PNEAC Fact Sheet
Compliance Issues for Lithographic Printers
By Debra Jacobson, PNEAC

The following is a list of potential sources of pollution to the air, water, and land commonly found in a lithographic printing plant that may be subject to permitting and/or special waste disposal and reporting requirements. Not all activities and pollutants identified can be found in each offset printing facility. The federal regulations that may impact these activities are referenced by section number (part), and at the end of this fact sheet specific chapter, subchapter, and specific sections are referenced. State and local regulations vary, and therefore the printer should review those regulations or seek assistance with identifying whether or not regulations apply to each process, product or equipment.

EPA = U.S. Environmental Protection Agency VOC = Volatile Organic Compound HAP = Hazardous Air Pollutant

AIR

Prepress Department

Sources of VOC Emissions Comment Potential Requirement Federal Regulation
Plate Correction
Fluids -
Insignificant amounts of VOC may be emitted from plate correction fluids simply due to the small volume typically used by most printing facilities Low levels of VOC emissions are not usually regulated or permitted, except in the case of facilities subject to Title V or FESOP permitting requirements, in which case the emissions would have to be inventoried, but likely considered "insignificant" or trivial. Several state air pollution control authorities exempt prepress activities from permit requirements. 40 CFR Part 70
Film Cleaner Insignificant amounts of VOC may be emitted from film cleaners simply due to the small volume typically used by most printing facilities. Low levels of VOC emissions are not usually regulated or permitted, except in the case of facilities subject to Title V or FESOP permitting requirements, in which case the emissions would have to be inventoried, but likely considered "insignificant" or trivial. Several state air pollution control authorities exempt prepress activities from permit requirements. 40 CFR Part 70
Proofing Insignificant amounts of VOC may be emitted from newer proofing systems due to new chemistries and technology. Existing older solvent-based proofing systems can emit larger quantities of VOC. Low levels of VOC emissions are not usually regulated or permitted, except in the case of facilities subject to Title V or FESOP permitting requirements, in which case the emissions would have to be inventoried, but likely considered "insignificant" or trivial. Several state air pollution control authorities exempt prepress activities from permit requirements. 40 CFR Part 70
Plate Making Insignificant amounts of VOC may be emitted from plate making simply due to the small volume and low VOC content of most plate developing chemistries typically used by most printing facilities. Low levels of VOC emissions are not usually regulated or permitted, except in the case of facilities subject to Title V or FESOP permitting requirements, in which case the emissions would have to be inventoried, but likely considered "insignificant" or trivial. Several state air pollution control authorities exempt prepress activities from permit requirements. 40 CFR Part 70
Film Developing Insignificant amounts of VOC may be emitted from film developing simply due to the small volume and low VOC content of most plate developing chemistries typically used by most printing facilities. Low levels of VOC emissions are not usually regulated or permitted, except in the case of facilities subject to Title V or FESOP permitting requirements, in which case the emissions would have to be inventoried, but likely considered "insignificant" or trivial. Several state air pollution control authorities exempt prepress activities from permit requirements. 40 CFR Part 70
Sources of HAPs Comment Potential Requirement Federal Regulation
Film Cleaner Insignificant amounts of HAP, namely hexane, may be emitted from film cleaners simply due to the small volume typically used by most printing facilities. Low levels of HAP emissions are not usually regulated or permitted, except in the case of facilities subject to Title V or FESOP permitting requirements, in which case the emissions would have to be inventoried, but likely considered "insignificant" or trivial. Several state air pollution control authorities exempt prepress activities from permit requirements. 40 CFR Part 70
Film Developing While hydroquinone is a common ingredient in film developers and is a HAP, it is not generally released to the air. Hydroquionone is consumed in the film development process.
Plate Making, Proofing, and Other Activities HAPs are not commonly found in the chemicals used in these processes.
Sources Particulate Matter Comment Potential Requirement Federal Regulation
None commonly known.

