scheduled.
1-800-442-4613
Fax Number:
1-800-348-9529
I-4
II.
PERFORMANCE
Speakers’ / Program Notes
Doreen Monteleone
Environmental Issues: Land Mines or Leverage for Improvements . . . . . II-3
Ink Management / Inside Flexo Video . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-9
Case Study: Highland Supply Corp. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-11
Fact Sheet: Reducing VOCs in Flexography: Highland Supply Corp., DfE . . . . .II-13
Wayne Pferdehirt
Solvents, Wipes and Towels: Issues and Choices . . . . . . . . . . . . . . . . . . II-19
Case Study: Anagram International, Inc. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-23
Fact Sheet: Anagram Saves Over $68,000 through Waste Reduction, MNTAP . . II-25
Jim O’Leary
Update on Management of Used Shop Towels and Wipes . . . . . . . . . . . . . II-29
Flexo Platemaking: Making Sense of Current Choices
1.
Dan Owenby, Solvent & Aqueous Plate Processing. . . . . II-35
2.
Brad Taylor, Digitally-Imaged Plates . . . . . . . . . . . . . . . II-43
Case Study: OEC Graphics, Inc. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-47
1-800-442-4613
Fax Number:
1-800-348-9529
II - 1
II - 2
Environmental Issues:
Land Mines or Leverage for Improvement?
Doreen M. Monteleone, Ph.D.
Director of Environmental Affairs
Regulations
•
•
•
•
Clean Air Act Amendments of 1990
Clean Water Act
Resource Conservation and Recovery Act
Comprehensive Environmental Response,
Compensation and Liability Act
• Emergency Planning and Community Rightto-Know
• Safe Drinking Water Act
• Toxic Substances Control Act
Different
Ink
Systems
Different
Printers
Different
Presses
Different
Substrates
II - 3
Waste Can be Reduced Almost
Anywhere in a Print Shop
Where Do I Begin?
• Do a facility walk through.
• Develop a plan to:
– Reduce VOC emissions.
– Reduce waste.
– Improve environment inside
plant and outside.
– Save money.
• Use environmental
requirements as leverage for
change.
Environmental Compliance
• Know your requirements.
• All environmental regulations have thresholds
which mandate action or dictate
requirements.
• Compliance begins with “lowest”
governmental agency’s requirements.
II - 4
Basic Principles of Compliance
Permit Requirements
Control Requirements
Reduce pollutants as close to the source as
possible.
Reducing VOCs
• Evaluate ink
alternatives.
• Evaluate your
solvent use.
Using Solvent Inks
• Lowest VOC content possible - consult with
ink manufacturer.
• Solvent reduction techniques - press
operation and clean-up.
II - 5
Converting to Water-Based Inks
• More compatible
with porous
substrates.
• Use of corona
treater on films.
• Wastewater
management.
Converting to UV Inks
• UV inks emit virtually no VOCs.
• Technology has not been perfected in wide
web operations.
• Continuing research.
Printing Plates
• Perc alternative solvents (PASs).
• Water washable flexo plates.
• Digitally imaged flexo plates.
II - 6
Used Shop Towels
• State policies
dictate if/when
used shop towels
are considered
hazardous waste.
• A national policy
is being
developed.
Carpe Diem
(Seize the Day)
• Comply with regulations, print a quality
product, improve the environment, increase
your efficiency and save money.
• It’s never too late to begin.
• Keep it a process of continual improvement.
II - 7
II - 8
Inside Flexo: Ink Management
PERFORMANCE
Notes:
II - 9
PERFORMANCE
This portion of the videoconference was prepared using segments from Inside Flexo: A Cleaner Run for the Money,
a video produced through funding from the US EPA’s Design for the Environment (DfE) Flexography Project. For
a free copy of the entire 19-minute video, please contact:
Pollution Prevention Information Clearinghouse (PPIC)
US EPA
401 M Street SW (7407)
Washington DC 20460
Ph: 202-260-1023
Fax: 202-260-4359
e-mail: [email protected]
Please visit the DfE web site: www.epa.gov/dfe
II - 10
Case Study: Highland Supply Corp.
Notes:
PERFORMANCE
II - 11
Case Study: Highland Supply Corp.
Notes Continued:
PERFORMANCE
II - 12
A Cooperative Project
between the
U.S. Environmental
Protection Agency
and the Printing Trade
Associations
Nationwide
March 1997
FOR
THE
ENVIRONMENT
Flexography Case Study 1
EPA 744-F-96-013
Reducing VOCs in
Flexography
Case Study Highlights
+
+
+
+
+
+
+
Highland Supply Corporation:
Company Background
Using Water-Based Inks
Environmental Benefits
Economic Benefits
Other Benefits
Commitment From Management and
Employees
About the DfE Flexography Project
Also in this case study:
+
+
This case study highlights the experience of
one wide-web flexographic printer that
successfully reduced volatile organic
compound (VOC) emissions and hazardous
waste by switching inks. While every facility is
unique, it is hoped that the information
provided can help even very different
flexographic printers. In particular, this case
study shows:
+
how a water-based ink system and
water-based cleaning procedure can
reduce VOC emissions, hazardous
waste, operating costs, and worker
health risks
+
how the printer overcame challenges to
print successfully with water-based inks
II -13
Highland Supply Corporation:
Facility Profile
Eliminating Solvents in Other Areas
of the Facility
DfE Flexography Case Study 1: Reducing VOCs in Flexography
Facility Profile
Highland Supply Corporation,
Highland, IL
p. 2 of 5
Company Background
Highland Supply Corporation (HSC), at its Highland,
Illinois facilities, manufactures decorative packaging
products for the floral industry. Its product line includes
printed and laminated films, foils, and paper. In 1988,
HSC made it company policy to reduce or eliminate air
emissions and hazardous waste generation. HSC focused
on reducing one of its primary emissions, VOCs, for two
reasons. First, HSC was aware that VOCs can be
harmful to worker health and the environment. Second,
HSC predicted that federal and state environmental
regulations for VOCs would become more stringent in
the future.
Main Product
Decorative packaging for the floral
industry
The company found that its solvent-based inks (50%
VOCs by weight) were the primary source of its VOC
emissions. To reduce these emissions, the company
initially looked into installing air pollution control
equipment such as solvent recovery or oxidizers. But if
future regulations were to require further VOC
reduction, these units could not be easily adapted. In
addition, the electricity and natural gas required to run
them would be expensive. HSC decided instead to
reduce its VOC emissions by replacing its solvent-based
ink system with a water based system.
Plant Size
50,000 square feet
Water-Based Ink System
No. of Employees
150 to 250 (depending upon the season)
Output
125 to 150 million linear feet annually
from
flexographic presses
PrintingPresses
Five flexographic and ten rotogravure
presses
Primary Ink
Water-based ink (100% of product sales)
Primary Substrate
Polypropylene (85% of product sales)
Type of Printing
Reverse and surface; Line and process
work
In 1989, HSC began using a new water-based ink on two
rotogravure presses. The following year, water-based
inks were tested on the flexographic presses. By 1991,
HSC was using the water-based ink on all its presses.
Water-based inks now account for 100% of the total ink
used in the facility.
When HSC first used the water-based ink system, the
company encountered a number of new challenges,
including some adverse customer response to the print
quality of the inks. However, HSC was dedicated to the
system and conducted many hours of research and
testing. The company modified presses and changed
internal color standards. Some other challenges HSC
encountered, and the corresponding solutions, are listed
below:
II -14
p. 2 of 5
Challenges Encountered with the
Water-based Ink
HSC’s Solution
Drying of the ink was incomplete
Improved drying systems by lowering
temperature and increasing air flow rates
Water fastness was insufficient
Continuously improved ink formulations and
additives
Print quality was variable
Monitored the pH and viscosity of the inks
Ink adhesion was insufficient
Installed a corona treater
Printing metallic inks was difficult
Continuously improved ink formulations and
additives
Printing UPC symbols was difficult
Printed the white UPC symbol background
with a water-based, high density ink
Cleaning the anilox rolls and plates
was difficult because the water-based
inks would not resolubilize
Installed an ultrasonic cleaner; switched to a
citrus-based cleaner; allowed more time for
cleaning
Environmental Benefits
VOC EMISSIONS WERE DRAMATICALLY
REDUCED.
In 1989, HSC’s water-based ink contained 10% to 12% VOCs
by weight. By 1996, the average VOC content for water-based
ink formulas was down to 0.71% VOCs by weight, according
to HSC. The few VOCs remaining in the water-based inks are
from dispersions and surfactants. HSC recently bought new
equipment to use in creating its own VOC-free dispersions.
This reduction in the VOC content of the inks, along with the
elimination of solvents in other areas of the facility, had a
dramatic effect on HSC’s total VOC emissions. The following
graph shows the company’s annual VOC emissions for 1989,
1991, 1993, 1995, and 1996, as reported to the Illinois
Environmental Protection Agency.
HAZARDOUS WASTE WAS ELIMINATED.
The water-based ink system contributed to another important
benefit. HSC reports that it completely eliminated hazardous
waste from waste ink and cleaning operations in 1994, 1995,
and 1996. HSC generates a small amount of nonhazardous
solid waste from disposable cleaning wipes.
II -15
Eliminating Solvents In
Other Areas
Highland Supply
Corporation has stopped
using traditional solvents in
adhesive, cleaning, and
maintenance. For example:
In 1992, HSC installed an
ultrasonic cleaner to clean
anilox and plate cylinders.
In 1993, HSC replaced other
traditional solvent-based
cleaners (methyl ehtyl
ketone, methyl isobutyl
ketone, and toluene) with a
mixture of water and
d-limonene (a citrus-based
cleaner).
p. 2 of 5
RECYCLING WASTE INK.
HSC also reduced the amount of total waste generated by recycling its water-based ink. When the
company first used water-based inks, the waste ink was solidified and sent to a landfill under a
nonhazardous waste permit. Recycling of the water-based inks began in 1992. By 1995, HSC
recycled 99% of its waste water-based inks. Press return ink is stored in a separate container
labeled with the formula ID number until it can be blended back into virgin ink of the same color.
New colors can also be made, and hard-to-match waste ink can be made into dark green and
black inks. HSC also added a computer with a colorimeter and scanner to facilitate better
blending of the recycled inks.
Economic Benefits
REDUCED INK COSTS. HSC's new water-based inks cost less per unit area printed. This is
because HSC's water-based inks have a higher ink mileage than the previously-used
solvent-based inks.
HAZARDOUS WASTE DISPOSAL COSTS ELIMINATED. Since hazardous waste is no
longer generated, HSC spends very little on disposal costs. Solid nonhazardous waste disposal
costs totaled less than $1,000 in 1996.
LABOR HOURS SAVED. When HSC switched to water-based inks, some permitting
requirements were eliminated. HSC avoided the labor costs needed to meet these requirements. If
HSC was still using solvent-based inks today, more than 100 tons of VOCs would be emitted
each year, making HSC a "major source" under Title V of the 1990 Clean Air Act Amendments.
Since HSC is not a "major source," it has avoided spending significant labor hours to prepare and
file initial permit applications, and will save additional labor hours every year in years to come.
In addition, HSC reduced flammable liquid usage below Occupational Safety and Health
Administration (OSHA) reporting thresholds (Process Safety Management, OSHA 1910:119).
Being exempt from this regulation saves HSC significant labor hours in the first year and
additional labor hours in subsequent years.
II -16
p. 2 of 5
Other Benefits
Additional benefits that improve HSC's safety, working conditions, marketing, and public image
include:
+
Eliminated health risks related to VOC exposure
+
Reduced fire hazard
+
Eliminated need for expensive explosion-proof storage
+
Improved public image and community relations
Commitment From Management and Employees
Comapny-wide commitment was essential to the success of HSC's switch to water-based inks. To
strengthen this commitment, management integrated recycling and pollution prevention standards
into the job descriptions for each employee, implemented aggressive health and safety programs,
and conducted an internal pollution prevention assessment.
With a commitment from management and continuous improvement in the printing process, your
company can also realize the benefits of reducing VOC emissions and hazardous waste.
About the Design for the Environment Flexography Project
The goal of the Design for the Environment (DfE) Flexography Project is to provide
flexographers with information that can help them design an operation which is more
environmentally sound, safer for workers, and more cost effective.
The partners of the DfE Flexography Project, in a voluntary cooperative effort, are evaluating
three different ink technologies: solvent, water-based, and UV-cured. Information is being
gathered on the performance, cost, and health and environmental risk trade-offs of several inks
within each technology.
In addition to the Flexography Project, similar DfE projects are currently underway with both the
screen printing and lithography industries.
To obtain additional copies of this or other bulletins and case studies, or for more information
about EPA's Design for the Environment Program, contact:
Pollution Prevention Information Clearinghouse, (PPIC)
401 M Street, SW (7409)
Washington, DC 20460
Phone: (202) 260-1023
Fax: (202) 260-4659
E-mail: [email protected]
Direct questions or problems regarding this page to: [email protected]
II -17
II - 18
Solvents, Wipes and Towels:
Issues and Choices
Wayne Pferdehirt
Co-Director, PNEAC
Problems You Want to Avoid
• Hazardous Waste Costs and Liabilities
• Expansion Restricted by Emissions
Reaching Permit Limits
• Compliance Fines
• Unnecessary Production Costs
Questions
• What Do Regulations Require?
• How to Minimize Costs?
– Purchase
– Handling and Use
– Disposal
• How to Best Manage Risk?
II - 19
Solvent Selection
• Inks and Solvents Work as System
• Will Used Solvent be Hazardous
Waste?
• What are Emissions and Effects on
Permits?
• Storage Requirements?
• Worker Health Impacts?
Comparing Alternative Solvents
•
•
•
•
•
VOCs
HAPs
Vapor Pressure
Flash Point
Hazardous Constituents
Reducing Solvent Costs and
Wastes
• Control Purchasing, Storage and Distribution
• Minimize Number of Solvents Used
• Modify Cleaning Procedures
– Reduce amount used
– Reduce required frequency of cleaning
• Keep All Containers Covered
• Look for Reuse & Recycling Opportunities
II - 20
Comparing Disposable Wipes
and Reusable Towels
• Costs
• Performance
• Regulatory Requirements for
Managing Used Towels and Wipes
• Liabilities
• Local Circumstances
– Disposal options
– Laundry services
Reusable Towels
• Minimize Your Liability from Damages
at Landfill
• Use Reputable, Properly Permitted
Laundry Service
• Be Aware of State/Local Requirements
for Managing Used Towels
• May Need Special Arrangements with
Laundry to Ensure Cleanliness of
Towels
Disposable Wipes
• Offer Convenience and Purity (from lint and
contamination from previous uses)
• Before Sending to Landfill, Be Sure to Know:
–
–
–
–
Local regulations
Solvent(s) used
Nature of other residues on wipes
Names and quality of landfill facilities used by
hauler
• Consider Other Disposal Options to Reduce
Liabilities
– fuel blender
– Municipal incinerator
II - 21
Ingredients for Successful Change
• Expressed Priority and
Commitment by Top
Management
• Broad Teamwork in Identifying
Problems and Opportunities
• Training in Use of New Materials
and Practices
• What Gets Measured Gets
Changed
Charting a Path
• What Does the Law Require?
• What Can I Do to Best Manage
Potential Risks?
• Start at the Source: Ink and Solvent
Selection and Use
II - 22
Case Study: Anagram International, Inc.
PERFORMANCE
Notes:
II -23
Case Study: Anagram International, Inc.
PERFORMANCE
Notes Continued:
II -24
Printing
Environmental Technology
FACT SHEET
Anagram Saves Over $68,600 through Waste Reduction
Reducing Solvent and Ink Purchases and Waste
in the Flexographic Printing Industry
Intern Project Summary, Minnesota Technical Assistance Program, University of Minnesota
Intern Project Date: Summer 1996
Intern: Qui Hong, University of Minnesota, Chemical Engineering Senior
Company: Anagram International, Inc., Eden Prairie, Minnesota
Project: Reduce solvent and ink waste
Results: Waste reduced by 30%
Process Background
Anagram International, Inc. manufactures products made of synthetically-based films. Their products
include Mylar7 balloons, self-sealing valves, consumer gift packaging and industrial packaging.
Anagram employs approximately 400 people and operates 24 hours a day, seven days a week.
Anagram uses three six-color and one eight-color flexographic printing presses. Flexographic printing
uses flexible raised-image printing plates and rapid-drying fluid inks to carry out direct rotary printing.
Solvent is used to thin inks, clean the presses and wipe up ink spills. Used solvent is sent out for
recycling then purchased back at less than virgin-solvent costs. The recycled solvent is used primarily to
clean the printing decks.
Incentives for Change
The printing manager established a goal to reduce hazardous waste 25 percent by the end of 1996 as a
cost cutting effort.
Anagram=s printing operation generated most of their hazardous waste. At the start of the intern
project, they generated 34 drums of hazardous waste a month. Waste from cleaning the printing decks
made up about 75 percent (1,400 gallons) of the total.
II - 25
MnTAP Fact Sheet: Anagram Saves Over $68,600 through Waste Reduction
p. 2 of 4
Options Implemented
Multiple Stage Cleaning
Every printing press had five to six buckets of pump-wash solvent nearby to clean each press' six to eight
printing decks. One of these buckets would be randomly selected to flush the ink from the decks.
Press cleaning was modified to an organized three-stage cleaning process.
Stage 1: Majority of the ink is removed using dirty solvent.
Stage 2: Ink, left after the first stage, is removed using partially dirty solvent.
Stage 3: Any remaining ink is removed by the cleanest solvent.
Using all three stages takes an extra four to six minutes per deck, but often using only the first two stages
cleans sufficiently.
When the solvent in the stage-1 bucket becomes too thick, it is emptied. Solvent is replenished by the
subsequent stage (i.e., the solvent used as stage 2 becomes stage 1) and stage 3 is filled with fresh
solvent. Solvent use decreases because the solvent is used longer before it is discarded.
To make the system easy, each printing press has a cart with three buckets that are clearly labeled so
employees know when each bucket should be used. Employee training on using the system and on its
benefits, along with making the system easy to use were essential to the success of multiple-stage
cleaning.
Savings: $28,200 per year in solvent purchases and disposal costs. Reduces solvent waste by almost 120
drums per year.
Shutdown Procedure
During press shutdown, the ink pumps are placed in individual buckets of pump-wash solvent to prevent
any solvent or ink from drying inside them. Fresh solvent was usually obtained to soak the pumps. Now,
solvent buckets are dedicated for press shutdown and are not used for cleaning. The solvent remains
fairly clean and is used indefinitely. Buckets of pump wash, designated by the signs that say APump wash
used only to soak pumps@ are placed by each printing press and the press workers are trained on their
proper use.
Savings: Included in multiple-stage cleaning savings.
Deck Draining
Before a printing deck is cleaned, the ink from the ink chamber and hoses is drained into a bucket.
Because of the layout of the pump and hoses, about two pounds of ink remains in the hoses of the
bottom printing decks. When solvent is flushed through the system, more solvent is needed to clean out
this wasted ink.
Before cleaning, the ink is recovered by elevating the entrances to the hoses for ten seconds.
Savings: $15,400 per year in ink purchases.
II - 26
p. 3 of 4
Printing Deck Hose Length and Size
Hoses between the ink pumps and the printing decks varied in length and often were longer than
necessary, causing slack in the lines. During a color change, ink was lost when it did not drain
completely. The intern determined the optimal hose length for each level of the printing decks. Now, a
sign that lists the correct lengths and a ruler are located by the extra hose so employees can easily cut the
correct lengths.
Savings: Not determined.
Recycled Solvent for Thinning Ink
Anagram sends out their used solvent for recycling and purchases back the recycled solvent for use as
press wash. Recycled solvent is now combined with virgin solvent (1:4) to thin the inks and it has no
affect on printing quality.
Savings: $16,800 a year in virgin solvent purchases.
Recycled Ink
Experiments determined that contaminated ink, which does not contain any white ink, can be reworked
into the black ink. Contaminated ink is now added at ten percent to the black ink without affecting
quality.
Savings: $8,200 a year in ink purchases and disposal costs.
Additional Options
Floor Washings
Anagram combines their waste from washing the floor with ink and solvent waste. Separating out the
floor washings (2-3 drums per month) may permit them to be sewered. Anagram is reviewing this with
their wastewater treatment authority.
Savings: Not determined.
On-site Solvent Distillation
An on-site solvent recovery system was investigated. The system must use a vacuum in order to distill
nitrocellulose, an ink component, which can be explosive when dry. The use of a solvent recovery
system would eliminate the purchase of recycled solvent and would reduce the amount of waste being
shipped out by over 75 percent.
Potential savings: $29,100 annually in recycled solvent purchases and disposal costs. Would reduce
hazardous waste by 240 drums per year.
II - 27
p. 4 of 4
Results
Implementing the options identified above has reduced Anagram=s hazardous waste by 30 percent. This
will save them over $68,600 a year. Greater savings are possible if additional options are implemented.
Anagram has completed other hazardous waste reduction projects as well. In eight months, they
exceeded their goal - ahead of schedule - and reduced hazardous waste by 50 percent.
More Information
MnTAP has a variety of technical assistance services available to help Minnesota companies to manage
and reduce their industrial waste. If you would like assistance or more information about MnTAP's
Intern Program, call 612/627-4646 or 800/247-0015 from greater Minnesota.
Reasonable effort has been made to review and verify information in this document. Neither PNEAC and its partners, nor the
technical reviewers and their agencies, assume responsibility for completeness and accuracy of the information, or its
interpretation. The reader is responsible for making the appropriate decisions with respect to their operation, specific
materials employed, work practices, equipment and regulatory obligations. It is imperative to verify current applicable
regulatory requirements with state and/or local regulatory agencies.
II - 28
UPDATE ON MANAGEMENT OF
USED SHOP TOWELS AND WIPES
Jim O’Leary
Senior Policy Analyst
US Environmental Protection Agency
Goals
• Describe current federal regulations
• Give update on EPA efforts to revise
regulations
Current Federal Regulation
• Wipe or towel can be classified as
hazardous waste if solvent or residue is
hazardous
• Hazardous
– If it exhibits a hazardous characteristic
(e.g., toxic, flammable)
– If waste is a “listed waste”
II - 29
EPA Deferred Interpretation to
Regions and States
• EPA regions and nearly all states
subject disposable wipes to regulation
as hazardous waste
• Some regions and most states have
allowed exemption of reusable shop
towels from regulation as hazardous
waste
Use of Towels and Wipes by Printers
• Typically use large numbers of
towels or wipes
• Relatively large amounts of solvent
per towel/wipe
• Many use solvents with flammable
or toxic constituents
• Greater use of reusable towels than
disposable wipes
Amount of Solvent
in Used Towels
• Two to three times the weight of towel
• Typically 40 to 50 grams per towel
II - 30
Reasons Argued for Exempting
Reusable Towels
• Materials do not pose a risk to human
health or environment
• Materials were being recycled
Key Question:
Do solvent-contaminated towels and
wipes pose unacceptable risks to
human health or environment?
• How should materials be managed?
– At point of generation
– During transportation
– At handling facilities
• Should we be more concerned about
certain handling practices over others?
Two Options Being Considered
by EPA
• Option One: Not Considered
Hazardous if
– Stored in covered containers
– Transported in closed, labeled containers
– No free liquids
– Shipped to industrial laundry or permitted
solid waste facility
II - 31
by EPA
• Option Two: Not Considered
Hazardous if
– Stored in covered containers
– Transported in closed, labeled containers
– No free liquids
and
by EPA
• Option Two (continued)
One of the Following Management Options
Must be Used:
– Disposed at permitted landfill
• Must be dry (less than 5 grams)
• May not contain solvents on a list to be determined
– Recycled at permitted industrial laundry
• Laundry to have specified weight limit on solventcontaminated towels received per year
or
• Laundry must assure that towels are dry (less than 5
grams solvent)
continued
by EPA
• Additional Management Options
Under Option Two
– Industrial dry cleaner
• Permitted under CWA
or
• Zero discharger
– Permitted municipal waste combustor
– Safe solvent recycling facility
– State-approved facility
II - 32
Draft Language of Options being Evaluated by EPA
1. Industrial towels, wipes and rags that contain hazardous
solvents are not hazardous wastes subject to regulation
under 40 CFR parts 260, 261 to 266, 268 and 270 so long as
A. These materials are stored in covered containers at
the generation site, and if transported off-site, these
materials are stored in closed containers labeled
“solvent-contaminated shop towels” or “solventcontaminated wipes” or “solvent-contaminated rags”,
B. Prior to being transported off-site, these materials do
not release any liquid when wrung, and
C. The materials go to an industrial laundry or to a
facility allowed by state law to accept solid waste.
2. Industrial towels, wipes and rags that contain hazardous
solvents are not hazardous wastes subject to regulation
under 40 CFR parts 260, 261 to 266, 268 and 270 so long as
A. These materials are stored in covered containers at
the generation site, and if transported off-site, these
materials are stored in closed containers labeled
“solvent-contaminated shop towels” or “solventcontaminated wipes” or “solvent-contaminated rags”,
B. Prior to being transported off-site, these materials do
not release any liquid when wrung, and
(continued)
Option 2 continued:
C. These materials are either:
1. disposed of in a MSWLF or a Subtitle C landfill
after they are shown to be dry (less than 5 grams
per wipe, rag, or towel, on average) and they do
not contain one of the following solvents found in
Table X (to be determined),
2. recycled in an industrial laundry subject to CWA
requirements, and the industrial laundry either
receives less than XX lbs (to be determined) of
solvent-contaminated shop towels annually, or (2)
assures that the shop towels are dry (less than
5 grams of solvent) before entering the laundering
process, (continued)
II - 33
Option 2 continued:
3. managed in an industrial dry cleaner subject to
CWA requirements, or is a zero discharger of
dry cleaning waste water pollutants,
4. managed in a municipal waste combuster subject
to CAA requirements,
5. managed in a facility safely recycling the hazardous
solvents, or
6. managed in state-approved facility.
Anticipated Effects on
Operations on Printers
• No free liquids
• Shipment in marked, enclosed
containers
• Laundries will act to reduce amount of
solvent in incoming towels
– Centrifuging/wringing at laundry
– Requiring control by customers
Comments from Printers
• Proposed changes could decrease
inconsistencies in regulations
• Could foster more pollution prevention,
reuse and recycling
• Concerns about clarity, flexibility and
certainty of wording in rule
II - 34
Dan Owenby
Technical Service Manager
Chemence, Inc.
Topics to Cover
• Role of solvents in platemaking
• Usage
• Disposal
Solvents in Platemaking
• Part of making
photopolymer printing
plates
• Used to process
photopolymer plates
after imaging
II - 35
Plate Washout
• Plates are washed out in
solvent to remove uncured
polymer to form a relief image
on the surface
Plate Washout -Process
• Uncured polymer
before washout
• Plate washing in
solvent
• Plate after washing
Plate Processors
• Three main types of processors
– Rotary
• Mainly solvent processing
– Orbital
• Mainly aqueous processing
– In-Line
• Used for both solvent & aqueous
II - 36
Rotary Processor
Fumes
Drum
Brushes
Solvent
Orbital Processor
Platen
Solution
Brushes
Plate
Rotary/Orbital Processors
• Washes plates on a rotating
drum/oscillating platen
• Must be opened to mount/demount
plates
• Fumes are readily breathable
• Physical contact with solvent
highly likely during rinse and blot
II - 37
In-Line Processor
Fumes
Vent stack
to outside
Plate washing cassette
Rinsing brush
Blotting brushes
Pre-drier
Air
flow
Air
flow
Blower
In-Line Processor
•
•
•
•
Self contained
Closed to most fumes
Little physical contact with solvent
All washout operations done automatically
The Solvents
• Solvent: PAS Solvents (Hydrocarbon
based)
• Aqueous: Lactic Acid/H2O
• Aqueous: Surfactant/H2O
II - 38
Solvent-Usage
• Is a replacement for perc.
