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14 FLEXOGRAPHY: PRINCIPLES & PRACTICES

the standards may include, but are not limit-

ed to, process changes or material substitu-

tions; enclosure; measures to collect, cap-

ture or treat emissions; work practice or

operational requirements, or any combina-

tion of the above.

USEPA’s final NESHAP for the Printing

and Publishing Industry, adopted in May

1996, established emission limits for publi-

cation rotogravure printing, and package-

product rotogravure/wide-web flexographic

printing, and provides industry with several

compliance options

(existing facilities will

have three years to comply with the rule

[until May 1999]. Facilities may comply with

the rule’s requirements through the use of:

• pollution prevention methods that

allow printers to eliminate the use of

toxic chemicals by substituting non-

toxic chemicals for toxic ones;

• traditional emissions capture and con-

trol equipment that eliminates more

than 95% of the HAP emissions; or

• a combination of the two compliance

options.

Because of the NESHAP, air toxics emis-

sions are expected to be reduced from pack-

age-product rotogravure and wide-web flex-

ographic printers by about 2,100 tons annu-

ally, representing a 40% reduction from cur-

rent levels. The final version of NESHAP

also outlines the monitoring, record keeping

and reporting requirements.

The Printing and Publishing NESHAP

allows for the use of inks, coatings and other

materials that contain low quantities of haz-

ardous air pollutants without having to

install additional control equipment. This

provides a pollution prevention approach to

compliance. Most HAPs used by printers are

also VOCs. The use of materials that contain

low amounts of VOCs, such as in water-

based systems, has provided a popular, alter-

native method for printers to meet state and

federal VOC emission requirements without

the costs of additional control equipment.

The pollution prevention options in the final

rule build upon this alternative method for

meeting VOC emissions requirements by

extending it to HAPs.

The regulation allows all affected facilities

to assess compliance across all of the print-

ing presses present at the facility. During the

regulatory development process, compliance

was assessed for package-product roto-

gravure/wide-web flexographic printing facil-

ities on a press-by-press basis. The multi-

press approach in the final regulation will

allow for the most cost-effective reduction of

HAP emissions and provide printers with the

most flexibility in scheduling production in

their facilities.

USEPA’s final regulation applies to about

200 printing and publishing facilities nation-

wide. This includes some facilities that are

major sources because of non-printing activ-

ities and only emit small amounts of HAPs

from printing operations. Simplified require-

ments for these facilities are included in the

final rule.

The estimated industry-wide annualized

costs of the final regulations are estimated at

$40 million. These costs include $21 million

per year for publication rotogravure printers

and $19 million per year for package and prod-

uct rotogravure and wide-web flexographic

printers. The annual costs associated with the

final regulation could be considerably lower

for facilities that use inks, solvents and other

materials that contain low amounts of HAPs.

OZONE-DEPLETING CHEMICALS

The ozone layer in the upper atmosphere

provides protection by absorbing harmful

ultraviolet radiation emitted from the sun,

and should not be confused with the ozone

smog that we breathe. Without the ozone

Refer to 40 CFR (Code of Federal Regulations), parts 9 and 63.

layer, life on Earth could not exist. Ozone in

the stratosphere serves as a protective

shield, filtering out harmful ultraviolet radia-

tion emitting from the sun. Exposure to UV

light has been linked to the development of

cataracts and skin cancer.

In the mid-1970s, scientists suggested that

chlorofluorocarbons (CFCs) could destroy

stratospheric ozone. Evidence that the ozone

layer is dwindling led 93 nations, including

the major industrialized nations, to agree to

cooperate in reducing production and use of

chemicals that destroy the ozone layer. Many

ozone-destroying chemicals have been, and

still are being, phased out of production

because of the CAAA.

Title VI of the CAAA deals with ozone-

depleting chemicals. Two solvents in partic-

ular, carbon tetrachloride and methyl chlo-

roform (1,1,1-trichloroethane), used in the

printing industry, are affected by this law. As

such they were no longer produced in the

United States as of January 1, 1996.

IMPACT ON SMALL BUSINESS

To attain the NAAQS and control toxic

emissions, air pollutants from hundreds of

thousands of small businesses

are now being

controlled. The specific requirements affect-

ing small businesses depend on how badly

the local air is polluted and the kinds and

quantities of pollutants the businesses emit.

