EPA
United States
Environmental Protection
Agency
Office of Pollution
Prevention and Toxics
(7406)
EPA744-R-00-004a
September 2000
PUBLIC COMMENT DRAFT
        FLEXOGRAPHIC INK OPTIONS:
           A CLEANER TECHNOLOGIES
            SUBSTITUTES ASSESSMENT
                              Volume 1

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 Flexographic Ink Options
A Cleaner Technologies Substitutes Assessment
               VOLUME 1


      PUBLIC COMMENT DRAFT
               September 2000
 Developed in Partnership by the Following Associations
  CflUFORNIfl
  FILM €XTRUD€RS
  & CONV6RT6RS
  flSSOCIflTION
U.S.EPA
naoim
              FILM&BAG
              FEDERATION

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           Contact Information

                    Karen Chu
          Design for the Environment Program
         U.S. Environmental Protection Agency
            1200 Pennsylvania Avenue, NW
                  Mail Code 7406
               Washington, DC 20044
                phone: 202-260-0695
                 fax: 202-260-0981
                chu.karen@epa.gov
      DfE Flexpgraphy Website Address:
www.epa.gov/dfe/flexography/flexography.html
                       11

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                             Contents
 Preface	xi

 Acknowledgments	 xiii

 Steering Committee	  xv

 Technical Committee	xvii

 Participating Suppliers	-....•	xix

 Abbreviations Used in the CTSA	xxi

 Glossary	 xxiii



                            VOLUME 1: TEXT


EXECUTIVE SUMMARY	


BACKGROUND OF THE DFE FLEXOGRAPHY PROJECT	ES-2

POTENTIAL HAZARDS AND RISKS OF INK CHEMICALS	ES-4
      Aquatic Hazards	 ES-5
      Human Health Hazards 	ES-6
      Human Health Risks	 ES-7

PERFORMANCE	 ES-11

COSTS	ES-14

RESOURCE USE AND ENERGY CONSERVATION	ES-15

FEDERAL ENVIRONMENTAL REGULATIONS	ES-16

CHOOSING AMONG FLEXOGRAPHIC INKS  	ES-18

CONCLUDING REMARKS 	 ES-19


Chapter 1: INTRODUCTION TO THE CLEANER TECHNOLOGIES SUBSTITUTES ASSESSMENT  ~

1.1 PROJECT BACKGROUND	1-1

1.2 WHAT IS A CLEANER TECHNOLOGIES SUBSTITUTES ASSESSMENT?	1-2

      CTSA Methodology	1-2

1.3 WHO WILL BENEFIT FROM THIS CTSA?  	1-3

1.4 OVERVIEW OF THE CTSA 	1-3
                                    m

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 Chapter 2: OVERVIEW OF FLEXOGRAPHIC PRINTING
 2.1 INTRODUCTION TO FLEXOGRAPHIC INKS		  2-3
       Ink Components	  .........  	  2-3
       Ink Systems	  2-4

 2.2 MARKET PROFILE OF THE FLEXOGRAPHIC PRINTING INDUSTRY	  2-7
       Descriptions of Different Flexography Market Segments	  2-7
       Market-Related Trends in the Flexographic Printing Industry	  2-11
       Markets for Printing Inks	:		  2-13
       Markets for Flexographic Inks	,	.	  2-16
       Imports and Exports for Flexographic Inks	  2-17

 2.3 FEDERAL REGULATIONS	,	  2-19
       Clean Air Act			.	  2-19
       Resource Conservation and Recovery Act	  2-21
       Toxic Substances Control Act	  2-24
       Clean Water Act	  2-38
       Safe Drinking Water Act	  2-31
       Comprehensive Environmental Response, Compensation, and Liability Act	 ]..	  2-31
       Emergency Planning and Community Right-to-Know Act	  2-32
       Occupational Safety and Health Act	  2-33

 2.4 PROCESS SAFETY ASSESSMENT	,	  2-41
       Safety Hazards of Ink Formulations	'....'	...-....:	  2-41
       Process Safety Concerns	  2-44

 REFERENCES	,	  2-47


 Chapter 3: RISK

 3.1 INTRODUCTION TO RISK	'.	  3-4
       Background	  3-4
       Quantitative Expressions of Hazard and Risk	  3-5
       Definitions of Systemic Toxicity, Developmental Toxicity, and Carcinogenic Effects	  3-6
       Definition of Aquatic Toxicity	..'.'..	 	  3-8

 3.2 HUMAN HEALTH AND ECOLOGICAL HAZARDS	..	  3-9
       Human Health Hazards	';.,.'.	  3.9
       Ecological Hazards				 3-25

 3.3 CATEGORIZATION OF FLEXOGRAPHIC INK CHEMICALS FOR THIS CTSA 	 3-29
       Chemical Categories by Ink Formulation	 3.32

3.4 ENVIRONMENTAL AIR RELEASE ASSESSMENT	 3-36
       Environmental Air Release Methodology		 3-35
       Environmental Air Release Results	 3.37

3.5 OCCUPATIONAL EXPOSURE ASSESSMENT	 3-40
       Occupational Exposure Methodology	 3.40
       Occupational Exposure Results	 3.43
                                          IV

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3.6  GENERAL POPULATION EXPOSURE ASSESSMENT	  3-46
       General Population Exposure Methodology	  3-46
       General Population Exposure Results	  3-49

3.7  RISK CHARACTERIZATION  	  3-52
       Risk Characterization Methodology	  3-52
       Occupational Risk Results	  3-53
       General Population Risk Results	  3-60

REFERENCES	• • •  3'65


Chapter 4: PERFORMANCE	_____	

4.1  METHODOLOGY	 4-4
       Methodology for On-site Performance Demonstrations  	 4-4
       Tests Performed on Samples from Performance Demonstrations and Laboratory Runs 	 4-5
       Inks Used for the Study	  4-11
       Substrates Used forthe Tests	  4-11
       Image and Plates Used forthe Tests	• • • •  4-12
       Types of Printing Performed	•	•	  4-12
       Limitations of the Performance Demonstrations	  4-12
       Methodology for Laboratory Runs	; • •				  4-13

4.2 RESULTS OF PERFORMANCE DEMONSTRATION AND LABORATORY RUN TESTS —
SOLVENT-BASED AND WATER-BASED INKS	  4-17
       Adhesive Lamination — Solvent-based and Water-based Inks		  4-17
       Block Resistance — Solvent-based and Water-based Inks	  4-18
       CIE L*a*b* — Solvent-based and Water-based Inks	  4-18
       Coating Weight — Solvent-based and Water-based Inks	:	  4-20
       Density — Solvent-based and Water-based Inks  	  4-23
       Dimensional Stability — Solvent-based and Water-based Inks  	  4-25
       Gloss — Solvent-based and Water-based Inks	  4-26
       Heat Resistance/Heat Seal — Solvent-based and Water-based Inks	  4-27
       Ice Water Crinkle Adhesion — Solvent-based and Water-based Inks	  4-28
       Image Analysis — Solvent-based and Water-based Inks	  4-29
       Jar Odor — Solvent-based and Water-based Inks 	• •  4-30
       Mottle/Lay — Solvent-based and Water-based Inks ..'...'	  4-32
       Opacity — Solvent-based and Water-based Inks	  4-34
       Rub Resistance — Solvent-based and Water-based Inks  	- - 4-34
       Tape Adhesiveness — Solvent-based and Water-based Inks	 4-35
       Trap _ Solvent-based and Water-based Inks	 4-36
       Highlights of Performance Results for Solvent-Based and Water-Based Inks	 4-38

4.3 RESULTS OF PERFORMANCE DEMONSTRATION AND LABORATORY RUN TESTS —
 UV-CURED INKS	 4-38
       Block Resistance — UV-cured Inks	•	 4-39
       CIE L*a*b* — UV-cured Inks 	:	:	 4-40
       Coating Weight — UV-cured Inks	 4-41
       Coefficient of Friction — UV-cured Inks	•	 4-42
       Density — UV-cured Inks	 4-43
       Dimensional Stability — UV-cured Inks	 4-44
       Gloss — UV-cured Inks	 4-44
       Ice Water Crinkle Adhesion — UV-cured Inks	-	 4-45
       Image Analysis — UV-cured Inks	"•••••	 4-45

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        Jar Odor— UV-cured Inks	,...,	.	..		            4.47
        Mottle/Lay — UV-cured Inks	'.-/.'.'.'.'.'.'.'.''.'.'.'.'.'.'."  4-48
        Opacity — UV-cured Inks	'.'.'.'.'.'.'.'.'.'.	  4-49
        Rub Resistance — UV-cured Inks	'...:'.'.'.'.}''.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.''  4-50
        Tape Adhesiveness — UV-cured Inks	'.'.'.'.'.'.'.'.           4-50
        Trap — UV-cured Inks	'.'.'.'.'.'.'.'.'.'.'.''.'.      4-50
        Uncured Residue — UV-cured Inks	.:...................  4-51
        Summary of Performance Test Results for UV-Cured Inks	'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.  4-51
        Technological Development in UV-cured Inks	'..-..'.'.'.'.'.'.'.'.'.'.'.'/;  4-52

 4.4 SITE PROFILES	                         4.54
        Site 1:  Water-based lnk#W2 on OPP	'."•	"	  4.55
        Site 2:  Water-based lnk#W3 on LDPE and PE/EVA	'.'.'.'.	  4.57
        Site 3:  Water-based Ink #W3 on LDPE and PE/EVA	•••••••  4_gg
        Site 4:  Water-based lnk#W1 on OPP		..	.......       4-61
        Site 5:  Solvent-based Ink #S2 on LDPE and PE/EVA  	         	•••••••      ^^
        Site 6:  UV lnk#U2 on LDPE, PE/EVA, and OPP	     	  4-64
        Site 7:  Solvent-based lnk#S2 on LDPE and PE/EVA  	               	  4-66
        Site 8:  UV Ink #U3 on LDPE, PE/EVA, and OPP	                    ......  ^^
        Site 9A: Water-based lnk#W4 on OPP  	  	  4.70
        Site 9B: Solvent-based lnk#S1 on OPP	            	.-•••••••  ^
        Site 10: Solvent-based lnk#S2 on OPP	             	  4.73
        Site 11: UV lnk#U1 on LDPE (no slip)  	'.'.'.'.'.'.'..'.'.'.  4-75

 REFERENCES	         4-77


 Chapter 5: COST	   •      	,   •    	

 5.1 DEVELOPMENT OF COSTS	 . .  .	  5-3
       Material Costs	'.•...:...'.'."'.'.'.'.'.'.'.'.'.  5-3
       Labor Costs	" ]  5.7
       Capital  Costs for New Presses	;. 5.10
       Capital  Costs for Retrofitting a Press				'.'.'.'.'.'.'.'.'.'.'.'.'. 5-13
       Energy  Costs		......... 5-15
       Uncertainties			'.•'.'.'/.'.'.]'.'.'.'.'.'.'.'. 5-15

 5.2 COST ANALYSIS RESULTS	 5-17
       Summary of Cost Analysis Results 	;	' [ 5.^7
       Discussion of Cost Analysis Results 	,	' 5.20

 5.3 DISCUSSION OF ADDITIONAL COSTS	  . 5-24
       Regulatory Costs	 5-24
       Insurance and Storage Requirements	 5-25
       Other Environmental Costs and Benefits	  5-25

 REFERENCES	  5-26

ADDITIONAL REFERENCES	  5.27
                                          VI

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Chapter 6: RESOURCE AND ENERGY CONSERVATION
6.1  INK AND ADDITIVE CONSUMPTION	 6-3
      Methodology	 6-3
      Limitations and Uncertainties	•	 6-5
      Ink and Additive Consumption Estimates	,	 6-6

6.2  ENERGY CONSUMPTION	 6-10
      Methodology	 6-10
      Limitations and Uncertainties	•• • • 6-16
      Energy Consumption Estimates	-	 6-17

6.3  ENVIRONMENTAL IMPACTS OF ENERGY REQUIREMENTS ...:..	 6-23
      Emissions from Energy Production  	 6-23
      Environmental Impacts of Energy Production		•	 6-25
      Limitations and Uncertainties	 6-25
      6.4  CLEAN-UP AND WASTE DISPOSAL PROCEDURES	 6-28
      Press Clean-Up and Waste Reduction in the CTSA Performance Demonstrations
                                                                     	 6-29
REFERENCES		• •	•	 Q-31


Chapter 7: ADDITIONAL IMPROVEMENT OPPORTUNITIES	

7.1  POLLUTION PREVENTION OPPORTUNITIES 	  7-3

7.2 RECYCLING AND RESOURCE RECOVERY	•  7-8
       Silver Recovery	•- • • •  7-8
       Solvent Recovery	•	• • •.;	  7-8
       Solid Waste Recycling 	•••••  7-8

7.3 CONTROL OPTIONS	•	  J^
       Sources of Flexographic Ink Pollutants Amenable to Treatment or Control Options	  7-9
       Control Options and Capture Devices for Air Releases	  7-10
       Control Options for Liquid Releases	•	  7-12

REFERENCES	  7"14


Chapter 8: CHOOSING AMONG INK TECHNOLOGIES		

8.1 SUMMARY BY INK SYSTEM AND PRODUCT LINE	  8-2
         Introduction	'	  8~~
         Solvent-based Inks  	•	  °'];
         Water-based Inks	  °'^
         UV-cured Inks	•. • •  8'20

 8.2 QUALITATIVE SOCIAL BENEFIT-COST ASSESSMENT	  8-24
         Introduction to Social Benefit-Cost Assessment	  8-24
         Benefit-Cost Methodology and Data Availability	  8-26
         Potential Private and Public Costs 	  8-26
         Potential Private and Public Benefits	  8-31
         Summary of Social Benefit-Cost Assessment 	  8-34
                                          vn

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8.3 DECISION INFORMATION SUMMARY
        Introduction  	...'...
8-36
8-36
        Ink System Comparison  	'.,.,	  ^   	•••-...  ^^
        Highlights of Chemical Category Information	 ".  '.''.'.	        8-41
        Hazard, Risk and Regulation of Individual CTSA Chemicals ...............   :	  8-46
        Suggestions for Evaluating and Improving Flexographic Inks .'..'.'.'.'.'.'.'.'.'.'.'.'.'.'.	'  8-63
REFERENCES
                                                                                   8-66
                                        vm

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                VOLUME 2: APPENDICES TO ALL CHAPTERS
Appendices to Chapter 3: RISK
Appendix 3-A: Flexographic Ink Formulations and Structures
Appendix 3-B: Human Health and Ecological Hazard Results
Appendix 3-C: Supplementary Environmental Air Release Information
Appendix 3-D: Environmental Air Release Data
Appendix 3-E: Supplemental Occupational Exposure Assessment Methodology
Appendix 3-F: Occupational Exposure Data
Appendix 3-G: Supplementary General Population Exposure Information
Appendix 3-H: General Population Exposure Data
Appendix 3-1: Systemic Toxicity Risk Results
Appendix 3-J: Developmental Toxicity Risk Results
Appendix 3-K: Summary of Occupational Systemic Toxicity Risk — Dermal
Appendix 3rL: Summary of Occupational Systemic Toxicity Risk — Inhalation
Appendix 3-M: Summary of Occupational Developmental Toxicity Risk — Dermal
Appendix 3-N: Summary of Occupational Developmental Toxicity Risk — Inhalation
Appendix 3-O: Summary of General Population Systemic Toxicity Risk — Inhalation
Appendix 3-P: Summary of General Population Developmental Toxicity Risk — Inhalation
Appendices to Chapter 4: PERFORMANCE	.      	,	

Appendix 4-A: Overall Performance Demonstration Methodology
Appendix 4-B: Facility Background Questionnaire
Appendix 4-C: Performance Demonstration Data Collectipn Form
Appendix 4-D: Test Image Design
Appendix 4-E: Laboratory Test Procedures and Performance Data
Appendix 4-F: Anilox Configuration Data from the Performance Demonstrations
Appendix 4-G: Surface Tension Data from the Performance Demonstrations
Appendix 4-H: Viscosity Data from the Performance Demonstrations
Appendix 4-1: Descriptions and Test Data  for Performance Demonstration Sites
Appendix 4-J: Descriptions and Performance Test Data for the Laboratory Runs
Appendix 4-K: Performance Test Data from Laboratory Runs for Inks Not Used in the Performance
Demonstrations

Appendices to Chapter 5: COST		.	

Appendix 5-A: Cost Analysis Methodology
Appendix 5-B: Supplemental Cost Analysis Information


Appendices to Chapter 6: RESOURCE AND ENERGY CONSERVATION	

Appendix 6-A: Supplemental Resource and Energy Conservation Information
Appendix 6-B: Glean-Up and Waste Disposal Procedures for Each Site
Appendix 6-C: Pollution Generation Reports
                                            IX

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                                     Preface
This draft report, Flexographic Ink Options: A Cleaner Tzchnologies Substitutes Assessment, presents the
findings and analysis of a voluntary, cooperative effort between the flexographic printing industry and the
U.S. EPA.  This is not an official guidance document and should not be relied on by companies in the
printing industry to determine regulatory requirements. Information on cost and product usage in this
document was provided by individual product vendors and has not been corroborated by EPA. Mention
of specific company names or products does not constitute an endorsement by EPA.

Comments are welcome on all aspects  of the draft CTSA. Please send comments by November 30, 2000,
to:

       Karen Chu
       Design for the Environment Program
       Office of Pollution Prevention and Toxics
       U.S. Environmental Protection Agency
       1200 Pennsylvania Avenue, NW
       Mail Code 7406
       Washington, DC 20460
       e-mail: chu.karen@epa.gov

To learn more about EPA's Design for the Environment Program, please visit www.epa.gov/dfe. You may
download and print copies of DfE documents directly from the website. To order additional printed copies
of this document or other DfE publications, please contact:

       EPA's Pollution Prevention Information Clearinghouse (PPIC)
       U.S. Environmental Protection Agency
       1200 Pennsylvania Avenue, NW
       Mail Code 7409
       Washington, DC 20460
       Phone:  (202)260-1023
       Fax: (202)260-4659
       E-mail: ppic@epa.gov
                                             XI

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                          Acknowledgments
DfE would like to thank its many partners for their participation in the Flexography Project.

    •    Members of the Steering and Technical Committees (see separate lists that follow) provided
         valuable guidance and feedback throughout the project.

    •    Volunteer printers and suppliers (see separate list that follows) contributed much time, expertise,
         materials, and the use of their facilities; their cooperation was essential to the project.

    •    Lori Kincaid of the University of Tennessee Center for Clean Products and Clean Technologies
         analyzed the data on energy and resource conservation.

    •    John Serafano of Western Michigan University attended the performance demonstrations,
         supervised the laboratory runs, and analyzed the  performance data.

    •    Laura Rubin, formerly of Industrial Technology  Institute, contributed to the cost analysis.

    •    Members of the EPA Workgroup contributed significantly, especially to the  risk,  cost, and
         benefit-cost analyses. The Workgroup consisted  of the following individuals: Susan Dillman,
         Conrad Flessner, Jr., Eric Jackson, Susan Krueger, David Lai, Fred Metz, and Jerry Smrchek.

    •    This document was prepared by Susan Altman, Dennis Chang, Cheryl Keenan, Harry (Trey)
         Kellett III, and Srabani Roy of Abt Associates, Inc. under EPA Contract 68-W6-0021, Work
         Assignments 3-07, 4-05, and 5-08.
                                             Xlll

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XIV

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                       Steering  Committee
Robert Bateman
Roplast Industries
3155 South 5th Avenue
Oraville, CA 95965
phone: 530-532-95000
fax: 530-532-9576
rbateman@roplast.com

Karen Chu
U.S. EPA
1200 Pennsylvania Avenue, NW
Mail Code 7406
Washington, DC 20044
phone: 202-260-0695
fax: 202-260-0981
chu. karen@epa. gov

Norma Fox
CFECA
2402 Vista Nobleza
Newport Beach,  CA 92660
phone:  949-644-7659
fax: 949-640-9911
nsfox@earthlink.net

George Fuchs
National Association of Printing Ink
Manufacturers
581 Main St.
Woodbridge, NJ 07095-1104
phone: 732-855-1525fax: 732-855-1838
gfuchs@napim. org
Doreen Monteleone
Flexographic Technical Association
900 Marconi Avenue
Ronkonkoma, NY 11779-7212
phone: 631-737-6020
fax: 631-737-6813
dinonteleone@flexography.org

Alex Ross
RadTech International, N.A.
400 North Cherry
Falls Church, VA 22046
phone:  703-534-9313
fax: 703-533-1910
rossradtec@aol.com

Mark Wygonik
Flexible Packaging Association
1090 Vermont Avenue, NW Suite 500
Washington, DC 20005
phone:  202-842-3880
fax: 202-842-3841
mwygonik@flexpack.org
                                          -xv-

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-XVI-

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                     Technical  Committee
A.J. Daw Printing Ink Co.
    Jim Daw
    Rex Tamm
Abt Associates Inc.
    Cheryl Keenan
American Inks and Coatings
    Robert Anthony
Anguil Environmental Systems, Inc.
    Lee Kottke
Automated Packaging
    Paul Banfield
Bema Film Systems, Inc.
    Michael Siciliano
Bryce Corporation
    Bob  Hawkins
    John Yeganeh
Cello-Foil Products, Inc.
    Rieger Lesiow
Coast Converters
    Sol Schor
Curwood, Inc.
    Howard Hofmeister
Deluxe Packages
    Steve Steckbauer
Dispersion Specialties, Inc.
    William Webster
DuPont Cyrel
    Alice Missimer
Duralam, Inc.
     D. Dennis Redding
Emerald Packaging
     Ron Garriety
 Enercon Industries Corp
     Dave Markgraf
 Fine Line Graphics
     Jim Toles
 Flint Ink
     Michael  MacDonald
     Dr. Chris Patterson
 Fusion UV Systems, Inc.
     David Snyder
 Georgia-Pacific
     Dave Root
 Hallmark Cards
     John M. Sandefur
Harper Corporation of America
    Dan Reilly
Highland Supply Corporation
    Gene Wall
Huron River Watershed Council
    Laura Rubin
International Paper
    James Manning
INX International Ink Co.
    Michael Hines
    Robert Ramsay
    Jim Stein
    John Vogel
Kidder, Inc.
    Mark Dallmeyer
MacDermid Graphic Arts
    D. Bradley Miller
    Linda Weglewski
Maine Poly, Inc.
    Robert Neal
MEGTEC Systems
    Dan Bemi
    Steve Rach
Orange Plastics
    Carmello Pireano
Pechiney Plastic Packaging
    David Ellison
P-F Technical Services, Inc.
    Fred Shapiro
Precision Printing & Packaging, Inc.
     Michael A. Klekovic
Printpack, Inc.
     Doug Cook
     Tom Dunn
 Progressive Inks
     David Argent
     Paul Lodewyck
 Research Triangle Institute
     Dean Cornstubble
 SC Johnson Polymer
     Rick Grandke
 Sericol
     Jack Wald
 Strout Plastics
     Thomas Everett
                                          -xvii-

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 Sun Chemical Corporation
     Sam Gilbert
     Robert Mullen
     Brijesh Nigam
     William Rusterholz
     Richard Wagner
 U.S. EPA
     Chuck Darvin
     Carlos Nunez
     David Salman
    Kay Whitfield
UCB Chemicals
    Peter Weissman
University of Tennessee
    Lori Kincaid
Waste Management and Research Center
    Debra Jacobson
Western Michigan University
    John Serafano
                                        -XVlll-

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       Participating  Suppliers  and  Printers

The following companies voluntarily supplied materials for this CTSA or participated in the project's
performance demonstrations.
             A. J. Daw Printing Ink Company
             Akzo Nobel Inks Corp.
             Automated Packaging
             Bryce Corporation
             Cello-Foil Products
             Deluxe Packages
             E.I. du Pont de Nemours & Co.
             Emerald Packaging
             Enercon Industries
             Fine Line Graphics
             Flex Pack
             Flint Ink
             Harper Corporation of America
             INX International
             Lawson Mardon Packaging USA
             MacDermid Graphic Arts
             Maine Poly
             Mobil Chemical Corp.
             Progressive Inks
             Roplast Industries
             Sun Chemical Corporation
             Windmoeller & Hoelscher Corp.
                                       -xix-

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          Abbreviations Used in  the CTSA
ADC
ADD
BACT
BCM
BOD
CAA
CAS
CBI
CERCLA
CESQG
CTG
CTSA
CWA
DfE
EPA
EPCRA
FOG
FPA
FTA
FWPCA
HAP
HQ
HSWA
IARC
LDPE
LEPC
LOAEL
LQG
MACT
MEK
MIBK
MOE
MSDS
NAICS
Average Daily Concentration
Average Daily Dose
Best Available Control Technology
Billion Cubic Microns per Square Inch
Biological Oxygen Demand
Clean Air Act
Chemical Abstracts Service Registry Number
Confidential Business Information
Comprehensive Environmental Response, Compensation, and Liability Act
Conditionally Exempt Small Quantity Generator
Control Technology Guidelines
Cleaner Technology Substitutes Assessment
Clean Water Act
Design for the Environment
Environmental Protection Agency
Emergency Planning and Community Right-to-Know Act
Fat/Oil/Grease
Flexible Packaging Association
Flexographic Technical Association
Federal Water Pollution Control Act
Hazardous Air Pollutant
Hazard Quotient
Hazardous and Solid Waste Amendments
International Agency for Research on Cancer
Low-Density Polyethylene
Local Emergency Planning Commission
Lowest Observed Adverse Effect Level
Large Quantity Generator
Maximum Achievable Control Technology
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Margin of Exposure
Material Safety Data Sheet
North American Industry Classification System
                                        -xxi-

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  NAPEM
  NCP
  NESHAP
  NOAEL
  NPDES
  OPP
  OPPT
  OSHA
  PE/EVA
  POTW
 PTE
 RACT
 RCRA
 RfC
 RfD
 SARA
 SDWA
 SERC
 SIC
 SQG
 TRI
 TSD
 TSS
UST
VOC
  National Association of Printing Ink Manufacturers
  National Oil and Hazardous Substances Pollution Contingency Plan
  National Emissions Standards for Hazardous Air Pollutants
  No Observed Adverse Effect Level
  National Pollution Discharge Elimination System
  Oriented Polypropylene
  Office of Pollution Prevention and Toxics
  Occupational Safety and Health Administration
  Polyethylene/Ethylvinyl Acetate
  Publicly Owned Treatment Works
  Permanent Total Enclosure
 Reasonably Achievable Control Technology
 Resource Conservation and Recovery Act
 Reference Concentration
 Reference Dose
 Superfund Amendments and Reauthorization Act
 Safe Drinking Water Act
 State Emergency Response Commission
 Standard Industrial Classification
 Small Quantity Generator
 Toxics Release Inventory
 Treatment, Storage, and Disposal (facility)
 Total Suspended Solids
Underground Storage Tank
Volatile Organic Compound
                                         -xxii-

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                                     Glossary
Acetate
Acrylate
Acute exposure

Additive
Adhesion

Adhesive

Adsorbent

Adsorption

Ambient environment
Amide
Anilox roll

Anilox volume

Aquatic toxicity
Benefit
 Best Available Control
 Technology (BACT)
 Block resistance
a family of solvents also known as esters of acetic acid
a chemical functional group commonly used in UV curing
one dose or multiple dose exposures occurring over a short time (24
hours)
a substance used in small quantities to modify the properties of an ink
state in which two surfaces are held together by molecular forces;
measure of the strength with which one material sticks to another
any material that is applied to one or more surfaces to form a bond
between the two
material (e.g., carbon) that adsorbs (concentrates) a substance on its
surface
accumulation of a gaseous, liquid, or dissolved substance on the
surface of a solid
the existing conditions in the environment or immediate vicinity
a nitrogen-containing compound that usually is basic (alkaline)
engraved steel and chrome-coated metering roll to control the amount
of ink sent from the fountain roller to the printing plates
the volume of cells on an anilox roll hi a standardized area, expressed
as billion cubic microns per square inch (BCM)
capability of a substance to cause adverse effects in aquatic organisms
the value to society of a good or  service. From a firm's perspective,
the benefit of a good or service can be measured by the revenue the
firm receives from its sales as compared to the costs incurred when
producing its products. From the consumer's perspective, the benefit
can be measured by what the consumer would be willing to pay for the
good or service. Some goods  and services, such as environmental
 amenities and health risk reductions, are not generally for sale in a
 market economy. However, these goods and services do provide
 benefits to society which should be recognized.  Economists attempt to
 estimate the value of these goods and services through various
 nonmarket valuation methods.
 an emission limitation based on the maximum degree of emission
 reduction (considering energy, environmental, and economic impacts)
 achievable through application of production processes and available
 methods, systems, and techniques; (EPA) the most stringent
 technology available for controlling emissions; major sources are
 required to use BACT, unless it can be demonstrated that it is not
 feasible for energy, environmental, or economic reasons.
 a type of performance test that measures the bond between ink and
  substrate when heat and pressure are applied
                                             -XXlll-

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   Blocking


   Caliper


   Carcinogen

   Carcinogenic effect


   Catalyst


  Catalytic oxidizer
  Cationic ink


  Central impression printing
  press
  Chill roller


  Coating


  Co-extruded
  polyethylene/ethyl vinyl
  acetate (PE/EVA)

  Co-extrusion


 Colorant


 Control option
 Conventional pollutant




 Core


 Corona treater


Corrosivity

Cross-linker
   undesired adhesion between layers of material that may cause damage
   to at least one surface upon their separation

   the thickness of a sheet or material measured under specific
   conditions, expressed in thousandths of an inch
   cancer-causing chemical

   malignant tumor or other manifestation of abnormal cell growth caused
   by cancer

   a substance that accelerates the rate of a reaction between two or more
   substances without being consumed in the process
  type of oxidizer that contains a catalyst

  a type of UV-cured ink in which photoihitiators start the reaction by
  causing an electron deficiency in the monomers and oligomers

  printing press in which the material being printed is in continuous
  contact with a single-large diameter impression cylinder; the color
  stations are arranged around the circumference of the cylinder and
  imprint the image on the substrate      .

  metal roll or drum with internal cooling, used to cool the printed web
  prior to rewinding

  the outer covering of a film or web; the film may be coated on one or  '
  both sides

  a type of film substrate used in flexographic printing



  a process used to produce a product, such as a film substrate, by
  forcing more than one extruder through a common die
 a substance that provides the color associated with ink;  it can be a
 pigment or a dye

 add-on technological system or device that removes pollutants from a
 flexographic facility's waste stream and thereby keeps them out of air,
 water, and landfills; pollutants may be captured for reuse, recycling
 or disposal    .    •                                       .     '

 a pollutant chemical in wastewater effluent regulated under the Clean
 Water Act (CWA); includes biological oxygen demand (BOD), total
 suspended solids (TSS), fecal coliform bacteria, fat/oil/greases (FOG)
 andpH

 a tube on which paper, film, or foil is wound for shipment; the metal
 body of a roller which is rubber .covered

 equipment that electrically charges the. substrate to improve ink
 adhesion by raising the surface tension of the substrate
capability of corroding

a component of UV-cured. inks.  Such as a monomer or oligomer, that
is capable of reacting to form a solid coating
                                            -xxiv-

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Cure


Curing agent

Dermal exposure
Developmental toxicity


Die

Diluent

Direct medical costs
Dispersant

Dispersion


Doctor blade


Dose-response assessment



Dot gain

Dye
                   5 '   '  ' ' ' '

