Printers'
National
Environmental
Assistance
Center
Fact Sheet
PNEAC
www.pneac.org

1-888-US-PNEAC

United States Environmental Protection Agency 
Solid Waste and Emergency Response (5305W) 
EPA530-K-97-007 
January 1998 

RCRA IN FOCUS: PRINTING


REGULATORY UPDATE 

REDUCING PRINT SHOP WASTES 

HOT OFF THE PRESS RESOURCES 

IN FOCUS 


CONTENTS 

Frequently Asked Questions About RCRA 

The Life Cycle of a Typical Printing Waste 

Requirements for Regulated Printers 

Reduce or Minimize the Hazardous Wastes You Generate 

Other Environmental Laws Affecting the Printing Industry

Contacts and Resources 


FOR MORE INFORMATION CALL: 
RCRA Hotline 
U.S. Environmental Protection Agency 
800 424-9346 or TDD 800 553-7672.
In the Washington, DC, area: 703 412-9810 
or TDD 703 412-3323.


FOREWORD 


Whether you are a screen printer, lithographer,
flexographer, or other printer, your printing processes
probably generate hazardous waste. That means you are
regulated by the U.S. Environmental Protection Agency (EPA)
under a federal law called the Resource Conservation and
Recovery Act (RCRA). Under RCRA, you are required to follow
certain procedures when generating, storing, transporting,
treating, or disposing of hazardous waste. RCRA in Focus
provides an overview of the federal regulations you are
required to follow and the wastes that are likely to be
hazardous in your business. It also provides federal
recycling and pollution prevention options to help you
decrease the amount of hazardous waste you generate.


FREQUENTLY ASKED QUESTIONS ABOUT RCRA


What Is RCRA? 

RCRA is a federal law that encourages environmentally sound
methods for managing commercial and industrial waste as well
as household and municipal waste. It regulates facilities
that generate, transport, treat, store, or dispose of
hazardous waste. The vast majority of printers are
considered hazardous waste generators, rather than
treatment, storage, and disposal facilities (TSDFs), which
are subject to more rigorous regulations.

The term "RCRA" is often used interchangeably to refer to
the law, the regulations, and EPA policy and guidance. The
law describes the waste management program mandated by
Congress that gave EPA authority to develop the RCRA
program. EPA regulations carry out the Congressional intent
by providing explicit, legally enforceable requirements for
waste management. EPA guidance documents and policy
directives clarify issues related to the implementation of
the regulations.

All the RCRA hazardous waste regulations can be found in the
Code of Federal Regulations (CFR), Title 40, Parts 260 to
279. The CFR can be purchased through the U.S. Government
Printing Office (GPO).


Who Is Regulated? 

Any printer that generates hazardous waste is potentially
subject to RCRA. You must conduct tests required by the
regulations or use your knowledge of and familiarity with
the waste you generate to determine whether it is hazardous
waste (as opposed to other types of waste). You might be
subject to substantial civil and criminal penalties if you
fail to properly or completely identify hazardous waste
generated by your business.


What Is Hazardous Waste? 

To be considered hazardous waste, a material first must be
classified as a solid waste. EPA defines solid waste as
garbage, refuse, sludge, or other discarded material
(including solids, semisolids, liquids, and contained
gaseous materials). If your waste is considered solid waste,
you must then determine if it is hazardous waste. Wastes are
defined as hazardous by EPA if they are specifically named
on one of four lists of hazardous wastes (listed wastes), or
if they exhibit one of four characteristics (characteristic
wastes). Each type of RCRA hazardous waste is given a unique
hazardous waste code using the letters D, F, K, P, or U and
three digits (e.g., D001, F005, or P039). See pages 8 to 10
for additional information on printing waste codes.

Listed Wastes. Wastes are listed as hazardous because they
are known to be harmful to human health and the environment
when not managed properly, regardless of their
concentrations. The lists include the following three types
of waste: 

* Non-Specific Source Wastes. These are material-specific 
wastes, such as solvents, generated by several different 
industries. Waste codes range from F001 to F039. 
Potential printing wastes include F001 to F005 
(solvents).

* Specific Source Wastes. These are wastes from 
specifically identified industries. Waste codes range 
from K001 to K161.

* Discarded Commercial Chemical Products. 
Off-specification products, container residuals, spill 
residue runoff, or active ingredients that have spilled 
or are unused and that have been, or are intended to be, 
discarded. Examples of printing wastes include U019 
(benzene), U056 (cyclohexane), and U220 (toluene). Waste 
codes range from P001 to P205 and U001 to U411.


************************************************************
STATE REQUIREMENTS 

You may be regulated both by your state hazardous waste
agency and EPA. RCRA allows states to receive legal
permission, known as authorization, to implement the RCRA
hazardous waste program.

You must always contact your state authority to determine
which state requirements apply to your business. To operate
a hazardous waste program, a state's regulations must be
consistent with, and at least as stringent as, the federal
program. Some states adopt more stringent requirements for
facilities handling hazardous waste, which are considered
part of the authorized program.

MORE QUESTIONS? 

Call the RCRA Hotline at 800 424-9346 or TDD 800 553-7672
for additional information about RCRA rules and regulations.
In the Washington, DC, area, call 703 412-9810 or TDD 703
412-3323.
************************************************************


Characteristic Wastes. Even if your waste does not appear on
one of the hazardous waste lists, it still might be
regulated as hazardous waste if it exhibits one or more of
the following characteristics: 

* Ignitability. Ignitable wastes create fires under 
certain conditions or are spontaneously combustible, and 
have a flash point less than 60 degrees Centigrade (140 
degrees Fahrenheit). Examples include used solvents, 
which have a waste code of D001.