Small businesses may or may not be

required to obtain a Title V operating permit

depending on their potential to emit (PTE).

Potential to emit currently is the only feder-

ally acceptable method to determine applic-

ability of air pollution regulations, for both

VOCs and HAPs

. The concept of PTE

assumes that the given piece of equipment

runs 24 hours a day and 365 days per year,

with maximum material consumption or

maximum design capacity, unless the cur-

rent operating permit imposes limitations on

hours of operation, materials consumption

or other process variables.

SMALL BUSINESS ASSISTANCE

To ensure that small businesses would have

access to the technical and compliance infor-

mation necessary to comply with the CAAA of

1990, every state was required under Section

507 to establish a Small Business Stationary

Source Technical and Environmental Compli-

ance Assistance Program. The program’s com-

ponents include a Small Business Ombuds-

man (SBO) and Small Business Assistance

Program (SBAP). The Small Business

Ombudsman serves as a representative of

small businesses, cuts red-tape, provides out-

reach and education, and works closely with

the Small Business Assistance Progam, which

provides technical and compliance assistance.

Every state now has a small business pro-

gram, but the degree to which they provide

assistance is dependent on funding levels.

They typically provide seminars, workshops,

pollution prevention and assistance guides,

and on-site audits. At a minimum, all pro-

grams can provide information and assis-

tance over the telephone. Some programs

are confidential and/or separate from the

regulatory agency, so businesses can talk

freely about their compliance status.

For a list of the current ombudsman and

assistance programs, contact the USEPA

Small Business Ombudsman at (800) 368-

5888, or visit their web site: www.icubed.

com/epa_sbo/index.html.

ENVIRONMENT AND SAFETY 15

Small businesses have been defined as a stationary source that is owned or

operated by a person that employs 100 or fewer employees, is a small busi-

ness concern as defined by the US Small Business Administration, is not a

major stationary source, does not emit 50 tons or more per year of any reg-

ulated pollutant, and emits less than 75 tons per year of all regulated pollu-

tants.

The USEPA is considering a rule by which businesses operating below 50%

of the major source threshold could avoid the Title V permit.

16 FLEXOGRAPHY: PRINCIPLES & PRACTICES

ome hazardous substances are

regulated under the Toxic Sub-

stances Control Act (TSCA).

TSCA was enacted by Congress

to test, regulate and screen all

chemicals produced or import-

ed into the United States. Many thousands of

chemicals and their compounds are devel-

oped each year with unknown toxic or dan-

gerous characteristics. TSCA requires that

any chemical used for commercial purposes

must either appear on or be exempt from the

TSCA Chemical Substance Inventory. In

addition, records of allegations of previously

unknown adverse health effects from expo-

sure to any chemical must be maintained.

Any existing chemical that poses health

and environmental hazards is tracked and

reported under TSCA. Procedures also are

authorized for corrective action under TSCA

in cases of cleanup of toxic materials conta-

mination. TSCA supplements other federal

statutes, including the Clean Air Act and the

Toxic Release Inventory under Emergency

Planning and Community Right-to-Know.

Toxic Substances

Control Act

Of importance to the printing industry are

Sections 4, 5, 6 and 8 of TSCA:

Section 4: Authorizes the USEPA to require

testing of chemical substances or mixtures

that the USEPA determines could be a risk

to human health or to the environment.

Section 5: Grants the USEPA the right to test

all new chemical substances to determine

their toxicity and subsequent risk 90 days

before manufacturing, processing or import-

ing of said chemical.

Section 6: This section is the official notifica-

tion that the USEPA may regulate the manu-

facture, processing, distribution in com-

merce, and use and disposal of any chemical

substance determined to be toxic.

Section 8: Requires all users and manufactur-

ers to keep records and submit reports to

the USEPA. For example, printers using film

developers or replenishers should contact

the local environmental agency to determine

reporting requirements. Also, printers who

import inks are also subject to all TSCA

reporting requirements.

urrent operating industries that

produce hazardous wastes are

regulated by the provisions of the

Resource Conservation and Re-

covery Act (RCRA). One major

requirement is a cradle-to-grave

reporting system that tracks hazardous

wastes from the factory through transporta-

tion, treatment and disposal. Most states have

received authority from USEPA to regulate

and enforce RCRA. All the RCRA hazardous

waste regulations can be found in 40 CFR

Parts 260 and 279.