Electrolytic silver recovery



Exposed population
process of treating inks with ultraviolet light which creates a bond
between the monomers and oligomers in the ink; the reaction (or
"drying") causes the ink to solidify and bind with the substrate
a chemical that participates in the reaction that results in the curing of
UVinks      .
exposure through the skin                                .
.adverse effects caused to a developing organism from exposure to a
substance prior to conception, during prenatal development, or
postnatally up to the time of sexual maturation
any of various sharp cutting forms, used to cut desired shapes  from .
papers, paperboard, plastics or other stocks
a liquid with, no solvent action, used to dilute or thin an ink or lacquer;
a type of extender
costs associated specifically with the identification and  treatment of a
disease or illness (e.g., costs of visits to the doctor, hospital costs,
costs of drugs). Discounting: Economic analysis procedure by which
monetary valuations of benefits and/or costs occurring  at different
times are  converted into present values which can be directly
compared to one another.
material that enables a uniform distribution of solid particles
a uniform distribution  of solid particles  in a vehicle by mixing or
milling                             "
a thin flexible blade that grazes the anilox roll at an angle to remove
excess ink from the roll before the ink is applied to the printing plate
in a risk assessment, 'the relationship between the dose of the chemical
received and the incidence and severity of the adverse health effects in
the exposed population      .   •    .
the undesired increase in size of a printed "dot" of ink
coloring material which is soluble in an ink vehicle, as opposed to
pigments, which are not soluble, and must be dispersed
method of silver recovery whereby a current is passed between two
electrodes in silver-laden water, plating the silver on the cathode in a
virtually pure form
the estimated number of people from the general public or a specific
population group who are exposed to a  chemical, process, and/or
technology. The general public could be exposed to a chemical
through wide dispersion of a chemical in the environment (e.g.,
DDT). A specific population group could be exposed to a chemical
due to its physical proximity to a manufacturing facility (e:g.,
residents who live near a  facility using a chemical), through the use of
the chemical or a product containing a chemical, or through other
means.           ,
                                              -xxv-

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  Exposed worker population
  Exposure assessment
 Epoxy resin

 Extender
 External benefits
 External costs
 Externality
Extrusion

Flaniniability
Flexible packaging
  the estimated number of employees in an industry exposed to the
  chemical, process, and/or technology under consideration. This
  number may be based on market share data as well as estimations of
  the number of facilities and the number of employees in each facility
  associated with the chemical, process, and/or technology under
  consideration
  in risk assessment, identification of the pathways of which toxicants
  may reach individuals, estimation of how much of a chemical an
  individual is likely to be exposed to, and estimation of the number of
  people likely to be exposed
  plastic or resinous materials used for strong, fast-setting adhesives, as
  heat resistant coatings and binders
  any material added to inks to reduce its color strength and/or viscosity
 a positive effect on a third party who is not part of a market
 transaction.  For example, if an educational program (i.e., a smoking-
 cessation class) results in behavioral changes which reduce the
 exposure of a population group to a disease (i.e., lung cancer),  then an
 external benefit is experienced by those members of the group who  did
 not participate in the educational program (i.e., those inhaling second-
 hand smoke). External benefits also occur when environmental
 improvements enhance enjoyment of recreational activities (e.g.,
 swimming, hiking, etc.).
 a negative effect on a third party who is not part of a market
 transaction. For example, if a steel mill emits waste into a river which
 poisons the fish in a nearby fishery, the fishery experiences an
 external cost to restock as a consequence of the steel production. Other
 examples of external costs are the effects of second-hand smoke on
 nonsmokers, increasing the incidence of respiratory distress, and a
 smokestack which deposits soot on someone's laundry, thereby
 incurring costs of relaundering.
 a cost or benefit that involves a third party who is not a part of a
 market transaction; "a direct effect on another's profit or welfare
 arising as an incidental by-product of some-other person's or firm's
 legitimate activity" (Mishan, 1976). The term "externality" is a
 general term which can refer to either external benefits or external
 costs.
 the production of a continuous product (e.g., a sheet of film) by
 forcing a material (e.g., thermoplastic) through a die or orifice
the capability of burning
any package or part of packaging with a thickness of ten millimeters or
less whose shape can be; changed readily
Flexographic printing plate   a plate with a raised image that prints on the desired substrate
                                             -xxvi-

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Formulation

Fountain
Fountain roll

Four-color process


Free radical

Free radical curing

Fugitive emissions

Hazard

Hazard identification
Hazard quotient
 Hazardous
 Hazardous Air Pollutant
 (HAP)
 Hazardous waste
 Hazardous waste generator
 Human health benefits
 Human health costs
a specific color (e.g., Reflex blue) within an ink product line used in
the CTSA (e.g., solvent-based ink#l)
a pan or trough on a press that serves as a reservoir for ink
a press roll that picks' up ink or coating material from the fountain and
applies it to the transfer roll
printing with cyan, magenta, and yellow color inks plus black, and
using combinations of these colors to create all other colors (see
process printing)
an unstable, reactive molecule that has a neutral charge (in comparison
to an ion)
a type of UV-cured ink in which the photoinitiators release reactive
free radicals
emissions that escape from the printing press and leave the facility
through openings such as windows and doors
potential for a chemical or other pollutant to cause human illness or
injury; the inherent toxicity of a compound
in a risk assessment, determining whether exposure to  a chemical
could cause adverse health effects in humans or in nature; an informed
judgment based on verifiable toxicity data from animal models or
human studies
the ratio of estimated site-specific exposure to a single  chemical over a
specified period to the estimated daily exposure level at which no
adverse health effects are likely to occur
harmful to human health and the environment
air pollutants listed under the Clean Air Act (CAA) as  being hazardous
to human health and the environment
by-products of industrial activities that can pose a substantial or
potential hazard to human health or the environment when improperly
managed
a facility that produces hazardous waste
reduced health risks to workers in an industry or business as well as to
the general public as a result of switching to less toxic or less
hazardous chemicals, processes, and/or technologies. An example
would be switching to a less volatile chemical or a new method of
storing or using a volatile, hazardous chemical, to reduce the amount
of volatilization, thereby lessening worker inhalation exposures as well
as decreasing the formation of photochemical smog in the ambient air.,
the cost of adverse human health effects associated with production,
consumption and disposal of a firm's product.  An example is the cost
to individuals and society of the respiratory effects caused by stack
emissions, which can be quantified by analyzing the resulting costs of
health care and the reduction in life expectancy, as well as the lost
wages as a result of being unable to work.
                                             -XXVll-

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  Ignitability
  Illness costs
  Incineration
  Indirect medical costs
  Individual risk

  Inhalation exposure
  Ink pan
  Ink splitter


  In-line printing press


 Ion exchange

 Laminate
 Line color printing
 Liquid ink
 Low-density polyethylene
 (LDPE)
 Lowest Observed Adverse
 Effect Level (LOAEL)
 Major Source
Makeready
   capability of lighting on fire
   a financial term referring to the liability and health care insurance
   costs a company must pay to protect itself against injury or disability
   to its workers or other affected individuals. These costs are known as
   illness benefits to the affected individual. Appendix J summarizes
   several cost of illness valuation methods.
   the process of burning to ashes with the intent of reducing harmful
   substances to more benign ones
   indirect medical costs associated with a disease or medical condition
   resulting from exposure to a chemical, product or technology.
   Examples would be the costs of decreased productivity of patients
   suffering a disability or death and the value of pain and suffering
   borne by the afflicted individual and/or family and friends.
   an estimate of the probability of an exposed individual experiencing an
  adverse effect, such as "1  in 1,000" (or 10) risk of cancer.
  exposure through breathing
  reservoir for ink
  a device that separates solids from fluids in waste ink and cleaning
  solutions, or removes pigments from water-based ink wastes using a
  porous cellulose material
  a multicolored press in which the color stations are mounted
  horizontally in a line; a press coupled to another operation such as
  bagmaking, sheeting, diecutting, creasing, etc.
  method of recovering silver from wash water Or mixtures of wash
  waters, fixer and bleach fix, especially from dilute solutions
  to bond together two or more layers of material or materials
 process of printing 'line work1 such as text, display type and graphics
 low-viscosity ink
. type of film substrate used for printing on packaging such as frozen
 food bags
 lowest exposure level at which adverse effects to human health and/or
 the environment have been shown to occur
 under Title V of the Clean Air Act, a facility that has the potential to
 emit 10 tons per year or more of any individual Hazardous Air
 Pollutant (HAP), 25 tons per year or more of any combination of
 HAPs, or 100 tons per year or more of any air pollutant.  The 100
 TPY limit applies to facilities located in areas with relatively good air
 quality ("attainment areas"); the limit decreases in non-attainment
 areas.

the preparation and correction of the printing plate before starting the   <-
print run, to insure uniformly clean impressions; all preparatory
operations preceding production
                                            -XXVlll-

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Margin of exposure (MOE)

Material Safety Data Sheet
(MSDS)
Maximum Achievable
Control Technology (MACT)

Metallic replacement
Monomer

Narrow web press
National Emission Standards
for Hazardous Air Pollutants
(NESHAP)
Net benefit
No Observed Adverse Effect
Level (NOAEL)

Non-conventional pollutant

Oligomer

Opportunity cost
 Oral exposure
 Oral toxicity
the ratio of the no-observed-adverse-effect-level (NOAEL) to the
estimated exposure dose
a compilation of information required under the Occupational Safety
and Health Administration (OSHA) Communication Standard on the
identity of hazardous chemicals, health and physical hazards, exposure
limits, and precautions of a product
the emission standard for sources of air pollution requiring the
maximum reduction of hazardous emissions, taking cost and feasibility
into account
method of silver recovery whereby wastewater is passed through one
or more steel wool filters in which silver in the wastewater is
chemically replaced by  iron from the filter
an individual molecular unit that is capable of linking together to form
polymers
any printing press web that is less than 24 inches wide; narrow web
presses are able to do multiple converting operations (e.g., diecutting)
in the same pass with the printing
emissions standards set by EPA for air pollutants that may cause an
increase in fatalities or in serious, irreversible, or incapacitating illness

the difference between the benefits and the costs. For a company this
could be interpreted as revenue - costs, assuming that the revenue and
the costs are fully determined.
the highest exposure level that can occur without statistically or
biologically significant adverse effects  to human health and/or the
environment
any wastewater effluent pollutant regulated under the Clean Water Act
(CWA) that is not identified as a conventional or priority pollutant
a low-weight polymer that is capable of further combination; the
component of UV-cured inks that links together to form a solid coating
a hidden or implied cost incurred due to the use of limited resources
such that they are not available for an alternative use. For example,
the use of specific laborers in the production of one product precludes"
their use in the production of another product. The opportunity cost to
the firm of producing the first product is the lost profit from not
producing the second. Another example would be a case where in
hiring legal representation to respond to a lawsuit, and due to limited
financial resources, a firm must cancel a planned expansion. The
opportunity cost of responding to the lawsuit is the lost gain from not
expanding.
exposure through eating or drinking contaminated substances
ability of a chemcial to cause injury when ingested
                                             -xxix-

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  Oriented polypropylene
  (OPP)
  Overprinting
  Oxidation

  Oxidizer

  Ozone


 Paste ink
 Permanent total enclosure

 Photoinitiator

 Photopolymer

 Pigment
 Pinholing

 Plasticizer

 Pollution prevention


 Polyethylene

 Polymer
 Polymerization

Polypropylene

Population risk
  a film substrate noted for clarity, stiffness, and ability to form a strong
  barrier
  the printing of one impression over another
  the reaction of a chemical (such as VOCs) with oxygen; the process of
  combining with oxygen
  equipment that burns contaminated air to break down harmful
  substances (e.g., VOCs) into water, carbon dioxide and other gases
  a gas containing three oxygen molecules; at ground level it is a
  pollutant formed in part by the reaction of volatile organic compounds
  (VOCs) released by solvent-based inks; contributes to smog formation
  high-viscosity ink
  a structure that completely surrounds a source of air emissions,
 captures all VOC emissions, and sends them to a control device
 the component of UV-cured inks that reacts  with ultraviolet light to
 begin the curing process
 any mixture of materials that can change its own physical properties
 on exposure to ultraviolet or visible light
 insoluble substance used to give color to inks, paints and plastics
 failure of a printed ink to form a complete continuous  film; visible in
 the form of small holes in the printed area
 material (usually in liquid form) that is added to ink to improve the
 flexibility of dried ink
 identification of substances, processes, and activities that create-
 excessive waste products or pollutants, followed by reductions in
 pollution generation by altering or eliminating a process or materials
 a synthetic resin of high molecular weight resulting from the
 polymerization of ethylene gas under pressure.
 a compound formed by the linking together of simple molecules
 a chemical reaction in which the molecules of a monomer are linked.
 together to form large molecules
 a synthetic resin of high molecular weight resulting from the
polymerization of propylene gas
an aggregate measure of the projected frequency of effects among all
exposed people, such as "four cancer cases per year."
                                             -xxx-

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Present value
Press-side solvent or additive

Primer
Priority pollutant

Private (internalized)
benefits
Private (internalized) costs
Process color printing
Product line
Propylene
Publicly Owned Treatment
Works (POTW)
Reactive diluent

Reactivity
Reasonably Available
Control Technology (RACT)
Recycling
 Reducer
the value in today's terms of a sum of money received in the future.
Present Value is a concept which specifically recognizes the time value
of money, i.e., the fact that $1 received today is not the same as $1
received in ten years time. Even if there is no inflation, $1 received
today can be invested .at a positive interest rate (say 5 percent), and
can yield $1.63 in ten years; $1 received today is the same as $1.63
received ten years in the future. Alternately, the present value of $1
received in ten years is $0.61. The rate at which future receipts are
converted into present value terms is called the discount rate
(analogous to the interest rate given above). The formula for
calculating present value is given in the Cost Analysis module.
a product added to ink during a press run to improve the printing
performance (e.g., to decrease viscosity)
a first coat intended to enhance subsequent printing
a toxic chemical found in wastewater effluent and regulated ujnder the
Clean Water Act (CWA)                                    .  .
the direct gain received  by industry  or consumers from their actions in
the marketplace. One example includes the revenue a firm obtains in
the sale of a good or service. Another example is the satisfaction a
consumer receives from consuming  a good or service.
the direct negative effects incurred by industry or consumers from
their actions in the marketplace. Examples include a firm's cost of raw
materials and labor, a firm's costs of complying with environmental
regulations, or the cost to a consumer of purchasing a product.
halftone color printing created by the color separation process; a piece
of copy is broken down to the primary colors to produce individual
halftones, whith are then recombined at the press to replicate the full
range of colors
a group of proprietary inks that are  made by one manufacturer, share
certain printing characteristics, include multiple colors, and are
intended for use with a specific ink  system (e.g., solvent-based)
gas used in polymerization to form polypropylene
a municipal or regional  water treatment plant

a material in UV-cured  inks that reduces the viscosity of the ink and
reacts instead of volatilization upon curing                        ;  "
property of being able to decompose or react with other chemicals
technology required under the Clean Air Act to regulate the emissions
of volatile organic compounds
the practice of reducing environmental wastes by recovering and
reprocessing waste materials, thereby reducing the use of virgin
materials
material used to alter the body, viscosity or color strength of ink
                                              -xxxi-

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 Reference concentration


 Reference dose


 Repeat length

 Reportable quantity


 Reproductive toxicity

 Resin


 Reverse printing

 Risk


 Risk characterization


 Scuffing
 Silver recovery
 Smog-related emissions



 Social benefit
Social cost
  lowest daily human exposure measured by continuous inhalation that
  does not have an appreciable risk of deleterious, non-cancerous effects
  during a lifetime                     .
  estimate of the lowest daily human exposure that does not have an
  appreciable risk of deleterious, non-cancerous effects during a lifetime
  (expressed as an oral dose per kilogram of body weight)
  printing length of a plate cylinder, determined by one complete
  revolution of the plate cylinder gear
  substance-specific amount of hazardous material reportable under the
  Comprehensive Environmental Response, Compensation, and Liability
  Act (CERCLA)
  biologically adverse effects on the female or male reproductive organs,
  the related endocrine system, or offspring
  natural or synthetic complex organic substance with no distinct melting
 point, which in a solvent solution forms the binder portion of the
  flexographic ink
 printing on the underside of a transparent film; or a design in which an
 image or type is "dropped-out"  and the background is printed
 a measure of the probability that damage will occur to life, health,  or
 some aspect of the environment as a result of exposure to a given
 hazard
 in risk assessment, the process of using hazard, dose-response, and
 exposure information to develop quantitative and qualitative
 expressions of risk
 action of rubbing something against a printed surface
 process by which silver is recovered from printing wastewater
 gases, such as volatile organic compounds (VOCs),  carbon monoxide,
 and nitrogen oxides (NOX), that are released during printing or energy
 production operations and contribute to the formation of smog when
 exposed to sunlight
 the total benefit of an activity that society receives, i.e., the sum of the
 private benefits and the  external benefits. For example, if a new
 product prevents pollution (e.g., reduced waste in production or
 consumption of the product), then the total benefit to society of the
 new product is the sum of the private benefit (value of the product that
 is reflected in the marketplace) and the external benefit (benefit society
 receives from reduced waste).
 the total cost of an activity that is imposed on society. Social costs are
 the sum of the private costs and the external  costs. Therefore, in the
 example of the steel mill, social costs of steel production are the sum
 of all private costs (e.g., raw material and labor costs) and the sum of
 all external costs (e.g., the costs associated with replacing the
poisoned fish).
                                             -XXXll-

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Solvent
Solvent-based ink

Solvent recovery
Solvent resistance

Stack emission
Stack printing press

Substrate
Systemic toxicity

Thermal oxidizer
Thinner

Tone
Toxic Chemical Release
Inventory (TRI)

Toxicity
Trapping
Tropospheric Ozone
Turbidity

Ultraviolet light
UV-cured ink
Vehicle

 Viscosity
 Volatile Organic Compounds
 (VOCs)

 Volatilization

 Waste generator
medium used to dissolve a substance
an ink containing more than 25% VOCs and formulated to dry via
evaporation
process of recovering purified solvents from VOC emissions
the ability of a cured ink coating to resist removal during exposure to a
solvent such as methyl ethyl ketone (MEK)
emissions that are collected from the printing press and are released
through a roof vent or stack to the outside air, sometimes undergoing
treatment to reduce the emissions
press where the printing stations are placed one above the other, each
with its own impression cylinder
material upon which an image is printed
adverse effects on any organ system following absorption and
distribution of a chemical throughout the body
oxidizer that requires high operating temperatures (see Oxidizer)
liquid, solvent, and/or diluent added to ink for dilution or thinning; a
type of extender
color quality or value; a tint or shade of color
requirement under the Emergency Planning and Community Right-to-
Know Act (EPCRA) requiring certain facilities to report release of
specified chemicals
property of being harmful or poisonous
printing of one color over another
see Ozone
a condition in which the clarity of water is reduced because of the
presence of sediment, pigment, or other suspended material
electromagnetic radiation of shorter wavelength than visible light
 ink that is cured by ultraviolet light rather than evaporation
 liquid component of a printing ink; carries the ink from the ink pan to
the substrate
 resistance to flow
 any organic (carbon-containing) compound that participates in
 atmospheric photochemical reactions except those designated by EPA
 as having  negligible photochemical reactivity
 passing from liquid to gaseous state; subject to rapid evaporation;
 having high vapor-pressure at room temperature
 a facility that generates wastes and is responsible for determining
 whether the waste is hazardous and what classification may apply to a
 waste stream
                                             -XXXlll-

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Water-based ink
Wetting


Wide-web press


Willingness-to-pay
 an ink containing less than 25% VOCs and formulated to dry via
 evaporation

 process by which a liquid wets the surface of a dissimilar material by
 reducing the surface tension of the liquid

 a printing press with a web that is greater than 24 inches wide, usually
 in the range of 50-60 inches

 estimates used in benefits valuation intended to encompass the full
 value of avoiding a health or environmental effect, which are often not
 observable in the marketplace. For human health effects, the
 components of willingness-to-pay include the value of avoided pain
 and suffering,  impacts on the quality of life,  costs of medical
treatment, loss of income, and, in the case of mortality, the value of a
statistical life.
                                           -xxxiv-

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FLEXOGRAPHYCTSA
                   EXECUTIVE SUMMARY
                       Executive Summary
                         CHAPTER CONTENTS


BACKGROUND OF THE DFE FLEXOGRAPHY PROJECT	!....... ES-2

POTENTIAL HAZARDS AND RISKS OF INK CHEMICALS	ES-4
     Aquatic Hazards	•	ES'6
     Human Health Hazards	ES-7
     Human Health Risks	ES-8

PERFORMANCE 	ES-13

COSTS	ES-16

RESOURCE USE AND ENERGY CONSERVATION 	ES-17
                                                          i
FEDERAL ENVIRONMENTAL REGULATIONS	ES-18

CHOOSING AMONG FLEXOGRAPHIC INKS 	ES-21

CONCLUDING REMARKS	ES'21
 PUBLIC COMMENT DRAFT
ES-1
September 2000

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  FLEXOGRAPHY CTSA
                                                                         EXECUTIVE SUMMARY
 BACKGROUND OF THE DEE FLEXOGRAPHY PROJECT

                Flexographic Ink Options:  A  Cleaner Technologies  Substitutes  Assessment (CTSA)
                assembles and analyzes the technical research that was performed by the U. S. EPA Design
                for the Environment (DfE) Flexography Project!  The findings of this research are of
                considerable interest to the flexographic industry, both in the wealth of details and as an
                overall view of this industry segment at a particular point in time.  As far as is known,
                this study provides the most detailed analysis ever done on flexographic inks.

                The partnership scoped and researched
                   •  three ink systems (solvent-based, water-based, ultraviolet-cured)
                   •  nine ink product lines (2 solvent-based, 4 water-based, 3 UV-cured), and five
                      colors of ink, including both process and spot (line) colors, for a total of 45
                      individual ink formulations
                   •  more than 100 chemicals belonging to 23 chemical categories
                   •  three film substrates (clear low-density polyethylene, white polyethylene/ethyl
                      vinyl acetate, and clear oriented polypropylene)

                This CTSA document identifies
                   •  results of 18 performance tests
                   •  potential hazards and risks to worker health and the environment
                   •  costs (related to purchase and use of the ink components, energy consumption, ink
                      use, environmental compliance, and other regulatory aspects)
                   •  other opportunities for environmental improvements in flexographic inks and
                      printing practices
                   •   highlights of federal regulations affecting the industry

               To ensure that ink formulators, printers, and technical assistance providers will have
               access to this information, the partnership intends to make the entire CTSA available in
               both printed and electronic formats. For more information about documents and other
               materials related to this project, readers can also visit the EPA Flexography Project
               website:  (http://www.epa.gov/dfe/flexography/flexography.html).
                                    CTSA Considerations

 The CTSA is intended to reflect the characteristics of printing inks under "real world" production conditions.
 Performance tests were printed on volunteer commercial presses, not on a tightly controlled experimental
 press. Worker health risks were determined based on conditions found in a typical printing facility, rather
 than those of an ideal workplace. Like any study with this goal, it may lack the statistical accuracy of a
 controlled experiment, but it offers practical results that may approximate those of a typical printer.
               Flexography currently accounts for about 20 percent of U.S. printing industry output, and
               it is the world's fastest growing printing technology, with an annual growth rate of 6.3 %
               in 1996. Especially well suited to printing on flexible and non-uniform surfaces (such as
               plastic films and corrugated board), flexography prints a wide range of products we all
               use, such as snack food and frozen food bags, labels for  medicines and personal care
PUBLIC COMMENT DRAF1
ES-2
                                                                              September 2000

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FLEXOQRAPHY CTSA
                          EXECUTIVE SUMMARY
               products, newspapers, drink bottles, and cereal containers.  States with the majority of
               fiexographic facilities include California, Illinois, New York, North Carolina, Ohio,
               Pennsylvania, Texas, Wisconsin, Georgia, and New Jersey.  Fiexographic facilities are
               generally small; approximately 40% have fewer than 20 employees, and 70 % have fewer
               than 50 employees. However, the industry is seeing a trend of mergers and acquisitions.
               As mergers cause firms to grow, the selections of ink by an individual company can have
               an increasingly significant effect.

               In the mid-1990s, the DfE Program at U.S. EPA began working with  fiexographic
               printing industry representatives to identify an aspect of the fiexographic printing industry
               with significant  environmental concerns.   Historically, most fiexographic  inks were
               solvent-based, had high levels of volatile organic compounds (VOCs), and contained a
               wide variety of pollutants. Although the industry has addressed environmental and health
               problems of inks through add-on pollution control devices, these have not resolved all
               concerns of human health and ecological risks.

               Therefore,  the DfE Flexography Project,  a voluntary partnership  with industry,  was
               established. The research project was initiated by representatives of fiexographic trade
               associations,  ink formulators, printers,  suppliers to the printing industry,  academic
               institutions, and EPA. The Project partners decided to focus on fiexographic inks, which
               constitute a major cost category and have a variety of environmental and health issues.
               The Project's goals have been to work with the fiexographic industry to understand the
               range of environmental and  health impacts  of fiexographic inks, help  fiexographic
               professionals to select the cleanest  inks  that make  business  sense, and highlight
               opportunities for printers and formulators to take simple, useful actions that will improve
               operations and the environment.

               Details about the process  that was used to develop the CTSA can be found in Chapter  1
               (Introduction).  The methodology that was used to conduct the research is. addressed in
               each relevant chapter.

               The CTSA demonstrates that each of the fiexographic ink systems and chemical categories
               studied may have health and environmental implications associated with their use.  The
               results can help printers and formulators recognize these potential hazards and risks, and
               identify safer alternatives for some chemicals  and chemical categories.
 PUBLIC COMMENT DRAFT
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September 2000

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  FLEXOGRAPHY CTSA
                                                                       EXECUTIVE SUMMARY
                         The Design for the Environment (DfE) Program

 The Design for the Environment (DfE) Program is a voluntary partnership-based program between the U.S
 Environmental Protection Agency (EPA) and various industries. Working with its partners, the DfE Program
 identifies cost-effective alternatives to existing products and processes that reduce risks to workers and the
 environmental while maintaining or improving performance and product quality. Thus, as shown in the
 diagram below, consideration of Performance, Cost, and Environmental Risk contribute to a Decision that
 is in the best interests of both the business and society.  DfE serves as,a catalyst for lasting change thai
 balances business practicalities with sound environmental decision-making.  A primary goal of DfE is to
 encourage pollution prevention rather than relying on end-of-pipe controls to reduce risks to human health
 and the environment.
POTENTIAL HAZARDS AND RISKS OF INK CHEMICALS

              A risk assessment is a process that identifies chemicals that may present harm to humans
              and other organisms. Hazard identification seeks to determine whether a chemical can
              cause adverse health effects in humans or in nature. A dose-response assessment portrays
              the relationship between the dose of a chemical received and the incidence and severity
              of adverse health effects in the exposed population. An exposure assessment identifies
              populations  that are or could be  exposed to  a chemical.   A comparative risk
              characterization then uses all this information to develop quantitative and qualitative
              expressions of risk, for the purpose of comparing ink chemicals and ink systems. The
              methodology and findings of the risk assessment performed for flexographic inks are
              described in Chapter 3 and its appendices.  Figure ES.l shows  the risk assessment
              process, and the box that follows shows the assumptions  that the Project made about a
              "model facility" in developing the risk assessment.
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FLEXOQRAPHY CTSA
                                                                   EXECUTIVE SUMMARY
                      Figure ES.1 The CTSA Risk Assessment Process
                  Workplace
                  Practices
                  Source Release
                  Assessment
                  Human Health
                  Hazards
                  Environmental
                  Hazards
                                                             Risk
                                                        Characterization
                                      Model Facility Characteristics

                    4 presses
                    2 oxidizers
                    48" web
                    6 colors
                    500 f pm press speed
                    7.5 hr avg run length
                    22.5 production hours per day
                    300 production days per year
                    7,000 ft3/minute ventilation rate
              Release assumptions:
                    30% of volatile compounds released to air will be uncaptured emissions, 70% will
                    be stack emissions
                    solvent-based ink systems have a catalytic oxidizer with a 95% destruction
                    efficiency
              Exposure assumptions:
                    Press and prep room worker exposure assumptions: 7.5 hour shift, 250 days/year
                    Routine 2-hand contact with ink for dermal exposure; no gloves
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September 2000

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 FLEXOGRAPHY CTSA
                                                                        EXECUTIVE SUMMARY
                                  Risk Analysis Considerations


     The results were based on the ink formulations as submitted to Df E.  Reaction products or other
     changes in chemical composition resulting from the printing process (e.g., the curing process for UV-
     cured inks) were not considered.
     Hazard information for some chemicals was incomplete. Where hazard information was not
     complete, chemical  hazard was assessed by considering the hazards of similar chemicals.
     Exposure and risk results are dependent on assumptions of how printing facilities are operated. For
     example, dermal results were calculated based on the assumption that no gloves are worn. If all
     workers consistently wear gloves when working with these chemicals, dermal exposure and risk
     would be substantially lower than reported here.
     In order to protect manufacturers' proprietary information, the risk section groups the specific
     chemicals in the ink formulations into chemical categories rather than presenting individual
     chemicals.
     Other factors that may affect risk, such as cleaning products, substrate composition, etc., were not
     considered in this analysis.
     Risk modeling was based on conditions expected in a "model facility." Key information about this
    facility are presented below. Other assumptions are described in Chapter 3.  Under different
    assumptions, the results could potentially shift.	
        Aquatic Hazards
               Over half of the more than 100 compounds studied in the flexography performance
               demonstrations showed a medium or high aquatic hazard concern.  Eighteen chemicals
               were found to be of high aquatic hazard concern (see the box that follows). Another 34
               chemicals  were found to be of medium  aquatic hazard concern.  Because it was not
               expected that flexographic chemicals would be released to the aquatic  environment,
               exposure assessments were not conducted, so risk characterizations for aquatic populations
               are not available.  Therefore, it is possible that some or all of these chemicals could
               potentially pose risks to aquatic life if released to water bodies.
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FLEXOGRAPHY CTSA
                                                                       EXECUTIVE SUMMARY
                                 Chemicals of High Aquatic Hazard Concern

               Amides, tallow, hydrogenated
               Ammonia
                .1. Basic Violet 1 (molybdatephosphate and molybdatetungstenatephosphate)
                ;.l. Pigment Violet 27
               Dicyclohexyl phthalate
               Distillates, petroleum, hydrotreated light
               2-Ethylhexyl diphenyl phosphate
                ilycerol propoxylate triacrylate
               n-Heptane
               1,6-HeXanediol diacrylate
               1-Isopropylthioxanthone
               4-lsopropylthioxanthone
               Mineral oil
               Resin acids, hydrogenated, methyl esters
               Styrene
               Thioxanthone derivative
               Trimethylolpropane ethoxylate triacrylate

               A chemical with a high aquatic hazard is capable of causing long-term effects in
               aquatic organisms in a concentration of less than 0.1 mg/L.	
        Human Health Hazards

               The  CTSA  identified  three  types of  human health hazards: systemic  toxicity,
               developmental  toxicity, and carcinogenic (cancer-causing) hazards. Systemic toxicity
               refers to adverse effects on any organ system following absorption and distribution of a
               chemical throughout the body.   Two  chemicals used in the CTSA performance
               demonstrations (ethanol and silica) presented a high hazard, and twenty others presented
               a medium hazard.  Many chemicals have not been studied thoroughly for environmental
               or health effects, hazards, or risks.  Chemicals in UV-cured inks, perhaps because they
               are much newer, are much less likely than solvent- and water-based chemicals to have
               undergone in-depth testing.

