Waste Blanket Wash — Watch Out for Your Wash
* Not labeling containers used for hazardous waste accumulation while in the waste storage area.
* Not keeping hazardous waste containers closed.
* Not designating a hazardous waste storage area.
* Not maintaining emergency equipment in the designated storage area (e.g., communications device or alarm system, fire extinguishers, spill control equipment, etc.).
* Not conducting general awareness training for employees involved in hazardous waste handling.
* Not conducting weekly inspections of hazardous waste storage areas.
So far, none of the facilities that have been inspected have met the requirements that LQGs must meet. These include: not submitting annual or biennial reports; not developing a formal contingency plan; not having a formal waste minimization plan; and not having formal employee training in hazardous waste management and in responding to accidental releases.
In addition, violations involved with the improper handling of Universal Wastes have also been cited. Universal Wastes are special wastes that, if disposed, would be classified as hazardous wastes. But if recycled, they fall under a less stringent set of requirements. Common Universal Wastes include lead acid batteries, fluorescent and other mercury-containing bulbs, thermostats and switches and, in some states, obsolete electronics (e-wastes). Universal Waste violations include throwing them away as trash, not keeping the wastes in closed containers, no start (fill) dates on the container labels and not shipping them offsite within the allowed one-year time limit.
Lastly, inspectors are finding problems with the management of used shop towels. Reusable or launderable towels that are contaminated with waste solvents that are classified as hazardous can be managed as nonhazardous if certain procedures are followed.
While each state has its own policy, two key requirements are that states require the towels to not be saturated and kept in closed containers. Some printers are not keeping the towels in closed containers and the towels at the bottom of the container are sitting in a pool of liquid, which is enough to fail the no saturation criteria. Disposable towels contaminated with solvents that would be classified as hazardous must be managed as a hazardous waste and cannot be simply thrown away as trash.
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.