Summary of Focus Group Discussions with Screen Printers
    and Lithographers for the Design for the Environment
                            Printing Project
                                Prepared/or:
                                 Julie Lynch
                          Pollution Prevention Division
                     Office of Pollution Prevention and Toxics
                                 U.S. EPA
                              401 M Street, SW
                            Washington, DC 20460

                                Prepared by:
                                Abt Associates
                              55 Wheeler Street
                            Cambridge, MA 02138
                          For More Information:

For more information on the Design for the Environment Printing Projects in screen printing,
lithography, and flexography, visit the DfE Web Site at http://es.inel.gov/dfe or contact:

              Pollution Prevention Information Clearinghouse (PPIC)
                                 U.S. EPA
                            401 M Street SW (7409)
                            Washington, DC 20460
                             phone: 202-260-1023
                              fax: 202-260-4659
                          email: ppic@epamail.epa.gov
               PPIC Web Site:http://es.inel.gov/p2pubs/ppic/ppic.html

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 1. Introduction

       The Design for the Environment (DfE) Printing Project is a unique, cooperative effort
 between the Environmental Protection Agency (EPA) and the printing industry aimed specifically
 at developing pollution prevention information for printers.  The project was initiated when
 printing industry associations came to EPA and requested assistance in evaluating products that
 claim  to  be environmentally friendly.   EPA and  several trade associations responded by
 establishing the DfE  Printing Project.   As one of the first steps  in this project,  industry
 representatives were asked to prioritize areas of environmental  concern in printing.  Blanket
 washes in lithography and screen reclamation  products in screen printing were identified by
 printers as the two areas of greatest concern and have been the primary focus of the project to
 date. The DfE printing project is now gathering information on  the performance, cost and the
 health and environmental risks of alternative blanket wash and screen  reclamation products.

       Information on the performance of alternative products will be  collected through product
 performance demonstrations  conducted  at volunteer printing  facilities.  The  health  and
 environmental risks associated with these alternative products will be estimated by the EPA DfE
 staff. In gathering this data, the DfE project hopes that this information will assist printers by:

       •      providing printers with information on a variety of alternatives to the products they
             currently use,
       •      encouraging printing suppliers to compete on the basis  of the environmental and
             health characteristics of their products, and by
       •      giving printers guidelines so that when they consider  new  products, they will know
             what type of information concerning environmental effects their suppliers should
             be providing.

       The information collected in the DfE printing project represents a significant effort by both
the printing industry and the EPA. The EPA will prepare a full report, known as the Cleaner
Technologies Substitutes Assessment (CTSA), documenting this research. Prior to the completion
of this project, however, the Agency wants to make sure that this information reaches as many
printers as possible and that it is  summarized in a format that is most useful to printers.  To
determine the needs  and preferences of printers regarding the format and content of information
products developed by the project,  Abt Associates was contracted by EPA to conduct a series of
focus groups nationwide with lithographers and screen printers.

       These focus groups were designed to answer to following questions:

       •      What type of information do printers need in order to evaluate environmentally
             friendly alternative products?
       •      In what format would printers like to see this information presented?
       •      What is the best way to distribute this information to as many printers as
             possible?

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       Abt Associates conducted eight focus groups; four with screen printers and four with
lithographers. These focus groups were held in the northeast, midwest, northwest, and southwest
sections of the country.  A total of 88 people attended the eight meetings including 48 printers,
14 printing supplies manufacturers or distributors, 6 printing industry consultants, 13 state and
local government agency representatives and 7 trade association representatives.

       This report first presents the methodology used to conduct the focus groups, provides an
overview of findings, and then  summarizes the findings of screen printing focus groups and
lithography focus groups separately.  Individual summaries of each focus group, the facilitator's
guides and the "mockups" presented at the focus groups are attached as appendices to this report.

2. Methodology

       To determine the most appropriate content and format for the final information products
generated by the DfE printing project, focus groups were held separately with screen printers and
lithographers. These focus groups were conducted in five cities to capture the .variety of printers'
perspectives nationwide.  Boston,  Chicago, Seattle, Portland, and Los Angeles were identified by
the Screen Printers Association International (SPAT) and the Printing Industries of America (PIA)
as 1) having active local screen  printing or lithography trade groups and 2) being cities where
similar focus groups have not already been conducted. It was felt that printers hi these locations
would be likely to use the information coming out of the DfE printing project and could provide
important input into the development of the content and format of the final information products.

Each focus group is described in the table below:
Location
Boston
Cambridge, MA
Natick, MA
Chicago

Seattle
Portland
Los Angeles

Date
November 16, 1993
October 21, 1993
December 6, 1993
December 7, 1993
January 19, 1994
January 20, 1994
April 21, 1994
April 21, 1994
Industry Group
Screen Printers
Lithographers
Screen Printers
Lithographers
Screen Printers
Lithographers
Screen Printers
Lithographers
Number of
Participants
6
10
11
10
23
12
8
8

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       Because the DfE printing project affects several groups involved in the printing industry,
 attendance at the focus groups was not limited to printers. Manufacturers and suppliers of blanket
 washes and screen reclamation products, printing equipment manufacturers, trade association
 representatives, printing industry consultants,  and state and local government representatives were
 also present.  Two-thirds of the participants, however,  were printers or represented printers
 interests (consultants, trade association representatives).  To encourage printers to speak freely
 about the DfE project, EPA did not attend any of the focus groups.

       To recruit participants, several approaches were  employed.  For screen printers, Abt
 Associates contacted both SPAI members and non-members in Boston, Chicago, and Los Angeles
 following a written  invitation from SPAI.  In Seattle,  the Seattle Metro Hazardous Waste
 Management Program (contacted by EPA's DfE outreach staff) requested the attendance of screen
 printers from their on-site consultations with screen printers and their Screen Print Advisory
 Team.1   For lithographers,  the Printing Industries of New England (an affiliate of Printing
 Industries of America (PIA)) coordinated a focus group  with their regular environmental
 committee meeting in Boston.  In Chicago,  lithographers were contacted from the general DfE
 mailing list. In Portland, the Pacific Printing and Imaging  Association (also contacted by EPA's
 DfE outreach staff) invited members (lithographers) interested in environmental issues.  The local
 PIA affiliate, PIA - Southern California, invited members to the Los Angeles lithography focus
 group. As shown in the table, actual participation ranged from 6 participants to 23 participants.
 High participation in the latter case was due to the attendance of 10 state and local government
 representatives.

       It  should be  noted that since most focus group participants are either  involved in
 environmental committees or are active trade association members, their responses may not be
 representative of the experiences or opinions of screen printers or lithographers as a whole.  In
 fact, many participants pointed out that small printers and quick print  shops were not well
 represented at the focus groups and may view  the DfE information products somewhat differently.
 Participants, however, were asked for their recommendations on what information and format
 would be  most appropriate for small facilities.

       In  the focus groups, participants were asked a series of questions about the usefulness of
 information rekted to alternative blanket washes or screen reclamation products.  An initial matrix
 was passed out to participants that presented  the type of information that will be gathered by the
 DfE project and disseminated to printers.  After  reviewing and commenting on  the type of
 information included in the initial matrix, participants were given four additional format mockups
to review. The initial matrix was presented as an option as well.  Mockup formats ranged from
 descriptive text to detailed technical information. See Appendix C  for examples of the mockups.
    Seattle Metro is charged with assisting small quantity generators as part of the State's Hazardous Waste
Reduction Plan. Through the Plan, Seattle Metro has conducted on-site visits and has formed the Screen Print
Advisory Team. This team is made up of screen printers and vendors.

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These mockups presented risk, performance, and cost information in a variety of formats and
varying levels of detail.  Participants were asked to comment specifically on each mockup as well
as on  other informational needs they have that might be addressed by  the  DfE  project.
Discussions centered around the following topics:

       •       Content  — Mockups  included  descriptive or numeric information about  the
              chemical  constituents, chemical characteristics,  performance, cost, risk, and
              disposal of the alternative product. In addition, the test conditions present during
              performance demonstrations were also included to facilitate the interpretation of the
              information presented in the mockups.  Participants were asked whether the type
              of information presented was adequate for them to make comparisons  between
              alternative products. Suggestions were requested for possible additions or deletions
              to the mockups.

       •       Format — Mockups were presented in a variety of formats including: a matrix,
              a table, and a fact sheet.  Two versions of the matrix were displayed; mockup #1
              included detailed, technical descriptions of product characteristics (e.g., cancer risk
              of 10 ~4) while mockup #2 used more descriptive language to describe the product
              attributes (e.g.,  carcinogen, skin irritant).  The table format of mockup #3 is very
              similar to mockup #2, except that headings appear on opposite axes and cells of
              information are not outlined.  Three versions of a fact sheet were offered.  The
              first two stand alone while the third functions as an attachment to the matrices or
              table.  In mockup #4, all products are listed on one fact sheet. Descriptions of the
              attributes of alternative products are grouped by category (i.e. performance, risk).
              In mockup #5, a separate fact sheet is provided for each product. Each fact sheet
              covers all categories for an individual product.  As an attachment, the fact sheet
              serves as a reference for each category in the matrix or table by providing details
              on how to interpret the information contained therein.  Participants were asked to
              select the format they felt would  be  most appropriate for  receiving  this
              information. Suggestions were also solicited on alternative formats.

       •      Vehicle- There are several options for delivering the DfE information to printers.
              To determine the most appropriate vehicle, participants were asked where they
              currently get such information. More importantly, they were asked which source
              they considered to be most credible to themselves and  to smaller  printers.
              Suggestions were requested for additional methods of delivering this information.

3. Overview of Findings

       Overall, screen printers and lithographers were enthusiastic about DfE and felt  it was an
important first step in encouraging pollution prevention practices  in the industry.  To make the
information more user-friendly, however, there was general agreement in all focus groups that,
whatever the final format, the information should be presented simply and in the most descriptive


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 terms possible. A simple format was thought to be the most useful to the widest audience. In
 addition, most printers asked for more information than is currently included in the mockups.
 Most printers emphasized that variations among print shops and work practices could make the
 results  of  the demonstrations hard  to  interpret,  unless  detailed information  about the
 demonstrations is made available.

        Another common concern among focus group participants was that the trade names of the
 products demonstrated will not be disclosed.  Both screen printers and lithographers agreed that
 this omission could make it much more difficult for them to use the information from the DfE
 project in their shops. Specifically, printers felt that if product names are not disclosed, a supplier
 could claim to be selling them the requested alternative product.  Printers, however, would have
 no way of verifying that they were actually receiving the product they had  requested. Many
 printers asked that a list of the names and phone numbers of participating manufacturers should
 be added as an appendix to the final information product.  This list would allow printers to contact
 a limited number of manufacturers directly for more information on their product lines.

        Focus group participants were also concerned that the demonstrations would not be
 conducted in a controlled setting such as a laboratory. They felt that through laboratory tests,
 products could be evaluated under consistent conditions instead of being subject to  the highly
 variable conditions that exist across printing facilities.

       Finally, all focus group participants agreed that it will be necessary to distribute the DfE
 information through several different sources in order to reach the greatest number of printers.
 Sources suggested by printers included: trade publications,  direct mailing and  state technical
 assistance personnel.
4. Screen Printers Focus Group Findings

       As mentioned in Section 2, participants were asked a series of questions on the content,
format and vehicles for distributing information products generated by DfE.  The most frequently
reported comments and concerns for each of these questions are summarized below.
4.1 Content

       An initial mockup in matrix format was presented to participants that listed the categories
of information that could be included in the final product (see screen reclamation system mockup
#1 in Appendix C).  Attendees had many suggestions for additional information they would like
to see incorporated into the matrix.   They suggested expanding on the information currently
presented as well as adding new information to the matrix.  In general, they want as much
information as is practical to present in a matrix format.  Additionally, they want the information

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presented  in  descriptive language;  not in technical  terms.    The  participants'  specific
recommendations are presented below.
4.1.1  Product System Names and Chemical Constituents

       A common concern in all four focus groups was that it would be extremely useful if the
trade names were given for the products demonstrated. Without product names, printers felt it
would be difficult to be sure they were purchasing products with the same characteristics as the
products presented in the matrix.   In  addition, printers would have to invest their time in
researching products and contacting suppliers to identify a supplier for the product they wanted
to try. It was mentioned that smaller shops probably would not make this effort. Printers voiced
a general distrust of their suppliers, and felt a supplier could claim to be selling them the requested
alternative product, however, printers had no way of verifying  they were actually getting the
product they had requested.

       There was also concern regarding the reporting of chemical constituents in ranges, instead
of specific percentages. Participants felt this exacerbated the difficulty in obtaining the requested
products from suppliers.

4.1.2  Performance

       Under  the Performance category, participants suggested some changes to the existing
subcategories.  Three of the focus groups recommended that "Quantity" should be reported as
"Quantity per  area of screen cleaned" instead of an absolute volume.  One group suggested the
"Cleaning time"  category should note if the haze  remover required overnight drying time.
Another group indicated that if the product is  recycled or reused, the number of times it is
recycled or reused prior to disposal or addition of fresh product should be listed.