                Developmental toxicity refers to adverse effects on a developing organism that may result
                from as little as a single exposure prior to conception, during prenatal development, or
                postnatally up  to the  time  of sexual  maturation.  The major manifestations  of
                developmental toxicity are death, structural abnormality, altered growth, or functional
                deficiency. Four  CTSA chemicals  (barium,  ethanolamine, isopropanol, and styrene)
                presented a high hazard, and four others presented a medium hazard.

                Cancer hazards to humans of flexographic chemicals were also studied by the CTSA, and
                the following concerns were identified.
                    •   Crystalline silica and ethanol have been determined to  be carcinogenic to
                        humans.
                    •   Amorphous silica, isopropanol, polyethylene, polytetrafluoroethylene,
  PUBLIC COMMENT DRAFT
                                                      ES-7
September 2000

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  FLEXOGRAPHY CTSA
                                                                         EXECUTIVE SUMMARY
                        propanol, C.I.-Pigment White 6, kaolin, acrylic resin, two types of petroleum
                        distillates (hydrotreated light and solvent-refined light paraffinics), and styrene
                        fall into various categories indicating potential for cancer concerns.

         Human Health Risks

                The hazard information for the flexographic ink chemicals was combined with estimated
                releases and  exposures  to  arrive at risk  characterizations for the ink systems and
                chemicals.  The CTSA identified three types  of human health risks: systemic toxicity,
                developmental toxicity, and carcinogenic risks.  Risk estimates  were modeled for both
                press  and prep room flexographic workers and the general population living near a
                facility.

                Overall, several systemic and developmental  toxicity risks  were  identified,  but no
                significant cancer risks  were found. Although some inks contained chemicals with
                carcinogenic concern, these chemicals cause cancer through pathways that are not relevant
                to flexographic workers (e.g., through eating  or breathing dust).

                The risk posed by ink system will vary depending upon:
                ,   •   specific chemical components of inks
                   •   use and handling of inks
                   •   type of toxicity (systemic vs. developmental)
                   •   exposure route (inhalation vs. dermal)

                Community Risks
                None of the flexographic chemicals posed a clear risk to residents living adjacent to a
                flexographic facility.  Several formulations posed possible risk  for inhalation,  but no
                formulations posed dermal risk because no dermal exposure to the general population was
                anticipated.  Possible risk was posed by some solvents in solvent-based and water-based
                inks, and by some monomers and other chemicals in UV-cured inks.  The risk assessment
                also found that exposure from solvent-based inks is expected to be higher than that from
                the other two systems despite the use of an oxidizer with the solvent-based system.  At the
                minimum emissions capture efficiency  (70%),  the  high rate  of volatile  emissions
                outweighs the decrease in emissions resulting from the pollution control equipment.


                Worker Health Risks
               Risk was assessed by modeling pressroom and prep room worker exposure. Each ink
               system was found to contain chemical categories with clear occupational health risks (see
               Tables  ES.l and ES.2). Alcohols, amides and nitrogenous compounds, and  acrylated
               polyols were the chemical categories most often found to be of clear worker risk concern.
               For pressroom workers, exposure  was highest with  solvent-based inks because of their
               higher air release rate.  The dermal exposure for both groups was found to be comparable
               for all three ink systems.  Individual chemicals that were found to pose  clear worker
               health risks are listed in the box (Toxicological Endpoints) following the tables.

               Selected risk findings include the following points:

               Overall:
                  •   Each ink system showed a considerable range among the formulations in
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September 2000

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FLEXOGRAPHY CTSA
                                                                       EXECUTIVE SUMMARY
                      the number of chemicals of concern (2-4 for solvent-based, 1-4 for water-
                      based, and 1-5 for UV-cured).
                  •   All ink systems had clear systemic and developmental risks to workers.
                  •   Some water-based and UV-cured inks were found to have fewer risk concerns
                      than solvent-based inks.
                  •   The use of press-side solvents and additives increased the occupational risk for
                      many of the solvent- and water-based ink formulations. In particular, propanol
                      and propylene glycol ethers in solvent-based inks, and ammonia, propanol,
                      isobutanol,  and ethyl carbitol in water-based inks presented clear or possible
                      occupational risk in certain formulations.

               Water-based inks:
                  •   Amides or nitrogenous compounds in water-based ink formulations were
                      common in presenting systemic risks to workers.
                  •   Stack releases were calculated to be higher for some water-based inks
                      compared to solvent, because oxidizers were not used with the water inks.

               Solvent-based inks:
                  •   Uncaptured emissions were higher for solvent-based inks.  Oxidizers treat only
                      captured stack emissions. Because pressroom workers can be exposed to
                      uncaptured emissions, oxidizers did not appear to reduce the health hazards
                      and risks for this group.
                  •   Most of the chemical categories presenting a clear occupational risk in solvent-
                      based ink formulations were solvents. The solvent-based inks released
                      considerably more volatile organic compounds than the water-based and UV-
                      cured inks.

               UV-cured inks:
                   •   Uncured UV inks posed a clear worker health risk via inhalation.  Although
                      chemical emissions from cured inks have not been tested, it is expected that
                      curing greatly reduces the inhalation risks to workers compared to the risks
                      presented in this report for uncured inks.
                   •  Dermal exposure to UV inks also resulted in a clear worker health risk.  The
                      dermal risks associated with cured UV inks  are not known.
                   •  Acrylated polyols were the most prevalent category of clear risk in the UV-
                      cured formulations, based on toxicological data.
  PUBLIC COMMENT DRAFT
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September 2000

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 FLEXOGRAPHY CTSA
                                                                       EXECUTIVE SUMMARY
                                              Defining Risk Levels

                Clear risk indicates that there is an inadequate level of safety for the chemical in question
                under the assumed exposure conditions, and that adverse effects can be expected.  A
                chemical is placed in this category if it has a Hazard Quotient (HQ) (see Note 1 below
                greater than 10, or a Margin of Exposure (MOE) (see Note 2) that is equal to or less than
                10 or 100 (depending on the type of available data). If the chemical does not have a HQ
                or MOE, but instead was analyzed by the structure activity team (SAT), the chemical i
                considered to be of clear risk if it has a moderate or high hazard rating (see Note 3).

                Possible risk indicates that the level of safety is slightly less than desirable and that the
                chemical may produce adverse effects at the expected exposure level. A chemical is
                designated as a possible risk if it has a HQ between 1 and 10, or a MOE that either ii
                between 10 and 100 or 100 and 1,000. A SAT-analyzed chemical is of possible risk if i
                poses a low-moderate hazard (see Note 3).

                Low or negligible risk indicates that there is an adequate level of safety at the expected
                exposure level. A chemical of low or negligible risk has a  HQ less than 1, or a MOE that
                s greaterthan 100 or 1,000. An SAT-analyzed chemical is of low or negligible riskif it has
                a low hazard rating, (see Note 3).

                Jote 1. A Hazard Quotient (HQ) is the ratio of the average daily dose (ADD) to the
                Reference Dose (RfD) or Reference Concentration (RfC), where Rf D and RfC are defined
                as the  lowest daily human exposure that is likely to be without appreciable risk  of
                non-cancer toxic effects during a  lifetime. The more the HQ exceeds 1, the greater the
                evel of concern. HQ values below 1 imply that adverse effects are not likely to  occur.

                tote 2. A Margin of  Exposure (MOE) is calculated when  a RfD or RfC is not available.
                t is the ratio of the NOAEL or LOAEL of a chemical to the estimated human  dose  or
                exposure level. The NOAEL is the level at which no significant effects are observed. The
                LOAEL is the lowest concentration at which effects are observed.  The MOE indicates the
                magnitude by which the NOAEL or LOAEL exceeds the estimated human dose or exposure
                evel. High MOE values (e.g., greater than 100 for a NOAEL-based MOE or greater than
                ,000 for a LOAEL-based MOE) imply a low level of risk. As the MOE decreases, the level
                )f risk increases.

                Mote 3. The SAT provided hazard levels based on analog data and/or structure activity
                onsiderations, in which characteristics of the chemicals were estimated in part based on
                imilarities with chemicals that have been studied more thoroughly. SAT-based systemic
                oxicity concerns were ranked according to the following criteria: high concern — evidence
                f adverse effects in humans, or conclusive evidence of severe effects in animal studies;
                moderate concern r- suggestive evidence of toxic effects in animals; or close structural,
                unctional, and/or mechanistic analogy to chemicals with known toxjcity; low concern —
                hemicals not meeting the above criteria.
PUBLIC COMMENT DRAFT
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                                                                             September 2000

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FLEXOGRAPHY CTSA
                       EXECUTIVE SUMMARY
                 Table ES.1 Clear inhalation Risks for Flexographic Workers
Ink System
Solvent-based
Water-based
UV-cured
Chemical Categories of Clear Risk
Alcohols
Alkyl acetates
Hydrocarbons (low molecular weight)
Alcohols
Amides or nitrogenous compounds
Ethylene glycol ethers
Acrylated polyols
Amides or nitrogenous compounds
Systemic
Risk
X
X
X
X
X
X
X
X
Developmental
Risk
X
X
X
X
    See Defining Risk Levels box for definition of clear risk.
                  Table ES.2 Clear Dermal Risks for Flexographic Workers
Ink System
Solvent-based
Water-based
UV-cured
Chemical Categories of Clear Risk
Alcohols
Alkyl acetates
Inorganic pigments
Organometallic pigments
Organotitanium compounds
Organic acids or salts
Alcohols
Amides or nitrogenous compounds
Ethylene glycol ethers
Organic pigments
Organometallic pigments
Acrylated polyols
Acrylated polymers
Amides or nitrogenous compounds
Inorganic pigments
Organometallic pigments
Oraanoohosphorus compounds
Systemic
Risk
X
X
X
X
X
X
X
X
X
X
X
X
X
Developmental
Risk
X
X
X
X
X
X
X
X
X
X
X
    See Defining Risk Levels box for definition of clear risk.
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September 2000

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 FLEXOGRAPHY CTSA
                                                                         EXECUTIVE SUMMARY
             Toxicological Endpoints of CTSA Chemicals with Clear Worker Health Risks
     A total of 23 of f lexographic ink chemicals (about 23% of the total) were found to pose clear worke
     health risks (See Defining Risk Levels box for definition of clear risk).  The possible effects that are
     listed for each chemical are those that have been reported in the medical literature in association with
     use of the chemical.  No inferences can be made from this list about possible exposure,  doses, o
     severity of effects.
     Alcohols, C11 -CIS-secondary, ethoxylated - skin irritant; eye irritation and lung effects
     Ammonia - skin and eye irritation; corneal, liver, spleen, and respiratory effects
     Ammonium hydroxide - skin irritation, eye effects, nasal irritation, respiratory effects
     Barium - decreased body weight, increased arterial blood pressure, respiratory effects;
     developmental effects - reduced survival, decreased weight gain, blood effects
     Butyl acetate - changes in serum chemistry, fluctuations in blood pressure; developmental effects -
     fetotoxicity, musculoskeletal abnormalities
     Butyl carbitol - blood and skin effects, liver effects
      I Pigment Red 23 - blood, kidney, and stomach effects
     D&C Red No. 7 - thymus, reproductive, and kidney effects, and changes in organ weights and
     "linical chemistry
     Dipropylene glycol diacrylate (SAT)  - genotoxicity, neurotoxicity, oncogenicity; developmental
     and reproductive effects; dermal and respiratory sensitization; skin and eye irritation
     Distillates, petroleum, hydrotreated, light (SAT) - skin carcinogenicity; skin, eye, and mucous
     membrane irritation, carcinogenicity, genotoxicity, and narcosis at high doses
     Ethanolamine - skin sensitizer; respiratory irritation; kidney, liver, neurotoxic, and respiratory
     effects
     Ethyl acetate - general toxicity
     Ethyl carbitol - decreased food consumption; bladder, blood, kidney, liver, spleen, and blood
    chemistry effects; altered organ weights; neurotoxic reproductive effects
      lycerol propoxylate triacrylate - tissue necrosis, decreased body weight, neurotoxic and
     espiratory effects
    n-Heptane - auditory and neurotoxic effects, altered serum chemistry
    Hydroxylamine derivative (SAT) - genotoxicity, dermal sensitization, developmental toxicity
    Hydroxypropyl acrylate - respiratory effects
     sobutanol - blood and neurotoxic effects, changes in enzyme levels; reproductive effects - cardiac
     eptal defects
     sopropanol - dermal sensitizer; blood and skin effects, tissue necrosis; kidney, liver, and spleen
    effects; respiratory effects; changes in enzyme levels and clinical and urine chemistry;
    developmental effects - fetal death, musculoskeletal abnormalities, fetotoxicity
     sopropoxyethoxytitanium bis (SAT) - neurotoxicity, genotoxicity, oncotoxicity,  and
    developmental/reproductive toxicity. Skin, eye,  mucous membrane irritant
    Phosphine oxide, bis - skin sensitizer
    Propanol - liver and reproductive effects (decreased fetal weight, malformations)
     'rimethylolpropane triacrylate - decreased body weight; skin and neurotoxic effects; changes in
     linical chemistry; altered organ weights; respiratory effects
    Another 43 chemicals (about 43% of the total) were found to pose possible worker health risks.
PUBLIC COMMENT DRAFT
ES-12
                                                                               September 2000

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FLEXOGRAPHY CTSA
                   EXECUTIVE SUMMARY
PERFORMANCE
              The CTSA used a combination of performance demonstrations at 11 volunteer facilities
              as well as laboratory tests at the Western Michigan  University (WMU). The  ink
              formulations  were printed  on three  substrates: (1) clear low-density polyethylene
              (LDPE), (2) white polyethylene/ethyl vinyl acetate (PE/EVA), and (3) clear oriented
              polypropylene (OPP).  These three substrates were chosen to  allow a wide range of
              flexographic printers to benefit from the data analysis. The test image included process
              and line printing,  to represent a wide range of types  of flexographic printing. The
              performance demonstration runs also included both surface and reverse printing. All the
              inks/substrate samples collected in both  the performance  demonstrations and  the
              laboratory runs were subjected to an extensive series of tests. A total of 18 different tests
              were conducted to analyze a wide range of ink properties and inks' effects on substrates,
              focusing on aspects that would be important to many flexographic printers. The tests
              (listed alphabetically in Table ES.3) measure many aspects of  appearance, odor, and
              durability of the inks, as well as evidence of interactions between the inks and film
              substrates. Some of these tests have established quality standards, whereas many do not.
              The performance test methodology and results are shown in detail in Chapter 4 and its
              appendices.

                   Table ES.3 Performance Tests Conducted on CTSA Inks
Test Name
Adhesive
lamination
Block
resistance
CIEL*a*b*
Coating weight
Coefficient of
friction (COF)
Density
Dimensional
stability
Gloss
Heat resistance/
heat seal
Purpose
Measures bond strength between the adhesive layer of the lamination and the ink.
In laminations, the ink needs to bond well to both top and bottom lamination
structures.
Measures the bond between ink and substrate when heat and pressure are applied.
Ink transfer from a printed substrate to a surface in contact with the print indicates
that blocking has occurred.
Measures the reflected light of a printed color and calculates a unique numerical
value. The ability to match L*a*b* values is crucial in producing high-quality
graphics and meeting customer specifications.
Measures the weight of the ink film layer on a substrate after drying; affects all
final printed properties, both optical and physical.
Determines the resistance of a printed object to sliding. High COF is important is
some situations, low COF in others.
Measures the degree of darkness (light-absorption) of a printed solid.
Measures how printing conditions distort the linear dimensions of the substrate.
Various factors, such as heat from the dryers, can affect stability by changing the
physical dimensions of the substrate — in either the cross-web direction
(perpendicular to the movement of the web) or the machine direction (the direction
in which the web moves).
Measures the reflection from a light source directed at the surface from an angle.
Measures the degree to which a printed substrate will resist transfer when heated.
Many printed products are subjected to extreme heat during handling and storage.
 PUBLIC COMMENT DRAFT
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September 2000

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 FLEXOGRAPHY CTSA
                     EXECUTIVE SUMMARY
Ice water
crinkle
adhesion
Image analysis
Jar odor
Mottle/lay
Opacity
Rub resistance
Tape
adhesiveness
Trap
Uncured
residue (UV-
cured inks only)
Measures the integrity and flexibility of the ink on the substrate when exposed to
refrigerator and freezer conditions. Many f lexographically printed products, such
as those used for frozen foods, are subjected to very cold conditions. The inks
must stay flexible and maintain the integrity of their adhesion to the substrate
under these conditions so that they don't rub off or flake off.
Measures how well the image is formed. Good image detail is important for
printing, particularly for small type, reverse type, and halftones (single or process
color).
Measures the type and strength of odor produced by ink film on the substrate.
Many f lexographically printed products are used for food packaging, so it is
important that ink odor does not affect the packaged product.
Measures spottiness or non-uniformity of an ink film layer.
Minimizing mottle is important for high-quality printing.
Measures the percentage of light blocked from being transmitted through the ink
film and substrate. The opacity values indicate the uniformity of ink coverage of
the substrate. Opacity is critical on clear substrates, where an opaque background
is needed to provide a backdrop for other color graphics.
Indicates the ink's ability to resist being rubbed off substrate. Dry rub resistance is
critical on products such as retail bags and bread bags, as the exposed ink film is
abraded and scuffed during end use. Wet rub resistance is very important on
frozen food bags, which can be subjected to abrasion during handling.
Measures the bond of the dry ink to the substrate. Adequate ink adhesion is
critical; if the ink doesn't adhere well enough, it will not be able to stand up to the
normal demands placed on the finished product.
Measures how well one ink prints on top of another. Good trapping is necessary to
ensure adequate overprinting and to produce the desired color hue.
Measures whether uncured residue from UV-cured ink remains on the printed
substrate after the final UV curing station. Uncured ink may have possible
negative results, such as odor, ink transfer to the rollers, and ink contact with food
after packaging.
              Substrate type played  a major role  in performance, especially for UV-cured inks,
              showing that the ink-substrate relationship is very important to the performance of
              printed products.  In fact, the results varied widely among tests for each ink system.  No
              one test can provide a reliable or accurate indicator of overall quality for any printer.
              When determining which type of ink system will be most appropriate for the facility,
              printers need to consider the needs of their clients, the type of substrates and products
              that they most often print, the desired aspects of quality  that are most critical, cost,
              health and environmental risks, energy use, and pollution prevention opportunities.

              Some general conclusions that can be drawn from the performance analysis include the
              following:
                  •  No clear evidence emerged from these tests that either the solvent-based or the
                     water-based system performed better overall.
                  •  Many tests results showed wide variability.
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FLEXOGRAPHY CTSA
                   EXECUTIVE SUMMARY
                  •   A flexographic printer cannot assume that any of these ink systems or ink-
                      substrate combinations will be best-suited to the firm's  overall needs.  Careful
                      testing of a potential ink system on the various substrates that a printer will be
                      using most often is critical to obtaining desired quality on a consistent basis.

                Table ES.4 lists  ink system, color, and substrate combination with "best in class"
                performance for selected tests that were run.  It is important to keep  in mind that most
                tests do not have industry standards, and for some tests the determination of a better or
                worse result can depend on the needs of a specific printing situation.   Also, not all
                systems received all tests. Therefore, these results point to the wide diversity of findings
                rather than to any possible superiority of a particular ink  system,  substrate, or
                formulation. The "worst" score is also provided, only to give an indication of the large
                range in scores on almost all tests. For details on these and the other performance tests,
                see Chapter 4.                            •

                Table ES.4 "Best in Class" Performance on Selected CTSA Tests
Test
Adhesive lamination
Block resistance
Density
Gloss
Heat resistance
Ice water crinkle
Image analysis
Mottle
Rub resistance, wet
'Best Score ;
,Sd40 kg
1*0
SLIT '
5W*
d failures
0% femsva)
•.354 -fan6
4T
no fstfura
Ink System
solvent
UV no slip
UV high slip
solvent
solvent
solvent
water
solvent
UV no slip
water
Substrate
OPP
LDPE
LDPE
PE/EVA
OPP
LDPE, PE/EVA
PE/EVA
LDPE
LDPE
Color
N/A
N/A
blue
N/A
N/A
N/A
cyan
green
green
Worst Score'
.2575 kg
3.2
1.09
32.31
24 failures
36% removal
1050 Mm2
812
failure at 2.2
strokes
  aThis score represents the other end of the range of all scores received on this test for all ink systems tested.
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 FLEXOGRAPHY CTSA
                                                                        EXECUTIVE SUMMARY
                                    Performance Analysis Considerations
                   The Partnership's Technical Committee and Western Michigan University selected 18
                   standard tests and designed a test image that included representative types of printing
                   (e.g., text, blocks, and gradients).

                   The substrates were selected to correspond to important flexographic  product
                   segments.

                   Printing facilities volunteered to conduct the performance demonstrations.
                   Performance demonstration inks were donated by ink companies.  The inks were
                   considered representative at that time.

                   Because performance is a function of many factors  — including equipment, ink,
                   substrate, and operator  experience — it is possible that a printer who conducted its
                   own performance tests would have different results than the CTSA.
                   Ink manufacturers are continually improving their inks, and new formulations on the
                   market today may yield improved performance.
 COSTS
               Table ES.5 lists the average CTSA cost results for each ink system. Costs of materials,
               labor, capital (new press or retrofit) and energy, as well as regulatory, insurance, and
               storage costs,  are discussed in detail in Chapter 5.  These costs were based on ink
               consumption and energy use assumptions presented in Chapter 6.

               For this analysis, the cost of inks and additives proved to be the second highest cost
               category (behind substrate). Because this was a short-term demonstration, the efficiencies
               of a long run with familiar products were not realized.  Press speed under actual printing
               conditions is expected to be substantially different (and in general, higher) than in this
               analysis.  However, generally speaking, press speed appears to be the most important
               cost driver, and thus a critical variable in maximizing profitability of flexographic
               printing, because all costs except that of ink and substrate are dependent on press speed.
               Therefore, if a facility can run one ink system (or one formulation) notably faster than
               another while meeting product quality standards, the faster system or formulation will
               probably also be the most cost-effective system.
                   Table ES.5 Cost Averages (per 6,000 square feet, at 500 feet per minute)
Ink system
Solvent-based
Water-based
UV-cured
Materials (Ink
& Additives)
$15.29
$9.55
$18.63
Labor
$5.29
$5.29
$5.29
Energy
$0.53
$0.35
$1.03
Capital
$11.87
$11.41
$11.87
Total
$32.98
$26.60
$36.82
              As the table shows, water-based inks had the lowest material costs.  Water-based inks
              were consumed at a lower rate than solvent-based ink and had a lower per-pound cost
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FLEXOGRAPHY CTSA
                   EXECUTIVE SUMMARY
              than UV-cured. This system also had the lowest energy cost, due partly to the fact that
              no oxidizer, which combusts emissions at high temperatures, was used. Water-based inks
              had the lowest capital costs, because the presses usually did not have pollution control
              equipment  or UV curing lamps.  Therefore, at a press speed of 500 feet per minute,
              water-based inks were the least expensive. If an oxidizer were used with water-based inks
              (as is required in some areas), much of the cost savings would  disappear.

              Solvent-based inks had the highest capital costs because of the expense of oxidizers, and
              thus the total cost for this ink system was substantially higher than the water-based
              system. UV-cured inks had the highest energy costs because only electricity was used for
              this system, whereas the other two systems used a large percentage of less expensive
              natural gas. UV also had the highest material costs because of the higher per-pound cost
              of UV inks.
                                       Cost Analysis Considerations

                  Glean-up and waste disposal costs were not included in the quantitative analysis.
                  The print run conditions may affect the level of ink maintenance, and therefore ink
                  costs, more significantly than was demonstrated at the volunteer sites.
RESOURCE USE AND ENERGY CONSERVATION

              The methodology and findings for ink and energy consumption in the CTSA are detailed
              in Chapter 6. Table ES .6 lists the energy use and estimated overall emissions from each
              ink system.

                      Table ES.6  Average Energy Consumption (at 500 feet per minute)
Ink System
Solvent-based
Water-based
UV-cured
Energy Consumed per 6,000
ft2 (Btu)a
100,000
73,000
78,000
Emissions Generated
(g/6000 ft2)
10,000
6,800
18,000
               aElectrical energy was converted to Btus using the factor of 3,413 Btu per kW-hr.
               These energy estimates were used in the cost calculations for Chapter 5. Because the
               water-ba ed ink systems did not uses an oxidizer, their energy consumption was lower
               than for solvent-based inks or UV-cured inks.  Much of the energy for the water-based
               system was derived from natural gas, which releases less emissions per unit of energy
               than does electricity. Thus, the environmental emissions due to energy production were
               also lowest for water-based inks.

               UV-cured inks consumed less energy than solvent-based inks but were estimated to result
               in the highest energy-related emissions, because all energy for this system comes from
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  FLEXOGRAPHY CTSA
                                                                       EXECUTIVE SUMMARY
               electricity. Electricity generation and consumption are less efficient than the direct use
               of oil or natural gas.  (See Tables 6.19 and 6.20 for details.)
                                   Resource Use Analysis Considerations

                   Ink consumption was calculated during the performance demonstrations by recording
                   the amount of ink added to the press and  subtracting the amount removed during
                   cleanup. Several site-specific factors affected the calculated ink consumption figures:
                   type of cleaning equipment, anilox roll size, and the level of surface tension of the
                   substrate.
                   The energy consumption analysis only considered equipment that would differ among
                   the inksystems. Therefore, drying/curing equipment is included, but substrate winding
                   equipment and ink pumps are not.
                   Pollution estimates were developed using a  computer model rather than by capturing
                   and analyzing actual emissions from the facilities.
 FEDERAL ENVIRONMENTAL REGULATIONS

               This study is not regulatory in nature, and DfE is a non-regulatory program that operates
               on the basis of voluntary, multi-stakeholder partnerships. To provide additional useful
               information for the flexographic printing industry, however, the CTSA does include a
               basic overview of the major federal statutes that concern flexographic printers (see
               Chapter 2).  Certain chemicals in the CTSA inks are specifically regulated by name
               under at least one federal statute (Table ES.7). In addition, many others are regulated as
               volatile organic compounds (VOCs).

               A substantial number of the chemicals in the CTSA, however, remain unregulated under
               federal laws. Because many chemicals are not regulated and many have not been not
               tested  for hazardous properties, printers may  be unaware of the possible risks and
               hazards that accompany some chemicals.
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FLEXOGRAPHYCTSA
                  EXECUTIVE SUMMARY
                   Table ES.7  Major Federal Regulations Affecting Chemicals in the CTSA
               Regulation
   Affected Chemicals
               Clean Air Act
                     112(b) Hazardous Air Pollutant
   Butyl carbitol
   Ethyl carbitol
   Styrene
                     112(r) Risk Management Plan
   Ammonia (in concentrations greater
   than 20%)
               Resource Conservation and Recovery Act (RCRA)
                     Characteristic Wastes (D Wastes)
                     (other chemicals than those shown
                     here can also be characteristic
                     wastes)
   Barium (D005)
   Ethyl acetate (D001)
   Ignitable solvent-based inks (D001)
   Isobutanol (D001)
                     Non-specific Source Wastes
                     (F Wastes)
   Ethyl acetate (F003)
   Isobutanol (F005)
                     Specific Unused Chemicals
                     (U Wastes)
   Ethyl acetate (U112)
   Isobutanol (U140)
                Toxic Substances Control Act (TSCA)
                     Section 4
    Butyl acetate
    Butyl carbitol
    Dipropylene giycol methyl ether
    Ethyl acetate
    2-Ethylhexyl dephenyl phosphate
    Isobutanol
    n-Heptane        	
                       Section 8(a) PAIR
    Ammonia
    Dicyclohexyl phthalate
    Dipropylene giycol methyl ether
    Isobutanol
    Isopropanol
    Ethyl acetate
    Ethyl carbitol
    2-Ethylhexyl dephenyl phosphate
    n-Heptane
    1,6-Hexanediol diacrylate
    Hydroxypropyl acrylate
    Propylene giycol methyl ether
    Silicone oil
    Styrene
    Urea
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 FLEXOGRAPHY CTSA
                                                                      EXECUTIVE SUMMARY
                       Section 8(d)
     Dicyclohexyl phthalate
     Dipropylene glycol methyl ether
     Ethyl carbitol
     Ethyl acetate
     2-Ethylhexyl diphenyl phosphate
     n-Heptane
     Isobutanol
     Isopropanol
     Propylene glycol methyl ether
     Silicone oil
                       Section 12(b)
     Butyl acetate
     Butyl carbitol
     Dipropylene glycol methyl ether
     Ethyl acetate
     2-Ethylhexyl diphenyl phosphate
     Isobutanol
     n-Heptane
                Clean Water Act (CWA)
                      Hazardous Substances
                      (Reportable Quantities)
     Ammonia (100 Ibs.)
     Ammonium hydroxide (1000 Ibs.)
     Butyl acetate (5000 Ibs.)
     Styrene (1000 Ibs.)
                      Priority Pollutants
     Surfactants
                Safe Drinking Water Act (SDWA)
                     National Primary Drinking Water     Barium
                     Regulations                       Styrene
               Comprehensive Environmental Response, Compensation, and Liability Act
               (CERCLA)
                     Reportable Quantities (RQs)
     Ammonia (100 Ibs.)
     Ammonium hydroxide (1000 Ibs.)
     Butyl acetate (5000 Ibs.)
     Butyl carbitol (RQ not listed)
     Dicyclohexyl phthalate (RQ not listed)
     Ethyl acetate (5000 Ibs.) <
     Ethyl carbitol (RQ not listed)
     Isobutanol (5000 Ibs.)
     Styrene (1000 Ibs.)
               Emergency Planning and Community Right-to-Know Act (EPCRA)

                     Extremely Hazardous Substances   Ammonia
                     TRI Chemicals
    Ammonia (10% of total aqueous
    ammonia)
    Barium
    Butyl carbitol
    Ethyl carbitol
    Isopropanol
    Styrene
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FLEXOGRAPHY CTSA
                    EXECUTIVE SUMMARY
               Occupational Safety and Health Act (OSHA)
                     Personal Exposure Limits (PELs)
    Ammonia
    Barium
    2-Butoxyethanol
    Butyl acetate
    Dipropylene glycol methyl ether
    Ethanol
    Ethanolamine
    Ethyl acetate
    n-Heptane
    Isobutanol
    Isopropanol
    Kaolin
    Propanol
   . Propyl acetate
    Styrene	
CHOOSING AMONG FLEXOGRAPHIC INKS

              As the CTSA makes clear, the choice of an ink system, an ink product line, or a specific
              ink formulation (color within a product line) is not a simple one, or one that should be
              based solely on any one aspect.  Chapter 8 of the CTSA includes a table that provides
              an overall view of certain performance, cost, and resource use test results across all three
              ink systems (Table 8.2).  The CTSA found that within each ink system, there was
              substantial variation in test results among individual product lines. Therefore, selecting
              the "cleanest" formulation within a system is just as important as selecting a system.

              In addition to competitive aspects such as performance, cost, and energy use, inks also
              have important environmental health and safety implications.  Every ink product line
              analyzed in the CTSA included chemicals that are associated with multiple clear health
              risks to flexographic workers (Table 8.3). Each ink system also was found to have safety
              hazards for the workplace (flammability, ignitability, reactivity, or corrosivity concerns).
              All of the formulations released VOCs and sometimes HAPs as well (Table 8.4).

