">PBT (Persistent Bioaccumulative Toxic Pollutant)
Powered industrial trucks include forklifts and roll trucks. Both battery and propane powered trucks are commonly used at printing facilities to move materials.
In addition to forklifts and roll trucks, there are other types of powered industrial trucks used in printing facilities, including battery powered pallet jacks, pallet trucks, and container tilters.
Forklifts are used in a printing facility to move input materials off trucks, load finished product onto trucks for delivery, move work in process (WIP) within the facility, and move raw materials to the various production equipment.
Heavy-duty forklifts used to move heavy rolls or skids of substrate are commonly found in a printing facility. Additionally, roll trucks with special clamps such as a drum clamp or a roll clamp are common.
Best Management Practices & Pollution Prevention
Recycling Lead-Acid Batteries
In order to keep in compliance with environmental regulations, lead-acid batteries need to be disposed of or recycled properly. This also helps manage your waste stream and can limit your exposure to liability, while keeping the environment healthy and setting a good example. When disposing of lead-acid batteries, keep in mind that they are classified as a hazardous waste, and must be handled accordingly. If lead-acid batteries are recycled, they are classified as universal waste, which means they are subject to less rigorous regulations. For more information click on the Regulations tab.
Forklift Maintenance and Repair
Any maintenance or repairs to forklifts should be completed within a building if possible. Using a tarp or other protective barrier underneath the forklift while performing maintenance or repairs will contain spilled fluids such as coolant and oil. Performing scheduled maintenance or repairs also helps minimize the potential for these fluids to accidentally leak, preventing contaminatation to the environment, while helping maintain a safe workplace.
If preventative maintenance and repairs on forklifts are contracted out, the vendor is responsible for properly disposing of oils, greases and batteries in accordance with all regulations. The repair technician should certify that the materials are being disposed of properly on the work order that accompanies the billing. Printers should keep records of maintenance and certifications in order to document that the disposal was properly done.
For access to vendors who may supply alternative materials and equipment, see the PNEAC Vendor Directory.
Lead-acid batteries found in powered industrial trucks commonly contain toxic levels of lead and sulfuric acid that can pose a significant threat to the environment. The sulfuric acid (battery electrolyte) in lead acid batteries is subject to the Emergency Planning and Community Right-to-Know Act (EPCRA) under the Superfund Amendments and Reauthorization Act (SARA) Sections 311 and 312 – hazardous chemicals stored. Section 311 reporting requirements are triggered if a facility stores any listed chemical, which includes sulfuric acid, over the amounts explained below.
SARA Section 312 reporting requirements, a.k.a. Tier II reports under the EPCRA requirements, are triggered if a facility stores any listed chemical in excess of the limits specified in the Section 302, 304, and the PBT (Persistent Bioaccumulative Toxic Pollutant) list of chemicals. In the case of lead-acid batteries, the sulfuric acid is listed on the Section 302 list of extremely hazardous chemicals and has a reporting threshold of 1,000 pounds at any given time during the year. The 1,000-pound threshold is very easy to reach with just a few power hand trucks or forklifts.
Based on the materials in a powered industrial truck, Section 313 reporting requirements are triggered* if a facility accumulates or stores 500 lbs (water weighs about 8.3 lbs/gal, and the electrolyte is usually denser than water, making it closer to 10 lbs/gal) of sulfuric acid, 10 lbs of mercury or 100 lbs of lead on site for any given day during the calendar year. Record keeping is required regardless of whether or not a facility is required to report. (*Additional chemicals can trigger SARA recordkeeping and reporting requirements. See the list linked in the additional information section for the complete list. Also see the PBT list of SARA reportable chemicals.)
When calculating the amount of any reportable substance, the amount stored on site is based on all sources of each material. For example, lead in lead acid batteries, trace amounts of lead compounds in ink pigments, trace amounts of lead in grinding wheels, etc. must be considered in the total quantity of lead stored on site.
When calculating the amounts of sulfuric acid, this does not include the weight of the battery case. However, you must include acid stored in spent batteries; new, but unused batteries, and acid stored in other containers or in batteries that are in active use.