• Washout superior to perc.
– Is formulated to wash
plates - not clean paint
brushes, do laundry, etc.
• Is not a carcinogen
• Can be used in most
existing perc processors
Solvent - Disposal
SOLVENT
• Can be distilled for
recovery & reuse
• Solid still bottoms
typically can be
landfilled
• Liquid still bottoms
must be incinerated or
fuels blended
Surfactant SolutionsUsage
• Specialized soap(s)
• Defoamer(s)
• Deionized water
– If needed
• Suspends polymer
in washout solution
II - 39
Solution Disposal Continuous
To mixing
cone
Washout chamber
Mixing cone
To filter
bags
To sewer
Lactic Acid-Usage
• Lactic acid/water solution
w/pH 2.0-2.5
• Used as an alternative to
solvents
• Water wash formulation
plates only
Lactic Acid-Disposal
Spent
Solution
Tank
F
i
l
t
e
r
Effluent
Tank
• Spent solution ultrafiltered to separate water
from polymer
• Polymer can typically be
landfilled if dry
• Effluent reused or
discharged to sewer after
pH balance if local
ordinances allow
II - 40
Economic Benefits-Aqueous
•
•
•
•
No Solvent Cost
No Solvent Recovery Cost
No Hazardous Waste Cost
High Productivity
The Polymers
• Liquid
• Sheet
Liquid-Usage
• Used to cast plates
• Cures with UV lights
• Washes out in water
and specialized
soap(s), defoamer(s)
• Inert in cured, solid
form
II - 41
Liquid - Disposal
• Can be landfilled after
curing solid
• Liquid to treatment,
storage & disposal
facility for
incineration/fuel
blending
Sheet-Usage
•
•
•
•
Semi-solid sheet
Cures with UV lights
Washes out in solvent
Inert in cured form
Sheet - Disposal
• Can be landfilled after
curing solid
II - 42
Digitally-Imaged Plates
Brad Taylor, DuPont Corp.
Conventional Plate Making
UV Light
Film
Raw Plate
Polymerize
Polymerize
Photopolymer Plate
Processing
Washout
Dry
Light
Finished
Finishin Relief Plate
g
Cross-section
II - 43
Digital Plate Structure
Integral
Mask
Photopolymer
Plate
Photopolymer plate with laser imageable mask
Digital Plate Imaging
UV Light
Polymerize
Polymerize
Write image in black integral mask with
laser
Digital Plate Processing
Washout
Dry
Light
Finishin Finished
g
Relief Plate
Cross-section
II - 44
Digital Plates Print Better !
Consistency
Dot Sharpening
Small Features
Offset Cut-Back
Exposure Latitude
White Highlights/Open Shadows
Plate Making Waste
Comparison
Waste Per Color for a 1 Square Meter
Job:
Conventional
• 1 liter chemistry (500 cc fixer, 500 cc
developer)
• 2 square meters polyester film
Digital
• < 5 grams integral mask material
II - 45
II - 46
Case Study: OEC Graphics, Inc.
PERFORMANCE
Notes:
II - 47
Case Study: OEC Graphics, Inc.
PERFORMANCE
Notes Continued
II - 48
III.
PERFORMANCE
Supplementary Fact Sheets and Articles
Environmental Management of Photopolymer Flexographic
Printing Plates, PNEAC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-3
Use of Blast Media to Clean Press Parts, PNEAC . . . . . . . . . . . . . . . . . . . . . . . . III-9
How to Read and Use an MSDS for Environmental Purposes, PNEAC . . . . . . . III-11
What is a Hazardous Waste?, PNEAC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-17
Basic RCRA Recordkeeping Requirements for Printers, PNEAC . . . . . . . . . . . . III-27
Understanding Air Pollution Permits, PNEAC . . . . . . . . . . . . . . . . . . . . . . . . . . III-31
Silver Recovery Systems and Waste Reduction Photoprocessing,
North Carolina Department of Environment, Health and
Natural Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-37
Environmental Compliance Checklist for Printers, GATF . . . . . . . . . . . . . . . . . III-43
Federal Environmental Regulations Potentially Affecting The Commercial
Printing Industry, DfE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-59
When Plates Go Bad! , Dan Owenby. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-65
The following are available at www.pneac.org under Fact Sheets/Case Studies:
1. Management of Aqueous Waste from Water-Based Flexographic Printing
Processor, FTA
2. Hood Flexible Packaging Saves $50,000 by Reducing Film Scrap, MNTAP
3. Learning from Three Companies that Reduced VOC Emissions, DfE
4. Water and Ink Waste Reduction at F.C. Meyer Company, Massachusetts Office of
Environmental Affairs
5. Replacement of Hazardous Material in Wide Web Flexographic Printing Process,
USEPA
1-800-442-4613
Fax Number:
1-800-348-9529
III- 1
III - 2
Printers’
Printing
National
Environmental
Assistance
Center
CASE STUDY
PNEAC
www.pneac.org
1-888-USPNEAC
ENVIRONMENTAL MANAGEMENT OF
PHOTOPOLYMER FLEXOGRAPHIC PRINTING
PLATES
The defining characteristic of flexographic printing is the flexographic printing plate.
Flexographic plates have the printing image in relief, which means the image area is raised
relative to the non-image area. As with any industry, technological evolution has brought
changes in flexographic plates. Plates made from light sensitive photopolymers are now being
used throughout the industry. Photopolymer plates are similar to traditional rubber plates in that
they are flexible and resilient, but their use poses different environmental concerns. In this fact
sheet, environmental considerations are described in the use of various photopolymer
flexographic plate development processes.
CONVENTIONAL PHOTOPOLYMER PLATES
Conventional photopolymer plates are either viscous liquids or solid sheets of various thickness.
The photopolymer is exposed to ultraviolet light through a film negative and the unexposed areas
are washed out by means of a solvent or water wash Figure 1. The result is the relief plate that is
capable of transferring ink from the anilox roll to the substrate.
III - 3
PNEAC Case Study: Environmental Management of Photopolymer Flexo Printing Plates, p. 2 of 5
There are several steps to making conventional photopolymer plates. Though the process may
differ slightly from system to system, they all require the following:
• Back exposure of the plate base to UV light to harden (cure) the floor and establish relief
depth.
• Face exposure of the plate surface to UV light through a film negative to harden (cure)
printed images.
• Washout in appropriate solvent or water to remove unexposed polymer leaving printing
images in relief.
• Dry to remove absorbed solvent.
• Post exposure to UV light for a final cure of the floor and to establish character shoulders of
the raised image.
• Finish plate with water, solvent or UV light to remove residual tackiness.
In conventional photopolymer plate making, waste is created when the film is developed. Film
processors use developer and fixer solutions which in most cases, can be discarded to the sewer
after silver recovery is performed on the used fixer solution. In some regions of the country
there is strict control of the waste silver. Both developer and fixer solutions can be removed,
recycled and replaced by a film chemistry service. Rinse waters contain low concentrations of
silver. Although there is little economic benefit to recovering silver from rinse waters, the Clean
Water Act and stringent state/ local discharge regulations can trigger application of silver
recovery on untreated wash water if the silver concentration exceeds regulatory limits. On-site
recovery of silver involves metallic replacement, electrolytic recovery and chemical
precipitation. After silver recovery, effluent is generally discharged into the drain where it goes
to the publicly owned treatment works (POTW) for treatment and eventual release back to the
environment. Processing solutions must not be discharged to a septic system and instead must be
collected and shipped for processing. After use, the films must be discarded or, sometimes,
recycled.
Perchloroethylene (PERC, PCA), a Hazardous Air Pollutant (HAP), was traditionally used as a
solvent to wash photopolymer plates. The regulation of chlorinated solvents due to air
contamination, health hazards and hazardous waste has promoted the introduction of alternative
solvent and water washable plates.
For any type of flexographic printing plate, purchasing the right size sheet or using the correct
amount of liquid, based on negative film size, will minimize waste of unexposed photopolymer.
If waste is still generated, it is recommended to save unused strips as test plates for the resetting
of exposure and washout conditions.
For both solvent and water systems, filtered polymer, unexposed photopolymer plates and
processed photopolymer plates are normally classified as non-hazardous wastes. Cured plates
may be incinerated, or alternatively, sent to a landfill that is authorized to accept the material.
However, they should be qualified to determine if they are hazardous wastes by exhibiting the
characteristics of toxicity. Ask the plate supplier for details on what is a hazardous waste
III - 4
Solvent Washable Plate Specifics
Percholorethylene alternative solvents (PAS) are now being used by many platemakers. Drying
times using PASs have improved significantly over earlier versions. PASs can be used to
develop almost any solvent washable photopolymer plate.
PASs are volatile organic compounds (VOCs) comprised of hydrocarbons and alcohol which can
be eye and respiratory irritants. Therefore, adequate ventilation must be provided while PASs
are being used. Also, safety glasses or goggles and gloves should be worn when handling these
chemicals. PASs typically have a flashpoint of 150-200-F and are stable under normal room
temperature and storage conditions.
Solvent can be recycled, but its useable lifetime depends on the number and size of the plates and
the amount of material removed. Once the solvent is spent, it can either be sent to an off-site
distiller, or equipment can be purchased to distill the solvent on-site. PASs can be recycled by
using vacuum distillation. PASs that are mixtures may require balancing (with chemicals) after
distillation to get back to the correct ratio of components.
Still bottoms generated from distillation are usually incinerated, but can be landfilled depending
on local requirements. It also is possible to use still bottoms for fuel blending. It is advised to
run the appropriate tests to determine if waste products are classified as hazardous wastes. If
they are determined to be hazardous wastes, then they can not be landfilled without prior
treatment. Information and test results should be available from the supplier to help with this
determination.
Water Washable Plates Specifics
Water washable plates largely reduce or eliminate many of the concerns of solvent washable
plates including emissions of VOCs; flammability because of lower flash point; hazardous waste;
and influence on human health. The use of these more environmentally friendly water washable
plates enhances corporate image with regulators, customers and the public. By switching to
these types of plates, the need to purchase and install pollution control equipment may be
reduced or avoided.
Water washable plates come in two versions: sheet and liquid photopolymer. Early versions of
water washable sheet plates had some limitations in their application. Recently, the qualities of
water washable plates have been much improved.
Water washable sheet plates are prepared with almost the same procedure as that used for solvent
washable sheet plates. The biggest difference in process equipment between solvent washable
plates and water washable plates is the washout unit, which is usually accompanied with a
washout water treatment unit. A washout water treatment unit is designed to satisfy the
requirements of most local POTWs. Analytical data of filtered washout water should be
available from the plate supplier. However, before discharging filtered washout water into a
sanitary drain, the local sewer authority should be contacted to determine if such discharge is
permissible. Sometimes, secondary treatment may be required to pass strict limits along with the
need to obtain a permit.
III - 5
Water washable plates are also available as a viscous liquid. Liquid photopolymer resins (LPRs)
are completely curable materials that are developed in a totally aqueous medium. Their main
environmental advantage (over sheet material) is that unexposed portions of the plate can be
reclaimed manually with a squeegee and reused. This is especially beneficial when a relatively
large plate with minimal impressions is required. These materials are not regulated as hazardous
substances or as toxic chemicals and are therefore not regulated as hazardous waste if discarded.
LPRs contain no chemicals that are regulated as priority pollutants under the Clean Water Act
(CWA).
After the available unexposed liquid resin is recovered, the residual material is removed in an
aqueous bath containing additives such as detergents, defoamers, stabilizers and water treatment
agents. Spent washout solutions should be acceptable to most conventional POTWs that use
typical biological treatment technology.
Extracting uncured resin from the waste water requires the use of organic solvents which may
indicate the presence of oil and grease. In some operations for which effluent would not meet
local discharge limits prior to entering the sewer, pretreatment, such as flocculation, coagulation
and clarification may be required. Before discharging any waste water, it is important to contact
the local sewer authority to determine if the discharge is acceptable.
Most discarded liquid resin systems are not regulated as hazardous wastes or as CWA priority
pollutants. However, manufacturers recommend careful handling of the waste resin as LPRs can
act as a skin irritant. Waste resins can be incinerated at a licensed treatment and disposal facility
or they may be cured and disposed of as plate material. Contact the supplier for information and
data to support the nonhazardous classification.
DIGITAL PHOTOPOLYMER PLATES
Traditional plate processing requires the use of film using developer and fixer chemicals and
generates silver bearing waste. A significant environmental advantage of digitally imaged sheet
photopolymer flexographic platemaking is that it uses no film during the production process.
This eliminates used film and processing chemicals as well as the need for silver recovery
equipment.
First introduced in 1995, digital flexo plate imaging technology incorporates a very thin layer of
material, termed the integral mask, that is not transparent to UV light. An imaging device (much
like an imagesetter) using a high-power infrared laser(s) removes, or ablates, the integral mask in
an imagewise fashion, revealing the uncured photopolymer underneath Figure 2a. The
underlying photopolymer does not absorb the infrared laser radiation, and thus it is not affected
by the laser ablation.
III - 6
The digital plate receives a main ultraviolet exposure after laser ablating which images through
the integral mask Figure 2b. The remaining black layer absorbs the ultraviolet radiation. The
ultraviolet radiation polymerizes the underlying photopolymer where the black layer has been
removed. The plate is washed, dried and finished with the same process as a conventional
solvent washable photopolymer plate.
Today's digital plates are all solvent washable technology and like conventional processes using
PASs, the solvent is handled, distilled and reused as discussed above for PASs. Water washable
digital plates are in development.
Like conventional photopolymer plates, filtered polymer, unexposed photopolymer plates and
processed photopolymer plates are normally classified as non-hazardous wastes. However, they
should be examined to determine if they exhibit the characteristics of toxicity. Characteristics of
ignitability, corrosivity and reactivity may also need to be examined under RCRA. Ask the plate
supplier for information and data to support the nonhazardous classification.
Additional Information
Author: Doreen Monteleone, PNEAC / Flexographic Technical Association
For additional information on flexographic printing plates and environmental issues impacting
flexographic printers, contact the Flexographic Technical Association at http://www.fta-ffta.org
or call(516) 737-6020.
For further guidance on managing photoprocessing waste water, contact the Silver Council at
http://www.silvercouncil.org
or call (301) 664-5150 and request information on the Code of Management Practice; Guide for
Commercial Imaging.
interpretation. The reader is responsible for making the appropriate decisions with respect to their operation, specific materials
employed, work practices, equipment and regulatory obligations. It is imperative to verify current applicable regulatory
requirements with state and/or local regulatory agencies.
III - 7
III - 8
Printers’
Printing
National
Environmental
Assistance
Center
CASE STUDY
PNEAC
www.pneac.org
1-888-USPNEAC
Use of Plastic Blast Media to Clean Press Parts
The flexographic packaging industry has made great strides in reducing the total amount of solvents
consumed and emitted into the atmosphere. The reduction in the amount of volatiles in solvent inks
and the conversion to water-based inks have allowed many companies to grow while reducing their
overall emissions. Regulations have dictated the need for solvent-capture systems that are costly,
but also greatly reduce total emissions. (See editor’s notes at the end of the article.)
Solvents and soak tanks are still common in packaging for cleaning press parts such as ink trays,
pumps and buckets. However, a new blasting technology uses a unique plastic media to eliminate
the need for harsh chemistries and soak tanks. Using this technology, several companies have
greatly reduced chemical expenditures, disposal costs and operator exposure to the corrosive
chemistry.
Alliance Packaging (formerly
Flex Pack) in Sacramento
CA, has taken advantage of
the parts cleaner shown in
Figure 1 to clean ink pumps,
pans and other press
components. Alliance's Lou
Figuera estimates they have
cut the consumption of
cleaning chemistry in half,
resulting in savings of about
$500 per week. Use of
ammonia, various soaps and
Figure 1. The parts cleaner features convenient access through four
pH conditioners have been all
glove ports on the front cabinet
but eliminated using the parts
cleaner.
“Reducing operator exposure to harsh chemicals was a primary concern” states Figuera.
“Eliminating the risk of exposure or injury was a major motivation to move toward the blast
technology”
The plastic blast media will remove dried-on ink, without risk of damage to the part's surface. The
72"x36" unit is totally enclosed, with four rubber gloves providing access through the cabinet front.
III - 9
PNEAC Case Study: Use of Plastic Blast Media to Clean Press Parts
p. 2 of 2
The blast stream is initiated with a foot pedal, and a hand-held nozzle then focuses the blast on the
parts requiring cleaning. The plastic media used in this system is similar to the plastic media used
in anilox cleaning systems, but is somewhat larger in particle size and more effective.
Once the blast has occurred, the plastic is returned to a reclaim unit. The
returned media is sent through an elaborate air wash system, removing fine
dust particles from the dried-on ink. The good media returns to the blast
unit again.
Over an extended period of time, (100-200 uses), the plastic media shown
in Figure 2 begins to break down and becomes too fine for cleaning. This
Figure 2. A close-up
spent media, along with the fine dust from the ink, is captured in collection
of the plastic media
bags and deposited in a tray for disposal as a non-hazardous waste (as long
used by the parts
as the material removed from the parts is non-hazardous) .
cleaner.
At Alliance Packaging, the reduction of 150 to 175 gallons of chemical cleaning waste per week has
significantly reduced disposal costs. A filtration system reduces six or seven barrels of liquid waste
to one 55-gallon drum of solid waste, but the cost for disposal of the solid is still $150 to $200 per
barrel. Those with different filtration systems may experience greater savings.
Cost-efficiency is only one benefit of this system. “Cleaned parts are now available for use in less
than an hour, where previously they required an overnight soak, then lots of ‘elbow grease’ to clean”
concludes Figuera. This provides a quicker cleaning process, one that reduces press downtime and
contributes to greater operating efficiency for the entire company.
Author: Dale Patterson, President of Absolutely Micro*Clean, LLC.
This article first appeared in FLEXO magazine, July, 1998, p. 54-55, as ‘Environmentally
Friendly Cleaning’.
PNEAC Editor’s Notes:
Mention of trade names of commercial products does not constitute endorsement or recommendation
for use by PNEAC or USEPA. Micro*Clean is listed in the PNEAC vendors list,
<www.pneac.org/vendors/vendhome.html>.
The described process removes solvent-based inks best. It works well on both water-based and UVcured inks. No cleaning solvent is introduced into this process. Printers using water-based or UV
inks can see larger solvent emission reductions than those who clean with solvent reclaimed from
solvent-based inks. Dry and brittle residue is removed better than wet or rubbery material.
technical reviewers and their agencies, assume responsibility for completeness and accuracy of the information, or its interpretation.
The reader is responsible for making the appropriate decisions with respect to their operation, specific materials employed, work
practices, equipment and regulatory obligations. It is imperative to verify current applicable regulatory requirements with state and/or
local regulatory agencies.
III - 10
Printers’
Printing
National
Environmental
Assistance
Center
Fact Sheet
PNEAC
www.pneac.org
1-888-USPNEAC
How to Read and Use an MSDS for
Environmental Purposes
OSHA mandates that each product used commercially which contains any hazardous ingredient must
be accompanied by a Material Safety Data Sheet or MSDS upon entering a facility if there is one or
more people employed at that location. The MSDS was initially designed to convey important safety
hazard information and measures to protect persons who may come in contact with a product,
including employees, fire fighters, etc. Current, revised, and obsolete MSDS must be kept on file at a
facility for 30 years or as long as the company is in business (whichever comes first).
The MSDS also serves to provide important environmental compliance information, including VOC
content, hazardous chemical ingredients and their CAS numbers, product density, and vapor
pressure. This information is required for hazardous air pollutant (HAPs) and VOC emission
calculations, as well as other annual record keeping and reporting requirements, such as SARA 311
and 312 reporting
There is currently no required format for a MSDS, but the most common is the OSHA Form 174
which contains 9 different sections. Other formats may illustrate the same required information, but
in an alternative location on the sheet. This guide follows the same sequence as the OSHA Form 174.
Each section of OSHA Form 174 is listed and environmental information or description is provided
where applicable.
Section I. Basic Product Information
1. Trade Name or Synonym.
This name may not reflect the product's use or the name the product is referred to in your facility. It
is recommended that the facility mark on the MSDS the department or application of the product if it
is unclear on the MSDS.
2. Manufacturers Name and Address.
This may be different than product source or supplier. It is advised that if the product supplier is
different write their name and phone number on the MSDS sheet.
3. Emergency Telephone Number.
There must be 24 hour telephone access to a company representative in case of a spill, release, or
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PNEAC Fact Sheet: How to Read and Use an MSDS for Environmental Purposes p.2 of 6
personal injury. Many suppliers of hazardous materials contract out to an emergency answering
service provider such as Chemtrec.
4. Chemical Name of Product.
Refers only to products that are single substances, such as methyl ethyl ketone. This information may
be omitted if the product is a mixture or proprietary.
5. Date Prepared.
Signifies the date the original MSDS information was compiled or last updated. This information
should be used to verify whether a new MSDS has been updated or is a duplicate of current MSDS
on file.
6. Signature of Preparer.
Optional information, name and/or signature of the person who prepared the MSDS.
Section II: Hazardous Ingredients
This section lists the chemical name, CAS (chemical abstract service) number, and the quantity of
the chemical within the product expressed in percent by volume or weight. This information is
needed to calculate the chemical usage and storage quantities for SARA Section 311, 312, and 313
compliance as well as calculating HAPs and VOC emissions from the product for air permitting
calculations or quantity of chemical released. Some state air operating permits specify how the VOC
information must be calculated and the printer may need to work with the supplier to provide the
VOC information in the correct units of measure.
Many MSDS omit the VOC containing products in this section, but will list the total volatile content
of the product. The printer will need to consult the supplier to obtain a product data sheet which
provides information about the actual chemical and its concentration that is a VOC.
A supplier may list chemical content as a range due to proprietary concerns, for example 10-15%. In
this case the printer should verify the VOC content with the product supplier. If the actual VOC
content cannot be verified, consider the higher percentage when calculating total concentration of
VOC or HAP.
VOC emission calculations and certification that the information is correct is the responsibility of the
printer. In other words it is the printer's responsibility to verify that the VOC information that the
supplier provided is correct. One way to assure that the information is correct is to request that the
supplier determine the VOC content of their products through EPA Test Method 24 or Method 24A,
which are analysis protocols for determining VOC content of liquids established by U.S. EPA.
Section III: Physical Data
1. Boiling Point:
The temperature in degrees F at which a liquid boils under normal atmospheric conditions.
III - 12
2. Vapor Pressure:
The pressure of saturated vapor above the liquid in mercury at 68 degrees F.
Boiling point (bp) and vapor pressure (vp) indicate how rapidly the material evaporates or how much
VOC and HAPs are in the product. For example, Isopropyl alcohol has a boiling point of 180 degrees
F and a vapor pressure of 33 mm Hg. Where as ethylene glycol has a bp of 379 degrees F and a vp of
0.1 mm Hg. Products with a low boiling point, vapor pressure and vapor density typically are high
VOC products. Some state air regulations limit the vapor pressure of certain printing products, such
as blanket wash or fountain solution (used in offset printing).
When considering alternative products in order to reduce VOC emissions, the vapor pressure of a
solution is a key factor. It is best to select products with low VOC and no or low HAP content and/or
products with a vapor pressure of 10mm Hg at 20 C or less. A product which contains 100% VOC,
but has a vapor press of 10mm of Hg at 70 at 20 C will emit approximately 30% VOC's by weight
because the product does not evaporate as quickly.
3. Vapor Density:
The weight of a vapor or gas compared with an equal volume of air measured at 60-90 degrees F.
Vapor density indicates whether the vapor is heavier or lighter than air. With flammable materials,
when the vapor density is greater than one, vapors will tend to move or collect in a low spot. Flame
sources should be carefully controlled or avoided in these areas. For example the vapor density of
isopropyl alcohol is 2.07, propane is 1.52, and helium is 0.1114; which means IPA and propane are
an immediate fire hazard because the gas can collect in low spots within a building and easily ignite.
4. Solubility in Water:
Indicates how quickly the material combines with distilled water at 50 F. It is measured in the
following terms:
Negligible
less than 0.1%
Slight
0.1 to 1%
Moderate
1 to 10%
Appreciable more than 10%
Complete
in all proportions
5. Specific Gravity
This is the ratio of the density of a material to the density of water. In other words, it compares the
weight of water to the weight of material. This information is especially important in the event of a
spill which can reach a lake or stream.
6. Evaporation Rate
This the rate the material evaporates compared to either butyl acetate or ethyl ether.
7. Appearance and Odor
III - 13
A brief description of the material. Ex. viscous colored liquid with ammonia odor.
8. Percent Volatile by Weight
This information may not be included (required on old format); the printer may need to ask the
supplier in writing, to include this information on all MSDS or provide a product data sheet.
This is the total VOC content of the product. This number should correspond with the sum of the
VOC products listed in Section II. This number should be used to calculate the total VOC emissions
of the product. This is calculated by multiplying the total pounds of material by the %VOC content
listed (or gal product x density x %VOC). Some state air regulations limit the VOC content of
products commonly used by printers.
For SARA reporting purposes each reportable chemical listed, the printer must calculate the amount
consumed or stored on site by the % content listed in the health hazard section. The total amount (in
all mixtures and pure form) stored or consumed on site must then be compared to the reporting limit.
If the reporting limit for any "listed" chemical is less than what was consumed or stored
on site during any month or calendar year reporting requirements may apply.
Section IV: Fire and Explosion Data
1. Flash Point
The minimum temperature in degrees Fahrenheit, at which a liquid gives off enough vapor for the
material to auto ignite. The most common test method is the closed cup method.
2. Flammable or Explosive Limits
The range of gas or vapor concentrations (percent by volume in air) which will burn or explode if an
ignition source is present. This is expressed as the lower explosion limit or LEL and the upper
explosion limit or UEL.
3. Extinguishing Media
Lists the fire fighting media suitable for use on the burning material. Some chemicals may negatively
react to water which is the most common extinguishing media. Therefore alternative methods, such
as carbon dioxide may be more suitable for extinguishing the flames.
4. Special Fire Fighting Procedures
This includes information about the toxicity of combustion products, any special personal protective
equipment, etc.
5. Unusual Fire and Explosion Hazards
This describes any special potential hazards which may need attention. For example, if water is
improperly applied to a flammable liquid with a flash point greater than 212 F, a violent boiling
reaction could occur.
Section V. Reactivity Data
III - 14
1. Stability
Indicates whether a chemical is stable or unstable under reasonably foreseeable conditions of storage,
use or misuse. If unstable, the potential reactions will be listed.