              Each of these aspects of ink use is associated with costs and benefits for both individual
              flexographic printing facilities and the larger society in which they function.  These
              implications, which do not often enter in a printer's decision-making process, can be
              significant.

CONCLUDING REMARKS

              Flexography is a thriving and rapidly expanding industry. As flexography grows, so do
              its impacts. Packaging is the major growth area in flexography, so decisions about ink
              systems used for printing of packaging will have a proportionally larger impact as the use
              of flexographic packaging expands.  Also, because of the trend of mergers  and
              acquisitions in the flexographic industry, individual firms grow in size and influence, so
              decisions about inks made by one company may have a greater effect. Decision-makers
              should be aware that they are capable of encouraging environmental  improvements and
              moving their operation closer to environmental sustainability.
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 FLEXOGRAPHY CTSA
                     EXECUTIVE SUMMARY
               Because the use of flexographic inks is expected to continue growing, environmental
               impacts could grow as well.  Although individual ink formulations studied in the CTSA
               contained widely varying numbers of chemical categories of concern, no ink system or
               formulation was found to be free of hazards or risks.  In particular, specific formulations
               in systems that are often regarded as less harmful (i.e., water-based and UV-cured) are
               not necessarily more safe.  As the CTSA shows, hazards and risks varied considerably
               among the systems,  depending, on solvent content and other factors.

               There may be substantial opportunities to reformulate inks to reduce environmental and
               human health risks. For example, solvent-based printers need to keep oxidizers in prime
               working condition at all times.   Fruiters  using  water-based inks without an oxidizer
               should select inks containing the lowest possible percentage of VOCs. And both solvent-
               and  water-based  printers can  significantly  reduce their energy  requirements  by
               recirculating warm air  from  dryers. To  identify other  opportunities  to make
               improvements, printers and ink formulators should consider all aspects of inks, including
               performance characteristics, risks to facility workers and the environment, and costs.

               Knowledge is key to improving inks and printing practices.  The information in this
               CTSA can help printers and formulators identify potential hazards and risks present in
               some inks, as well as identifying possibly safer alternatives for some chemicals and
               chemical categories. Table ES.8 lists general methods for reducing potential hazards of
               and risks of working with inks that professionals working ,jn or with the flexographic
               industry may wish to consider.                             -
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F1.EXOGRAPHY CTSA
                EXECUTIVE SUMMARY
              Table ES.8 Ways to Reduce Hazards and Risks Related to Flexographic Inks
Suggestion
Read CTSA materials to become
familiar with environmental and health
impacts of chemicals in inks.
Select the cleanest inks that make
business sense. Minimize use of
hazardous inks.
Minimize the need for and use of
press-side solvents and other
additives.
Maximize good ventilation, particularly
in the prep and press rooms.
Ensure that all workers who handle
inks wear butyl or nitrile gloves, to
minimize exposure to chemicals.
Ensure that all pollution control
devices are maintained properly and
work correctly at all times.
Identify ways to improve operations
and environmental performance by
looking at all steps in the printing
process throughout the facility.
Develop comprehensive safe working
policies and practices for inks, and
ensure that workers follow them.
Minimize the amount and number of
hazardous ingredients in inks.
Make environmental and health
information about inks more
accessible and understandable (e.g.,
expand MSDSs, provide best practice
tips, include chemical information in
sales materials).
Support research on untested and
inadequately tested flexographic ink
chemicals, especially those with clear
or possible risk concerns and those
that are produced in high quantities
(high production volume chemicals). ,
Printers
X
X
X
X
X
X
X
X


X
Formulators
X

X





X
X
X
Other
(Technology
Assistance
Providers,
Colleges, etc.)
X





X
X


X
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CHAPTER 1
                                                               INTRODUCTION TO THE CTSA
                         Chapter li Introduction to the
                Cleaner Technologies Substitutes Assessment
1.1 PROJECT BACKGROUND
               The Design for the Environment (Dffi) Program is a voluntary partnership-based program
               between the U.S. Environmental Protection Agency (EPA) and various industries.  DfE
               works directly with companies to integrate health and environmental considerations into
               business decisions. DfE serves as a catalyst for lasting change that balances business
               practicalities with sound environmental decision-making. The DfE approach is intended
               to  compare performance, risks, and costs associated with  alternatives to traditional
               industrial systems, materials, and methods.  A primary goal of DfE is to encourage
               pollution prevention rather than relying on end-of-pipe controls to reduce risks to human
               health and the environment.

               Flexography is a process used primarily for printing on paper, corrugated paperboard, and
               flexible plastic materials. Flexography uses a soft, flexible printing plate that is mounted
               on a rotary cylinder.  Flexographic presses are equipped with anywhere from one to as
               many as twelve color stations.  Examples of items printed with flexography  include
               comics, newspapers, appliance boxes, and many grocery store packages - including cereal
               boxes, shampoo and soda bottle labels, frozen food and bread bags, and milk cartons.

                Flexography accounts for about 20 percent of U.S. printing industry output, and it is the
               world's fastest  growing printing  technology.   The nearly 1,000 U.S.  flexography
               companies employ 30,000 people, have annual sales of $4.7  billion, and use more than
               475 million pounds of ink per year.  Over 60 % of flexography companies have fewer than
               20 employees.

               The DfE Flexography Partnership was initiated by representatives of flexographic trade
               associations,  ink formulators,  printers,  suppliers  to  the printing industry, academic
               institutions, and EPA.  The trade associations that-worked on the Partnership represent
               over 1,600 flexographic printers and ink manufacturers. (The Partners are listed in the
               Acknowledgments at the front of Volume I.)

                The flexographic industry's many small printing  companies rarely have the time or
                resources to  gather in-depth information on safer and lower-risk alternatives to current
                materials and processes.  The Flexography Project was set up to provide flexographers
                with information that can help them design a business that is more environmentally sound,
                safer for workers, and more cost-effective.

                The Flexography Project partners decided to focus on flexographic inks, which constitute
                a major cost category and have a variety of environmental and health issues.  Factors that
                were considered in selecting flexographic inks as the subject of this research included
                awareness of health issues related to chemicals used in flexographic inks, growth of the
                flexographic industry,  significant recent advances in flexographic technology,  and
                increasing attention to regulations.
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 CHAPTER 1
                                                                 INTRODUCTION TO THE CTSA
 1.2 WHAT IS A CLEANER TECHNOLOGIES SUBSTITUTES ASSESSMENT?

                This research project (called a Cleaner Technologies Substitutes Assessment, or CTSA)
                systematically  examined  the  tradeoffs  associated  with traditional  and  alternative
                flexographic ink chemicals. These tradeoffs include environmental concerns (such as risk,
                environmental releases, energy impacts,  and resource conservation), performance, and
                cost.  Many of these issues are frequently overlooked by conventional analyses.

                Although this CTSA focuses on inks, the approach that was used is transferable to other
                business decisions.  In  other words, the  foundation for  this CTSA is  the careful
                consideration of all facets that affect flexographic inks, including aspects that many firms
                fail to address at all. The goal of this project is to help the flexographic industry include
                these aspects  in business decisions, and thereby to improve both private business and the
               larger environment.

               This CTSA involved a detailed comparison of more than 100 flexographic ink chemicals,
               based upon actual printing of the inks on three substrates. The Partnership analyzed three
               ink systems: solvent-based, water-based, and ultraviolet-cured, the last of which is a fairly
               new technology. Solvent-based inks represented the industry benchmark for easy of use
               and quality of results.  The inks traditionally used in this  system, however, contain
               solvents made of volatile organic compounds and other chemicals, which can pose risks
               to human health and the environment.  The Project tested the different ink systems on
               three different film substrates that printed on wide-web presses. (See  Chapter  2 for an
               overview of the ink systems that were analyzed.) The Partners chose film because there
               was less documentation of water-based and UV-cured ink systems on these substrates.
               They tested the inks on wide-web presses because of the technical challenges facing
               flexographic printers in using water-based and UV-cured inks to print film substrates on
               these presses.

        CTSA Methodology

               The Partners developed a detailed methodology  for testing  the ink  systems, which
               involved  (1) performance demonstrations at eleven volunteer printing facilities and (2)
               laboratory runs conducted at the printing facility of Western Michigan University (WMU).
               The methodology included the following general steps:

                      •      The performance demonstration printing sites supplied detailed
                             information about their facilities and the press used in the flexographic
                             demonstration.

                      •       Each site ran a demonstration.

                      •       Western Michigan University conducted technical analyses of the
                             printed samples, and provided them to the Partners.

                      •       The University of Tennessee used facility information to analyze
                             energy consumption and costs:

                      •       The EPA Risk Workgroup used a variety of existing information to
                             analyze the hazards and risks  of the ink chemicals and ink systems.
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CHAPTER 1
                                                               INTRODUCTION TO THE CTSA
                     •      Finally, all the information was combined into this document. The
                            CTSA evaluates the performance, costs, and environmental and
                            human health impacts of the flexographic inks that were tested.


1.3 WHO WILL BENEFIT FROM THIS CTSA?

              The CTSA provides what is arguably the most detailed analysis ever performed on
              flexographic ink chemicals. Small printers, inkformulators, technical assistance providers
              to the printing industry, and others interested in technical information about flexography,
              printing inks, or environmentally focused information about the printing industry may all
              find this information useful.

              The CTSA provides data to help ink formulators develop high-quality inks  with fewer
              chemicals that pose risks to human health and the environment.  Printers can use the
              CTSA to help identify types of chemicals and ink systems that may print equally well for
              specific purposes while posing fewer problems for workers and making  regulatory
              compliance easier. Technical assistance providers can find a wealth of information in
              the  CTSA to  help small businesses think through the many issues in selecting an
              appropriate ink system that incorporates health and environmental considerations as  well
              as performance and cost information.

              The benefits of the CTSA include its wealth of detailed information about a large group
              of chemicals (more than 100),  including many common chemical categories found in
              flexographic inks. In addition to the original performance demonstration study, a huge
              amount of work was done to bring all the existing information together in a way that
              would be helpful to flexographic professionals. The hundreds of tables and charts provide
              detailed  data about hazards, risks, environmental releases, and other aspects of ink
              chemicals that can be difficult to locate but are very important to consider when choosing
              or evaluating ink technologies and systems.

              The CTSA, despite its detail, represents only a "snapshot"  taken of a specific printing
              sample demonstrated by a small, non-random number of performance sites at a specific
              time.  In addition, the inks used in the performance demonstrations were selected and
              donated by ink manufacturers, and only three types of film were used as test substrates.
               Therefore, readers should not assume that the information in the CTSA represents current
               information about flexographic printers, inks in general, or results on other  substrates.


 1.4 OVERVIEW OF THE CTSA

               This CTSA consists of two volumes. Volume 1 contains the text, and Volume 2 includes
               Appendices that provide important background information about the CTSA.  Because the
               CTSA contains  so much information, it may be helpful to use specific sections to suit
               different needs.

               The list that follows is provided to help readers locate particular types of  information
               quickly.
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  CHAPTER 1
                                                                 INTRODUCTION TO THE CTSA
                Table of Contents: The Contents at the front of Volume 1 contains a detailed breakdown
                of the topics discussed in every chapter.  A scan of the Contents can provide a good
                orientation to the material contained in the CTSA.

                Results and Implications of the CTSA: Readers who want a quick overview of the most
                important findings of the CTSA should begin by reading the Executive iSummary, which
                precedes Chapter 1 of the CTSA. Chapter 8  (Choosing Among Ink Technologies)
                contains a more detailed discussion of the interactions between risk, performance, and
                cost, and provides comparative interpretations of the results by ink system and chemical
                category.  This chapter will be most helpful to professionals who are interested  in
                considering alternatives to current inks and in developing cleaner products.

                Chapter Introductions:  An Introduction  at  the beginning of each chapter provides
                highlights of the chapter and the most important results, as well as a table of contents for
                that chapter.

                Background: The Glossary at the front of Volume 1 defines a number of technical terms
                that are used in the CTSA.  Chapter 2 (Overview of Flexographic Printing) provides
                general information about the flexographic printing industry, the components and safety
                aspects  of the  ink systems that were studied,  and   federal regulations relevant to
                flexography.

               Performance Information: The research behind the CTSA examined 45 ink formulations.
               A total of 18 performance tests were chosen and run. Chapter 4 (Performance) describes
               the results of the tests.  The chapter first discusses the performance of solvent-based and
               water-based inks, then ultraviolet-cured (UV) inks, and finally profiles each physical site
               where performance demonstrations were conducted.

               Environmental  Information:  Chapter 3 (Risk) discusses  the environmental  issues,
               including the hazards to aquatic life, exposure of printing industry employees and the
               general public, and the risks that were identified in the CTSA. Information about natural
               resource consumption related to this study is discussed in Chapter 6  (Resource and
               Energy Consumption), and pollution prevention and  control options are mentioned in
               Chapter  7 (Additional  Improvement Opportunities).   Chapter 2  (Overview of
               Flexographic Printing) contains a short discussion of federal environmental regulations
               that are relevant to the flexographic printing industry.

               Cost Information: Different aspects of cost discussed in Chapter 5 (Cost), as well as in
               Chapter 8 (Choosing Among Ink Technologies).

               Appendices: The Appendices, which are provided in Volume 2, contain a great quantity
               of background information to supplement the main text.  Each appendix is numbered to
               match the chapter to which it relates; for instance, Appendix 3-A contains details about
               the information in Chapter 3.
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CHAPTER 2
     OVERVIEW OF FLEXOGRAPHIC PRINTING
          Chapter 2: Overview of Flexographic Printing
                             CHAPTER CONTENTS
2.1 INTRODUCTION TO FLEXOGRAPHIC INKS	2-3
       Ink Components  	2"3
       Ink Systems	2-4

2.2 MARKET PROFILE OF THE FLEXOGRAPHIC PRINTING INDUSTRY	2-7
       Descriptions of Different Flexography Market Segments  	2-7
             Market-Related Trends in the Flexographic Printing Industry 	2-11
       Markets for Printing Inks Overall	2-13
       Markets for Flexographic Ink Systems	'	2-16
       Imports and Exports for Flexographic Inks	2-17

2.3 FEDERAL REGULATIONS  	2-19
       Clean Air Act	•	2-19
       Resource Conservation and Recovery Act	2-21
       Toxic Substances Control Act	•	2-24
       Clean Water Act  	2'28
       Safe Drinking Water Act  	2-31
       Comprehensive Environmental Response, Compensation, and Liability Act	2-31
       Emergency Planning and Community Right-to-Know Act	2-32
       Occupational Safety and Health Act	2-33

 2.4 PROCESS SAFETY	•	2-41
       Reactivity, Flammability, Ignitability, and Corrosivity of Flexographic Ink Chemicals	2-41
       Process Safety Concerns	2'44

 REFERENCES	2~47
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  CHAPTER 2
                                                     OVERVIEW OF FLEXOGRAPHIC PRINTING
                                      INTRODUCTION

  This chapter presents an overview of flexographic inks, the printing process used, the market trends,
  federal regulations that relate to the flexographic printing industry, and safety issues related to the printing
  process. This information provides some context for interpreting the specific CTSA research that follows.



  COMPONENTS OF FLEXOGRAPHIC INKS: Section 2.1 describes the major types of ink components for
  the three ink systems that were studied — solvent-based, water-based, and UV-cured. These categories
  include solvents, colorants, resins, additives, and compounds that are unique to UV inks.

  MARKET PROFILE: Section  2.2 describes the general flexographic printing market, including sub-
  categories, market trends, and markets for flexographic inks in particular.


  FEDERAL REGULATIONS: Section 2.3 provides an overview of the federal regulations pertaining to
  environmental releases and workplace safety potentially affecting the flexographic printing industry. This
  section does not attempt to provide a comprehensive analysis of regulations.


  PROCESS SAFETY: Section 2.4 describes safety issues related to the flexographic printing process.



  Flexography is an industry in the  midst of major changes.  Technological advances made in the past
  decade, combined with compelling market forces, have opened up major new growth areas for flexographic
  nks and printing. At the same time, regulatory  pressures have caused printers and formulators to think
  carefully about the safety and environmental impacts of flexographic inks and the ways in which they use
  hem.
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2.1 INTRODUCTION TO FLEXOGRAPHIC INKS

               A functional flexographic ink must exhibit several qualities.  It must produce a color or
               other visual effect.  It must adhere to the material being printed (the substrate).  It must
               withstand conditions to which it will be exposed in practical use, such as to chemicals,
               abrasion, and extreme temperatures.  Finally, it must produce a consistent finish.

               Different types of ingredients contribute to a successful ink. This section discusses the
               categories of chemicals that comprise a typical ink product line, and the three general ink
               systems into which the chemical categories fall.

        Ink Components

               Five types of components allow ink to adhere to a substrate and produce its visual effect.
               The solvent provides fluidity, which allows the ink to be transported from the ink fountain
               to the substrate.  The colorant, which can be either a pigment or dye, provides the color
               associated with ink. The resin causes the ink to adhere to the substrate, among other traits.
               Additives modify the physical properties of the inks, such as flexibility and the coefficient
               of  friction.  Finally,  in  UV-cured  inks, UV-reactive  compounds  participate  in the
               photochemical reaction that cures the ink.

               Solvents
               Solvents are important in delivering the ink to  the substrate. The solvent allows the ink
               to flow through the printing mechanism, and then evaporates so that the ink forms a solid
               coating on  the  substrate.   Typically, inks are manufactured and  transported  in a
               concentrated form, and  the printer  must add solvent  to the ink to  attain the desired
               viscosity. A solvent must  display several important characteristics.  It must adequately
               disperse or  dissolve the solid components of the ink, but must not react with the ink or
               with any  part of the  press.  It must dry quickly and thoroughly, and have low odor.
               Finally, it is desirable for the solvent to have minimal flammability and toxicity concerns.

               Common solvents  in solvent-based inks are ethanol, propanol,  and propyl acetate. In
               water-based inks, the solvent is water, which is amended with alcohols, glycols, or glycol
               ethers. UV-cured inks are different in that they do not have solvents per se, in that the
               chemicals are not added with the intention of being evaporated after application of the ink.
               Fluidity is provided by liquid, uncured components of the ink, such as monomers, which
                are incorporated chemically into the ink upon curing, instead of evaporating.

                Colorants
                Colorants  are  compounds  that reflect and absorb  certain  wavelengths ot  light.
                Wavelengths that are reflected by a colorant are seen by the eye and perceived as colors.
                The two types of colorants used in printing are dyes and pigments.  Dyes are soluble in
                the vehicle, and the final product can be transparent. The most common dyes are basic,
                amino-based compounds.   The transparent properties of dyes can be beneficial when
                transparency is desired, and the  colors of dyes  are often quite strong. However, dyes can
                be susceptible to attack by chemicals and water, and they can also be toxic.

                Pigments are small, insoluble particles. They  can be made from a wide range of organic
                and inorganic compounds, and as a result, have a variety of properties. Particle size and
                chemical stability  are two variable properties  that can yield differing ink characteristics.
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                In general, pigment-containing inks are more resistant to chemicals and heat and are less
                prone to bleeding through the substrate than dye-containing inks.

                Resins
                Resins are solid compounds  that are soluble in the solvent and often have complex
                molecular structures. They cause ink to adhere to the substrate, disperse the pigment, and
                provide gloss  to the finished coating.   Resins also can impart  differing degrees of
                flexibility, scuff resistance, cohesive strength, block resistance, and compatibility with the
                printing plates.   Common categories  of resins include nitrocellulose,  polyamides,
                carboxylated acrylics, and polyketones.

                Additives
                Several components can be added to inks to improve the performance of the finished
                products.  Examples include plasticizers, which enhance the flexibility of resins;  waxes,
                which enhance slip, rub and scuff resistance; wetting agents, which modify the surface
                tension to improve adherence to substrates; and defoaming agents, which in water-based
                inks reduce soap-like effects.

                UV-Specific Compounds
                The curing process of UV-cured inks is fundamentally different from that of solvent- and
                water-based inks.  Chemicals in the inks react to form solid polymers upon exposure to
                ultraviolet light. Three types of compounds are necessary in order for such a reaction to
                occur: monomers, oligomers, and photoinitiators. Monomers are individual molecular
                units that can combine to form larger structures known as polymers. Oligomers are small
                polymers that can be further combined to form larger polymers. A photoinitator uses UV
                light to enable a  chemical reaction to take place.   Photoinitiators are often aromatic
                ketones, and monomers and oligomers are acrylate-based in most commonly used inks.

                In free-radical curing (presently the most common commercial form), the photoinitiator
                fragments into  reactive free radicals in the presence of ultraviolet light.  These free
                radicals react with monomers and oligomers, which link together to form a polymer that
               binds the ink together.  The reaction is illustrated in the box below.  The photoinitiator
               (indicated by -CO-R) reacts in the presence of UV light to form a free radical (»R). This
               free  radical  then  reacts with  an acrylic  monomer  (or  oligomer)  so  that the
               monomer/oligomer bonds with similar compounds to form a polymer.
                                       -CO-R-
                                                   Energy
•»-CO•+•R
                            •R + CHZ =CH-COOR -> -[CH2 -CR-COOR]n
       Ink Systems
               The primary difference among the three major ink systems is the method used for
               drying or curing the ink.  Solvent-based and water-based inks are dried using
               evaporation, whereas UV-cured inks are cured by chemical reactions.
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              Solvent-based Inks
              Solvent-based inks were the first printing inks available commercially. Historically they
              have been very popular because they dry quickly, perform well, and allow printers a wide
              choice of products. The solvents in these inks, however, are primarily  volatile organic
              compounds (VOCs), which have concerns for health and safety, as they are usually very
              flammable. Environmentally, VOCs contribute to the formation of ground-level ozone,
              which is a component of smog and causes respiratory and other health problems. Partly
              because of these concerns, other types of inks were developed and markets for them began
              to develop.

               Water-based Inks
              The primary solvent in water-based inks is water, but it is important  to realize that water-
              based inks also can and usually do contain varying and often substantial percentages of
               organic solvents and VOCs.  The colorants for water-based inks are very similar to those
               for solvent-based inks, but resins and additives are generally quite different. Water-based
               inks are often less flammable than solvent-based inks and are thus easier  to store and use.
               Depending on  the VOC content, they may also have  fewer environmental concerns.
               However, they may take significantly longer to dry  and are often  not as  easy to use as
               solvent-based inks.

               Ultraviolet-cured Inks
               UV-cured inks comprise a comparatively new ink technology in the  flexographic printing
               industry. They are very different from solvent- and water-based inks in that they are cured
               through chemical reactions rather than drying through evaporation.  Because of this, UV-
               cured inks do not contain traditional organic solvents, which means they do not emit
               VOCs.    However,  they  do contain  many  chemicals that  have not been tested
               comprehensively for environmental, health, and safety impacts. Future research is needed
               on untested UV chemicals. UV inks have found a growing market  outlet in narrow-web
               printing.
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                       PRINTING WITH A CENTRAL IMPRESSION FLEXOGRAPHIC PRESS

                There are three major types of flexographic printing presses: in-line, stack, and centr
                impression  (CI).  The CI press was selected  for  use in the CTSA performanc
                demonstrations.  In many ways  the CI press represents  the standard for quality in th
                flexographic printing industry, especially in converting. This type of press has a particula
                advantage in holding tight register, which allows it to be used for technically demanding
                multiple-color jobs on many different substrates. As graphic design in the packaging are
                has become more complex, flexography has been able to increase its market share largelj
                because of the registration capabilities of the  CI press  (Flexography:  Principles and
                Practices, fifth edition, volume 6, page 7).

                The CI press is distinguished and named for its structural configuration (see Figure 2.1)
                in which different color stations are arranged around a single large (central impression
                drum.  The number of stations can vary.  Most CI presses have six color stations, bu
                presses are now being  built with eight and ten stations. The presses used in the CTSA
                performance demonstrations had  six color stations.

                The DfE Flexography Project Partners chose to run the performance demonstrations on
                wide web CI presses with a target width of 24 inches.  (Suggested specifications of the
                presses chosen for the performance demonstrations are given in Appendix 4-A.) The poin
                of choosing this type of press was to allow the Partners to investigate the capabilities oi
                ink systems on film substrates,  which represent some of the most complex printing
                situations and also the anticipated future direction of flexographic printing.  Wide web
               printing in particular can pose many challenges. As a case in point, at the time the Project
               was being developed, UV-cured inks were making inroads in narrow-web printing but not
               yet in wide-web printing.

                                                  Figure 2.1
                Diagram of Central Impression Press (from Flexography: Principles and Practices,
                                        5th edition, volume 6, page 6).
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2.2  MARKET PROFILE OF THE FLEXOGRAPHIC PRINTING INDUSTRY

              Selection of the flexography industry for this study was based, in part, on the vitality of
              the industry. For several years, flexography has experienced some of the fastest growth
              among printing industries worldwide, with an average annual growth rate of 6.3 %.'

              In 1997, the U.S. Census reported that the  United States had 914 commercial printing
              establishments in which flexographic printing was the primary print process.  These
              establishments employed 30,550 employees, with a payroll of $1,030,023,000.2 However,
              many more facilities — about 2,300 printing facilities in the U.S. — operated flexographic
              presses.3

              The  proportion of the printing industry that is  made up by flexographic printing has
              steadily grown.  In 1994 flexographic printing accounted for 64% of the  U.S. printing
              market share; by 1995 this portion had grown to 75%. In 1996, the flexographic printing
              industry was a $44 billion dollar industry growing at a rate of 6.3% per year.4 Wide-web
              flexography, the segment upon which this CTSA was based, was estimated as a $16 billion
              industry in 1996,5 and that grew by an estimated 7%  in 1999.6

              Historically, flexdgraphic printing facilities have been concentrated in the Midwest. These
              states continue to dominate, but with expansion of the industry, more facilities have opened
              in California and Texas. Close to 60% of all flexographic facilities are'located in ten
              states: California, Florida, Illinois, Missouri,  New Jersey, New York, North Carolina,
              Ohio, Texas, and Wisconsin.7

              Flexographic  facilities are typically  small; approximately  61 %^have fewer than 20
              employees, and roughly 83% have fewer than 50 employees.8 The smallest facilities tend
              to focus exclusively  on flexographic printing and predominantly operate narrow web
              presses. The largest facilities tend to operate a combination of graphic arts processes and
              produce various forms of flexible packaging.9


       Descriptions of Different Flexography Market Segments

               In 1997, the U.S. Department of Commerce introduced a new industry classification
               system, the North American Industry Classification System (NAICS).  NAICS  replaced the
               Standard Industrial Classification (SIC) system as the standard classification system for the
               United States, Canada, and Mexico.  Under NAICS, an industry is generally defined as
               a group of establishments that have similar production processes. Printing  and Related
               Support Activities is listed under NAICS code 323. Commercial Flexographic Printing is
               tracked under NAICS code  323112.   It is  defined  as  an industry  comprised of
               establishments engaged in  flexographic printing,  excluding  publishing (with certain
               exceptions, including books and manifest business forms).10

              The four-digit SIC code 2893 (Printing Ink) is now NAICS code 32591. Flexible packaging
              segments are also covered by several NAICS codes.  Table 2.1 matches the 1997 NAICS
              codes with the 1987 SIC codes for flexographic printing, flexographic inks,  and flexible
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              packaging products.  The flexographic inks and printing segments have been highlighted
              in the table (in grey shading), as these are the primary focus of this CTSA.

             Table 2.1  1997 Flexography NAICS Codes Matched with 1987 SIC Codes
code
322
322221
322222
322223
322224
322225
323
323112
323112
325
325910
326
326111
326112
1997 NAICS U.S. Description
SIC
code
1987 SIC U.S. Description
Paper Manufacturing
Coated and Laminated Packaging
Paper-and Plastics Film
Manufacturing
Coated and Laminated Paper
Manufacturing
Plastics, Foil, and Coated Paper
Bag Manufacturing
Uncoated Paper and Multiwall Bag
Manufacturing
Laminated Aluminum Foil
Manufacturing for Flexible
Packaging Uses
2671*
2672
2679*
2673*
2674
3497*
Printing and Related Support Activities
Commercial Flexographic Printing
Commercial Flexographic Printing
(Continued)
2759*
2771*
2782*
Packaging Paper and Plastics Film,
Coated and Laminated (single-web
paper, paper multiweb laminated rolls
and sheets)
Coated and Laminated Paper, Not
Elsewhere Classified
Converted Paper and Paperboard
Products, Not Elsewhere Classified
(wallpaper and gift wrap paper)
Plastics, Foil, and Coated Paper Bags
(coated or multiweb laminated bags)
Uncoated Paper and Multiwall Bags
Metal Foil and Leaf (laminated
aluminum foil rolls and sheets for
flexible packaging uses)
•* f ~ ^ 	 	 fff
Commercial Printing, Not Elsewhere
Classified (flexographic printing)
Greeting Cards (flexographic printing
of greeting cards)
Blankbooks, Loose-leaf Binders and
Devices (ffexographic printing of
checkbooks)
Chemical Manufacturing ; -
Printing Ink Manufacturing
2893*
Bronze Ink, Flexographic Ink, Gold Ink,
Gravure Ink, Letterpress tnk/
Lithographic Inc, Offset Ink, Printing
Ink: base or unfinished, Screen
Process Ink, fnk * duplicating
Plastics Product Manufacturing
Unsupported Plastics Bag
Manufacturing
Unsupported Plastics Packaging
Film and Sheet Manufacturing
2673*
2671*
Plastics, Foil, and Coated Paper Bags
(plastic bags)
Packaging Paper and Plastics Film,
Coated and Laminated (plastics
packaging film and sheet)
 •Indicates part of a 1987 SIC category
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              The greatest growth of the  flexographic marketplace recently has been  seen  in the
              Corrugated, Folding Carton, and Labels segments.11

              Flexible Packaging
              Flexible packaging is defined  as any package or part of packaging with a thickness of ten
              millimeters or less whose shape can be readily changed. Most of the printing of flexible
              packaging is done by flexographic printing processes. According to the Flexible Packaging
              Association (FPA),  the flexible  packaging industry  employed 375,000 people,  and
              converters-employed 87,000 in 1998 12 Based on U.S.  Department of Commerce census
              data, FPA estimated that the flexible packaging industry grew 3.2 in 1997 to $17.5 billion
              (Table 2.2). In 1998, the flexible packaging industry grew by approximately 3% to $18.5
              billion and it is forecasted to  grow by 6.9% in upcoming years.13  The President of the
              Flexible Technical Association stated in May  1999 that about 65%  of packaging  is
              accounted for by flexography.14
                 Table 2.2 Relevant Categories for Flexographic Printers in Flexible Packaging
Category
Paper coating and
laminating, packaging
Bags: plastics,
laminated, and coated
Bags: uncoated paper
and multi-wall
Metal foil and leaf
TOTAL
SIC
Code
2671
2673
2674
3497

Value of
Shipments
(1997)1
$4.5 billion
$7.5 billion
$3.0 billion
$2.5 billion
$17.5 billion
Sample Products
Bread wrappers, coated or
laminated packaging paper,
waxed paper for packaging
Frozen food bags, trash bags,
plastic merchandise bags
Paper grocery and shopping
bags, glassine bags, un-coated
paper merchandise bags
Foil lids in frozen foods, foil
laminated to paper or other
materials

              1FPA Estimates (FPA, 1998)
              The demand for flexible packaging is driven by food products (particularly fresh produce
              and snack foods), pharmaceutical products, surgical and medical equipment, agricultural
              products, industrial chemicals, household goods, garden supplies, pet food, cosmetics, and
              retail merchandise.  Food products alone account for 50% of the demand for flexible
              packaging; medical and pharmaceutical products constitute 25 %.