* Corrosivity. Corrosive wastes are acids or bases that 
are capable of corroding metal containers, such as 
storage tanks, drums, and barrels. Acid or alkaline 
process baths are a good example. The waste code for 
these materials is D002.

* Reactivity. Reactive wastes are unstable under "normal" 
conditions. They can cause explosions, toxic fumes, 
gases, or vapors when mixed with water. The waste code 
for these materials is D003.

* Toxicity. Toxic wastes are harmful or fatal when 
ingested or absorbed. When toxic wastes are disposed of 
on land, contaminated liquid may drain (leach) from the 
waste and pollute ground water. Toxicity is defined 
through a laboratory procedure called the Toxicity 
Characteristic Leaching Procedure. Printing wastes 
include D011 (silver), D019 (carbon tetrachloride), and 
D040 (trichloroethylene). Waste codes for toxic 
materials range from D004 to D039.


How Are Generators Regulated? 

If your business generates hazardous waste, you must manage
it according to regulations for your specific generator
type. Hazardous waste generators are divided into three
categories, according to how much they generate in a
calendar month: 


* Large Quantity Generators (LQGs). LQGs generate greater 
than or equal to 200 gallons of hazardous waste per 
month (equivalent to 1,000 kg or approximately 2,200 
lb), or greater than 0.02 gallons (approximately 1 kg or 
2.2 lb) of acutely hazardous waste per month.

* Small Quantity Generators (SQGs). SQGs generate more 
than 25 gallons (equivalent to 100 kg or approximately 
220 lb), but less than 200 gallons (1,000 kg or 2,200 
lb) of hazardous waste per month.

* Conditionally Exempt Small Quantity Generators (CESQGs). 
CESQGs generate less than 25 gallons of hazardous waste 
per month (or equal to 100 kg or 200 lb), and less than 
or equal to 0.02 gallons (1 kg or 2.2 lb) of acutely 
hazardous waste per month. 

Some states do not recognize the CESQG class. Contact your
state environmental agency to find out if the CESQG status
is recognized. To find your appropriate state contact, call
the RCRA Hotline at 800 424-9346.

Under the federal RCRA requirements, your generator status
might change from one month to the next as the quantity of
waste you generate changes. State requirements vary widely.
You must comply with whichever standard is applicable for a
given month. In many cases, small businesses that fall into
different generator categories at different times choose to
always satisfy the more stringent requirements (usually
state requirements) to simplify compliance. Generators must
"count" the amount of waste generated, which involves adding
up the total weight of all quantities of characteristic and
listed waste generated at a particular facility. Certain
wastes, such as those that are reclaimed or recycled
continuously on site, are not counted under the federal
regulations.


************************************************************
AM I REGULATED BY RCRA OR SUPERFUND? 

RCRA regulates the treatment, storage, and disposal of
hazardous waste being generated now and in the future.

Superfund was created to pay for the identification,
inspection, investigation, ranking, and cleanup of abandoned
or uncontrolled hazardous waste sites that people
responsible for contamination are unable or unwilling to
clean up. Call the RCRA Hotline for more information.

HOW IS USED OIL HANDLED? 

RCRA contains special provisions for the management of used
oil destined for recycling or reuse. These management
standards apply to oil refined from crude oil or any
synthetic oil that has become contaminated through use by
chemical or physical impurities. Used oil that will be
recycled or reused is subject to special management
standards, rather than the hazardous waste standards, unless
it is treated as a waste (i.e., you decide to send the used
oil for treatment and disposal rather than recovery or
recycling).
************************************************************


THE LIFE CYCLE OF A TYPICAL PRINTING WASTE

You've just cleaned off the press with solvents and wiped it
down. Now you have liquid solvent waste that must be
managed. You own a small business that produces a wide
variety of hazardous wastes. You know it is time to
investigate and follow the RCRA regulations.

This example details one typical printing waste life cycle
for an SQG that is sending solvent waste off site for
treatment, and it illustrates the most common scenario of
activities. Other life cycles could apply depending on the
waste, whether onsite treatment will occur, the type of
waste management units used, and your generator status.


1. IDENTIFY WASTE

By running tests or using your knowledge of the waste,
identify whether your solvent waste is hazardous. Based on
these analyses, determine the appropriate waste code for
your solvents; in this case, for example, it is F001. File
all records of test results, waste analyses, and other
determinations made in the hazardous waste identification
process and keep them for at least 3 years.


2. COUNT WASTE 

As a second step, determine how much solvent waste you have
produced in a calendar month. Do not count solvent placed
directly into a solvent recovery still. Count the solvent
still bottoms when they are removed from the still, however.


3. DETERMINE GENERATOR STATUS 


Based on waste counting, determine your generator status. In
this case, you have produced more than 25 gallons, but less
than 200 gallons, of hazardous waste in the past month,
which means you are an SQG in this calendar month period.


4. OBTAIN EPA IDENTIFICATION NUMBER 

To identify your business as a hazardous waste generator,
obtain an EPA identification number by submitting Form
8700-12 (Notification of Regulated Waste Activity), which is
obtained from your state hazardous waste agency. Remember,
your state requirements might be different.


5. PLACE WASTE IN ACCUMULATION UNIT 

When the waste is generated, place it in an accumulation
unit. Mark accumulation tanks and containers with the date
the waste was placed in the unit as well as mark the words
"Hazardous Waste." Ensure that containers are not rusty or
leaking, are stored in areas with adequate ventilation and
drainage, and are kept closed except to add or remove waste.


6. IMPLEMENT LQG PREPAREDNESS AND PREVENTION REQUIREMENTS

Check to be sure that emergency preparedness and prevention
requirements are met. These include adequate emergency
response systems and notification to local emergency
response authorities. 