       Several printers suggested  expanding the "Printing limitations" column  to include
information on the incompatibilities and restrictions for product use.   Several  participants
suggested adding a category to include information on the effects of the ink remover on the stencil
and the effects of the haze remover on the screen mesh.

4.1.3  Cost

       In the initial matrix, cost is presented as "$/gallon." Participants felt that this was the best
way to present cost information because they  could easily calculate their own total cost by
combining the volume of product used and cleaning time with their wage rate.   For ease of
comparison, cost should be presented as a standard quantity for all products.  A quantity of "$/5-
gallon  container" was suggested as the standard.  Participants hi Los  Angeles pointed out,
however,  that due to regional differences hi prices, comparisons may not be very accurate.

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 4.1.4  Risk/Hazard

        Risk information was presented in both descriptive and technical terms. All focus groups
 agreed that the descriptive language would be most understandable for the largest number of
 readers. In general, printers' greatest concern was with the human health and safety risks of their
 screen reclamation products.2 Some of their suggestions for additional information on risk include:
              Divide information into short-term risks and long-term risks;
              Report exposure route(s) of concern;
              Document the Personal Protective Equipment requirements and recommendations
              of the manufacturer; and
              Report any other recommended precautions.
4.1.5  Disposal Issues

       Waste disposal was one of the most complicated issues in the focus group discussions.
Participants recognized the difficulty in reporting specific disposal requirements due to variability
among state and local regulations and the site specific nature of what wastes are generated.  This
difficulty was particularly evident in the Los Angeles focus group. Participants there expressed
that information on disposal requirements  would only be useful to them  if it was  specific to
Southern California air quality requirements.  Some of the suggestions they made include:

       •      Clearly state that the disposal information in the matrix applies only to products
              that have not been mixed with other products, chemicals or materials. Disposal
              requirements may change significantly after the product is used and mixed with
              waste ink or other printing materials.
       •      Provide guidance on how to get disposal information. For example, describe what
              lab tests are required prior to  making a decision on disposal methods and  the
              approximate costs of these tests.
       •      List federal reporting requirements associated with the products (e.g., EPCRA).
       •      Do not just note to "...dispose of hi accordance with federal, state and local
              regulations..." as is stated on MSDSs. A local government official pointed out  the
              importance of noting that printers should contact their state and local environmental
              agencies for regulatory information,  since small printers may not be aware of all
              the regulations that may apply to them.
       •      Add a description of the disposal requirements of the strictest state or local
              regulations in the country. Printers felt that since all regions may eventually adopt
  2 Due to strict air quality requirements in Southern California, printers in Los Angeles were somewhat more
concerned with whether or not use of an alternative product would allow them to meet air quality regulations than with
the risks associated with the product.

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             these regulations, printers could use this information to plan ahead for future
             compliance.

4.1.6 Test Conditions

       Test conditions presented in the initial matrix included ink type, emulsion type and ink
color.  Since the variability of conditions  from one screen printer to  another  is so great,
participants stressed the need for more information on test conditions in order to adequately
interpret the performance and risk information presented hi the matrix. It was suggested that the
following test conditions be added:

       •      Screen Mesh (threads per inch) and Tension -- Mesh count and tension level  can
              influence screen reclamation products' performance.
       •      Application Method ~ Due to differences in shop equipment and procedures,
              printers want specific information on the type of equipment (brush, rag, pressure
              wash, etc.) used in the demonstrations.
       •      Ink and Emulsion type - Screen reclamation products will perform differently
              depending on the ink and emulsion used.  Solvent based ink was felt to be too
              broad a category. It would be more appropriate to use specific ink types such as
              acrylic-based lacquer ink.
       •      Temperature, Humidity, Ventilation -  These conditions  are important since
              product performance will vary depending on ambient conditions.
       •      Screen Drying Time - How long a screen has dried prior to reclamation can affect
              the performance and cost of the reclamation products.
       •      Screen History - Factors such as total number of impressions, number of screens
              times screen had been reclaimed previously,  and general screen condition will
              influence performance of the reclamation products.
 4.1.7 Suggestions for Additional Information to be Included in the Final Information
       Product

       Participants identified additional details that they felt should be included somewhere in the
 final information product. Several of their suggestions could be included in the notes column of
 the matrix.  For example, it was recommended that effects of the products on the mesh, product
 incompatibilities, and any printing limitations be listed.  Other product characteristics such as
 VOC content and pH were suggested as separate columns. Finally, many printers asked that a list
 of the names and phone numbers of participating manufacturers should be added as an  appendix
 to the final information product. This list would allow printers to contact a limited number of
 manufacturers (i.e., the participating manufacturers) directly for more  information on their
 product lines.

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4.2    Format

       After reviewing and commenting on the type of information to be included in the final
information product, as presented in the initial matrix, participants were given four additional
format mockups to review.  The initial matrix was presented as an option as well.  Mockup
formats ranged from descriptive text to detailed technical information. Reaction to the level of
detail offered in the mockups was mixed.  Members of the Boston focus group felt that the format
should be as scientific and quantitative as possible.  They, therefore, chose mockup #1 (the initial
matrix - includes very detailed information in technical terms) as the superior choice.  In contrast,
Chicago attendees preferred simplified explanations using descriptive text as in mockup #2
(descriptive, easy to read matrix).  Descriptive text was thought to be more accessible to the
largest audience.  In Seattle and Los Angeles, participants recommended a combination of the
descriptive text in mockup #2 and detailed information presented in mockup #1.  In all cases,
participants felt that an explanatory fact sheet should accompany the mockup.  This fact sheet
would help users interpret the information presented in each category by defining the terms used
in the matrix and describing how the information was obtained.

       One participant proposed that mockup #1 be combined with mockup #5 (a collection of one
page fact sheets on each product). In this format, mockup #1 would serve as a table of contents
that would allow a printer to look through the matrix of information and select the products that
appeared most suitable for his/her operations. For more information, the printer could then turn
directly to the fact sheets on the products of interest.  Other printers agreed that this option would
probably be the most useful format.

       Two suggestions were made to simplify the final information product format.  First, many
participants expressed an interest in seeing products ranked hi a "consumer reports" format where
each  attribute is rated as poor, fair or good.  This ranking would allow for easy comparison
between products.  Second, some participants felt that screen printers do not typically use more
than one type of ink (i.e., solvent, aqueous, UV) in the same facility. As a result, they suggested
that the results be separated into different matrices: one for solvent-based inks, one for aqueous-
based inks and one for UV-based inks.

       While the discussion centered on the mockups, several other formats were presented to
participants for their consideration.  For example, the information generated by the DfE printing
project could be relayed through videotapes, posters, brochures, or on diskette.  Videotapes were
a popular option since printers felt this would be an excellent way to present the information to
all shop employees at the same time. Some printers indicated, however, that they did not have
the tune to preview videotapes and would prefer to receive a hard copy of the information.

4.3    Vehicles

       Focus group participants had numerous ideas for disseminating this information to printers,
including hard to reach printers such as small shops that are not involved in a trade association.

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Li addition, some attendees stressed the importance of receiving the final information product from
several sources at once. Dissemination through multiple sources would serve two purposes. First,
distribution through a variety of sources would increase the number of printers receiving the
information. Second, receiving the information through many channels would help to emphasize
its importance and improve its credibility.

       To distribute the information to as many printers as possible, participants suggested the
following:

       •      Trade Associations —  Make the information available at trade shows and seek the
              endorsement of trade associations.  With endorsement of several trade associations,
              the information would reach a  wider audience and  would also increase it's
              credibility.
       •      Trade  Journals —  It was suggested that articles  announcing their release and
              describing the DfE results should be published in  trade journals such as Screen
              Print Magazine. A tear-out card could be added to the journal that would allow
              printers to mail in  a  request for  a copy  of  the final information product.
              Additionally, the final products could be mailed out with or included in the
              journals. Some participants, however, noted that trade journal articles can appear
              biased.
       •      Suppliers - Since printers receive  a great deal of information from suppliers
              already, suppliers were thought to be a good vehicle for conveying this material.
              Some printers, however, felt that suppliers would not be a credible  source for
              interpreting the DfE information since suppliers may not want to pass on
              information that could be beneficial to their competitors.  Others noted that since
              suppliers are the only source of information for some printers, distribution of this
              material through suppliers may be required.
        •      Direct Mail - Participants felt that direct mailings  of the final products could come
              from a variety of  organizations including:  EPA, state and local government
              agencies (offices of technical assistance), and trade  associations.  It would also be
              useful to stamp mailings as "EPA Official" and to indicate that the information is
              the result of joint research with EPA and "printers just like you."

 4.4    Participants'  Comments on the DfE Performance Demonstrations for Screen Printers

        Throughout the focus groups, participants had many questions and comments regarding
 the performance demonstration methodology. In general, most printers viewed the  demonstrations
 as a good starting point for implementing pollution prevention  concepts in their industry.  They
 expressed concerns, however, in three areas. First, some printers felt the information collected
 during performance demonstrations would not provide them with the type of information they
 need to select between alternative products (i.e., specifications or guidance on product attributes).
 They suggested DfE provide a list of questions for them to ask their suppliers regarding alternative
 products.   Alternatively, a participant recommended that  DfE  provide a list of the chemical

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constituents that printers might want to avoid and a list of those that are acceptable for use.
Second, some printers said they would prefer to see laboratory testing of alternative products
instead of demonstrations in printing facilities.  They felt that through laboratory tests, products
could be evaluated under consistent conditions instead of being subjected to the highly variable
conditions that exist across printing facilities in the U.S.  Under consistent test conditions, printers
thought it would be easier to compare products.   Moreover, in the absence of "hard data"
collected under controlled conditions, it would be  very easy for suppliers to discredit the results.
For example, they could attribute poor performance of their product or their lack of participation
to inconsistent test conditions.  Third, some participants thought the information generated from
the demonstrations would become obsolete quickly.  It is, therefore, important to make the final
information product available to printers as soon as possible. In addition, they noted that without
annual demonstrations, the utility of the information would be limited.
5. Lithographers Focus Groups

       As in the screen printers' focus groups, lithographers were asked a series of questions on
the content, format and vehicles for distributing information products generated by DfE. The most
common comments and concerns raised by participants hi the course of the focus groups are
summarized below.
5.1 Content

       An initial mockup in matrix format was presented to participants that illustrated a number
of categories of information that could be included in the final product (see blanket wash mockup
#1 in Appendix C).  As hi the screen printer focus groups, lithographers had many suggestions
for additional information they would like to see included. Regarding additional information, they
suggested expanding on the information currently presented as well as adding new information to
the matrix.  They would like to see as much information about the performance demonstration
conditions and associated risks/hazards as possible.  The participants specific recommendations
are presented below.
5.1.1  Product names and chemical constituents

       Most participants felt that it was important to include the trade names of the products
demonstrated. Similar to screen printers' concerns, lithographers felt that it would be difficult to
be sure they were purchasing products from their suppliers with the same characteristics as the
products listed in the matrix.  Furthermore, some printers voiced a mistrust of their suppliers.
They felt a supplier could claim to be selling them the requested alternative product, however,
printers had no way of verifying they were actually getting the product or attributes they had
requested. One participant offered a suggestion to avoid such problems. He suggested that a

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"reader service card" be included with the final information product. This would allow printers
to circle a number corresponding to a blanket wash demonstrated and mail it back to EPA. EPA
would then forward the card to the appropriate manufacturer so the manufacturer could contact
the printer with more information on the product.

       There was also a request that as much information as possible be provided on the chemical
content of the products.  Without trade names, requesting particular chemical compositions is the
only way that printers can communicate to their suppliers the types of products they would like
to try. One focus group preferred to see the chemical constituents given as an upper limit instead
of as a range (e.g., "Product A contains < 10% Chemical 1" instead of "Product A contains 5 % -
15%  Chemical 1"). Because suppliers may use different synonyms for the same chemical,
Chemical Abstract Service (CAS) numbers should be included. Information on the non-hazardous
but active components of the products would be helpful as well.
5.1.2  Performance

       In the initial matrix, performance of the alternative blanket wash refers to, its: ability to cut
ink, the quantity of the product required to clean the blanket, the time required to clean the
blanket, and the ease with which the product dries.  Focus group participants suggested revisions
to existing columns of information hi the matrix and proposed that supplementary columns be
added. Specifically, it was suggested that quantity of blanket wash required should be reported in
comparison to the quantity of the baseline product used hi order to reduce the subjectivity of the
measurement.  To obtain a more accurate estimate of the total tune requirements associated with
the alternative product, the time required to clean the blanket should be expanded to include the
time and number of cleanings needed to get the press back up to color when changing from a dark
color to a light color. In addition, the "ease of drying" category should be changed to "speed of
drying." Information on the side effects of the blanket wash on the blanket (e.g.,  swelling and
glazing) is another component of the product's performance that printers requested be included
in the matrix.