              Every year the FPA conducts a survey of its member companies  (consisting of printers,
              converters, packaging companies, packaging schools, and other  related companies), to
              obtain industry statistics. .In its 1998 Outlook Survey respondents (94 companies) were
              asked what they thought the outlook for their industry might be in the next five years.
              Figure 2.1 shows highlights of the 1998 responses.  (Categories total more than 100%
              because respondents could mention multiple issues.)
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                       Figure 2.1 Flexible Packaging Industry's 1998 Vision of Next 5 Years
                                H  Mergers and Acquisitions
                                I   I  Technological Advances
                                Q  Industry Growth
                                I   |  Globalization
                                [3  Rigid-to-Flexible Conversion

              Source: FPA, 1998 Outlook Survey


              Tags and Labels
              Flexography dominates the market for tag and label printing, which has surged over the
              past decade. Labels and tags comprised $9 billion in 1998, or 9% of the North American
              packaging market.15

              Corrugated Containers
              Corrugated  containers provide an economical  source  of strong,  versatile packaging.
              Corrugated board is typically made of kraft linerboard, which uses virgin, unbleached,
              softwood pulp.  The corrugated container industry is one of the largest industries utilizing
              flexographic printing.  In  1996, the corrugated container  industry was  a $18 billion
              industry.16  It is also one of the fastest-growing industries, with an average annual growth
              rate of 6% between 1993 and  1998."

              Corrugated materials are characterized by irregularities, which in the past made it difficult
              or expensive to print high-quality graphics directly on the corrugated board.  As the role
              of corrugated packaging has expanded from simply protecting its contents for transport and
              handling to generating customer interest at the point of sale, technology has also improved.
              By the late 1990s, flexographic printers could print directly on corrugated substrates while
              maintaining high print quality, thereby increasing the use of corrugated containers.

              Flexography prints 14 million tons of corrugated material each year, exceeding all other
              paper/paperboard end-use markets such as folding cartons, paper cups, milk cartons, and
              envelopes.18 In 1996, corrugated containers accounted for 45% of the flexographic printing
              market.  Flexography accounted for 20% of the folding carton sector alone in 1997, and
              this was expected to increase to between 30%  and 40% by the year 2000.19
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      Market-Related Trends in the Flexographic Printing Industry

              As print quality has improved, flexographic printing has successfully penetrated additional
              printing markets.  Between 1995 and 1997 the most dramatic changes were seen in the
              Tags, Tapes and Labels segment.  In 1995 only 55% of these products were printed by
              flexography; by 1997 this number increased to 75 %. The most dramatic decrease occurred
              in the Folding Cartons segment; printing of these products by flexography dropped from
              40% to 15-20% between 1995 and 1997. This may be due to the shift in the packaging
              industry from rigid to flexible packaging.

              Industry experts predict that flexographic market share will grow to 20 % in coming years.w
              A variety of technical, economic, and industry marketing factors account for this anticipated
              growth, as described in the following paragraphs.

              Improved quality of flexographic printing:   Early print quality of flexography was
              typically inferior to that of lithography and gravure. Technological advances have greatly
              improved the quality of flexography, leading to greater use of color and more sophisticated
              and colorful design.  These  technological improvements in flexographic printing have
              resulted in increased acceptance of flexography by print buyers.

              Increased demand for flexographic printing: Because of quality improvements and lower
              costs,  flexography is expected to take some market share away from  other printing
              segments.

              Expanded applications for flexible packaging:  In recent years there has also been a shift
              from rigid packaging (e.g.,  cardboard boxes, glass) to soft packaging. This in turn has
              increased  the   need  for  printing  of  flexible packaging  of  fresh produce,  drugs,
              surgical/medical, snack foods, and agricultural products/industrial chemicals.21

              It is expected that demand for flexible packaging will  continue to increase, leading to
              increasing growth in the use of flexographic inks and printing processes. The flexible
              packaging industry was expected to grow by an estimated 3.7% to $18.1 billion in 1998.
              Figure 2.2 illustrates the growth in the flexible packaging industry between 1991 and
            .  1998.22
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                            Figure 2.2 Size of Flexible Packaging Industry, 1991-1998
                                              (Billions of Dollars)
                          •   1991
                          D   1994
                          B   1997*
                  1992
                  1995
                  1998**
1993
1996*
              *FPA Estimate
*FPA Forecast Source: FPA, 1998
              Shorter print runs  with more variability and  faster delivery:  Increasing market
              segmentation, and significant technological improvements in the flexible packaging and
              printing industries, have caused many industries to expand the alternatives within a product
              line.  For example, potato chip manufacturers may market a variety of products such as
              "light", "low salt", and "barbecue", where there once was only one product. This trend
              has also led to more applications for pressure-sensitive labels.23

              Another aspect of this trend has been a move toward shorter printing turnaround and faster
              delivery.  Packaging now acts as  "on-the-shelf" promotion, requiring shorter runs for
              specialized  products.   With  comparable quality and  lower  cost of printing plates,
              flexography is able to respond to the  demands  for shorter, more frequent runs more
              economically than the gravure and lithographic processes.

              Expanded variety of products: In recent years the combination of general economic
              growth and improvements in the flexible packaging and flexographic printing quality have
              led to greater use of flexography  for printing a wide variety of packaging, including
              packaged fresh foods, convenience foods, drugs,  surgical  and  medical products, and
              agricultural and industrial products and  chemicals.

              Digital Technology: Recent, rapid growth in digital prepress and output technology have
              created a variety of new markets and applications for digitally printed products.

              Other factors that will tend to influence  the future of flexographic printing include:

                  •  Growth of new electronic "publication" venues, such as the Internet
                  •  Regulatory issues
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                  •   Continued mergers and acquisitions
                  •   Rapidly increasing competition
                      Globalization of trade

             The combined long-term effects of all these trends are not clear, but some industry experts
             predict potentially difficult times ahead for small printers and those that do not continue to
             confront the rapidly changing marketplace of the future.

      Markets for Printing Inks Overall

             The use of flexographic inks has been increasing faster than that of any other ink type, a
             trend that is expected to  continue.  According to  Ink  World magazine, in 1997  the
             flexographic ink market was growing at a rate of 6-8 % annually, with the largest gains in
             the Corrugated, Folded Carton and Labels sectors.24  Flexographic inks represented 18%
             (about $720 million) of the $4 billion printing ink market  in 1997.25

             The largest consumers of printing ink overall in 1998 were the publication and commercial
             segments of the printing industry, followed by  the packaging ink  segment.26  In  1998,
             flexographic inks made up 58% of the packaging ink segment  but only  3% of the
             publication and commercial printing ink segment (Figures 2-3 and 2-4).

                 Figure 2-3 Market Composition of the Publication and Commercial Printing Ink
                                               Segment (1998)
                              Letterpress
                              Litho. Heatset
                              Gravure
       Qj  Litho. News and No-heat
       H . Litho. Sheetfed
       §T]  Flexography
              Source: NAPIM, 1999
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                      Figure 2-4 Market Composition of the Packaging Ink Segment (1998)

               40% -
               35% -
               30% -
               25% -
               20% -
               15%-
               10%-
                             Other
                             Flexo. Water-based
                             Gravure Water-based
            Litho. Sheetfed
            Flexo. Solvent-based
            Gravure Solvent-based
              Source: NAPIM, 1999
              According to industry reports, 1995 -1998 were difficult years for ink manufacturers.27
              Faced with increasing raw material costs and aggressive pricing strategies by the largest
              manufacturers, many manufacturers experienced decreases in sales growth.  Raw material
              costs have been a particular problem for the industry since prices began to rise dramatically
              hi 1994.  Raw material costs accounted for 57% of the value of shipments in 1995 and
              1996.28

              In the past few years the printing ink industry has experienced a very active period of
              mergers and acquisitions, reflecting a similar trend in flexography.  This is reflected in the
              volume of sales for the largest ink companies. As shown in Table 2.3, Sun Chemical had
              more than three times the 1997 sales dollars than the number 2 company, Flint Ink.  The
              top 20 companies in Table 2.5 totaled $3,940 million in 1997 sales.
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                             Table 2.3  Leading U.S. Ink Manufacturers in 1^97
Rank
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
15
17
18
19
20

Com oan v
Sun Chemical
Flint Ink
INX International
The Ink Company
Alper Ink Group
Siegwerk
Superior Printing Ink
Heritage Inks International
SICPA Industries of America
Van Son Ink Corp. (of
America)
Wikoff Color Corp.
Nazdar
Color Converting Industries
Handschy Industries
Coates Brothers Inc.
Toyo Ink America
Braden Sutphin Ink Co.
Louis Werneke Co.
Central Ink
Manders Premier
Total sales of too 20 firms
Location
Fort Lee, NJ
Detroit, Ml
Elk Grove Village, IL
W. Sacramento, CA
New York, NY
Lynchburg, VA
New York, NY
Edison, NJ
Springfield, VA
Mineola, NY
Fort Mill, SC
Shawnee, KS
Des Moines, IA
Bellwood, IL
Rutherford, NJ
Englewood Cliffs, NJ
Cleveland, OH
Plymouth, MN
West Chicago, IL
Niles. IL

Sales (Smillibn)
2,dooa
625
310
125
120
80
78
62
60
60
59
57
49
41
40
40
38
35
31
30
3.940
                Source: Ink World, April 1997.
                a$2 billion in worldwide printing ink sales. $1 billion in North American ink sales, including
                revenues from General Printing Ink (GPI), US Ink, and Kohl & Madden.
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       Markets for Flexographic Ink Systems

              The Solvent-based Ink System
               Solvent-based inks are widely used in many flexographic printing processes. They are
               generally considered to be the industry standard for ease of use and quality of printing.
               However, use of solvent-based inks has raised a number of environmental concerns, and
               other ink systems were developed partly to improve on some of these concerns.

              The Water-based Ink System
               Water-based inks were first used to print kraft linerboard for  decorative  corrugated
               cartons.  Improvements in the printability of water-based inks paralleled concerns about
               environmental regulations related to use of solvent-based inks. This spurred the increased
               use of water-based inks in many other areas of flexographic printing. In 1998, water-based
               inks made up 51 % of the printing inks consumption ($435 million of $850 million total)
               and 60% of the volume of all flexographic inks.29 In 1999 all newsprint was printed with
               water-based inks,30 about 30% of all film was printed with water-based inks, and wide-web
               printing consisted of 51 % water-based inks.31 Water-based inks are now used to print 80%
               of the total market of printing films, corrugated, paper and paperbbard, low-end giftwrap.32

              The UV-cured Ink System
               Packaging that comes in direct contact with food and medicine usually has not been printed
               with UV-cured inks because of the odor from any uncured ink and because of the potential
               for monomers  in the ink  to migrate through the packaging to  the product.   Newer
               developments have improved UV technology in both areas, and UV flexographic printing
              may eventually stake a market share in this lucrative segment of packaging.  Cationic inks,
              because they cure more thoroughly, could play .a significant  role in  expanding these
              markets.33

              The decrease in the amount of photoinitiator (the most expensive component) required for
              UV technology, and the increasing  size of the market for UV inks (especially in the
              narrow-web field), are causing the price of UV inks to drop. The use of UV inks has also
              been steadily increasing. The use of UV flexographic inks grew by 12% in 1999.34 This
              technology has gained a strong foothold  in narrow-web labels  and tags.  By 1998 UV
              accounted for at least $85 million in ink consumption.35

              This combination of factors is expected to cause UV curing to continue to grow in market
              share, and to make some inroads into wide-web printing.

              However, the technology to remove VOCs and other harmful chemicals from solvent-based
              ink emissions improved markedly during the 1990s.  In addition, regulators began to apply
              environmental regulations to water-based ink emissions as well as to solvent-based inks.
              Partly for these reasons, the market for UV inks has not increased  as rapidly as was once
              expected.

              Table 2.4 lists the dollar volume  of inks used by different'flexographic product markets.
              One of the largest industries to use flexographic inks is the packaging industry,  which uses
              90% of flexographic inks.36 Table 2.5 shows the quantity and value of product shipments
              of flexographic inks in 1997. The total value of shipments of flexographic inks in that year
              was  $703.1 million.
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                          Table 2.4 Use of Flexographic Inks by Product Category
Product
Flexible Packaging
Corrugated Containers
Food Containers
Labels/Envelope/Commerciai Printing
Bags
Newspaper
Household Paper
Miscellaneous
Wall Coverings
Rigid Plastics
Folding Cartons
Total
1994 Ink Use ($ million V
290
150
50
45
40
25
20
20
15
10
10
675
               a Wainberg, Peter.  1995. "Not Only Flexo Ink...But Technology." FLEXO, June 1995.
                               Table 2.5 1997 Shipments of Flexographic Inks
Ink type
Solvent-based
Water-based
News and Commercial
Other Flexographic
Flexographic , n.s.k."
Total
Product Shipments
Value (million dollars)
160.5
334.2
102.4
50.6
55.4
703.1
                Source: U.S. Department of Census, 1999.
                a NAPIM, 1998.
                b Not specified by kind.
        Imports and Exports for Flexographic Inks

              Exports of colored flexographic inks have been rising over recent years, but import volume
          ;    decreased significantly in 1999.

              NAPIM estimated 1998 total U.S. printing ink exports at 52 million kilograms (about 115
              million pounds), a 9.7% increase over 1997.  Major  destinations for exports of U.S.
              printing inks include Canada, South America, Asia/Pacific, Europe, Mexico, Central
              America, and the Carribean.  Exports to Mexico grew  by 76.4% between 1997 and the
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               first 11 months of 1998.37  This may be due to the increased trade opportunities made
               available through the North American Free Trade Agreement (NAFTA).

              Exports of black flexographic inks dropped by  about 50% between 1998 and  1999
              (2,406,900 kilograms in  1998 to 1,166,040 kilograms in 1999).  Exports of colored
              flexographic  inks increased by 16%  from 8,342,930 kilograms in 1998 to 9,671,620
              kilograms in  1999.

               The United States imports printing inks from Japan, Canada, Germany, the Netherlands,
               the United Kingdom, and Mexico. In 1998 the United States imported 20 million kilograms
               of printing inks, including 638,660 kilograms of black flexographic ink (NAPIM, 1999).
               In 1999, however, imports of black ink fell by more than 50% to 301,770 kilograms.
               Imports of other colors of flexographic inks also fell by 25%, from 2,521,000 kilograms
               in 1998 to 1,893,370 kilograms in 1999.3s
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2.3 FEDERAL REGULATIONS
              This section describes federal environmental, health, and safety regulations that may affect
              the use of flexographic printing chemicals and inks.  Regulatory requirements have
              significant  effects on  costs, equipment requirements,  overhead, and  owner/operator
              liability.

              Flexographic printers may be subject to some of the following federal laws:

                  •   Clean Air Act (CAA)
                  •   Resource Conservation and Recovery Act (RCRA)
                  •   Toxic Substances Control Act (TSCA)
                  •   Clean Water Act (CWA)
                  •   Safe Drinking Water Act (SDWA)
                  •   Comprehensive  Environmental  Response,  Compensation,  and Liability Act
                      (CERCLA)
                  •   Emergency Planning and Community Right to Know Act (EPCRA)
                  •   Occupational Safety and Health Act (OSH Act)

               Federal environmental laws often provide for implementation by federally  approved,
               authorized, or delegated state or local agency programs.  These programs must be at least
               as stringent as the federal programs, and may be more stringent. There may also be
               additional  state or local requirements that have no  federal counterpart.  This summary
               discusses only federal laws, and only covers ink chemicals referenced in this CTSA.
               Therefore, readers  should  be aware of state and  local regulations, and requirements
               associated with  chemicals not used in  this CTSA.  Also,  this section only discusses
               regulations applicable to the flexographic printing process; other activities undertaken in
               a printing facility (such as prepress processes) may involve other requirements. A list of
               additional  sources for regulatory information can be found in the box at the  end of this
               section.
        Clean Air Act
               Air regulations represent the major environmental challenge for flexographic printers. The
               Clean Air Act (CAA) and amendments were established to protect and improve air quality
               and reduce damage to human health and the environment by air pollutants.

               Three components of the Clean Air Act are particularly relevant to printers: the National
               Ambient Air Quality Standards (NAAQS), National Emission Standards for Hazardous Air
               Pollutants (NESHAP), and permitting.

               National Ambient Air Quality Standards (NAAQS)
               The National Ambient Air Quality Standards (NAAQS) set maximum concentration limits
               for six air pollutants.  The most relevant to printers is ozone, which is the principal
               component of smog and is created in part by volatile organic compounds (VOCs) released
               from inks.  Each state must develop a State Implementation Plan (SIP) that identifies
               sources of pollution for these six pollutants and determines what reductions are required
               to meet the NAAQS.  If the region violates the standard for ozone, it is classified as a
               nonattainment area.  Depending on the degree of nonattainment,  specific pollution
               controls, such as those described in the Control Technology Guidelines (CTGs), may be
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                mandated for sources with potentially uncontrolled VOC emissions. The three basic control
                guidelines developed for flexographic and gravure printing are the following:
                   •   Use of add-on controls such as thermal and catalytic oxidizers, carbon absorption,
                       or solvent recovery, with a reduction rate of 60%.
                   •   Use of water-based inks that contain at least 75 % by volume water and at most
                       25% by volume organic solvents.
                   •   Use of high-solids inks that have a solvent content of no more than 40% by
                       volume.

                National Emissions Standards for Hazardous Air Pollutants
                EPA  has promulgated National  Emission Standards  for Hazardous  Air Pollutants
                (NESHAPs) for the printing and publishing industry. (These cover wide-web flexography
                and rotogravure.) Section  112 of.the CAA requires EPA to establish NESHAPs for all
                major source categories of stationary sources  that emit  any of the 188  Hazardous Air
                Pollutants (HAPs) listed in the CAA. HAPs are listed for regulation because they present,
                or may present, a threat of adverse human health effects or adverse environmental effects!
                The CAA defines major sources as those that emit, or have the potential to emit, 10 tons
               per year of any one HAP or 25 tons per year of any combination of HAPs.

               NESHAPs require regulated sources  to meet  emission  standards  which represent the
               maximum degree of reduction in emissions that EPA determines is achievable for sources
               hi the category. Such standards are known as Maximum Achievable Control Technology
               Standards or MACT.   In  addition to meeting the emission standard, the source must
               maintain records,  file reports,  and correctly  install, use, and  maintain monitoring
               equipment.

               Each affected wide-web flexographic printing facility must limit monthly HAP emissions
               to one of the following measures:
                   •   five percent of the organic3 HAPs
                   •   four percent of the mass of inks, coatings, varnishes, adhesives, primers, solvents,
                      reducers, thinners,  and other materials
                   •   twenty percent of the mass of solids, or
                   •   a calculated equivalent allowable mass based on the organic HAPs and solids
                      contents of the inks, coatings, varnishes, adhesives, primers, solvents, reducers,
                      thinners, and other materials

               These limits can be achieved by substituting non-toxic chemicals  for organic HAPs,
               installing traditional emissions capture and control equipment, or  implementing some
               combination of these two compliance options.

               Five HAPs are found  in the inks  used  for this CTSA,  and are listed  in Table 2.6.
               Additionally,  Section 112(r) of the CAA  lists chemicals  that are acutely toxic or
               flammable.   If a CAA 112(r) chemical is held in a process  in a quantity above the
               applicable threshold level, the facility must establish a Risk Management Program to avoid
               the accidental release of the chemical. One chemical used hi this CTSA, ammonia,  is
               regulated under CAA 112(r), with a threshold of 10,000 (or 20,000 pounds in the case of
               ammonia hydroxide).
        1 Organic HAPs are a subset of VOCs that excludes certain inorganic compounds.
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              Permitting
              Printers may be required to  obtain two types  of permits  related to  air emissions:
              construction and operating.  Construction permits are issued by state or local agencies;
              they are required when building a new facility, and may be required when installing new
              equipment such as a printing press.  It may be necessary to obtain a  construction permit
              before beginning pre-construction activities such as moving existing  equipment, pouring
              concrete, or making arrangements for utility connections.

              Many printers also are required to obtain operating permits.  One kind of operating permit
              is that  issued by  state or local agencies.   They may contain enforceable operating
              conditions and control requirements, as well as recordkeeping and reporting requirements.

              Under Title V of the Clean Air Act Amendments of 1990, major sources are required to
              obtain a Title V operating permit.  Major sources are facilities that have the potential to
              emit 10 tons per year or more of any individual HAP, 25 tons per year or more of any
              combination of HAPs, or 100 tons per year  or more of any air pollutant classified as a
              VOC.  The  thresholds are  lower for facilities in ozone nonattainment areas.  Permit
               applications include a period of review by the public, neighboring states, and EPA. Permit
               requirements include  emissions monitoring, record keeping,  reporting, and all of a
               facility's other CAA requirements.

               Under  certain conditions, an  alternative to  Title V permits may be available.  These
               Federally Enforceable State Operating Permits (FESOPs) limit emissions from a facility
               to below the Title V thresholds. FESOPs are generally less complicated than Title V
               permits and are issued by states but can be enforced by EPA.
                               Table 2.6 CTSA Chemicals Regulated Under CAA
                    Chemical
Hazardous Air Pollutant
Risk Management Plan
                 Ammonia3

                 Butyl carbitol
                 Ethyl carbitol
                 Styrene
                 In concentrations greater than 20%.
         Resource Conservation and Recovery Act

                The Resource Conservation and Recovery Act (RCRA) governs the management of
                hazardous waste.  Hazardous waste can be identified as characteristic (ignitable, corrosive,
                reactive, or toxic) or as a  specific listed waste (e.g., certain spent solvents, such as
                toluene). (See Section2.4, Process Safety Assessment, for an explanation of characteristic
                wastes.)  The major solvents used by flexographic printers are categorized as ignitable.
                Hazardous wastes must be treated, stored, and disposed of only by approved methods, and
                require strict recordkeeping.
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                 RCRA hazardous wastes are categorized by codes. Characteristic wastes are indicated by
                 a "D" code. There are four categories of listed hazardous wastes, two of which are most
                 relevant to the printing industry:

                    •   The F  list designates particular wastes from  certain common industrial or
                        manufacturing processes. They are wastes from non-specific sources, because
                        processes producing these wastes can occur in different industries.   This  list
                        includes certain spent solvents.
                    •   The U list includes hazardous pure or commercial grade formulations of certain
                        specific unused  chemicals.    These wastes  include  product  that  has  been
                        accidentally spilled or cannot be used because it does not meet specifications.

                Some chemicals appear under multiple lists, depending on their use; for example, ethyl
                acetate is associated with waste codes U112 (as a product waste) and F003 (as a spent
                solvent waste). Table 2.7 lists chemicals used in this CTSA that may be regulated under
                RCRA.

                               Table 2.7 CTSA Chemicals Regulated Under RCRA
                 Chemical
D Waste Code"    F Waste Code    U Waste Code
                 Barium                          D005

                 Ethyl acetate                     D001

                 Ignitable solvent-based inks        D001

                 Isobutanol                       D001
                      F003
                      F005
U112
                                                                                   U140
                 •Characteristic wastes (D code) are regulated as hazardous wastes when they exhibit the
                 characteristic (e.g., ignitabie if the flashpoint is below 140°F) or contain the toxic constituent at
                 levels above the level of regulatory concern.
               Hazardous waste generators are subject to one of three sets of requirements, depending on
               the volume of hazardous waste generated:

                  •   Large Quantity Generators (LQG) generate greater than 1000 kg (approximately
                      2200 Ibs) of hazardous waste per month or greater than 1 kg (2.2 Ibs) of acutely
                      hazardous waste per month.

                  •   Small Quantity Generators (SQG) generate between 100 kg (approx. 220 Ibs.) and
                      1000 kg (approx. 2200 Ibs.) of hazardous waste per month and less than 1 kg of
                      acutely hazardous waste per month.

                  •   Conditionally Exempt Small Quantity Generators (CESQG) generate no more than
                      100 kg (approx. 220 Ibs.) of hazardous waste per month and less than 1 kg (2.2
                      Ibs.) of acutely hazardous waste per month.

               CESQG requirements include hazardous waste identification, waste counting to determine
               generator status, maximum quantity limits, and a requirement to treat or dispose of waste
               on-site or at specified off-site facilities. SQG and LQG requirements also include storage
               unit specifications, personnel training, recprdkeeping, and contingency plans.  See table
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              2.8 for more information on the requirements for each generator status level.  The
              substitution of materials that do not result in hazardous waste generation can reduce or
              eliminate RCRA requirements.

                               Table 2.8  Requirements for RCRA Generators
Requirement
EPA ID Number
On-site
Accumulation
Quantity
Accumulation
Time Limits
Storage
Requirements
Off-site
Management of
Wastes
Manifest
Biennial Report
Personnel
Training
Contingency
Plan
Emergency
Procedures
Transport
Requirements
CESQG
Not Required
* 1,000 kg (-2,200
Ibs.); ^ kg (2.2 Ibs.)
acute; 100 kg (-220
Ibs.) acute spill
residue
None
None
State approved or
RCRA
permitted/interim
status facility
Not Required
Not Required
Not Required
Not Required
Not Required
Yes [if required by
U.S. Department of
Transportation (DOT)]
SQG
Required
<;6,000 kg (-13,200
Ibs.)
<;180daysor<;270
days (if >200 miles)
Basic requirements
with technical
standards for tanks
or containers
RCRA
permitted/interim
status facility
Required
Not Required
Basic Training
Required
Basic Plan
Required
Yes
LOG
Required
No Limit
<;90 days
Full compliance
for management
of tanks,
containers, drip
pads, or
containment
buildings
RCRA
permitted/interim
status facility
Required
Required
Required
Full Plan
Required
Required
Yes
               Source: U.S. EPA, RCRA, Superfund & EPCRA Hotline Training Module: Introduction to Generators,
               1999.
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         Toxic Substances Control Act

                The Toxic Substances Control Act (TSCA), enacted in 1976 and subsequently amended,
                gives EPA a broad mandate to protect health and the environment from unreasonable
                chemical risks, to gather information, to identify harmful substances, and to control those
                substances  whose risks outweigh their benefits to society  and the economy.  TSCA
                provides EPA the authority to regulate activities conducted by manufacturers, importers,
                processors, distributors, users, and disposers of chemical substances or mixtures.   The
                major sections of interest to flexographic ink formulators and printers are described below.

                Section 4
                Section 4 authorizes EPA to require testing of certain chemical substances  or mixtures
                identified as risks to determine their effects on human health or the environment.   The
                TSCA Master  Testing List  is  a list  of chemical  substances  for  priority  testing
                consideration. Its major purposes are to 1) identify regulatory and voluntary chemical
                testing needs, 2) focus limited EPA resources on those chemicals with the highest priority
                testing needs, 3) publicize EPA's testing priorities for industrial chemicals, 4) obtain broad
                public comments on EPA's testing program and priorities, and 5) encourage initiatives by
                industry to help EPA meet those priority needs.

                Section 5
                Section 5 requires manufacturers and importers of new chemical substances  (substances
                not previously listed on the TSCA Inventory) to submit a Premanufacrure Notice to  EPA
                90 days prior to nonexempt commercial manufacture or import.   Similar reporting is
                required for those existing chemical substances (substances listed on the TSCA Inventory)
                for which certain  activities have been designated as a "significant new use."  Upon
                reviewing these notices, EPA may 1) issue an order or rule regulating the manufacture,
                use, or disposal of the substance, 2) require a manufacturer, importer, or processor of the
                new chemical or a chemical for a significant new use to  develop test  data, and/or 3)
                promulgate a rule identifying significant new uses of the substance.
                                         Section 5 and Acrylate Esters

               A Significant New Use Rule (SNUR) was proposed for acrylate esters, which are found in
               some flexographic ink formulations.  However, EPA withdrew the proposed SNUR after
               receiving,  under  the terms  of  a voluntary agreement, toxicity data  from acrylate
               manufacturers that determined that neither triethylene glycol diacrylate nortriethylene glycol
               dimethacrylate were considered carcinogenic. As a result, EPA no longer supports the
               carcinogen concern for acrylates as a class. However, EPA may still regulate and maintain
               health concerns for certain acrylates on a "case-by-case" basis when they are structurally
               similar to  substances for which  EPA  has supporting toxicity  data or when  there are
               mechanistic/toxicity data supporting the concern. Data from experimental studies show some
               acrylates  can  cause  carcinogenicity, genotoxicity,  neurotoxicity,  reproductive and
               developmental effects, and respiratory sensitization.  For dermal exposure, EPA continues
               to recommend the use of protective equipment, such as impervious gloves and  protective
               clothing, for workers exposed to new or existing acrylates and methacrylates. For inhalation
               exposure,  NIOSH-approved respirators or engineering controls to reduce or eliminate
               workplace  exposures should be used.  EPA continues to evaluate the acrylate chemical
              Icategory for ecotoxicity.
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              Section 6
              Section 6 provides EPA with the authority to regulate the manufacture,  processing,
              distribution in commerce, use and disposal of chemical substances or mixtures determined
              to pose an unreasonable risk to health or the environment. EPA may prohibit or limit the
              manufacture, processing, distribution  in commerce, use,  or disposal of a substance.
              Action can range from a complete ban to a labeling requirement.

              Section 8
              Under section 8(a) of TSCA, EPA has promulgated regulations at 40 CFR part 712,
              subpart B (the Preliminary Assessment Information Rule (PAIR)), which established
              procedures for chemical manufacturers and importers to  report production, use, and
              exposure-related information on listed chemical substances.  Any person (except a "small
              manufacturer or importer") who imports or manufactures chemicals identified by EPA in
              this rule must report  information on production volume,  environmental releases, and
              certain other releases. Small manufacturers, or importers may be required to report such
              information on some chemicals. TSCA section 8(a) affects  large ink manufacturers with
              total annual sales from all sites owned or controlled by the domestic or foreign parent
              company at or above  $30 million for the reporting period, and who produce or import.
              45,400 kilograms (100,000 pounds) or more of the chemical (see 40 CFR 712.25(c)).

              Sections 8(a) and (b) and the implementing regulations, 40 CFR part 710, require EPA to
              compile, maintain and publish a list of all chemical substances manufactured  in, imported
              into, or processed in the  United States  (the  TSCA Inventory).   Certain chemical
              manufacturers and importers are required to regularly report additional  information
              necessary to allow EPA to maintain the inventory (TSCA Inventory Update Rule).

              Under EPA's section 8(c) regulations at 40  CFR part 717, manufacturers, importers and
              processors must maintain records of significant  adverse reactions to  health or  the
              environment for which certain allegations of harm have been made by plant personnel,
              consumers,  or the surrounding community.  See 40 CFR 717.5 to determine if these
              requirements apply to flexographic printing industry chemicals. A word of caution: an
              allegation may be of such a serious nature as to be considered an 8(e) notification.

              Under section 8(d) of TSCA, EPA has promulgated regulations that require any person
              who manufactures, imports, or, in some cases, processes (or proposes to manufacture,
              import, or,  in some cases, process) a chemical substance or mixture identified under 40
              CFR part 716 must submit to EPA copies of unpublished health and safety studies with
              respect to that substance or mixture.