2. Incompatibility
Lists chemicals and compounds that will negatively react with the product and should not be
combined or stored. This is important to review prior to use and/or disposal. Shop towels and waste
storage containers are one of the more common areas where incompatible materials are inadvertently
combined and a negative reaction occurs.
3. Hazardous Decomposition or By-Products
Describes the products produced as a result of heating, burning or oxidizing. For example, thermal
decomposition of vinyl chloride plastics produces carbon monoxide (CO), carbon dioxide (CO2) and
hydrochloric acid (HCl)
4. Hazardous Polymerization
Describes the products that may be produced as a result of combining/exposing incompatible
products. For example combining chlorine (bleach) with ammonia will produce hydrochloric acid.
Section VI. Health Hazard Data
1. Routes of Entry
Ways the material could enter the body.
2. Health Hazards (acute and chronic)
Potential over exposure affects that will dissipate when moved away from product (acute) and
potential health affects resulting from repeated, long term overexposure which leads to symptoms
that remain fom greater than a few minutes/hours (chronic).
3. Carcinogenicity
Indicates whether or not the product is known or suspect cause of cancer.
4. Signs/symptoms of Exposure
5. Medical conditions generally aggravated by exposure
Lists potential medical conditions which will worsen as a result of exposure to this product.
6. Emergency and First Aid Procedures.
Recommendations on how to treat victims of over exposure.
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Section VII: Spill and Leak Procedures
1. Steps to be taken in case material is released or spilled
Describes special precautions if the material is spilled, such as evacuate area.
2. Waste Disposal Method
This area rarely describes how the product should be disposed of because each state and local
government's waste disposal regulations may be different. Check with the supplier and review your
state and local ordinances for proper disposal methods. Additionally, review waste water discharge
permits prior to flushing any product down any drain.
3. Precautions to be taken in handling and storing.
Provides information such as recommendations for temperature control, light exposure, etc. which
should be followed to avoid product degradation.
4. Other Precautions
Section VIII: Control Measures
1. Respiratory Protection
Specifies necessary protection to avoid inhalation overexposure.
2. Ventilation
Indicates type of ventilation needed to avoid overexposure.
3. Protective Gloves/eye protection/other equipment
Specifies the type of eye, hand and/or body protection that should be used while handling product.
4. Other Protective Clothing or Equipment
Includes additional recommended protective garments not covered in #3.
5. Work/Hygienic Practices
Provides information regarding personal handling such as washing hands prior to consuming food or
beverage, etc.
For additional information about pollution prevention opportunities in the printing industry call the PNEAC toll
free number at 1-888-USPNEAC or contact :
Graphic Arts Technical Foundation - Gary Jones or Rick Hartwig(412/741-6860
Printing Industries of America - Ben Cooper (703/519-8115)
Illinois Hazardous Waste Research and Information Center - Gary Miller (217/333-8940) or Debra Jacobson
(630/472-5019)
University of Wisconsin - Wayne Pferdehirt (608/265-2361) or Keith West (920/465-2940) or Bob Gifford
(608/262-1083)
Reasonable effort has been made to review and verify information in this document. Neither PNEAC and its
partners, nor the technical reviewers and their agencies, assume responsibility for completeness and accuracy of the
information, or its interpretation. The reader is responsible for making the appropriate decisions with respect to their
operation, specific materials employed, work practices, equipment and regulatory obligations. It is imperative to
verify current applicable regulatory requirements with state and/or local regulatory agencies.
III - 16
Printers’
Printing
National
Environmental
Assistance
Center
Fact Sheet
PNEAC
www.pneac.org
1-888-USPNEAC
WHAT IS A HAZARDOUS WASTE?
As a result of conducting its business, a printer may generate wastes that are considered hazardous or
otherwise regulated by EPA, state, and local agencies including the Department of Transportation. If not
handled and disposed of properly, these wastes can cause serious problems, injury or death of humans,
animals, and/or plant life; or damage or pollute land, air, or water. In addition, improperly handled and
disposed wastes expose the printer to liability ranging from possible enforcement actions including but not
limited to fines, cleanup costs associated with Superfund liability, and, in extreme cases, criminal
enforcement.
This fact sheet is designed to provide information on how to determine if a waste is classified as
hazardous under the federal regulations. The federal regulations were developed as a result of the
passage of the Resource Conservation and Recovery Act signed into law in 1976. It is important to
recognize that some states have differing definitions of hazardous or other regulated wastes. These
additional and other wastes include more wastes than those covered by EPA’s regulations. However, all
states must, as a minimum, include all of the wastes defined as hazardous under the federal regulations.
Waste Determination
The first and most important step is to determine if a spent material is in fact a waste. While this may
seem to be obvious, the regulation’s definition of a waste is quite detailed and somewhat confusing.
Essentially, a waste is any solid, liquid, or contained gaseous material that is no longer used and is either
recycled, thrown away, or stored until sufficient quantities are accumulated for treatment or disposal. If a
“waste” is used as a raw material in a subsequent process within the printer’s facility or other
manufacturers, process, it is not considered a waste and therefore it does not have to be manifested.
However other regulations, such as Department of Transportation hazardous material shipping
requirements still, apply.
After the material is determined to be a waste, it must be evaluated relative to its ingredients and physical
characteristics. A waste is classified as a hazardous waste in one of two ways:
I. It exhibits any of the characteristics specified by EPA regulations or
II. It is specifically listed as a hazardous waste in EPA regulations
Characteristic Wastes
A waste is considered hazardous if it exhibits one or more characteristics identified in the federal
regulations. The characteristics are:
· Ignitability
· Corrosivity
· Reactivity
· Toxicity
Attached Chart A describes the four characteristics along with examples of waste characteristics possibly
generated by printers. In reviewing hazardous wastes generated by printers, the most common wastes
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PNEAC Fact Sheet: What is a Hazardous Waste?,
p. 2 of 10
generated exhibit one or more of the four characteristics. Of the characteristic wastes, D001 or ignitables
are the most prevalent waste due to spent cleaning solvents with flashpoints below 140°F.
Listed Wastes
A waste is considered hazardous if it appears on any one or more of the four hazardous waste lists (F, P,
K, or U) contained in the federal regulations. Wastes falling on one of the four lists have been classified
as hazardous because they contain any of a number of toxic constituents that have been shown to be
harmful to health and/or the environment. EPA regulations specifically list over 400 hazardous wastes,
including specific wastes derived from manufacturing processes and discarded commercial chemical
products.
The next most common wastes generated by printers, after characteristic wastes, are F-listed ones. The
F-listed wastes apply to those wastes that are considered used or spent. Understanding the F-listed
category can be somewhat challenging and confusing. Attached Chart C contains the list of F categories.
In order for a waste to be classified as F001, F002, F004, or F005, it must contain a total of 10% or more
(by volume) of one or more of the chemicals listed in that category. For example, a waste solvent blend
containing 10% methylene chloride and 90% water would be classified as an F002 waste.
For the F003 category, a waste must either be 100% of any of the chemicals in the F003 category or
contain one of the chemicals in the category and 10% or more of any chemicals in F001, F002, F004, or
F005 categories. Any waste chemical in the category originally used as a “technical grade” is also
considered 100%. For example, a waste solvent blend containing 5% xylene, 15% methylene chloride,
and 80% water would be classified as an F003 and F002 hazardous waste. Likewise, a waste solvent
blend containing 15% xylene, 15% methylene chloride, and 70% water would also be classified as F002
and F003. However, a waste solvent blend containing 25% xylene, 5% methylene chloride, and 70%
water would not be classified as an F-listed waste. Depending upon the flashpoint of the waste, it could
be still classified as a hazardous waste. If the flashpoint is below 140°F, then it would be a D001 or
ignitable hazardous waste. It should also be noted that the waste could be characteristically toxic,
depending on the cleaner and/or residues removed by the cleaner.
The U and P listed wastes are for those discarded, unused commercial chemical products that are either
100% pure, technical grade, or any formulation where the chemical is the active ingredient. K-listed
wastes are those from specific industrial manufacturing processes such as lead or chrome pigment
manufacturing. Few if any printers generate P or K listed wastes. Attached Chart D contains several Ulisted chemicals that could be generated by a printer.
In some instances, a waste may receive two designations or classifications. Generally the primary
ingredients in the waste will be the primary classification, with the other classification being noted on the
manifest. When there may be confusion with these types of wastes, it is best to consult the state agency,
state technical assistance provider, or PNEAC. Multiple classifications of wastes are not common within
the printing industry.
Hazardous Waste Determination
It is the printer’s responsibility to determine whether the wastes generated at the facility are hazardous
and the subsequent classification that is to be assigned to the waste. EPA allows for two approaches to
determine if a waste is hazardous:
I. The generator can “apply knowledge” or
II. The generator can test the waste using a variety of test methods.
Applying knowledge of the physical characteristics of a chemical or material and how it is used in a given
process is the most cost-effective method of hazardous waste determination. Under this approach, the
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p.3 of 10
printer applies knowledge of the material's physical characteristics and its use to determine whether the
waste is hazardous. For example, the generator would identify which purchased materials were combined
in the generation of the waste. Those materials, plus any contaminants that the materials might have
picked up during use, would have to be evaluated to determine if the resulting waste has, or might have,
a listed hazardous constituent (see above) or exhibits a hazardous waste characteristic (i.e., ignitability,
corrosivity, reactivity, or toxicity). Material safety data sheets (MSDSs) are a commonly used source of
information for this analysis. If a material is chemically unchanged (e.g., uncontaminated ink), the MSDS
would be representative of the material as a waste. Is the flash point of the cleaning solution 140°F or
less? If so, the waste cleaning solution and ink mixture is ignitable and gets a designation of D001. Does
the waste have a pH less than or equal to 2.0, or greater than or equal to 12.5? If so, it is corrosive and
gets a designation of D002. The MSDS and other product information can also be used to compare the
ingredients to either list of “listed” hazardous wastes.
If the applying knowledge review is inconclusive, testing should be performed to be certain of the waste’s
classification. The “applying knowledge“ approach is best used to document clear-cut cases where it is
obvious that the materials used and the manner in which they are used would not result in a hazardous
waste. Improper classification of a hazardous waste as non-hazardous does not relieve a generator of the
liabilities that could result from improper disposal of the hazardous waste. In some cases where it
appears likely but uncertain that a waste is non-hazardous, testing can be performed to verify the
analysis. This testing could then be used as part of the data that is used in the “applying knowledge“
review of subsequent wastes generated from the same input materials and processes.
In using the applying knowledge approach it is important to note that very few waste streams are solely
composed of just the uncontaminated material itself. Typical waste streams are usually mixtures of
several waste products. For example, waste press cleaning solvent will actually be a mixture of the
solvent and the ink. Therefore, when the applying knowledge approach is used, remember Ù the hazard
classification needs to take into account the entire waste mixture and not just one of the ingredients.
When using MSDSs as part of the “applying knowledge” approach, recognize that MSDSs are not
required to address all of the environmental concerns related to a product. MSDSs are not environmental
data sheets, which means that although they do contain very important and useful information about a
product, they are not required to detail all of the environmental concerns associated with a given product.
MSDSs are mandated by OSHA, and their purpose is to provide information about the health and safety
aspects associated with a particular chemical or product. MSDSs are prepared by manufacturers,
suppliers, and importers to meet OSHA requirements regarding the health and safety aspects of a
product. Helpful environmental information is often included on MSDSs, but this information should not be
assumed to be exhaustive.
When in question, ask the supplier or manufacturer for more information. In some cases, testing may be
appropriate to supplement or verify information from the manufacturer. To illustrate the limitation of
MSDSs when making waste classification determinations, it should be recognized that MSDSs are only
required to report hazardous ingredients that are present in concentrations of at least 1%, or 0.1% for
carcinogens. A 1% concentration translates to 10,000 parts per million (ppm). Likewise, a chemical
present in a 0.1% concentration would be equivalent to 1,000 parts per million. The threshold quantities
for several toxic criteria chemicals is substantially below 10,000 parts per million (see TCLP threshold
levels in Chart A); for example, the hazardous waste threshold level for carbon tetrachloride is 0.5 parts
per million. To address this inadequacy of MSDSs as a sufficient basis to make hazardous waste
determinations, request that suppliers provide you with a written statement identifying any constituents in
their materials that may cause the resulting waste to be classified as hazardous waste.
Testing the waste, although incurring more cost than applying knowledge, can provide specific results to
determine if a waste is hazardous. The types of tests commonly used are flashpoint, pH, and toxicity
characteristic leaching procedure (TCLP). TCLP contains specific testing procedures that must be
followed, and the ones used depend upon the physical state of the particular waste being analyzed.
TCLP will be used to determine heavy metal content and the concentration of certain other organic
III - 19
p.4 of 10
chemicals. Chart B contains the complete list of chemicals regulated under TCLP and a list of possible
TCLP wastes generated by printers.
The first step in testing involves obtaining two samples of the waste. One waste sample is sent to a
testing laboratory to conduct an analysis of the waste. The other sample is retained in case the first
sample becomes lost, contaminated, or if the results of the first sample are questionable. Samples should
be representative of the waste chemical, meaning the waste material should be collected at the point of
generation (e.g., cleaning solvents used after cleaning, used fountain solutions including additives, etc.).
Once the samples are collected, they should be sealed in a clean, durable, and compatible container,
dated, and either shipped immediately to the laboratory or refrigerated until shipment can be made. To
ensure that the samples remained untampered, a chain of custody should accompany them from the
moment it was collected until it is received at the laboratory. The chain of custody is used to show when
the sample was passed along to other parties, identifying everyone who had access to the sample.
Documentation
It is very important that you can prove that all waste streams have been properly classified. Whether you
apply knowledge or test the waste, some form of documentation is necessary. Attached is a waste profile
sheet that should be used for classifying each waste stream. The sheet should be kept on file along with
copies of MSDSs and any results of tests conducted on the wastes. In many instances, vendors who
transport/dispose your waste typically conduct these tests. Depending upon the particular waste, tests for
pH, flashpoint, and TCLP should be conducted. These test results should be attached to the profile sheet.
As long as the wastes remain the same, retesting or reprofiling is not required.
Liability Management
Because hazardous waste is generated as a result of an industrial manufacturing process, it is subject to
strict government disposal regulations. Under the current environmental laws and regulations, all
industrial waste streams generated by a printer are that printer’s responsibility forever, even if the printer
follows all applicable regulations. Hazardous waste that is improperly disposed or was once legally
disposed that eventually causes environmental contamination can result in Superfund liability for the
printer. Therefore, it is imperative that all wastes, including nonhazardous ones, be properly handled and
disposed of in as permanent fashion as feasible.
The best approach to ink waste disposal is to not generate it in the first place. Several techniques can be
used to reduce, recycle, or reuse materials. Several fact sheets addressing this subject for various
products used by printers can be found on PNEAC’s web page at www.pneac.org. Printers who have
adopted some or all of these approaches have reduced the amount of waste generated. Since disposal of
waste is inevitable, preferred methods include neutralization, stabilization, solidification, incineration, or
other appropriate treatment methods. Landfilling of hazardous waste should not be considered. In fact, it
is illegal to landfill hazardous waste without first treating it. Landfills should be avoided for chemical
nonhazardous wastes as they only represent long-term storage. They do not offer a permanent means of
disposal, and printers have been caught in Superfund cleanup actions because they had landfilled ink
waste.
Summary and Conclusion
It is the printer’s responsibility to properly characterize and manage their waste streams, including
hazardous waste. This is why it is critical that the printer understands the definition of a hazardous waste
so that all wastes generated can be properly classified. Classifying nonhazardous wastes as hazardous
increases a printer’s liability and disposal costs, and can cause the printer to be classified as a larger
generator than it actually is, which results in increased compliance requirements. Most importantly, all
wastes must be properly identified, managed, and disposed, or the printer can face cleanup liability
concerns. Hazardous waste carries additional concerns in that improper classification, management, and
disposal can lead to enforcement actions. It is also essential to recognize that some states regulate
III - 20
p.5 of 10
certain wastes as hazardous per state waste regulations. For example, although EPA does not consider
used oil being recycled to be a hazardous waste, many states regulate used oil as hazardous waste.
Accordingly, the printer needs to understand both the federal definition of waste (as presented in this fact
sheet) and what additional wastes the state defines as hazardous. Adoption of appropriate reduction,
reuse, and recycling techniques and employing permanent treatment methods will help reduce liability to
the greatest possible extent. In all but very limited circumstances, a printer’s liability for waste can never
be completely eliminated.
For additional information about pollution prevention opportunities in the printing industry call the PNEAC toll free
number at 1-888-USPNEAC or contact :
· Graphic Arts Technical Foundation - Gary Jones or Rick Hartwig(412/741-6860
· Printing Industries of America - Ben Cooper (703/519-8115)
· Illinois Hazardous Waste Research and Information Center - Gary Miller (217/333-8940) or Debra Jacobson
(630/472-5019)
· University of Wisconsin - Wayne Pferdehirt (608/265-2361) or Keith West (920/465-2940) or Bob Gifford
(608/262-1083)
·
·
·
RCRA/Superfund Hotline (800/424-9346), Washington, DC (703/557-1938)
Your state hazardous waste management agency
Your EPA regional office
III - 21
p.6 of 10
Chart A
Characteristics of Hazardous Waste
Characteristic
Criteria Of Characteristic Waste
·
Characteristic
of Ignitability
·
·
·
Characteristic
s of
Corrosivity
·
·
Characteristic
of Reactivity
·
·
·
·
Characteristic
of Toxicity
·
·
·
Possible Printing-Related
Sources
A liquid (expect solutions containing
less than 25% alcohol) that has a flash
point below 140° (60°C); or
A non-liquid capable of spontaneous
and sustained combustion under
normal conditions; or,
An ignitable compressed gas (as
defined by DOT); or
An oxidizer (as defined by DOT)
Chemical products such as
blanket and roller washes,
cleanup solvents, isopropyl
alcohol, and inks.
An aqueous material with a pH less
than 2.0 or greater than or equal to
12.5%; or
A liquid that corrodes steel at a rate
greater than ¼ inch per year at a
temperature of 130°F (55°C)
Plate and film processing
chemicals, particularly
etching chemicals. Acids,
waste battery acid, and
alkaline cleaners, depending
on their pH.
Normally unstable and reacts violently
without detonating; or
Reacts violently or forms an explosive
mixture with water; or
Generates toxic gases, vapor, or
fumes when mixed with water; or
Contains cyanide or sulfide and
generates toxic gas vapors or fumes at
a pH between 2 and 12.5.
Contains specific toxic contaminants
above threshold levels;
Waste needs to be tested2 using
specific test method(s);
List of some common printing
contaminants and threshold levels are
provided on the following pages.
Waste
Code
D001
Shop towels being thrown
out for disposal
Waste bleaches and
oxidizers
Waste fixer, plate processing
chemicals, ink, and cleanup
solvents, and specific
pesticides.
D003
D003
D004D043
Please see next chart for
specific toxic
contaminants.
Notes:
1. For solvents, check the MSDS. Normally the product’s flash point will be provided as “Physical Data.”
2. Testing is normally done by an outside laboratory or through a disposal company.
III - 22
p 7 of 10
Chart B
List of Chemicals Regulated by TCLP
Organics
Benzene
Carbon tetrachloride
Chlordane
Chlorobenzene
Chloroform
Cresol
m-Cresol
o-Cresol
p-Cresol
1,4-Dichlorobenzene
1,2-Dichloroethane
1,1-Dichloroethylene
2,4-Dinitrotoluene
Heptachlor (and its epoxide)
Hexachlorobutadiene
Hexachlorobenzene
Hexachloroethane
Methyl ethyl ketone
Nitrobenzene
Pentachlorophenol
Pyridine
Tetrachloroethylene
Trichloroethylene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Vinyl chloride
Endrin
Lindane
Methoxychlor
Toxaphene
2,4-Dichlorophenoxyacetic acid
2,4,5-Trichlorophenoxypropionic
acid
Regulatory
Levels
Waste
Code
0.50 ppm
0.50 ppm
0.03 ppm
100.0 ppm
6.0 ppm
200.0 ppm
200.0 ppm
200.0 ppm
200.0 ppm
7.5 ppm
0.50 ppm
0.70 ppm
0.13 ppm
0.008 ppm
0.5 ppm
0.13 ppm
3.0 ppm
200.0 ppm
2.0 ppm
100.0 ppm
5.0 ppm
0.7 ppm
0.5 ppm
400.0 ppm
2.0 ppm
0.20 ppm
0.02 ppm
0.4 ppm
10.0 ppm
0.5 ppm
10.0 ppm
1.0 ppm
D018
D019
D020
D021
D022
D026
D024
D023
D025
D027
D028
D029
D030
D031
D033
D032
D034
D035
D036
D037
D038
D039
D040
D041
D042
D043
D012
D013
D014
D015
D016
D017
Metals
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Regulatory
Levels
5.0 ppm
100.0 ppm
1.0 ppm
5.0 ppm
5.0 ppm
0.2 ppm
1.0 ppm
5.0 ppm
Waste Code
D004
D005
D006
D007
D008
D009
D010
D011
Possible EPA Toxic Characteristic Contaminants Found in Printing Waste
Contaminant
Waste
Code
Barium
Benzene
Chromium
Methyl ethyl ketone
D005
D018
D007
D019
D035
Regulatory
Threshold
100.0 ppm
0.5 ppm
5.0 ppm
0.5 ppm
200.0 ppm
III - 23
Contaminant
Waste
Code
Regulatory
Threshold
Silver
Trichloroethylene
Vinyl chloride
D011
D039
D043
5.0 ppm
0.5 ppm
0.2 ppm
p 8 of 10
Chart C
Examples of F-Listed Wastes
F001 The following spent halogenated solvents used in degreasing: tetrachloroethylene,
trichloroethylene, methylene chloride, 1,1,1-trichloroethane, and chlorinated fluorocarbons; all
spent solvent mixtures/blends used in degreasing containing, before use, a total of 10% or more
(by volume) of one or more of the above halogenated solvents or those solvents listed in F002,
F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent
mixtures.
F002 The following spent halogenated solvents: tetrachloroethylene, trichloroethylene,
methylene chloride, 1,1,1-trichloroethane, chlorobenzene, 1,1,2-trichloro-1,2,2triflouroethane, ortho-dichlorobenzene, trichlorofluoromethane, and 1,1,2trichloroethane; all spent solvent mixtures/blends containing, before use, a total of 10%
or more (by volume) of one or more of the above halogenated solvents or those solvents
listed in F001, F004, and F005; and still bottoms from the recovery of these spent
solvents and spent solvent mixtures.
F003 The following ignitable non-toxic solvents: xylene, acetone, ethyl acetate, ethyl benzene,
ethyl ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; all
spent solvent mixtures/blends containing, before use, only the above spent nonhalogenated solvents; and all spent solvent mixtures/blends containing before use, one or
more of the above non-halogenated solvents, and a total of 10% or more (by volume) of
one or more of the above halogenated solvents or those solvents listed in F001, F002,
F004, and F005; and still bottoms from the recovery of these spent solvents and spent
solvent mixtures.
F004 Toxic non-halogenated solvents: Aerosols, cresylic acid and nitrobenzene, all spent
solvent mixtures/blends containing, before use, only the above spent non-halogenated
solvents; and all spent solvent mixtures/blends containing, before use, one or more of the
above non-halogenated solvents, and a total of 10% or more (by volume) of one or more
of the above halogenated solvents or those solvents listed in F001, F002, F004, and F005;
and still bottoms from the recovery of these spent solvents and spent solvent mixtures.
F005 The following spent non-halogenated solvents: toluene, methyl ethyl ketone, carbon
disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane; all spent
solvent mixtures/blends containing, before use, a total of 10% or more (by volume) of
one or more of the above non-halogenated solvents or those solvents listed in F001, F002,
or F004; and still bottoms from the recovery of these spent solvents and spent solvent
mixtures.
III - 24
p 9 of 10
Chart D
Possible U-Listed Wastes Found In Printing Waste
Name/Description
Acetone
Benzene
Chromium
Cumene
Cyclohexane
Dibutyl phthalate
Ethyl acetate
Ethanol, 2-ethoxy
Ethylene glycol monoethyl ether
Formaldehyde
Methanol
Waste
Code
U002
U019
U211
U007
U055
U056
U069
U112
U359
U359
U122
U154
Name/Description
Methyl chloroform
Methylene chloride
Methyl ethyl ketone (MEK)
Methyl isobutyl ketone
Tetrachloroethylene
(perchloroethylene)
Toluene
Toluene diisocyanate
Trichloroethylene
Vinyl chloride
Xylene
III - 25
Waste
Code
U226
U080
U159
U161
U210
U220
U223
U228
U043
U239
p 10 of 10
Waste Profile Sheet
General Information
Department ______________________ Waste Coordinator ___________________
Waste Name ________________________________________________________
Process Generating the Waste __________________________________________
___________________________________________________________________
Waste Generation Rate (Gallons or pounds per month) ______________________
Current Disposal Procedure ____________________________________________
___________________________________________________________________
One-Time Disposal? Yes ___ No ___
Waste Classification
Nonhazardous _____
Residual Waste _____
Hazardous _____ If so, list the EPA Waste Codes: _______ ______ ______ _____
Waste Composition
Tests of Representative Sample Yes ___ No ___ (attach test results)
Process Knowledge Yes ___ No ___ (attach supporting documentation, e.g. MSDSs)
1.
2.
3.
4.
5.
6.
Waste Composition
Percent
___________________________
___________________________
___________________________
___________________________
___________________________
___________________________
___________
___________
___________
___________
___________
___________
General Parameters: Flash Point ______°F pH ______
Physical State at 70°F Solid ____ Liquid ____ Semi-Solid ____ Gas ____
Waste Packaging Type & Size (e.g., 55-gal, drum) ____________________________
Waste Coordinator Signature _____________________ Date _________________
III - 26
Printers’
Printing
National
Environmental
Environmental Complinace
Assistance
Center
Fact Sheet
PNEAC
www.pneac.org
1-888-USPNEAC
Basic RCRA Recordkeeping Requirements For Printers
The Resource Conservation and Recovery Act (RCRA) of 1984 gave the U.S. Environmental Protection Agency
(EPA) the authority to regulate municipal and hazardous waste. The purpose of this fact sheet is to provide a basic
understanding of the various recordkeeping requirements mandated by EPA. Depending on state and local
requirements, additional recordkeeping requirements and longer record retention requirements may apply.
RECORDKEEPING:
The information below in a starting point for determining if your RCRA required records are in order. Since
paperwork is one of the easiest noncompliance issues to spot during an EPA audit, keep your paperwork in order.
Here are some records to keep.
!
EPA Identification Number / Notice of Hazardous Waste Activity (40 CFR 262.11)
Prior to offering hazardous waste to transporters or treatment, storage, or disposal facilities a generator must obtain a
EPA (waste generator) identification number. The facility must complete EPA form 870012 and submit it to the
Agency. Copies of the application and notification/assignment of the facilities assigned identification number must
be kept on file. No specified record retention period. Note, this number does not expire or change, unless the facility
relocates.
!
Hazardous Waste Storage and Accumulation (40 CFR 262.34)
Facilities that generate greater than 221 lbs per month (SQG & LQG) of hazardous waste are required to train
affected employees on proper waste handling and emergency procedures, maintain documentation on waste
handling procedures, which includes designated emergency response personnel; documentation on duration and date
of waste storage, and a written storage time compliance procedure. No specified record retention period.