       Several printers suggested adding three more columns under the Performance category;
product odor,  ease of use, and necessity of a drying step (e.g., additional rag wiping). Product
odor would indicate whether or not the alternative blanket wash had an unpleasant odor. Printers
reported that some press operators would refuse to use a product with a particularly unpleasant
odor.   "Ease of use" would report information such as whether or not the blanket wash was
slippery or greasy, whether or not there was any drag  on the blanket when using the alternative,
and the physical effort required to clean the blanket.  The "drying step" column would indicate
whether or not a product had to be dried off the blanket with wipes.
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5.1.3  Cost

       In the initial  matrix, the cost of using an alternative blanket wash is presented as
"$/gallon."  Participants felt that this was the most appropriate way to present product costs
because it would easily allow them to calculate their own total cost by combining the volume of
the product used and cleaning tune with their wage rate.

5.1.4  Risk/Hazard and Federal Regulations

       Risk/hazard information was presented in the  matrix in both technical and descriptive
terms. Most participants agreed that this information should be presented in the most descriptive
terms possible. It was also suggested that the risk/hazard and federal regulations columns might
be more useful if they were renamed "health and safety" and "environmental burden" respectively.
The health and safety column could include the permissible exposure limit (PEL), the hazardous
materials information system  (HMIS) codes for the health  risks of  each chemical, and
recommendations for personal protective equipment.  One printer pointed out that when selecting
products he reviews the risk/hazard information on products' MSDS first.  He  felt, and other
participants agreed, that it would be very important to include this information in the DfE final
product.

       In the environmental burden column,  information could be presented on both waste
disposal requirements and other regulatory issues such as reporting and permitting requirements.
Regarding waste disposal, participants would like to have information about their state and local
requirements. They suggested a cooperative effort between state and local agencies that would
provide regulatory information about the alternative blanket washes listed in the matrix to local
printers.  At a minimum, a warning indicating that state and local requirements may be more
stringent than federal requirements should be included.  Phone numbers  of state and local
regulatory contacts should also be provided. The Los Angeles group felt very strongly that it was
more important to list the local regulations than the federal regulations, for their situation. These
printers feel that if they are in compliance with the strict emissions limits set by the Southern
California Air Quality  Management District, they will also be meeting the federal requirements.

       Regardless of the information given on  local regulations, federal regulatory information
affecting the product should be listed. Information such as whether the chemical is a TRI chemical
or a hazardous air pollutant (HAP) under the Clean Air Act was thought to be particularly useful
for printers in determining whether, when eliminating a problem in one medium, they will create
a problem in other media.  Participants in Los Angeles thought it would be a good idea to include
information on the strictest  regulations in the country for each medium on the final information
product.
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5.1.5  Chemical Characteristics

       The chemical characteristics of alternative blanket washes such as VOC content, vapor
pressure,  and flash point are presented in the initial matrix.  Participants' comments on this
information were limited to requesting that the vapor pressure column be replaced by a column
on evaporation rate and that the matrix contain more specific information on VOC content (i.e.
reporting actual VOC content instead of giving a range). VOC content should also be reported
in "pounds/gallon" and "grams/liter" instead of as a percent of total volume.


5.1.6  Suggestions for Additional Information to be Included in the  Final Information
       Product

       Participants proposed additional details that they felt should be included somewhere in the
final information product.   Several participants commented that the conditions under which the
demonstrations were performed would affect the results.  As such, they felt that to accurately
interpret the matrix they would need as much information as possible on demonstration conditions.
They, therefore, suggested that a separate column be added on test conditions.  This column could
present information on: ink coverage, press manufacturer and model, age of press, length of run,
blanket condition, and dampening system.  Finally, a list of the names and phone numbers of
participating manufacturers should be added as an appendix to the final information product. This
list would allow printers to contact a limited number of manufacturers (i.e.,  the participating
manufacturers) directly for  more information on their product lines.
5.2    Format

       After reviewing and commenting on the type of information to be included in the final
information product, as presented in the initial matrix, participants were given four additional
format mockups to review.  The initial matrix was presented as an option as well.  Mockup
formats ranged from descriptive text to detailed technical information.  Similar to the screen
printers focus group, reaction to the level of detail offered hi the mockups was mixed.  It was
pointed out that just as there are significant variations from one printing  facility to another, the
target audience for the DfE results will also be disparate. As a result, many participants suggested
that there should be more than one final product.  In Boston, Portland, and Los Angeles, the
preferred format was  a version  of mockup  #1 (the initial matrix - includes very detailed
information in technical terms), with some variations.  Boston attendees preferred mockup #1 for
their own use, but felt that it would be too detailed for printers at quick print shops and other
small operations, and suggested that mockup #3 (a descriptive, easy to read table) would be better
for less informed printers.  Los Angeles participants wanted to include the one page fact sheets
on each product (as hi mockup #5) as supplemental information to mockup #1. In  Chicago,
printers felt that mockup #2 (descriptive, easy to  read matrix) would be  the best format for the
press  operators since they are typically most interested  in health and  safety hazards.  They

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preferred a more detailed mockup such as mockup #1, however, for themselves (management or
supervisors, as opposed to operators).  All of the focus groups agreed that, whatever the format,
an explanatory factsheet should always be included.  This fact sheet would help all users interpret
the information presented in each category by defining the terms used in the matrix and explaining
how the information was obtained.

       To make cross-product comparisons easier, participants in Boston and Chicago proposed
ordering the products by VOC  content, listed in ascending order.  In Portland,  one printer
suggested that the DfB information would be more accessible if it were on disk in a spreadsheet
format.  This format would allow management to reformat and tailor the information to their
facility's needs.

       Whatever format is used for the final information product, participants thought it was
important to make it eye catching and of high quality.  For example, they particularly liked the
DfE printing industry case study.

       While the discussion concentrated on the formats presented in the mockups, several other
formats were presented to attendees for their consideration.  As was suggested to screen printers,
the information coming out of the DfE project could be relayed via videotape, brochures, and
posters. The most popular alternative format was a poster.  Participants liked the idea of putting
the final information  product on a poster  so  that they could review all the products at once,
without turning pages.  The poster would be enhanced by providing a supplemental booklet of fact
sheets (one for each alternative blanket wash).  The booklet would allow users to locate detailed
information for any alternative blanket wash they  were interested in.

       Reaction to videotape was mixed.   Some printers  felt that a video would be a useful
addition to the printed material and would make it easier to educate many of their workers at the
same time. In contrast, others felt that they would never take the time in a business day to look
at the tape.   In Portland, a fold-out brochure was proposed that would consist of a slightly
enlarged version of the final information product.

5.3    Vehicles

       Focus group participants  had  numerous ideas for disseminating the DfE information to
printers, including hard to reach printers such as small shops that may not be involved in a trade
association.  Among the most commonly heard recommendations was enlisting the support of
trade associations and suppliers.  Specific ideas include:

       •      Disseminate the information through trade association presentations, conferences,
              and trade journals.  Articles and announcements in trade journals would be useful
              in notifying printers that the information  was coming.   The final information
             product itself could also be published in trade publications.
                                          15

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             Provide the final information product to suppliers for distribution.  Participants
             explained that printers rely on their suppliers to inform them of new developments
             in the industry.

             Conduct a general mailing of the DfE final information product to printers.  If
             possible, the mailing should be addressed to the production manager, purchasing
             agent, and/or the pressman.  The mailing should also be labeled with an "EPA
             official stamp."  This label would tend to make the piece stand out from all the
             other mail printers receive each day.  This approach might be the only way to
             reach small printers that do not belong to a trade association.

             Contact franchise headquarters.  Franchise headquarters could  pass on the
             information to their franchises in newsletters or separate mailings.

             Have state and local environmental regulatory staff, especially technical assistance
             program personnel, publicize the final product in their outreach efforts such as
             bringing the final information product to print shops during their visits.
5.4    Participants' Comments on the DfE Performance Demonstrations for Lithographers

       Each focus group voiced a unique set of questions and concerns about the performance
demonstration methodology. In general, however, printers reacted positively to the DfE printing
project and felt that it would serve as a good first step in encouraging printers to implement
pollution prevention concepts in their shops.  In Boston, concern centered on the details of how
the demonstrations would be performed. For example, participants felt that it was important to
consider the characteristics of the rags used in performance demonstrations.  Because the age and
type of rag can greatly affect the volume of blanket wash used, variations in rags used during the
demonstrations could skew the results.  It  was suggested, therefore, that new  rags be used
consistently during the demonstrations, otherwise the volume of blanket wash used might vary for
reasons other that differences in the alternative products.  Concern was also voiced about the
variability among pressmen applying the blanket wash.  Due to variations in quantities used by
different pressmen, participants felt that it was important for the same person to use the product
for the duration of the demonstration.

       In Chicago, printers using automatic blanket washers pointed out that they are limited to
the blanket washes recommended by their equipment supplier.  As such, the DfE information may
be of limited usefulness to them,  particularly if the alternative  products  included in the
performance demonstrations have not yet been tested for compatibility by automatic blanket
washer suppliers.

       Focus group attendees in Portland had more general concerns about  the performance
demonstrations. They felt that the demonstrations would be much more useful (i.e., credible and

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less subjective) if conducted in a controlled setting.  They felt there was too much variability from
one print shop to another to make meaningful comparisons among alternative products.  They
added, however, that it would be best to confirm the results of a laboratory test with in-field
product demonstrations.  One suggestion was to conduct such in-field tests on a multi-unit press
where the baseline product and alternative product are used on the same press at the same time.
This group also expressed concern over the number of alternative products to be demonstrated.
They felt that data on 30 - 35 products would be too much information to digest.  It was suggested
that  products either be grouped by similar chemical formulations  or limited to less than 10
alternative products in total.

       Los Angeles participants also suggested some changes to the demonstration methodology.
First, they would like to  see the in-field demonstrations limited to printers who have similar
operations, such as only 24"  sheet-fed presses, to provide more consistent results. Second, they
suggested the scope of the in-field demonstrations should be expanded to record information on
the ability of the product to remove ink from rollers and printing tools (where ink may be thicker)
in addition to it's performance in cleaning the blanket. Their last recommendation was to include
a run where the press is changed from a dark color to a light color and a run from a light to a dark
color. This will give an indication of the additional time, effort, and quantity of product needed
to come up to color hi two distinct scenarios.
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                   APPENDIX A
Screen Printer and Lithographer Focus Group Summaries
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                            Lithography DfE Focus Group
                                     Natick, MA
                                   October 21,1993
                                   4:00 - 5:30 p.m.

1. Logistics
           The focus group was held at the Printing Industries of New England (PINE) office
           in Natick, MA as part of their Environmental Committee meeting. There were 10
           people there including 5 printers, 3 consultants, and 2 PINE environmental staff
           members.  Being members of a  trade association. Environmental Committee, the
           attendees were probably more knowledgeable about environmental issues in the
           printing industry than the average printer.

2. Reaction to DfE
           After a brief introduction to the DfE Printing Project, there were several comments
           and questions centered around the issue of masking the product names in the results.
           From  the discussions at the start of the meeting, participants seemed to feel the
           information would be useless without the product names because they wouldn't know
           how to get the same products from suppliers. However, by the end of the meeting,
           there was a change in attitude and it appeared that everyone was enthusiastic about
           receiving the results and they felt that the information would be very useful, even
           without the supplier names.
3. Content
           There were several parameters that were not included in the matrix that would be
           useful. These were:
             - Effort required to clean the blanket (this is a function of the lubricity of the
             product).
             - Physical characteristics of the product including the odor and the "feel" (i.e., is
             it oily).
             - CAS#. Different suppliers use different synonyms for the same chemical, making
             it difficult to identify a chemical if the CAS # is not included.

           The "Risk/Hazard" category would be more useful if it was divided into two
           categories:  "Health   and  Safety  Risk"  and  "Environmental  Burden".  The
           "Environmental Burden" category could tie into waste disposal and regulatory issues,
           such as reporting, disposal and permitting requirements.

           A list of participating suppliers  should be included as part of the final information
           product with the company name, phone number and  a contact name for  all
           participating suppliers.
                                         A-3

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4. Format
            Group the products in the matrix by VOC content, listed in ascending order.

            Just as there are great variations from one printing facility to another, the target
            audience for the DfE results will also be disparate. Printers suggested there should
            be more than one final product. The people attending this focus group preferred
            Mock Up #1;  the most detailed format. However,  when they thought about the
            people in quick print shops and other small operations, they felt that Mock up #1
            would be too detailed. Mock up #3 was suggested as a product for less informed
            printers.

            A Fact Sheet explaining the matrix should always be included with each of the matrix
            formats.

            They liked the idea of putting the matrix on a poster so they could glance over all the
            products at once, without turning pages.

5. Vehicles
            Trade publications, trade associations, industry conferences and ECB were suggested
            as vehicles for distributing this information.

            It  was  also suggested that  federal,  state and  trade  association  environmental
            regulatory staff,  especially technical assistance program personnel, bring  this
            information to the facilities.

            Another suggestion was to send a general mailing. For a mailing, labelling it with
            some sort of "EPA Official" header would tend to  make the piece stand out from all
            the other mail they get in a day.

            Many small printers do not belong to a trade organization. They can be reached
            through a general mailing.  Franchise  operations can be  reached through  their
            corporate headquarters. The corporate  offices often publish newsletters or send
            mailings out to their franchises and they also make recommendations about the types
            of supplies their franchises use.