7. PREPARE CONTINGENCY PLAN 

Next, ensure that a contingency plan is prepared in
accordance with standards. The contingency plan is designed
to minimize hazards from fires, explosions, and unplanned
releases. Keep a copy of the contingency plan on site, and
assign a facility emergency coordinator to be on site or on
call at all times.


8. IMPLEMENT PERSONNEL TRAINING 

Be sure that your personnel are familiar with hazardous
waste handling and emergency procedures.


9. CONTRACT WITH HAZARDOUS WASTE TRANSPORTER 


To send waste off site to a TSDF, contract with a registered
hazardous waste transporter. To locate a reliable
transporter, contact a colleague to obtain a reference.


10. FOLLOW U.S. DEPARTMENT OF TRANSPORTATION (DOT)
PACKAGING STANDARDS 

Before shipping waste off site for treatment, storage, or
disposal, package, label, and mark waste containers in
accordance with all applicable DOT requirements. Call the
DOT Hotline at 800 467-4922.


11. PREPARE HAZARDOUS WASTE MANIFEST 

Send a manifest along with all hazardous waste sent off site
to a TSDF, and keep your copy on site for 3 years. The
manifest contains a certification stating that you have a
program in place to reduce the volume and toxicity of waste
generated to the degree economically practicable, and that
you have selected a treatment, storage, or disposal method
currently available that minimizes current and future
threats from the waste.


12. PREPARE APPROPRIATE NOTIFICATION AND CERTIFICATION

Ensure that all hazardous waste sent off site for treatment,
storage, or disposal is accompanied by appropriate
notifications and certifications (initial shipments only).


13. SEND WASTE OFF SITE FOR TREATMENT, STORAGE, OR DISPOSAL

Using a registered hazardous waste transporter, send the
waste to a RCRA hazardous waste TSDF accompanied by the
appropriate manifest and land disposal restrictions
notifications and certifications. You can choose from any
permitted or interim status TSDF. Optional destinations for
solvents include a hazardous waste incinerator that will
landfill the incinerator ash, a hazardous waste fuel blender
who will blend the solvents with other wastes and then burn
them for energy recovery in a boiler or industrial furnaces,
or a facility that will recycle the solvents.



REQUIREMENTS FOR REGULATED PRINTERS


The following table presents an overview of the federal RCRA
regulatory requirements for printers that are either LQGs,
SQGs, or CESQGs. As noted, your state might have different
or more stringent requirements.


************************************************************
RCRA REGULATORY REQUIREMENTS
LQGs SQGs CESQGs

EPA IDENTIFICATION NUMBER 
LQGs SQGs

* Obtain an EPA identification number for each facility 
within your company. EPA and states use this 12-character 
identification number to track hazardous waste 
activities.

* Obtain an EPA identification number by submitting form 
8700-12 (Notification of Regulated Waste Activity), which 
is provided by your state hazardous waste agency. This 
is a one-time notification. Contact your state regarding 
the need for renotification if circumstances at your 
facility change.


HAZARDOUS WASTE IDENTIFICATION
LQGs SQGs CESQGs

* Identify whether you generate hazardous waste to 
determine if you are subject to the RCRA hazardous waste 
regulations. Test procedures are described in "Test 
Methods for the Evaluation of Solid Waste, 
Physical/Chemical Methods, SW-846," or tests can be 
performed by a local laboratory.


USED OIL STANDARDS
LQGs SQGs CESQGs

* If you generate used oil, you are subject to a separate 
set of management standards from the hazardous waste 
management standards, if the used oil will be recycled. 
If used oil is to be treated and disposed of, perform 
the hazardous waste identification step listed above.


WASTE COUNTING 
LQGs SQGs CESQGs

* Determine how much hazardous waste you generate to 
determine your generator status.


ACCUMULATION AREA 
LQGs SQGs

* You can accumulate waste in a "satellite accumulation 
area" with minimal regulatory burden. This area must be 
at or near the point of generation and under the control 
of the operator of the process generating the waste.

* There is no time limit on accumulation in the satellite 
accumulation area for waste under 55 gallons.

* There is a 55-gallon accumulation limit in the satellite 
accumulation area. Excess waste beyond the 55-gallon 
limit must be moved from the satellite accumulation area 
within 3 days.

* You must accumulate the waste in containers.

* Waste containers must be marked with the words "Hazardous 
Waste" or other words that identify their contents.

* This waste is exempt from other accumulation provisions 
while in the satellite accumulation area.


OTHER ACCUMULATION AREA (Time and Quantity Limits) 
LQGs SQGs CESQGs

* If waste accumulation does not meet the requirements for 
satellite accumulation, it is subject to more stringent 
requirements. LQGs can accumulate waste on site for up to 
90 days without a permit. SQGs can accumulate waste for 
180 days, Quantity Limits) or 270 days if the SQG must 
transport the waste more than 200 miles to a destination 
facility.

* Begin counting accumulation time when waste is first 
placed in the accumulation unit.

* Waste must be put in an exempt unit, recycled, or sent 
off site within the proper time period stated above.

* If an LQG or SQG accumulates wastes beyond the allotted 
time period, the facility is fully subject to the 
requirements of a hazardous waste storage facility unless 
granted an exemption. SQGs cannot accumulate more than 
6,000 kg of hazardous waste at any time.

* CESQGs cannot accumulate more than 1,000 kg of hazardous 
waste, more than 1 kg or acutely hazardous waste, or 100 
kg of spill residue from acutely hazardous waste at any 
time.