To be considered hazardous waste, a mate-

rial must first be classified as a solid waste.

USEPA defines solid waste as garbage,

refuse, sludge or other discarded material

(including solids, semisolids, liquids and con-

tained gaseous materials). Wastes are defined

as hazardous if they are specifically named on

one of four lists of hazardous wastes (listed

wastes), or if they exhibit one of four charac-

teristics (characteristic wastes).

LISTED WASTES

There are four separate lists of hazardous

wastes. If any of the wastes from a printing

facility is on any of these lists, the facility is

subject to regulation under RCRA. The listing

is often defined by industrial processes, but

all wastes are listed because they contain

particular chemical constituents. These con-

stituents are listed in Appendix VII to 40 CFR

Part 261 with code letters F, P, K and U

For wastes from non-specific sources and

ENVIRONMENT AND SAFETY 17

Resource Conservation

And Recovery Act

including wastes generated by industrial

processes that may occur in several different

industries, the code always begins with F.

F001 through F005 designate various types

of spent solvent waste. Examples include

methylene chloride, 1,1,1,-trichloroethane,

xylene, acetone, benzene and n-butyl alco-

hol. The second category of listed wastes

includes hazardous wastes from specific

sources; these wastes have codes that begin

with the letter K, but are not used in the

printing industry.

The remaining lists cover commercial

chemical products that have been or are

intended to be discarded; these have two

letter designations, P and U. Waste codes

beginning with P are considered acutely

hazardous, while those beginning with U are

simply considered hazardous (Table 4). No

chemicals used in the printing industry are

considered as acutely hazardous Code P.

Due to the 1980 adoption of the “mixture

rule” and the “derived-from” rule, generators

cannot evade hazardous waste regulations by

diluting or otherwise changing the composi-

tion of listed waste. The mixture rule pro-

vides that any mixture of a listed hazardous

and non-hazardous waste is a hazardous

waste. The derived-from rule provides that

waste derived from a listed hazardous waste

is also deemed hazardous waste. These rules

were struck down in 1991, but at the court’s

suggestion, the USEPA has temporarily reen-

Lists of the F, P, K and Hazardous wastes can also be obtained by calling the

USEPA RCRA/Superfund/EPCRA Hotline at (800) 424-9346.

18 FLEXOGRAPHY: PRINCIPLES & PRACTICES

acted the rules on an interim basis while it

conducts a new rulemaking review.

CHARACTERISTIC WASTES

Even if a waste does not appear on one of

the hazardous waste lists, it still might be reg-

ulated as hazardous waste if it exhibits one

or more of the following characteristics:

Ignitability: Wastes which create fires under

certain conditions or are spontaneously com-

bustible and have a flash point less than 60°C

(140° F). Examples include used solvents

which have a waste code of D001.

Corrosivity: Corrosive wastes are acids or

bases that are capable of corroding metal

containers, such as storage tanks, drums and

barrels. Acid and alkaline process baths are

a good example. The waste code for these

materials is D002.

Reactivity: Reactive wastes are unstable

under “normal” conditions. They can cause

explosions, toxic fumes, gases or vapors

when mixed with water. The waste code for

these materials is D003.

Toxicity: Toxic wastes are harmful or fatal

when ingested or absorbed. When toxic

wastes are disposed of on land, contaminat-

ed liquid may drain (leach) from the waste

and pollute the ground water. Toxicity is

defined through a laboratory procedure

called the Toxicity Characteristic Leaching

Procedure. Toxic printing wastes include sil-

ver (D011), carbon tetrachloride (D019) and

trichloroethylene (D040). Waste codes for

toxic materials range from D004 to D040.

GENERATOR STATUS

Generator status defines how to dispose of

a listed or characteristic waste. The haz-

ardous waste generator is defined as any per-

son, by site, who creates a hazardous waste

or makes a waste subject to RCRA Subtitle C.

Generators are divided into three categories:

Large Quantity Generators (LQG): These facili-

ties generate at least 1,000 kg. (2,200 lbs.)

of hazardous waste per month, or more than

1 kg. (2.2 lbs.) of acutely hazardous

waste

per month.