!
Manifests and Land Disposal Notification (40 CFR 262.40)
Facilities that generate greater than 221 lbs per month (SQG & LQG) of hazardous waste are to maintain copies of
each signed manifest. One copy should be retained when the waste is transported from the facility and the second
copy must be signed and supplied by the disposal facility within 45 days after the waste leaves the generator's
facility. The facility's manifests or the signed manifests from the treatment storage and disposal facility receiving
the hazardous waste are to be retained for 3 years.
Records of test results, waste analyses, or other determinations that the waste is hazardous must be kept for 3 years.
!
Biennial Report (40 CFR 262.41)
A Biennial Report (each even numbered year) must be submitted to the USEPA by Small Quantity and Large
Quantity Generators no later than March 1"' (on odd numbered years most states require a report be submitted to the
state agency). A copy of the Biennial Report and Exception Report must be kept for 3 years.
!
Exception Reporting (40 CFR 262.42)
If the hazardous waste generator does not receive a signed copy of the manifest from the disposal facility within 45
days after the waste was accepted by the initial transporter, an Exception Report must be supplied to the state
regulatory agency and a copy of this report must be retained with the manifest. The exception report must be
retained for at least 3 years.
III - 27
PNEAC Fact Sheet: Basic RCRA Recordkeeping for Printers,
!
p. 2 of 3
Hazardous Waste Minimization/Pollution Prevention Requirements (40 CFR 262
App)
Hazardous waste generators using a manifest under the "Generator's Certification" attests to "If I am a large quantity
generator, I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree
I have determined to be economically practicable and that I have selected the practicable method of treatment,
storage, or disposal currently available to one which minimizes the present and future threat to human health and the
environment; OR, if I am a small quantity generator, I have made a good faith effort to minimize my waste
generation and select the best waste management method that is available to me and that I can afford." In other
words a waste minimization and pollution prevention plan is required to be implemented. It is recommended that a
written program be developed and retained on-site.
!
Hazardous Waste Storage Area Inspection (40 CFR 265.1101)
The hazardous waste storage area must be inspected at least every 7 days to monitor leak detection equipment and
detect signs of releases of hazardous waste in or around the containment area. Records of weekly inspections must
be maintained for at least 3 years.
!
Recyclable Materials (40 CFR 266.70)
Persons Who Generate or Store Recyclable Materials That Are Reclaimed to Recover Economically Significant
Amount of Silver and Other Precious Metals (40 CFR 266.70): Generators must maintain manifests when material is
being transported for reclamation. Persons who store these materials (nonspeculatively) must keep records showing
the volume of these materials stored at the beginning of the calendar year; the amount generated or received during
the calendar year; and the amount of materials remaining at the end of the calendar year. No specified retention
period for the documents.
!
Used Oil Generators (40 CFR 279.74)
Generators of used oil are to keep a record of each used oil shipment that is accepted for processing/re-refining and
shipped to a used oil burner, processor/re-refiner, or disposal facility. These records may take the form of a log,
invoice, manifest, bill of lading, or other shipping documents. Records are to be retained for 3 years.
!
Underground Storage Tanks (UST's) (40 CFR 280 & 281)
Owners and operators of new and existing USTs are to maintain records that demonstrate compliance with
performance standards (monitoring, testing, protection, repairs, and closure). These records are to be maintained for
the life of the tank and piping system.
Hazardous Waste Generator Status:
Conditionally Exempt SQG
Small Quantity Generator
Large Quantity Generator
less than 220 lbs/month
221-2205 lbs/month
2205 lbs/month or greater
If no specific records retention time is established, records should be retained for at least five years.
III - 28
PNEAC Fact Sheet: Basic RCRA Recordkeeping for Printers,
p. 3 of 3
(630/472-5019)
(608/262-1083)
III - 29
III - 30
Printers’
Printing
National
Environmental
Assistance
Center
Fact Sheet
PNEAC
www.pneac.org
1-888-USPNEAC
Understanding Air Pollution Permits
Printers, both large and small, need to be aware of the revisions to air pollution permitting requirements that are
being imposed across the country. In the quest for continuing air pollution emission reductions, an increasing
number of printers and other businesses are now subject to Environmental Protection Agency (EPA) and state/local
air pollution control permits because of their volatile organic compound (VOC) and to a lesser degree, hazardous air
pollutant (HAP) emissions. The purpose of this fact sheet is to review the current status of air permitting that
printers of all sizes could possibly be required to meet.
VOC emissions are tightly controlled because they lead to the formation of ozone in the lower atmosphere. Ozone is
a reactive form of oxygen and is a component of smog. EPA has established acceptable levels of ozone that can be
present in the lower atmosphere. Areas exceeding the specific ozone level are classified as not in attainment with the
standard. Non-attainment areas are further classified as to the severity of the ozone problem and can be marginal,
moderate, serious, severe, or extreme. Congress, through the 1990 Clean Air Act Amendments, has established
detailed requirements for states with nonattainment areas to implement in order to clean up the air allowing them to
meet the ozone standard. The Act also details those measures that states with attainment areas need to implement in
order to maintain the their clean air status. These requirements include a new federal operating permit program
under Title V of the act, specific VOC emission reduction measures, and timelines for completion.
The release of toxic chemicals into the air has received considerable attention by both environmental and
community groups who want to know specifically how much of a specific toxic chemical they are being exposed to
and the types of adverse health effects this exposure can cause. The 1990 Clean Air Act Amendments has identified
188 Hazardous Air Pollutants (HAPs) that are of a particular concern. Congress has directed EPA to establish an
operating permit program for businesses that emit HAPs above certain thresholds and to require these businesses to
reduce those emissions through very stringent control requirements called Maximum Available Control Technology
(MACT). A MACT standard has been established for the printing industry and focuses on emissions from
flexographic and rotogravure operations.
Air pollution control requirements are divided into two separate, but related requirements. The first involves permit
requirements and the second is the imposition of specific control requirements. It is important to understand that
there are thresholds associated with each of these separate requirements and the need to obtain a permit does not
necessarily mean that a printer will have control requirements imposed on its facility. Permits serve several roles.
They provide an inventory of air pollution sources. States and local agencies use these inventories in their planning
process for either the further reduction of air pollution or maintenance of current air quality.
The permit also serves as the legal document that incorporates any applicable control requirements designed to
reduce the emissions of certain pollutants. The last important function of permits is that they provide a facility with
the legal basis for operation. Permits should be viewed as a “contract” or agreement between the printer and the
permitting authority. This contract is legally binding and will contain terms and conditions that must be met by the
printer. Failure to meet these terms and conditions can subject the printer to an enforcement action.
III - 31
PNEAC Fact Sheet: Understanding Air Pollution Permits,
p. 2 of 6
Types of Permits
Permits can be issued in several different formats ranging from the simple one-page variety to the very complex.
Some state and local agencies require a permit-to-construct before any new facility can be built or, more
importantly, before a new piece of equipment like a printing press can be installed. Technically, a printer is not
allowed to accept delivery of a new piece of equipment or even begin any work to modify a piece of equipment
without having a valid construction permit. In fact, any “pre-construction activity” such as moving existing
equipment to make room for new equipment, pouring of concrete, or making arrangement for utility connections is
prohibited until a construction permit is obtained. The state/local agencies with a permit-to-construct program will
also generally require a permit-to-operate as well. In some cases, the construction permit can also serve as the
operating permit. It is also important to know that other state/local agencies without a permit-to-construct program
can have a permit-to-operate program. It is imperative that the printer learns and understands the specific permitting
requirements applicable to their operation.
Permits-to-operate look very similar to permits-to-construct and will contain all applicable and enforceable
operating conditions and control requirements. They may also contain recordkeeping and reporting requirements.
Operating permits will have a specified period of effectiveness. Some permits require an annual renewal, but more
permits are now being written with a five-year term.
Besides the construction/operating permit systems described above, some state/local permitting authorities have a
“registration permit” system for those businesses or individual pieces of equipment that do not emit a large amount
of air pollution. Typically, these types of “permits” are less complex and do not require the facility to provide a
significant amount of detail in the application forms. For example, the state of Ohio has a registration permit
program for sheetfed offset lithographic presses that emit less than 3 tons per year of VOCs. As long as the press’s
emissions stay below this level, an operating permit is not required. However, an application for registration needs
to be submitted in order to demonstrate compliance.
Because of the 1990 Clean Air Act Amendments, another type of operating permit was created called a Title V
operating permit. These permits have a five-year term limit and are federally enforceable. They specify all control
requirements, emission limits, recordkeeping, compliance reporting, compliance certification, and monitoring
requirements. Title V permits only apply to certain types of facilities and are administered by the state/local
agencies, but reviewed and approved by USEPA. A federally enforceable permit is one that can be enforced by
EPA. As a result of the Title V operating permit program, a new type of operating permit called a Federally
Enforceable State Operating Permit (FESOP). FESOP permits only apply to certain types of printing operations, but
as the name implies, they are state/local agency issued permits that can be enforced by EPA. Generally, the types of
permits that most printers have to obtain are issued by the state/local are not federally enforceable.
Title V and FESOP permits are unlike any permitting program that has been in place in the past. They require a
detailed analysis of a facility’s emission sources and must address the future utilization of the equipment and
materials. Completing the permit application cannot be simply delegated to the “engineering” department because it
requires input from the operating, sales and marketing, and administration. Current and future strategic business
decisions have to be made within the context of the Title V permitting process. Modifications and changes to the
permit will be difficult and time consuming to accomplish and the printer could loose a business opportunity as a
result.
The need to obtain an air pollution control permit depends on the applicable thresholds that have been set by the
state/local air pollution control agency. The thresholds can be based on several different parameters. Some
state/local agencies use the actual emission rate or amount while others use potential emissions. Some permitting
authorities do not use an emission-based threshold, but use an actual material consumption rate basis to determine if
permits are required.
III - 32
p. 3 of 6
Permitting Thresholds
Permitting thresholds can vary quite dramatically and are driven by federal, state, and local requirements. The
permitting thresholds can be for either an individual piece of equipment (e.g., press) or the entire facility (e.g.,
presses, coaters, bindery, and prepress). They can be expressed in pounds per hour, pounds per day, pounds per
month, tons per year, or based on some type of material consumption limit.
For example, in New York City, all printers regardless of their emission rate are required to have a permit. In the
remainder of New York State, any printer with total VOC actual emissions less than 12.5 tons per year must obtain a
registration permit. Those with actual emissions greater than 12.5 and less than 25 tons per year must obtain a state
facility permit and those with potential emissions greater than either 25 or 50 tons per year must obtain a Title V
permit. The Illinois EPA requires a permit for any printer that uses more than 750 gallons per year of VOCs, while
Pennsylvania has both an actual and potential emission permit thresholds.
The threshold for the new federal Title V operating permit uses a facility’s annual potential emissions (e.g., potential
to emit) to determine applicability and applies to both VOC and hazardous air pollutant (HAP) emissions. The HAP
threshold for permitting is 10 tons per year for a single HAP chemical and 25 tons per year for all HAP single
chemical(s) or HAP categories combined. These thresholds are universal in that they apply across the entire country
and are not tied to any attainment or nonattainment classification.
The Title V thresholds for VOC emissions are dependent upon the geographical location and severity of the nonattainment problem. The only extreme area is Los Angeles, CA and the threshold is 10 tons per year. Severe areas
like Chicago, IL, Philadelphia, Pa, and New York City area have thresholds of 25 tons per year. Serious areas like
Atlanta, GA and the entire ozone transport region have thresholds of 50 tons per year. The ozone transport region
includes the entire area bound by Pennsylvania, Maryland, District of Columbia, Delaware, New York, New Jersey,
Connecticut, Massachusetts, New Hampshire, Vermont, Rhode Island, and Maine. Moderate and Marginal areas
such as St. Louis, MO have thresholds of 100 tons per year. The new nonattainment classification system can
extend to several counties that physically touch the nonattainment area.
FESOP permits can be called by different names, but as the name implies, they are federally enforceable operating
permits. Printing operations whose potential emissions exceed the Title V permit threshold with actual emissions
below the threshold can qualify for a FESOP permit. Among the other applicable control requirements, FESOP
permits will contain additional limits on hours of operation, input material consumption rates, or emissions that will
ensure that the facility will not emit pollution at rates greater than the major source threshold. FESOP permits are
generally not as rigorous as Title V permits and do not have the same fee structure associated with them.
Potential to emit
Potential to emit (PTE) is defined as the greatest amount of emissions that could be released from a piece of
equipment or facility based on its maximum design capacity or maximum production. Potential to emit
determinations must assume the equipment will run 24 hours/day 365 days/year or 8,760 hours/year. The only way
to avoid these assumptions is to have federally enforceable limits imposed on an operation that either limit the hours
of operation, material input rate, or require the use of an add-on control device such as an oxidizer. There exists
considerable controversy in how PTE is to be calculated, and how it applies to printers. Because printers produce a
variety of products with various coverages, the amount of ink, fountain solution, coating, and other materials applied
change the job and are difficult to characterize in PTE calculations.
There are at least three different ways to calculate potential emissions from a printing press. The first method is a
worst case. It assumes 100% application of all input materials such as inks, coatings, fountain solutions, and
cleaning solvents on all cylinders at maximum press speed for 8,760 hours/year. In a study performed on a printer
using water-based flexography and letterpress to manufacturer corrugated boxes, their 5 tons per year actual
emissions climbed to 4,000 tons by assuming the worst case scenario. While this method is not realistic, some state
III - 33
p. 4 of 6
agencies insist that printers use this method. The second method, which is preferred by industry, takes the actual
average annual hourly emission rate and multiplies it by 8,760 hours/year. In the same study performed on the
corrugated manufacturer, the potential emissions using this approach would be 20 tons/year.
The third method further confuses the permitting threshold determination. Some states including Illinois and
Wisconsin, use a maximum theoretical emission (MTE) rate for rule applicability. The concept of MTE is the same
as PTE in that it requires that a printer assume equipment is running at its maximum design capacity or maximum
production rate for 24 hours/day 365 days/year or 8,760 hours/year. It does not allow for any reduction in emissions
due to limits on the hours of operation, material input rate, or use of an add-on control device such as an oxidizer.
Because of the way PTE is applied, it has affected many small printers with extremely low actual emissions. Simply
because their potential emissions made them "major sources," they are subject to more stringent regulation. EPA has
recognized that small businesses that are not physically capable of emitting the "potential" described in the
regulations should not be subjected to the requirements being imposed on the much larger major sources. These
small businesses possess neither the technical nor financial resources to respond to these requirements.
EPA PTE Guidance
On April 14, 1998, the Environmental Protection Agency released its Potential To Emit (PTE) Guidance for Specific
Source Categories. The guidance was issued for state and local air pollution control agencies to use in setting rules
to exempt small sources of air pollution from being subject to full regulation. It can be downloaded from
http://www.epa.gov/ttnsbap1/access.html.
As described above, the current air pollution control regulations could cause individual printing operations to be
considered "major sources" of air pollution and required to obtain a Title V operating permit based on their
potential, not actual, air pollution emissions. The new Potential To Emit (PTE) Guidance for Specific Source
Categories will allow state and local air pollution agencies to exempt individual small businesses from being
considered "major sources".
The EPA PTE guidance document will allow state and local air pollution control agencies to establishing rules
exempting small sources of VOC and HAP emissions from being considered "major" sources. Printers qualifying
under the guidance would not be subject to a Title V or Federally Enforceable State Operating Permit and all of the
control requirements that are applied to these types of operations.
The guidance utilizes a "cap" approach. If a source can demonstrate through records that actual emissions are less
than 50 percent of the major source threshold for their given area, the source will be treated as a minor source. To
further simplify determinations for small printers, a quick reference threshold chart was created with consumption
levels for those materials that account for the largest source of VOC or HAP emissions in a printing operation.
Indicators were established for each printing process type (see chart below). For example, a sheetfed offset
lithographic printer typically has two principal sources of VOC emissions or environmental indicators-cleaning
solvents and fountain solution additives, namely isopropyl alcohol. If the printing establishment is located in
Pittsburgh, a marginal ozone non-attainment area, it could use 14,275 gallons of cleaning solvent and fountain
solution additives combined before it would be considered a major source.
Even if printers exceed the levels listed in the table, they can still take advantage of this guidance if their total actual
emissions do not exceed more than 50 percent of the major source threshold definition. A technical support
document to the guidance has been prepared by EPA and contains the formulas to be used in calculating emissions.
Furthermore, the environmental indicators identified have to account for 90 percent or more of the emissions
released from the facility. If other activities-ink jetting, for instance-contribute more than 10 percent of the
emissions, then the table provided in the EPA guidance cannot be used and printers must calculate their actual
emissions to determine if they qualify under the guidance.
III - 34
p. 5 of 6
Some printing operations will not qualify under the new guidance, including printers with actual emissions greater
than 50 percent of the major source threshold and those using add-on control devices such as after-burners or
oxidizers. Because of the complexities associated with control devices, printers utilizing control devices were
excluded from the new guidance, even though their actual emissions could be below 50 percent of the major source
threshold.
To help these printers, EPA has been petitioned to accept an approach that better approximates a printer's ability to
run at maximum conditions. For these printers, a more realistic approach to determining PTE would be to take the
actual average hourly emission rate and multiply it by 8,760 hours per year.
This approach provides a better approximation of printers' ability to run at maximum production capacities by
extrapolating the current actual emissions into potential emissions that better reflect a realistic increase in
production. This approach assumes printers would continue to produce the same mix of jobs, but they would be
produced every hour in the year. Even though printers cannot physically run a press 8,760 hours per year, this takes
into account any variations due to ink coverages and increases in productivity. Printers can readily determine actual
average emissions based on material balances and hours of operation from production data. The EPA's current
approach requires printers to make assumptions about material use and equipment utilization that are open to
challenge by the agency.
VOC and HAP Emission Calculations
Besides finding the appropriate threshold to determine whether a permit is required, the printer must also determine
their VOC/HAP emission levels. This is accomplished by first deriving material use information. The materials to
consider include, but are not limited to inks, extenders, diluents, fountain solutions, fountain solution additives,
coatings, cleaning solutions, and other miscellaneous chemicals. Material use is typically defined as the amount
purchased minus the change in inventory, minus the amount discarded. The amount released is determined by
multiplying the amount used by the VOC content and if appropriate, an emission factor. An emission factor is the
number used to reflect the actual release of materials. For example, a 5% emission factor for VOCs is applied to all
sheetfed offset lithographic inks. Studies conducted by the printing industry have shown that 95% of VOCs in
lithographic inks are retained by the substrate. For more information see the other PNEAC fact sheet(s) on
determining VOC and HAP emissions from the appropriate printing process.
Summary
Every printer, whether operating a large or small facility, must know and understand the air pollution permit
regulations applicable to their facility. Knowing and complying with these regulations are crucial for printers
because it allows them to legally operate their businesses under the current regulatory requirements. Even if a printer
is not legally required to have a permit in order to operate their business, it is equally important to know and have
proven and documented that they are not subject to the regulation. This aspect of the printer’s business needs to be
actively managed just like other important aspects of the business. In the long run, an active approach benefits the
printer rather than the alternative of ignoring regulations, where it will ultimately becomes an enforcement action
and a business liability.
III - 35
p. 6 of 6
•
•
•
(630/472-5019)
•
(608/262-1083
Reasonable effort has been made to review and verify information in this document. Neither PNEAC and its partners,
nor the technical reviewers and their agencies, assume responsibility for completeness and accuracy of the
information, or its interpretation. The reader is responsible for making the appropriate decisions with respect to their
operation, specific materials employed, work practices, equipment and regulatory obligations. It is imperative to verify
current applicable regulatory requirements with state and/or local regulatory agencies.
III - 36
POLLUTION PREVENTION PROGRAM
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT,
HEALTH, AND NATURAL RESOURCES
SILVER RECOVERY SYSTEMS AND WASTE REDUCTION IN PHOTOPROCESSING
There are several reasons to be interested in the recovery of silver from photoprocessing waste. Silver
is a valuable natural resource of finite supply, it has monetary value as a recovered commodity, and
it's release into the environment is strictly regulated. In photoprocessing, silver compounds are the
basic light-sensitive material used in most of today's photographic films and papers. During
processing, particularly in the fixing bath or bleach-fix, silver is removed from the film or paper and
is carried out in the solution, usually in the form of a silver thiosulfate complex.
Major sources of recoverable silver are: photoprocessing solutions, spent rinse water, scrap film, and
scrap printing paper. As much as 80 percent of the total silver processed for black and white
positives and almost 100 percent of the silver processed in color work will end up in the fixer
solution. Silver is also present in the rinse water following the fixer or bleach-fix due to carry-over.
Economic considerations include initial equipment cost, the amount and value of silver recovered, and
the return on investment. Space and energy requirements, day-to-day attention required,
maintenance, and reliability are also important. It is necessary to know the amount of silver available
for recovery, the total volume of fixer and bleach-fix solutions used in processing, and the expected
performance of the recovery method under consideration.
Several technologies exist for recovering silver onsite. The most common methods of onsite recovery
from the fixer and bleach-fix processing solutions involve metallic replacement, electrolytic recovery
and chemical precipitation. Ion exchange and reverse osmosis are other methods that can be used
alone or in combination with conventional silver recovery systems. However, these are generally
considered suitable only for dilute solutions of silver. A silver recovery system can be devoted to a
single process line or can be used to remove silver from the combined fixer from several process lines
in a plant.
The most widely used silver recovery method for large operations is electrolysis, where the silver is
recovered from solution by electroplating it on a cathode, Fig. 1. A controlled, direct electrical
current is passed between two electrodes suspended in the silver-bearing solution. Silver is deposited
on the cathode in the form of nearly pure silver plate. The cathodes are removed periodically, and the
silver is stripped off for sale or reuse. While this method requires a substantially larger capital
expenditure and needs an electrical connection it does have the advantage over other methods in that
it yields virtually pure silver. This results in lower refining and shipping costs and it does not
contaminate the fixer, thereby permitting its reuse for some processes. When properly operated, 95
percent of the potential available silver can be recovered. Combining electrolytic silver recovery with
in-situ ion exchange can result in more than 99.5 percent silver recovery efficiency.
A recirculating electrolytic recovery system has advantages over systems that only remove silver.
Silver is removed from fixer solution by the recovery cell which is connected "in line" as part of a
III - 37
N. Carolina DEHNR Fact Sheet: Silver Recovery Systems and Waste Reduction in Photoprocessing, p. 2 / 5
recirculation system. Fixer solution reclaimed by electrolytic silver recovery can have limited reuse
in the photoprocess. By recirculating the desilvered fixer to the in-use process tank, less fresh fixer
solution is needed to replenish the bath. Fixer replenishment can be reduced 20 percent or more
without degradation of product quality. Chemical replenishment can be managed through the frequent
and consistent use of test strips. A properly designed recirculating system can lower the silver in the
fixer from a concentration of 1 ounce/gal. to 1 ounce/100 gals. The amount of silver carried over to
the rinse water is similarly reduced.
Metallic replacement requires little capital expenditure for equipment and requires only a few simple
plumbing connections. The equipment consists of a plastic container, a plastic-lined steel or stainless
steel drum filled with metal, usually steel wool, and some plastic hose and plumbing connections.
See Fig. 2. Silver is recovered when the silver-bearing solution flows through the cartridge and
makes contact with the steel wool. The iron goes into solution as an ion, and the metallic silver is
released as a solid to collect in a sludge at the bottom of the cartridge or is deposited on the steel
wool. The yield a user can expect is determined by the silver concentrations in solution, the volume
of solution that is run through the cartridge, and the care with which the operation is managed. When
silver is no longer effectively removed, the silver-bearing sludge is sent to a refiner who will refine
it and pay the customer for the recovered silver.
Figure 1. Diagram of an electrolytic silver
recovery cell.
Figure 2. Diagram of a metallic replacement
silver recovery cartridge
The disadvantages of these two methods are that neither can recover more than 95 percent of the
silver from concentrated solutions, effectively treat dilute wastewater, nor remove other metals from
the effluent.
Another option is chemical precipitation with sodium sulfide, sodium borohydride or sodium
dithionite. This can remove virtually 100 percent of the silver and most other metals from
photographic effluent. With the addition of alkaline sodium sulfide and the resulting precipitation of
III - 38
silver sulfide, levels of soluble silver below 0.1 mg/L are possible. However, the more difficult part
of the process is the separation of the precipitate from the liquid. Total silver levels of 0.5 to 1.0
mg/L are usually obtained due to filtration limitations. This process requires only a small capital
expenditure and uses chemicals which are relatively inexpensive. It is not as widely used as the
electrolytic or metallic replacement methods because of the inconvenience of handling large amounts
of chemicals, the separation process required, and the problem of concentrating finely precipitated
silver sulfide particles into a sludge that can be dried and refined. Also, careful pH control is required
to avoid generation of highly toxic hydrogen sulfide gas.
Ion exchange is generally used for effective recovery of silver from rinse water or other dilute
solutions of silver. The ion exchange method involves the exchange of ions in the solution with ions
of a similar charge on the resin. The soluble silver
thiosulfate complex is exchanged with the anion on
the resin. This exhaustion step and is accomplished
by running the solution through a column containing
the resin, Fig. 3. For large operations, the next step
is the regeneration step in which the silver is removed
from the resin column with a silver complexing agent
such as anmnonium thiosulfate. This step includes
several backwashes to remove particulate matter and
excess regenerant before the next exhaustion step is
initiated. Silver is then recovered from the thiosulfate
regenerant with an electrolytic recovery cell. For
Figure 3 Ion Exchange system.
smaller operations an alternative to performing the
regeneration step onsite would be to remove the resin from the column and send it to a refiner for
silver reclamation. Important factors in considering an ion exchange system for silver recovery are;
selection of the resin, flow rate of the silver-bearing solution, column configuration, and selection of
the regenerant. It has been demonstrated that the use of ion exchange can reduce the silver
concentration in photographic effluent to levels in the range of 0.5 to 2 mg/L and can recover over
98 percent of the available silver. If this method is used as a tailing method after primary recovery
by electrolysis, levels in the range of 0.1 to 1 mg/L can be obtained.
Reverse osmosis (RO) is also used for dilute solutions. RO uses high pressure to force the
silver-bearing solution through a semipermeable membrane to separate larger molecules, such as salts
and organics, from smaller molecules like water. The extent of separation is determined by membrane
surface chemistry and pore size, fluid pressure, and wastewater characteristics. For removal of
silver, after-fix rinse water is flow-equalized, filtered, and pumped through an RO unit. Once the
silver is separated from the water in this manner it can be recovered by conventional means such as
metallic replacement, electrolytic recovery or chemical precipitation. Operating problems include
fouling of the membrane and biological growth.
Evaporation is another option for managing waste photographic solutions. The wastewaters are
collected and heated to evaporate all liquids. The resulting sludge is collected in filter bags. These
bags can be sent to a silver reclaimer for recovery. The major advantage of the evaporation technique
is it achieves "zero" water discharge. This method would be useful to operations that do not have
III - 39
access to sewer connections or wastewater discharge. A disadvantage is that the organics and
ammonia in the waste solution may also be evaporated, creating an air pollution problem. A charcoal
air filter may be necessary to capture the organics. Filter purchase, disposal, and electrical power add
to operating costs.