Printing Department

Sources of VOC Emissions Comment Potential Requirement Federal Regulation
Fountain solution - Products that contain wetting additives such as alcohols (isopropyl alcohol) or alcohol substitutes are considered VOC emission sources. Permit, record keeping, reporting, monitoring For heatset web sources subject to RACT* requirements one of the following needs to be met: 1. Maintain the as applied VOC content of the fountain solution at or below 1.6 percent, by weight; or 2. Maintain the as applied VOC content of the fountain solution at or below 3.0 percent, by weight, and refrigerate the fountain solution to 60oF or less; or 3. Maintain the as applied VOC content of the fountain solution at or below 5.0 percent, by weight, and use no alcohol in the fountain solution. For nonheatset web sources subject to RACT* requirements one of the following needs to be met: 1. Use no alcohol in the fountain solution 2. Maintain the as applied VOC content of the fountain solution at or below 5.0 percent, by weight, and use no alcohol in the fountain solution. For sheetfed sources subject to RACT* requirements one of the following needs to be met: 1. Maintain the as applied VOC content of the fountain solution at or below 5.0 percent, byweight; or 2. Maintain the as applied VOC content of the fountain solution at or below 8.5 percent, by weight, and refrigerate the fountain solution to 60oF or less; or 40 CFR Parts 50, 51, 70, 82
Cleaning Solvents – Blanket and Roller Washes Most solvent based cleaning products will contain specific or blends of various chemicals or compounds that are considered a VOC. Detergent based products, used for specific applications, may have little to no VOC. Alternative blanket wash solutions may still contain small amounts of VOC. Permit, record keeping, reporting, monitoring For sources subject to RACT requirements*, blanket and roller wash shall be 1. no greater than 30% VOC by weight., or VOC composite vapor pressure shall be less than 10 mm Hg at 20oC (68oF).
Inks/Coatings Traditional petroleum based and soy based inks will contain VOC's. Sheetfed and non-heatset web inks and conventional coatings (varnishes) only emit 5% of the VOC content. Heatset web offset inks and conventional coatings (varnishes) emit 80% of the VOC content. Ultra violet and electron beam curable inks contain zero or trace amounts of VOC. Coatings are either conventional varnish, water based, solvent based, or UV curable with UV and conventional coatings possessing the same emission characteristics as inks. Water and solvent based coatings will release all of the VOCs in them. Permit, record keeping, reporting, monitoring For heatset sources subject to RACT requirements, duct heatset web dryer emissions to a pollution control device capable of reducing emissions by 90% or greater. There are no ink VOC requirements for nonheatset web or sheetfed sources subject to RACT. 40 CFR Parts 50, 51, 70, 82
Paper coating operations - Some paper coatings such as adhesives or other materials applied in-line may contain solvents that emit VOC's. Permitting, record keeping, reporting, monitoring. The paper coating RACT rule limits the VOC content is 2.5 pounds per gallon minus water and exempt compounds. 40 CFR Parts 50, 51, 61, 63, 68, 70, 82
Sources of HAPs Comment Potential Requirement Federal Regulation
Fountain solution Fountain solutions (alcohol substitutes) typically contain ethylene glycol, and several different types of glycol ethers. Permit, record keeping, reporting, monitoring 40 CFR Parts 61,63
Fountain Solution Refrigeration Systems or Equipment Chillers Systems may contain refrigerants (CFC's or HCFC's) that are classified as ozone depleting substances. Venting of refrigerant is prohibited. Refrigerants must be recovered and recycled by certified technician. Equipment used to recover and recycle refrigerants must be certified. Certified technician must complete servicing. Refrigeration units containing more than 50 pounds of Class I or Class II refrigerants must have records of servicing activities maintained. Used refrigeration equipment cannot be discarded without first removing refrigerant. 40 CFR Part 82
Inks/Coatings HAP's are not commonly found in offset inks and coatings. N/A N/A
Cleaning Solvent Cleaning solvent blends and/or pure chemicals such as Methyl Ethyl Ketone (MEK) may contain hazardous air pollutants. Common HAPs include glycol ethers, xylene, cumene, Review MSDS and the EPA's list of HAP's Permit, record keeping, reporting, monitoring 40 CFR Parts 61, 63, 68
Sources of PM Comment Potential Requirement Regulation
Printing presses Paper dust, spray powder from sheetfed presses, and other particulates in the form of condensable organics from uncontrolled ink oil emissions from heatset web presses may be emitted. PM emissions are generally not significant leading to opacity problems. Permit, record keeping, reporting, monitoring If ducted outside facility - most state permitting authorities have a 20% over a six minute period opacity limit and some have instaneous limits of 60%. 40 CFR Parts 50, 51, 70
In-line trimming or cutting Paper dust If ducted outside facility permit, record keeping, reporting, monitoring. If ducted outside facility - most state permitting authorities have a 20% over a six minute period opacity limit and some have instaneous limits of 60%. 40 CFR Parts 50, 51, 70
Cyclone W/ baler systems Paper dust If ducted to outside facility - permit, record keeping, reporting, monitoring If ducted outside facility - most state permitting authorities have a 20% over a six minute period opacity limit and some have instaneous limits of 60%. 40 CFR Parts 50, 51, 70
Sources of CO,Sox, & NOx Comment Potential Requirement Federal Regulation
Heatset Web Offset printing press dryers Gas fired dryers are a source of CO, SOx & NOX. Most dryers found in printing are not large units and do not emit significant amounts of pollutants. Record keeping, reporting Most dryers firing natural gas with heat input of 10 million Btu or less are exempt from permitting. Threshold for those burning fuel are lower – Check with State/Local Authority. 40 CFR Parts 50, 51, 70
Boilers Natural Gas and fuel oil fired boilers are a source of CO,SOx & NOx. Most boilers found in printing are not large units and do not emit significant amounts of pollutants. Dependant on Btu capacity - Permit, record keeping, reporting, monitoring Most boilers firing natural gas with heat input of 10 million Btu or less are exempt from permitting. Threshold for those burning fuel are lower – Check with State/Local Authority. 40 CFR Parts 50, 51, 70
Fuel Combustion Equipment - heating devices, hot water heaters, furnaces, space heaters, backup generators Gas and fuel oil fired fuel combustion equipment are a source of CO, SOx, & NOx. Most fuel combustion equipment found in printing are not large units and do not emit significant amounts of pollutants. Dependant on Btu capacity - Permit, record keeping, reporting, monitoring Most fuel combustion equipment firing natural gas with heat input of 10 million Btu or less is exempt from permitting. Threshold for those burning fuel are lower – Check with State/Local Authority. 40 CFR Parts 50, 51, 70
Pollution control devices Oxidizers are a source of CO, SOx & NOx. Most oxidizers found in printing are not large units and do not emit significant amounts of pollutants. Permit, record keeping, reporting, monitoring Most oxidizers firing natural gas with heat input of 10 million Btu or less are exempt from permitting. Threshold for those burning fuel are lower – Check with State/Local Authority. 40 CFR Parts 50, 51, 70