Small Quantity Generators (SQG): These facili-

ties generate more than 100 kg. (220 lbs.) but

less than 1,000 kg. (2,200 lbs.) hazardous

waste per month and up to 1 kg. (2.2 lbs.) of

acutely hazardous waste per month.

Conditionally Exempt Small Quantity Gener-

ators (CESQG)

: These facilities generate no

Table 4

Waste Name or Description

Code of Waste

U002 Acetone*

U019 Benzene

U211 Carbon tetrachloride

U055 Cumene

U056 Cyclohexane

U069 Dibutyl phthalate

U112 Ethyl acetate

U359 Ethanol, 2-ethoxy

U359 Ethylene glycol monoethyl ether

U122 Formaldehyde

U154 Methanol

U226 Methyl chloroform

U080 Methylene chloride

U159 Methyl ethyl ketone (MEK)

U161 Methyl isobutyl ketone

U210 Tetrachloroethylene (perchloroethylene)

U220 Toluene

U223 Toluene diisocyanate

U228 Trichloroethylene

U043 Vinyl chloride

U239 Xylene

*recently delisted.

CODE U LISTED PRINTING WASTES

Not likely to affect printers.

Some states do not recognize the CESQG class. Contact the state environ-

mental agency to find out if the CESQG is recognized. To find the appropriate

state contact, call the RCRA Hotline at (800) 424-9346.

more than 100 kg. (220 lbs.) per month of

hazardous waste and up to 1 kg. (2.2 lbs.) per

month of acutely hazardous waste.

Large and small quantity generators must

meet many similar requirements. Small

Quantity Generators may accumulate up to

6,000 kg. (13,200 lbs.) of hazardous waste

on-site at any one time for up to 180 days

without being regulated as a treatment, stor-

age or disposal facility (TSD) and thereby

having to apply for a TSD permit. Small

Quantity Generators are allowed to store

waste on-site for 270 days without having to

apply for TSD status provided the waste

must be transported over 200 miles. Large

Quantity Generators have only a 90-day win-

dow to ship waste off-site without needing a

TSD permit. Most provisions do not apply to

generators who send their wastes off-site

within the 90- or 180-day window wherever

applicable.

Hazardous waste generators that do not

meet the conditions for Conditionally

Exempt Small Quantity Generators must:

• obtain a generator identification number;

• store and ship hazardous waste in suit-

able containers or tanks;

• manifest the waste properly;

• maintain copies of the manifest, a ship-

ment log covering all hazardous waste

shipments and test records;

• comply with applicable land disposal

restriction requirements; and

• report releases or threats of releases of

hazardous waste.

TRANSPORTATION

Under the Superfund Amendment and

Reauthorization Act, no one without a gener-

ator number may transport or offer for trans-

portation a hazardous material. This number

must appear on the manifest and on all labels.

Most states supply numbered manifest

forms with enough duplicates for the state

agency, the generator, each transporter, and

the designated TSD facility, with another

copy signed and returned to the generator.

A manifest must contain all of the follow-

ing information:

• a manifest document number;

• the generator’s name, mailing address,

telephone number and USEPA identifi-

cation numbers;

• the name and USEPA identification

number of each transporter;

• the name, address and USEPA identifi-

cation number of the TSD facility and

an alternative facility, if any;

• all items required by the US Department

of Transportation regulations, such as a

description of the wastes and proper

shipping name; and

• the quantity of each hazardous waste

item, by units of weight or volume, and

the type and number of containers as

loaded into the transporter’s vehicle.

The following certification must appear

verbatim on the manifest: “This is to certify

that the above-named materials are properly

classified, described, packaged, marked and

labeled and are in proper condition for trans-

portation according to the applicable regula-

tions of the Department of Transportation

and the USEPA.” For an example of a haz-

ardous waste manifest, see Appendix B.

The generator must sign the manifest by

hand and so must the initial transporter, who

must also write the date of acceptance. The

remaining copies accompany the shipment

to the TSD facility.

If the generator doesn’t receive a hand-

signed copy of the manifest from the TSD

facility within 35 days, the transporter

and/or the facility must be contacted. If the

manifest is not located in 10 days, the gener-

ator must send a copy of the manifest with a

cover letter to the regional USEPA adminis-

trator explaining efforts made to locate the

shipment and any results. This will give the

USEPA the basis for an investigation.

