Waste Blanket Wash — Watch Out for Your Wash
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.
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.
* 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.
In order to reduce or eliminate this problem, there are three approaches that can be taken. The first would be to adjust the volume of solvent being applied to the blanket and training employees in how frequently the system should be cycled. By making adjustments to the volume being applied and training employees on proper applications, some printers have cut their waste volume in half.
Several other printers have been successful in replacing their current solvents with ones that are not classified as hazardous waste. These solvents need to have a flashpoint above 140°F and not contain any chemical that would be on one of the USEPA’s lists of “listed” hazardous wastes. In pursuing this approach, it is important to work with the vendor of your automatic blanket wash system to determine if they have any solvents that would not be classified as hazardous waste and ensure the solvents are compatible and approved for use in the system.
The drawback to this approach is that there is still a large volume of waste that must be properly disposed, which can be expensive. Switching to nonhazardous solvents in conjunction with a distillation unit can be a very powerful combination, as it will eliminate this hazardous waste stream and reduce costs.
If printers choose distillation units as the preferred method of waste reduction without changing to a non-hazardous solvent, they must realize that the regulations focus on the “point of generation” and the ability to change generator status is limited and depends upon how the waste is transferred from the press to the distillation unit.
When the distillation unit is hard piped from the press, then the only waste that gets counted toward determining generator classification is the waste generated by the distillation unit itself. If the waste blanket wash is hand-carried to the distillation unit and recovered, the entire volume of the waste is counted toward the generator classification. The good news is that once the waste is counted once during the month, it does not get recounted until the following month.
The last and perhaps most expensive approach would be to replace the automatic blanket wash system with one that does not use liquid. While this is not a practical option for presses that are in operation, it is something that should be considered with a new press purchase. The non-liquid systems still generate waste, but it is not the same problem. The waste from these systems must be evaluated to see if they are a hazardous waste, but the amount of waste generated from these systems is dramatically less than the liquid systems.
The advent of automatic blanket wash systems on large, multicolor sheetfed presses has allowed printers to dramatically increase productivity. Printers that have these systems are urged to review their internal program and make any necessary changes to meet USEPA and state hazardous waste regulations and take steps to minimize or eliminate this waste stream. Taking proactive steps now will allow for easier regulatory compliance and cost savings.
About the Author
Gary Jones is the manager of Environmental, Health and Safety for the Printing Industries of America/Graphic Arts Technical Foundation. He has 19 years of experience in addressing EHS issues for the printing industry. Jones can be reached at firstname.lastname@example.org or (412) 259-1794.
Conference Coming Up
The National Environmental, Health and Safety Conference for the Graphic Communications Industries is the only national event designed to meet the needs of those responsible for environmental, health and safety (EHS) compliance, regardless of printing process. During the 11th annual event, scheduled for March 27-29 in Indianapolis, attendees will hear printer case studies and regulatory updates, examine the latest EHS technology, and be able to attend optional, low-cost, certification-level training.
More than 30 topics will be addressed, including new topics on how to “sell” safety, turn around loss experience, reduce energy usage, calculate air emissions, fill out OSHA forms and control stormwater contamination. Attendees can pick from sessions tailored to specific printing processes, and others designed for all printers. A free orientation session will help those new to managing EHS affairs understand the core issues and their job responsibilities. Certification options for 2006 have been expanded to include first-aid, OSHA’s Hazardous Waste Operations and Emergency Response Standard (HAZWOPER), and train-the-trainer requirements for EPA’s RCRA hazardous waste regulations.
The NEHS Conference is a combined effort of the Printing Industries of America/Graphic Arts Technical Foundation (PIA/GATF), Specialty Graphic Imaging Association (SGIA), Flexographic Technical Association (FTA), Gravure Association of America (GAA) and the National Association of Printing Ink Manufacturers (NAPIM). More than 20 other groups, from local printing associations to professional associations, provide cooperative support. For more information visit www.nehsconference.org or contact Ned Herrick at (800) 910-4283, ext. 712.
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.