iNFOCUS
J "" V
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CONTENTS
Frequently Asked Questions About RCRA 2
The Life Cycle of a Typical Printing Waste 4
Requirements for Regulated Printers 6
Reduce or Minimize the Hazardous Wastes You Generate 8
Other Environmental Laws Affecting the Printing Industry 11
Contacts and Resources 13
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.
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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 m 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.
PRINTING
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STATE
REQUIREMENTS
You may be regulat-
ed 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 con-
tact your state authority
to determine which state
requirements apply to
your business. To oper-
ate a hazardous waste
program, a state's regula-
tions must be consistent
with, and at least as
stringent as, the federal
program. Some states
adopt more stringent
requirements for facili-
ties handling hazardous
waste, which are consid-
ered part of the autho-
rized 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.
FREQUENTLY ASKED QUESTIONS
ABOUT RCRA
What Is RCRA?
RCRA is a federal law that encourages environmentally sound methods for managing commer-
cial and industrial waste as well as household and municipal waste. It regulates facilities that gener-
ate, transport, treat, store, or dispose of hazardous waste. The vast majority of printers are consid-
ered 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 gener-
ate 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 haz-
ardous 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, liq-
uids, and contained gaseous materials). If your waste is considered solid waste, you must then deter-
mine 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
fromKOOltoKiei.
• 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 (cyclohex-
ane), and U220 (toluene). Waste codes range from P001 to P205 and U001 to U411.
RCRA IN FOCUS
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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 combus-
tible, and have a flash point less than 60 °C (140 °F). Examples include used solvents, which have
a waste code of DOO1.
• 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 dis-
posed 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), DO 19 (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 Ib), or greater than
0.02 gallons (approximately 1 kg or 2.2 Ib) of acutely hazardous waste per month.
• Small Quantity Generators (SQGs). SQGs generate more than 25 gallons (equivalent to 100 kg or
approximately 220 Ib), but less than 200 gallons (1,000 kg or 2,200 Ib) 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 Ib), and less than or equal to 0.02 gal-
lons (1 kg or 2.2 Ib) 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 strin-
gent 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 char-
acteristic 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 spe-
cial 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).
PRINTING
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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 regu-
lations.
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.
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 FOOL File all
records of test results, waste
analyses, and other determi-
nations made in the haz-
ardous waste identification
process and keep them for at
least 3 years.
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 sol-
vent still bottoms when they
are removed from the still,
however.
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 certifica-
tions. You can choose from
any permitted or interim sta-
tus TSDF. Optional destina-
tions for solvents include a
hazardous waste incinerator
that will landfill the incinera-
tor ash, a hazardous waste
fuel blender who will blend
the solvents with other
wastes and then burn them
for energy recovery in a boil-
er or industrial furnaces, or a
facility that will recycle the
solvents.
PREPARE APPROPRIATE
NOTIFICATION AND
CERTIFICATION
Ensure that all hazardous
waste sent off site for treat-
ment, storage, or disposal is
accompanied by appropriate
notifications and certifica-
tions (initial shipments only).
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 certifica-
tion 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 treat-
ment, storage, or disposal
method currently available
that minimizes current and
future threats from the waste.
RCRA IN FOCUS
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DETERMINE
GENERATOR STATUS
Based on waste counting,
determine your generator
status. In this case, you have
produced more than 25 gal-
lons, but less than 200 gal-
lons, of hazardous waste in
the past month, which
means you are an SQG in
this calendar month period.
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 require-
ments might be different.
PLACE WASTE IN
ACCUMULATION
UNIT
Wfien the^aste 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.
IMPLEMENT LQG
PREPAREDNESS AND
PREVENTION
REQUIREMENTS
Check to be sure that emer-
gency preparedness and pre-
vention requirements are
met. These include adequate
emergency response systems
and notification to local
emergency response authori-
ties.
FOLLOW U.S.
DEPARTMENT OF
TRANSPORTATION (DOT)
PACKAGING STANDARDS
Before shipping waste off site
for treatment, storage, or dis-
posal, package, label, and mark
waste containers in accordance
with all applicable DOT
requirements. Call the DOT
Hotline at 800 467-4922.