               Section  8(e) provides, that  any  person who  1)  manufactures, imports, processes or
               distributes in commerce a chemical substance or mixture, and 2) obtains information which
               reasonably supports the conclusion that such substance or mixture presents  a substantial
               risk of injury to health or the environment must immediately report that information to
               EPA.unless the person has actual knowledge that EPA has been adequately informed of
               such information.

               Section 12
               Section 12 requires exporters of certain chemical substances or mixtures to notify EPA
               about these exports and EPA, in turn,  must notify the relevant foreign governments.
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               Section 13
               Section 13 requires importers of a chemical shipment to certify at the port of entry to the
               U.S. that either 1) the shipment is subject to TSCA and complies with all applicable rules
               and orders thereunder, or 2) the shipment is not subject to TSCA.
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    The Chemical Right-to-Know Initiative and the High Production Volume Challenge Program
  he Chemical Right-to-Know Initiative was launched in 1998 in response to studies by the Environmental
 Defense Fund, the American Chemistry Council, and EPA that found that most commercial chemicals have
  ery little, if any, toxicity information on which to make sound judgements about potential risks. Three key
  omponents of the RTK Initiative are to:
     •   complete baseline testing on the most widely used commercial chemicals
     •   conduct extensive testing on chemicals to which children are disproportionately exposed
     •   collect TRI release information on high-priority PBT (persistent,  bioaccumulative, toxic) chemicals
  'he ultimate goal of the RTK Initiative is to make this information publicly available so that the public can
 make informed choices and decisions about their health and local environment.
 EPA challenged industry to voluntarily undertake testing on 2,800 HPV (high production volume) chemical
 or which baseline data are not available.   HPV chemicals were defined as those manufactured in, or
 mported into, the US in amounts equal to or exceeding 1 million pounds per year (based on 1990 Inventory
 Update Rule data). Many of the HPV chemicals have been sponsored by industry, and EPA hopes to have
 all HPV testing completed by 2004. The following chemicals in the Flexo CTSA are in the HPV challenge
              Table 2.9  Chemicals in the High Production Volume Challenge Program
             Butyl acetate
             Butyl carbitol
             C.I. Pigment Blue 15
             C.I. Pigment Blue 61
             C.I. Pigment Green 7
             C.I. Pigment Red 48, barium salt
             C.I. Pigment Red 48, calcium salt
             C.I. Pigment Yellow 14
             Citric acid
             D&C Red No. 7
             Dicyclohexyl phthalate
             Dioctyl sulfosuccinate, sodium salt
             Dipropylene glycol methyl ether
             Distillates, (petroleum), hydrotreated light

             Distillates, (petroleum), solvent-refined
             light paraffinic
             Erucamide
             Ethanol
             Ethanolamine
             Ethyl acetate
             Ethyl carbitol  	 	
  2-Ethylhexyl diphenyl phosphate
  n-Heptane
  1,6 Hexanediol acrylate
  Hydroxypropyl acrylate
  Isobutanol
  Isopropanol
  Paraffin wax
  Polyethylene glycol
  Propanol
  Propyl acetate
  Propylene glycol methyl ether
  Propylene glycol propyl ether
  Resin acids, hydrogenated, methyl esters
  Solvent naphtha (petroleum), light
  aliphatic
  Styrene

  Tetramethyldecyndiol
  Titanium isopropoxide
  Trimethylolpropane ethoxylate triacrylate
   Trimethyolpropane triacrylate
   Urea
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                              Table 2.10 CTSA Chemicals Regulated Under TSCA
 Chemical Name

 Ammonia
 Butyl acetate
 Butyl carbitol
 Dicyclohexyl phthalate
 Dipropylene glycol
 methyl ether
 Ethyl acetate
 Ethyl carbitol
 2-Ethylhexyl diphenyl
 phosphate
 n-Heptane
 1,6-Hexanediol
 diacrylate
 Hydroxypropyl
 acrylate
 Isobutanol
 Isopropanol
 Propylene glycol
 methyl ether
Silicons oil
Styrene
Urea
                                        Section 4    Section 8(a)  Section 8(d)   Section 12(b)
                                                        PAIR
       Clean Water Act
              The Clean Water Act (CWA) protects the chemical, physical, and biological quality of
              surface waters (e.g., lakes or rivers) in the United States. The CWA regulates wastewater
              discharged directly into surface waters or into municipal sewer systems.  Most printers
              discharge wastewater to municipal sewer systems, which also are known as Publicly
              Operated Treatment Works (POTWs).
              National Pollutant Discharge Elimination System Program
              Discharges of wastewater from point sources directly into a navigable water body are
              regulated under the National Pollutant Discharge Elimination System (NPDES) program
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               (CWA §402). This program applies to commercial and industrial facilities, as well as to
               POTWs.  This program requires affected facilities to apply for a NPDES permit that is
               issued either by EPA or an authorized state agency.

               The permits issued under NPDES contain industry-specific, technology-based, and water
               quality-based limitations on wastewater effluent.   Generally, all facilities must meet
               limitations reflecting the best  available control technology, regardless of the quality of
               receiving waters.  Additionally, water  quality-based limitations may also be required
               depending on the classification of the waters to which the  effluent is discharged.  For
               example, state and locally mandated water quality criteria may be designated to protect
               surface waters for aquatic life and recreation. In addition, NPDES permits specify the
               pollutant monitoring and reporting requirements for each regulated facility.

               In addition, a storm water permit may be required if storm water is released to waters of
               the United States or to a municipal separate storm sewer system.  In states in which EPA
               is the NPDES permitting authority, printers are eligible for the Multi-Sector General
               Permit (MSGP).   In  states where  state  agencies are authorized to execute NPDES
               permitting, requirements may be different or more stringent.  A MSGP application
               requires a  Storm Water Pollution Prevention Plan (SWPPP), which  includes site maps
               showing drainage and outfall locations, an inventory of exposed materials, and pollution
               prevention Best  Management Practices  (BMPs).   At least  two  days  prior to the
               commencement of industrial activity, the facility would submit a Notice of Intent (NOI).
               Compliance  with the MSGP may  require  visual  examinations and analytical and
               compliance monitoring. If contaminated storm water is (or is planned to be) dischaged to
               a POTW, the POTW must be notified and permission to discharge obtained.

               Printing facilities may be eligible for a conditional no exposure exclusion from storm water
               permitting.  The exclusion is applicable if "all industrial materials and activities are
               protected by a storm resistant  shelter to prevent exposure to rain, snow, snowmelt, and/or
               runoff," the facility operator  submits a written No Exposure Certification form, and the
               operator allows the permitting authority to inspect the facility and make inspection reports
               publicly available upon request.

                Wastewater Discharges to POTW
               Printing facilities that discharge or otherwise introduce their wastewater to POTWs are not
                required to obtain a National Pollutant Discharge Elimination System (NPDES) permit.
                However, such facilities may be  required to comply with regional and local discharge
                requirements and federal or local pretreatment standards, and obtain local permits.  Such
                requirements are established by the local and regional sewerage authorities to prevent
                significant interference with the  POTW.  Certain requirements also prevent the  pass-
                through of hazardous, toxic, or other wastes not removed by available treatment methods.
                A POTW may require commercial and industrial customers, including printers, to monitor
                wastewater, keep records, and notify the POTW of certain discharges.

                A national pretreatment program (CWA §307(b)) regulates the introduction of pollutants
                to POTWs by  industrial users. Pretreatment standards include general prohibitions and
                 categorical industry standards (implemented on a nationwide basis), as well as local limits.
                 General prohibitions  involve pollutants that may not be introduced by any POTW users.
                 These include the following materials:
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                    •   Pollutants that cause a fire or explosion hazard in the POTW
                    •   Pollutants that will cause corrosive structural damage to the POTW
                    •   Solid or viscous pollutants in amounts which will cause obstruction to the flow in
                       the POTW
                    •   Any pollutant, including oxygen demanding pollutants (BOD, etc) released in a
                       discharge at a flow rate and/or pollutant concentration that will cause interference
                       with the POTW
                    •   Heat in amounts that will inhibit biological activity in the POTW
                    •   Petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin in
                       amounts that will cause interference or pass-through
                    •   Pollutants that result in the presence of toxic gases, vapors' or fumes within the
                       POTW in a quantity that may cause acute worker health and safety problems
                    •   Any trucked or hauled pollutants, except at discharge points designated bv the
                       POTW.

                No  categorical pretreatment standards have been established for the printing industry.
                However, POTWs may establish local limits for customers.

                Listed Chemicals
                CTSA chemicals specifically regulated under the CWA (Table 2.11) are included in one
                of the following categories:

                   •  Hazardous substances  that are listed  under Section 311   of the CWA have
                      Reportable Quantity (RQ) thresholds; should a release of such a chemical occur
                      abpve the threshold (or the effluent limitation established in a facility's NPDES or
                      POTW permit), notice must be made to the federal government of the discharge.
                      Four chemicals found in the inks used in this CTSA are hazardous substances.
                   •  Priority Pollutants are 126 chemicals that must be tested for as a requirement of
                      NPDES permits.   One priority pollutant — surfactants (e.g., ethlyene  glycol
                      ethers) — is found in the inks used in this CTSA.
                              Table 2.11 CTSA Chemicals Regulated Under CWA
                Chemical
  Hazardous
Substance RQ
    (Ibs.)
                                                                           Priority Pollutant
                Ammonia
                Ammonium hydroxide
                Butyl acetate
                Styrene

                Surfactants (e.g., ethy!ene glycol ethers)
     100

     1000

     5000

     1000
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       Safe Drinking Water Act

              The goal of the Safe Drinking Water Act (SDWA) is to ensure that drinking water is safe
              for the public. Under the SDWA, EPA has established national primary drinking water
              regulations.  The primary regulations set maximum concentrations for substances found
              in drinking water that can adversely affect human health.  Flexographic chemicals that may
              be regulated by SDWA include barium and styrene.


       Comprehensive Environmental Response, Compensation, and Liability Act

              The  Comprehensive  Environmental Response,  Compensation,  and  Liability  Act
              (CERCLA, or more commonly known as Superfund) was enacted in 1980. CERCLA is
              the Act that created the Superfund hazardous substance cleanup program and set up a
              variety of mechanisms to address risks to public health, welfare, and the environment
              caused by hazardous substance releases.

              Two important components  of CERCLA  are  the (1) hazardous substance release
              notification requirements, and (2) establishment of the parties that are liable for response
              costs for removal or remediation of a release. Substances defined as hazardous under
               CERCLA are listed in 40 CFR 302.4.  Under CERCLA and other acts, EPA has assigned
               a Reportable Quantity (RQ) to most hazardous substances; regulatory RQs are either 1,10,
               100  1000, or 5000 pounds (except for radionuclides).   If a release greater than the RQ
               occurs, a person in charge of the facility must immediately notify the National Response
               Center'to help EPA identify sites that potentially warrant a response action.  If EPA has
               not assigned an RQ to a hazardous  substance, typically  its  RQ  is one pound.  Eight
               chemicals used in this CTSA have RQs, and are provided in Table 2.12.
                 Chemical
                             Table 2.12 CTSA Chemicals Regulated Under CERCLA
                                                                  RQdbs.)
                 Ammonia
                 Ammonium hydroxide
                 Butyl acetate
                 Butyl carbitoP
                 Dicyclohexyl phthalateb
                 Ethyl acetate
                 Ethyl carbitoP
                 Isobutanol
                 Styrene
 100
1000
5000
5000"
  •
5000
1000
                 J This chemical is part of the glycol ethers broad category; a reportable quarrtjy te not listed.
                 " This chemical is part of the phthalate esters broad category; a reportable quantity is not listed.
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         Emergency Planning and Community Right-to-Know Act

                 In 1986, Congress passed the Emergency Planning and Right-to-know Act (EPCRA) as
                 part of the Superfund Amendments and Reauthorization Act (SARA).  Three provisions
                 of EPCRA may be of concern for printers: emergency notification, community right to
                 know reporting, and the Toxic Release Inventory (TRI).

                 EPCRA Section 302 defines and regulates certain extremely hazardous substances.  If
                 quantities of these chemicals at a facility exceed the threshold planning quantities, the
                 facility must notify the state and local emergency planning committees.  These chemicals
                 are also regulated by EPCRA Section 304, which requires facilities to report releases in
                 excess of reportable quantities to the same state and local authorities, and to the local fire
                 department.  One chemical used in this CTSA, ammonia, is  listed  as an extremely
                hazardous substance (EHS).  EPCRA 304 also requires facilities to notify the  state and
                local authorities of release of  CERCLA.1 hazardous substances  so that state and local
                governments and citizens can be informed of potential hazards.

                EPCRA Sections 311  and  312  require facilities to  report inventory information on the
                hazardous chemicals present on-site. Facilities are regulated under these provisions if they
                are regulated under OSHA's Hazard Communication Standard and exceed established
                thresholds for hazardous chemicals as defined in 29 CFR 1910.1200(c) at any one time.
                Facilities using hazardous chemicals must submit reports containing information on each
                hazardous chemical's identity, physical and health hazards, and location to state and local
                emergency planning committees and the local fire department.  Reporting thresholds are
                10,000 pounds for a compound that is not classified as an EHS,  and 500 pounds or the
                chemical's threshold planning quantity (TPQ), whichever is lower, for an EHS. The EHS
                used in the CTSA, ammonia, has a reporting threshold of 500 pounds.

                Under EPCRA Section 313, a facility in a covered SIC code (of which printing is one)
                that  has 10 or more full-time  employees or the equivalent, and that manufactures^
                processes, or otherwise uses a toxic chemical listed in 40 CFR Section 372.65 above the
                applicable reporting threshold, must either file a toxic chemical release inventory (TRI)
                reporting form (EPA Form R), or if applicable, an  annual certification statement (EPA
                Form A).  The Form R details a facility's release and other waste management activities
                of these listed toxic chemicals, including those releases specifically allowed by EPA or
                state permits.  Except for the specific exemptions listed in 40 CFR372.45(d),  printers
                should be aware that suppliers of products containing TRI chemicals above certain de
               minimis (minimum) concentrations are required to notify each customer (to whom  the
               mixture or trade name  product is sold or otherwise  distributed from the facility) of the
               name of each listed toxic chemical and the percent by weight of each toxic chemical in the
               mixture or trade name product. Table 2.13 lists the six chemicals used in this CTSA that
               must be reported to TRI when  annual use exceeds the TRI thresholds.  The annual
               reporting thresholds for these chemicals, none of which are EPCRA Section 313 persistent
               bioaccumlative toxins  (PBTs),a are -25,000 pounds  for  manufacture and process,  and
               10,000 pounds for otherwise use.
         Recently promulgated rules lowered the reporting thresholds for compounds that are persistent, bioaccumlative
         toxins in the environment. Information can be obtained by contacting the RCRA, Superfund, and EPCRA Hotline
         at the number and website listed at the end of this section.
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                             Table 2.13 CTSA Chemicals Regulated Under EPCRA
                Chemical
                                                      EPCRA 302
                                                 Extremely Hazardous
                                                      Substances
  EPCRA 313
TRI Chemicals
                Ammonia
                Barium
                Butyl carbitol
                Ethyl carbitol
                Isopropanol"
                Styrene
                "Includes anhydrous ammonia and aqueous ammonia from water dissociable ammonium salts
                and other sources; 10% of total aqueous ammonia is reportable.
                "Processors and users of isopropanol are not required to report it.  It is reportable by
                manufacturers using the strong acid process.
        Occupational Safety and Health Act

               The Occupational Safety and Health Administration (OSHA) was established to reduce
               occupational health hazards.  OSHA regulations outline the educational and informational
               resources that a printer must utilize to assure the safe use of chemicals and the health of
               employees, including the following basic requirements:

                   •    Material Safety Data Sheets (MSDSs) for certain hazardous chemicals must be
                       provided  by suppliers and maintained  in-house for  use by employees.   For
                       chemicals stored and used in amounts in excess of threshold levels,  copies of
                       MSDSs must be submitted to state and local emergency planning agencies and the
                       local fire department.
                   •   If a chemical is claimed to be proprietary, the appropriate information must be
                       supplied to the designated health official.
                   •   All containers must be properly labeled.
                   •   A Job Safety and Health Protection workplace poster that indicates  employee
                       rights and responsibilities must be posted in a prominent place.
                   •   A safety training program must be developed, and all employees must be trained.
                   •   Facilities must submit an annual report indicating  the aggregate amount of
                       chemicals (above threshold quantities) used at their facilities, classified by hazard
                       category.

                The  Occupational Safety and  Health Act (OSH Act) also requires the use of personal
                protection equipment (PPE) for specific situations.  These may involve the use of gloves
                and goggles when working with certain solvents and inks.  Other requirements relevant
                to printers include the installation of emergency eye wash stations in areas where eye
                irritants are used, and the development of a hearing conservation program if noise levels
                are equal to or exceed an eight-hour time weighted average of 85 decibels.

                OSHA lockout/tagout  regulations require  the  control of energy  to  equipment during
                servicing and maintenance. To prevent a machine from unexpectedly energizing, a facility
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                must develop a plan to ensure that the energy source of a machine is locked out (with a
                locking device) or tagged out (with a prominent sign and fastener) when servicing or
                maintenance is being performed. For routine servicing (such as minor cleaning), printers
                may use effective alternative protection such as the "inch-safe-service" method which
                allows energization of the press to inch it forward for servicing purposes as long as, at a
                minimum, a stop/safe/ready function is available at designated control stations and other
                requirements are followed.

                The OSH Act also governs the exposure of workers to chemicals in the workplace. OSHA
                has established permissible exposure limits (PELs) for air contaminants, which are
                regulatory limits on the amount or concentration of a substance in the air (29 CFR
                1910.1000 Subpart Z) based on an 8-hour time weighted average.  (PELs also may have
                a skin designation.)   Other chemical  exposure concentrations  potentially used for
                regulation by OSHA include ceiling limits and short term exposure limits.
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               Table 2.14 Flexography Federal Regulations Chemical Worksheet
 Regulation
                                               Affected Chemicals
 Clean Air Act (CAA)
       112(b) Hazardous Air Pollutant
Butyl carbitol
Ethyl carbitol
Styrene
        112(r) Risk Management Plan
Ammonia (in concentrations greater than 20%)
  Resource Conservation and Recovery Act (RCRA)
        Characteristic Wastes (D Wastes)
Barium (D005)
Ethyl acetate (D001)
Ignitable solvent-based inks (D001)
Isobutanol(DOOI)
Any other waste that exhibits ignitability,
  corrosivity, reactivity, or toxicity as defined by
  RCRA
        Non-specific Source Wastes (F Wastes)
 Ethyl acetate (F003)
 Isobutanol (F005)
        Specific Unused Chemicals (U Wastes)
 Ethylacetate(U112)
 Isobutanol (U140)
  Toxic Substances Control Act (TSCA)
        Section 4
 Butyl acetate
 Butyl carbitol
 Dipropylene glycol methyl ether
 Ethyl acetate
 2-Ethylhexyl diphenyl phosphate
 n-Heptane
 Isobutanol
        Section 8(a) PAIR
 Ammonia
 Dicyclohexyl phthalate
 Dipropylene glycol methyl ether
 Ethyl acetate
 Ethyl carbitol
 2-Ethylhexyl diphenyl phosphate
 n-Heptane
 1,6 Hexanediol diacrylate
 Hydroxypropyl acrylate
 Isobutanol
 Isopropanol
 Propylene glycol methyl ether
 Silicone oil
 Styrene
 Urea
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           Table 2.14  Flexography Federal Regulations Chemical Worksheet (continued)
                   Regulation
              Affected Chemicals
        Section 8(d)
  Dicyclohexyl phthalate
  Dipropylene glycol methyl ether
  Ethyl acetate
  Ethyl carbitol
  2-Ethylhexyl diphenyl phosphate
  n-Heptane
  Isobutanol
  Isopropanol
  Propylene glycol methyl ether
  Silicone oil
        Section 12(b)
 Butyl acetate
 Butyl carbitol
 Dipropylene glycol methyl ether
 Ethyl acetate
 2-Ethylhexyl diphenyl phosphate
 n-Heptane
 Isobutanol
  Clean Water Act (CWA)
       Hazardous Substances
       (Reportable Quantities)
 Ammonia (100 Ibs.)
 Ammonium hydroxide (1000 Ibs.)
 Butyl acetate (5000 Ibs.)
 Styrene (1000 Ibs.)
       Priority Pollutants
 Surfactants
 Safe Drinking Water Act (SDWA)
       National Primary Drinking Water
       Regulations
 Barium
 Styrene
 Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
       Reportable Quantities (RQs)
Ammonia (100 Ibs.)
Ammonium hydroxide (1000 Ibs.)
Butyl acetate (5000 Ibs.)
Butyl carbitol (RQ not listed)
Dicyclohexyl phthalate (RQ not listed)
Ethyl acetate (5000 Ibs.)
Ethyl carbitol (RQ not listed)
Isobutanol (5000 Ibs.)
Styrene (1000 Ibs.)
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         Table 2.14 Flexography Federal Regulations Chemical Worksheet (continued)
                 Regulation
                                                        Affected Chemicals
 Emergency Planning and Community Right-to-Know Act (EPCRA)
       Extremely Hazardous Substances
Ammonia
       TRI Chemicals
Ammonia (10% of total aqueous ammonia)
Barium
Butyl carbitol
Ethyl carbitol
Isopropanol
Styrene
  Occupational Safety and Health Act (OSHA)
       Personal Exposure Limits (PELs)
Ammonia
Barium
2-Butoxyethanol
Butyl acetate
Dipropylene glycol methyl ether
Ethanol
Ethanolamine
Ethyl acetate
n-Heptane
Isobutanol
Isopropanol
Kaolin
Propanol
Propyl acetate
Styrene          	
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  Additional Information on Printing-Related Regulations
  I GENERAL INFORMATION                                  !    ~            ~	"——
  i
  i                           >.
  [Printers' National Environmental Assistance Center (PNEAC)
  IA website with links to compliance assistance and pollution prevention information and state-specific
  I requirements                                                                      r
               Website: www.pneac.org

  Federal Environmental Regulations Potentially Affecting the Commercial Printing Industry (1994)
  A short booklet that describes important points about the Clean Air Act, Clean Water Act RCRA etc
  and how the printing industry is affected by each. Available from The Pollution Prevention Clearinghouse
  Ask for Document EPA 744-B-94-001.
               Telephone: 202-260-1023
               Website: www.epa.gov/opptintr/library/libppic.htm

  Government Printing Office (GPO)
  The GPO website provides links to the full text of the Code of Federal Regulations (CFR), Federal Register
  notices for the past several years, and other resources!
               Website: www.access.gpo.gov/nara/

  INFORMATION ABOUT THE CLEAN AIR ACT

  The Clean Air Technology Center (CATC)
 j A source of general information on air emissions-related technology.
              Telephone: 919-541-0800
              Website: www.epa.gov/ttn/catc

 INFORMATION ABOUT THE RESOURCE CONSERVATION AND RECOVERY ACT

 The RCRA, Superfund & EPCRA Hotline offers information and publications that are relevant to RCRA
              Telephone:800-424-9346            --..-.
              Website: www.epa.gov/epaoswer/hotline
 i

 \RCRA in Focus: Printing
 | A short booklet that provides an overview of the federal regulations that the printing industry is required
 (to follow and lists the printing industry wastes that are likely to be hazardous. Available from the RCRA
 SSuperfund & EPCRA Hotline. Ask for Document EPA 530-,K-97-007.
 t                                      .
 ' Understanding the Hazardous Waste Rules: A Handbook for Small Businesses, 1996 Update
 A maiiURl that is targeted to  small quantity generators of  hazardous wastes.  The manual helps small
 businesses determine whether they generate hazardous waste and provides comprehensive information on
Ihow to comply with the federal hazardous waste regulations for small quantity generators Available from
(the RCRA, Superfund & EPCRA Hotline. Ask for Document EPA 530-K-95-001
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INFORMATION ABOUT THE TOXIC SUBSTANCES CONTROL ACT

The TSCA Assistance Information Service (TSCA hotline) can provide information TSCA.
             Telephone: 202-554-1404'
             Website: www.epa.gov/opptintr/chemtest

INFORMATION ABOUT THE CLEAN WATER ACT

The Office of Water
The Office of Water, especially the Office of Wastewater Management, can be contacted for information
on Clean Water Act provisions that relate to the printing industry.
             Telephone: 202-260-5700
             Website: www.epa.gov/OW

INFORMATION ABOUT THE SAFE DRINKING WATER ACT

The Safe Drinking Water Hotline can provide information on issues related to the Safe Drinking Water
Act.
             Telephone: 800-426-4791
             Website: www.epa.gov/OGWDW/

INFORMATION  ABOUT   THE  COMPREHENSIVE   ENVIRONMENTAL  RESPONSE,
COMPENSATION, AND LIABILITY ACT

The RCRA, Superfund & EPCRA Hotline offers information and publications that are relevant to
CERCLA.
             Telephone: 800-424-9346
             Website: www.epa.gov/epaoswer/hotline                              -

The Superfund Website provides general information on CERCLA.
             Website: www.epa.gov/superfund

 INFORMATION ABOUT THE EMERGENCY PLANNING AND RIGHT-TO-KNOW ACT

 The Chemical Emergency Preparedness and Prevention Office website
 Website offers information on the emergency response aspects of EPCRA, which are administered under
 the Chemical Emergency Preparedness and Prevention Office.
              Website: www.epa.gov/swercepp/

 The Toxics Release Inventory website
 Provides information on the Toxics Release Inventory reporting requirements, which are implemented by
 the Office of Pollution Prevention and Toxics.                         ,
              Website: www. epa. gov/opptintr/tri/index.html
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  The RCRA, Superfund & EPCRA Hotline offers information and publications that are relevant to
  EPCRA.
              Telephone:800-424-9346
              Website: www.epa.gov/epaoswer/hotline

  INFORMATION ABOUT THE OCCUPATIONAL SAFETY AND HEALTH ACT

  The Occupational Safety and Health Administration (OSHA) website
  Provides information on the Occupational Safety and Health Act, OSHA regulations, standards,
  interpretations, and other information.
              Website: www.osha.gov/

 INFORMATION ABOUT THE DEPARTMENT OF TRANSPORTATION

 The Department of Transportation (DOT) Hazardous Materials Information Center provides
 information about transporting hazardous materials.
              Telephone: 800-467-4922
 	Website: http://hazmat.dot.gov/   	
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2.4 PROCESS SAFETY

               Procedures for safely preparing, operating, and cleaning press equipment help to avoid
               serious injuries and health problems to employees. An effective process safety program
               identifies workplace hazards and seeks to eliminate or reduce their potential for harm.
               Chemicals used in the flexographic printing process present safety hazards to workers and
               the facility; therefore they must be handled and stored properly using appropriate personal
               protective equipment and safe operating practices.

                The U.S. Department of Labor and the Occupational Safety and Health Administration
                (OSHA) have established safety standards and regulations to assist employers in creating
                a safe working environment and protect workers from potential workplace hazards.  In
                addition, individual states may also have safety standards regulating chemical and physical
                workplace hazards for many industries.  Federal safety standards and regulations affecting
                the flexographic printing industry can be found in the Code of Federal Regulations (CFR)
                Title 29, Part 1910 and are available by contacting the local OSHA field office. State and
                local regulations are available from the appropriate state office.

        Reactivity, Flammabflity, Ignitability, and Corrosivity of Flexographic Ink Chemicals

                Table 2.15 lists four safety hazard factors for the nine ink product lines that were tested
                in the performance demonstrations, and Table 2.16 summarizes the safety hazards by ink
                system. (Where available, the reactivity and flammability values were extracted directly
                from Section One of the Material Safety Data Sheet (MSDS), which contains the National
                Fire Protection Association (NFPA) values for these factors.) Printers should be aware
                of the safety hazards for all chemicals used and stored hi a facility, should post the relevant
                MSDSs as required, and should consider whether ink products with lower safety ratings
                are available and suitable.

                For reactivity, NFPA ranks materials on a scale from 0 to 4, with 0 being the safest:

                   0 — materials that are normally stable, even under fire exposure conditions, and that
                   do not react with water; normal fire fighting procedures may be used.

                   1  — materials that are  normally  stable but  may  become  unstable  at elevated
                   temperatures and pressures, as well as materials that will react (but not violently) with
                   water, releasing some energy; fires involving these materials should be approached with
                   caution.

                   2 — materials that are normally unstable and readily undergo violent chemical change,
                   but are not capable of detonation;  this includes materials  that can rapidly release
                   energy, materials that can undergo violent chemical changes at high temperatures and
                   pressures, and materials that react violently with water.  In advanced or massive fires
                    involving these materials, fire fighting should be done from a safe distance from a
                   protected location.

                    3 - materials that, in themselves, are capable of detonation, explosive decomposition,
                    or explosive  reaction,  but require a strong  initiating source  or  heating  under
                    confinement; fires involving these materials should be fought from a protected location.
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                   4 - materials  that, in themselves,  are  readily capable of detonation,  explosive
                   decomposition,  or explosive reaction at normal temperatures and pressures.   If a
                   material having this Reactivity Hazard Rating is involved in a fire, the area should be
                   immediately evacuated.

                For the CTSA inks, all inks except the UV product lines were rated as completely non-
                reactive.  One UV product line was given a rating  of 1, and the others did not have a
                rating.

                For flammability,  NFPA ranks materials also on a scale from 0 to 4, with 0  being the
                safest:

                  0 — materials that will not burn.

                  1 — materials that must be preheated before ignition will occur and whose flash point
                  exceeds 200 °F (93.4 °C), as well as most ordinary combustible materials.

                  2 — materials that must be moderately heated before ignition will occur and that readily
                  give off ignitible vapors.

                  3 -flammable liquids and materials that can be easily ignited under almost all normal
                  temperature conditions; water may be ineffective  in controlling or extinguishing fires
                  in such materials.

                  4 - flammable  gases, pyrophoric-liquids,  and flammable liquids.  The  preferred
                  method of fire attack is to stop the flow of material or to protect exposures while
                  allowing the fire  to burn itself out.

               Flammability ratings for the CTSA ink product lines ranged widely.  Both solvent-based
               inks were rated  at 3, and water-based inks received ratings ranging from 0 to 3.  One UV
               product line was given a rating of 1, but the others were unrated.

               For ignitability,  the inks  are classified  as  either ignitable (y) or  not ignitable  (n).
               Ignitability is based on the flash point of the ink product line, which is the lowest
               temperature at which it can be ignited. A chemical is considered ignitable if it is a liquid,
               other than an aqueous solution containing less than 24% alcohol by volume and has a flash
               point less than 60°C  (140 °F).39 For the CTSA product lines, only the two solvent-based
               inks were rated  as ignitable.