Post-Press

Sources of VOC Emissions Comment Potential Requirement Federal Regulation
Adhesives Adhesives may contain varying amounts of VOC's and/or HAPs, check the MSDS to determine if the specific product does contain VOC or HAPs. Adhesives are generally not a significant source of VOC and/or HAP emissions. Permit, record keeping, reporting, monitoring Low levels of VOC emissions are not usually regulated or permitted, except in the case of facilities subject to Title V or FESOP permitting requirements, in which case the emissions would have to be inventoried, but likely considered "insignificant" or trivial. 40 CFR Parts 50, 51, 70, 82
Laminates & coatings Laminates and coatings may contain varying amounts of VOC's and/or HAPs, check the MSDS to determine if the specific product does contain VOC or HAPs. Laminates and Coatings are generally not a significant source of VOC and/or HAP emissions. See above for more information on coating emissions. Permit, record keeping, reporting, monitoring Low levels of VOC emissions are not usually regulated or permitted, except in the case of facilities subject to Title V or FESOP permitting requirements, in which case the emissions would have to be inventoried, but likely considered "insignificant" or trivial. 40 CFR Parts 50, 51, 70, 82
Ink jet printing activities Ink jet inks may contain varying amounts of VOC's and HAP's, check the MSDS to determine if the specific product does contain VOC or HAPs. Some solvent-based ink jet inks can release significant amounts of VOC and HAPs. The most common HAPs are methyl ethyl ketone and methanol. Permit, record keeping, reporting, monitoring Low levels of VOC emissions are not usually regulated or permitted, except in the case of facilities subject to Title V or FESOP permitting requirements, in which case the emissions would have to be inventoried, but likely considered "insignificant" or trivial. Solvent-based ink jet activities emitting significant levels of VOCs or HAPs could be subject to control requirements. 40 CFR Parts 50, 51, 70, 82
Flexo imprinter Flexo imprinting inks may contain varying amounts of VOC's and HAP's, check the MSDS to determine if the specific product does contain VOC. Permit, record keeping, reporting, monitoring 40 CFR Parts 50, 51, 70, 82
Cleaning solvents See above See above See above
Sources of PM Comment Potential Requirement Federal Regulation
Converting & Die Cutting Paper dust If ducted outside, permit, record keeping, reporting,
monitoring. Most operations venting inside the facility are
exempt.