STORAGE UNIT REQUIREMENTS
LQGs SQGs

* Accumulate waste only in units that are in good 
condition, remain closed except when adding or removing, 
are inspected at least weekly, are compatible with the 
types of waste, and meet special standards for ignitable 
waste and incompatible waste.

* LQGs can use accumulation tanks and containers that have 
been assessed for integrity, have a secondary containment 
system, and are inspected each operating day. SQGs can 
use certain accumulation tanks as well.

* LQGs can use containment buildings as well.

* For all units, the date that the accumulation period 
begins must be clearly marked and visible on each 
container. All containers and tanks must be clearly 
marked or labeled with the words "Hazardous Waste," and 
accumulation units must be shut down and closed 
permanently in accordance with standards at the end of 
the unit life.

* LQGs and SQGs can treat their waste without a RCRA 
storage permit in accumulation units that meet standards.


AIR EMISSIONS 
LQGs

* LQGs must comply with organic air emissions requirements.


PREPAREDNESS AND PREVENTION
LQGs SQGs

* LQGs and SQGs must comply with preparedness and 
prevention requirements, including the following: 
-- An adequate internal alarm or communications 
system.
-- A device capable of summoning emergency personnel.
-- Portable fire control equipment.
-- Adequate water pressure to operate fire control 
systems.
-- Adequate testing and maintenance of all emergency 
systems.
-- Access to communication or alarm systems during 
waste handling activities.
-- Adequate aisle space for emergency response.
-- An arrangement with local emergency response 
authorities.


CONTINGENCY PLAN
LQGs SQGs

* LQG facilities must prepare a facility contingency plan 
in accordance with regulations.

* The contingency plan must be designed to minimize hazards 
from fires, explosions, or any unplanned release of 
hazardous waste or constituents.

* A copy of the contingency plan must be kept on site and 
an additional copy must be submitted to all local 
emergency services providers.

* LQGs and SQGs must have an emergency coordinator on site 
or on call at all times to respond to emergencies.

* Emergency response information must be posted next to the 
telephone.

* In the event of a fire, explosion, or release that could 
threaten human health outside the facility or when a 
spill has reached surface water, the emergency 
coordinator must notify the National Response Center at 
800 424-8802.


PERSONNEL TRAINING 
LQGs SQGs

* LQGs must have a personnel training program in accordance 
with regulatory standards.

* Training must instruct facility personnel about hazardous 
waste management procedures and emergency response.

* Training must be completed within 6 months from the 
applicability of requirements.

* The facility must undertake an annual review of initial 
training.

* SQGs must ensure that all employees are thoroughly 
familiar with proper waste handling and emergency 
procedures relevant to their responsibilities.


DOT PACKAGING 
LQGs SQGs CESQGs

* Before being transported, waste must be packaged, 
labeled, and marked in accordance with applicable DOT 
requirements. Call the DOT hazardous materials 
information line at 202 366-4488 for information.


OFFSITE MANAGEMENT OF WASTE
LQGs SQGs CESQGs

* Hazardous waste sent off site for handling may only be 
sent to a hazardous waste TSDF or recycling facility 
unless otherwise exempt.

* CESQGs: See onsite management of waste below.

ONSITE MANAGEMENT OF WASTE
CESQGs

* CESQGs may either treat waste on site, if they qualify as 
one of the following types of facilities, or ensure 
delivery of waste to one of the following types of 
facilities: permitted RCRA TSDF; interim status TSDF; 
state authorized to handle hazardous waste; permitted, 
licensed, or registered by state to handle municipal 
solid waste according to standards; permitted, licensed, 
or registered by state to handle nonmunicipal waste; if 
managed after January 12, 1998, facility is permitted, 
licensed, or registered by state to handle nonhazardous 
waste in accordance with standards; facility beneficially 
uses or reuses, or legitimately recycles or reclaims, its 
waste; facility treats its waste prior to beneficial use, 
reuse, or legitimate recycling or reclamation; or a 
universal waste handler in accordance with standards.


MANIFEST 
LQGs SQGs 

* Hazardous waste sent off site must be accompanied by a 
manifest, a multipage form that documents the waste's 
progress through treatment, storage, and disposal. It can 
usually be obtained from your state agency.

* The manifest must have enough copies to provide the 
generator, each transporter, and the destination facility 
with one copy for their records and a second copy to be 
returned to the generator after completion by the 
destination facility operator.

* SQGs that have a contractual agreement with a waste 
reclaimer that specifies the types and frequencies of 
shipments do not need to manifest the wastes if they 
retain a copy of the agreement in their files.


LAND DISPOSAL RESTRICTIONS (LDR) NOTIFICATION
LQGs SQGs 

* Your waste must meet certain treatment standards under 
the LDR program. Waste must be treated to reduce the 
hazardous constituents to levels set by EPA or the waste 
must be treated using a specified technology. All waste 
sent off site for treatment, storage, and disposal must 
be accompanied by appropriate LDR program notifications 
and certifications. There are no required forms, but 
these papers must indicate whether or not wastes meet 
treatment standards, or whether the waste is excluded 
from the definition of hazardous or solid waste or is 
otherwise exempt.

HAZARDOUS WASTE MINIMIZATION
LQGs SQGs 

* To encourage generators to produce less hazardous waste, 
LQGs are required to have a program in place to reduce 
the volume and toxicity of waste generated to the degree 
economically practicable, and must select a currently 
available treatment, storage, or disposal method that 
minimizes present and future threats.

* LQGs and SQGs must sign a certification of hazardous 
waste minimization on the manifest.

* SQGs must make a good faith effort to minimize waste 
generation and to select the best available waste 
management method that they can afford.