6. Other issues related to DfE
Testing Protocol
            Consider the rags used in performance testing. The age and type of rag could greatly
            affect the volume of cleaning solution used and therefore skew the test results. It was
            suggested that new rags always be used for the test, otherwise the volume of cleaning
            solution used could be extremely inconsistent.

            Some printers expressed concerns regarding the long term effects of the alternative

                                           A-4

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Other
            blanket wash solution on the blanket and rollers. These effects would not surface in
            a one week test.

            The same person should be testing the product all week. There are great variations
            in volume from one operator to the next.

            The  atmospheric  conditions  (including temperature  and  ventilation)  and the
            equipment (press, rollers, blanket, ink) used in testing should be recorded as part  of
            the testing.
           Printers are suspicious of the information they get from suppliers. They feel they can
           not trust the information on the MSDS. Also, the suppliers' literature they get does
           not provide much information on alternative products besides the VOC content.
                                          A-5

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                           Screen Printing DfE Focus Group
                                   Cambridge, MA
                                  November 16,1993
                                   8:30 - 10:30 a.m.
1. Logistics
           The focus group was held at Abt Associates offices in Cambridge MA. Six people
           attended including 5 printers and 1 distributor.

2. Reaction to DfE
           The participants were concerned that without the product names, the results would
           be difficult to use. They voiced their preference for naming the products and
           manufacturers,  but, unlike the lithography focus group, there was not much
           discussion on this topic.

           They also preferred to see the products ranked somehow and suggested a
           "Consumer Reports" format.
3. Content
           The group suggested several characteristics that should be added to the final
           information product. In general, they wanted to get as much information as
           possible in the greatest detail possible. They recommended the following additions
           and changes:
           • Include information on the Side Effects of the products on the mesh (e.g.,
           corrosive damage).
           • Report "Quantity" as quantity per area of screen cleaned.
           • In the "Reclamation time" category, note if the haze remover required
           overnight drying time or not.
           • For "Risk", include detailed, descriptive information. It was suggested that risk
           information be divided into "Short Term Risks" and "Long Term Risks". Also,
           they would like information on the exposure route of concern and recommended
           personal protection equipment.
           • Regarding "Disposal Issues", they do not want anything that says "...dispose in
           accordance with federal, state and local regulations," similar to many MSDSs.
           One printer suggested adding a description of the disposal method required to
           comply with the strictest local regulations in the country (usually California).  He
           felt that eventually all areas would have to comply with such strict requirements
           and he would like to plan ahead for regulatory changes.

           They felt that it was important to have an objective evaluation of the disposal
           requirements for the product. Most printers felt they could not trust the
           information on the MSDS. One printer commented that there was a crowd of
           "snake oil" salesmen at the New Orleans conference, making such questionable
           environmental claims that one would expect a "baby Jesus in every gallon" of the
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4. Format
           product that will change it into water.
           • Since the variability of operations from one screen printer to another is so great,
           they want as much information as possible on the "Test Conditions." Such factors
           as temperature, humidity, ventilation and screen drying time are critical.
           • Add information on the "Application Method" used in testing and list
           alternative application methods since printing facilities have all different kinds of
           equipment.
           In general, they want as much information as possible to collect. The more
           scientific and quantitative, the better.  One participant suggested that the matrix
           (mockup #1) be provided along with a fact sheet (similar to mockup #5) on each
           product. The matrix would serve as a  table of contents, where a printer could
           look through the list and screen the products down to the few that looked most
           suitable for his operation. Then, he would read the fact sheets (or a case study
           format was also suggested) that give detailed information on just those products
           that interested him. Those fact sheets would need to include much more
           information regarding the test conditions. The other participants agreed that this
           suggestion would probably be the most useful format.

           This group of printers said that no screen printer uses both solvent-based inks and
           UV-based inks in the same facility. They suggested breaking the results into
           different matrices: one for  solvent-based inks, one for UV-based inks and one for
           aqueous-based inks.

5. Vehicles
           To distribute this information to as many screen printers as possible, they
           suggested:
            • Send out a direct mailing. Place announcements in the trade publications' "In
           the News" column that this information will be coming in a mailing. That is,
           advertise the mailing before sending it.
            • Enlist the four major trade publications to send  out the final information product
           with a copy of the magazine (or a tear-out card to mail back for the report).
            • Some printers may only get information through their suppliers. Printers who
           are more concerned with issues of worker health and safety and environmental
           effects, do not trust the information coming from  suppliers. These printers, will
           get this information from a trade publication or from a direct mailing. However,
           the printers who are less concerned with risk issues, only get their information
           from their suppliers and this route should definately be used.

6. Testing Protocol
           Participants expressed several concerns with the Testing Protocol. They wanted
           these comments passed on  to EPA in  hopes of influencing  the final Testing
            Protocol. These comments are summarized in a separate memo.
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                           Screen Printing DfE Focus Group
                                     Chicago, IL
                                  December 6,1993
                                   8:30 - 10:30 a.m.
1. Logistics
           The focus group was held at the Holiday Inn at O'Hare airport in Chicago. Eleven
           people attended including 6 printers, 1 consultant, 1 equipment manufacturer, 3
           product suppliers/manufacturers.

2. Reaction to DfE
           The participants, mainly the suppliers, felt that it would be difficult to provide
           enough information about the performance demonstrations to make the results
           useful. They noted that there are so many  variables involved in testing that it
           would be hard to include them all in the final information product.

           Printers felt that the final information coming out of DfE would be limited in it's
           usefulness in selecting an alternative product. The lack of product names and the
           variability between printing shops were the primary limitations. However, they
           did feel that it would help them to determine what kinds of information and
           questions they should get from their suppliers.

           Some participants were concerned that by  the tune this information is published, it
           will be obsolete as new products come to market.
3. Content
           The group suggested several characteristics that should be added to the final
           information product. They recommended:
           • Add information on the "Application Method" used in testing. How is the
           product applied? What procedures and equipment were used in applying the
           product during the demonstration.
           • Report "Quantity" as quantity per area of screen cleaned.
           • For "Risk", include detailed, descriptive information. They also requested
           specific information on what Personal Protective Equipment was required and any
           other recommended precautions.
           • Report "Cost" in terms of a standard quantity. They suggested $/5 gallon
           container as a standard.
           • Regarding "Disposal Issues", they wanted information on both regulatory issues
           and on exactly how to dispose of the product. Since it may be difficult to provide
           detailed disposal information (because of local variations in regulations and
           because the product will most likely be mixed with ink and other chemicals when
           disposing it), one participant suggested providing information on how to go about
           getting the disposal information. For example, describe what lab tests are required
           prior to disposal and the price you can expect to pay for the testing. They also
                                         A-9

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4. Format
           wanted to know the federal reporting requirements associated with the product.
           • Since the variability of operations from one screen printer to another is so great,
           they want as much information as possible on the "Test Conditions."  Such factors
           as temperature, screen drying time,  more information on ink type, the resin
           system, the history of the screen, screen mesh and screen tension are critical.
           •  Add a column that lists the incompatibilities and restrictions for product use.
           •  The equipment supplier recommended that the term "System" be replaced with
           "Test" or "Product". He felt that "System" suggested that the cleaning process
           depended only on the chemicals you use without regard for how they are applied.
           Printers felt, and suppliers agreed, that the information should be in the most
           simple terms possible. They mentioned that the information must be in a format
           that the average printer can quickly understand. Within the discussion of "simple
           formats", there were two different suggestions: Several printers suggested very
           simple, basic information on the performance and risks of the product be
           provided. Mock Up #2, with a fact sheet, was proposed as an appropriate format
           for providing this simple information. Alternatively, other participants proposed
           the final information product should be a list of questions/information that printers
           should ask of their suppliers. Such a proposal eliminates the need for performance
           demonstrations. The reasoning was that it would be impossible to get all the
           information needed to evaluate the products, so instead give printers guidance or a
           "grocery list" of the information they should be receiving from suppliers on
           alternative products.  Other printers at the focus group disagreed with this proposal
           and noted that the performance information is needed.
5. Vehicles
            Participants like the idea of supplying this information on videotape because they
            could present the information to several people in the shop at the same time. The
            suppliers mentioned that "nobody reads anymore". They said the majority of
            questions they receive by phone are already answered in their printed material, but
            no one reads it.

            To distribute this information to as many screen printers as possible:
            • Distribution through SPAI, trade publications (but don't allow them to edit it)
            and  suppliers. They said that it would be most credible if the got the same
            information from several of these sources.
            • One participant recommended that printers would find the information most
            credible if it indicated that it was a result of discussions from industry focus
            groups, of "printers just like you".
                                          A-10

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6. Testing Protocol
           Suppliers expressed several concerns with the Testing Protocol. The focus of their
           comments was that they did not want to give away their chemical formulations.
           After spending a lot of money on research, they would not allow their
           formulations to be published so that someone else could go mix the same product.
                                        A-ll

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                             Lithography DfE Focus Group
                                      Chicago, IL
                                   December 7, 1993,
                                   8:30 -10:00 a.m.
1. Logistics
            The focus group was held at the Abt Associates office in Chicago. Ten people
            attended including 8 printers, 1 PIA affiliate representative, 1 equipment
            manufacturer.

2. Reaction to DfE
            The group felt that the information coming out of the project would be useful, but
            limited because product names were not given. They would like to see a list with
            the name of the manufacturers who participated in the performance demonstration,
            including a contact name and phone number for each participating company.

            Some participants were concerned that this information could become obsolete
            quickly as new products come to market. One printer suggested that a
            performance demonstration occur annually.
3. Content
           The group suggested several characteristics that should be added to the final
           information product. They recommended:
           • In the "Performance" category, add a column for "Odor", "Lubricity" (a.k.a.,
           "rag drag"), and whether or not a drying step was required.
           • Supply as much information as possible on "Chemical Content". Chemical
           composition is the only means the printer has available to communicate to their
           suppliers the products they would like to try. Include information on the non-
           hazardous components of the product also.
           • Report "Quantity" as compared to the baseline product quantity to reduce
           subjectivity.
           • Record how long it takes to get the press back up to  color.
           • Note if a residue of the previous job is still on the blanket after the wash.
           • For "Risk", include descriptive information. They mentioned that eye and skin
           effects were very important.
           • Report "Cost" in terms of $/gallon.
           • Regarding the "Disposal Issues" category, they want information on both
           disposal and regulatory issues. The printers were interested in a list of the
           applicable federal regulations for the product, and they also recommended
           including a warning saying local regulations may be more stringent than the
           federal regulations. They requested that phone numbers of state level regulatory
           contacts be provided.
           • Be more specific about the VOC content. Report the percent VOC content (not
           the range) and also report in "pounds/gallon".
                                         A-13

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4. Format
           Printers felt that Mock Up #2 would be the best format for the press operators
           since they are typically most interested in the health and safety hazards. They
           preferred Mock Up #3 for themselves (management or supervisors, as opposed to
           operators). Although Mock Ups #2 and #3 contain the same information, the
           presentation is different and it may have appeared to the participants that Mock
           Up #3 contains more numerical information. They felt a "Fact Sheet" explaining
           the columns of the matrix would be helpful with any of the formats.

           Some printers felt a video would be useful in addition to the printed material.
           Others felt they would never take the time to view a tape.

           They agreed the products should be sorted by VOC content.

5. Vehicles
           To get this information to as many printers as possible, they suggested:
            • Mail it to printers with an "EPA OFFICIAL"  stamp on it. They would not
           ignore a mailing with "EPA" on it.
            • Provide this information to the suppliers for distribution. They use their
            suppliers as consultants and they trust suppliers to inform them of what's coming
            down the pike.
            • Publish the information in as many trade publications as possible.

6. Other Comments
            Printers using automatic blanket washers mentioned that they had to use blanket
            washes that were on the  equipment suppliers recommended blanket wash list; they
            would only consider washes that are on this approved list.

            The equipment supplier noted that their automatic blanket washer used
            significantly less blanket wash solution when they switched from high VOC to the
            low VOC blanket washes. This observation contradicted what other printers have
            said about switching to low VOC solutions in manual applications where
            significantly more wash  is reportedly required.
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                            Screen Printing DfE Focus Group
                                      Seattle, WA
                                   January 19, 1994,
                                    8:30 - 10:30 a.m.

1. Logistics
            The focus group was held at the offices of Metro Hazardous Waste Management in
            Seattle. Twenty-three people  attended, including 7 printers, 3 printing supply
            manufacturers, 2 printing suppliers, 10 representatives from local and state technical
            assistance groups and the county health department, and 1 consultant.