If ducted outside facility - most state permitting authorities have a 20% over a six minute period opacity limit and some
have instaneous limits of 60%.
40 CFR Parts 50, 51, 70, 82
Paper slitting
Cutting and trimming operations (guillotine)
Perfect binding
In-line off-line trimming or cutting
Sources of CO, SOx, & NOx Comment Potential Requirement Federal Regulation
None commonly known
Wastewater Discharges

Prepress Department

Sources of Pollutants Comment Potential Requirement Federal Regulation
Fixer containing silverthiosulfate - Silver is a heavy metal whose discharges are regulated by U.S. EPA, state regulatory agencies and local sewer authorities. Printers must meet the discharge limits established by the local sewer authority. A silver recovery system may be required to treat the fix or washwater prior to discharging it into the sewer system or off-site disposal or recycling may be necessary. Fix is also has a low pH and can be high in BODs, CODs, and total suspended solids. Discharges to the sewer must meet the local sewer authority's acceptable pH range. If the material does not, it must be neutralized prior to discharge or disposed of in other means. Do not discharge to a septic system. Silver is a heavy metal whose discharges are regulated by U.S. EPA, state regulatory agencies and local sewer authorities. Printers must meet the discharge limits established by the local sewer authority. A silver recovery system may be required to treat the fix or washwater prior to discharging it into the sewer system or off-site disposal or recycling may be necessary. Fix is also has a low pH and can be high in BODs, CODs, and total suspended solids. Discharges to the sewer must meet the local sewer authority's acceptable pH range. If the material does not, it must be neutralized prior tWaste water discharge permit and/or pretreatment, or off-site disposal as a hazardous waste.o discharge or disposed of in other means. Do not discharge to a septic system. 40 CFR Parts 116, 117, 121, 122, 125, 129, 136
Developer Developer has a high pH and can be high in BODs, CODs, and total suspended solids. Discharges to the sewer must meet the local sewer authority's acceptable pH range. If the material does not, it must be neutralized prior to discharge or disposed of in other means. Do not discharge to a septic system. Waste water discharge permit and/or pretreatment 40 CFR Parts 116, 117, 121, 122, 125, 129, 136
Other plate processing solutions Solutions for conventional aluminum plates are typically water-based with a small amount of solvent, typically propyl alcohol. Plate processing solutions for new direct-to-plate systems can have a high pH and BODs, CODs, and total suspended solids. Plate processing solutions for etching bimetallic plates exhibit low pH. Discharges to the sewer must meet the local sewer authority's acceptable pH range. If the material does not, it must be neutralized prior to discharge or disposed of in other means. Do not discharge to a septic system. Waste water discharge permit and/or pretreatment, or off-site disposal as a hazardous waste for bimetallic etching chemistry. 40 CFR Parts 116, 117, 121, 122, 125, 129, 136
Film & Plate Processor Cleaning Solutions Traditional film and plate processor cleaning solutions may contain chromic acid, which exhibits a low pH and high chrome content. Chromic acid should be avoided as it may be carcinogenic to humans. Discharges to the sewer must meet the local sewer authority's acceptable metal content and pH range. If the material does not, it must be neutralized prior to discharge or disposed of in other means. Do not discharge to a septic system. Waste water discharge permit and/or pretreatment, or off-site disposal as a hazardous waste. 40 CFR Parts 116, 117, 121, 122, 125, 129, 136