An alternative to onsite recovery is to collect the bleach/fix in containers and have a silver recovery
contractor haul it away to reclaim the silver. For this service the photolab may be paid only about 20
percent of the silver value. This low percentage may be partially offset by its high silver recovery
yield. Off site recovery can be done on a larger, more efficient scale than onsite recovery. The small
quantity generator or the generator who desires a minimum commitment may find advantages in off
site services.
Silver can be recovered from scrap film and paper by soaking the material in spent fixer solution.
Once dissolved in the fixer, the silver can be recovered through any of the silver recovery processes
used by the lab. There are also businesses which will buy scrap photographic film and paper from the
photoprocessor.
There are additional actions that should be considered by photolabs to minimize waste.
• Inventory of chemicals should be controlled so that they are used before their expiration date.
• Solutions should be made up only in quantities to meet realistic processing volumes .
• Floating lids should be used on developer solution tanks to prevent evaporation and loss of
potency.
• Silver recovery unit operating conditions should be carefully monitored and maintained within
vendor specifications.
• Spent rinse water can be treated to restore purity and recycled for rinsing.
• The use of squeegees can reduce considerably the amount of liquid carried out of the solution by
the film.
• Common sense safeguards such as keeping the mixing area clean, avoiding mixing of dry
chemicals where airborne particles can cause contamination of other solutions, and use of
separate mixing tanks for developers will minimize contamination or errors in mixing.
• Counter-current rinsing can be used to reduce water consumption. The basic concept of
counter-current rinsing is to use the water from previous rinsings to contact the film at its most
contaminated stage. Fresh water enters the process only at the final rinse stage.
• Bleach, bleach-fix, fix, and developer can be recycled and reused.
For information on vendors and purchasers of recovered silver contact:
Office of Waste Prevention
Pollution Reduction Program
N. C. Department of Environment, Health & Natural Resources
Post Office Box 27687
Raleigh, NC 27611-7687
919-571-4100
III - 40
REFERENCES
1. Eastman Kodak Company “Disposal and Treatment of Photographic Processing
Solutions In Support of Clean Water,” 1982.
2. Arthur D. Little, Inc., “Waste Audit - Photoprocessing Industry” prepared for Alternative
Technology Section, Toxic Substances Control Division, California Department of Health
Services, April 1989.
3. Thomas P. Cribbs and Thomas J. Dagon, Eastman Kokak Company, "A Review of Waste
Reduction Programs in the Photoprocessing Industry."
4. Monica E. Campbell and William M. Glenn, The Pollution Probe Foundation,
"Profit from Pollution Prevention," 1982.
Date: May, 1992
For more detailed information about pollution prevention opportunities in the printing industry
visit the PNEAC web site at www.pneac.org, call the PNEAC toll free number at
1-888-USPNEAC, or contact :
•
•
•
•
Graphic Arts Technical Foundation - Gary Jones or Rick Hartwig (412/741-6860)
Illinois Waste Management and Research Center - Gary Miller (217/333-8940) or Debra
Jacobson (630/472-5019)
University of Wisconsin - Wayne Pferdehirt (608/265-2361), Keith West (920/465-2940)
or Bob Gifford (608/262-1083)
Reasonable effort has been made to review and verify information in this document. Neither PNEAC and its
partners, nor the technical reviewers and their agencies, assume responsibility for completeness and accuracy of the
information, or its interpretation. The reader is responsible for making the appropriate decisions with respect to
their operation, specific materials employed, work practices, equipment and regulatory obligations. It is imperative
to verify current applicable regulatory requirements with state and/or local regulatory agencies.
III - 41
III - 42
Environmental Compliance Checklist for Printers
Prepared by Gary Jones, Graphic Arts Technical Foundation (GATF) Revised 4/18/1996
This information is reprinted with permission from "Regulatory Concerns for the Printer: A Checklist,"
produced by the Graphic Arts Technical Foundation (GATF), copyright 1996.
A. Air
q
Annually prepare detailed facility wide omissions inventory which includes emissions of Volatile
Organic Compounds (VOCs), Hazardous Air Pollutants (HAPs) Nitrogen Oxides (NOx), Sulfur
Oxides (SOx) , Carbon Monoxide (CO) and Particulate Matter (e.g., paper dust or uncontrolled
ink oil emissions). Emissions should be determined for both actual and potential emissions.
Sources of emissions include film and plate processors, some proofing systems, printing presses,
bindery lines, cyclones, bailers, boilers, dryers, furnaces, and other fuel combustion equipment.
Emission determinations can be based on either test data or mass balance incorporating
appropriate engineering estimates and emission factors.
q
Determine thresholds for registration construction/installation and operating permits for testing
operations which could be equipment specific (e.g., press, control device, or boiler) or facilitywide. Many state/local permitting programs are now focusing on facility permits and not per
equipment permits. The thresholds for registration and permits depend upon the current
attainment/nonattainment classification of the area, specific regulations being enforced by the
appropriate government agency, and the amount or rate of air pollutants being emitted. Contact
state/local agency to obtain a copy of permit and air pollution control requirements;
q
Obtain appropriate permit(s) for existing operation. Keep copies of all permit application
packages and omission determinations.
q
Determine permit thresholds for installation of new equipment to existing operations. New
equipment could include presses, coaters, omission control devices, boilers, cyclones,
evaporators, distillation units, and some proofing and bindery equipment. The thresholds for new
equipment and processes depend upon the current attainment/nonattainment classification of the
area, specific regulations are enforced by the appropriate government agency, and the amount/rate
of air pollutants being emitted. Contact state/local agency to obtain a copy of permit and air
pollution control requirements.
q
Obtain appropriate permit(s) for existing operation. Keep copies of all permit application
packages and emission determinations.
q
Determine thresholds for modifications to existing equipment that would require a permit
amendment. Modifications to existing equipment includes changes in materials used (e.g., inks,
dampening solutions, coatings, cleaning solvents, and other chemistries), increase in operating
speeds, or material application rates. Keep copies of all correspondence and subsequent permit
amendments. Modifications do not need to lead to an increase in omissions especially if an
existing permit dictates the use of specific equipment, throughput rates, materials or chemicals.
All emission increases need to be closely examined.
q
Determine thresholds for exemption. Some equipment/facilities may be exempt from registration
and permit requirements. Exemption level is dependent upon attainment/nonattainment
classification of area, date of installation, and rate/amount of emissions. All exemption
determinations need to be documented.
q
Establish a system to track all permits and ensure that permit renewals are filed in a timely
manner.
III - 43
GATF: Environmental Compliance Checklist for Printers
p. 2 of 16
q
Document all actions taken to reduce or eliminate emissions. Changing process materials (e.g.,
use of isopropanol substitutes) or shutting down equipment could generate reductions. Typically,
all creditable emission reductions must have occurred after 1990. Some states have specific
forms to file for emission reduction credits. These credits can be used internally to net emission
increases or sold to another company requiring offsets for emission increases.
q
Establish appropriate recordkeeping and monitoring system. The system should be designed to
allow for the demonstration of compliance with permit conditions and detection of potential
violations. Permit conditions or regulations may require records of materials use, hours of
operation, pollution control logs, temperatures of combustion or fountain solution, routine tests,
etc. Depending upon the specific permit condition, it may be appropriate to periodically sample
and test incoming materials, emissions, and control devices.
q
File semi-annual emission reports and annual certification. Some permits, especially Title V,
require facilities to submit reports and certification of compliance.
q
File annual emission statements. Emission statements can be required of sources/facilities even if
they are exempt from permitting. Thresholds for omission statements vary according to specific
state/local agency and attainment/nonattainment classification. Some states require emission
statements from facilities with emissions greater than 3 tons per year. Many states require them
from facilities with emissions greater than 10 tons per year.
q
If necessary, develop and implement (when required) an emission reduction plan. Emission
reduction plans typically address omissions of VOCs and NOx during excessive day(s) of ozone
formation. Depending upon severity of ozone formation, actions taken could be minor (e.g.,
delaying certain non -critical operations, car pooling, keeping chemical containers closed) or
major which would involve production curtailment.
q
Keep records of any telephone conversation, correspondence, testing, and calculations; and send
all correspondence to any agency by return registered mail.
B. Water Discharges
q Inventory all sources of wastewater discharges.
q
Determine fate of all sink drains, floor drains, processor and equipment drains and sewage lines.
Direct discharges of wastewater are prohibited, unless permitted (see NPDES requirements
below).
q
Maintain copies of sewer connect permit or notification and other correspondence.
q
Annually determine the total wastewater flow in gallons. The amount resulting from industrial
water use should be either measured or estimated. Sources of information for estimating total
flow include records indicating the volume of water purchased, other water purchased with
process chemistry like water-based coatings, water-based inks, film and fountain solution
concentrates, and any water pumped from wells. If necessary, gallons per month and day may
also have to be determined.
q
Contact local publicly owned treatment works (POTW or sewer authority for permission to
discharge process wastewater effluent and for permitting requirements and obtain a copy of the
sewer code.
q
Most POTWs require silver recovery and may have specific limitations for certain chemicals,
heavy metals, and physical characteristics (e.g., Copper, Ammonia, pH, COD, and BOD)
contained in wastewater effluent. Contact POTW to determine specific limits.
III - 44
p. 3 of 16
q
Establish a system to track all permits and ensure that permit renewals are filed in a timely
manner.
q
Some states/local POTWs require employees who operate and maintain any pretreatment
equipment to be trained and certified as wastewater treatment operator. Contact local
POTW/state agency to determine requirements.
q
Conduct testing of wastewater discharges. Permits and/or sewer code may require periodic
discharge testing and monitoring reports of effluents. Contact local POTW to determine
requirements.
q
When conducting wastewater sampling, especially during compliance determination testing, take
a sample of incoming water to use as baseline. The preferred sampling protocol is a multiplehour (ideally, 24-hour) composite sample versus a grab sample.
q
Establish policies and procedures to prevent inadvertent release of prohibited materials. EPA ban
on discharging of oil/grease, materials that could create a fire or explosion, and chemicals that
could produce toxic vapors and fumes. Many POTWs allow a small amount of oil/grease
discharge, usually in the 50- to 100-ppm range. Some ignitable, especially those that contain less
than 25% alcohol, could also be exempt from the discharge ban.
q
Permanently block all open floor drains in the facility or if floor drain is necessary, provide drain
covers. In case of a spill, open floor drains provide a means to allow spilled chemicals to be
discharged directly to the POTW and depending upon the material spilled, in a concentrated form.
Alternately, a raised pipe or other device could be provided to prevent spilled chemicals from
being released through the open floor drain. The alternate approach cannot present a tripping
hazard.
q
Provide secondary containment for all processors or equipment using chemistry to help contain
spills and prevent than from spreading. The secondary containment should be capable of holding
at feast 110% of the volume of the contents of a single chemical container or processor. If mom
than one container or processor is included in the containment area then the secondary
containment must be capable of holding 150% of the volume of the largest primary container or
10% of the aggregate volume of all primary containers, whichever is greater.
q
Assemble and locate appropriate spill response and neutralization materials in prepress area.
Materials include a wide variety of absorbents, two or three mops, mop bucket with wringer,
several squeegees, several push brooms, traffic tape, spill sign, small shovel, clean container with
lid for receiving spilled materials and contaminated cleanup material, weak acids (for developer),
alkali material (for fix), containers, and personal protective equipment, (e.g., rubber gloves,
goggles, aprons, shoe covers, and general purpose respirators).
q
Discharges of more than 33lbs/month of hazardous waste, especially listed ones, or any acute
wastes mixed with domestic sewage requires written notification to local EPA office, state waste
agency, and POTW.
q
Significant dischargers (those discharging more than 25,000 gallons/day) and occasionally
smaller dischargers may be required to submit biannual effluent testing data and develop plans to
respond to accidental spills and discharges. Contact local POTW to determine requirements.
q
File annual industrial wastewater discharge survey. Some local POTWs require annual reporting
of industrial effluents. Some surveys can be extensive.
III - 45
q
p. 4 of 16
Install and maintain backflow prevention system. Some water authorities require backflow
prevention devices on each piece of process equipment connected to incoming water supply.
Some water authorities require annual testing and registration of all backflow preventers.
National Pollutant Discharge Elimination System (NPDES) permit
q
Obtain permit for discharges of industrial and sanitary wastewater effluent, non-contact cooling
water, and boiler blowdown water to navigable waterways (e.g., streams, creeks, lakes, rivers,
etc.).
q
Obtain NPDES stormwater discharge permit for any rain or snowmelt runoff exposed to
industrial activity (e.g., contaminated with chemicals) and discharged to navigable waterways.
NPDES permits can be either group, individual, or general. Printers constructing shelters over
sources of contamination (e.g., dumpsters) or bringing materials inside can exempt themselves
from this regulation.
q
If stormwater discharge permit is required, determine pollutant monitoring, sampling and testing
requirements. Keep copies of all testing results.
q
If a stormwater discharge permit is required, develop and implement pollution prevention plan
designed to minimize or eliminate sources of pollution.
q
Contaminated stormwater discharges to municipal systems require notification to the
municipality. Printers constructing shelters over sources of contamination (e.g., dumpsters) or
bringing materials inside can exempt themselves from this regulation.
q
Establish tracking system to ensure permit renewals are filed in a timely manner.
Septic system:
q
Ensure that all septic systems are installed in accordance with state/local requirements. Permits
for installation may be necessary.
q
Conduct annual inspection of septic system to ensure it is operating properly. Same state/local
agencies require annual inspections by qualified engineers.
q
Prohibit discharges of industrial wastewater effluent into septic system. In some instances, states
will allow discharges of certain industrial wastes into septic systems, but dischargers will
typically be required to obtain a NPDES permit.
q
If a septic system had been previously used and/or removed, keep copies of all sampling and test
results indicating contamination with industrial effluents. If remediation actions were taken,
copies of all pertinent records and test results must be maintained.
Drinking water:
q
Make sure that lead-free solder for pipes and drinking water fountains are used.
q
Use lead-free drinking fountains that have not been cited/recalled for lead-lined cooling tanks.
q
Water being supplied from wells for drinking may have to be periodically tested for presence of
contaminants. This testing is usually mandatory for plants with more than 25 employees.
III - 46
p. 5 of 16
C. Hazardous Waste
q
Determine if hazardous waste is generated. A waste is any material that has been abandoned or
discarded that iii unsuitable for use without treatment or recycling. The U.S. Environmental
Protection Agency (USEPA) has established a protocol of using process knowledge, chemical
identification, or testing (flashpoint, pH, Toxicity Characteristic Leaching Procedure, etc.) to
determine classification of wastes. USEPA also provides for many exceptions, while some state
agencies do not observe the same exemptions. For example, in some states, silver-laden fixer
must be counted as a hazardous waste, while USEPA exempts it. In addition, some states regulate
other materials like used oil as hazardous wastes. Please check with your state agency to see if
they regulate materials USEPA does not.
1.
Ignitable Wastes
q
A liquid that has a flashpoint below 60C or 140F. Aqueous solutions containing less than
24% alcohol by volume are not included in this definition.
q
A non-liquid capable of spontaneous and sustained combustion under normal conditions.
q
An ignitable compressed gas as defined by DOT.
q
An oxidizer as defined by DOT.
2.
Corrosive Wastes
q
An aqueous material with a pH less than 2.0 or greater than 12.5.
q
A liquid that corrodes steel at a rate greater than one-forth inch per year at a temperature of
55C or 130F.
3.
Reactive Wastes
q
Normally unstable and reacts violently without detonating.
q
Reacts violently with water.
q
Forms an explosive mixture with water.
q
Generates toxic gases, vapor, or fumes when mixed with water.
q
Contains cyanide or sulfide and generates toxic gas vapors or fumes at a pH between 2 and
12.5.
4.
Toxic Wastes
q
Requires testing by Toxicity Characteristic Leaching Procedure (TCLP) for 25 organic
chemicals, 8 metals, and 6 pesticides and sets threshold levels above which the waste would
be classified as hazardous.
III - 47
5.
p. 6 of 16
Listed Wastes
q
Waste contains or is completely composed of chemicals from four separate lists of hazardous
wastes. Some "F" listed wastes must contain chemicals on the list that exceed at least 10% of
the original mixture.
Generator Status
Determine generator status (e.g., exempt, small, or large), which is dependent upon the amount of
hazardous waste generated per month. Some states do not recognize distinctions between exempt and
small and between small and large quantity generators, thus requiring either exempt quantity
generators to observe small-quantity generator requirements and small-quantity generators to observe
large-quantity requirements.
q
Exempt quantity generators are those generating less than 220 pounds/month of hazardous
waste and less than 2.2 pounds/month of acute waste.
q
Small quantity generators are those facilities who generate between 220 and 2,200
pounds/month of hazardous waste and less than 2.2 pounds/month of acute waste.
q
Large generates over 2,200 pounds/month of hazardous waste and/or more than 2.2
pounds/month of acute waste.
Wastes to count toward generator status (Note: This list is not all inclusive.):
q
All listed and characteristic wastes that are accumulated on-site for any time period.
q
All listed and characteristic wastes that are packaged and transported off-site.
q
Placed in a regulated onsite treatment or disposal unit.
q
Still bottoms or slugs removed from storage tanks.
q
Contaminated soil or spilled chemistry.
q
Any material mixed with a listed hazardous waste.
q
Unused inventory that has not been used within one year.
Wastes not to count toward generator status (Note: This list is not all-inclusive.):
q
Sewer discharges sent directly to a POTW, as long as POTW grants permission.
q
Sewer discharges from a neutralization (pH) unit.
q
Wastes continuously reclaimed on-site in a closed pipe system.
q
Any material already counted once during a calendar month, treated or reclaimed, and
used again.
III - 48
p. 7 of 16
q
Used oil sent off-site for disposal or recycling and not mixed with listed hazardous waste
and contains less than 1,000 ppm total halogens. Chlorofluorocarbon-bearing compressor
oils are exempt, if not mixed with other oils and recycled or reclaimed. Oils burned
either onsite or offsite for energy recovery that contain more than 2 ppm cadmium, 10
ppm chromium, 100 ppm lead, or 5 ppm arsenic must be burned in specially equipped
furnaces, boilers, or incinerators with scrubbers.
q
Any material left in containers emptied through conventional means. If a container is
less than 110 gallons, then one inch or 3% by weight of the total capacity is allowed in
the container for it to be considered empty. For example, 55-Gallon drums are allowed
one inch of material remaining in it for them to be considered empty. A five-pound ink
can would be allowed to have about one-eighth of an inch of ink in it to be considered
empty. Containers greater than 100 gallons are allowed either one inch or 0.3% by
weight of the total capacity. Containers with acute wastes must be tripled rinsed.
q
For reusable shop towels contaminated with hazardous waste (e.g., some solvents and
inks), states may require written contract with laundry facility; laundry uses own trucks to
pick up and deliver shop towels; shop towels not saturated with solvent and pass paint
filter test. (Under these conditions, shop towels being washed and returned should be
exempt from regulation). Some states regulate all reusable and disposable solvent-laden
shop towels (regardless of amount) as hazardous and require manifests, while other states
have established management practices to exempt them from being classified as
hazardous. It is important to minimize the amount of excess solvent placed on the shop
towels to help launderers meet their wastewater discharge limits. Obtain copy of state
interpretation of solvent-laden reusable cleaning shop towels.
q
Some states classify waste and used oil recovered silver and silver-bearing wastes,
fluorescent and high-intensity lights (mercury content), PCBs, ethylene glycol (antifreeze) and uncontaminated lithographic ink as hazardous.
q
Fluorescent lights properly disposed. Some states regulate them as hazardous because of
the mercury content.
q
Batteries and recalled pesticides classified as universal wastes and can be taken to local
collection center without manifest.
Exempt Quantity Generator Requirements:
q
Determine amount of hazardous waste generated per month.
q
Label and store wastes according to requirements (see below).
q
Ensure wastes are properly disposed at licensed treatment, storage, and disposal facility.
q
Can use own vehicle to transport waste to disposal facility.
q
Can participate in local neighborhood hazardous waste collection program.
q
Total hazardous waste accumulation not to exceed 2,200 pounds.
q
Spills or accidental releases of listed materials above reportable quantities require notification
to national response center (800/424-8802), state, and local governmental agencies. Obtain
proper telephone numbers for appropriate agency.
III - 49
p. 8 of 16
Small Quantity Generator Requirements:
q
q
Collect, label and store wastes according to requirements (see below).
q
Obtain facility identification number for off-site shipment of hazardous waste to a treatment
or recycling facility. Number is specific to location and is not transferable.
q Change in type or volume of hazardous waste stream requires notification of state agency
by refiling the notification of hazardous waste activity form.
q
Manifests for all shipments of hazardous wastes with all proper EPA code(s), land ban
notification. Some states allow for contractual reclamation or recycling that does not require
a manifest (e.g., solvent reclamation or reusable rags).
q Generator must keep copies of manifests for at least three years and land ban forms for
five years. Some states require twenty-year retention for manifests. Permanent manifest
storage for Superfund purposes is strongly suggested.
q Exception report for missing manifest must be filed within 60 days of shipment.
q
Complete annual or biennial report. Some states require small quantity generators to file
reports on waste generation and minimization activities.
q
Total hazardous waste accumulation not to exceed 13,200 pounds in any 180 day period. A
270 day storage period is allowed if waste shipment to disposal facility is over 200 miles.
Some states do not recognize the federal time limits and impose tighter limits.
q
Confirm treatment method and treatment facility location, existence of liability insurance,
financial status, regulatory status (permits), and historical regulatory compliance record for
every treatment facility receiving waste and also the transporter (if a separate company).
q
Appoint an emergency coordinator either on-site or available 24 hours per day.
q
Contact local emergency response authorities and coordinate any response actions for facility.
Information should be provided on waste storage, sprinkler system, utility cut-offs, and water
main, etc. (See contingency plan for large quantity generators below.)
q
Post name and number of emergency coordinator and fire department at strategic locations
like phones and front door.
q
Post location of fire extinguishers, spill control equipment, and fire alarms at strategic
locations.
q
Provide general awareness training on proper waste handling and emergency response to all
employees involved in hazardous waste management activities.
q
Develop informal waste minimization plan.
q
Spills or accidental releases of listed materials above reportable quantities require notification
to national response center (800/424-8802), state, and focal governmental agencies. Obtain
and keep on hand proper telephone numbers for appropriate agency.
Some states require generators to develop and implement pollution prevention and waste
minimization plans.
q
III - 50
p. 9 of 16
Large Quantity Generator Requirements:
q
q
Collect, label and store wastes according to requirements (see below).
q
Obtain facility identification number for off-site shipment of hazardous waste to a treatment
or recycling facility. Number is specific to location and is not transferable.
q Change in type or volume of hazardous waste stream requires notification of state agency
by refiling the notification of hazardous waste activity form.
q
Manifests for all shipments of hazardous wastes with all proper EPA code(s), land ban
notification. Some states allow for contractual reclamation or recycling that does not require
a manifest (e.g., solvent reclamation or reusable shop towels).
q Generator must keep copies of manifests for at least three years and land ban forms for
five years. Some states require twenty-year retention for manifests. Permanent manifest
storage for Superfund purposes is strongly suggested.
q
Investigation of missing manifest must begin within 35 days of shipment and exception
report for missing manifest must be filed within 45 days of shipment.
q
Complete and submit biennial report. Some states require more frequent reporting.
q
Total hazardous waste accumulation not to exceed 13,200 pounds in any 90-day period.
q
financial status, regulatory status (permits), and historical regulatory compliance record for
every treatment facility receiving waste and also the transporter (if a separate company).
q
Appoint an emergency coordinator either on-site or available 24 hours per day.
q
Post name and number of emergency coordinator and fire department at strategic locations
like phones and front door.
q
Post location of fire extinguishers, spill control equipment and fire alarms at strategic
locations.
q
Develop and implement a formal emergency procedure and contingency plan. Plan needs to
be shared with local emergency response authorities.
Minimum Elements of Contingency plan for responding to an emergency:
Facility description including review of activities, map and review of existing response plan.
III - 51
q
p. 10 of 16
q
Activity review should include description of materials processed waste generated, and
copies of appropriate MSDSs.
q
Facility map should be 7.5" USG with facility name and ID number indicating property
boundaries, storage tanks, location of surface drainage courses and potentially exposed
surface and groundwater.
q
Facility plot plan should indicate boundaries, manufacturing areas, raw material and
product storage areas, waste handling and storage areas, drains, pipes; and outfalls, secure
and open access areas, and entrance and exit routes.
q
Brief incident history including spill description and cleanup measures.
q
Facility personnel action responses including organizational structure of chain of
command.
q
List names, addresses, and phone numbers of emergency coordinators; designate primary
emergency coordinator and list others in order of responsibility.
q
Spill and leak-prevention measures including planning for emergencies, employee
training, inspection and monitoring program, and preventive measures like housekeeping
material compatibility considerations, and security.
q
Countermeasure plan details describing measures to be taken facility personnel and
outside contractors, list of emergency equipment available for response, internal and
external communication and alarm system and evacuation plan for facility personnel.
q
Contingency plan amended with dates.
q
Copies of plan submitted to police, fire department hospital, and local emergency
response teams.
q
At least one emergency coordinator is on facility premises at all times or on call.
q
Some states require emergency response capabilities fix containment/clean that require
training under OSHA spill control regulation.
Develop and implement formal employee training program. Training records must be kept as
long as a person is employed, and for three years after leaving the company. Employee's job
descriptions must include hazardous waste handling responsibilities.
Minimum Elements of Employee Training Program:
q
Training program consisting of classroom or on-the-job training (JOT) covering
hazardous waste identification, storage, labeling and shipping requirements, handling
procedures, and emergency response actions.
q
Training directed by person trained in hazardous waste management procedures.
q
Training completed within six months of employment or assignment.
q
Annual training review.
III - 52
p. 11 of 16
Training records:
q
q
Job title and name of employee.
q
Job description.
q
Amount and type of initial and continuing training to be given each person filling
position.
q
Documentation of training as job experience given to and completed by personnel.
q
Records kept until closure or three years after termination of employment.
Develop and implement formal waste minimization plan.
Minimum Elements of a Waste Minimization Program:
q
q
Development of a written policy setting explicit waste reduction goals.
q
Designation of waste minimization coordinator.
q
Development and implementation of employee appropriate training and recognition of
accomplishments.
q
Characterization of waste generation and management by developing and maintaining a
waste accounting system to track waste generation dates, types, and amounts. Attempt to
determine true costs associated with waste generation and cleanup including regulatory
oversight, recordkeeping reporting, loss of potential production costs of materials in
waste stream, transportation and disposal costs, employee exposure and health care, and
potential future liability.
q
Conduct periodic waste minimization assessments by identifying opportunities at all
points in the production process where materials can be prevented from becoming a
waste. Opportunities should be analyzed based on true cost of waste management.
q
Explore technology transfer opportunities. Sources of information include internal and
external sources like other companies, trade associations, consultants, and federal or state
funded programs.
q
Implement most promising options are identified by assessment process evaluations.
q
Conduct periodic review of program for effectiveness and feedback for potential
improvement.
