Waste Blanket Wash — Watch Out for Your Wash
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.
The agency usually becomes aware that a printer is now a LQG two ways. One way is because they have failed to file an annual report on hazardous waste generation and waste reduction efforts. Some states require their LQGs to either file annual hazardous waste reports and, at the very least, they have to filed every even year.
The second way is when a shipment of hazardous waste is sent offsite for disposal. One copy of the manifest, required to accompany the waste, is sent to the state where the printer resides and when the manifests are examined for errors, the large quantity of waste shipped will be noticed. If the printer registered as a SQG and is now a LQG, and if it did not submit an annual or biennial report, then the local field office is notified and an inspection will occur. In most instances, the penalties associated with the resulting inspections have been rather severe, ranging from about $12,000 to $18,000 per facility.
Common violations include:
* Not labeling satellite accumulation and accumulation containers as “Hazardous Waste”.
* Not labeling the date the containers were moved into the hazardous waste storage area.
Gary A. Jones is the director of environmental, health and safety (EHS) affairs at the Specialty Graphic and Imaging Association in Fairfax, VA. His primary responsibility is to monitor and analyze EHS regulatory activities at all domestic and some international government levels. He provides representation on behalf of the printing and specialty graphic imaging industry.