Printing Department

Sources of Water Pollutants Comment Potential Requirement Federal Regulation
Fountain solution May contain flammable materials (isopropyl alcohol) that are prohibited from all sanitary discharge systems if the flashpoint is below 140oF. Need to confirm acceptability with local POTW. Do not discharge to a septic system. Need permission from local POTW to discharge. Waste water discharge permit and/or pretreatment, or off-site disposal. 40 CFR Parts 114, 116, 117, 121, 122, 125, 129, 136
Water based coatings and adhesives May contain flammable materials (isopropyl alcohol) and other solvents in limited quantities that are prohibited from being discharged if the flashpoint is below 140oF. Need to confirm acceptability with local POTW. Do not discharge to a septic system. Need permission from local POTW to discharge. Waste water discharge permit and/or pretreatment, or off-site disposal. 40 CFR Parts 114, 116, 117, 121, 122, 125, 129, 136
Floor and equipment cleaning wash water May contain flammable or combustible materials, excessive color or pigment, and heavy metals. May also exceed the acceptable pH range for discharge water established by the local sewer authority, this is commonly associated with detergent based products. Do not discharge to a septic system. Need permission from local POTW to discharge. Waste water discharge permit and/or pretreatment, or off-site disposal. 40 CFR Parts 114, 116, 117, 121, 122, 125, 129, 136

Post Press

Sources of Water Pollutants Comment Potential Requirement Federal Regulation
Compressor condensate water - May contain excessive fats/oils/grease. An oil water separator may be needed to remove excess oil prior to discharging the condensate in order to meet the local sewer authority's discharge limit. Oil recyclable if separated from water. Do not discharge to a septic system. Waste water discharge permit and/or pretreatment, or off-site disposal. 40 CFR Parts 114, 116, 117, 121, 122, 125, 129, 136, 279
Water based coatings and adhesives May contain flammable materials (isopropyl alcohol) and other solvents in limited quantities that are prohibited from being discharged if the flashpoint is below 140o F. Some adhesives may contain binders that will disrupt the municipal waste water treatment system. Need to confirm acceptability with local POTW. Do not discharge to a septic system. Waste water discharge permit and/or pretreatment, or off-site disposal 40 CFR Parts 114, 116, 117, 121, 122, 125, 129, 136, 279

Solid Waste - Land (Hazardous Waste)

Prepress Department

Sources of Solid Waste Comment Potential Requirement Federal Regulation
Spent film Contains trace amounts of silver halide. Considered a hazardous waste if silver content is greater than 5 ppm as measured by TCLP. Most films used in the graphic arts industry are not hazardous. Contact vendor for confirmation or otherwise test. May be recycled. EPA Haz. Waste Generator ID#, manifest, record keeping, testing, proper handling and storage, labeling and other requirements (Only if hazardous waste). 40 CFR Parts 241, 260, 261, 262, 268
Spent Fixer Contains silver, even after passing through silver recovery units. Considered a hazardous waste if silver content is greater than 5 ppm as measured by TCLP. Will have to test to confirm silver concentration. May be recycled. EPA Haz. Waste Generator ID#, manifest, record keeping, testing, proper handling and storage, labeling and other requirements (Only if hazardous waste). 40 CFR Parts 241, 260, 261, 262, 268
Spent Developer Spent developer is generally not classified as a hazardous waste. Confirm with testing. May be recycled.
Spent Plate Developing Solutions Spent developer is generally not classified as a hazardous waste. Confirm with testing for silver content (daylight plates and some direct-toplate). May be recycled. EPA Haz. Waste Generator ID#, manifest, record keeping, testing, proper handling and storage, labeling and other requirements (Only if hazardous waste). 40 CFR Parts 241, 260, 261, 262, 268
Used Containers Packaging for photo and plate processing chemicals may contain product residues. Make sure containers meet the EPA's definition of "empty" (i.e., contains less than 1” of material in a 30-55 gallon drum or less than 3% of the dry volume weight). In order to recycle off site generator may need to rinse containers prior to shipment. If containers are to be recycled, records documenting the number of drums or containers per shipment to reconditioner/recycler should be retained. 40 CFR Part 261 49 CFR Part 173.29

