WASTE BLANKET WASH — WATCH OUT FOR YOUR WASH

February 2006 By Gary A. Jones

multipage

The rise in popularity of the multicolor sheetfed offset lithographic printing press, while clearly a good indicator of expanding business, has created a challenge with the United States Environmental Protection Agency (USEPA) regulations and waste automatic blanket wash. Meeting this challenge requires a knowledge and understanding of EPA’s regulations as they apply to waste blanket wash, and what must be done to meet those specific regulations.

The topic is important enough that it is also being featured at the upcoming National Environmental, Health and Safety Conference for the Graphic Communications Industries in Indianapolis, scheduled for March 27-29 (see sidebar below).

At the heart of the problem is generation and disposal of the waste blanket wash from liquid automatic blanket wash systems, which is usually classified as a hazardous waste. Under USEPA’s regulations, waste blanket washes are hazardous wastes because they usually have flashpoints below 140° F, even though they may have been mixed with a considerable amount of water.

USEPA imposes numerous requirements upon hazardous-waste generators, which govern all aspects of a waste management program, including waste classification, storage, reporting and record keeping, and training. The extent of these requirements depends upon how much hazardous waste is generated on a monthly basis.

USEPA has three classes of generators:

* Large-Quantity Generators (LQGs)—generating more than 2,200 pounds of hazardous waste per month or about four to five 55-gallon drums.

* Small-Quantity Generators (SQGs)—generating more than 220 pounds and less than 2,200 pounds per month or about one-half to five 55-gallon drums.

* Conditionally Exempt Small-Quantity Generators (CESQGs)—generating 220 pounds or less per month or about one-half of a 55-gallon drum.

Conditionally exempt small-quantity generators (CESQGs) are usually subject to very minimal regulation, while small-quantity generators (SQGs) and large-quantity generators (LQGs) are subject to more hazardous waste management requirements. It is important to understand that—because states can be more stringent than USEPA—some states define generator status differently and have more stringent or different requirements for SQGs and CESQGs.

Generally, most printers are classified as either a CESQG or a SQG because they do not generate significant quantities of waste. However, sheetfed presses with liquid automatic blanket wash systems have caused many printers to now be classified as LQGs.

In many instances, printers with these systems have experienced a dramatic increase in the volume of waste generated because of waste blanket wash which, at one time would have generated only several drums of waste blanket wash, are now generating 10 to 15 drums per month. Unfortunately, the printer only becomes aware of the change when the agency inspector shows up for a compliance inspection.

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