Original Site Part 1 Original Site Part 2	EPA & OSHA: Common Misconceptions By Gary Jones Jan 1, 2005 12:00 AM What you don't know CAN hurt you Smaller printers frequently assume they are exempt from certain Occupational Safety and Health Administration (OSHA) and Environmental Protection Agency (EPA) regulations. But as you'll learn, compliance isn't optional. Here are the facts about some common issues. "OSHA regulations don't apply to me because I have fewer than 10 employees." Fact: OSHA has a set of regulations that cover manufacturing operations. Because printing is classified as manufacturing, printers must comply with all applicable general industry standards, including hazard communication, machine guarding, lockout/tagout, fire safety, personal protective equipment, hearing conservation, and injury and illness recordkeeping. Did you know? There are only two common exemptions from OSHA regulations that apply to printers with fewer than 10 employees: completing the new Form 300, injury and illness recordkeeping paperwork, and having a written emergency evacuation plan. "My old equipment doesn't need machine guards because it is grandfathered." Fact: According to OSHA's regulations and interpretations, there is no grandfather clause applicable to existing equipment. Old equipment is not exempt from the machine guarding standard. It is the printer's—rather than the equipment vendor's—responsibility to ensure that equipment is properly guarded. OSHA's regulations require guarding for all ingoing nip points, rollers, wheels, pinch points, sprockets, pulleys, chains, rotating shafts and other hazardous equipment areas. OSHA's regulations do not require that the guards be interlocked. "Because I have cord-and-plug equipment and maintenance contracts, lockout/tagout doesn't apply." Fact: Cord-and-plug equipment isn't subject to lockout/tagout requirements, provided that it is unplugged during servicing/maintenance and the plug remains in clear view of the employee performing the service. For all non-cord-and-plug equipment, however, a hazard analysis must be performed and specific lockout/tagout procedures must be developed and implemented for any servicing/maintenance procedures. OSHA has issued several letters of interpretation, one in 1992 and the other in 2004, that allow the printing industry to use alternative procedures for minor servicing and maintenance such as clearing certain types of paper jams, changing blankets and plates, cleaning blankets and plates, making equipment adjustments, etc. "I don't have to conduct a job safety analysis, because we've never had an accident." Fact: The requirement for conducting a formal and documented job hazard analysis under OSHA's Personal Protective Equipment standard depends on the hazards present in a particular job. Accident history has nothing to do with it. Each hazard must be identified by job category and appropriate personal protective equipment. Once identified, employees must be trained in the equipment's use, limitations and proper maintenance. "I have collected Material Safety Data Sheets (MSDSs) for my products. Therefore, I am in compliance." Fact: Collecting your MSDSs only puts you about one-fifth of the way to full compliance. Under OSHA's Hazard Communication Standard, simply collecting MSDSs is insufficient to demonstrate compliance. Obtaining and maintaining MSDSs is one of five basic requirements that must be met under the Hazard Communication Standard. Other requirements include: • A formal written program. • An inventory of all hazardous chemicals. • Labeling all chemical containers with the appropriate hazard warnings. • Employees training in the safe handling and use of chemicals. Did you know? All obsolete MSDSs must be maintained for 30 years. These are considered employee exposure records. "We're so small, I don't have to obtain an air pollution permit." Fact: The requirement for a construction and/or operating permit depends on the location and the amount of air emissions that can be generated from individual pieces of equipment or the facility as a whole. Areas that do not meet EPA's ozone standard are classified as "nonattainment" and have low air permit thresholds, which are typically based on the amount of volatile organic compound (VOC) or hazardous air pollutant (HAP) emissions per hour, day or year. Many states have lowered their air permit thresholds and now require small printers to obtain a permit to legally operate their businesses. Some air pollution control agencies set their ir permit threshold based on the amount of VOC-containing material used per year. For example, Illinois requires a permit for all printers who use more than 750 gallons of VOC-containing material per year. Maryland requires an air permit for any sheetfed offset press greater than 18 inches. It is important to know and understand your state and/or local air permit threshold and ensure that if a permit is necessary, one is obtained. Bet you didn't know: In addition to these thresholds, which are based on actual emissions, some thresholds are based on potential emissions. Potential emissions require printers to assume that they are using their equipment at maximum production conditions or coverage 24 hours per day, 365 days per year. For example, the threshold for a permit in Massachusetts is 1 ton per year of potential VOC emissions. The federal threshold for a major source of HAPs is 10 tons for a single HAP and 25 tons for all HAPs combined. "Digital equipment is green and does not cause air pollution." Fact: Digital technologies are not necessarily "green." Direct-to-plate imaging systems, for example, could have a high-pH developing effluent that must be neutralized. And if the platesetter is silver-halide based, users must recover the silver and neutralize the effluent. Bet you didn't know: Some digital output devices, such as wide-format inkjet systems, can generate tons of VOC and HAP emissions. Many of these systems are subject to air permitting, which means a construction and/or operating permit is necessary prior to the unit being delivered and used. Other digital presses use a liquid toner system that contains VOCs and also is subject to permitting. If the wide-format inkjet printer is using a solvent that is also an HAP, then having as few as three of these units could cause the printing company to be classified as a major source for HAPs, subject to Title V air permit requirements. "I can throw away my used shop towels or cleaning pads." Fact: Cleaning