              For corrosiveness, the inks  are classified  as either corrosive (y) or not  corrosive (n)
              Corrosiveness was determined based on the pH of the product.40 A chemical is corrosive
              if it is aqueous and has a pH less than or equal to 2 or  greater than or equal to 12.5. This
              information was not available for any product lines except one, which was rated as non-
              corrosive.
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                 Table 2.15 Safety Hazard Factors for CTSA Ink Product Lines3
Product line
Solvent-based #S1
Solvent-based #S2
Water-based #W1
Water-based #W2
Water-based #W3
Water-based #W4
UV-cured #U1
UV-cured #U2
UV-cured #U3
Formulation
(Color)
All
All
Blue, green
White, cyan
Magenta
Blue, green,
white
Cyan, magenta
All
Blue
Green
White
Cyan
Magenta
All
All
All
Reactivity
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

1

Flammability
3
3
3
2
1
0
1
1
0
2
3
2
2
3
2
0
3
2

1

Ignitability
y
y
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
Corrosivity





n















  a A blank cell indicates that there was not enough information available to develop a safety hazard factor ranking.
  For inks that were blended and therefore have more than one MSDS, the ratings for all components in each
  formulation are given.
                          Table 2.16 Summary of Safety Hazard Factors by Ink System
Ink system
Solvent-based
Water-based
UV-cured
Reactivity
0
0
c
Flammability
3
0-3
d
Ignitability
y
n
n
Corrosiveness
NDa
b
NDa
                 a No data
                 b Incomplete data — three formulations of one product line were not corrosive.
                 0 Incomplete data — all formulations of one product line were given reactivity levels of 1.
                 d Incomplete data — all formulations of one product line were given flammability levels of 1
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              The following observations can be noted from the tables:

                  •   All of the solvent- and water-based inks had reactivity levels of zero.  One UV-
                      cured ink (#U2) had a reactivity level of one; the reactivity of other UV-cured inks
                      was unknown.

                  •   Flammability was more of a concern for some inks than others. All of the solvent-
                      based inks had flammability levels of three. Some of the water-based inks (Water-
                      based inks #W2 and #W3) had flammability levels of zero or one. However, some
                      formulations of Water-based inks #W1 and #W4 had flammability levels of two or
                      three. The flammability levels for UV-cured ink #U2 was one; the flammability
                      of the other UV-cured inks were not known.

                  •   Ignitability was a concern primarily for solvent-based inks.

                  •   Although information for corrosiveness was sparse, the water-based inks for which
                      information was available were listed  as not corrosive.

  4,    Process Safety Concerns

              Exposure to chemicals is just one of the safety issues that flexographic printers may have
              to deal with during their daily activities. By establishing and following proper safeguards
              and practices, printers can benefit  in three ways: increased worker safety, lower insurance
              rates, and fewer work days missed due to accidents and injuries.

               To maintain a safe and efficient workplace, employers and employees need to understand
               the importance of establishing safety procedures and using appropriate safeguards. The
               most important safety practices include the following:

               Training
               A critical element of workplace safety and an efficiently running press is a well-educated
               workforce.  To help achieve this goal, the Occupational Safety and Health Administration
               (OSHA) Hazard Communication Standard requires that all employees be trained in the use
               of hazardous chemicals to which they may be exposed. Training may be conducted either
              by facility staffer by outside parties who are familiar with the flexography process and the
              pertinent safety concerns.   The training  should be held for each new employee, and all
              employees should have retraining when necessary (for example, if new equipment is
              installed or new ink types are used) or on a regular schedule. The training program should
              explain the types of inks, solvents, cleaning compounds, and other chemicals used, and
              precautions for handling or storing them; when  and how personal protective equipment
              (PPE) should be worn; the  need for other safety features such as equipment guards and
              their proper use; and how to maintain equipment in good operating condition.

              Contingency Plan for Chemical Spills and Emergencies
              Most states require manufacturing facilities, including flexographic printing facilities, to
              establish a contingency plan in the event of an accidental chemical release. Having a plan
              in place can reduce injuries to employees, help protect the community and environment,
              and minimize downtime.  The plan should include the following:

                 •   a list of chemicals in the facility
                 •   how the chemicals are stored and  used
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                 •   information on the likely cause, nature, and route of a chemical release
                     emergency response devices and procedures including alarm systems, evacuation
                     plans, and arrangements with local hospitals, police, and fire departments
                 •   contact information for the facility emergency coordinators
                 •   emergency equipment information, such as the location of fire extinguishers and
                     spill control kits.41

               Electrical Grounding
               Grounding  is an important safety precaution when using machinery.  When conductive
               material, like a steel central impression drum, is not grounded, the conductor may generate
               and/or store electricity.  Non-conductive or  ungrounded conductive materials become
               electrostatically charged by  friction.42   Static may be generated when the  web  is
               unwinding, when the web leaves the rollers, or by friction from shoes and clothing. Static
               is also increased by low humidity.43 Static may result in sparks that can cause explosions
               and electrical interference.  Proper grounding is the simplest way to control static.

               Storing Chemicals
               Chemicals that are ignitable or flammable should be labeled accordingly and stored in the
               appropriate storage space.  Chemicals that are incompatible with  other chemicals or that
               require special precautions during use should also be appropriately labeled and stored. For
               example, solvents and solvent-based inks should be stored in ventilated, explosion-proof
               rooms.  Since some of the chemicals used in the press room may be flammable, the facility
               should be inspected periodically by the local fire marshall to ensure that the chemicals are
               stored properly and ventilated, thus reducing the potential for a fire.

               Storing Rags and Towels
               Rags and towels that are used to wipe up chemicals or clean presses may be considered
               hazardous waste by EPA and state and local agencies if they contain specified hazardous
               chemicals  in sufficient amounts. These  towels should be stored and disposed of  in
               accordance with federal, state, and local regulations. If uncertain about whether or not the
               shop's used rags 9r towels require special treatment as hazardous waste, a printer should
               contact the state environmental agency or state technical assistance program.

               Preventive Worker Behavior
               Personal safety considerations are also the responsibility of the worker. Workers should
               be discouraged from eating or keeping food near presses or chemicals.  Since presses
               contain moving parts, workers should also refrain from wearing jewelry or loose clothing
               that may become caught in the machinery and cause injury to the worker.  In particular,
               the wearing of rings or necklaces may lead to injury. Workers with long hair should pull
               their hair back or wear a hair net to prevent the hair from getting caught in the machinery.

               Material Safety Data Sheets
               Since flexographic printing requires the use of a variety of chemicals, it is important that
               workers know and follow the correct procedures for handling the  chemicals. Much of the
               information about the use,  disposal, and storage of chemicals may be obtained from the
               Material Safety Data Sheet (MSDS) provided by the manufacturer for each ink product
               line, cleaner, and other chemicals. The MSDS also recommends the appropriate personal
               protective equipment for handling a particular chemical.  The MSDS for each chemical
               used should be placed in an easily accessible location in the vicinity of the press room.
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               Personal Protective Equipment (PPE)
                OSHA has developed several PPE standards that are applicable to the printing industry.
                These standards address general safety requirements (29 CFR Part 1910.132), the use of
                eye and face protection (Part 1910.133), head protection (Part 1910.135), foot protection
                (Part 1910.136), and hand protection (Part 1910.138). The standards for eye, face, and
                hand protection are particularly  important for printers who have frequent contact with
                chemicals (including solvents, dispersants, surfactants, and inks) that may irritate or harm
                the skin and eyes.

                In order to prevent or minimize exposure to such chemicals, workers should be trained in
                the proper use  of personal protective equipment.  For many  chemicals, appropriate
                equipment includes goggles, aprons or other impervious clothing, and gloves.  In some
                printing facilities with loud presses, hearing protection may be recommended or required.

                Equipment Guards
                In addition to the use of proper personal protective equipment for all workers, OSHA has
                developed safety standards that apply to the actual equipment used in printing facilities.
                These machine safety guards are described in 29 CFR Part 1910.212 and are  applicable
                to all sectors of the printing industry,, including flexography.  Barrier guards, two-hand
                trip devices, and electrical safety devices are among  the safeguards recommended by
                OSHA.  Safeguards for  the normal operation of press equipment are included in the
                standards for mechanical power-transmission apparatus (29 CFR Part 1910.219)  and
                include belts, pulleys, flywheels, gears, chains, sprockets, and shafts.

                The National Printing Equipment  and  Supply Association has available copies of the
                American National Standard for Safety Specifications for Printing Press Drive Controls.
                These safety recommendations address the design of press drive controls specifically, as
                well as safety signaling systems for printing presses. Printers should be familiar with the
                safety requirements included in these standards and should contact their local OSHA office
                or state technical assistance program for assistance in determining how to comply with
               them.

               OSHA also has a  lockout/tagout standard (29 CFR part 1910.147).   This standard is
               designed to prevent the  accidental start-up  of  electric machinery during cleaning or
               maintenance operations.  This  standard may  pose  particular problems  for flexographic
               printers during minor, routine procedures that require frequent stops (e.g., cleaning the
               press or on-press maintenance).  For such cases, OSHA has granted an exemption for
               minor servicing of machinery provided the equipment has other appropriate safeguards,
               such as a stop/safe/ready button which overrides all  other controls and is under  the
               exclusive control of the worker performing the servicing. Such minor servicing of printing
               presses has  been determined to include clearing jams, minor cleaning,  lubricating,
               adjusting operations, plate changing tasks, paper webbing, and roll changing. Rigid finger
               guards should also extend across the rolls, above and below the area to be cleaned. Proper
               training of workers is required under the standard whether lockout/tagout is employed or
               not. For further information on the applicability of the OSHA lockout/tagout standard to
               printing operations, printers should contact their local OSHA field office.
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REFERENCES


 1. Abt Associates Inc.  1996. Personal communication with Henry Salmaggi, Flexographic Technical
 Association.  June 26.

 2. U.S. Department of Commerce.  1999.  "1997 Economic Census: Manufacturing Industry Series, Commercial
 Flexographic Printing," EC97M-3231C, November.

 3. Lewis, A. F.  1997. Blue Book Marketing Information Reports: Graphic Arts Industry Analysis by Plant Size,
 Equipment, Product Specialties. New York, NY:  A.F. Lewis & Co., Inc.

 4. Ink World. May/June 1996.  "The Flexo Report: Improvements through ink innovations."

 5. Ibid.

 6. Flexo, December 1998.  "1999 Industry Forecasts," p. 32.

 7. U.S. Department of Commerce.  1999.  Op. cit.

 8. U.S. Department of Commerce.  1999. Op. cit.

 9. Flexographic Technical Association (FTA). 1985. Third Flexo Plant Survey. Ronkonkoma, NY:
 Flexographic Technical Association, Inc.

 10. U.S. Department of Commerce. 1999. Op.  cit.

 II. Ink World.  May  1997.   "Refining flexography." p. 37.

 12. Flexible Packaging Association (FPA).  1998. 1998 State of the Industry Report. Washington, DC:  FPA.

 13. Flexo.  February 1999.   "A bright forecast." pp.  32-33.

 14.  Ink World.  May 1999.  "The flexo report." p. 32.

 15.Flexo. February 1999."FTA corner." p. 67.

 16. Ink World.  1996. The Flexo Report: Improvements through ink innovations.  May/June.

 17.   Flexo. February 1999. Op. cit.

 18. Flexographic Technical Association (FTA).  1995.  Flexography Principles and Practice, 4h ed.
 Ronkonkoma, NY:  Flexographic Technical Association, Inc.

 19. Ink World.  July  1997.   "Fresh ink." p.  10.

 20.Digital Technology Solutions, October 1999.   "U.S. printing process by market share, 1997-2015." p. 71.

 21.   Flexible Packaging Association (FPA).  1998.  1998 State of the Industry Report. Washington, DC:  FPA.
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 22. Ibid.

 23. Flexo.  December 1999. Op.  cit.

 24. Ink World.  May 1997. Op.  cit.

 25. Fuchs,  G., personal communication with Abt Associates Inc., 2000.

 26. National Association of Printing Ink Manufacturers (NAPIM).  1999.  1999 State of the Industry Report
 Hasbrouck,  NJ:  NAPIM.

 27. Ibid.

 28.NAPIM, 1999.  Op.  cit.

 29. Flexo, February 1999. Op.cit.

 30.Ink World.  June 1999.  " A look at past, present, and future." p.  48.

 31. Ibid.

 32. Ink World.  May 1999.  "Looking for new opportunities." p.  40.

 33. Flexo. September 1997. "Product Trend Report: UV Inks and Curing." pp. 46-49.

 34. Flexo, February 1999.  Op. cit.

 35. Flexo, February 1999.  Op. cit.

 36. Flexo, February 1999.  Op. cit.

 37. NAPIM, 1999. Op.  cit.

 38. NAPIM, 1999. Op.  cit.

 39. 40 CFR (Protection of Environment, RCRA), Part 261, Identification and Listing of Hazardous Waste,
 §261.21, Characteristic of Ignitability.

 40. 40 CFR (Protection of Environment, RCRA), Part 261, Identification and Listing of Hazardous Waste,
 §261.22, Characteristic of Corrosivity.

 41. Flexographic Technical Association  (FTA).  1995.  Flexography Principles and Practice.  Ronkonkoma, NY:
 Flexographic Technical Association, Inc.

42. Flexo.  August 1996."Static Electricity."

43. Shapiro, Fred.  1997. Correspondence with Abt Associates Inc., including the brochure, "Checklist for the
Flexographic Print Shop"  (author unknown).
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                              Chapter 3: Risk
                             CHAPTER CONTENTS
3.1  INTRODUCTION TO RISK	• -	3-4
       Background	3-4
       Quantitative Expressions of Hazard and Risk  	3-5
       Definitions of Systemic Toxicity, Developmental Toxicity, and Carcinogenic Effects  	3-6
       Definition of Aquatic Toxicity 	3-8

3.2 HUMAN HEALTH AND ECOLOGICAL HAZARDS  	3-9
       Human Health Hazards	 3-9
       Ecological Hazards	•	3-25

3.3 CATEGORIZATION OF FLEXOGRAPHIC INK CHEMICALS FOR THIS CTSA 	3-29
       Chemical Categories by Product Line 	3-32

3.4 ENVIRONMENTAL AIR RELEASE ASSESSMENT 	3-36
       Environmental Air Release Methodology	• • • •	3-36
       Environmental Air Release Results  	3-37

3.5 OCCUPATIONAL EXPOSURE ASSESSMENT 	3-40
       Occupational Exposure Methodology	3-40
       Occupational Exposure Results  	3-43

3.6 GENERAL POPULATION EXPOSURE ASSESSMENT  	3-46
       General Population Exposure Methodology 	• • 3-46
       General Population Exposure Results 	3-49

3.7 RISK CHARACTERIZATION	•	3-52
       Occupational Risk Results	•	'3-5*
       General Population Risk Results	3-60

 REFERENCES			• • •	•	3'65
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                                      INTRODUCTION

 This chapter presents the hazards, exposures, and associated health and environmental risks that may
 result from the chemicals  in the solvent-based, water-based, and UV-cured ink systems studied in the
 CTSA.


 INTRODUCTION: Section 3.1 presents an introduction to the central concepts of risk.  Common steps of
 a risk assessment are described, including hazard identification, dose-response assessment, exposure
 assessment, and risk characterization.  Finally, three  major types of potential effects of hazardous
 substances on living organisms (systemic toxicity, developmental toxicity, and carcinogenic effects) are
 described.


 HAZARD IDENTIFICATION: Section 3.2 discusses the human and ecological health and ecological hazards
 of all the chemicals in the flexographic inks included in this study. The information is based on data found
 in published toxicological studies and reports prepared by the EPA Structure Activity Team (SAT). Detailed
 information can be found in Appendices 3-A and 3-B.  Additionally, some chemicals are regulated under
 major federal regulations; information about the applicability of these regulations can be found in Chapter



 CHEMICAL CATEGORIES: Section 3.3 describes the chemical categories into which the flexographic ink
 chemicals were organized for this CTSA.  Subsequent sections of the CTSA discuss these chemical
 categories rather than specific chemicals, in order to protect the confidentiality of ink manufacturers
 regarding specific ink formulations. This section also identifies the relevant chemical categories for each of
 the ink formulations studied.


 AIR RELEASES:  Section 3.4 presents the environmental air releases that may result from  using these
 flexographic inks.  The results were generated with mass balance calculations.


 EXPOSURE ASSESSMENT FOR WORKERS AND GENERAL POPULATION: Section 3.5 discusses the
 )otential dermal and inhalation exposures to workers that can occur as a result of working with these inks.
 The exposure assessmentwas performed undertwo modeled scenarios: the ink preparation room (Scenario
 1) and the press room (Scenario 2). The results of both scenarios are presented in this section, but only the
 results from Scenario 2 are used for the subsequent Risk Characterization.  Section 3.6 presents potential
 nhalation exposures for the general population.


 *!SK CHARACTERIZATION: Lastly, Section 3.7 describes the risk characterization for these flexographic
 nks. The risk characterization integrates the hazard and exposure information to arrive at risk estimates to
 workers and the exposed general population near to a flexographic facility.


                               HIGHLIGHTS OF  RESULTS


 Jseful information can be gleaned from each section of this chapter.  However, when comparing the overall
 mpacts of ink formulations, the risk characterization (Section 3.7) is the most relevant.  These results are
 jased on  modeled assumptions about conditions and practices in flexographic printing facilities,  and
 tierefore may not represent all printing facilities.  However, in any printing facility, workers are exposed to
 printing chemicals to some extent. Chapter  7 contains information about practices that can reduce or
eliminate pollution and worker exposure from many steps in the printing process.
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       Thirty of the 48 chemicals for which toxicological information is available were found to
       represent medium or high hazard levels for systemic or developmental toxic effects.  In
       addition, two chemicals, crystalline silica and ethanol, have been documented to be carcinogenic
       to humans.  Another six chemicals show evidence of carcinogenicity via inhalation or dermal
       exposure routes, but are not classified as carcinogenic at this time. (See Section 3.2)
       With regard to ecological hazard, the analysis found that 18 chemicals were of high concern,
       and another 35 had medium hazard rankings.  (See Section 3.2)
       The solvent-based inks released considerably more volatile matter than the water-based and
       UV-cured inks. Water-based and UV-cured ink releases were comparable; however, the UV-cured
       results should be interpreted as an upper limit or worst-case scenario, because in practice much of
       the volatile material reacts and becomes nonvolatile.  (See Section" 3.4)
       Inhalation exposure is related to air releases.  For workers in the press room, exposure is
       highest with solvent-based  inks because of their higher air release rate.  For the  general
       population, however, exposure from solvent-based inks is lower than that from water-based inks
       because of the anticipated use of emission control equipment with solvent-based inks.     v
       The dermal exposure for prep room and press room workers is comparable for all three ink systems,
       and there is no expected dermal exposure for the general population.  (See Sections 3.5 and 3.6)
       Each ink system contained chemicals of clear risk for occupational health. For both solvent-
       based and water-based inks, the chemicals that most commonly were of clear risk were solvents,
       with some colorants and other chemicals also listed.  For UV-cured inks, chemicals  of clear
       occupational risk were monomers, pigments, additives, and some chemicals that crossed functional
       categories.
       Regarding risk to the general population, no chemicals were found to be  of clear risk.
       Possible risk was posed by some solvents in solvent-based and water-based  inks, and by some
       monomers and other chemicals in UV-cured inks.   (See Section 3.7)

                                         CAVEATS

       These results analyze only 45 of the many thousands of ink formulations that are available.
       They represent only a snapshot taken at a small selection of printing facilities,  and should not be
       taken as representative of inks in general.
        The results presented in this chapter were based on the ink formulations as submitted to DfE;
        reaction products orother changes in chemical composition resulting from the printing process (e.g.,
        the curing process for UV-cured inks) were not considered.
        Information for some chemicals was incomplete. EPA's Structure Activity Team (SAT) estimated
        properties for these chemicals based on molecular structure, similarity to well-studied chemicals,
        and other factors, but SAT reports are less preferable than direct toxicological research results.
        The results of this analysis also are dependent on assumptions that may or may not be true for other
        printing situations. (The assumptions are stated in the chapter and accompanying appendices.) For
        example, dermal results were calculated based on the assumption that no gloves are worn.  If
        workers wear gloves when working with these chemicals, dermal exposure  and  risk would be
        substantially lower than reported here.  Readers are advised to use caution when applying  any
        results from this analysis to other situations.
        The designation of a chemical as being of "high" hazard or "clear" risk does not give any indication
        of the potency of a chemical other than the fact that it meets the defined minimum threshold. A
        chemical with a high hazard or clear risk, therefore, may be slightly above the respective threshold,
        or may be far beyond that threshold.
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  3.1  INTRODUCTION TO RISK
                This section describes common concepts and components of a risk assessment. This
                information provides  a context in which to understand the  risk assessment that was
                performed on the flexographic chemicals studied in this CTSA.
         Background
                Chemicals affect the health of humans and the environment in a variety of ways. Human
                exposure to chemicals may occur through air that is inhaled, through water and food that
                are ingested, or through skin contact.   Exposure to particular chemicals may create
                concentration levels that result in cellular damage, which in turn may cause disease and
                death.1 A risk assessment is a four-step process that identifies chemicals that may present
                harm to humans and other organisms.

                A risk assessment includes four primary parts:

                   1   hazard identification
                   2   dose-response assessment
                   3   exposure assessment
                   4   risk characterization

               Hazard Identification
               The first step in a risk assessment is hazard identification.  This asks whether a chemical
               could cause  adverse health effects in humans  or  in nature.   That is, have  toxic or
               carcinogenic effects been observed in previous studies of the chemical?  Hazard  is
               independent of exposure, so it is necessary to conduct a dose-response assessment and
               exposure  assessment before applying hazard information directly to a specific  set of
               conditions.

               Dose-response Assessment
               A dose-response assessment determines the chemical's toxicity — the relationship between
               the dose of a chemical received and the incidence and severity of adverse health effects in
               the exposed population. Epidemiological or historical human-based data are the preferred
               sources used to  determine toxicity values.  If  those types of data are not available,
               laboratory animal studies  are evaluated  to see how their data may apply to humans!
               Toxicity values are used to estimate effects resulting from exposure to a chemical.

               In this CTSA, results of  the hazard identification and dose-response assessment are
               presented together in one section.

               Exposure Assessment
               An exposure  assessment identifies  populations (e.g.,  different groups such as factory
               workers or residents of an area) that are or could be exposed to a chemical. The exposure
               assessment describes the population's composition and size, and it identifies the types,
               magnitudes, frequencies, and durations of their exposure to the chemical. For this project!
               the  exposure assessment assumes that workers in a flexographic printing plant can be
               exposed to chemicals via dermal (skin) or inhalation (breathing) absorption, and that the
               general population  can be exposed via inhalation only.   It  is assumed  that neither
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               population is subject  to  toxic  effects  via  oral  exposure (e.g., drinking or  eating
               contaminated substances).

               Risk Characterization
               A risk characterization uses hazard, dose-response, and exposure information to develop
               quantitative and qualitative expressions of risk. A good risk characterization describes the
               assumptions, scientific judgments, and uncertainties embodied in the assessment.

        Quantitative Expressions of Hazard and Risk

               The manner in which estimates of hazard and risk are expressed depends on the nature of
               the hazard and the types of data upon which the assessment is based. For example, cancer
               risks are most often expressed as the probability of an individual developing cancer over
               a lifetime of exposure to the chemical in question. Risk estimates for adverse effects other
               than cancer are usually expressed as the ratio of the toxicological potency of the chemical
               to the estimated dose or exposure level received.  A key distinction between cancer and
               other toxicological effects is that most carcinogens are assumed to have no dose threshold.
               That is, exposure to any amount of the chemical is assumed to carry some risk. Other
               toxicological effects are generally assumed to have a dose threshold — an exposure level
               below which a significant adverse effect is not expected.

               The Reference Dose (RfD) is an estimate of the lowest daily human exposure that is likely
               to be without appreciable risk of deleterious, non-cancerous effects during a lifetime. The
               RfD is usually expressed as an oral dose per kilogram of body weight (given in units of
               mg/kg/day).  The Reference Concentration (RfC) is an analogous value for continuous
               inhalation exposure, usually expressed in mg/m3 (milligrams per cubic meter).

               Deriving an RfD or RfC involves determining a No Observed Adverse Effect Level
               (NOAEL) or Lowest  Observed Adverse Effect Level (LOAEL) from an appropriate
               toxicological or epidemiological  study, and  then applying various uncertainty and
               modifying factors to arrive at the RfD or RfC. The NOAEL is the highest exposure level
               that can  occur without statistically or biologically significant  adverse effects,  and the
               LOAEL is the lowest exposure level at which adverse effects have been shown to occur.
               Although some RfDs  and RfCs are based on actual human data, they are most often
               calculated from results obtained in laboratory animal studies. The following represents the
               equation for a RfD:
                                         RfD =
 NOAEL (or LOAEL)
       UF*MF
               In this equation, the Uncertainty Factor (UF) is a factor that reflects the various types of
               data sets used to estimate the RfD.  For example, a valid chronic animal NOAEL is
               normally divided by a UF of 100. Several forms of uncertainty are accounted for in the
               UF: variation in sensitivity among members of the human population, the uncertainty in
               extrapolating animal data to the case of humans, the uncertainty in extrapolating from data
               obtained in a study that is of less-than-lifetime exposure, and the uncertainty in using
               LOAEL data rather than NOAEL data.  The Modifying Factor (MF) is applied based on
               a professional judgement of the data base for the chemical.  The default value for MF is
                1.
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        Definitions of Systemic Toxicity, Developmental Toxicity, and Carcinogenic Effects

               This risk assessment identifies systemic toxicity, developmental toxicity, and carcinogenic
               risks of chemicals found hi the ink formulations used in the performance demonstrations.
               These measures are explained hi more detail below.

               Systemic Toxicity
               Systemic toxicity refers to adverse effects on any organ system following absorption and
               distribution of a chemical throughout the body. Adverse effects other than cancer and gene
               mutations are generally assumed to have a dose or exposure threshold. Thus, much of the
               evaluation for systemic toxicity for each chemical will depend on the relationship between
               the threshold  and the anticipated exposure.
                                                      }  -• ~     r

               RfDs and RfCs can be used to evaluate risks from chronic (long-term)  exposures to
               systemic toxicants.  EPA has defined an expression of risk called a Hazard Quotient (HQ),
               which is the ratio of the average daily dose to the RfD or RfC.  HQ values below 1 imply
               that adverse effects are very unlikely to occur. The more the HQ exceeds 1, the greater
               the level  of concern.   It is important to remember that the HQ is not a probabilistic
               statement of risk; a quotient of 0.001 does not mean that there is a one-in-a-thousand
               chance of the effect occurring.  Furthermore, it is important to remember that the level of
               concern does  not necessarily increase linearly as the HQ approaches or exceeds 1. The
               HQ is calculated by the following equation:
                                            HQ =
                                                      ADD
                                                  RfD (or RfC)
               The derivation of the Average Daily Dose (ADD) is described in Section 3.7,  Risk
               Characterization.

               When an RfD or RfC is not available, risk may be expressed as the Margin of Exposure
               (MOE) instead of a HQ.  The MOE is the ratio of a NOAEL or LOAEL (preferably from
               a chronic study) to an estimated dose or exposure level. The following equation represents
               the calculation of a MOE:
                                MOE =
                                               NOAEL (or LOAEL)
                                        calculated or measured human dose
              High MOE values (e.g., greater than 100 for a NOAEL-based MOE or 1,000 for a
              LOAEL-based MOE) imply a low level of risk. As the MOE decreases, the level of risk
              increases. As with the HQ, it is important to remember that the MOEis not a probabilistic
              statement of risk.

              Reproductive toxicity is also an important aspect of systemic toxicity. For purposes of this
              assessment, toxicity information on adult male and female reproductive systems was
              assessed.
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               Developmental Toxicity
               EPA defines developmental toxicity as adverse effects on a developing organism that may
               result from exposure prior to conception, during prenatal development, or postnatally up
               to the time of sexual maturation. This is different from reproductive toxicity, which is a
               component of systemic toxicity and represents adverse effects on the reproductive systems
               of mature organisms. Adverse developmental effects may be detected at any point in the
               life span of the  organism.  The major manifestations of developmental toxicity are (a)
               death, (b) structural abnormality, (c) altered growth, or (d) functional deficiency.

               Because many  elements associated with the hazard and  exposure components of
               developmental toxicity  risk assessment are  unique, this assessment treats these risks
               separately from other systemic toxicity risks.

               Developmental  toxicity  assessments usually assume  that a single  exposure  at any
               developmental stage may be sufficient to produce an adverse developmental effect. In the
               case of intermittent exposures, an examination of the peak exposure(s) is as important as
               the average dose over the time period of exposure. In this project, however, an acute
               (short-term) risk sampling showed an insignificant likelihood of acute effects; therefore,
               further peak exposure modeling was not performed, and only average exposure values are
               presented in this report.

               EPA has derived RfDs  and RfCs for developmental toxicants in a manner similar to its
               derivation of RfDs and RfCs for systemic toxicants. The RfDDT or RfCDT  is an estimate
               of a daily exposure to developmental toxicants by a human population that is assumed to
               be without appreciable risk of deleterious developmental effects. The use of the subscript
               "DT" refers specifically to developmental toxicity.

               Developmental toxicity risk can be expressed as a Hazard Quotient (dose or exposure level
               divided by the RfDDT or RfCDT) or a Margin of Exposure (NOAEL or LOAEL divided by
               the dose or exposure level).

               Carcinogenic Effects
               Carcinogenic effects are malignant tumors caused by cancer.  EPA groups chemicals into
               one of the five weight-of-evidence categories, which indicate the extent to  which the
               available data support the hypothesis that a substance causes cancer in humans.  The
               categories are listed below:

                   •   Group A — human carcinogen
                   •   Group B — probable human carcinogen (Bl indicates limited human evidence,
                                  B2 indicates sufficient evidence in animals but inadequate or no
                                  evidence in humans)
                   •   Group C — possible human carcinogen
                   •   Group D — not classifiable as to human carcinogenicity
                   •   Group E — evidence of noncarcinogenicity for humans
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                The International Agency for Research on Cancer (IARC) has an analogous categorization
                system; in this CTSA,  both categorization systems are used wherever information is
                available.

                The 1996 EPA proposed guidelines for carcinogenicity assessment use three categories to
                describe human carcinogenic potential:

                    •    Known/Likely — available tumor effects and other key data are adequate to
                        demonstrate carcinogenic potential for humans convincingly
                    •    Cannot Be Determined — available tumor effects or other key data are suggestive,
                        conflicting, or limited in quantity, and therefore are not adequate to demonstrate
                        carcinogenic potential for humans convincingly
                    •    Not Likely — experimental evidence is satisfactory for deciding that there is no
                        basis for human hazard concern

                When the available data are sufficient,  EPA calculates  a quantitative  estimate of the
                chemical's  carcinogenic potency.   Three measures are the slope factor, unit risk, and
                cancer risk.

                Slope factors express carcinogenic potency in terms of the estimated upper-bound
                incremental lifetime risk, in milligrams per kilogram of body weight (mg/kg) average daily
                dose.

                Unit risk is a similar measure of potency for air or drinking water concentrations. Unit
                risk is expressed as risk per ^g/m3 (micrograms per cubic meter) in air or as risk per /*g/L
                (micrograms per liter) in water for continuous lifetime exposures.a

                Cancer  risk is calculated by multiplying the estimated dose or exposure level by the
                appropriate measure of carcinogenic potency.  For example,  an individual  who has a
                lifetime  average daily  dose of 0.003 mg/kg of a carcinogen with a potency of 0.02
                mg/kg/day would experience a lifetime cancer risk of 0.00006 (1 in 17,000) from exposure
                to that chemical.  In general, risks from exposure  to more than one carcinogen are
                assumed to  be additive (the risk caused by each additional  chemical leads to a larger
                overall risk), unless other information points toward a different interpretation.