ENVIRONMENT AND SAFETY 19

20 FLEXOGRAPHY: PRINCIPLES & PRACTICES

The generator must keep the signed copy

of the manifest and any related papers for at

least three years. They must also file an

annual report for the preceding year no later

than March 1, listing transporters and facili-

ties used that year. In some states, reporting

is required every two years; this can be

checked with the local regulatory agency.

The records may be inspected at any time,

and generators should put them in a perma-

nent file.

UNDERGROUND STORAGE

TANK MANAGEMENT

RCRA establishes a program to control

and prevent leaks from underground storage

tanks. A storage tank is defined as under-

ground if 10% or more of the volume, includ-

ing the volume of underground pipes, is

beneath the surface of the ground. In the

printing industry, any of the following

exemptions may apply:

• underground storage tanks storing

heating oil used on premises;

• septic tanks and other tanks for collect-

ing waste water and storm water;

• flow-through process tanks;

• emergency spill tanks that are emptied

immediately after use.

Tanks that are not exempt must be

approved and must have all requirements for:

• design, construction, installation and

notification;

• general operations;

• release detection;

• release reporting, investigation and

confirmation;

• release response and corrective action

(for petroleum underground storage

tanks);

• closure of underground storage tanks;

and

• financial assurance (for petroleum and

ground storage tanks).

SPILLS

Every facility that generates hazardous

waste should have a contingency plan in

case of leaks or spills.

If a truck carrying hazardous waste has a

leak or spill, the vehicle must leave the high-

way and stop at the safest available place.

The driver must contact the National

Response Center (800) 424-8802, and a haz-

ardous material incident report must be filed

within 15 days. A generator should inspect

all waste containers for leakage before they

are transported. If a driver accepts a leaking

container, the driver, the carrier and shipper

are equally liable for the violation.

SHOP TOWELS

Application of regulations to shop towels

currently varies from state to state, and

interpretation of the federal regulations

varies from region to region within the

USEPA. For example, the state of California

passed a bill in October 1993 that exempts

reusable soiled textiles from hazardous

waste regulations, but to meet this exemp-

tion, the textiles must not bear any free liq-

uids. In New Mexico, both reusable and dis-

posable shop towels are considered haz-

ardous waste. Any determinations or inter-

pretations regarding this diverse and vari-

able waste stream should be made by the

regulatory agency implementing the RCRA

program for a particular state.

A towel is considered a listed hazardous

waste if it either contains listed waste, or is

otherwise mixed with hazardous waste.

Reusable or disposable towels must be used

and handled in an environmentally sound

manner to ensure compliance with applica-

ble state and federal regulations.

It is important when choosing reusable

rental towels, that the rental company is rep-

utable and is handling the towels properly.

The user (the printer) is ultimately responsi-

ble for the destiny of the effluents.

The USEPA is expected to issue a shop-

towel rule in the next two years.

LIFE CYCLE OF A TYPICAL

PRINTING WASTE

Below is an example of the stages in the

life cycle of a typical printing waste for a

Small Quantity Generator that is sending sol-

vent waste off site for treatment.

It illus-

trates the most common scenario of activi-

ties. Other life cycles could apply depending

on the waste, whether on-site treatment will

occur and the type of waste management

units used, and the generator status.

1. Identify waste: By running tests or

using knowledge of the waste, identify

whether the waste is hazardous. Based

on these analyses, determine the

appropriate waste code.

2. Count waste: Determine the quantity

of waste produced during a calendar

month. Solvents directly in a solvent

recovery still should not be counted.

Count solvent still bottoms when they

are recovered.

3. Determine generator status: Based on

waste counting, determine generator

status. This example assumes Small

Quantity Generator status.

4. Obtain USEPA identification number:

To identify a business as a hazardous

waste generator, a hazardous waste

identification number must be

obtained.

5. Place waste in an accumulation unit:

Accumulated waste must be placed in

a marked tank or container with the

date the waste was placed in the unit

and marked with the words “Hazard-

ous Waste.” Containers must not be

rusty or leaking. They must be stored

in areas with adequate ventilation and

drainage and kept closed except to

add or remove waste.