solvents are the most common hazardous waste products generated by small printers. Because the solvent is typically used with a shop towel, cotton pad or press cleanup mat, these wastes also can be classified as hazardous. All states have adopted a policy for reusable shop towels that lets users avoid classifying the towels as hazardous waste if a policy is followed. While requirements vary by state, users generally can't saturate towels with solvent, are required to keep towels in closed containers, and must have a contract with a launderer under which the launderer uses its own truck to pick up and return the towels. Some states require the containers to be labeled, and at least one requires notification. Did you know? If solvent is present, disposable towels can't simply be thrown away as trash—they must be collected and handled as a hazardous waste. EPA has a proposed regulation that will address both reusable and disposable towels. Assuming the regulation is finalized as proposed, this means that disposable towels can be thrown away without violating any regulations—if the towels meet certain requirements, such as the amount of solvents on them and the absence of certain EPA-identified solvents. "I can dump my waste fountain solution or camera waste down the drain. No one ever told me I couldn't, and besides, my salesman says it's biodegradable." Fact: Printers are responsible for all wastes generated, even wastewater discharges. If the printer discharges wastewater to the drain, the local sewer authority must be contacted to determine whether the waste is acceptable. Permission must be obtained prior to discharging. The local sewer authority will determine what is acceptable. Most sewer authorities have a "sewer code" that sets the limits regarding the types and concentrations of pollutants acceptable for treatment. Permission forms can include a letter from the pretreatment coordinator, test data indicating the effluent meets the sewer code limits, or a discharge permit. Some states and local sewer authorities require their industrial dischargers —which includes all printers, regardless of size—to obtain a wastewater discharge permit. If permission is granted to discharge wastewater to the sewer, then silver recovery is usually required for printers using film or silver-halide-based direct imaging plate systems to meet the silver discharge limit. If the printer has adopted a digital workflow and is directly imaging plates, many of these systems have developers that exceed a pH of 12.5, which makes them a hazardous waste. The plate effluents must be neutralized prior to discharge. The typical acceptable pH range set by sewer authorities is six to nine. Under no circumstances can any industrial wastewater be discharged to a septic system. Septic systems are designed to treat sanitary wastes only. Clearing the air "EPA only regulates the big printers." Fact: Because all sizes of printers are classified as manufacturers, virtually every EPA regulation applies. The degree in which the regulations apply depends on factors including geographical location and the thresholds set under each regulation. Also, many states and local government agencies directly regulate small printers. The most common regulations that must be met include: Clean Air Act | Regulates emissions of air pollutants. The most common air pollutants emitted by printers are volatile organic compounds (VOCs) and hazardous air pollutants (HAPs) which include inks, fountain solutions, coatings, varnishes, adhesives, blanket washes, plate cleaners, metering roller cleaners, other cleaning solvents, and ink jet and other digital ink systems. Clean Water Act | Regulates discharges of industrial wastewater and contaminated stormwater. Under the stormwater regulations, all printers regardless of size, who own their own building or lease a standalone building must either complete and submit a "no exposure certification" or file for a stormwater discharge permit. Resource Conservation and Recovery Act | Regulates hazardous waste, nonhazardous waste, universal waste and underground storage tanks. Most small printers are Conditionally Exempt Small Quantity Generators, which means they generate less than 220 lbs. (about half of a 55-gallon drum), or Small Quantity Generators, which means they generate more than 220 lbs. but less than 2,200 lbs. (about four to five 55-gallon drums) per month. The most common hazardous wastes generated by small printers are waste cleaning solvents. Emergency Planning and Community Right-to-Know Act | Requires the reporting of releases of certain hazardous substances above the applicable reportable quantity, submission of annual inventory reports for materials stored above specific thresholds, and annual emission reports for a specific list of chemicals used about specific thresholds. While most small printers do not store or use enough chemicals to trigger reporting under these regulations, the threshold for lead under the Toxic Release Inventory reporting is only 100 lbs. If a printer is still melting and casting lead, then this threshold is easily exceeded, triggering the annual report, that is due every July 1. Comprehensive Environmental Response Compensation and Liability Act (Supervened) | Regulates the cleanup of abandoned contaminated property. All parties who are identified as contributing waste, even if it was legal to dispose of it at the facility being cleaned up, are response for the cleanup costs associated with the contaminated property. Currently, there are about 25 small printers involved with the cleanup of a site in New Jersey called Pittsburgh Metals. Pittsburgh Metals recycled a variety of metals and each printer now involved had sent the company lead type and dross during the 1970s and 1980s. Each printer is facing a bill of at least $5,000 up to $50,000, depending upon how much lead and dross were shipped for recovery. Don't overlook liquid automatic blanket wash waste. Have you evaluated your blanket wash waste lately? Many new presses feature automatic blanket washes. Because the waste blanket wash typically is hazardous, the amount being generated per month could change printers' status from Conditionally Exempt to Small Quantity and from Small Quantity to Large Quantity Generator. Printers who have overlooked increased blanket wash waste also could inadvertently fail to comply with the additional requirements of the next highest classification. Several printers have been inspected and given notices of violation.