2. Reaction to DfE
            • The printers and suppliers felt the information would be much more useful if trade
            names were provided. One participant felt the information would be useless without
            trade names of products.  Others were concerned that they would have to do a lot of
            work (i.e., contacting suppliers, researching products) to identify the manufacturer
            of the product they wanted to try. They felt that smaller shops might not make this
            effort.  Participants were all concerned that if they had to request a formulation from
            their suppliers, the supplier may not give them what they had asked for.  Printers felt
            that suppliers would try to claim that the product that looked the best was theirs.
            •By the end of the meeting, participants agreed that while DfE does not address all
            their concerns, it is a good staring point for the industry.
            • Also, a representative from the state Department of Ecology mentioned that state
            agencies may be able to help address printers' concern regarding trade names. The
            state may be able to assist printers by providing more information that could help to
            identify manufacturers.  Also, the state may be able to provide additional information
            on disposal requirements tailored to state regulations.
3. Content
            The group suggested several additions to the information in the matrix.   They
            recommended:
            • Add a column for VOC content.
            • Include the pH of the product, where applicable.
            • The disposal procedures on this document refer only to the disposal of screen
            reclamation  products before use.    Add  a disclaimer noting  that  once the
            demonstration products are combined with ink or other printing products, the disposal
            procedures may vary.
            • Add "screen mesh" under Test Conditions.
            • Be more specific on the "ink type" and "emulsion type." For example, list "acrylic
            based lacquers" instead of just "solvent based" inks.
            • For Risk, include detailed descriptive information.
            • Add information on the application procedure(s) used for each alternative system
            demonstrated.
                                         A-15

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4. Format
• The local technical assistance representative suggested that a note to say "state and
local regulations may be more stringent. Check with your state and local offices
before disposal."
• They want to see Cost reported as $/gallon.
• One supplier felt that the type of information printers need is a list of the chemical
constituents to avoid in products and a list of those that are acceptable for use.
•  All participants agreed that  it would be very helpful to include  a list of the
manufacturers who participated, including a contact name and phone number.


• Most participants agreed that a combination of mockup #1  and #2  would be the
most useful.  They liked the descriptive text of mockup #2, combined  with the
detailed information and tabular format of mockup #1.
• All participants felt that a fact sheet describing the columns of the matrix would be
helpful.
• One printer mentioned he would like to see products ranked in a Consumer Reports
format.
5. Vehicles
            • They liked the idea of a videotape so they could show it to all their employees at
            once. One printer suggested that footage of a printer reclaiming a screen would be
            a useful part of the videotape.
            •  To  distribute the information to as many  screen printers as  possible, they
            suggested:
                 —  Distribution through SPAI trade shows.
                 —  They noted that it would be less credible if published in trade journals,
                     which sometimes appear biased.
                 —  Direct distribution from EPA with trade association endorsements.  The
                     best way would be with endorsements from several trade associations.
                 —  To reach printers that don't belong to a trade association, it may be best to
                     have states do direct mailings.
                 —  Most printers agreed that they would not view this information as credible
                     if it came only from their suppliers.

 6. Demonstration Protocol
             • Some of the printers would prefer to see the performance of alternative products
             evaluated under consistent, comparable, laboratory test conditions. The current
             methodology of demonstrations at a variety of printing facilities will not allow them
             to compare results.
             • Another printer disagreed with laboratory testing because he felt that it would turn
             into a product "approval" procedure.  Such a procedure would not allow emerging
             technologies to enter the market easily.
                                           A-16


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                            Lithography DfE Focus Group
                                    Portland, OR
                                  January 20,1994
                                   2:00 - 4:00 p.m.
1. Logistics
           The focus group was held at the Pacific Printing and Imaging Association (PPIA)
           office in Portland, Oregon. Twelve people attended: 5 printers, 2 trade association
           representatives, 3 state agency officials, 1 supplier, and 1 consultant.

2. Reaction to DfE
           The group's reaction to  the DfE project centered mainly on the demonstration
           methodology. These comments are summarized in Section 6. Unlike the previous
           two focus groups, discussions regarding the omission of product trade names was
           minimal.
3. Content
             The group suggested the following changes to the final information product:
           • Under the Performance category a column should be added for "Odor."
           • An additional column should be added to the Performance category for "Ease of
           Use." This column would report information such as whether or not the blanket
           wash was slippery or greasy, and whether or not there was any drag when using the
           alternative blanket wash.
           • It was suggested that "Ease of Drying" be changed to "Speed of Drying."
           • Report Cost in terms of $/gallon.
           • Include Hazardous Materials Information System (HMIS) codes for health risks of
           each chemical.
           • Risk information should be presented in descriptive terms.
           • Participants would like to see personal protective equipment recommendations
           included in the matrix.
           • Participants would hike information presented on specific human health and safety
           concerns. They would also like information specific to environmental concerns,
           including: waste disposal, federal regulations, and environmental burden.
           • Include the PEL for each chemical hi the human health and safety column.
           • Regarding disposal issues, participants would like to have information about their
           state and local requirements. They suggested a cooperative effort with state and local
           agencies that would provide regulatory information tailored to local printers.
           • Eliminate "Vapor pressure" column, but add  "Evaporation rate."
           • Participants would also like to have detailed information on test conditions such as:
           ink coverage, press manufacturer and model, age of press, length of run, blanket
           condition, dampening system.
                                        A-17

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4. Format
            Mock-up #1 was the preferred format for presenting the DfE information. There was
            also interest in mock-up #3. They felt that the fact sheets explaining the columns of
            the matrix would be useful with any of the formats.  It was also suggested that a
            spreadsheet  on disk would be very useful.  A spreadsheet format would allow
            management to reformat and tailor the information to their facility's needs. Other
            suggestions included: a poster and a fold-out brochure.  All participants agreed that
            several formats would ultimately be necessary.

5. Vehicles
            To get this information to as many printers as possible, they suggested:
            • Direct mailing to printers.  If possible, address to production manager, purchasing
            agents,  and/or pressman.  Labeling it with the official EPA logo would get their
            attention.
            •  Disseminate the information through trade association presentations and  trade
            journals. Articles and announcements in trade journals would be useful in notifying
            printers that the information was coming.
            • Provide information to suppliers for distribution.
            • It was also suggested that state and local environmental agency staff, especially
            technical assistance program personnel, bring this information to the facilities during
            their visits.

6. Testing Protocol Issues
            Participants had several comments about the testing protocol.  These comments are
            as follows:
            •  There was general  agreement that performance demonstrations would be much
            more useful (i.e., credible and less subjective) if conducted in a controlled setting.
            They felt there was too much variability from one print shop to another to make any
            comparisons among products. They added, however, that it would be best to confirm
            the results of a laboratory test with in-field product demonstrations. One suggestion
            was to conduct such in-field tests on a multi-unit press where the baseline product
            and alternative product are used on the same press at the same time.
            •  Concern  was  expressed  over  the  number  of alternative products  to be
            demonstrated. They felt that it would be too much information to digest. It was
            suggested that products either be grouped by similar chemical formulations or limited
            to less than  10 total.
                                           A-18

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 1. Logistics
                             Lithography DfE Focus Group
                                    Los Angeles, CA
                                     April 21,  1994
                                    9:00 - 11:00 am
              The focus  group was  held at the Printing Industries of America - Southern
              California office hi Los Angeles.  Eight people attended including 6 printers and
              2 trade association representatives.
2. Reaction to DfE
              The group expressed concern that product names would not be supplied. Without
              product names, printers felt it would be difficult to be sure they were purchasing
              products with the same characteristics as the products presented in the matrix.  In
              addition,  ranges of  chemical constituents  were thought to be  a problem.
              Specifically, they were concerned that products requested might not be the same
              formulation as products included hi the demonstrations. Furthermore, printers
              would have to invest their time in researching products and contacting suppliers to
              identify a supplier for the product they wanted to try. One participant suggested,
              however,  that it might be useful to include a "reader service card" with the final
              information product that would allow printers to circle a number corresponding to
              a blanket wash and mail it back to EPA.  EPA would then forward the card to the
              appropriate manufacturer.  The manufacturer could then contact the printer with
              more information on the product.
3. Content
             This group's primary concern was whether or not the product would comply with
             local air regulations. With the strict air regulations in Southern California, they felt
             that if they used products that were in compliance, their environmental and worker
             health risks would be low. The group  suggested several  changes to the final
             information product. They recommend:
             •In the Chemical Constituents column, report percentages as "percent less than",
             rather than in a range. Use 5 percent increments for reporting.  For example, the
             product contains: Chemical 1  at  < 5 percent, Chemical  2  at  < 40 percent,
             Chemical 3 at  < 45 percent.
             •  In the Performance category,  add a column indicating the effect of the
             alternative product on the blanket. For example, did the product glaze the blanket
             or cause swelling?
             •Also in the Performance category, indicate how many cleanings were required
             to bring the press back up to color, and how many shop towels were required to
             clean the blanket.
             •In the Cost category, report cost in terms of a standard quantity. They suggested
             reporting it in 2 quantities - $/5 gallon container and $/55 gallon drum.
                                         A-19

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4. Format
• For Risk,  include personal protective equipment recommended for use with
product by California OSHA.
• Regarding Federal Regulations, add an indication of whether the product is
subject to reporting requirements such as SARA 311, 312, and 313.
• This group felt very strongly that it was important to list the local regulations
that apply to the product. They are most concerned with the emission limits set by
the Southern California Air Quality Management District.  As was suggested in
other focus groups, they thought it would be a good idea to include information on
the strictest regulations in the country for each medium on the final information
product.
•For Chemical Characteristics, printers agreed that it would be useful to present
VOC content as Ibs/gallon and grams/liter instead of as a percent of total volume.
In addition, vapor pressure should be listed as partial vapor pressure rather than
total vapor pressure.
• Add a Test Conditions category to the matrix. This category  should include
information on ambient air temperature, ambient humidity, type of press, size of
press,  type of ink, and the type of blanket and roller, and the length of the run.


Initially, reaction was mixed to the various formats discussed in the focus group.
Some printers felt that it was important to provide information in the  most
descriptive terms possible. Others felt that numeric information would be more
useful to them.  After some discussion, however,  all agreed that mockup  #1
accompanied by a fact sheet on each product was the preferred format. One printer
commented that a "chart-like"  format would make products easier to compare.
Whatever format is used for  the final information product, it should be eye
catching and of high quality.  For example, they particularly liked the DfE printing
industry  case study.   Other formats discussed but not well received included;
posters, brochures,  and  videotapes.   One participant recommended using an
electronic format for the final information product such as CD ROM.  The rest of
the group felt that an electronic format is not readily portable and accessible and
would be of limited use.
5. Vehicle
              To distribute this information to as many lithographers as possible, they suggested:
              • Publish the results of the performance demonstrations as an article in a trade
              journal.
              • Distribute the final information product at trade shows and through regional
              printing newsletters.
              •Have PIA and EPA distribute the final information product directly to printers.
              • Use as many sources  as possible to disseminate the information.  Multiple
              sources would lend credibility to the final product.
                                          A-20

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6. Other DfE Issues
Demonstrations Methodology
           The printers had several suggestions regarding the Demonstration Methodology, such
           as:
           • They would like to see the in-field demonstrations limited to printers who have
           similar operations, such as only 24" sheet-fed presses. Such a  limitation would
           provide more consistent results.
           • Demonstrations  should also record information on the ability of the product to
           remove ink from rollers and printing tools (where ink may be thicker) as well as it's
           performance in cleaning the blanket.
           • The demonstrations should include a run where the press is changed from a dark
           color to a light color and a run from a light to a dark color. This will give an
           indication of the time, effort, and quantity of product needed to come up to color in
           the worst case and best case scenarios.
           • This information should be updated annually (at least) due to the rapid introduction
           of new products to the market.
MSDSs
            • Printers do not rely on the information from MSDSs. They describe receiving out-
            dated MSDSs and MSDSs that are generic to a product line, but offer no specific
            information on the product they purchased. They also complained that the formats
            are not consistent, making them even more difficult to interpret.
                                         A-21

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1. Logistics
                           Screen Printing DfE Focus Group
                                   Los Angeles, CA
                                    April 21, 1994
                                    1:00 - 2:30 pm
             The focus group was held at the Printing Industries of America -  Southern
             California office in Los Angeles.  Eight people attended including 6 printers and
             2 suppliers.
2. Reaction to DfE
              The group expressed concern that product names would not be supplied. Without
              product names, printers felt it would be difficult to be sure they were purchasing
              products with the same characteristics as the products presented in the matrix.
3. Content
             This group was concerned about whether or not alternative products would comply
             with local air regulations and whether or not they cleaned the screen as well as the
             products they were currently using. Other issues such as disposal requirements and
             product risks were secondary considerations. The group suggested several changes
             to the final information product.  They recommend:
             •In the performance column, clarify the information on quantity of product used
             and  time  required  to  reclaim  by including the screen  size  used  in  the
             demonstration. Also, if the product is reused or recycled, indicate how many times
             it is reused before disposal or addition of fresh product.
             •  Add information about the effects of  the ink remover on the stencil and the
             effects of the haze remover on the screen mesh.
             • Information on drying time of the ink remover was considered important, but
             only for on-press application of the product.
             • Include information on the application method of the product as it was used in
             the demonstration.
             •In the cost category, report cost in terms of a standard quantity.  They noted that
             it was useful for comparison of products, but that prices differ regionally, so such
             a comparison may not be very accurate.
             • For risk, include personal protective equipment.
             •Report risk information in descriptive terms and "plain language". Currently, air
             regulations are such a large concern, that product risk is not often a consideration.
             •They recognize that disposal issues are very localized, so they thought it would
             be difficult to include any information that was really useful to them.  Disposal
             issues are further complicated because products are mixed with inks and emulsion
             before disposal.
                                         A-23

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4. Format
5. Vehicle
             •Under Test Conditions, include more specific information on the ink type used.
             For example, list epoxy ink instead of just solvent-based ink. Also include the
             number of impressions of the last run. They did not think it was very useful to
             include the ink color.
             The participants felt that it was important to provide information in the most
             descriptive terms possible. Generally, they liked mockup #2, but suggested adding
             more specific information on the performance such as is presented in mockup #1
             (i.e., quantity applied and cleaning time). The printers preferred the simple,
             understandable terms of mockup #2 used to describe the Risks and the Disposal
             Issues. After some discussion, all agreed that mockup #2 accompanied by a fact
             sheet on each product was their preferred choice of formats. Other  formats
             discussed but not well received included posters, brochures, and videotapes.
             To distribute this information to as many lithographers as possible, they suggested:
             •Publish the results of the performance demonstrations in a trade journal.  Screen
             Printing Magazine was suggested as a publication that most print shops receive.
             • Distribute the final information product at trade shows.
             • SPAI was the most credible source to some printers. One printer noted that he
             feels SPAI is "on my side".
             •  Use as many sources as possible to disseminate the information.  Multiple
             sources would lend credibility to the final product.