BIENNIAL REPORT 
LQGs

* LQGs must submit biennial reports of waste generation and 
management activity by March 1 of every even-numbered 
year. EPA, other agencies, and the public use this 
information to track trends in hazardous waste 
management.


RECORDKEEPING 
LQGs SQGs 

* LQGs must maintain personnel training records until the 
facility closes.

* LQGs must keep copies of each biennial report for 3 
years.

* LQGs and SQGs must keep a copy of each manifest for 3 
years.

* LQGs and SQGs must keep records of test results, waste 
analyses, and other hazardous waste determinations for 3 
years.
************************************************************


REDUCE OR MINIMIZE THE HAZARDOUS WASTES YOU GENERATE

Recycling and pollution prevention measures can
significantly reduce your regulatory burden and may save
your business considerable money. This section presents
information on hazardous wastes typically generated by
various printing processes and provides suggestions for how
to recycle them or implement pollution prevention measures.
This list might not cover all chemicals used or wastes
produced by the printing industry. Consult the hazardous
waste lists and characteristics to determine if you generate
other hazardous wastes.


************************************************************
The following examples show hazardous wastes typically
generated by the printing industry and provide suggestions
for how to recycle, treat, or dispose of them according to
federal regulations.
************************************************************


Only the federal hazardous waste codes are provided here.
Your state might have different codes for some waste
streams. You should check with your state hazardous waste
authority for additional waste codes and requirements.


************************************************************
PROCESS Using ink in lithography, letterpress, screen 
printing, flexography, and gravure 

Wastes Waste ink with chromium, barium, and lead
Generated content; and waste ink contaminated with cleaning 
solvents, such as trichloroethylene, methylene 
chloride, 1,1,1-trichloroethane, carbon 
tetrachloride, 1,1,2-trichloroethane, 
1,2,3-trifluoroethane, chlorobenzene, xylene, 
acetone, methanol, methyl ethyl ketone (MEK), 
toluene, carbon disulfide, or benzene.

Possible D005 (barium), D007 (chromium), D008 (lead),
RCRA F001 to F005 (listed solvents), D001 (ignitable
Waste waste), D018 (benzene), D019 (carbon
Codes tetrachloride), D021 (chlorobenzene), and D040 
(trichloroethylene).

Potential * Recycle inks to make black ink. Reformulated
Recycling, black ink is comparable to lower quality new
Treatment, black inks such as newspaper ink.
and * Dispose of inks by sending them to a fuel
Disposal blending service that combines these and other 
Methods wastes for burning at industrial boilers or 
kilns.
* Ship waste using a registered hazardous waste 
transporter to a hazardous waste TSDF.

Potential * Dedicate presses to specific colors or
Pollution special inks to decrease the number of
Prevention cleanings required for each press.
Methods * Clean ink fountains only when changing colors 
or when there is a risk of ink drying.
* Run similar jobs simultaneously to reduce waste 
volume.
* Isolate inks contaminated with hazardous 
cleanup solvents from noncontaminated inks.
* Use organic solvent alternatives wherever 
possible, such as detergent or soap, 
nonhazardous blanket washes, and less toxic 
acetic acid solvents.

PROCESS Cleaning printing equipment 

Wastes Spent organic solvents might include
Generated trichloroethylene, methylene chloride, 1,1,1- 
trichloroethane, carbon tetrachloride, 
1,1,2-trichloroethane, 1,2,3-trifluoroethane, 
chlorobenzene, xylene, acetone, methanol, MEK, 
toluene, carbon disulfide, or benzene.

Possible F001 to F005 (listed solvents), D001 (ignitable
RCRA waste), D018 (benzene), D019 (carbon
Waste tetra-chloride), D021 (chlorobenzene), D040
Codes (trichloroethylene), D005 (barium), D007 
(chromium), D008 (lead), D018 (benzene), and D019 
(carbon tetrachloride).

Potential * Find a legitimate reuse for spent solvents on
Recycling, site. If reused, the solvents are not
Treatment, considered to be wastes and, therefore, are
and not regulated. Examples include reusing
Disposal solvents in a parts-cleaning unit that is
Codes used to clean dirty press parts.
* Dispose of solvents by sending them to a fuel 
blending service, which combines these and 
other wastes for burning at industrial boilers 
or kilns.
* Recycle spent solvents in an onsite solvent 
still.
* Contract with a solvent recycler or supplier to 
take the spent solvent away and replace it with 
fresh solvent.
* Ship waste using a registered hazardous waste 
transporter to a hazardous waste TSDF. Most 
solvents will be recycled or incinerated.
* Appropriate management techniques for rags and 
disposable wipers contaminated with solvents 
are at the discretion of your state or EPA 
regional office. A wide variety of options are 
available including sending them to laundry 
services after wringing out excess solvent, 
disposing of them as hazardous waste, treating 
them to recover the solvents, or incinerating 
them as hazardous waste. To obtain your 
appropriate state or regional contact, call the 
RCRA Hotline at 800 424-9346.

Potential * Print lighter colors first.
Pollution * Squeegee or wipe surfaces clean before
Prevention washing with solvent.
Methods * Dedicate presses to specific colors or special 
inks to decrease the number of cleanings 
required for each press.
* Run similar jobs simultaneously to reduce 
cleanup waste volume.

* Use organic solvent alternatives wherever 
possible, such as detergent or soap, 
nonhazardous blanket washes, and less toxic 
acetic acid solvents.


PROCESS Developing negatives and prints 

Wastes Waste photochemical solutions from fixer and
Generated rinsewater and from alkaline or acid process 
baths.