CONTRACT WITH
HAZARDOUS WASTE
TRANSPORTER
To send waste off site to a
TSDF, contract with a regis-
tered hazardous waste trans-
porter. To locate a reliable
transporter, contact a col-
league to obtain a reference.
IMPLEMENT
PERSONNEL TRAINING
Be sure that your personnel
are familiar with hazardous
waste handling and emergen-
cy procedures.
IEPARI
CONTINGENCY PLAN
Next, ensure that a contin-
gency 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.
PRINTING
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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
REGULATORY
REQUIREMENT
EPA Identification
Number
Hazardous Waste
Identification
Used Oil Standards
Waste Counting
Accumulation Area
LQGs SQGs CESQGs
Other Accumulation
Area (Time and
Quantity Limits)
Storage Unit
Requirements
Air Emissions
Preparedness
and Prevention
Contingency Plan
Personnel Training
DOT Packaging
Offsite Management
of Waste
Onsite Management
of Waste
Land Disposal
Restrictions (LDR)
Notification
Hazardous Waste
Minimization
Biennial Report
Record keeping
IMPLEMENTATION EXPLANATION
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.
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.
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.
Determine how much hazardous waste you generate to determine your generator status.
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.
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,
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 LOG 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.
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.
LQGs must comply with organic air emissions requirements.
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.
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 sur-
face water, the emergency coordinator must notify the National Response Center at 800 424-8802.
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.
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.
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.
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; per-
mitted, 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.
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
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.
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.
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.
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.
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REDUCE OR MINIMIZE THE
HAZARDOUS WASTES You GENERATE
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.
Recycling and pollution prevention measures can significantly reduce your regulatory
burden and may save your business considerable money. This section presents infor-
mation on hazardous wastes typically generated by various printing processes and pro-
vides suggestions for how to recycle them or implement pollution prevention mea-
sures. 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.
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 Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
PROCESS
Wastes Generated
Waste ink with chromium, barium, and lead content; and waste ink contaminated with clean-
ing 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.
D005 (barium), D007 (chromium), D008 (lead), F001 to F005 (listed solvents), D001
(ignitable waste), D018 (benzene), D019 (carbon tetrachloride), D021 (chlorobenzene), and
D040 (trichloroethylene).
• Recycle inks to make black ink. Reformulated black ink is comparable to lower quality
new black inks such as newspaper ink.
• Dispose of inks by sending them to a fuel blending service that 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.
• Dedicate presses to specific colors or special inks to decrease the number of cleanings
required for each press.
• 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, nonhaz-
ardous blanket washes, and less toxic acetic acid solvents.
Cleaning printing equipment
Spent organic solvents might include trichloroethylene, methylene chloride, 1,1,1-
trichloroethane, carbon tetrachloride, 1,1,2-trichloroethane, 1,2,3-trifluoroethane, chloroben-
zene, xylene, acetone, methanol, MEK, toluene, carbon disulfide, or benzene.
8
RCRA IN FOCUS
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Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
F001 to F005 (listed solvents), D001 (ignitable waste), D018 (benzene), D019 (carbon tetra-
chloride), D021 (chlorobenzene), D040 (trichloroethylene), D005 (barium), D007 (chromi-
um), D008 (lead), D018 (benzene), and D019 (carbon tetrachloride).
• Find a legitimate reuse for spent solvents on site. If reused, the solvents are not consid-
ered to be wastes and, therefore, are not regulated. Examples include reusing solvents
in a parts-cleaning unit that is 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 sol-
vents, or incinerating them as hazardous waste. To obtain your appropriate state or
regional contact, call the RCRA Hotline at 800 424-9346.
• Print lighter colors first.
• Squeegee or wipe surfaces clean before washing with solvent.
• 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, nonhaz-
ardous blanket washes, and less toxic acetic acid solvents.
Developing negatives and prints
Waste photochemical solutions from fixer and rinsewater and from alkaline or acid process baths.