EPCRA Regulatory Hierarchy:
- EPCRA section 302: List of chemicals and their reporting threshold. Presence of Extremely Hazardous Substances (EHS) at or above Threshold Planning Quantity (TPQ).
- EPCRA List of Extremely Hazardous Substances (EHS) – Alpha and CAS
- EPCRA section 304: Release of an EHS or Hazardous Substance at or above a reportable quantity must be reported to the Local Emergency Planning Committee (LEPC) and the National Response Center at 800.424.8802.
- EPCRA Sections 311: Presence of any chemicals listed under Section 302, PBT chemical list or Section 112R of the Clean Air Act. Batteries are classified as articles under Section 313 and do not have to be reported as PBTs as long as the lead within the battery case is not removed or otherwise altered. A list of chemicals or copies of MSDSs must be submitted to the LEPC and the fire department. Updates including additions or deletions must be provided at least quarterly.
- EPCRA section 312: The Tier II Report is required to be filed if 10,000 pounds of a listed chemical is stored on site on any calendar day in the year. If any substances are stored on site that are classified as an extremely hazardous substance (EHS), then the reporting threshold is 500 pounds or lower depending on the specific substance. The reporting threshold is also known as the threshold planning quantity (TPQ).
- Note that the TPQ for lead or lead compounds is 100 pounds.
- EPCRA Section 313: Form R Report is required if the facility uses or otherwise processes listed chemicals in excess of the reportable quantities. See the list of chemicals under section 302, PBT chemical list and the Section 112R Clean Air Act chemical list
More information about EPCRA
EPA classifies batteries as universal waste under 40 CFR 273. A small quantity handler of universal waste (SQHUW) is one that stores less than 5,000 Kg (or about 11,000 lbs.) of universal waste (all types combined) on any given day during the calendar year; a large quantity handler of universal waste is one that stores greater than 5,000 kg of universal waste on site. This includes waste batteries, fluorescent bulbs, HID (High Intensity Discharge) lamps, thermostats, etc.
SQHUWs (small quantity handlers of universal waste) are not required to notify EPA of their universal waste activities (no initial, annual, or biannual report required), and they are not required to obtain an U.S. EPA waste generator identification number as long as they do not store 5,000 Kg (or about 11,000 lbs.) of universal waste on site at any given time. See 40 CFR 273.32. Note that if a facility is generating other types of hazardous wastes they are still required to notify U.S. EPA and obtain an I.D. number.
SQHUWs are required to provide basic handling and emergency action information/training to employees who handle universal wastes. In the case of a release, handlers are required to immediately contain (prevent the spread or additional spillage) and handle/neutralize residues appropriately. They are also required to comply with all OSHA employee handling and exposure regulations. These requirements are analogous to those currently required for small quantity generators of hazardous waste. Any training provided under other programs that meets any or all of the training requirements of Part 273 of RCRA regulations may be used to fulfill this requirement. You need only add a reference to 40 CFR Part 273 to the training documentation.
The amount of universal waste a printing facility generates does not count towards their monthly quantity of RCRA hazardous waste determination. In other words, the amount of universal waste generated should not be counted towards the total amount of hazardous waste generated monthly. Universal waste does not impact your hazardous waste generator status.
Universal waste is subject to DOT packaging and shipping label requirements. However, when the waste does not require a hazardous waste manifest many of the DOT labeling requirements do not apply. Universal waste and containers of universal waste must be labeled at all times.
The waste batteries must be labeled as one of the following, depending on the type of universal waste:
- "Universal Waste - Battery(ies)"
- "Waste Battery(ies)"; or
- "Used Battery(ies)"
For more information, see 40CFR 273.15(b) and 40CFR273.35(b)
Record Keeping & Tracking
Offsite shipments of universal waste by a SQHUW do not require a hazardous waste manifest or other record keeping. However, it is recommended that simple documentation of quantities of universal waste shipped offsite be kept and maintained by SQHUWs in order to track and document generator status.
Health & Safety
Powered Industrial Trucks Standards (Forklift Training) and 20 CFR 1910.178
Each year, many injuries and deaths occur in U.S. workplaces due to powered industrial trucks. Many employees are injured when lift trucks are inadvertently driven off loading docks or lifts fall between docks and an unsecured trailer. Employees are also struck by lift trucks, due, in part, to poor signaling practices. With the right knowledge, training, and practice, many of these accidents can be prevented.