Spills or accidental releases of listed materials above reportable quantities require notification to
national response center (800/424-8802), state, and local governmental agencies. Obtain and
keep on hand proper telephone numbers for appropriate agency.
III - 53
p. 12 of 16
Storage and labeling Requirements:
1)
Satellite storage areas:
q
Total volume limited to 55 gallons.
q
Wastes must be stored in compatible containers.
q
Must be under visual control of operator and at or near equipment.
q
Multiple containers usually allowed, number depends on type of waste and size of
business.
q
Containers must be labeled 'hazardous Waste" and marked with accumulation date when
first amount of waste is placed into the container.
q
Containers must be closed unless filling or draining, spring closed funnel tops permitted.
q
Filled drums need to be moved to storage/disposal staging area within 72 hours of being
filled, if moved to storage area, they need to be relabeled for accumulation time limit.
q
There is no federal storage time limit, but some states have a time limit of one year or
less, while others do not allow satellite accumulation.
2)
Storage and Staging Areas:
q
All drums or other containers need to be labeled "Hazardous Wastes" with accumulation
date and contents [can use classification code (e.g., D001)1.
q
All wastes must be kept in closed containers unless they are being drained or filled.
q
Wastes need to be stored an impervious surface like sealed concrete or similar material.
q
Storage areas must have adequate aisle space (at least 3 ft.) for inspections and reading
labels.
q
Drums need to be properly maintained and not leaking or rusted.
q
Conduct weekly drum storage area inspections and daily inspections for tank storage.
Maintain log of inspection results indicating any corrective action.
q
Storage area needs to be equipped with or have immediate access to a communication
system (e.g., phone, alarm, or two-way radio), fire extinguisher, water (e.g., sprinkler
system), spill cleanup materials, and first-aid materials (e.g., eyewash).
q
Permits for recycling/recovery hazardous waste (e.g., silver recovery, distillation units).
Many states require generators of all sizes to obtain permits for these activities. Check
with state/local agency for requirements.
q
Unused chemicals not stored for more than one year. They are considered waste and
must be properly disposed.
III - 54
p. 13 of 16
D. Non-hazardous Waste
q
Some states have adopted mandatory recycling programs for business and require
annual/biannual reporting on program effectiveness.
q
Same states have adopted Residual Waste regulations governing the proper disposal of nonhazardous industrial wastes (e.g., uncontaminated lithographic inks, films, and chemical
containers). These wastes must go to an approved treatment/landfill facility, the generator has to
complete a biennial report, perform chemical analysis, and develop a source reduction plan.
q
financial status, regulatory status permits), and historical regulatory compliance record for every
treatment facility receiving waste and also the transporter (if a separate company).
E. Emergency Planning and Community Right-to-Know
q
Obtain copy of USEPA's consolidated list of chemicals (800/535-0202).
q
Procedure for notifying federal, state, and local authorities in case hazardous substances are
accidentally released above reportable quantity amounts. Depending on type of material,
quantity, location and duration, and receiving media, notification should be immediate but no
longer than 24 hrs may require written follow-up report detailing spill and remediation activities.
q
Submission of copies of Material Safety Data Sheds (MSDSs) or list of substances to local
authorities, state authorities, and fire department for substances stored above threshold levels-usually 500 lbs. for extremely hazardous substances and 10,000 lbs. for any substance(s)
requiring an MSDS. Some states and local governments have lower threshold levels and also
require submission of MSDSs to hospitals.'
q
Submission of Tier I/Tier II forms by March 1 for chemicals stored in excess of threshold levels
during previous calendar year. (See previous item for threshold quantities.) Some states and
local governments have lower threshold levels.
q
Submission of Form R, Toxic Chemical Release Inventory Reporting Form by July 1 for each
chemical on a specific list of chemicals used in excess of the threshold levels (25,000 lbs. for
manufactured or processed chemicals [components of inks] or 10,000 lbs. for otherwise used
chemicals [solvents]) during the previous calendar year. New Form R requires pollution
prevention activity reporting.
q
Consider using approved alternate reporting option for Section 313 (e.g., Form R). Under this
option a Form R need not be submitted only an annual certification is needed. Applies to
reporting year 1995 and chemical being reported must be used in quantities less than 1 million
pounds and have a combined reportable threshold of 500 pounds (i.e., released, treated, of
disposed).
III - 55
p. 14 of 16
F. Storage Tanks
q
Submit registration form for all chemical underground storage tanks (USTs) greater than 110
gallons storing listed hazardous chemicals or petroleum products except for heating oil tanks.
Some states do regulate heating oil tanks with the size for regulation varying. Some states
regulate all chemical tanks.
q
New petroleum USTs must be equipped with leak detection devices, corrosion protection, and
spill overfill prevention measures. New chemical USTs must also have secondary containment.
q
Existing petroleum and chemical USTs must be retrofitted with leak detection by 1993 depending
upon the age of the tank. Corrosion and spill/overfill prevention measures are required by 1998.
Existing chemical USTs must be retrofitted with secondary containment systems by 1998.
q
Aboveground tanks located outside the plant must have a spill containment system including
dikes. Some states regulate above ground storage tanks with regard to registration, spill control
programs, and other corrosion requirements.
q
Aboveground tanks located inside the plant (tote tanks) may also require a spill containment
system, registration, and spill control programs. Contact state for requirements.
q
Tank removal, especially of USTs, requires written notification, state supervision possible testing
for contamination, and remediation.
q
Demonstrate financial assurance of at least $1 million for cleanup costs and third-party claims
resulting from leaks and spills' from USTs.
q
Maintain records of testing; maintenance, spills, and cleanup activities.
G. Spill Prevention Control and Countermeasures Plan
q
Storage total of more than 1,320 gallons in aboveground tanks or single tanks exceeding 660
gallons or UST with more than 42,000 gallons of petroleum or petroleum-derived products (e.g.,
inks, lubrication oil gasoline, diesel fuel and possibly some solvents) that when accidentally
released can contaminate navigable waters of the United States and adjoining shorelines requires
development of contingency and cleanup plan. Plan must be updated and certified by professional
engineer every three years.
q
Spills of materials require notification of federal, state and local authorities.
III - 56
p. 15 of 16
H. Polychlorinated Biphenyls
q
Some states regulate polychlorinated biphenyls (PCBs) and PCB contaminated material as
hazardous wastes (e.g., ballasts from fluorescent lights, dielectric fluid from transformers, soil,
and power -stabilizing rectifiers).
q
PCBs or PCB-contaminated material must be shipped with a special manifest, or if considered
hazardous, then with a state manifest form.
q
480-volt or greater transformers containing more than 500 parts per million PCB located near a
commercial building and located in a network must be removed or reclassified by draining and
refilling by October 1, 1990. Transformers less than 480 volts can be used, but they must be
protected and disposed properly.
q
Transformers containing less than 500 ppm and greater than 50 ppm PCB can be used, but they
must be disposed properly.
q
Transformers containing less than 50 ppm are exempt from federal regulation.
q
Presence of PCB can be determined by records, manufacturer's data, or testing.
q
PCB containing transformers need to be inspected quarterly and prominently identified for
firefighters.
q
Fires involving PCB transformers need to reported to the national response center (800/4248802), state, and local emergency response personnel. The phone numbers should also be
included in the contingency plan.
q
Maintain records of inspections, manifests, service, marking and maintenance of PCB areas of the
proper forms.
q
A one-year time limit is imposed requiring the disposal of PCB contaminated materials removed
from service.
I. Asbestos
q
Renovation or demolition of more than 260 linear feet, 160 square feet or 35 cubic feet of
asbestos containing material requires EPA/state approval.
q
Removal of more than 80 linear feet or 15 cubic feet requires the presence of a trained person on
site to monitor activities and employee exposure. Make sure that the contractor has the proper
credentials and has not been cited for violations.
q
suggest institution of asbestos operation and maintenance program including regular inspections.
q
Some banks and lending institutions require that all asbestos be removed from commercial
buildings prior to granting loans for property acquisition or expansion.
q
See new OSHA regulations on employee training and exposure control requirements.
III - 57
p. 16 of 16
J. Department of Transportation Employee Training
q
Training required for employees and supervisors involved in driving, loading, unloading, or
handling hazardous materials. Training is specific to job function and should include:
q
General awareness of regulations.
q
Shipping paper preparation.
q
Recognition and identification of hazardous materials.
q
Proper handling and safety procedures
q
Procedures for accident prevention and emergency response including specific protection
measures like personal protective equipment.
q
DOT allows OSHA hazard communication standard, hazardous waste response (Hazwoper), and
USEPA Resource Conservation and Recovery Act (see hazardous waste generator requirements),
K. Ozone Depleting Substances
q
All products manufactured with or containing a Class I substance (chloroflurocarbons, halons,
carbon tetrachloride, or l,l,l-trichloroethane) after May 15, 1993 must be labeled. All products
manufactured with or containing a Class II substance (hydrochloroflurocarbons) after January 1,
2015 must be labeled. All containers used to transport or store a Class I or II substance must also
be labeled. Labeling requirements are specified by regulation.
q
No venting of refrigerants from commercial refrigeration equipment air conditioners, and vehicle
air conditioners. Refrigerants must be recovered and recycled by certified technician.
q
Certifications obtained fix technicians who will work on refrigeration equipment.
q
Equipment used to recover and recycle refrigerants must be certified.
q
Used refrigeration equipment cannot be discarded without first removing refrigerant.
q
Consider retrofitting existing equipment for new refrigerants.
III - 58
FEDERAL ENVIRONMENTAL REGULATIONS POTENTIALLY
AFFECTING THE COMMERCIAL PRINTING INDUSTRY
The following tables and information are drawn from the EPA publication, “Federal
Environmental Regulations Potentially Affecting the Printing Industry” (EPA 744B-94-001),
prepared by the Design for the Environment Program for the Office of Pollution Prevention
and Toxics, US Environmental Protection Agency, Washington, D.C., March 1994. The full
report is available from the EPA, www.epa.gov/opptintr/dfe/printing/fedregs/printreg.pdf.
Tables are numbered as in the full report.
EXHIBIT 6.
Chemicals Used in the Printing Industry That are Listed as
Hazardous Air Pollutants in the Clean Air Act Amendments
Benzene
Cadium compounds
Chromium compounds
Cumene
Dibutylphthalate
Diethanolamine
Ethyl benzene
Ethylene glycol
HAZARDOUS AIR POLLUTANTS
Formaldehyde
Methylene chloride
Glycol ethers
Perchloroethylene
Hexane
Polycyclic organic matter
Hydrochloric acid
Propylene oxide
Isophorone
Toluene
Lead compounds
2,4-Toluene diisocyanate
Methanol
1,1,2-Trichloroethane
Methyl ethyl ketone
Vinyl chloride
Xylenes
EXHIBIT 9.
Examples of Listed Wastes (U) Found in the Printing Industry
Waste
Code
U002
U019
U211
U055
U056
U069
U112
U359
U359
U122
U154
Name or Description of Waste
Acetone
Benzene
Cumene
Cyclohexane
Dibutyl phthalate
Ethyl acetate
Ethanol, 2-ethoxy
Ethylene glycol monoethyl ether
Formaldehyde
Methanol
Waste
Code
U226
U080
U159
U161
U210
U220
U223
U228
U043
U239
III - 59
Methyl chloroform
Methylene chloride
Methyl ethyl ketone (MEK)
Tetrachloroethylene (perchloroethylene)
Toluene
Toluene diisocyanate
Trichloroethylene
Vinyl chloride
Xylene
FEDERAL ENVIRONMENTAL REGULATIONS POTENTIALLY AFFECTING THE COMMERCIAL
PRINTING INDUSTRY
p. 2 of 5
EXHIBIT 8. Examples of Listed Wastes (F-series) Found in the Printing Industry
Waste Code
F001
The following spent halogenated solvents used in degreasing:
Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1trichloroethane, carbon tetrachloride, and chlorinated fluorocarbons; all spent
solvent mixtures/blends used in degreasing containing, before use, a total of ten
percent or more (by volume) of one or more of the above halogenated solvents
or those solvents listed in F002, F004, and F005; and still bottoms from the
recovery of these spent solvents and spent solvent mixtures.
F002
The following spent halogenated solvents: Tetrachloroethylene, methylene
chloride, trichloroethylene, 1,1,1-trichloroethane, chlorobenzene, 1,1,2trichloro-1,2,2- trifluoroethane, ortho-dichlorobenzene, trichlorofluoromethane,
and 1,1,2-trichloroethane; all spent solvent mixtures/blends containing, before
use, a total of ten percent or more (by volume) of one or more of the above
halogenated solvents or those listed in F001, F004, or F005; and still bottoms
from the recovery of these spent solvents and spent solvent mixtures.
F003
The following spent non-halogenated solvents: Xylene, acetone, ethyl acetate,
ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol,
cyclohexanone, and methanol; all spent solvent mixtures/blends containing,
before use, only the above spent non-halogenated solvents; and all spent
solvent mixtures/blends containing, before use, one or more of the above nonhalogenated solvents, and, a total of ten percent or more (by volume) of one or
more of those solvents listed in F001, F002, F004, and F005; and still bottoms
from the recovery of these spent solvents and spent solvent mixtures.
F005
The following spent non-halogenated solvents: Toluene, methyl ethyl ketone,
carbon disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, and 2nitropropane; all spent solvent mixtures/blends containing, before use, a total of
ten percent or more (by volume) of one or more of the above non-halogenated
solvents or those solvents listed in F001, F002, or F004; and still bottoms from
the recovery of these spent solvents and spent solvent mixtures.
III - 60
PRINTING INDUSTRY
p. 3 of 5
EXHIBIT 11.
EPA Toxic Characteristic Contaminants
That May be Found in Printing Industry Waste
Waste Code
D005
D007
D019
D035
Contaminant
Barium
Chromium
Methyl ethyl ketone
Waste Code
D011
D040
D043
Contaminant
Silver
Trichloroethylene
Vinyl chloride
APPENDIX B
CLEAN WATER ACT: REPORTABLE QUANTITIES OF HAZARDOUS SUBSTANCES
THAT MAY APPLY IN THE PRINTING INDUSTRY
Hazardous Substance
Benzene
Chloroform
Cyclohexane
Ethylbenzene
Formaldehyde
Hydrochloric acid
Propylene oxide
Styrene
Toluene
Xylene (mixed)
RQ (in pounds)
10
10
10
1,000
1,000
100
5,000
100
1,000
1,000
1,000
III - 61
PRINTING INDUSTRY
p. 4 of 5
APPENDIX D
CERCLA REPORTABLE QUANTITIES FOR SOME CHEMICALS
USED IN THE PRINTING INDUSTRY
Reportable
Chemical
Reportable Chemical
Quantity
Quantity
(lbs)
(lbs)
Acetone
5,000
Methyl chloroform 1,000
Ammonia
100
Methylene chloride 1,000
Benzene
10
Methanol
5,000
Cadmium and
1
Methyl ethyl ketone 5,000
compounds
10
Methyl isobutyl
5,000
ketone
Chloroform
10
Perchloroethylene
100
Chromium and
1
Phosphoric acid
5,000
compounds
Cumene
5,000
Propylene oxide
100
Cyclohexane
1,000
Sulfuric acid
1,000
Dibutyl phthalate
10
Toluene
1,000
Ethanol, 2-ethoxy
1,000
Toluene
100
diisocyanate
Ethyl acetate
5,000
1,1,11,000
Trichloroethane
Ethylbenzene
1,000
1,1,2100
Trichloroethane
Formaldehyde
100
Trichloroethylene
100
Hydrochloric acid
5,000
Vinyl chloride
1
Isophorone
5000
Xylene (mixed)
1,000
Lead and compounds
1
APPENDIX E
THRESHOLD PLANNING AND REPORTING QUANTITIES FOR
SOME EPCRA-DESIGNATED EXTREMELY HAZARDOUS CHEMICALS
USED IN THE PRINTING INDUSTRY
Chemical Name
Reportable Quantity
Threshold Planning Quantity
(lbs)
(lbs)
Ammonia
100
500
Formaldehyde
100
500
Hydroquinone
1
500/10,000*
Propylene oxide
100
10,000
Sulfuric acid
1,000
1,000
Toluene 2,4-Diisocyanate
100
500
* Revised threshold planning quantity based on new of re-evaluated toxicity data.
III - 62
PRINTING INDUSTRY
p. 5 of 5
APPENDIX F
CHEMICALS USED IN THE PRINTING INDUSTRY THAT
ARE LISTED IN THE TOXIC RELEASE INVENTORY
Acetone
Ammonia
Barium
Cadmium
Chromium
Copper*
Cumene
Cyclohexane
Methylene chloride
Ethylbenzene
TOXIC CHEMICALS
Ethylene glycol
Ethylene oxide
Formaldehyde
Freon 113
Hydrochloric acid
Hydroquinone
Lead
Methanol
Methyl ethyl ketone
* Copper phthalocyanini pigments delisted in May 1991.
III - 63
Phosphoric acid
Silver
Sulfuric acid
Tetrachloroethylene
Toluene
Trichloroethylene
1,1,1-Trichloroethane
Xylene
III - 64
WHEN
Plates Go Bad!
Here’s a step-by-step examination of the making of a photopolymer plate,
and the myriad things that can go wrong from start to finish.
By Dan Owenby
hotopolymer printing plates
have become a staple of the
f l e x ographic industry. And
while the technology is still far from
perfect, most of the problems associated with plates are fairly routine and
a result of errors in the platemaking
process, not flaws in the plate material. In this article, I’ll examine the
entire platemaking process, describing
what should happen at each step, and
what can go wrong if proper procedures are not followed. Interspersed
throughout the article are photos of
common plate defects, along with
their possible causes.
P
The Platemaking Process
Back exposure is the first step in
making a photopolymer plate. It’s a
simple task, but it’s one of the most
REVERSE FILL-IN
Causes:
• excessive face exposure
• excessive back exposure
• low-density negative
• defective negative
• out-of-contact polymer negative
Figure 1: Reverse fill-in is one of the many possible results of excessive back-exposure time.
important steps — if not the most
important step — in making a plate.
This is where the relief depth is set
for support of the printing image.
During back exposure, the plate is
exposed to UVA light. The UVA
portion of the electromagnetic spectrum encompasses a radiation wavelength range of 320-400 nanometers.
III - 65
At the moment UVA contacts the
plate, photoinitiators within the polymer energize and begin the curing,
or cross-linking, process. This chain
reaction will continue for the duration of the exposure, penetrating
deeper into the plate over the length
of the exposure time. Once the UVA
energy is removed, the cross-linking
chain reaction stops almost instantaneously, thus giving the plate a consistent penetration depth, or floor.
Improper back-exposure time can
lead to a floor depth that is either too
thin or too thick. Excessive backexposure time will create a floor that
is too thick, which means there will
not be enough unexposed polymer
remaining to properly create the
image (see Figure 1, on facing page).
On the other hand, insufficient backexposure time will create a floor that
is too thin. In this instance, there will
be too much unexposed polymer
STICKY PLATE/GUMMY FLOOR
Causes:
• insufficient back exposure
• insufficient washout
• insufficient oven-dry time
• insufficient germicidal detack
• insufficient post exposure
Figure 2: A sticky plate could be the result
of insufficient back-exposure time.
remaining, and the image will not
properly merge with the floor (see
Figure 2). Thus, floor thickness should
be checked with a micrometer to
ensure proper relief and floor consistency.
The next step is face exposure.
Here, the negative is positioned on
the photopolymer with the emulsion
side facing the surfa c e. A va c u u m
cover sheet is applied to create intimate contact between the plate and
negative, and UVA is used to transfer
the image to the uncured photopolymer remaining from the back-expo-
BLURRED IMAGE
Causes:
• defective negative
• air trapped under negative
• excessive face exposure
• emulsion on wrong side
Figure 3: A blurred image may be the sign of excessive face exposure.
III - 66
When Plates Go Bad!
shoulders and reduced shadow-dot
depths (see Figure 3, on page 47).
Underexposed plates will have wavy
lines, unsecured screens and a mottled
plate surface (see Figure 4). To ensure
that the photopolymer is fa c e exposed properly, the user needs to
have knowledge of the photopolymer
a c t iv i t y, the expose-unit’s lamp
strength, and the artwork’s level of
detail.
WAVY LINES & CHIPPING
Causes:
• insufficient face exposure
• excessive washout
• excessive brush pressure
• incorrect artwork on negative
Figure 4: Wavy lines and/or chipping can
occur if a plate has been underexposed.
s u re process. As the UVA energy
transmits through the clear areas of
the negative to the polymer, it initiates curing of the majority of the previously uncured polymer. The image
areas of the negative allow the light to
pass through, while the non-image
areas absorb the light, thus preventing
cross-linking from occurring. This
forms the printing image.
The amount of face-exposure time
is very important. Overexposed plates
will have shallow reve rses, bro a d
Washout
Next, the uncured polymer under
the non-image areas of the plate must
be removed. This is accomplished by
the combined process of washing the
plate with solvent (or water-based
acids or detergents, for water-wash
and liquid plates) while scrubbing it
with a brush. In most cases, the polymer is dissolved and removed in solution, not by the scrubbing action.
Thus, the amount of pressure applied
by the brushing should be the minimum amount necessary to remove
the polymer and recoat the plate with
the solvent. The plate should be
washed long enough to completely
reach the floor of the non-image
areas, but no longer than necessary.
During washout, the plate absorbs
solvent and swells up, much like a
sponge absorbing water. As a result,
upon removal of the plate from the
washout unit, fine lines may appear
wavy and reverses may seem to be
filled in. If the washout time was correct, these effects should disappear in
the early stages of dry-down.
TACKY PLATE
Causes:
• insufficient washout
• insufficient germicidal detack
Figure 5: Tackiness is a possible indicator of insufficient washout procedures.
III - 67
INCONSISTENT PLATE GAUGE
Causes:
• improper storage of raw materials
• defective material
• manufacturing error
Figure 6: If you’ve detected an inconsistency
in your plate gauge, it could be the result of
excessive washout that caused the plate to
swell beyond the point where it could be
sufficiently dried.
Too much or too little washout can
lead to serious problems. For instance,
if the washout time is insufficient,
then some of the unexposed polymer
will remain on the plate, meaning that
the relief depth will either be incorrect or inconsistent. Plates not washed
completely to the floor contain a layer
of non-exposed polymer on top of
the exposed floor. This layer is more
prone to develop tack during the press
run (see Figure 5).
On the other hand, if the plate is
overwashed, it may swell to such an
extent that it may not be dried down
When Plates Go Bad!
MOTTLED PLATE SURFACE
Causes:
• insufficient face exposure
• dirty washout solvent
• slip-film area damaged
Figure 7: A mottled plate surface, “orange peel,” in this case, may be the sign of insufficient
drying time.
Improper rinsing will
leave polymer in
the reverses/screens
and on the plate
surface, leading to a
mottled effect on the
printed product.
CRACKED PLATE
Causes:
• excessive finishing time
• plate stored in the round
• plate stored in the presence of light
• poor cleaning prior to storage
• high-ozone environment
Figure 8: A cracked plate could be an indicator of excess finishing time.
(see Figure 6, on page 48). Fine detail
may also be chipped off of the plate.
Again, washout time should be limited to the minimum time necessary to
reach the plate floor.
Rinsing/Blotting
The wash cycle will leave dissolved
photopolymer on the plate’s surface,
and this must be re m oved. Thus,
once the washout cycle is complete,
the plate should be rinsed in clean
solvent. When rinsing the plate, pay
particular attention to screen areas and
fine reverses. Improper rinsing will
leave polymer in the reverses/screens
and on the plate surface, leading to a
mottled effect on the printed product.
After rinsing, the plate should be
blotted with a lint-free towel to
remove as much solvent as possible.
This will allow the plate to dry down
with the highest efficiency. With inline processors, the rinsing and blotting are done automatically.
Next, the solvent that wa s
absorbed during washout must be
removed from the plate. Drying the
plate in a heated, forced-air drye r
accomplishes this. (The temperature
III - 68
of the dryer should be between 140
and 150 degrees Fahrenheit.) The
drying process allows the solvent to
evaporate out of the plate, returning
the plate to its normal gauge and
allowing the image areas to regain
their original dimensions. Keep in
mind that the solid areas will return
to gauge before the screen areas, due
to the larger surf ace area of the
screens.
Most of the problems associated
with dry-down result from insufficient drying. Of all the steps in the
platemaking process, this is the one
most commonly cut short. Sav i n g
time is of no benefit here, and can
lead to problems such as wavy lines,
tacky plates, “orange peel,” sticky
floors and a plate that smells of solvent (see Figure 7). The idea is to dry
the plate long enough to remove all
of the solvent. Fo rt u n a t e l y, excess
time in the dryer will not damage the
photopolymer, provided that the oven
temperature does not exceed the prescribed 150 degrees Fahrenheit. Oven
temperatures greater than 150 degrees
Fahrenheit can cause shrinkage of the
plate backing.
When Plates Go Bad!
MECHANICAL DAMAGE
Causes:
• improper handling
• cleaning brush too stiff
• plate jammed in press
• anilox roll grinding into plate
• improper storage
Figure 9: A plate with mechanical damage is best suited for the trash heap.
FLOOR CRACKED
Causes:
• excessive finishing time
• high-ozone environment
• improper plate storage
Figure 10: A cracked plate floor is often the result of improper storage procedures.
Finishing/Post-Exposure
A plate remains somewhat tacky
even after all solvent has been
removed in the dryer. This tack can
be eliminated by finishing, or surfacetreating, the plate. This is accomplished by exposing the plate surface
to UVC light, creating what is essentially a “super” cross-link. The UVC
portion of the electromagnetic spect rum is where the UV radiation
wavelength range is 200 to 290
n a n o m e t e rs. UVC does not fully
penetrate the plate, rather, it merely
“finishes” the surface.
Note that heat will change the
effectiveness of finishing, so the finishing/post-exposure unit should be
properly vented. Care should also be
taken to restrict finishing time to the
minimum amount of time necessary
to sufficiently remove the plate tack.
Excessive finishing will make the plate
brittle and cause it to crack (see Figure
8, on page 50).
While the plate is undergoing the
finishing process, it should be simultaneously post-exposed using UVA
light to penetrate the entire plate, thus
ensuring a complete cross-linking of
all the photopolymer and achieving
effective hardness.
III - 69
Mechanical Damage
A ny mechanical damage will,
almost without fail, render a plate
useless (see Figure 9). Thus, plates
must be handled correctly: cleaning
should be done with a soft-bristled
brush and a quality flexo-plate wash
formula; care must be taken in transportation and storage, or kinks may
develop; aniloxes must release immediately upon press stoppage or they
will damage a plate in seconds (see
Figure 10). In short, there are many
ways to damage a plate, and few, if
any, ways to fix one.
I n c o m p a t i ble inks or cleaning
chemicals are another source of plate
problems, in this case, swelling, softening and/or tack. If in doubt about
what will or won’t work with your
particular plates, call your plate supplier and ask for a list of approved/
c o m p a t i ble chemicals. Another
method of precaution would be to
perform a swell test to determine ink
c o m p a t i b i l i t y, provided a tabl e t o p
micrometer is available. To perform
this test, take a piece of plate, measure
its thickness, put it in a glass container, add the ink or cleaning solution,
and let the plate soak for 24 hours.