6. Other DfE Issues
            They agreed that it was important to get this information out to printers as soon as
            possible.
                                          A-24

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                       APPENDIX B
Screen Printer and Lithographer Focus Group Facilitator's Guides
                            B-l

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                                     Facilitator's Guide
                         Final Products Focus Group - Lithography
                                    DfE Printing Project
1. Introduction
           I'd like thank you all for participating in this focus group. We appreciate the time you're
           taking to be here today. It looks like everyone is here so let's get started.
           My name is
and I will be serving as the facilitator of the
           focus group. I am from Abt Associates, a consulting firm in Cambridge. We
           have been contracted by the EPA to help determine the best format for
           presenting the information collected in the Design for the Environment
           Printing Project. Abt is also involved in several other aspects of the Design
           for the Environment Project such as the Performance Testing of alternative
           products. Also from Abt is	who will be taking notes and
           helping me to  summarize your comments.

  a. Self introductions
           I'd like to begin today by having each of you introduce yourself, including
           your name, your company and your position.

  b. Logistics
           The point of this focus group is to have an open discussion. Please speak
           openly and candidly as we go through the Design for Environment
           information; our goal here is to get your opinions. In addition to this focus
           group, similar focus groups with lithographers will be held in 2 or 3 other
           locations. We  will also hold a series of focus groups with Screen Printers.
           Following these meetings, Abt will put together a report summarizing the
           discussions and findings. The report will not attribute specific comments to
           particular individuals and it will be available to anyone who would like a
           copy. Unless anyone objects, we would like to record this meeting as a back
           up to the note  taking.
           Is it OK if we tape the meeting?

2. Goals/Purpose of Meeting
  a. Intro to DfE
           For those of you who have not heard much about the EPA's Design for the Environment
           Printing Project, I'll briefly describe what it's all about and where this focus group fits
           in.
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         The Design for Environment Printing Project, referred to as DfE, is a unique
         project in that it is a cooperative effort by the EPA and printing trade
         associations liJke PIA, SPAI (the screen printers association), and others. The
         project is aimed specifically at developing pollution prevention information
         for printers. This project was initiated when printing industry association
         groups came to the EPA and asked for help in evaluating products that claim
         to be environmentally friendly. The EPA and several trade associations
         responded by setting up the DfE Printing Project. As one of the first steps in
         this project, industry representatives prioritized the areas of environmental
         concern in printing. Blanket washes in lithography and screen reclamation in
         screen printing were identified by printers as the two areas of greatest
         concern, so these two areas have been the primary focus of the project to
         date. For lithography, the project is gathering information on the
         performance, cost and the health and environemntal risks of alternative
         blanket wash products.

         A lot of information  will be collected and the DfE project hopes that this
         information will assist printers by:
            • Providing information on a variety of alternative blanket wash products
            • Encouraging your suppliers to compete on the basis of the health and environmental
           characteristics of their products
            • and by Giving you  a guide so when you consider other new products, you'll know
           what type of information on environmental effects you should be getting from your
           supplier.

         The information collected from the testing and research represents a
         significant effort by both the printing  industry and the EPA. The EPA will
         prepare a fairly lengthy document summarizing this research. However, one
         of the final steps in this project is to make sure that this information gets to
         the people who can use it,  printers, and that it is summarized in a format  that
         is most useful to you.

b. Purpose of this focus group
         That is where this focus group comes in. Through a series of meetings like
         this one, we are talking with lithographers to determine what the final
         product or products should look like.

         This is an opportunity for you to influence the final product you receive.
         Even if you have an  idea that you think only applies to your specific
         operation, let us know about it. It might be an idea that we end up hearing
         from other focus groups.
                                           B-4

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Today, we want to get your ideas and opinions on:

             • What information is most useful to you? (CONTENT)
             • What format is most useful to you? (FORMAT) and
             • What is the best way to get this information to printers? (VEHICLE)
             • Within the printing facility, who can (or who should) use this information?

           This is a lot to cover. I'll first go over the specifics of what information is
           being collected in the DfE project, so we can discuss what information is
           most useful to you.
           Second, we'll look at some mock ups of different formats for presenting the
           performance, cost and risk information so we can discuss which format
           works best for you.
  Are there any questions about the DfE project as I've explained it so far?
3. Content of CTSA Information
           There are 2 ways that DfE is gathering information:

           First, the EPA is testing alternative blanket wash products to determine how
           effectively they clean the blanket. All testing will be done at actual printers
           facilities where they will use the product hi production for a week. These
           printers are interested hi finding substitute products and they have
           volunteered their facility to help the DfE project collect the most useful
           information possible. The products being tested are voluntarily submitted by
           suppliers who want their products included in the testing.

           Second, the EPA will calculate the risks associated with the products tested
           based on the chemical content and estimates of the occupational exposure.
      Pass out copies of mock ups
           I'm passing out copies of some ideas of how all this information may be
           compiled. We'll go through the content and format of each of these
           individually, but you can see on the first page the type of information that
           will come out of the testing and the risk analysis work. What we will end up
           with is a mix of objective and subjective information. The information will
           include a subjective evaluation of how effective the product was, an estimate
           of the cost of the product, risk information, and chemical characteristics of
           the product.

           I'd like to go through each of these categories and talk about what kind of
           information you would like to see coming out of this project in the future,
           but before we do that I'd like to get some background and talk about what
           information you get now.
                                            B-5

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     If you wanted to try a different blanket wash, how do you go about getting the
     information you need to evaluate the new product?
       • Has anyone tried a different blanket wash recently?
       • Where did you get the information about the product? (Did the supplier approach
       you? Did you get the information through a trade journal or trade association?)
       • Did you have sufficient information to make a decision about the product?
       • Is there any information that you would like to have that you DID NOT get?
       • For those of you who haven't made a change recently, if you wanted to try a new
       blanket wash, how would you go about getting information to make a change?
       • Who would use this type of information within the facility?
Turn to Mock Up #1
     OK, that gives us some good background on the kind of information you're getting now.
     So next let's go through the matrix and talk about what kind of information you would
     like to get in the future.  The first page of your handouts is MOCK UP #1. Each mock up
     is labelled in the upper right hand comer. Using this matrix as a starting point, let's go
     through the types of information that you would like to have when selecting a blanket
     wash.

     There are a few things to note here:
        • Products are not referred to by their trade names, instead  they are
     referred to as Product A, B, C etc. This was the agreement made with
     suppliers in order to get their full cooperation.
        • The chemical constituents of the products are reported in ranges hi order
     to protect trade secrets.
        • Also, as we go through the different format options, you will notice that there are no
     rankings of products. No product is listed as "Best" or "Worst". The intention of this
     project is not to promote or endorse any product. The goal is to gather all the necessary
     information on alternative blanket washes, present it to the printers, and then let the
     printer make their own decision on which products are best for their operation.

     I'd like to go through  each of these categories and get your ideas on what kind of
     information should be included in each.

     Starting with the first category, PERFORMANCE:
     • The  evaluation of performance will be subjective, determined by the printer who is
     doing the testing. To reduce the subjectivity, the printer will first clean the blanket using
     a baseline product. Then, the performance of the test product  will be compared to the
     baseline. This should reduce the subjectivity between different people in different
     facilities. As we go through the performance categories listed  here, think about what
     other performance factors you would need to know about a new product. The parameters
     in this  matrix include:
                                       B-6

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  - Ability to cut ink
         This category would list the types of ink that the solution was able to remove
         during the testing.
  - The quantity of solution required per application
         The data for the other 3 performance categories compares the test product to the
         baseline product. Each printer testing a product, will first clean the blanket
         using the baseline. "Quantity" column indicates how much test product was
         required compared to the volume of baseline product used.
  - The tune required to clean the blanket
  - and the Effort Required

  Are there any other performance characteristics that you would like to see in this chart?

  What other information about the specific test conditions is useful (length of time ink
  was allowed to dry before cleaning, type of press etc.)?

Now for COST:
  • Cost is presented here in $/gallon.  What is the best way to present cost information?
  Is there some way to present it in $/cleaning? What would constitute a cleaning?

The next category on this matrix is RISK:
  The risk information is based on the chemical composition of the blanket wash. The
  EPA will look at the chemical constituents and identify the toxic properties associated
  with each one. They put the toxicity information together with information of
  exposures that they have estimated from a number of work place surveys, and estimate
  the risk of the product. What information do printers need regarding the risk of the
  product? is 10"4 too complicated? Would simple terms such as "eye and skin irritant" be
  preferred?

The last category on this matrix lists the CHEMICAL
CHARACTERISTICS of the product.
  VOC content and flash point are being measured as  part of the testing. Are there any
  other chemical properties that you would find useful in selecting a blanket wash?
  Vapor pressure will not be measured, but  the value as reported by the supplier could be
  included.
                                 B-7

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4. Format of Performance Testing Information

            • OK, now let's talk about HOW you would like to see this information
           presented? What format is most useful? The rest of the information packet I
            handed out has some other formats for presenting this information. These are
            only drafts at this point. These will be revised based on the comments we get
            from the focus groups. I want to get your suggestions on what type of format
            best suits your needs.
       Refer to MOCK UP $1
           Mock Up #1, the detailed format we have been discussing so far, is the most detailed
           format and contains the most numerical information.
•^   Turn to the Fact Sheet
           Another option would be to include a "Fact Sheet" with this matrix. Such a
           Fact Sheet would serve as a reference for each column in the table. For
           example, everyone reading this chart may not be familiar with what a flash
           point of 100ฐF means. The Fact Sheet would explain this column by
           describing that the flash point is the temperature at which the liquid gives off
           a vapor sufficient to form an ignitable mixture. A flash point of less than
           100ฐF is considered LOW, meaning that it may be a safety hazard. To avoid
           a fire hazard, precautions must be taken in storing and handling products
           with low flash points. A flash point greater than 200ฐF is generally not
           considered to be a hazard, but the safety of the product is dependent on the
           specific conditions in the facility. The Fact Sheet describes how to interpret
           the information in each column, but it does not describe the specific results
           associated with each product. In the case of performance, the Fact Sheet
           would describe how the performance ratings were obtained. For cost, the
           Fact Sheet would describe the factors that were used in the cost calculation
           including what wage rate was used. The Risk/Hazard column would describe
           what a risk of 10"* means and what range is considered an acceptable risk.

              • Would the Fact Sheet make this format easier to understand?
              • Would you be likely to read the Fact Sheet?
              • Do you think the length of the Fact Sheet should be limited? To 1 page?
                                                                               i
Now, I'd like to flip through each of the other 4 mockups I handed out, and then we can talk about
which one best suits your needs or what changes need to be made to these formats or any other
formats that you think would be useful that aren't included in this set of mockups.
                                             B-8

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        Turn to MOCK UP #2:
           This format is similar to the previous one, however, it uses more descriptive
           text where the first matrix used numbers to describe the results. For
           example, in the RISK column, the first example reported carcinogenic risk as
           10"4, and this format describes how the product can be a health risk. There
           are differences in the other categories as well.
       Turn to MOCK UP #3
           The third mock up gives the same type of information as the first matrix, but uses a
           different format. The products are listed across the top of the page, the content is also
           slightly different in that it is a combination of the descriptive and numeric information.
           The risk information is given descriptively.


       Turn to MOCK UP #4
           This mockup is a Fact Sheet only; no matrix is included. In format, it is
           similar to the Fact Sheet we talked about earlier. But,  since it is not
           accompanied by a matrix, it will contain information on the test results
           instead of just explanations  of what the different testing categories mean. For
           example, the performance category will describe how  the product performed
           under the given test conditions and will include any limitations of the
           product.
       Turn to MOCK UP #5
           The final mockup is a series of Fact Sheets. It's similar to the fact sheet we
           just looked at, but it has only one product on each page. With an expected 35
           or more products involved in the testing, this format would result in a 35 or
           more page document.
             • In which format is the risk information most useful to the printers?
             • Which format is easiest to understand?
             • Do you have any suggestions to improve any of these formats?
             • Are there any other formats that would be better?
5. Vehicles
           Several other ways of presenting this information were considered such as
             Brochures, posters, video conference, videotape, ...
             • Would a different vehicle for presenting this information be more useful?
             • Would another format in addition to the matrix be useful?

