PNEAC Fact Sheet
Offset Lithographic Automatic Blanket Wash Waste and Compliance Requirements
By Gary A. Jones

The rise in popularity of the multicolored 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 from automatic blanket wash systems. Meeting this challenge requires a knowledge and understanding of USEPA's appropriate state regulations as they apply to the waste blanket wash and what must be done to meet those specific regulatory requirements.

Understanding the Problem

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, wastes that either exhibit certain characteristics or contain specific chemicals, some at given concentrations, are classified as hazardous wastes. Waste blanket washes usually have flashpoints below 140°F, even though they may have been mixed with a considerable amount of water. See PNEAC's fact sheet, What is a Hazardous Waste (http://www.pneac.org/sheets/all/whatisahazwaste.cfm) for more details.

Wastes that have a flashpoint below 140°F are classified as ignitable and are assigned a waste code of D001. This waste code must appear on the label for the container used to ship the waste for disposal and the accompanying shipping papers called a uniform hazardous waste manifest.

The other important aspect of USEPA's hazardous waste regulations are the set of requirements that need to be met by the company that creates the waste known as a hazardous waste generator.

USEPA imposes numerous requirements upon hazardous-waste generators, which govern all aspects of a waste-management program, including waste classification, storage, marking, reporting and recordkeeping, and training. The extent of these requirements depends upon how much hazardous waste is generated at the facility a monthly basis. 2 USEPA has three classes of generators:

Large Quantity Generators (LQGs) - those who generate more than 2,200 pounds of hazardous waste per month or about 4-5 55-gallon drums.

Small Quantity generators (SQGs) - those who generate more than 220 pounds and less than 2,200 pounds per month or about 1/2 - 5 55-gallon drums.

Conditionally Exempt Small Quantity Generators (CESQGs) - those who generate less than 220 pounds or less per month or about 1/2 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.

Basic Hazardous Waste Generator Requirements

Requirement (40 CFR Section or Part) CESQG SQG LQG
Waste Determination (262.11) Yes Yes Yes
Generation Rate (261.5 and 262.34) per month ≤ 220 lbs >220 lbs ≤ 2,200 lbs >2,200 lbs
Accumulation Quantity (261.5 and 262.34) limit ≤ 2.2 lbs Acute ≤ 2,200 lbs (5 drums) ≤ 2.2 lbs Acute ≤ 13,200 lbs (28 drums) No Limit
Accumulation Time (261.5 and 262.34) No Limit 180 or 270 Days 90 Days
EPA ID Number (262.12) Not required Yes Yes
Manifesting (262, Subpart B) Not required Yes Yes
Mark Containers “Hazardous Waste” (262.34) Yes Yes Yes
Mark Containers With Start Date (262.34) Not required, but recommended Yes Yes
Satellite Accumulation (262.34(c)) * Yes Yes Yes
Personnel Training (262.34 and 265.16) None required Minimal (262.34(d)(5)(ii)) Yes
Preparedness and Prevention (265, Subpart C) No requirements Yes Yes
Contingency Planning (265, Subpart D) None required Minimal (262.34(d)(5)(ii)) Yes
Container Management (265, Subpart I) None required Yes except 265.176 Yes
Hazardous Waste Storage Area Inspections (265.174) No Yes Yes
Tank Management (265, Subpart J) No Only 265.201 Yes
Recordkeeping and Reporting (262, Subpart D) No Only 262.44 Yes
Land Disposal Restrictions (268.7) Yes Yes Yes

 

Generally, most printers are classified as either a CESQG or a SQG because they do not generate significant quantities of hazardous waste. However, the new sheetfed presses with liquid automatic blanket wash systems has caused many printers to now be classified as LQGs. In many instances, printers with these systems on their presses have experienced a dramatic increase in the volume of waste generated. Printers who at one time would have generated only one or two drums of waste blanket wash per month are now generating 10-15 drums per month.

Penalties for Noncompliance

Because generator status is determined on a monthly basis and there is no notification from the government when a facility changes status, such as when a printer moves from being an SQG to an LQG, many printers do not realize that they have quietly become LQGs. However, the change in status is quite noticeable to state regulators and USEPA and the printer is generally totally unaware of their situation until the appropriate agency inspector shows up for a compliance inspection.

There are two usual ways that a regulatory agency becomes aware that a printer is now a LQG. The first is that the printer fails to file an annual report on hazardous waste generation and waste reduction efforts. Several states require their LQGs to file an annual report on the amount of hazardous waste generated and reduction efforts. If the state does not require an annual report, then the USEPA requires this report to be submitted every even year by LQGs.