Then remove the piece of plate material and remeasure it. If the plate has
swelled by more than five percent,
compatibility is suspect.
As you can see, there are plenty of
things that can go wrong at some
point in the platemaking pro c e s s .
Indeed, a quality plate is the result of
sound techniques and careful attention
paid to detail. By consulting with your
plate supplier and following the procedures outlined in this article, you will
be well on your way to achieving better quality in your plates.
Dan Owenby is a senior field test engineer at
Polyfibron Technologies Inc., Atlanta. He has been
in the industry for 10 years and is a frequent
speaker at FTA and related flexographic technical
seminars. Owenby holds a B.S. in mechanical engineering from Southern Technical Institute and an
M.B.A. from Kennesaw State University. For more
information on Polyfibron, please visit their Web
site, www.polyfibron.com.
This Page is Blank
IV.
PERFORMANCE
1-800-442-4613
Fax Number:
1-800-348-9529
IV- 1
PERFORMANCE
David Argent has spent thirty years in ink and allied industries in his
native England, Canada and the United States occupying various technical
and management positions. He has broad-based experience with litho,
rotogravure, as well as flexography and has developed many products and
concepts to improve flexographic and rotogravure printing, especially in
the areas of High Solids, Thin Film and Water-Based Inks. Mr. Argent is
currently Product Manager with Progressive Ink and is active in GTA,
FTA, TAPPI, and as a founding member of FQC.
Phone: 314-768-5530, ext. 351
Fax: 314-768-5540
Karen Doerschug is a Senior Project Manager with the U.S.
Environmental Protection Agency’s Design for the Environment (DfE)
Program. DfE is a voluntary partnership program that promotes the
incorporation of environmental considerations into business decisions.
Ms. Doerschug manages DfE’s projects with the flexographic and
lithographic printing industries. She also leads DfE’s program evaluation
and communication teams, and participates in the program’s New Project
team. Prior to joining EPA, she worked with MCI, Searle and ICF
Consulting and has accumulated twelve years of experience in business
analysis, marketing and environmental issues.
Phone: 202-260-0695
Fax: 202-260-0981
Bill Dowdell has been President of the Flexographic Technical
Association since 1993. Prior to that, he was with the DuPont Corporation
for 28 years, including the last eight years as Worldwide Business Director
of DuPont’s CYREL Packaging Graphics business.
Phone: 631-737-6020, ext. 30
Fax: 631-737-6813
Mike Klemme has been with Highland Supply Corporation since 1986.
His broad-based experience with the company includes management of
plant production, maintenance and environmental programs, development
of production operating procedures and training materials, and research,
development and implementation of a water-based ink system for
flexographic and gravure printing. Mr. Klemme is currently responsible
for specifying and purchasing production equipment for all pre-press,
press and post-press operations, as well as the development of new or
improved inks and coatings.
Phone: 618-654-2161, ext. 470
Fax: 618-654-9623
IV-2
PERFORMANCE
Doreen M. Monteleone is Director of Environmental Affairs for the
Flexographic Technical Association where she has national responsibility
for environmental issues that affect flexographic printers. Since Dr.
Monteleone joined FTA in 1996, her accomplishments have included
representing the flexographic industry in the USEPA Design for the
Environment and Common Sense Intiatives, publishing the monthly
Environmental Newsletter, and serving as the association’s Supervisor of
Membership. Additionally, she works with federal, state and local
agencies to distribute information to FTA members, and reviews
regulations to make them appropriate for flexo printers. Dr. Monteleone
previously held several high-level positions within New York state
government providing environmental and other technical assistance to
businesses. She was a Resource Expert for the 1994-95 White House
Conference on Small Business and was the Conference Chair for the 1998
National Environmental, Health and Safety Conference for the Graphic
Communications Industries.
Phone: 631-737-6020, ext. 18
Fax: 631-737-6813
Jim O’Leary began his career as an operations research analyst with
Grumman Aerospace Corporation in 1965. After a move to the
Washington DC are in 1970, he worked for several management
consulting organizations as an operations research analyst. Since 1980, he
has been with the U.S. EPA in Washington hold various management and
non-supervisory positions, primarily with the Office of Solid Waste.
Currently, Mr. O’Leary is a special assistant to the Division director,
Hazardous Waste Identification Division where he conducts various
studies and analyses, including the study of solvent-contaminated shop
towels and wipes, and issues related to hazardous waste recycling
activities.
Phone: 703-308-8827
Fax: 703-308-0514
W. Michael McCabe is Acting Deputy Administrator for the U.S.
Environmental Protection Agency. He assists the EPA Administrator in
setting and communication national environmental policy, implementing
and enforcing federal environmental laws, and ensuring the efficient
management of the Agency and its 18,000 employees. Mr. McCabe has
25 years of experience in environmental policy and leadership within the
EPA as well as the legislative branch of the federal government.
IV-3
PERFORMANCE
Dan Owenby is the Technical Service Manager for Chemence, Inc. of
Alpharetta, Georgia. He has been in the industry for 11 years and is a
frequent speaker at FTA and related flexographic technical seminars. Mr.
Owenby holds a B.S. in Mechanical Engineering from Southern Technical
Institute and an M.B.A. from Kennesaw State University.
Phone: 770-664-6624, ext. 34
Fax: 678-429-0907
Wayne Pferdehirt is a Waste Reduction and Management Specialist with
the University of Wisconsin-Extension’s Solid and Hazardous Waste
Education Center, and a Co-Director of the Printers’ National
Environmental Assistance Center. Mr. Pferdehirt assists printers and other
businesses seeking to reduce hazardous wastes and toxic air and water
emissions. He also directs the University of Wisconsin – Madison’s first
on-line graduate program, the Master of Engineering in Professional
Practice.
Phone: 608-265-2361
Fax: 608-262-6250
Sigmond Singramdoo is a Process Engineer at Anagram International,
Inc. He is responsible for maintaining and improving all processes of the
printing and extrusion operations. Since 1995, Mr. Singramdoo has been
involved with the company’s Pollution Prevention Initiatives and
Hazardous Waste Reduction programs. As a result of these programs,
Anagram has received awards and recognition from local and state
government, as well as from trade associations. He is also an ISO 9000
and ISO 14000 auditor.
Phone: 612-949-5752
Fax: 612-949-5609
E-Mail: [email protected]
Brad Taylor is a Research Associate for DuPont Cyrelâ Packaging
Graphics Products. He is responsible for research, development and
applications support of DuPont Cyrelâ’s digital products, including
electronic prepress, digital imaging, and media testing, development, and
analysis. Prior to his assignment with Cyrelâ, Dr. Taylor worked on
various electronic imaging technologies in DuPont’s Printing and
Publishing and Imaging Systems businesses, which included thermal offset
plate imaging, color electronic scanning, color science and electronic
image recording technology.
Phone: 302-999-3627
Fax: 302-999-4579
IV-4
PERFORMANCE
Tom Underwood is Plant Manager for OEC Graphics, Inc. in Oshkosh,
Wisconsin.
Phone: 920-235-7770
Fax: 920-235-2252
Keith West is an Industrial Recycling Specialist for the Solid and
Hazardous Waste Education Center of University of Wisconsin –
Extension. For the past few years he has provided waste reduction and
pollution prevention assessments to manufacturers and other businesses in
the state. Mr. West worked for many years in private industry and among
his other accomplishments, he coordinated a small manufacturer’s ISO
9002 registration effort and Environmental Management System
development.
Phone: 920-465-2940
Fax: 920-465-2143
IV-5
This Page is Blank
V.
PERFORMANCE
Additional Sources of Information and Assistance
Printers National Environmental Assistance Center (PNEAC)
World Wide Web Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-3
Index of Fax-Back Documents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-7
Flexographic Technical Association (FTA) . . . . . . . . . . . . . . . . . . . . . . . . . . . V-11
Get Involved: Industry Contributions to Informed Ink Choices . . . . . . . . V-13
Focusing on Flexo Inks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-15
National Trade Associations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-17
State Pollution Prevention Technical Assistance Programs . . . . . . . . . . . . . . . V-19
Clean Air Act Small Business Ombudsmen and Technical Assistance
Directors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-25
National Small Business Environmental Resources . . . . . . . . . . . . . . . . . . . . . V-29
V-1
V-2
What is PNEAC?: Environment and Printing: The Printers' National En...AC: The Environmental Information Website for the Printing Industry
What Is PNEAC?
PNEAC's
EPA's Office of Enforcement and Compliance Assurance and Pollution
Prevention Policy Staff have partnered with industry and environmental experts to Advisory
Council
develop this environmental assistance center for the printing industry which
Council of Great
includes compliance assistance and P2 information.
Lakes
Governors
This is a communications-based center linking trade, governmental, and university
service providers to efficiently provide the most current and complete compliance Environmental
Defense Fund
assistance and pollution prevention information to the printing industry. The
Flexible
project's staff are located within the partnering organizations. The Great Lakes
Packaging
Association
Information Network is providing support for the two Internet Listservs.
PNEAC Partners (Contacting Humans at PNEAC)
Illinois Waste Management and Research Center:
● University of Illinois, Champaign, IL
❍ Gary Miller, PNEAC Director
(217) 333-8940 / [email protected]
❍
●
Todd Schumacher, Project Management Assistant
Oak Brook, IL
❍ Debra Jacobson
Solid and Hazardous Waste Education Center:
● University of Wisconsin, Madison, WI
❍ Wayne Pferdehirt, PNEAC Co-Director
❍
Bob Gifford
Graphic Arts Technical Foundation / Printing Industries of America:
● Sewickley, PA
❍ Gary Jones
❍
Rick Hartwig
V-3
http://www.pneac.org/whatis.html (1 of 3) [3/12/2000 2:19:40 PM]
Flexographic
Technical
Association
Gravure
Association of
America
National
Association of
Printers &
Lithographers
National
Institute of
Standards &
Technology
National
Pollution
Prevention
Roundtable
Screenprinting &
Graphic
Imaging
Association,
International
Clean Air Act
Small Business
Development
Centers
Association of
Small Business
Development
Centers
International
Association of
Printing House
Craftsmen
Who is PNEAC for?
Compliance Assistance Providers Technical Assistance Providers Small Business
Assistance Programs Small Business Development Centers Regulatory Agencies
(Federal, State, Local) P2 Programs Industry Trade Associations Printers
Products and Services
Training
One of the most important goals of the PNEAC project is to offer printers and
technical assistance providers a wide variety of training materials and educational
opportunities.
● Basics of Printing
● P2 In Lithographic Printing
● P2 In Gravure Printing
● P2 In flexographic Printing
● P2 in Screen Printing
● Compliance Assistance Training
● Green and Profitable Printing Training Videos
● Technical Assistance
● Regulatory Assistance
Documents/Products
While many of our services are provided at no charge, several of our products are
fairly expensive to create, and we charge nominal fees to recover these costs.
Green and Profitable Training Series
$75
Printing with Alcohol Substitutes- GATF SS#20
$20
Controlling Waste In Web Offset Printing
$39
(video)- GATF #4204V
Chemistry For The Graphic Arts- GATF #1401
$60
The Lithographers Manual- GATF #1407
$60
Glossary of Printing Terms- GATF #1305
$60
Fax Back Service
1-888-USPNEAC
The Fax Back Service makes fact sheets, case studies, and other documents
available via fax by calling our toll free number, 1-888-USPNEAC and accessing
the fax back information system.
V-4
Listservs
PrinTech is a free listserv to promote discussion among technical assistance
providers on P2 and compliance issues affecting printers. PrintReg is a listserv
similar to PrinTech, but focusing on regulatory issues facing printers.
To subscribe to either of these, go here or contact Wayne Pferdehirt at
608-265-2361.
Toll Free Access Line
1-888-USPNEAC
Our Toll Free number provides direct access to technical and compliance
assistance professionals.
V-5
V-6
Printers’
National
Environmental
Assistance
Center
FACT SHEETS
and
www.pneac.org
CASE
1-888-USPNEAC
STUDIES
PNEAC
PNEAC Fax-on-Demand FactsLine
1-888-USPNEAC
Index of Available Documents
Index
Name
Number
of Pages
1000
What is PNEAC?
3
1020
Federal Environmental Regulations Potentially Affecting the Printing Industry, EPA
DfE
(Unavailable by fax. Available from
<http://www.epa.gov/opptintr/dfe/printing/fedregs/printreg.pdf> or from the Pollution
Prevention Information Clearinghouse at (202) 260-1023 )
69
1040
Understanding Air Pollution Permits
7
1050
What are VOCs and Do Printing Related Materials Contain Them?
2
1130
What is a Hazardous Waste?
8
1160
Basic RCRA Recordkeeping Requirements For Printers
3
1200
How to Read and Use an MSDS for Environmental Purposes
6
1205
One Plan Complies With OSHA & EPA Emergency Response Requirements
6
1210
Basic OSHA Recordkeeping & Training Requirements Affecting Printers
7
1250
Printing Industry Manuals on Compliance, P2 & Processes
16
1420
Demystifying Environmental Management Systems, Jeff Adrian
3
1470
Pollution Prevention: Working with Suppliers, Montana, 6/96
2
1520
Pollution Prevention: Environmental Marketing, Montana, 6/96
2
1540
Energy Efficiency Program
2
1570
Managing Solvents and Wipes, EPA DfE
4
1600
Management of Solvents and Wipes in the Printing Industry
6
1620
Managing Solvents and Wipes, EPA DfE
4
1650
Options for Printers to Reduce Image Processing Costs by Minimizing Waste and
Recovering Silver
5
V-7
PNEAC Fax-on-Demand FactsLine 888-USPNEAC Index of Available Documents
Index
Name
p. 2 of 4
Number
of Pages
1670
Code of Management Practice; Guide for Commercial Imaging, Silver Council, 4/97
(Unavailable by fax. Available from
<http://www.silvercouncil.org/codes/commercmain.pdf>, or by calling 914-698-7603)
44
1680
Silver Recovery Systems And Waste Reduction in Photoprocessing. North Carolina
5
1800
Pollution Prevention: Facts About Paper, Montana, 6/96
6
1905
Profile of the Printing and Publishing Industry, EPA
(Unavailable by fax. Available at <http://es.epa.gov/comply/sector/#print>
Contact Ginger Gotliffe, EPA (202) 564-7072, E-mail:
[email protected] )
117
1906
Printing Industry and Use Cluster Profile, EPA DfE (Unavailable by fax. Available at
<http://www.epa.gov/opptintr/dfe/printing/usecluster/index.html > or from the
Pollution Prevention Information Clearinghouse at (202) 260-1023 )
183
2000
Environmental Compliance Checklist for Lithographic Printers
4
2250
Pollution Prevention Checklist For Lithographic Printers
15
2300
Pollution Prevention: Self-Assessment Checklist, Montana, 6/96
6
2310
Pollution Prevention at Custom Print, EPA DfE
4
2315
Pollution Prevention at Custom Print, EPA DfE (en Espanol)
4
2320
Workplace Practices Make the Difference, EPA DfE
4
2325
Workplace Practices Make the Difference, EPA DfE (en Espanol)
4
2330
Book Printer Reduces Waste at the Source, MI DEQ
6
2450
Deciding to Go Digital, MI DEQ
2
2500
Pollution Prevention: Plate Developing, Montana, 6/96
3
2690
Substitute Blanket Washes: Making Them Work, EPA DfE
4
2695
Substitute Blanket Washes: Making Them Work, EPA DfE (en Espanol)
4
2710
Vegetable Ester Blanket Washes, EPA DfE
4
2715
Vegetable Ester Blanket Washes, EPA DfE (en Espanol)
4
2720
A Worksheet to Help You Choose a Better Wash, EPA DfE
6
2725
A Worksheet to Help You Choose a Better Wash, EPA DfE (en Espanol)
6
2730
Blanket Wash Solutions for Small Printers, EPA DfE
2
V-8
Index
Name
p. 3 of 4
Number
of Pages
2740
CTSA Summary Booklet: Solutions for Lithographic Printers: An Evaluation of
Substitute
Blanket Washes (Unavailable by fax. Available from the Pollution Prevention
Information
Clearinghouse at (202) 260-1023. Available at
<http://www.epa.gov/opptintr/dfe/lithography/lithbkst.pdf>)
33
2742
CTSA: Lithographic Blanket Washes (Unavailable by fax. Available from the
Pollution Prevention Information Clearinghouse at (202) 260-1023. Available at
<http://www.epa.gov/opptintr/dfe/lithography/ctsa/litho.pdf > )
447
2750
How to Reduce, Reuse and Recycle Lithographic Ink Wastes
6
2800
Pollution Prevention: Printing Inks, Montana, 6/96
5
2810
On-Site Waste Ink Recycling, EPA
7
2860
Emission Reduction in Waterless Printing Operations
3
2900
Pollution Prevention: Fountain Solution Solutions; Montana, 6/96
4
3250
Screen Printing Project Fact Sheet: Designing Solutions for Screen Printers, EPA DfE
2
3550
Improving on a Good Thing: Romo Reduces TRI Releases
5
3600
Technology Alternatives for Screen Reclamation, EPA DfE
4
3605
Technology Alternatives for Screen Reclamation, EPA DfE (en Espanol)
4
3610
Smarter, Safer Screen Reclamation; Alternative System Epsilon, EPA DfE
4
3615
Smarter, Safer Screen Reclamation; Alternative System Epsilon, EPA DfE (en
Espanol)
4
3620
Smarter, Safer Screen Reclamation; Alternative System Chi, EPA DfE
4
3625
Smarter, Safer Screen Reclamation; Alternative System Chi, EPA DfE (en Espanol)
4
3630
Work Practice Alternatives for Screen Reclamation, EPA DfE
4
3635
Work Practice Alternatives for Screen Reclamation, EPA DfE (en Espanol)
4
3640
Reducing the Use of Reclamation Chemicals in Screen Printing, EPA DfE
4
3645
Reducing the Use of Reclamation Chemicals in Screen Printing, EPA DfE (en
Espanol)
4
3650
Changing Equipment and Reducing Solvent Use in Screen Reclamation, EPA DfE
4
3655
Changing Equipment and Reducing Solvent Use in Screen Reclamation, EPA DfE (en
Espanol)
4
3660
Innovations in Adhesives, Screen Cleaning and Screen Reclamation, EPA DfE
4
V-9
Index
Name
p. 4 of 4
Number
of Pages
3665
Innovations in Adhesives, Screen Cleaning and Screen Reclamation, EPA DfE (en
Espanol)
4
3670
Designing Solutions for Screen Printers: An Evaluation of Screen Reclamation
Systems, EPA DfE (Unavailable by fax. Available from the Pollution Prevention
Information Clearinghouse at (202) 260-1023. Also available from
<http://www.epa.gov/opptintr/dfe/screenprinting/ctsa/scbook.pdf> )
58
3680
Cleaner Technologies Substitutes Assessment Executive Summary: Screen
Reclamation, EPA DfE (Unavailable by fax. Available from the Pollution
Prevention Information Clearinghouse at (202) 260-1023. Also available from
<http://www.epa.gov/opptintr/dfe/screenprinting/ctsa/execsum.pdf> )
16
3690
Cleaner Technologies Substitutes Assessment: Screen Reclamation, EPA DfE
(Unavailable by fax. Available from the Pollution Prevention Information
Clearinghouse at
(202) 260-1023. Also available from
<http://www.epa.gov/opptintr/dfe/screenprinting/ctsa/index.html>
680
4300
Reducing VOCs in Flexography, EPA DfE
5
4305
Reducing VOCs in Flexography, EPA DfE
4400
Environmental Management of Photopolymer Flexographic Plates
6
4500
Focusing on Flexo Inks, EPA DfE
2
4510
Learning from Three Companies that Reduced VOC Emissions, EPA DfE
4
4515
Learning from Three Companies that Reduced VOC Emissions, EPA DfE (en
Espanol)
4
4520
Replacement of Hazardous Material in Wide Web Flexographic Printing Process, EPA
6
4530
Water and Ink Waste Reduction at F.C. Meyer Company, MA-OTA
2
4650
Anagram Saves Over $68,600 through Waste Reduction, MnTAP
4
4750
Reducing Film Scrap, MnTAP
3
5250
Environmental Research Brief: Waste Minimization Assessment for a Manufacturer of
New and Reworked Rotogravure Printing Cylinders, EPA
6
5400
Labels and Flexible Packaging, EPA
8
5500
Gravure-Coated Metalized Paper and Metalized Film, EPA
5
9998
Index of available documents (this document)
4
(en Espanol)
V-10
5
FLEXOGRAPHIC TECHNICAL ASSOCIATION
900 MARCONI AVENUE
RONKONKOMA, NY 11779
Phone: 631-737-6020
Fax: 631-737-6813
JOIN FTA!
Reduced Rates on Seminars and Products
Subscriptions to FLEXO® and FLEXO ESPAÑOL® Magazines
Technical and Environmental Assistance
Awards Competitions
SOME OF OUR EVENTS
v National Environmental, Health and Safety Conference for the Graphic
Communications Industries – the EHS event for printers
v Annual Forum and INFO*FLEX – the largest gathering of flexo printers which includes
seminars and tabletop exhibits
SOME OF OUR PRODUCTS
v Environmental Newsletter – a monthly newsletter sent to FTA members highlighting
the latest environmental issues
v Flexography: Principles and Practices, 5th Edition – a six volume text which
includes a chapter on environmental, health and safety regulations
v Environmental Glossary of Terms – a press pal which includes definitions for nearly
600 environmental terms and acronyms
v P2 Finance for Flexographers – a software program to analyze cost of pollution
prevention and environmental compliance modifications
v Inside Flexo, A Cleaner Run for the Money – a video of pollution prevention options
for flexo printers
v Flexographic Image Reproduction Specifications and Tolerances (FIRST) –
guidelines, tutorials and data that can be used as communication and production tools
v FLEXSYS™ Press Simulator – a computer simulation program designed to be used as
a training and diagnostic troubleshooting tool
COMING SOON!
v The Flexo Environment – a book encompassing environmental compliance and
pollution prevention issues
Visit FTA on the Internet at www.flexography.org
For membership information, contact the Membership Department at
[email protected] or call 631-737-6020
V-11
V - 12
Information Exchange Web Page
A Cooperative Project
between the
U.S. Environmental
Protection Agency
and the
April 2000
Get Involved:
Industry Contributions to Informed Ink Choices
Printing Trade
Associations
Nationwide
I
f you are a flexographic ink manufacturer or printer, you have probably
heard of DfE’s Flexographic Inks
Partnership. The goal of the Partnership
is to better understand the possible
environmental and health impacts of
ink chemicals and to encourage the
What’s in the Flexographic Inks CTSA?
The CTSA provides a wealth of information to help guide ink choices, with
the goal of enabling printers to be as efficient and as environmentally
responsible as possible.
Chapter 3: Risk*
• Possible health concerns relevant to press-room workers and their
management.
• Aquatic toxicity information that will be useful in the event of an
inadvertent release to water.
Chapter 4: Performance
• Performance of each of the CTSA formulations on 18 different performance tests. Compares solvent-based and water-based formulations,
and presents UV-cured formulations as an emerging technology.
Chapter 5: Cost
• Operating-cost assessment of the three flexographic ink technologies. Includes material, labor, capital, and energy costs.
• Information on other costs to consider when evaluating an ink,
including disposal, storage, and clean-up costs.
Chapter 6: Resource and Energy Conservation
• Energy requirements, and subsequent environmental implications,
of ink drying and curing systems, corona treaters, and oxidizers.
Chapter 7: Additional Improvement Opportunities
• Options to increase efficiency and control environmental emissions in
flexographic printing. Such choices may have a number of positive
financial as well as health and environmental implications.
* Because the ink formulations studied in the CTSA may not be the formulation
you use, you should work with your supplier to get specific information on your
current ink or the one you are considering.
V - 13
innovation and use of cleaner, safer
inks. To achieve these goals, the
Partnership is developing a comprehensive technical report — Flexographic
Ink Options: A Cleaner Technologies
Substitutes Assessment (CTSA). This
report, soon to be released, is a comparative evaluation of solvent-based,
water-based, and UV-cured ink systems
on wide-web film substrates. It assesses the performance, cost, energy, and
environmental and human health
aspects of 45 ink formulations.
The CTSA was developed to provide
printers and ink formulators with
information that can help guide their
ink choices and encourage them to
consider a variety of factors when
choosing or evaluating ink systems or
specific formulations. In particular,
judging inks based on only performance or cost leaves out very important information. Different formulations may pose different worker
health and environmental concerns.
Also, each printing facility operates
with a unique combination of customers, equipment, product specialty,
and labor resources. Thus, only by
working together can printers and
their suppliers make fully-informed
ink choices.
Similarly, the DfE Partnership recognizes that lessons learned by flexographers in developing, selecting, and
using inks represent another important
Information
Exchange
Web Page:
www.epa.gov/dfe/
flexography/
flexography.html
source of guidance. Most of the innovative approaches to reducing environmental health and safety impacts of ink
systems naturally come from industry
members, like you.
DfE Seeks Lessons Learned
from Industry Leaders, Like You
In the next few months prior to the
release of the CTSA, the Partnership
seeks input from printers and ink formulators, like you, in providing information to supplement the CTSA and
aid their colleagues in the innovation
and use of cleaner, safer inks. To facilitate this information exchange, the
DfE Web site now features a new
interactive page designed to allow
industry members to share insights on
optimizing the ink-selection and use
process. The format for information
exchange is organized into topic areas
such as performance, cost, and health
and environmental risk. For example,
in the performance topic area, sample
questions include:
• What are critical performance
attributes for wide-web film at
your facility?
• Share tips on optimizing performance for water-based inks.
• What information from ink formulators do you find most helpful in
selecting and using inks?
The Web page is organized for easy access
and information exchange with opportunities for formal and informal interaction.
Your input, combined with information
from the CTSA, will help the DfE
Partnership communicate practical, helpful
information to other flexographers.
See for yourself. Visit the flexography
page on DfE Web site at
www.epa.gov/dfe/flexography/
flexography.html. We look forward to
your contribution.
Partners in the
DfE Flexography
Project include:
California Film Extruders and
Converters Association
(CFECA)
Flexible Packaging Association
(FPA)
Flexographic Technical
Association (FTA)
Industrial Technology Institute
(ITI)
National Association of
Printing Ink Manufacturers
(NAPIM)
Film and Bag Federation (FBF)
RadTech International N.A.
National Institute of Standards
and Technology (NIST)
University of Tennessee (UT)
U.S. Environmental Protection
Agency (EPA)
Western Michigan University
(WMU)
and individual printers and
suppliers.
About the Design for the Environment Flexography Project
The broad goal of the DfE Flexography project is to provide flexographers with information that can
help them design an operation which is more environmentally sound, safer for workers, and more
cost effective.
The partners of the DfE Flexography Project, in a voluntary cooperative effort, are evaluating three
different ink technologies: solvent-based, water-based, and UV-cured. Information is being gathered
on the performance, cost, and health and environmental risk implications of several inks within
each technology.
In addition to the Flexography Project, DfE is piloting environmental management systems with the
Screen Printing and Graphic Imaging Association. DfE has also completed CTSA projects on screen
printing reclamation systems and lithographic blanket washes.