D011 (silver) and D002 (corrosive waste).
Ship silver waste using a registered hazardous waste transporter to a hazardous waste
TSDF.
Recover silver from fixing baths using chemical recovery cartridges, electrolytic recovery
cells, or ion exchange resins, and have a commercial recycler pick it up.
Neutralize waste on site in an exempt elementary neutralization unit.
Eliminate silver waste by using silver-free films such as vasicular, diazo, electrostatic,
and photopolymer.
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.
PRINTING
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PROCESS
Plate processing
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
Acid plate etching chemicals for metallic lithographic plates, and flexographic photopolymer plates.
D002 (corrosive waste), F002 (perchloroethylene), and F003 (butynol).
Neutralize waste acid on site in an exempt elementary neutralization unit.
Ship waste using a registered hazardous waste transporter to a hazardous waste TSDF
for treatment and disposal.
Replace metal etching process with nonhazardous alternative.
Check with your state about the use of alternative plate solvents that may or may not be
considered hazardous.
Printing processes
Unused inks, solvents, and other chemicals used in printing industry.
D001, D002, U002 (acetone), U019 (benzene), U211 and D019 (carbon tetrachloride), U055
(cumene), U056 (cyclohexane), U069 (dibutyl 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).
• Neutralize corrosive wastes on site in an exempt elementary neutralization unit.
• Find a legitimate reuse for unused chemicals on site. If legitimately reused, the chemi-
cals are not considered to be waste. 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.
• Instigate inventory controls to avoid overstocking on inks, solvents, and other printing
chemicals.
10
RCRA IN FOCUS
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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 naviga-
ble 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 docu-
ment, consult the fol-
lowing citations in
40 CFR:
Part 260—Hazardous
waste management sys-
tem: 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 haz-
ardous waste manage-
ment facilities.
Part 265—Interim status
standards for owners and
operators of hazardous
waste TSDFs.
Part 266—Standards for
the management of spe-
cific hazardous wastes
and specific types of
hazardous waste man-
agement facilities.
continued
PRINTING
11
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CFR GUIDE
continued
Part 268—Land disposal
restrictions.
Part 270—EPA adminis-
tered permit programs:
the Hazardous Waste
Permit Program.
Part 271—Requirements
for authorization of state
hazardous waste pro-
grams.
Part 272—Approved
state hazardous waste
management programs.
Part 273—Standards for
universal waste manage-
ment.
Part 279—Standards for
the management of used
oil.
FOR MORE
INFORMATION
For additional infor-
mation 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 haz-
ardous 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 con-
tamination 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, sul-
furic 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.htni 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 devel-
oped 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
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RCRA IN FOCUS
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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 regulato-
ry 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
Envirosense: http://es.inel.gov
(contains technical, policy, and general infor-
mation on pollution prevention topics)
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, NY11779
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:412741-2311
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, man-
age 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 munici-
pal and industrial nonhazardous solid waste. It
provides examples of waste and waste treat-
ment and disposal methods, waste minimiza-
tion 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 haz-
ardous 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 (DIE) program.
The DIE 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 infor-
mation that can help them design operations
that are more environmentally sound, specifi-
cally regarding screen reclamation. This book-
let lists 18 documents in English and 8 docu-
ments 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 pol-
lution prevention for screen printers.
Reducing VOCs in Flexography (EPA744-F-96-
013) is a fact sheet that highlights the experi-
ence of one flexographic printer that success-
fully reduced volatile organic compound emis-
sions and hazardous waste by switching to a
water-based ink system.
Vegetable Ester Blanket Washes (EPA744-F-96-
014) highlights vegetable esters as an alterna-
tive blanket wash. DfE's study of 22 commer-
cially available blanket washes revealed that
vegetable blanket washes have more environ-
mentally 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 blan-
ket washes that reduce volatile organic com-
pounds and hazardous air pollutants.
Pollution Prevention at Custom Print (EPA744-F-
96-001) is a case study that highlights the pol-
lution 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 sol-
vent 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 flexo-
graphic printers took to reduce their VOC
emissions.
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