Possible D011 (silver) and D002 (corrosive waste).
RCRA
Waste Codes

Potential * Ship silver waste using a registered
Recycling, hazardous waste transporter to a hazardous
Treatment, waste TSDF.
and * Recover silver from fixing baths using
Disposal chemical recovery cartridges, electrolytic
Methods recovery cells, or ion exchange resins, and 
have a commercial recycler pick it up.
* Neutralize waste on site in an exempt 
elementary neutralization unit.

Potential * Eliminate silver waste by using silver-free
Pollution films such as vasicular, diazo,
Prevention electrostatic, and photopolymer.
Methods * Add ammonium thiosulfate to silver- 
contaminated baths to extend the allowable 
buildup of silver.
* Use an acid stop bath prior to fixing bath to 
reduce effect of alkaline developer on fixing 
bath pH.
* Install waterless paper and film developing 
units to reduce volume of fixer waste.
* Employ countercurrent (using water from 
previous rinsings in initial film washing 
stage) rather than parallel rinse techniques.
* Containerize process baths to keep them from 
spoiling.


PROCESS Plate processing 

Wastes Acid plate etching chemicals for metallic
Generated lithographic plates, and flexographic photopolymer 
plates.

Possible D002 (corrosive waste), F002 (perchloroethylene), 
RCRA and F003 (butynol).
Waste
Codes

Potential * Neutralize waste acid on site in an exempt
Recycling, elementary neutralization unit.
Treatment,* Ship waste using a registered hazardous waste
and transporter to a hazardous waste TSDF for
Disposal treatment and disposal.
Methods

Potential * Replace metal etching process with
Pollution nonhazardous alternative.
Prevention* Check with your state about the use of
Methods alternative plate solvents that may or may not 
be considered hazardous.


PROCESS Printing processes 

Wastes Unused inks, solvents, and other chemicals used
Generated in printing industry.

Possible D001, D002, U002 (acetone), U019 (benzene),
RCRA U211 and D019 (carbon tetrachloride), U055
Wastes (cumene), U056 (cyclohexane), U069 (dibutyl
Codes phthalate), U112 (ethyl acetate), U259 (ethanol, 
2-ethoxy), U359 (ethylene glycol monoethyl ether), 
U122 (formaldehyde), U154 (methanol), U226 (methyl 
chloroform), U080 (methylene chloride), U159 and 
D035 (MEK), U161 (methyl isobutyl ketone), U210 
and D039 (tetrachloroethylene), U220 (toluene), 
U223 (toluene diisocyanate), U228 and D040 
(trichloroethylene), U043 and D043 (vinyl 
chloride), and U239 (xylene).

Potential * Neutralize corrosive wastes on site in an
Recycling, exempt elementary neutralization unit.
Treatment * Find a legitimate reuse for unused chemicals
and on site. If legitimately reused, the
Disposal chemicals are not considered to be waste.
Methods Examples include using solvents to clean dirty 
press parts.
* Dispose of organics with high fuel value by 
sending them to a fuel blending service, which 
combines these and other wastes for burning at 
industrial boilers or kilns.
* Ship waste using a registered hazardous waste 
transporter to a hazardous waste TSDF. Most 
organics will be incinerated.

Potential * Instigate inventory controls to avoid
Pollution overstocking on inks, solvents, and other
Prevention printing chemicals.
Methods
************************************************************


OTHER ENVIRONMENTAL LAWS AFFECTING THE PRINTING INDUSTRY 

The Clean Water Act 


The Water Pollution Control Act, commonly known as the Clean
Water Act (CWA), is the federal program designed to restore
and maintain the integrity of the nation's surface waters.
CWA controls direct discharges to surface waters (e.g.,
through a pipe) from industrial processes or stormwater
systems associated with an industrial activity. It also
regulates indirect discharges, or discharges to publicly
owned treatment works (POTW) through a public sewer system,
by requiring industrial facilities to pretreat their waste
before discharging to a public sewer. Industrial pollutants
from the printing industry that the CWA may regulate include
organics, such as solvents, and metals such as lead, silver,
mercury, copper, chromium, zinc, nickel, and cadmium. A
serious concern with wastewater discharges from print shops
is the high level of silver contained in photographic fixer
solutions and rinsewaters. These solutions will not meet
wastewater treatment plant discharge limits unless the
silver is removed.


CWA Resources: 

* 40 CFR Parts 100 to 129 and 400 to 503 

* EPA Office of Water home page: http://www.epa.gov/OW 

* EPA Office of Water: 202 260-5700 

* Your state water authority, regional EPA office, and 
your local POTW 


Oil Pollution Prevention Under the CWA 

The Oil Pollution Prevention regulations were promulgated
under the authority of the CWA. These regulations establish
requirements for facilities to prevent oil spills from
reaching the navigable waters of the United States or
adjoining shorelines. The regulations apply to
non-transportation-related facilities with a specific
aboveground or underground oil storage capacity that,
because of their location, can reasonably be expected to
discharge oil into the navigable waters of the United
States.


Oil Pollution Prevention Regulation Resources: 

* 40 CFR Part 112 

* Internet access: http://www.epa.gov/ 


The Clean Air Act 


The Clean Air Act (CAA) regulates air pollution. It includes
national emission standards for new stationary sources
within particular industrial categories. It also includes
national emission standards for hazardous air pollutants,
which are designed to control the emissions of particular
hazardous air pollutants (HAPs). Printers generate some
HAPs, including benzene, cadmium compounds, carbon
tetrachloride, chromium compounds, cobalt compounds, glycol
ethers, perchloroethylene, vinyl chloride, and xylene. The
CAA also seeks to prevent the accidental release of certain
hazardous chemicals and to minimize the consequences of such
releases.