           Who would you like to get this information from?
             • What source do you consider as the MOST CRFJMBLE in reaching you with this
             kind of information? Why?
                                             B-9

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6. Closing
           I hope you have a better idea of what information will be coming out of the
           Design for Environment Printing Project.
             • Does anyone have any further comments on content or format of this information or
             on the DfE project in general?
           Once again, I want to thank you again for participating.
                                             B-10

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                                      Facilitator's Guide
                         Final Products Focus Group - Screen Printing
                                     DfE Printing Project
1. Introduction
            I'd like to welcome you all and thank you for participating in this focus group. We
            appreciate the time you're taking to be here today. It looks like everyone is here so let's
            get started.

            My name is	and I will be facilitating today's meeting. I am from Abt
            Associates, we're a private consulting firm. We've been contracted by the  EPA to help
            determine the best format for presenting the information collected in the Design for the
            Environment Printing Project. Abt is also involved in several other aspects of the Design
            for the Environment Project such as the Performance Testing of alternative products.
            Also from Abt is	who will be taking notes and helping me to summarize
            your comments.

  a. Self introductions
            I'd like to begin this morning by having each of you introduce yourself, including your
            name, your company, and approximately what percentage of your business is in screen
            printing.

  b. Logistics
            The point of this focus group is to have an open discussion. Please speak openly and
            candidly; feel free to ask questions anytime; our goal here is to get your opinions. Abt
            will be putting together a report summarizing the discussions and findings.  The report
            will not attribute specific comments to particular individuals and it will be available to
            anyone who would like a copy. Unless anyone objects, we would like to record this
            meeting as a back up to the note taking.
            Is it OK if we tape the meeting?
2. Goals/Purpose of Meeting
  a. Intro to DfE
           For those of you who have not heard much about the EPA's Design for the Environment
           Printing Project, I'll briefly describe what it's all about and where this focus group fits
           in.

           The Design for Environment Printing Project, referred to as DfE, is a unique
           project in that it is a cooperative effort by the EPA and printing trade
           associations like SPAI, PIA (the lithographers association), NAQP and
           others. The project is aimed specifically at developing pollution prevention
           information for printers. This project was initiated when printing industry
                                             B-ll

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         association groups came to the EPA and asked for help in evaluating
         products that claim to be environmentally friendly. The EPA and several
         trade associations responded by setting up the DfE Printing Project. As one
         of the first steps in this project, industry representatives prioritized the
         areas of environmental concern in printing. Screen reclamation in screen
         printing and blanket washes in lithography and were identified by printers as
         the two areas of greatest concern, so these two areas have been the primary
         focus of the project to date. For screen printing, this will include
         performance testing alternative screen reclamation systems. In addition to the
         performance and cost data generated during these tests, the EPA is
         researching the associated environmental, health and safety risks of these
         products.

         The information collected from the testing and research represents the
         cumulative effort of both the printing industry and the EPA as they work
         together to gather concrete information on substitute products. The EPA will
         prepare a fairly lengthy document summarizing this research. However, one
         of the final steps in this project is to make sure that this information gets
         to the people who can use it, printers,  and that it is summarized in a
         format that is most useful to you.

b. Purpose of this focus group
         That is where this focus group comes in. Through a series of meetings like
         this one, we are talking with screen printers to determine what the final
         information should look like.

         Today, we want to get your ideas and  opinions on:
           • What information is most useful to  you? (CONTENT)
           • What format is most useful to you? (FORMAT) and
           • What is the best way to get this information to printers? (VEHICLE)
           • Within the printing facility, who can (or who should) use this information? Who is
           the TARGET audience?

         This is a lot of information to cover, so I'll first go over the specifics  of
         what information is being collected in  the DfE project, so we can discuss
         what information is most useful to  you.
         Second, we'll look at some mock ups of different formats for presenting the
         performance, cost and risk information so we can hear your ideas on what
         format works best for you.
                                          B-12

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  Are there any questions about the DfE project as I've explained it so far? Irealize this is pretty
much all new information for some of you.

           OK, I'd like to start by explaining the types of information being collected in
           the DfE project.

3. Content of CTSA Information
           There are 2 ways that DfE is gathering information:

           The first way is through performance testing. The EPA is testing alternative
           screen reclamation systems to determine how effectively they clean the
           screen.  All testing will be done at actual printers facilities where they will
           use the product hi production for one month. These printers are interested in
           finding substitute products and they have volunteered their facility to help the
           DfE project collect the most useful information possible. The products being
           tested are voluntarily submitted by suppliers who want their products
           included in the testing.

           Second, the EPA will calculate the risks  associated with the products tested
           based on the chemical content and estimates of the occupational exposure.


^ฎ   Pass out copies of mock ups
           I'm passing out copies of some ideas of how all this information may be
           compiled. These mockups are a way to start the discussion,  but the point of
           this meeting is to hear your thoughts on what format works  best for you. It
           may not be one I've thought of here. We'll be looking at the content and
           format of each one of these, let's start by looking at the chart on the first
           page. This chart shows the type of information that will come out of the
           testing and the risk analysis work. What we will end up with is a mix of
           objective and subjective information. The information will include a
           subjective evaluation of how effective the product was, an estimate of the
           cost  of the product, risk information, and chemical characteristics of the
           product.

           There are a few things to note here:
             • Products are not referred to by their trade names, instead they are
           referred to as System A, B, C etc. This was the agreement made with
           suppliers in order to get their full cooperation.
             (This was the agreement because:
             - EPA does not want to  give the impression that they are endorsing or promoting any
             products.
             - Suppliers can advertise which products are theirs.
             - Some suppliers DO want to publicize  which product is theirs and ideally someone will
             crack the code and advertise which products are which, but the EPA can't do that.
                                            B-13

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            - Hopefully, the results will spark the interest of printers and you will go to your
            suppliers and say, "I want this type of system. What do you have?"
            • The chemical constituents of the products are reported in ranges in order to protect
            trade secrets.
            • Also, as we go through the different format options, you will notice that there are no
            rankings of products. No product is listed as "Best" or "Worst". Again, the intention of
            this project is not to promote or endorse any product. The goal is to gather all the
            necessary information on alternative screen reclamation systems, present it to the
            printers, and then let the printer make their own decision on which products are best
            for their operation.


           The Dffl project hopes that this information will assist printers by:
            • Providing information on a variety  of alternative screen reclamation products
            • Encouraging your suppliers to compete on the basis of the health and environmental
            characteristics of their products
            • and by Giving you a guide so when you consider other new  products, you'll know
            what type of information on environmental effects you should  be getting from your
            supplier.

  Are there any questions?

           Before we go over the type of information you'll get from the DfE project in
           the (near) future, I'd like to talk about what information you get now.

           When you want to try a different screen reclamation system now, how do you go about
           getting the information to make a change?
              • Why -would you consider trying a new screen reclamation system? How would you go
            about getting information to make a change?
              • Has anyone tried a different screen reclamation system recently?
              • Where did you get the information about the product? (Supplier, trade journal, trade
            association, MSDS?) DfE advantage  overMSDS be. all products are evaluated in the
            same -way, using the same method and the same sources.
              • Did you have sufficient information to make a decision about the product?
              • Is there any information that you would like to have that you DID NOT get?
              • Who -would use this type of information within the facility?
OK, that's some good background information on where you are now. SUMMARIZE.


"^  Turn to  Mock Up #1
           OK, now let's move on to the first chart in the handouts and talk about what kind of
           information you would like to get. The first page of your handouts is labelled MOCK UP
           #1. Each mock up is  labelled hi the upper right hand comer. Using this matrix as a
           starting point,  let's go through the types of information that you would like to have when
           selecting a screen reclamation system.
                                            B-14

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 Each column lists a characteristic for each of the products listed down the left hand side
 of the page. The column headings include the performance of the product, the cost, it
 gives a numerical risk for carcinogens and a descriptive risk for non-carcinogens, it
 describes the federal regulations that apply to the specific chemical and then lists some of
 the test conditions.

 I'd like to go through each of these categories and get your ideas on what kind of
 information should be included in each.

 Starting with the first category, PERFORMANCE:
 •  The evaluation of performance will be subjective, determined by the printer who is
 doing the testing. How a product performs is very subjective and it is judged by the
 operator doing the test. As we go through the performance categories listed here, think
 about what other performance factors you would need to know about a new product. The
 parameters included in this matrix include:
   - Quantity applied
         How much product was used. This can be reported as  an average amount per
         square inch of screen.
         (calibrated squeeze bottle? TBD. Observer will be present for 1st day).
   - Cleaning time
         How long did it take to clean the screen.
   - Was the screen reusable?
         Yes or No. This category could also include subjective information on the
         quality of the screen.
   - and Were there any printing limitations on the screen after it was cleaned?

   • Are there any other performance characteristics that you -would like to see in this
  chart?

Now for COST:
  On this chart, cost is presented in $/gallon.
   • What is the best -way to present cost information? Is there some way to present it in
  $/'cleaning? What would constitute a cleaning?

The next category on this matrix is RISK:
  The risk information is based on the chemical composition of the product. The EPA
  will look at the chemical constituents and identify the toxic properties associated with
  each one. They put the toxicity information together with information of exposures that
  they have estimated from a number of work place surveys, and estimate the risk of the
  product.

  • What type of information on risk is most useful to you?
   • What information do you need in order to evaluate the risk associated with a
 particular product?
   • What about the format of the risk information?
                                 B-15

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             • Would printers prefer to see risk listed in this scientific format, like Iff5, or is a
             description of risk preferred, such as "the ink remover is a skin irritant".

           WASTE DISPOSAL
             The last category deals with the waste disposal issues associated with using this
             product.
             • What type of information on waste disposal do you need? Should federal regulatory
             requirements for the test product be listed? For example, "Hazardous Air Pollutant" or
             "RCRA waste 005/U220" or "SARA listed chemical", etc.

           TEST CONDITIONS
             Test conditions include the Ink type used during testing, the type of emulsion that was
             on the screen and the ink color used during the test. These may list several different
             types  if the cleaning results were fairly consistent throughout the testing period using
             different types of screens and inks.
             • Is there any  other information concerning the test conditions that you would need to
             know?

4. Format of Performance Testing Information

            • OK, now let's talk about HOW you would like to see this information
           presented? What format is most useful? Let's go through each mockup in
            this packet, briefly, and then talk about which one of these best suits your
            needs. If you have any ideas for different formats, we want to hear those
            too. As we go through these think about...
              ปIs there any information that you would need in selecting a screen reclamation system
             that is not on this chart? (What's missing?)
              • What information is essential? Why?
              • Is this format easy to understand?
              • Do you have any suggestions to improve this format?


 ^   Refer to MOCK UP #1
            Mock Up #1, the detailed format we have been discussing so far, is the most detailed
            format and contains the most numerical information.
        Turn to the Fact Sheet
            Another option would be to include a "Fact Sheet" with this matrix. Such a
            Fact Sheet would serve as a reference for each column in the table. For
            example, it would explain all the factors that were used to calculate the
            COST listed in the matrix. It would list the product cost/gallon, the labor
            time required/area of screen cleaned, standard screen cleaning wage and the
            labor and costs associated with waste disposal requirements to meet federal
            regulations
                                             B-16

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     The Fact Sheet describes how to interpret the information in each column, but it does not
     describe the specific results associated with each product. In the case of performance, the
     Fact Sheet would describe how the performance ratings were obtained. For cost, the Fact
     Sheet would describe the factors that were used in the cost calculation including what
     wage rate was used. The Risk/Hazard column would describe what a risk of 10"4 means.

       • Would the Fact Sheet make this format easier to understand?
       • Would you be likely to read the Fact Sheet?
       • Do you think the length of the Fact Sheet should be limited? To 1 page?


 Turn to MOCK UP #2:
     This format is similar to the previous one,  however, it uses more descriptive
     text where the first matrix used numbers to describe the results. For
     example, in the RISK column, the first example reported carcinogenic risk as
     10"4, and this format describes how the product can be a health risk.

     Like the first MOCK UP, this matrix could also be accompanied by a Fact Sheet. The
     Fact Sheet would be very similar to the Fact  Sheet discussed with MOCK UP #1.


Turn to MOCK UP #3
     The third mock up gives the same type of information as the first matrix, but uses a
     different format.  The products are listed across the top of the page. The content is also
     slightly different  in that it is a combination of the descriptive and numeric information.
     The risk information is given  descriptively.


Turn to MOCK UP #4
     This mockup is a Fact Sheet only; no matrix  is  included. In format, it is
     similar to the Fact Sheet we talked about earlier. But,  since it is not
     accompanied by a matrix,  it will contain information on the test results
     instead of just explanations of what the different testing categories mean. For
     example, the performance category will describe how the product performed
     under the given test conditions and will include any limitations of the
     product.
Turn to MOCK UP #5
    The final mockup is a series of Fact Sheets. It's similar to the fact sheet we
    just looked at, but it has only one product on each page. With an expected 15
    products involved in the testing, this format would result in a booklet of fact
    sheets.
                                     B-17

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Now, looking at the different formats in this packet, I want to ask some questions about which format
you as a printer find most useful in selecting an alternative screen reclamation system...