Printing Department

Sources of Solid Waste Comment Potential Requirement Federal Regulation
Offset Printing plates Some plates such as paper and polyester “daylight” plates or direct-toplate systems using silver halide may contain trace amounts of silver halide. Considered a hazardous waste if silver content is greater than 5 ppm as measured by TCLP. Contact vendor for test results or otherwise test to confirm status. May be recycled, especially aluminum plates. EPA Haz. Waste Generator ID#, manifest, record keeping, , testing, proper handling and storage, labeling and other requirements (Only if hazardous waste). 40 CFR Parts 241, 260, 261, 262, 268
Ink waste– Offset Lithographic Most uncontaminated lithographic ink does not meet the definition of a hazardous waste. Some specialty inks may contain regulated metals, which are considered hazardous and could render the waste ink hazardous. Contact vendor for TCLP test results or otherwise test to confirm status. Should be segregated from other non-hazardous ink waste. Can be reblended or recycled. EPA Haz. Waste Generator ID#, manifest, record keeping, , testing, proper handling and storage, labeling and other requirements (Only if hazardous waste). 40 CFR Parts 40 CFR Parts 241, 260, 261, 262, 268
Cleaning solvent waste May exhibit flammable characteristic (i.e., flashpoint below 140oF) or contain an EPA “listed” solvent making them a hazardous waste. Cleaning solvents mixed with water may also contain excessive suspended solids, excessive color, and/or pH levels that do not meet the local discharge limits. EPA Haz. Waste Generator ID#, manifest, record keeping, , testing, proper handling and storage, labeling and other requirements (Only if hazardous waste). 40 CFR Parts 241, 260, 261, 262, 268
Adhesives Generally, adhesive wastes are not classified as hazardous. May exhibit flammable characteristic (i.e., flashpoint below 140oF) or contain an EPA “listed” solvent making them a hazardous waste. Water-based adhesives may also contain excessive suspended solids, excessive color, and/or pH levels that do not meet the local discharge limits. EPA Haz. Waste Generator ID#, manifest, record keeping, , testing, proper handling and storage, labeling and other requirements (Only if hazardous waste). 40 CFR Parts 241, 260, 261, 262, 268
Coatings Generally, coating wastes are not classified as hazardous. May exhibit flammable characteristic (i.e., flashpoint below 140oF) or contain an EPA “listed” solvent making them a hazardous waste may also contain excessive suspended solids, excessive color, and/or pH levels that do not meet the local discharge limits.. EPA Haz. Waste Generator ID#, manifest, record keeping, , testing, proper handling and storage, labeling and other requirements (Only if hazardous waste). 40 CFR Parts 241, 260, 261, 262, 268
Solvent, ink, or oil laden launderable/reusable shop towels May exhibit flammable characteristic (i.e., flashpoint below 140oF) or contain a EPA “listed” solvent making them a hazardous waste. Many states specifically regulate shop towels and if certain management practices are followed, then they are not considered hazardous wastesManagement practices vary according to state but include: 1. Towels must be unsaturated and pass paint filter or “one drop” test. 2. Containers must be labeled and covered or closed. 3. Must have a contract with industrial launderer. Excessive contaminants may cause compliance problems at the industrial laundry facility. Solvent can be recovered from towels for reuse. EPA Haz. Waste Generator ID#, manifest, record keeping, testing, proper handling and storage, labeling and other requirements (Only if hazardous waste). 40 CFR Parts 241, 260, 261, 262, 268
Solvent, ink, or oil laden disposable shop towels May exhibit flammable characteristic (i.e., flashpoint below 140oF) or contain a EPA “listed” solvent making them a hazardous waste. Towels classified as hazardous cannot be landfilled or “thrown into the trash”. Grease and oil that is classified as a state hazardous waste will result in the towels being considered hazardous solid waste. Solvent can be recovered from towels for reuse. EPA Haz. Waste Generator ID#, manifest, record keeping, testing, proper handling and storage, labeling and other requirements (Only if hazardous waste). 40 CFR Parts 241, 260, 261, 262, 268
Sorbent products (oil dry, sorbent socks and drip pads) - Depending on state or local regulations and contaminants in material, may be subject to significant regulations regarding disposal. Confirm with state on proper management. May be wrung or otherwise treated to remove contaminants. May be reused. EPA Haz. Waste Generator ID#, manifest, record keeping, testing, proper handling and storage, labeling and other requirements (Only if hazardous waste). 40 CFR Parts 241, 260, 261, 262, 268
Oil / Lubricants In some states, these materials are classified as state hazardous wastes and are subject to specific recycling and/or storage/handling and disposal regulations. Oils/lubricants containing certain metals or halogens above specific levels are classified as federal hazardous waste. Some states regulate oil and other lubricants as special wastes with separate storage,handling, and disposal requirements. EPA Haz. Waste Generator ID#, manifest, record keeping, testing, proper handling and storage, labeling and other requirements (Only if hazardous waste). Recycling typically avoids significant regulation. 40 CFR Parts 241, 260, 261, 262, 268, 279, 300, 302, 355, 370, 372
Containers (ink, solvent, blanket wash, etc.) - All containers must be emptied according to EPA regulation, which states there must be no greater than 1 inch of material remaining in 30-55 gallon drums and/or no greater than 3% material compared to the total volume of the container. In some states containers are considered a "regulated" waste material and may be classified as hazardous waste depending on the original contents of the container. Records documenting the # of drums or containers per shipment to reconditioner/recycler should be retained. 40 CFR Part 261 49 CFR Part 173.29