CAA Resources: 

* 40 CFR Parts 50 to 99 

* Control Technology Center, Office of Air Quality, 
Planning, and Standards, EPA, general information: 919 
541-0800, publications 919 541-2777 

* Internet access: http://www.epa.gov/oar/oaqps/ctc


************************************************************
CFR GUIDE TO HAZARDOUS WASTE REGULATIONS 

To review the RCRA regulations referred to in this document,
consult the following citations in 40 CFR: 

Part 260--Hazardous waste management system: general.

Part 261--Identification and listing of hazardous waste.

Part 262--Standards applicable to generators of hazardous
waste.

Part 263--Standards applicable to transporters of hazardous
waste.

Part 264--Standards for owners and operators of hazardous
waste and specific types of hazardous waste management
facilities.

Part 265--Interim status standards for owners and operators
of hazardous waste TSDFs.

Part 266--Standards for the management of specific hazardous
wastes and specific types of hazardous waste management
facilities.

Part 268--Land disposal restrictions.

Part 270--EPA administered permit programs: the Hazardous
Waste Permit Program.

Part 271--Requirements for authorization of state hazardous
waste programs.

Part 272--Approved state hazardous waste management
programs.

Part 273--Standards for universal waste management.

Part 279--Standards for the management of used oil.

FOR MORE INFORMATION 

For additional information on any of these laws, contact the
RCRA Hotline at 800 424-9346 or 703 412-9810 in the
Washington, DC, area. 
TDD (hearing impaired): 800 553-7672 or 703 412-3323 in the
Washington, DC, area.
************************************************************

Comprehensive Environmental Response, Compensation, And
Liability Act (CERCLA OR Superfund) 

The Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) of 1980, commonly known as Superfund,
authorizes EPA to respond to releases, or threatened
releases, of hazardous substances that might endanger public
health, welfare, or the environment, that might come from
any source. Superfund also grants EPA the authority to force
parties responsible for environmental contamination to clean
it up or to reimburse response costs incurred by EPA. The
person in charge at your business must report to the
National Response Center (phone: 800 424-8802) any release
of a hazardous substance that exceeds a designated
"reportable quantity" for that substance within a 24-hour
period.


Superfund Resources: 

* Internet access: http://www.epa.gov/superfund 


The Emergency Planning And Community Right-to-know Act 


The Superfund Amendments and Reauthorization Act (SARA) of
1986 created the Emergency Planning and Community
Right-to-Know Act (EPCRA). This law was designed to improve
community access to information about potential chemical
hazards and to facilitate the development of chemical
emergency response plans by state and local governments. The
EPCRA regulations establish several types of reporting
obligations for facilities that store or manage specified
chemicals. Printers are likely to use some of the specific
chemicals such as ammonia, formaldehyde, hydroquinone,
propylene oxide, sulfuric acid, and 2,4-toluene
diisocyanate. Many of the chemicals used by printers, such
as phosphoric acid, lead, perchloroethylene, and fuel oil,
may be considered hazardous chemicals by the Occupational
Safety and Health Administration as well. These are subject
to additional requirements under EPCRA.


EPCRA Resources: 

* 40 CFR Parts 350 to 372 

* The State Emergency Response Commission (contact 
available from the RCRA Hotline) 

* Internet access: 
http://www.epa.gov/opptintr/tri/index.htm and 
http://www.epa.gov/swercepp 


Safe Drinking Water Act 


The Safe Drinking Water Act (SDWA) mandates that EPA
establish regulations to protect human health from
contaminants present in drinking water. Under the authority
of the SDWA, EPA developed national drinking water standards
and created a joint federal-state system to ensure
compliance with these standards. EPA also regulates
underground injection of liquid wastes under the SDWA to
protect underground sources of drinking water.


SDWA Resources: 

* 40 CFR Parts 141 to 148 

* SDWA Hotline: 800 426-4791 

* Internet access: http://www.epa.gov/ogwdw 


Toxic Substances Control Act 

The Toxic Substances Control Act (TSCA) allows EPA to
collect data on chemicals to evaluate, assess, mitigate, and
control risks that might be posed by their manufacture,
processing, and use. Printing facilities may be affected by
some of the TSCA requirements.


TSCA Resources: 

* 40 CFR Parts 702 to 799 

* TSCA Hotline: 202 554-1404 

* Internet access: http://www.epa.gov/internet/oppts


CONTACTS AND RESOURCES

Hotlines And Information Centers 

RCRA Hotline 

U.S. Environmental Protection Agency 
Phone: 800 424-9346 or 
TDD 800 553-7672.
In the Washington, DC, area: 703 412-9810 or 
TDD 703 412-3323.
Home page: http://www.epa.gov/epaoswer/hotline 

Answers questions on matters related to RCRA solid waste,
hazardous waste, and underground storage tanks, EPCRA, and
CERCLA.


RCRA Information Center 

U.S. Environmental Protection Agency 

RCRA Information Center (5305W) 
401 M Street, SW.
Washington, DC 20460 
Phone: 703 603-9230 
Fax: 703 603-9234 
E-mail: rcra-docket@epamail.epa.gov 

Holds and provides public access to all regulatory materials
on RCRA and distributes technical and nontechnical
information on RCRA issues.


Small Business Ombudsman Clearinghouse/Hotline 

U.S. Environmental Protection Agency 
Small Business Ombudsman (2131C) 
401 M Street, SW.
Washington, DC 20460 
Phone: 800 368-5888 
Fax: 703 305-6462 
Home page: http://www.smallbiz-enviroweb.org 

Helps private citizens, small businesses, and smaller
communities with questions on all program aspects within
EPA.


U.S. Department of Transportation 

Hazardous Materials Information Center 
Phone: 800 467-4922 

Provides information about DOT's hazardous materials
regulations.