            • Wfiich format is easiest to understand?
            • Do they all give enough information to make a decision about which product (a) to try?
           Js any information missing?
            • Do you have any suggestions to improve these formats ?
            • Do you prefer the matrix over the fact sheet format?
 5. Vehicles
6. Closing
            Several other ways of presenting this information were considered such as
             Brochures, posters, video conference, videotape, ...
              • Would a different vehicle for presenting this information be more useful?
              • Would another format in addition to the matrix be useful?
              • What source do you consider as the MOST CREDIBLE in reaching you with this kind
             of information? Why?
            I hope you have a better idea of what information will be coming out of the
            Design for Environment Printing Project.
            • Does anyone have any further comments on content or format of this information or on
            the DfE project in general?
            Once again, I want to thank you again for participating.
                                              B-18

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                             APPENDIX C
Screen Printer and Lithographer Focus Group Final Information Product Mockups
                                 c-i

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Mockups for Blanket Washes

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                                FACT SHEET FOR
                    BLAKI02T WASH PRODUCTS MATRIX
Product Name
            • Products are referred to as "Product A", "Product B", etc.. The product name and
            the supplier name are not given.

Chemical Constituents
            • The chemical composition of each blanket wash tested is reported within a range.
            • Exact chemical percentages are not reported in order to protect trade secrets of the
            suppliers.
            •  All chemicals that make up greater than 1 % of the product are listed. Both
            hazardous and non-hazardous constituents are included in this list.

Performance
            • Ability to cut ink:...
            • Quantity required:...
            • Time required:...
            • Effort required:...

Cost
            Cost includes:
            1. the product cost/gallon x quantity of product required per area of
            blanket cleaned +
            2. the labor time required/area of blanket cleaned x standard blanket
            cleaning wage +
            3. labor and costs associated with waste disposal requirements to meet
            federal regulations

Risk/Hazard
           The risk and hazard information in the matrix is based on the chemical composition
           of the product. The toxic properties of each chemical constituent of the product was
           identified as part of the risk analysis done by the EPA. The toxicity information was
           combined with estimates of work place exposures to calculate an estimate for risk.
           The exposures were estimated from a number of work place surveys completed by
           printers; the risk is not based on measurements of work place exposure.

Chemical Characteristics
            • VOCcontent:...
            • Vapor pressure:...
            • Flash point: The temperature at which the liquid gives off a vapor sufficient to

                                         C-7

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form an ignitable mixture. A flash point of less than 100ฐF is considered LOW,
meaning that it may be a safety hazard. To avoid a fire hazard, precautions must be
taken in storing and handling products with low flash points. A flash point greater
than 200ฐF is generally not considered to be a hazard, but the safety of the product
is dependent on the specific conditions in the facility. For each product tested, the
flash point was measured in triplicate at the GATF laboratory.
                                C-8

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                                                                                              MOCK UP #4

    RESULTS OF CLEANER TECHNOLOGIES SUBSTITUTE ASSESSMENT (CTSA) FOR
                                  BLANKET WASH PRODUCTS

 Background .
              Through the Design for the Environment (DfE) Printing Project, blanket wash products were
              evaluated through performance testing and through an evaluation of the risks and hazards associated
              with the product. This fact sheet presents the results of the product evaluations.

 Description of Products
              Product A is solvent-based, containing solvent x, solvent y and solvent z.
              Product B is an aqueous-based product containing chemical x and chemical y.
              Product C...
 Performance
              Product A: Effectively removed all ink (both X and Y types) without any noticeable damage to the
              blanket.
              Product B: Effectively removed ink X. Removed ink Y, however it took 4 minutes and required
              more effort.
              Product C:...
Relative Risks
              Product A: Classified as a possible carcinogen meaning there is evidence of carcinogenicity in
              animals in the absence of human data. Irritation and rash may result from dermal exposure. For
              long-term exposures via inhalation, there is evidence of nervous system and respiratory disorders.
              Product B: No evidence of carcinogenic effects. Skin irritation and rash may result from dermal
              exposure. Animal studies indicate some evidence of developmental toxicity.
              Product C:...
Safety Issues
              Product A: With a flashpoint of 160ฐF, flammability may be of moderate concern. Standard
              handling precautions apply.
              Product B: With a flashpoint of 97ฐF, flammability may be a significant concern. Fire prevention
              measures and proper ventilation are required for safe use.
              Product C:...

Waste Disposal Issues
              Product A: Must be filtered before disposal to comply with federal regulations.
              Product B: Contains no RCRA regulated materials
              Product C:...
Costs
             Cost includes:
             1. the product cost/gallon x quantity of product required per area (?) of blanket cleaned +
             2. the labor time required per area of blanket cleaned x standard blanket cleaning wage +
             3. labor and costs associated with waste disposal requirements to meet federal regulations
             Product A:...
             Product B:...
             Product C:...
                                                    C-13

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                                                                                 MOCK UP #5
 RESULTS OF CLEANER TECHNOLOGIES SUBSTITUTE ASSESSMENT (CTSA) FOR
                           BLANKET WASH PRODUCTS
                                         PROBUCT A
Performance
            • Effectively removed inks X and Y.
            • Average cleaning time was 2 minutes longer man the baseline product, Naphtha.
            • Quantity of product required ranged from 1.0 - 2.0 oz. more than the baseline product.
            • The press operator characterized the effort required to clean the blanket as approximately the
            same as the effort required using the baseline product.
            • The supplier does not recommend using this product with ink Z.
            • A rubber blanket, approximately 2 months old, was used in the testing.
            • The press used was a Heidleberg model 1234.

Relative Risks
            • Classified as a possible carcinogen meaning there is evidence of carcinogenicity
            in animals in the absence of human data.
            • Irritation and rash may result from dermal exposure.

Chemical Characteristics
            VOC content = 30 - 50%
            Vapor pressure = <5mm
            Flashpoint = 97ฐF
Safety Issues
Costs
Notes
              With a low flashpoint, combustibility and flammability may be a significant
            concern. Fire prevention measures and proper ventilation are required for safe use.
            Cost includes:
            1. the product cost/gallon x quantity of product required per area of blanket cleaned
            +
            2. the labor time required/area of blanket cleaned x standard blanket cleaning wage
            +
            3.  labor and costs associated with waste disposal requirements to meet federal
            regulations
              Product must be filtered before disposal to comply with federal regulations.
                                             C-15

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                                  FACT SHEET
                 SCREEN RECLAMATION SYSTEMS MATRIX
 Product Name
        • Products are referred to as "System A", "System B", etc.. The product name and the supplier name
        are not given.

 Chemical Constituents
        • The chemical composition of each screen reclamation system tested is reported within a range.
        • Exact chemical percentages are not reported in order to protect trade secrets of the suppliers.
        • All chemicals  that make up greater than 1% of the product are listed. Both hazardous and non-
        hazardous constituents are included in this list.

 Performance
        • Quantity applied:
        • Cleaning time:
        • Screen reusable:
        • Printing limitations:

 Cost
       Cost includes:
        1. the product cost/gallon x quantity of product required per area of screen cleaned +
       2. the labor time required/area of screen cleaned x standard screen cleaning wage +
       3. labor and costs associated with waste disposal requirements to meet federal regulations

Risk/Hazard
       The risk and hazard information in the matrix is based on the chemical composition of the product. The
       toxic properties of each chemical constituent of the product was identified as part of the risk analysis done
       by the EPA. The toxicity information was combined with estimates of work place exposures to calculate
       an estimate for risk. The exposures were estimated from a number of work place surveys completed by
       printers; the risk is not based on measurements of work place exposure.

Test Conditions
       • Ink type:
       • Emulsion type:
       • Ink color.

Disposal Issues
                                            C-21

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                                                                                                  MOCK UP #4

    RESULTS OF CLEANER TECHNOLOGIES SUBSTITUTE ASSESSMENT (CTSA) FOR
                              SCREEN RECLAMATION SYSTEMS

 Background
              Through the Design for the Environment (DfE) Printing Project, screen reclamation systems were
              evaluated through performance testing and through an evaluation of the risks and hazards associated
              with the system. This fact sheet presents the results of the system evaluations.

 Description of Systems
              System A is solvent-based, containing solvent x, solvent y and solvent z.
              System B  is a citrus-based system containing chemical x and chemical y.
              System C...
 Performance
              System A: Effectively removed all ink (both UV-based and solvent-based) and stencil without any
              tears in the mesh.
              System B: Effectively removed solvent-based inks and stencils. Not able to remove all of the UV-
              based ink from the screen: a ghost image appeared in some ("50%) of the UV-based ink screens
              in future printing.
              System C:...

Relative Risks
              System A: Classified as a possible carcinogen meaning there is evidence of carcinogenicity in
              animals in the absence of human data. Irritation and rash may result from dermal exposure. For
              long-term exposures via inhalation, there is evidence of nervous system and respiratory disorders.
              System B: No evidence of carcinogenic effects. Skin irritation and rash may result from dermal
              exposure. Animal studies indicate some evidence of developmental toxicity.
              System C:...


              System  A: Moderate  flashpoint.  Flammability  is of moderate concern.  Standard handling
              precautions apply.
              System B: With a flashpoint of 97ฐF, combustibility and flammability are a significant concern.
              Fire prevention measures and proper ventilation are required for safe use.
              System C:...

Waste Disposal Issues
              System A: Must be filtered before disposal to comply with federal regulations.
              System B: Contains no RCRA regulated materials
              System C:...
Safety Issues
Costs
             Cost includes:
             1. the system cost/gallon x quantity of product required per area of screen cleaned +
             2. the labor time required per area of screen cleaned x standard screen cleaning wage +
             3. labor and costs associated with waste disposal requirements to meet federal regulations
             System A:...
             System B:...
             System C:...
                                                     C-27

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                                                                          MOCK UP #5

   RESULTS OF CLEANER TECHNOLOGIES SUBSTITUTE ASSESSMENT (CTSA) FOR
                      SCREEN RECLAMATION PRODUCTS
Chemical Characteristics
           Ink Remover
           Chemical 1: 15-25%
           Chemical 2: 30-40%
           Chemical 3: 20-30%
           Chemical 4: 20-30%
                                    SYSTEM A
Emulsion Remover
      Chemical 1: 30-40%
      Chemical 2: 10-20%
      Chemical 3: 40-50%
Haze Remover
      Chemical 1: 40-50%
      Chemical 2: 40-50%
Performance
           • Effectively removed solvent-based ink and light-sensitive emulsion stencil
           from screen.
           • Average cleaning time was 10 minutes.
           • Quantity of product required ranged from 3.0 - 5.0 oz. per x sq. inch of screen cleaned.
           • The screen was reusable after each cleaning, x cleanings were done without any tears or
           damage to the screen.
           • The supplier does not recommend using this product with UV-based inks.

Relative Risks
           •  Classified  as  a possible carcinogen meaning  there  is evidence  of
           carcinogenicity in animals in the absence of human data.
           • Irritation and rash may result from dermal exposure.

Safety Issues
           • With a flashpoint of 97ฐF, combustibility and flammability are a significant
           concern. Fine prevention measures and proper ventilation are required for use.

Waste Disposal Issues
           • Product must be filtered before disposal to comply with federal regulations.
Costs
           Cost includes:
           1. the product cost/gallon x quantity of product required per area of screen
           cleaned +
           2. the labor time required per area of screen cleaned x standard screen cleaning
           wage +
           3. labor and costs associated with waste disposal requirements to meet federal regulations
                                         C-29

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                                                                         MOCK UP #5
  RESULTS OF CLEANER TECHNOLOGIES SUBSTITUTE ASSESSMENT (CTSA) FOR
                     SCREEN RECLAMATION PRODUCTS
                                     SYSTEMS
Chemical Characteristics
           Ink Remover
           Chemical 1: 15-25%
           Chemical 2: 30-40%
           Chemical 3: 20-30%
Emulsion Remover
      Chemical 1: 30-40%
      Chemical 2: 10-20%
      ChemicalS: 40-50%
Chemical 4: 20-30%
Haze Remover
      Chemical 1: 40-50%
      Chemical 2: 30-40%
      Chemical 3: 10-20%
Performance
           • Effectively removed UV-based ink and direct photo stencil from screen.
           • Average cleaning time was 8 minutes.
           • Quantity of product required ranged from 6.0 - 8.0 oz. per x sq. inch of screen cleaned.
           • The screen was reusable after each cleaning, x cleanings were done without any tears or
           damage to the screen.

Relative Risks
           • No evidence of carcinogenic effects.
           • For long-term exposure via inhalation, there is evidence of nervous system and respiratory
           disorders.

Safety Issues
           • With a flashpoint of 137ฐF, combustibility and flammability, are a moderate
           concern.  Recommended ventilation  and handling  procedures should be
           followed.

Waste Disposal Issues
           • Contains no RCRA regulated materials.
 Costs
           Cost includes:
           1. the product cost/gallon x quantity of product required per area of screen
           cleaned +
           2. the labor time required per area of screen cleaned x standard screen cleaning
           wage +
           3. labor and costs associated with waste disposal requirements to meet federal
           regulations
                                          C-30

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