Post Press

Sources of Solid Waste Comment Potential Requirement Federal Regulation
Adhesives Generally, adhesive wastes are not classified as hazardous. May exhibit flammable characteristic (i.e., flashpoint below 140oF) or contain an EPA “listed” solvent making them a hazardous waste. Water-based adhesives may also contain excessive suspended solids, excessive color, and/or pH levels that do not meet the local discharge limits. EPA Haz. Waste Generator ID#, manifest, record keeping, , testing , proper handling and storage, labeling and other requirements (Only if hazardous waste). 40 CFR Parts 241, 260, 261, 262, 268
Coatings Generally, coating wastes are not classified as hazardous. May exhibit flammable characteristic (i.e., flashpoint below 140oF) or contain an EPA “listed” solvent making them a hazardous waste may also contain excessive suspended solids, excessive color, and/or pH levels that do not meet the local discharge limits.. EPA Haz. Waste Generator ID#, manifest, record keeping, , testing , proper handling and storage, labeling and other requirements (Only if hazardous waste). 40 CFR Parts 241, 260, 261, 262, 268
Solid Waste generated during production activities that is typically not regulated as a land pollutant:

Prepress Department

Sources of Solid Waste Comment Potential Requirement Federal Regulation
Plate and film packaging, slip sheets, and other nonhazardous solid wastes. May be recycled.

Printing Department

Sources of Solid Waste Comment Potential Requirement Federal Regulation
Paper (from make ready & web breaks or jams) May be recycled. See state & local requirements
Off spec printing May be recycled. See state & local requirements
Shrink wrap, paper wraps, and paper cores (from incoming raw materials) May be recycled. See state & local requirements

Post Press

Sources of Solid Waste Comment Potential Requirement Federal Regulation
Shrink wrap (from outgoing material wrapping) May be recycled. See state & local requirements