Mention of trade names, companies, or commercial products does not constitute endorsement or
recommendation of use by either the U.S. Environmental Protection Agency or other firms, organizations, or individuals who have participated in the preparation of this publication.
V - 14
V - 15
V - 16
SUP-7.8 National Trade Associations - Partial Listing
(Current as of December 1999)
National Coalition for
Advanced Manufacturing
(NACFAM)
202/216-2740
202/289-7618 fax
Business Forms Management
Association
503/227-3393
503/274-7667 fax
http://bfma.org
Newspaper Association of
America (NAA)
703/902-1600
703/620-4557
http://www.naa.org
National Association of
Manufacturers
202/637-3000
202/637-3182 fax
http://www.nam.org
Graphic Arts Technical
Foundation (GATF)
412/741-6860
800/910-GATF
412/741-2311 fax
http://www.gatf.com
North American Graphic Arts
Suppliers Association
(NAGASA)
202/328-8441
202/328-8513 fax
http://nagasa.org/
Graphics Arts Marketing
Information Service/PIA
703/519-8100
http://printing.org/
NPES, The Association For
Suppliers of Printing and
Publishing Technologies
703/264-7200
703/620-0994 fax
http://www.npes.org
Chemical Coaters Association
Helpline
800/9 COAT IT
513/624-0601 fax
http://www.finishing.com/ccai/
index.html
CTC Hotline -- U.S. EPA
Control Technology Center
919/541-0800
919/541-0242 fax
http://www.epa.gov/earth100/
records/a00130.html
Electronics Manufacturing
Productivity Facility
317/226-5601
317/226-5615 fax
http://www.indiana.edu/~rugs/
ctrdir/empf.html
American Forest & Paper
Association
202/463-2700
202/463-2471 fax
http://205.197.9.134/
Association of Graphics
Communications (AGC)
212/279-2100
212/279-5381 fax
http://agcomm.org/
International Association of
Printing House Craftsmen
800/466-4274
612/560-1350 fax
http://www.iaphc.org/
International Digital Imaging
Association (IDIA)
908/359-3924
908/359-7619 fax
http://www.idia.org
International Prepress
Association
612/896-1908
612/896-0181 fax
http://www.ipa.org
Screen Printing & Graphic
Imaging Association
International
703/385-1335
703/273-0456 fax
http://www.sgia.org
National Recycling Coalition
703/683-9025
703/683-9026 fax
http://www.nrc-recycle.org/
National Association for
Printing Leadership
201/634-9600
201/634-0324 fax
http://www.napl.org
PrintImage International
312/321-6886
312/527-6789 fax
http://www.printimage.org
University of Wisconsin-Extension & The Solid and Hazardous Waste Education Center, January, 2000
V - 17
V - 18
State Pollution Prevention Technical Assistance Programs
Region 1
US EPA Region 1
Mark Mahoney
JFK Federal Bldg (SPP)
Boston, MA 02203
Ph: 617/ 918-1155
Fx: 617/565-4939
[email protected]
Connecticut DEP
Kim Trella
79 Elm St
Hartford, CT 06106
Ph: 860/424-3234
Fx: 860/566-4924
Maine DEP
Chris Rushton
State House Station 17
Augusta, ME 04333
Ph: 207/287-7100
Fx: 207/287-2814
[email protected]
Massachusetts DEP- OTA
Scott Fortier
100 Cambridge St. Rm 2109
Boston, MA 02202
Ph: 617/626-1090
Fx: 617/6261095
[email protected]
MA OTA - STEP Program
Paul Richard
100 Cambridge St. Rm 2000
Boston, MA 02202
Ph: 617/626-1042
[email protected]
Toxics Use Reduction Institute
Janet Clark
One University Avenue
Lowell, MA 01854
Ph: 508/934-3346
Fx: 508/934-3050
[email protected]
New Hampshire DES
Stephanie D=Agostino
6 Hazen Drive
Concord, NH 03301
Ph: 603/271-6398
Fx: 603/271-2867
[email protected]
Rhode Island DEM
Richard Enander
235 Promenade St.
Providence, RI 02908
Ph: 401/222-6822
Fx: 401/222-3810
Narragansett Bay Commission
James McCaughey
235 Promenade St.
Providence, RI 02908
Ph: 401/222-6680
Fx: 401/222-2584
[email protected]
New York DEC-P2 Unit
Mary Werner
50 Wolf Rd
Albany, NY 12233
Ph: 518/457-2553
Fx: 518/457-2570
[email protected]
Puerto Rico Environment
Carlos Gonzales
Ph: 809/765-7517 x381
Fx: 809/765-6853
Region 3
Vermont ANR
Gary Gulka
103 South Main St
Waterbury, VT 05671
Ph: 802/241-3626
[email protected]
NEWMOA
Terri Goldberg
129 Portland St, Suite 602
Boston, MA 02114
Ph: 617/367-8558
Fax: 617-367-0449
[email protected]
US EPA Region 3
Jeff Burke
1650 Arch St
Philadelphia PA 19103
Ph: 215/814-2761
Fx: 215/814-2782
[email protected]
Region 2
Delaware DNR
Andrea Kreiner
PO Box 1401
89 Kings Highway
Dover, DE 19903
Ph: 302/739-3822
Fx: 302/739-6242
[email protected]
US EPA Region 2
Danielle Fuligni
290 Broadway (SPMMB)
New York, NY 10007
Ph: 212/ 637-3584
Fx: 212/637-3771
[email protected]
MD Dept of Environment
Laura Armstrong
2500 Broening Hwy
Baltimore, MD 21224
Ph: 410/631-4119
Fx: 410/631-4477
[email protected]
New Jersey DEP
Melinda Dower
401 E State St, PO Box 423
Trenton, NJ 08625
Ph: 609/292-1122
Fx: 609/777-1330
[email protected]
PA Dept of Environment
Meredith Hill
PO Box 2063
Harrisburg, PA 17105
Ph: 717/783-8727
Fx: 717/787-8470
[email protected]
NJ TAP
Laura Battista
138 Warren St
Newark, NJ 07102
Ph: 973/596-5864
Fx: 973/596-6367
[email protected]
PA Technical Assistance
Jack Gido
110 Barbara Bldg II
University Park, PA 16802
Ph: 814/865-0427
Fx: 814/865-5909
V - 19
p. 2 of 5
Virginia DEQ
Sharon K. Baxter
PO Box 10009
Richmond, VA 23240
Ph: 804/698-4344
Fx: 804/698-4277
[email protected]
Kentucky P2 Center
Cam Metcalf
420 Lutz Hall
Louisville, KY 40292
Ph: 502/852-0965
Fx: 502/852-0964
[email protected]
Illinois Waste Mgmt
Tim Lindsey
One East Hazelwood Dr.
Champaign, IL 61820
Ph: 217/333-8955
Fx: 217/333-8944
[email protected]
West Virginia DEP-OWR
Leroy Gilbert
HC 61 Box 384
Danese, WV 25831
Ph: 304/484-6269
Fx: 304/558-2780
[email protected]
Mississippi DEQ
Thomas E. Whitten
PO Box 20305
Jackson, MS 39289
Ph: 601/961-5241
Fx: 601/961-5349
Indiana DEM
John Chavez
100 N Senate Ave PO6015
Indianapolis, IN 46206
Ph: 317/233-6658
Fx: 317/233-5627
[email protected]
Region 4
US EPA Region 4
Dan Ahern
61 Forsyth St SW
Atlanta, GA 30303
Ph: 404/ 562-9028
Fx: 404/562-9066
[email protected]
Alabama DEM - P2 Unit
Gary Ellis
PO Box 301463
Montgomery, AL 36130
Ph: 334/213-4303
Florida DEP - P2 Program
Julie Abcarian
2600 Blair Stone Road
Tallahassee. FL 32399
Ph: 850/488-0300
Fx: 850/921-8061
[email protected]
Georgia DNR- P2AD
Jancie Hatcher
7 MLK Jr. Dr. Suite 450
Atlanta. GA 30334
Ph: 404/651-5120
Fx: 404/651-5130
[email protected]
Kentucky DEP
Vicki Pettus
14 Reilly Road
Frankfort, KY 40601
Ph: 502/564-6716
North Carolina DEHNR
Gary Hunt
PO Box 29569
Raleigh, NC 27626
Ph: 919/715-6500
Fx: 919/715-6794
[email protected]
South Carolina DHEC
Robert Burgess
2600 Bull St
Columbia, SC 29208
Ph: 803/898-3971
[email protected]
Tennessee DEC
Angie Pitcock
401 Church St
Nashville, TN 37243
Ph: 615/532-0760
Region 5
US EPA Region 5
Phil Kaplan
77 West Jackson Blvd
Chicago, IL 60604
Ph: 312/353-4669
Fx: 312/353-4788
[email protected]
Illinois EPA
Keri Luly
1021 N Grand Ave. East
Springfield, IL 62794
Ph: 217/524-1846
Fx: 217/557-2125
[email protected]
V - 20
IN Clean Manufacturing Tech & Safe
Materials Institute
Alice Smith
2655 Yeager Rd. Suite 103
West Lafayette, IN 47906
Ph: 765/463-4749
Fx: 765/463-3795
[email protected]
Michigan DEQ
Marcia Horan
PO Box 30273
Lansing, MI 48909
Ph: 517/373-9122
Fx: 517/335-4729
[email protected]
Minnesota (MN TAP)
Cindy McComas
1313 5th St SW Suite 207
Minneapolis, MN 55414
Ph: 612/627-4556
Fx: 612/627-4769
[email protected]
MN Pollution Control Agency
Al Innes
520 Lafayette Road North
St. Paul, MN 55155
Ph: 651/296-7330
Fx: 651/282-6247
[email protected]
MN Office of Environmental Assistance
Phillip Muessig
520 Lafayette Road North
St. Paul, MN 55155
Ph: 651/215-0204
Fx: 651/215-0246
[email protected]
MN Technology Inc.
Kevin O'Donnell
111 3rd Ave. South
Minneapolis, MN 55401
Ph: 612/672-3446
Fx: 612/497-8475
[email protected]
Louisiana DEQ
Gary Johnson
PO Box 82263
Baton Rouge, LA 70884
Ph: 504/765-0739
Fx: 504/765-0742
[email protected]
Ohio EPA
Michael Kelley
P.O. Box 1049
Columbus, OH 43216-1049
Ph: 614/644-3469
Fx: 614/728-2807
[email protected]
Louisiana TAP
University of New Orleans
New Orleans, LA
Ph: 504/286-6305
Fax: 504/286-5586
University of Wisconsin
Rick Grote
610 Langdon St, Rm 530
Madison, WI 53703
Ph: 608/265-3055
Fx: 608/262-6250
[email protected]
National Farmstead Program
Liz Nevers
B142 Steenbock Library
Madison WI 53706
Ph: 608/265-2774
Fx: 608/265-2775
[email protected]
Wisconsin DNR
Lynn Persson
PO Box 7921
Madison, WI 53707
Ph: 608/267-3763
Fx: 608/267-0496
Region 6
US EPA Region 6
Eli Martinez
1455 Ross Ave Suite 1200
Dallas, TX 75202
Ph: 214/665-2119
Fx: 214/665-7446
[email protected]
Arkansas IDC
Alford Drinkwater
One Capitol Mall
Little Rock, AR 72201
Ph: 501/682-7325
Fx: 501/682-2703
adrinkwater@aedc/state.ar.us
p. 3 of 5
Lower Colorado River Authority
Mark Johnson
PO Box 220
Austin, TX 78703
Ph: 512/473-3200
Fx: 512/473-3579
[email protected]
Region 7
New Mexico ED
Patricia Gallagher
1190 St Framcis Dr
Sante Fe, NM 87502
Ph: 505/827-0677
Fx: 505/827-2846
[email protected]
Oklahoma DEQ
Dianne Wilkins
707 N Robinson PO Box 1677
Oklahoma City, OK 73101
Ph: 405/702-6116
Fx: 405/702-6100
[email protected]
Texas NRCC
Kathey Ferland
PO Box 13087 - MC112
Austin, TX 78711
Ph: 512/239-3177
Fx: 512/239-3165
[email protected]
Gulf Coast Hazardous Substance
Research
Margaret Aycock
PO Box 10671
Beaumont, TX 77710
Ph: 409/880-8897
Fx: 409/880-1837
[email protected]
TX Manuf. Assistance Center
Conrad Soltero
Univ. of TX-El Paso
500 W University , Burges
El Paso, TX 75202
Ph: 915/747-5930
Fx: 915/747-5437
[email protected]
V - 21
US EPA Region 7
Marc Matthews
726 Minnesota Ave (ARTD/TSPP)
Kansas City, KS 66101
Ph: 913/551-7517
Fx: 913/551-7065
[email protected]
Iowa DNR
Jeff Fiagle
502 E. 9th St
Des Moines, IA 50319
Ph: 515/281-5353
Fx: 515/281-8895
[email protected]
Iowa Waste Reduction Center
Christine Twait
1005 Technology Parkway
Cedar Fall, IA 50613
Ph: 319/273-8905
Fax: 319/268-3733
[email protected]
IOWA DED
Linda King
Small Business Liasion
Ph: 515/242-4761
Fx: 515-242-6338
Kansas DHE
Janet Neff
Bldg. 283 , Forbes Field
Topeka, KS 66620
Ph: 785/296-0669
Fx: 785/296-3266
[email protected]
KSU - P2 Institute
Sherry Davis
133 Ward Hall
Manhatten, KS 66506
Ph: 785/532-6501
Fx: 785/532-6952
[email protected]
Missouri DNR - TAP
David Goggins
PO Box 176
Jefferson City, MO 65102
Ph: 573/526-6627
Fx: 573/526-5808
[email protected]
NE Business Development Center
Rick Yoder
1135 M St, Suite 200
Lincoln, NE 68508
Ph: 402/472-1183
Fx: 402/472-3363
[email protected]
Nebraska DEQ, P2 Office
Ben Hammerschmidt
PO Box 98922
Lincoln, NE 68509
Ph: 402/471-6988
Fax: 402/471-2909
[email protected]
MAMTC
Anne Brown
801 Campus Dr
Garden City, KS 67846
Ph: 316/276-9505
Fx: 316/276-9523
[email protected]
p. 4 of 5
Region 8
Region 9
US EPA Region 8
John Larson
999 18th St, Suite 500
Denver, CO 80202
Ph: 303/312-6030
Fx: 303/312-6741
[email protected]
US EPA Region 9
Eileen Sheehan
75 Hawthorn St (WST-1-1)
San Francisco, CA 94105
Ph: 415/744-2190
Fx: 415/744-1680
[email protected]
Colorado DHE
Parry Burnap
4300 Cherry Creek Dr
Denver, CO 80222
Ph: 303/692-3009
Fx: 303/782-4969
[email protected]
Arizonia DEQ
Jacquelione Maye
3033 North Central Ave
Phoenix, AZ 85012
Ph: 602/207-4607
Fax: 602/207-2302
[email protected]
Montana P2 Program
Michael P. Vogel
109 Taylor Hall
Bozeman, MT 59717
Ph: 406/994-3451
Fx: 406/994-5417
[email protected]
California EPA
Terri Cronin
8800 Cal Center Dr
Sacramento, CA 95826
North Dakota Dept of Health
Jeffrey L. Burgess
PO Box 5520
Bismarck, ND 58506-5520
Ph: 701/328-5150
Fx: 701/328-5200
[email protected]
South Dakota DENR
Dennis Clarke
523 E Capitol Ave
Pierre, SD 57501-3151
Ph: 605/773-4254
Fx: 605/773-4068
Utah DEQ
Sonja Wallace
168 N 1950 West
Salt Lake City, UT 84114
Ph: 801/536-4477
Fx: 801/536-0061
swallace.deq.state.ut.us
Wyoming DEQ
Patricia Jordan
122 West 25th
Cheyenne, WY 82002
Ph: 307/777-6105
Fx: 307/777-5973
[email protected]
V - 22
California Energy Commission
David Jones
1519 9th St
Ph: 916/654-4554
CA Toxic Substance Control
Kathy Barwick
PO Box 806
Ph: 916/323-9560
Fx: 916/327-4494
UCLA P2 Center
Billy Romain
Ph: 310/825-2654
Fx: 310/206-3906
Hawaii Department of Health
Marlyn Aguilar
919 Ala Moana Blvd, Rm 212
Honolulu, HI 96814
Ph: 808/586-7496
Fx: 808/586-7509
[email protected]
Nevada Small Business Development
Center
Kevin Dick
6100 Neil Rd. Suite 400
Reno, NV 89511
Ph: 775/689-6677
Fx: 775/689-6689
[email protected]
Region 10
US EPA Region 10
Carolyn Gangmark
1200 Sixth Ave (01-085)
Seattle, WA 98101
Ph: 206/553-4072
Fx: 206/553-8338
[email protected]
Alaska DEC
Marianne See
555 Cordova St
Anchorage, AK 99501
Ph: 907/269-7586
Fx: 907/269-7600
[email protected]
p. 5 of 5
Idaho DEQ
Katie Sewell
450 West State St
Boise, ID 83720
Ph: 208/373-0465
Fx: 208/373-0169
[email protected]
Pacific Northwest P2 Resource Center
Madeline Sten
1326 Fifth Ave., Suite 650
Seattle, WA 98101
Ph: 206/223-1151
Fx: 206/223-1165
[email protected]
Oregon DEQ
Marianne Fitzgerald
811 SW Sixth St
Portland, OR 97204
Ph: 503/229-5946
Fax: 503/229-5850
[email protected]
Washington State University
Carol Reisenberg
501 Johnson Tower
Pullman, WA 99164
Ph: 509/335-1576
Fx: 509/335-0949
[email protected]
Washington DEC
Lynn Helbrecht
PO Box 47600
Olympia, WA 98504
Ph: 360/407-6760
Fx: 360/407-6715
[email protected]
This list is updated and maintained on the EPA P2 Home Page
www.epa.gov/oppintr/p2/p2statecontacts.htm
11/99
V - 23
V - 24
Clean Air Act Small Business Ombudsmen and Technical Assistance Directors
STATE
AL
OMBUDSMAN
PHONE
TECH. ASST. DIR.
PHONE
Blake Roper
(334) 394-4335
Mike Sherman
(334) 271-7873
(N) (800) 533-2336
AK
(N) (800) 533-2336
Tom Chapple
(907) 269-7686
(S) (800) 510-2332
AZ
Gregory Workman
(602) 207-4337
(S) (800) 234-5677,
x 4337
AZ
Richard Polito
(602) 506-5102
MARICOPA COUNTY
AR
CA
Kathleen Tschogl
(916) 323-6791
Joe Bob Garner
(501)682-0866
Peter Venturini
(916) 445-0650
(S) (800) 272-4572
CA
La Ronda Bowen
South Coast AQMD
CO
(909) 396-3235
(S) (800) 272-4572
Larry Kolczak
(S)(800)388-2121
Cathy Heald
(303) 692-2034
(S)(800)388-2121
Nick Melliadis
(S) (800) 886-7689
CT
Tracy Babbidge
(909) 396-3215
(303) 692-3175
(N) (800) 333-7798
(860) 424-3382
(S) (800) 760-7036
DE
To be Announced
(302) 739-6400
DC
Sandra Handon
(202) 535-1722
Olivia Achuko
(202) 535-2997
FL
Elsa Bishop
(850) 414-8399
Bruce Thomas
(850) 921-7744
(S) 800-722-7457
(S) (800) 722-7457
GA
Marvin Lowry
(404) 362-2656
Anita Dorsey-Word
(404) 362-4842
HI
Anthony Ching
(808) 586-4527
Robert Tam
(808) 586-4200
ID
Sally Tarowski
(208) 373-0472
IL
Don Squires
(217) 785-1625
Mark Enstrom
(217) 524-0169
(S) (888) 372-1996
IA
Linda King
(N) (515) 242-4761
(S) (800) 252-3998
John Konefes
(S) (800) 358-5510
IN
KS
Erika SeydelCheney
(317) 232-8598
Janet Neff
(785) 296-0669
(S) (800) 422-3109
Cheri Storms
(S) (800) 451-6027
Rose Marie Wilmoth
(502) 564-2150 X128
Jean Waters
Jim Friloux
(225) 765-0735
Gregory Copley
(606) 257-1131
(N) (800) 562-2327
Dick Lehr
(S) (800) 259-2890
MA
(785) 532-4698
(N) (800) 578-8898
(N) (800) 926-8111
LA
(317) 233-1041
(S) (800) 451-6027
(N) (800) 357-6087
KY
(319) 273-8905
(225) 765-2453
(S) (800) 259-2890
Terry Goldberg
(617) 367-8558
X 302
V - 25
p. 2 of 3
STATE
OMBUDSMAN
PHONE
TECH. ASST. DIR.
PHONE
MD
Don Jackson
(410) 631-3165
Andrew Gosden
410-631-4158
ME
Ron Dyer
(S) (800) 633-6101,
(S) ( 800) 633-
X 3772
6101,x4158
(207) 287-4152
Brian Kavanah
(S) (800) 789-9802
(207) 287-6188
(S) (800) 789-9802
MI
Dana Cole
(517) 241-3518
Dave Fiedler
(517) 373-0607
(N) (800) 662-9278
MN
Charlie Kennedy
(651) 297-8615
Troy Johnson
(651) 296-7767
(S) (800) 985-4247
MO
Angie Heffner
(573) 751-3222
(S) (800)657-3938
Byron Shaw
(S) (800)361-4827
MS
Jesse Thompson
(601) 961-5167
(N) (800) 361-4827
Randy Wolfe
Karen Ekstrom
(406) 444-2960
(N) (800) 433-8773
NE
Dan Eddinger
(402) 471-3413
NV
Marcia Manley
(775) 687-4670,
(601)961-5166
(N) (800)725-6112
(N) (800) 725-6112
MT
(573) 526-6627
Warren Norton
(406) 444-2960
(N) (800) 433-8773
Janet Goodman
(775) 687-4670,
x3164
x3162
(S) (800) 992-0900
NH
Rudolph Cartier
(603) 271-1379
Rudolph Cartier
(603) 271-1379
NJ
Lauren Moore
(609) 292-3863
Chuck McCarty
(609) 292-5565
Cecilia Williams
(505) 827-0042
(N) (800) 643-6090
NM
Robert Horwitz
(505) 827-9685
(N) (800) 810-7227
(N) (800) 810-7227
NY
Tria Case
(212) 803-2280
Marian J. Mudar,
Ph.d
(S) (800) 780-7227
(N) (800) 782-8369
NC
Edythe McKinney
(919) 733-0823
Karen Davis
Jeff Burgess
(701) 328-5153
Tom Bachman
Mark Shanahan
(614) 728-3540
(701) 328-5188
(S) (800) 755-1625
(S) (800) 755-1625
OH
(919) 733-1267
(N) 800-829-4841
(N) (800) 829-4841
ND
(518) 457-9135
Rick Carleski
(614) 728-1742
(S) (800) 225-5051
OK
Steve Thompson
(405) 702-7100
Alwin Ning
(405) 702-6100
OR
Paul Burnet
(503) 229-5776
Jill Inahara
(503) 229-6147
(800) 452-4011 (S)
V - 26
(S) (800) 452-4011
STATE
PA
p. 3 of 3
OMBUDSMAN
PHONE
TECH. ASST. DIR.
PHONE
Greg Czarnecki
(717) 772-8951
Cecily Beall
(215) 656-8709
(N) (800) 722-4743
PR
Tomas DeLeon
(787) 724-1451
Maria Rivera
(787) 767-8025
X296
RI
Pam Annarummo
(401) 222-6822
X7204
(S) (800) 253-2674
SC
SD
Natalie M. Loquist
Phyllis Copeland
Joe Nadenicek
(803) 898-3997
(803) 898-3957
(N) (800) 819-9001
(N) (800) 819-9001
(605) 773-3836
Bryan Gustafson
(S) (800) 438-3367
(S) (800) 438-3367
TN
Ernest Blankenship
(615) 532-6262
Linda Sadler
Israel Anderson
(512) 239-5319
Tamra ShaeOatman
Stephanie Bernkopf
(801) 536-4479
Ron Reece
(801) 536-4091
(N) (800) 270-4440
(N) (800)458-0145
VT
(512) 239-1066
(N) (800) 447-2827
(N) (800) 447-2827
UT
(615) 532-8012
(N) (800) 734-3619
(N) 800-734-3619
TX
(605) 773-7171
Judy Mirro
(802) 241-3745
(S) (800) 974-9559
VA
John Daniel
(804) 698-4311
Richard
Rasmussen
(S) (800) 592-5482
(S) (800) 592-5482
VI
WA
(804) 698-4394
Marylyn A.
Stapleton
(340) 777-4577,x228
Marylyn A.
Stapleton
(340) 777-4577,x228
Leighton Pratt
(360) 407-7018
Bernard Brady
(360) 407-6803
Fred Durham
(304) 558-1217
WV
(S) (800) 982-2474
WI
Hampton Rothwell
(608) 267-0313
Pam Christenson
(N) (800) 435-7287
(N) (800) 435-7287
WY
Note: (S) = State
Dan Clark
(307) 777-7388
(N) = National
V - 27
(608) 267-9214
Charles Raffelson
(307) 777-7347
V - 28
SUP-1.0 National Small Business Environmental Resources
Quick Reference List
Federal Hotlines
Water: Safe Drinking Water
9 am - 5:30 pm EST, M-F
800/426-4791
http://www.epa.gov/safewater
Chemical Information: ChemTrec Chemical
Referral Center (Chemical Manufacturers
Association)
9 am - 5 pm EST, M-F
800/262-8200
800/424-9346
http://www.cmahq.com
Pollution Prevention: U.S. EPA Information
Clearinghouse (PPIC)
202/260-1023
24-hour voice mail
http://www.epa.gov/earth100
Chemical Safety: Emergency Planning and
Community Right-to-Know Act (EPCRA)
800/535-0202
800/424-9346
http://www.epa.gov/epaoswer/hotline
Small Business Clearinghouse: U.S. EPA
Ombudsman
800/368-5888
24-hour voice mail
http://www.epa.gov/sbo
Groundwater/Stormwater: U.S. EPA Office of
Water Resource Center
202/260-7786
24-hour voice mail
http://www.epa.gov/watrhome
Solid & Hazardous Waste: (RCRA)
800/424-9346
Ozone Depleting Chemicals: Stratospheric Ozone
(Clean Air Act -CAA)
800/296-1996
http://www.epa.gov/ozone
Spill Response: National Response Center (U.S.
Coast Guard)
24 Hours
800/424-8802
http://www.epa.gov/superfund/programs/er/nrs/nrsnr
c.htm
Pesticides: National Pesticide
Telecommunications Network
6:30 am - 4:30 pm PST, M-F
800/858-7378
Superfund (CERCLA)
800/424-9346
Transportation: Hazardous Materials (U.S.
DOT)
202/366-4488
800/467-4922
http://hazmat.dot.gov/
Toxic Substances: Toxic Substances Control Act
(TSCA) and Asbestos
8:30 am - 5 pm EST, M-F
202/554-1404
http://www.epa.gov/opptintr/opptloc.htm
Underground Storage Tanks (USTs)
800/424-9346
University of Wisconsin-Extension & The Solid and Hazardous Waste Education Center, January, 2000
V - 29

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