Generally, reducing the risk of powered industrial truck incidents requires comprehensive worker training, systematic traffic management, a safe work environment, a safe powered industrial truck, and safe work practices.
The primary OSHA standard is 29 CFR1910.178, Powered Industrial Trucks.
Since OSHA standards limit the operation of powered industrial trucks to only trained and authorized personnel, strict training requirements and performance standards must be met according to these regulations.
Since March 1, 1999 forklift operator training by a qualified instructor must be documented. The training required involves both classroom and practical demonstration of operator proficiency. Retraining is to provide every three years or when a near miss or accident occurs. The following links provide specific details on OSHA’s regulations:
OSHA Requirements for Forklift Safety
Sit-down forklifts manufactured in October 1993 and after are addressed by 29 CFR 1910.178, which requires seat belts. For forklifts manufactured prior to October 1993, if the employer has not taken advantage of a manufacturers offer for a retrofit, OSHA can cite the employer under Section 5 (a)(1). This is the general duty clause of the Occupational Safety and Health Act.
Good Operating Practices related to powered industrial and hand trucks, include:
- Use signs to inform, and policies to prohibit employees from entering areas where industrial trucks are active.
- Use the horn when appropriate to alert others.
- Maintain adequate lighting.
- When moving loads, when convenient, drive backward.
- Train operators to inspect and recognize potential problems or hazards. Operators should pass a written and driven proficiency exam to be certified to operate a forklift. Recertification should be done every 3 years.
- Implement an equipment inspection plan.
- Report and correct problems in a timely fashion.
- Institute a program of safe storage and stacking.
- Train employees in proper housekeeping procedures.
- Plastic wrap loads to maintain stability.
- Inspect and replace bad floor areas.
- Provide windows in doors low enough for employees to see who or what is coming on the other side, even if pushing pallet jacks.
- Train employees in proper and safe methods for using hand and electric jacks.
- If applicable, train employees how to properly handle propane cylinders used on the forklift.
- Provide one-way entrance and exits to help avoid collisions.
- Check for flat spots on rubber tires; over a long period of time the solid rubber wheel on the front of a powered industrial truck can develop a flat spot resulting in unstable loads and poor handling.
Attachments to Industrial Trucks
Printers commonly purchase attachments for powered industrial trucks from suppliers other than the powered industrial truck manufacturer. This can result in a safety and OSHA liability. Any additional equipment, such as a drum clamp, used on lift equipment must be properly maintained, be in good working order, and must be affixed with a engraved or stamped plate that certifies that the manufacturer of the fork truck to which the device is attached approves its use with the specific make and model of fork truck.
Batteries and Industrial Trucks
Exposure to fumes or vapors from the battery charging process can be dangerous. Lead-acid batteries have the potential to emit highly flammable hydrogen gas, which may result in a fire or explosion upon ignition.
All batteries, even sealed ones like alkaline batteries, should have a material safety data sheet (MSDS). Although exposure to chemicals during normal use may be highly unlikely, exposure can occur from installing and replacing batteries, in particular by leakage from corroded batteries. These are covered under the policy definition of “normal use” by OSHA.
Most battery accidents occur when the batteries are changed manually. Batteries can weigh 1,500 pounds. Battery lifting equipment can be purchased to facilitate this task. Powered industrial truck batteries need to be removed by hoist and routinely charged.
- Provide all employees with personal protective equipment
- Provide eyewash and showers for emergencies – This is required at battery charging stations
- Provide proper ventilation
No greater than 300 lbs. of LP (liquified propane) gas may be stored inside a building. This could include the compressed gas used to operate forklifts. If spare cylinders are located inside the building, the total volume of LP gas stored should not exceed this limit. This inside storage limit excludes cylinders in use or mounted for ready use.
Compressed gas cylinders must be stored at least 50 feet inside the property line. This applies whether or not the cylinders are stored inside a building or outside.
Cylinders with leaking valves or fittings that cannot be stopped by closing the valve, must be taken outdoors away from ignition sources and slowly emptied. Use extreme caution when dealing with LP gas.