U.S. Government Printing Office 

Superintendent of Documents 
P.O. Box 371954 
Pittsburgh, PA 15250-7954 
Phone: 202 512-1800 
Fax: 202 512-2250 

Prints and distributes the Code of Federal Regulations.
Title 40, Parts 260 to 299, contains most of the RCRA
requirements.


Additional Internet Addresses 

EPA Home Page: http://www.epa.gov 


EPA RCRA Hazardous Waste Resources
http://www.epa.gov/osw/topics.htm 

Code of Federal Regulations
http://www.epa.gov/docs/epacfr40/ 

The Printer's National Environmental Assistance Center
http://www.pneac.org 

Other Industry Contacts 

Screenprinting and Graphics Imaging Association
International 
10015 Main Street 
Fairfax, VA 22031-3489 
Phone: 703 385-1335 
Contact: Marcia Y. Kinter 
Fax: 703 273-2870 
Home page: http://www.sgia.org 

Flexographic Technical Association 
900 Marconi Avenue 
Ronkonkoma, NY 11779 
Phone: 516 737-6020 
Contact: Dr. Doreen Monteleone 
Fax: 516 737-6813 
Home page: http://www.fta.ffta.org 

National Association of Printing Ink Manufacturers 
777 Terrace Avenue, Heights Plaza 
Hasbrouck Heights, NJ 07604 
Phone: 201 288-9454 
Contact: George Fuchs 
Fax: 201 288-9453 

Graphic Arts Technical Foundation 
200 Deer Run Road 
Sewickley, PA 15143 
Phone: 412 741-6860 
Contact: Gary Jones 
Fax: 412 741-2311 


Other Resources 

Call the RCRA Hotline (800 424-9346) to order any of the
following documents: 


Understanding the Hazardous Waste Rules: A Handbook for
Small Businesses 1996 Update (EPA530-K-95-001) provides an
overview to help small business owners and operators
understand how best to comply with federal hazardous waste
management regulations. This booklet defines the three
categories of hazardous waste generators and assists small
quantity generators in determining if federal regulations
apply. This document explains how to obtain an EPA
identification number, manage waste on site, and ship waste
off site.

RCRA: Reducing Risk From Waste (EPA530-K-97- 004) provides a
brief overview of the national RCRA program and the role of
the states. This booklet defines RCRA hazardous waste and
how the RCRA regulations apply to generators, transporters,
and TSDFs. It focuses on hazardous waste but also addresses
municipal and industrial nonhazardous solid waste. It
provides examples of waste and waste treatment and disposal
methods, waste minimization tips, links to other
environmental laws related to hazardous substances, a
glossary of terms, and a guide to the RCRA section of the
Code of Federal Regulations.

Identifying Your Waste: The Starting Point (EPA530-F-97-029)
is a short brochure that explains how to determine if you
generate hazardous waste. It explains the definition of
solid waste and describes the five ways that wastes can be
considered hazardous. In addition, it provides information
about how to manage the various types of waste that are
generated by small businesses.

Call the Pollution Prevention Information Clearinghouse (202
260-1023) to order any of the following documents.

Screen Printing Project: Publications List (EPA744-
F-96-021) is a document produced by EPA's Design for the
Environment (DfE) program. he DfE Screen Printing Project is
a voluntary effort between representatives of the screen
printing industry and EPA. The goal of the project is to
provide screen printers with information that can help them
design operations that are more environmentally sound,
specifically regarding screen reclamation. This booklet
lists 18 documents in English and 8 documents in Spanish
that are available free of charge. Documents include case
studies and fact sheets that describe how companies reduced
the use of reclamation chemicals in screen printing and
reduced the use of solvents in screen reclamation as well as
videos on pollution prevention for screen printers.


Reducing VOCs in Flexography (EPA744-F-96- 013) is a fact
sheet that highlights the experience of one flexographic
printer that successfully reduced volatile organic compound
emissions and hazardous waste by switching to a water-based
ink system.

Vegetable Ester Blanket Washes (EPA744-F-96- 014) highlights
vegetable esters as an alternative blanket wash. DfE's study
of 22 commercially available blanket washes revealed that
vegetable blanket washes have more environmentally sound
properties than other blanket washes, including reduced
flammability.

Workplace Practices Make the Difference (EPA744- F-96-008)
describes the activities among 206 lithographers that
reduced chemical usage. These lithographers provide
suggestions for pollution prevention that are cost-effective
and improve processes.

Substitute Blanket Washes: Making Them Work
(EPA744-F-96-002) describes substitute blanket washes that
reduce volatile organic compounds and hazardous air
pollutants.

Pollution Prevention at Custom Print (EPA744-F-96- 001) is a
case study that highlights the pollution prevention
activities of one print shop. The company reduced the use of
chemicals on site by 70 percent, which has reduced waste and
saved $5,000 per year.

Managing Solvents and Wipes (EPA744-K-93- 001) is a case
study that shows one company's success with substituting
environmentally friendlier solvents, reducing the amount of
solvent in wastewater, and saving money in the process.

Learning From Three Companies That Reduced VOC Emissions
(EPA744-F-96-016) is a fact sheet that highlights the steps
that three flexographic printers took to reduce their VOC
emissions.

Reasonable effort has been made to review and verify information in this document. Neither PNEAC and its partners, nor the technical reviewers and their agencies, assume responsibility for completeness and accuracy of the information, or its interpretation. The reader is responsible for making the appropriate decisions with respect to their operation, specific materials employed, work practices, equipment and regulatory obligations.  It is imperative to verify current applicable regulatory requirements with state and/or local regulatory agencies.

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