Other

Sources of Solid Waste Comment Potential Requirement Federal Regulation
Wooden Pallets / Broken Pieces Pallet material may be regulated by state or local regulation regarding disposal. Good pallets can be reused; broken pallets can be repaired/refurbished. If material is contaminated with solvents, inks, oil, etc, it may be considered regulated or potentially hazardous waste. May be restricted from land disposal. EPA Haz. Waste Generator ID#, manifest, record keeping, , testing, proper handling and storage, labeling and other requirements (Only if hazardous waste). 40 CFR Parts 241, 260, 261, 262, 268
Corrugated or other packaging If packaging is contaminated with solvents, inks, oil, etc. it may be considered a regulated waste. May be restricted from land disposal if specific conditions exist. 40 CFR Part 241,
Lead/Acid Batteries Considered a hazardous waste due to lead content. May be recycled. U.S. EPA Universal Waste Rules 40 CFR Parts 260, 261, 264, 265, 268, 270, 273
Fluorescent Bulbs Considered a hazardous waste due to mercury content. May be recycled. New, low or no mercury bulbs are now available. Make sure they pass the TCLP for heavy metals prior to disposal in municipal waste. Contact vendor for TCLP test data or otherwise test. U.S. EPA Universal Waste Rules 40 CFR Parts 260, 261, 264, 265, 268, 270, 273
Incandescent Bulbs May be considered hazardous waste due to lead content. May be recycled. U.S. EPA Universal Waste Rules 40 CFR Parts 260, 261, 264, 265, 268, 270, 273
Lighting ballasts containing Mercury (Hg) May be recycled. U.S. EPA Universal Waste Rules 40 CFR Parts 260, 261, 264, 265, 268, 270, 273
Lighting ballasts installed prior to 1972 May contain PCB's in packing material. May be recycled. U.S. EPA Universal Waste Rules 40 CFR Parts 260, 261, 264, 265, 268, 270, 273
Spent computers and other electronic devices May contain regulated precious metals and other recyclable materials. May be recycled. U.S. EPA Universal Waste Rules 40 CFR Parts 260, 261, 264, 265, 268, 270, 273

For additional information about compliance issues or pollution prevention opportunities in the printing industry visit the PNEAC web site at www.pneac.org

Graphic Arts Technical Foundation - Gary Jones or Rick Hartwig (412/741-6860)

Printing Industries of America - Ben Cooper (703/519-8115)

40 CFR Regulations Potentially Affecting Lithographic Printers (Record keeping Citations)

Part 50 - National Primary and Secondary Ambient Air Quality Standards Sections 50.1-50.12

Part 51 - Requirements for Preparation, Adoption, and Submittal of Implementation Plans

  1. Subpart G - Control Strategy Section 51.110 - 51.119
  2. Subpart I - Review of New Sources and Modifications Section 51.160 - 51.166
  3. Subpart J - Ambient Air Quality Surveillance Section 51.190
  4. Subpart K - Source Surveillance Section 51.210 - 51.214
  5. Subpart N - Compliance ScheduleSection 51.260 - 51.262
  6. Subpart P - Protection of Visibility Section 51.300 - 51.307
  7. Subpart Q - Reports Section 51.320 - 51.327

Part 61 - Emissions Standards for HAP's

  1. Subpart A - General Provisions Sections 61.01-61.19
  2. Subpart V - Emissions Standards for Equipment Leaks (fugitive emissions) 61.240-61.247

Part 63 - Emission Standards for HAP's for Source Categories

  1. Subpart A - General Provisions Section 63.01-63.15
  2. Subpart B - Control Technology for Major Sources Sections 63.50 - 63.56
  3. Subpart D - Compliance Extensions for Early Reductions of Haz Air Pollutants Section 63.70-63.81
  4. Subpart H - Emission Standards of HAP for Equipment Leaks Section 63.160 - 63.182

Part 68 - Chemical Accident Prevention

  1. Subpart A - General Provisions Section 68.1 - 68.3
  2. Subpart B - RMP Requirements
  3. Subpart - Regulated Substances for Accidental Release Prevention Section 68.100 - 68.125

Part 70 - State Operating Permit Programs - Title V

  1. Section 70.1 - 70.11

Part 82 - Protection of Stratospheric Ozone

  1. Subpart A - Production and Consumption Controls Section 82.1 - 82.13
  2. Subpart F - Recycling and Emission Reduction Section 82.150 - 82.166
  3. Subpart G - Significant New Alternatives Policy Program Section 82.170 - 82.12

Primary Author

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

Other PNEAC Contacts

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

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

Written: 1998
Updated: June 20, 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.

© 1998 PNEAC