The second is when the actual waste is shipped. When a shipment of hazardous waste is sent offsite for disposal, a roundtrip manifest is required to accompany the waste. Once the waste reaches its destination, two copies are sent back to the generator indicating the receipt of the waste. One copy is called the "Return" copy, which is the generator's, and the other is the "State" copy, which is sent to the state. There is agency staff that reviews the return copies to check for errors and during the review, if larger quantities are shipped from a facility, the agency will cross reference this with their records to see how the facility registered with the state. If the printer registered as an SQG and they are now an LQG, and if they did not submit an annual or biennial report, then the local field office is typically notified and an inspection will occur.

Enforcement Experiences of Printers

Many of the more recent inspections at printing operations have resulted in rather large penalties for violations that were observed. The inspections have uncovered numerous violations for improper waste management onsite under the SQG and LQG requirements. The penalties have been rather severe ranging from about $12,000 to $18,000 per facility. The penalties could have been even greater, but because these situations have been the first instances of violations, the fines were reduced. Now that these printers are LQGs and violations have been discovered, they will be inspected on a regular basis.

The common SQG violations include the following:

Not labeling satellite accumulation and accumulation containers "Hazardous Waste." Satellite accumulation containers are used to collect hazardous waste at or near the point of generation and this would include the containers used to collect the waste blanket wash at the press.

Not labeling hazardous waste containers with the date they were moved into the hazardous waste storage area. Satellite containers do not have to be dated until they are full and they must be moved to the storage area within three days of being full.

Not labeling hazardous waste containers used for accumulation while in the hazardous waste storage area (not at the point of generation). The container must be dated on the day the first drop goes into the container.

Not keeping containers closed that are used to collect hazardous waste. This applies to all hazardous waste containers. Usually, spring closed funnels that are screwed into the bung hole on a drum are considered "closed" and an acceptable alternative.

Not designating a hazardous waste storage area. This area must be marked with a sign, located on an impervious crack free surface, and located in an area not subject to a lot of traffic or near open floor drains. Some states also require secondary containment for this area and it is highly recommended the generators provide secondary containment regardless of the regulations.

Not maintaining emergency equipment in the designated storage area and periodically tested to ensure it is in working order (e.g., communications device or alarm system, fire extinguishers, spill control equipment, etc.). This also includes posting emergency phone numbers at a phone near or at the storage area.

Not conducting general awareness training for all employees involved in hazardous waste handling.

Not conducting weekly inspections of hazardous waste storage areas. A log should be kept indicating the condition of the containers, any leaks or spills, and if any corrective action was taken. So far, none of the facilities that have been inspected have met the requirements that LQGs must meet (see box). These include:

Submitting an annual or biennial report (depending on state or federal requirements).

Developing a formal contingency plan.

Having a formal waste minimization plan.

Having formal employee training in hazardous waste management and responding to accidental releases.

In addition to the violations associated with hazardous waste, those involving the improper storage and handling of Universal Wastes have also been discovered and 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 generated by printers include lead acid batteries, fluorescent light bulbs and other mercury containing bulbs, thermostats, and switches. In some states, obsolete electronics (e-wastes) are also regulated as Universal Wastes. See PNEAC's fact sheet Universal Waste Rules and How They Affect a Printer (http://www.pneac.org/sheets/all/UniversalWasteRules.cfm) for more details on how these rules affect printers.

The Universal Waste violations include not keeping the wastes in closed containers, not labeling the container, and not indicating a start date of when the container was first began to be filled. There is a one year limit on the accumulation of any Universal Wastes.

Lastly, the 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 and USEPA is working on a national regulation, most states require the towels to not be saturated, kept in closed containers, and a contract exists between the printer and the launderer. Some printers are not keeping the towels in closed containers and/or the towels at the bottom of the container are sitting in a pool of liquid causing towels to fail the nosaturation criterion. Since the towels were not being manifested or managed as a hazardous waste, the violations have included the improper management of launderable towels. 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.

Addressing the Automatic Blanket Wash Issue

There are three approaches that can be taken to minimize or eliminate the large volume of hazardous waste that is created from the use of automatic blanket wash systems. The first would be to adjust the volume of solvent being applied to the blanket. By making adjustments to the volume being applied, some printers have cut their waste volume in half. In combination with adjustments to the volume, training should be provided to the operators about how frequent the wash system should be cycled. One of the benefits associated with these types of systems is that it saves time and increases productivity, but because they are easily used, they tend to get used more frequently than they should. This overuse of the cleaning system increases waste generation which can be very costly to manage.

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 140oF and not contain any chemical that would be on one of USEPA's lists of "listed" hazardous wastes (see EPA's web page, What Is A Hazardous Waste at http://www.epa.gov/epaoswer/osw/hazwaste.htm#hazwaste). In pursuing this approach, it is important to work with the vendor of the automatic blanket wash system to ensure that any warranties will not be voided. It is best to contact the vendor of the system to determine if they have any solvents that would not be classified as a hazardous waste. The drawback to this approach is that there is still a large volume of waste that must be properly disposed, which can be expensive. Replacing with nonhazardous solvents in conjunction with a distillation unit can be a very powerful combination as it will eliminate this hazardous waste stream and reduce disposal costs. While EPA does not require a permit for a distillation unit, individual state laws do vary and an air emission permit or waste treatment permit may be needed. In addition, an operator training may also be required.