6. Implement Large Quantity Generator

preparedness and prevention require-

ments: Emergency preparedness and

prevention requirements must be met.

These include adequate emergency

response systems and notification to

local emergency response authorities.

7. Prepare a contingency plan: A contin-

gency plan must be prepared accord-

ing to standards. The plan is designed

to minimize hazards from fires, explo-

sions and unplanned releases. A copy

of the plan must be kept on-site and a

facility emergency coordinator must

be on site at all times.

8. Implement personnel training: Person-

nel must be familiar with hazardous

waste handling and emergency proce-

dures.

9. Contract with hazardous waste trans-

porter: Contract a registered haz-

ardous waste transporter to send

waste off site to a licensed facility.

10. Follow US Department of Transpor-

tation (USDOT) packaging standards:

Before shipping waste off site for

treatment, storage or disposal, pack-

age, label and mark waste containers

in accordance with all applicable

USDOT requirements.

11. Prepare hazardous waste manifest: A

manifest is to be sent along with all

hazardous waste sent off site to a reg-

istered facility. Copies should be kept

for three years.

12. Prepare appropriate notification and

certification: All hazardous waste sent

off site for treatment, storage or dis-

posal must be accompanied by appro-

ENVIRONMENT AND SAFETY 21

The USDOT hotline is (800) 467-4922.

Taken from RCRA in Focus, Printing, EPA530-K-97-007

Hazardous waste generator numbers can be obtained from the USEPA by sub-

mitting Form 8700-12 (Notification of Regulated Waste Activity), which is

obtained from the state hazardous waste agency.

22 FLEXOGRAPHY: PRINCIPLES & PRACTICES

priate notification and certifications

(initial shipment only).

13. Send waste off site for treatment, stor-

age or disposal: Using a registered haz-

ardous waste transporter, send the

waste to an RCRA hazardous waste

registered facility accompanied by the

appropriate manifest and land-dispos-

al-restrictions notifications and certifi-

cations. A permitted or interim status

facility can be used. Optional destina-

tions for solvents include a hazardous

waste incinerator that will landfill the

incinerator ash, a hazardous waste

fuel blender who will blend the sol-

vents with other wastes and then burn

them for energy recovery in a boiler or

industrial furnace, or a facility that will

recycle the solvents.

n addition to active facilities regulated

under RCRA, some sites also contain

abandoned hazardous wastes for which

ownership is unclear or unknown. In

these situations, control and cleanup is

possible through the Comprehensive

Environmental Response, Compensation

and Liability Act (CERCLA), commonly

known as Superfund. Under the Superfund

program, USEPA has the authority to clean

ENVIRONMENT AND SAFETY 23

Comprehensive Environmental

Response, Compensation

And Liability Act

up the nation’s worst hazardous waste sites.

CERCLA was reauthorized by the Superfund

Amendments and Reauthorization Act of

1986 (SARA).

HAZARDOUS CHEMICAL

REPORTING

When CERCLA was amended by SARA,

Title III, Section 302 of SARA authorized the

Table 5

CHEMICAL REPORTABLE QUANTITY (LBS)

Acetone 5,000

Ammonia 100

Benzene 10

Cadmium and compounds 1

Carbon tetrachloride 10

Chloroform 10

Chromium and compounds 1

Cumene 5,000

Cyclohexane 1,000

Dibutyl phthalate 10

Ethanol, 2-ethoxy 1,000

Ethyl acetate 5,000

Ethylbenzene 1,000

Formaldehyde 100

Hydrochloric acid 5,000

Isophorone 5,000

Lead and Compounds 1

CHEMICAL REPORTABLE QUANTITY (LBS)

Methyl chloroform 1,000

Methylene chloride 1,000

Methanol 5,000

Methyl ethyl ketone 5,000

Methyl isobutyl ketone 5,000

Perchloroethylene 100

Phosphoric acid 5,000

Propylene oxide 100

Sulfuric acid 1,000

Toluene 1,000

Toluene diisocyanate 100

1,1,1-Trichloroethane 1,000

1,1,2-Trichloroethane 100

Trichloroethylene 100

Vinyl chloride 1

Xylene (mixed) 1,000

HAZARDOUS CHEMICALS USED BY THE PRINTING INDUSTRY AND

REPORTABLE UNDER CERCLA