It is important to make sure that if nonhazardous solvents are going to be used that the subsequent waste be placed into their original containers or new clean ones. If a nonhazardous waste is mixed with a hazardous waste left in an "empty" container, then the entire mixture is regulated as a hazardous waste.

A distillation unit can be used to reduce the amount of hazardous blanket waste generated. However, these onsite recycling units are subject to additional requirements if you are an SQG or LQG. Some states also require both air and waste permits for these units. Although this may be an attractive method for waste reduction, the USEPA strongly promotes process modifications to economically reduce waste rather than using end-of-line treatment or recycling.

If printers choose a distillation unit as the preferred method of waste reduction, they must realize that the regulations currently focus on the "point of generation". What this means is that the manner in which the waste blanket wash is transferred to the distillation unit will affect the generator status. If the waste blanket wash is manually transferred to the distillation unit or a holding tank that feeds the distillation unit, the entire amount of the waste (converted to weight) will have to be counted toward the monthly generator status determination. The only way to avoid this is if waste blanket wash is hard piped directly from the press to either the unit or a holding tank that is subsequently piped to the distillation unit.

When the distillation unit is hard piped (or directly connected by a pipe) from the press, then the only waste that gets counted toward determining generator classification is the waste generated by the distillation unit itself. Under this scenario, EPA has determined that the process is "closed looped" and that the waste blanket wash is part of a manufacturing process and the waste blanket wash can be reclaimed and reused.

For the solvent that is manually transferred to the distillation unit, once the solvent is reclaimed that volume of waste is only counted once during the month. Any additional solvent added is also included in the total generated during the month. For example, if 55 gallons of waste are taken to the distillation unit and 50 gallons are recovered, with 5 gallons of fresh solvent added to the recovered solvent, the weight of the entire 55 gallons are counted. Once the 50 recovered gallons and 5 fresh gallons are used and recovered, only the weight of the new 5 gallons is counted toward the generator classification for that month.

Once a new month begins, the counting process starts over again. If the unit were hard piped to the distillation unit, then only the original 5 gallons and any subsequent waste from the distillation unit would be counted toward the generator classification.

The last and perhaps the 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 from an economic perspective for presses that have already been purchased, installed, and in production, it is something that should be discussed as a new press purchase is being considered or negotiated. The non-liquid systems are basically a cloth material that has been impregnated with a solvent, which is typically a vegetable oil derived. The cloth is placed between two sets of rollers that allow it to be pressed against the blanket during the cleaning cycle.

However, these systems do generate waste cloth material. The good news is that they do not generate large volumes of liquid waste. The waste cloth will have residual solvent and ink waste on them and they must be evaluated and compared to the definition of hazardous waste to see if they would be hazardous. For example, California regulates uncontaminated lithographic ink as a hazardous waste and since there is ink on the waste cloth, the waste cloth would be considered a hazardous waste until it was specifically excluded as such. Not all states are as stringent as California, but it is important to determine how the waste cloth is regulated.

Summary and Conclusion

The advent of automatic blanket wash systems on large multicolored sheetfed presses has allowed printers to dramatically increase productivity. As with all things, there are advantages and disadvantages and while the automatic blanket washes are a benefit to production, they may also cause compliance issues with federal and state hazardous waste regulations. Printers who have sheetfed presses with automatic blanket wash systems who have not evaluated their hazardous waste management program are urged to review their internal program and make any necessary changes to meet USEPA and state hazardous waste regulations. Printers who are generating significant quantities of waste automatic blanket wash solution should take steps to minimize or eliminate this waste stream as well as other hazardous waste streams. Printers who are in the process of purchasing a new press are encouraged to examine a non-liquid automatic blanket wash system or at the very least request that the vendor provide a list of cleaning solvents that would not be classified as a hazardous waste when they are used.

For more information or to contact someone from PNEAC please visit www.pneac.org and post your request using "Ask PNEAC".

Primary Author

Gary Jones
Graphic Arts Technical Foundation
GJones@printing.org
412.741.6860

Other PNEAC Contacts

Debra Jacobson
University of Illinois Sustainable Technology Center
djacobson@istc.illinois.edu
630.472.5019

Wayne Pferdehirt
Solid & Hazardous Waste Education Center
pferdehi@epd.engr.wisc.edu
608.265.2361

Written: 2007
Updated: July 2011

Note: Reasonable effort has been made to review and verify information in this document. Neither PNEAC and it's partners, nor the technical reviewers and their agencies, assume responsibility for completeness and accuracy of the information, or it's 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.

© 2007 PNEAC