        Definition of Aquatic Toxicity

                Aquatic toxicity refers to an adverse effect on an aquatic organism following exposure to
                a toxicant.  For this analysis, acute and chronic aquatic toxicity values were gathered for
                fish, aquatic invertebrates, and green algae. The acute values are reported in either of two
                ways:

                   •  LC50, the concentration  at  which 50 percent of test  organisms die within a
                      specified short-term exposure period
                   •  EC50, the concentration at which 50 percent of the organisms show an adverse
                      (non-lethal) effect, such as growth inhibition,  at the end of the exposure period.
               a Sufficient input data were not available for the flexographic ink chemicals considered in this
               CTSA; therefore, slope factors or unit risk measures were not calculated for this analysis.
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3.2 HUMAN HEALTH AND ECOLOGICAL HAZARDS

       Human Health Hazards

              Human Health Hazard Methodology
              As a first step toward determining the hazards and potential exposure associated with each
              chemical found in the flexographic inks used in this study, EPA compiled information
              about their chemical and physical properties.  Profiles of the CTSA chemicals are
              presented in  Appendix  3-A.   The profiles include the chemical  structure  and key
              properties, including molecular weight, melting and boiling point, vapor pressure, flash
              point,  water  solubility,  density,  and  function in ink.   The  chemicals are  listed
              alphabetically, with their synonyms and CAS numbers, in Table 3-A. 1 of that Appendix.

              Databases exist that list chemical hazard information  used to characterize systemic,
              developmental, and carcinogenic effects.  Most databases are available through online
              searching and are maintained by a variety of government and private organizations. They
              may contain both  numeric and textual information relating to the chemicals. Some of the
              hazard databases used in the initial literature search for this CTSA include the following:

                  •   EPA's Integrated Risk Information System (IRIS)
                  •   National Library of Medicine's Hazardous Substances Data Bank (HSDB)
                  •   TOXLINE
                  •   TOXLIT
                  •   GENETOX
                  •   Registry of Toxic Effects of Chemical Substances (RTECS)
                  •   American Conference of Governmental Industrial Hygienists (ACGIH)
                  •   Agency for Toxic Substances and Disease Registry (ATSDR)
                  •   National  Toxicology Program (NTP)
                  •   International Agency for Research on Cancer (IARC)
                  •   National  Institute for Occupational Safety and Health (NIOSH)
                  •   Occupational Safety and Health Administration (OSHA)

               These databases yielded secondary data for this report; no attempts were made to verify
               the information.  Other data were also reviewed, including toxicological data developed
               under EPA's Office of Pollution Prevention and Toxics' Chemical Testing Program, as
               well as unpublished data submitted under TSCA §§ 8(d)  and 8(e) found in the TSCA Test
               Submissions System and TRIAGE databases.

               Human health  hazard profiles were  prepared  for chemicals about  which human
               toxicological data exist in databases. A hazard level (low, medium, or high) was assigned
               to each chemical based on the available data for dermal and inhalation routes for systemic
               and developmental effects.

               When toxicity data were not available for particular exposure routes, toxicity values were
               estimated based on data from other exposure routes. For example, the systemic LOAEL
               (dermal exposure route) for ammonia was derived from oral exposure data. In addition,
               some data originating from an inhalation study, for example, may have been systematically
               converted to oral toxicity value before being converted back to an inhalation value for this
               analysis. In  general, using toxicity values derived from alternate pathway data increases
               the uncertainty of the risk results.
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                 Many of the chemicals contained in the flexographic inks researched in this CTSA were
                 not represented adequately in the databases listed above. These chemicals were evaluated
                 by the Structure Activity Team (SAT) of EPA's Office of Pollution Prevention and Toxics.
                 The  SAT provided hazard  levels based  on analog data  and/or  structure  activity
                 considerations, in which characteristics of the chemicals were estimated in part based on
                 similarities with chemicals that have been studied more thoroughly.  Using SAT hazard
                 evaluations introduces a greater level of uncertainty in the results. SAT-based systemic
                 toxicity concerns were ranked according to the following criteria:

                    •    High concern - evidence of adverse effects in humans, or conclusive evidence
                        of severe effects in animal studies
                    •    Moderate concern - suggestive evidence of toxic effects in animals; or close
                        structural,  functional, and/or  mechanistic  analogy to chemicals with known
                        toxicity
                    •    Low concern — chemicals not  meeting the above criteria

                When a chemical did not clearly fit one of the SAT concern level categories,  ratings of
                low-moderate or moderate-high were  assigned.   It should be noted that SAT-based
                developmental toxicity concerns were  not ranked;  the SAT only indicated whether a
                concern for developmental toxicity existed for a given chemical.

                Human  Health Hazard Results
                Tables 3.1 A-F present a summary of the hazard information for each chemical used in this
                CTSA.  The tables contain the following columns.

                   •   Chemical Category indicates the category under which the chemical is grouped.
                       These categories are the basis of the subsequent  release, exposure, and risk
                       analyses.
                   •  Ink System lists  the ink systems that contain at least one chemical within each
                      chemical category.
                   •  ChemicaI/CAS# presents the name of the chemical and the Chemical Abstracts
                      Service (CAS) registry number  assigned to the chemical.
                   •  Expected Exposure Route indicates whether the data presented hi subsequent
                      columns is based on inhalation or dermal exposure.  If inhalation exposure is not
                      provided for a chemical, that indicates that the compound has a vapor pressure
                      below 0.01 mm Hg, and therefore inhalation would not be expected.
                   •  Estimated  Concentration  of  Concern  is a  calculated figure based on
                      toxicological  data; it  indicates  the concentration  at  which  systemic  or
                      developmental effects may begin to appear.
                   •  Concern for Toxic Effects indicates whether the chemical poses a low, medium,
                      or high hazard concern (see "Systemic Toxicological Effects" and "Developmental
                      Toxic Effects" in this section  for more information).  There  are two  values
                      presented in each cell: the first indicates the hazard level for systemic effects, and
                      the second lists the hazard for developmental effects. An indication of whether the
                      hazard level is based  on toxicological data (Tox)  or on a SAT report  (SAT)
                      follows in parentheses.
                   •   Toxicological Endpoints presents the type of anticipated health effects that have
                      been reported for animal or human studies. This is a qualitative listing of reported
                      effects; it does not imply anything about the severity of the effects or the doses at
                      which the effects occur.
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               This section describes the overall hazard findings and then presents a summary for each
               ink function (e.g., solvents and colorants).  For a more detailed presentation of health
               hazard results, see Tables 3-B.l and 3-B.2 in Appendix 3-B.

               Hazard is summarized for systemic and developmental effects.  For chemicals with
               toxicological data, a level of low, medium, or high are assigned based on the available
               dose-response information.

               Systemic Toxic Effects: Hazard levels for systemic toxic effects of the flexographic ink
               chemicals were derived from subchronic/chronic toxicity information found in the human
               health hazard profiles (see Appendix 3-B).3 The following results are shown in Table 3.1:

                  •   Twenty-one chemicals presented a low hazard (practically non-toxic to slightly
                      toxic, dermal LD50 > 2 g/kg).b
                  •   Twenty presented a medium hazard  (moderately toxic at subchronic/chronic oral
                      doses > 50mg/kg).
                  •   Two (ethanol  and silica)  presented a  high hazard (severe  to frank toxicity at
                      subchronic/chronic oral doses < 50  mg/kg).

               The most common systemic effects observed in animal studies are listed below. Toxic
               effects seen in animals were presumed to be also manifested in humans.

                  •   respiratory and neurotoxic effects (19 chemicals)
                  •   altered organ weights (19 chemicals)
                  •   liver effects (18 chemicals)
                  •   blood effects (15 chemicals)
                  •   decreased body weight or body weight gain (15 chemicals)
                  •   reproductive effects (14 chemicals)
                  •   kidney effects  (12 chemicals)
                  •   changes in serum or clinical chemistry (nine chemicals)
                  •   skin effects (eight chemicals)

               Chemicals without adequate systemic toxicity data were evaluated by the SAT.  The SAT
               reports indicated that  14 chemicals  were of low hazard, 35 were of low to moderate
               hazard, and four were of moderate hazard.4 None were of high hazard.

               Developmental Toxic Effects: Adequate developmental toxicity data (including NOAELs
               or LOAELs) were available for 24 flexographic ink chemicals.  RfDDT and RfCDT were not
               available for any of the chemicals.   Hazard levels for developmental effects of these
               chemicals were derived from developmental  toxicity information  found in the human
               health hazard profiles.5  The following are shown in Table 3.1:

                   •   Sixteen chemicals presented a low hazard (no effects or effects seen at oral doses
                       >250mg/kg/day).
                   •   Four presented a medium  hazard (effects  seen  at  oral doses of 50 to  250
                      mg/kg/day).
                b LD50 is the dose of a chemical taken by mouth, adsorbed by the skin, or injected that is
                estimated to cause death in 50 percent of the test animals.
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 CHAPTER 3
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                   •   Four (barium, ethanolamine, isopropanol, and styrene) presented a high hazard
                       (effects seen at oral doses ^50 mg/kg/day).

               The most common developmental effects observed in animal studies are listed below.
               Toxic effects seen in animals were presumed to be also manifested in humans.

                   •   decreased pre- or post-natal survival and decreased fetal body weight  or body
                       weight gain (nine chemicals)
                   •   fetal malformations (seven chemicals)
                   •   retarded skeletal and/or muscle growth and development (four chemicals)
                   •   inhibited or altered fetal growth and/or development (three chemicals)
                   •   delayed, poor, or non-ossification of bones (three chemicals)
                   •   altered fetal organ weights (three chemicals)
                   •   central nervous system structural anomalies (two chemicals)
                   •   altered gonad growth and development (two chemicals)
                   •   skeletal variants (three chemicals)
                   •   unspecified fetotoxicity (two chemicals)

               Of the chemicals without adequate developmental toxicity data, SAT reports indicated a
               developmental hazard for 15 chemicals.

               Table 3.1 is separated into six sections; each table corresponds to the chemicals' function
               in the ink. Basic definitions of each function can be found in Chapter 2.

               Solvents (Table 3.1-A): Sixteen of the chemicals studied in this CTSA are categorized
               as solvents. Nearly all are volatile, and therefore can be inhaled.  Twelve of them have
               toxicological data; the remaining four were studied by the SAT. As indicated in Table
               3.1-A, propylene glycol ethers generally had the lowest hazard rankings, and ethylene
               glycol ethers and alcohols had the highest rankings.

               Colorants (Table 3.1-B):  Seventeen chemicals were colorants.  In this CTSA, all of the
               colorants used were pigments, or dispersed solid particles.  Few of the chemicals have
               undergone toxicological testing, so most (all but five) were analyzed by the SAT. Because
               the compounds are solids with essentially no vapor pressure, none were expected to result
               hi inhalation exposure. Table 3.1-B presents the hazard information on the colorants; most
               present a low-moderate hazard as determined by the SAT.

               Resins (Table 3.1-C): Ten chemicals in this CTSA were classified as resins.  Eight were
               analyzed by the SAT, and one (miscellaneous resins) could not be studied because there
               was not enough information to perform a SAT analysis. Toxicological data were available
               for one chemical.  As shown in Table 3.1-C, most chemicals have a low hazard.

               Additives (Table 3.1-D): Eight chemicals were categorized as additives.  Toxicological
               data were  available  for two chemicals,  and the SAT analyzed four of the remaining
               chemicals.  There was  not enough information available for the SAT to analyze two
               chemicals. Table 3.1-D indicates that the organotitanium compounds were the category
               with most  concern, with all chemicals in that  category having  a medium hazard level
               according to the SAT.
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              UV-Reactive Compounds (Table 3.1-E): Twenty-three chemicals are included in this
              group.   Table 3.1-E further groups these compounds according to three functions:
              monomers, oligomers, and photoinitiators.  An additional category, 'multiple functions,'
              contains chemicals that may belong to more than one of these groups. Toxicological data
              were available for six  chemicals,  the  SAT analyzed 14 additional chemicals, and
              insufficient information was available to analyze three chemicals.  Monomers were the
              most consistently hazardous chemicals - all had medium hazard concern for systemic toxic
              effects.  However, there also were multiple-function chemicals and photoinitators with a
              medium hazard level.

              Multiple-Function (Table 3.1-F): This category contains chemical categories for which
              the chemicals are in two or more of the categories above.  For example, the category
              amides and nitrogenous compounds contains chemicals that are solvents or additives. Of
              the 25 chemicals in this category, toxicological data are available for 16, and the other
              nine were analyzed by the SAT. As shown in Table 3.1-F, nine chemicals in this category
              have either  medium or high hazard  levels for toxic effects  (either  systemic  or
              developmental).
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  PUBLIC COMMENT DRAFT
3-19
September 2000

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  CHAPTER 3
                                                                        RISK
PUBLIC COMMENT DRAFT
3-20
                                                              September 2000

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CHAPTER.
                                                                              RISK
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  PUBLIC COMMENT DRAFT
3-21
September 2000

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  CHAPTER 3
                                                                        RISK
PUBLIC COMMENT DRAFT
                                   3-22
                                                              September 2000

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CHAPTER 3
                                                                                         RISK
       Summary of Carcinogenic Effects
               The available information on carcinogenic effects of chemicals in the flexographic inks
               studied is presented in Table 3.2.  Quantitative data were not sufficient to calculate slope
               factors; therefore, the information in Table 3.2 is qualitative in nature.

               Seven chemicals have been given classifications by either the International Agency for
               Research on Cancer (IARC) or EPA:

                   •   Crystalline silica and ethanol are IARC Group 1 chemicals, which indicates that
                 :     mere is sufficient evidence that they are carcinogenic to humans.   ,
                   •   Amorphous silica, isopropanol, polyethylene, and polytetrafluoroethylene are
                      IARC Group 3 chemicals, which indicates that their characteristics with respect
                      to cancer cannot'be determined.     :
                   •   Propanol has been categorized by EPA as a Group C chemical, or possible human
                      carcinogen.                                                           ,

               Six additional chemicals are listed for which evidence of carcinogenicity via inhalation or
               dermal exposure routes  has been documented in literature, but which have not been
               assigned IARC or EPA classifications.  Three of these chemicals, C.I. Pigment White 6,
               kaolin, and acrylic resin, have been documented to cause lung tumors in rats. Two types
               of petroleum distillates, hydrotreated light and solvent-refined light paraffinics, have been
               shown to cause skin tumors in mice.  Styrene has been documented to cause mammary
               tumors in rats.                              :

               SAT reports indicated low to moderate carcinogenicity hazard levels for 17 chemicals.
               All'other chemicals for which SAT'reports  were generated indicated either low or
               negligible carcinogenicity "hazard.          ...              .
  PUBLIC COMMENT DRAFT
3-23
                                                                                September 2000

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  CHAPTER 3
                                                                            RISK
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PUBLIC COMMENT DRAFT
                                                                 September 2000

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CHAPTERS
                                                                                           RISK
        Ecological Hazards
               Ecological Hazard Methodology
               This analysis addressed the ecological hazards of flexographic ink chemicals to aquatic
               species (fish, aquatic invertebrates, and green algae).  Hazards to terrestrial species were
               not assessed because sufficient toxicity data were not available. Aquatic toxicity values
               may be obtained from the results of standard toxicity tests reported to EPA, published in
               the literature, or estimated using predictive techniques. Please see Appendix 3-B for more
               information about the methodology used in this analysis for determining ecological
               hazards.

               For this study, discrete organic chemicals were assessed using predictive equations called
               Structure Activity Relationships (SARs), which estimate the acute and chronic toxicity of
               chemicals to aquatic organisms.  The toxicity values relate to individual chemicals only;
               interactions among chemicals within a  formulation were not considered.  Although
               measured values are preferred, SAR estimates can be used in the absence of test data to
               estimate toxicity values within a specific chemical class.  The equations are derived from
               correlation and linear regression analyses based on measured data.

               Aquatic  hazard profiles for each flexographic ink chemical consisted of a maximum of
               three acute toxicity values and three chronic values:

                   •   Fish acute value (usually a fish 96-hour LC50 value)
                   •   Aquatic invertebrate acute value (usually a daphnid 48-hour LC50 value)
                   •   Green algal toxicity value (usually an algal 96-hour EC50 value)
                   •   Fish chronic value (ChV) (usually a fish  28-day early life stage  no-effect-
                       concentration chronic value)
                   •   Aquatic invertebrate chronic value (usually a daphnid 21-day ChV)
                    •   Algal chronic value (usually an algal 96-hour value for biomass)

                The ecological hazards of the chemicals were determined in a similar manner  to the human
                hazards presented earlier in this section.  The analysis was complicated by two issues: 1)
                many of the compounds were not addressed by existing aquatic toxicity test literature; and
                2) some of the chemicals (e.g., petroleum-based products) were mixtures, not discrete
                compounds.

                The concentration of concern was also derived  for each chemical.   This  value  was
                calculated by dividing the lowest of the three chronic values by  a factor of ten.  If the
                discharge of a chemical to the aquatic environment resulted in an estimated concentration
                equal to or greater than the concern concentration, then the chemical would likely be
                hazardous to organisms found in the aquatic environment.

                For the purpose of an overall assessment, the listed chemicals can be given an aquatic
                hazard  level according  to the concentration of concern to obtain an estimated chronic
                value. A chronic value is the concentration of the chemical that results in no statistically
                significant sub-lethal  effects on the  test organism following a longer-term  or chronic
                exposure. The hazard level is assigned according to the following criteria:

                    •   High hazard chemicals: estimated chronic value < 0.1 mg/L
                    •   Medium hazard chemicals: 0.1 mg/L < estimated chronic value <  10 mg/L
  PUBLIC COMMENT DRAFT
3-25
                                                                                  September 2000

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  CHAPTER 3
                                                                                            RISK
                    •   Low hazard chemicals: estimated chronic value > 10 mg/L

                 Lower chronic values indicate higher hazard levels. For example, the presence of 0.1 mg
                 of a high-hazard chemical in a liter of water could cause a problem, while at least 10 mg
                 of a low-hazard chemical would have to be present to cause similar effects.

                 Ecological Hazard Limitations and Uncertainty
                 Some  petroleum  products, such as  mineral spirits, petroleum distillates, and solvent
                 naphtha, are mixtures.   They  do not lend themselves readily to  the standard  hazard
                 assessment process using SARs, because the chemical constituents and the percentage of
                 each in the mixture vary. The constituents in these products include linear and branched
                 paraffins, and cyclic paraffins, with the total number of carbons ranging from  five to
                 sixteen.

                 For this CTSA, the toxicity of a mixture was determined by estimating the toxicity of each
                 individual constituent. Lacking adequate description and characterization, it was assumed
                that each component was present in equal proportions in the product. The geometric mean
                of the range of estimates provided the best estimate of the toxicity.  (These assumptions
                may not have been representative of the mixture currently on the market.) The toxicity
                of the individual components of the petroleum products  was based on tests using pure
                samples.  The potential byproducts or impurities of petroleum distillation that are typically
                found hi these mixtures were not incorporated into this hazard assessment.

                It was also not possible to estimate the hazard of some polymers, such as acrylic acid and
                polyamide polymers.  However, these chemicals have molecular weights above  1,000 and
                structures that would make it difficult for them to be toxic to aquatic organisms.  In
                general, nonionic polymers and those which are insoluble are of low aquatic hazard.

                The aquatic hazard profiles for flexographic ink chemicals may consist of only  measured
                data, only predicted values,  or a combination of both, because  data sources may be
                chemical-specific toxicity tests or SARs. Uncertainty or assessment factors were used to
                incorporate the concepts of  uncertainty and variability into  concern  concentration
                calculations.  These uncertainty factors include laboratory tests versus field data, measured
                versus estimated data, and differences in species' sensitivities.  In general,  if only one
                toxicity value is available, there is great uncertainty about the applicability of this value
              ,  to other organisms in the environment. Conversely, when more information is available,
                there is more certainty about the toxicity values.

                Ecological Hazard Results
                The results of the estimated aquatic toxicity determinations are presented in Tables  3-B.3
                and 3-B.4 in Appendix 3-B. The lowest or most sensitive values from SAR analysis or
                from actual measured test data were used.  No valid, published  literature was found to
               conflict with the estimated values. In many cases, the predicted and measured values were
               similar; for these chemicals, the lower value was selected for inclusion  in Table 3-B.4.
               For each chemical, the estimated toxicity values are given in mg/L for acute and chronic
               effects to fish, daphnids, and algae. The last column lists the concern concentration set for
               the chemical in water.
PUBLIC COMMENT DRAFT
3-26
                                                                               September 2000

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CHAPTERS
                                                                                          RISK
               For 26  chemicals,  no aquatic  toxic effects were expected.  Nevertheless,  concern
               concentrations were calculated whenever possible.  Concern concentrations ranged from
               0.001 to 20 mg/L.

               All the chemicals then were ranked, based on the lowest of the three estimated chronic
               toxicity values. This relative toxicity ranking provides guidance to the selection and use
               of chemicals that are less hazardous to aquatic organisms. The chemicals with high and
               medium hazard rankings are summarized in Table 3.3.  A more detailed presentation is
               provided in Table 3-B.4 in Appendix 3-B.

               High hazard rankings were assigned to 18 chemicals. Thirty-five chemicals had medium
               hazard rankings. A low hazard rank was assigned to those chemicals for which a chronic
               value could not be calculated.

               This study did not characterize risk for aquatic organisms, because routine water releases
               or discharges of hazardous chemicals were not anticipated from the use of the flexographic
               ink. chemicals. Should such a release or discharge occur, the estimated or predicted
               environmental concentration would need to exceed the  lowest chronic or acute toxicity
               value that was estimated for these chemicals to result in adverse effects.

               However, all flexographic ink chemicals can theoretically be subject to accidental spills
               or releases. Also,  many  flexographic printing facilities routinely release wastewater to
               publicly owned water treatment plants (POTWs). Different geographic regions and
               different POTWs have different levels of acceptability for such wastes, and the acceptable
               levels can change over time. Discontinuing use of chemicals that appear in Table 3.3 can
               help avoid potential problems.
  PUBLIC COMMENT DRAFT
3-27
                                                                                 September 2000

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  CHAPTER 3
                                                                                             RISK
                         Table 3.3 Chemicals of High and Medium Aquatic Toxicity Hazard
                                         (Based on Toxicological Studies)
                                             Chemicals of high hazard
                  Amides, tallow, hydrogenated
                  C.I. Basic Violet 1, molybdatephosphate

                 I C.I. Pigment Violet 27
                  Distillates (petroleum), hydrotreated light
                  glycerol propoxylate triacrylate
                  1,6-Hexanediol diacrylate
                  4-lsopropylthioxanthone
                  Resin acids, hydrogenated, methyl esters
                  Thioxanthone derivative
 Ammonia
 C.I. Basic Violet 1,
 molybdatetungstatephosphate
 dicyclohexyl phthalate
 2-Ethylhexyl diphenyl phosphate
 n-Heptane
 2-lsopropylthioxanthone
 Mineral oil
 Styrene
 Trimethylolpropane ethoxylate triacrylate
                                          Chemicals of medium hazard
                 Acrylic acid polymer, acidic #1
                 Alcohols, C11-15-secondary, ethoxylated
                 2-Benzyl-2-(dimethylamino)-4'-
                 morpholinobutyrophenone
                 C.I. Pigment Blue 61
                 C.I. Pigment Red 48, calcium salt (1:1)
                 Citric acid
                 Dioctyl sulfosuccinate, sodium salt

                 Dipropylene glycol diacrylate
                [ Ethyl acetate
                 1-Hydroxycyclohexyl phenyl ketone
                [ Hydroxypropyl acrylate

                I Methylenedisalicylic acid

                 Phosphine oxide, bis(2,6-
                 dimethoxybenzoyl) (2,4,4-trimethylpentyl)-
                 Resin, acrylic

                 Styrene acrylic acid polymer #1
                 Styrene acrylic acid resin
                Titanium diisopropoxide bis  (2,4-
                pentanedionate)
               I Trimethylolpropane triacrylate
 Acrylic acid polymer, acidic #2
 Ammonium hydroxide
 Butyl acetate

 C.I. Pigment Red 48, barium salt (1:1)
 C.I. Pigment Red 52, calcium salt (1:1)
 D&C Red No.7
 Diphenyl (2,4,6-trimethylbenzoyl)
 phosphine oxide
 Ethanolamine
 Ethyl 4-dimethylaminobenzoate
 Hydroxylamine derivative
 Isopropoxyethoxytitanium
 bis(acetylacetonate)
 2-Methyl-4'(methylthio)-2-
 morpholinopropiophenone
 Propyl acetate

 Solvent naphtha (petroleum), light
 aliphatic
 Styrene acrylic acid polymer #2
Tetramethyldecyndiol
Trimethylolpropane propoxylate triacrylate
PUBLIC COMMENT DRAFT
                                              3-28
                                                                                September 2000

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CHAPTER 3
                                                                                       RISK
3.3 CATEGORIZATION OF FLEXOGRAPfflC INK CHEMICALS FOR THIS CTSA

              This section describes the categories that each flexographic ink chemical was assigned.
              This was  done because the specific chemical formulations  of  flexographic  inks are
              generally  considered to be  proprietary.   Manufacturers  prefer not to reveal their
              formulations, because a competitor can potentially use this information to formulate and
              sell a nearly identical ink, often at a lower price without having to invest in research and
              development. Therefore, the Flexography Project developed a system to mask specific ink
              formulations discussed in the CTSA.

              Each participating supplier voluntarily submitted a product line  to EPA, where it was
              entered as  Confidential  Business Information  (CBI).   EPA completed  the  risk
              characterization using the exact formulations but without knowledge of the supplier. Each
              brand name was replaced with an ink system number (e.g., Solvent-based Ink #S1). This
              numbering system  is used  throughout the CTSA.   In addition, to maintain the
              confidentiality of the formulations, the CTSA reports the results using the categorization
              system shown in Table 3.4.   Results were reported for chemical categories only, and
              specific chemicals are not linked in the  CTSA to any particular formulation.  The final
              column in Table 3.4 presents the Chemical Abstracts Service (CAS) number for each
              chemical. Many chemicals have multiple names, so CAS numbers are used as a universal
              way of identifying unique chemicals.

              In addition to the chemicals found in the flexographic ink formulations, press-side solvents
              and additives were used in most of the performance demonstration runs. Table 3-A.2 in
              Appendix 3-A lists the press-side solvents and additives used for each ink formulation at
              each demonstration site. These chemicals were also considered in this risk assessment.
 PUBLIC COMMENT DRAFT
3-29
September 2000

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 CHAPTER 3
                                                                            RISK
                              Table 3.4 Categorization of Ink Chemicals
Category
Acrylated polyols
Acrylated polymers
Acrylic acid
polymers
Alcohols
Alkyl acetates
Amides or
nitrogenous
compounds
Aromatic esters
Aromatic ketones
Chemicals in category
Dipropylene glycol diacrylate
1 ,6-Hexanediol diacrylate
Hydroxypropyl acrylate
Trimethylolpropane triacrylate
Acrylated epoxy polymer0
Acrylated oligoamine polymer0
Acrylated polyester polymer (#'s 1 and 2)°
Glycerol propoxylate triacrylate
Trimethylolpropane ethoxylate triacrylate
Trimethylolpropane propoxylate triacrylate
Acrylic acid-butyl acrylate-methyl methacrylate-
styrene polymer
Acrylic acid polymer, acidic (#'s 1 and 2)°
Acrylic acid polymer, insoluble0
Butyl acrylate-methacrylic acid-methyl
methacrylate polymer
Styrene acrylic acid polymer (#'s 1 and 2)°
Styrene acrylic acid resin0
Ethanol
Isobutanol
Isopropanol
Propanol
Tetramethyldecyndiol
Butyl acetate
Ethyl acetate
Propyl acetate
Amides, tallow, hydrogenated
Ammonia
Ammonium hydroxide
Erucamide
Ethanolamine
Hydroxylamine derivative
Urea
Dicyclohexyl phthalate
Ethyl 4-dimethylaminobenzoate
2-Benzyl-2-(dimethylamino)-4'-
morpholinobutyrophenone
1-Hydroxycyclohexyl phenyl ketone
2-Hydroxy-2-methylpropiophenone
2-lsopropylthioxanthone
4-lsopropylthioxanthone
2-Methyl-4'-(methylthio)-2-
morpholinopropiophenone
Thioxanthone derivative0
CAS
number
57472-68-1
13048-33-4
25584-83-2
15625-89-5
NAa
NA
NA
52408-84-1
28961-43-5
53879-54-2
27306-39-4
NA
NA
25035-69-2
NA
NA
64-17-5
78-83-1
67-63-0
71-23-8
126-86-3
123-86-4
141-78-6
109-60-4
61790-31-6
7664-41-7
1336-21-6
112-84-5
141-43-5
NA
57-13-6
84-61-7'
10287-53-5
119313-12-1
947-19-3
7473-98-5
5495-84-1
83846-86-0
71868-10-5
NA
PUBLIC COMMENT DRAFT
3-30
                                                                  September 2000

-------
CHAPTER 3
                                      RISK
                         Table 3.4 Categorization of Ink Chemicals (continued)
Category
Ethylene glycol
ethers
Hydrocarbons —
high molecular
weight
Hydrocarbons —
low molecular
weight
Inorganics
Olefin polymers
Organic acids or
salts
Organophosphorus
compounds
Organotitanium
compounds
Pigments —
inorganic
Pigments —
organic
Chemicals in category
Alcohols, C11-15-secondary, ethoxylated
Butyl carbitol
Ethoxylated tetramethyldecyndiol
Ethyl carbitol
Polyethylene glycol
Distillates (petroleum), hydrotreated light
Distillates (petroleum), solvent-refined light
paraffinic
Mineral oil
Paraffin wax
n-Heptane
Solvent naphtha (petroleum), light aliphatic
Styrene
Barium
Kaolin
Silica
Polyethylene
Polytetrafluoroethylene
Citric acid
Dioctyl sulfosuccinate, sodium salt
Methylenedisalicylic acid
Diphenyl (2,4,6-trimethylbenzoyl) phosphine
oxide
2-Ethylhexyl diphenyl phosphate
Phosphine oxide, bis(2,6-dimethoxybenzoyl)
(2,4,4-trimethylpentyl)-
Isopropoxyethoxytitanium bis(acetylacetonate)
Titanium diisopropoxide bis(2,4-pentanedionate)
Titanium isopropoxide
C.I. Pigment White 6
C.I. Pigment White 7
C.I. Pigment Blue 61
C.I. Pigment Red 23
C.I. Pigment Red 269
C.I. Pigment Violet 23
C.I. Pigment Yellow 14
C.I. Pigment Yellow 74
CAS
number
68131-40-8
112-34-5
9014-85-1
111-90-0
25322-68-3
64742-47-8
64741-89-5
8012-95-1
8002-74-2
142-82-5
64742-89-8
100-42-5
7440-39-3
1332-58-7
7631-86-9
9002-88-4
9002-84-0
77-92-9
577-11-7
27496-82-8
75980-60-8
1241-94-7
145052-34-2
68586-02-7
17927-72-9
546-68-9
13463-67-7
1314-98-3
1324-76-1
6471-49-4
67990-05-0
6358-30-1
5468-75-7
6358-31-2
 PUBLIC COMMENT DRAFT
3-31
September 2000

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 CHAPTER 3
                                                                                            RISK
                              Table 3.4 Categorization of Ink Chemicals (continued)
Category
Pigments —
organometallic
Polyol derivatives
Propylene glycol
ethers
Resins
Siloxanes
Chemicals in category
C.I. Basic Violet 1 , molybdatephosphate
C.I. Basic Violet 1 , molybdate-
tu ngstatephosphate
C.I. Pigment Blue 15
C.I. Pigment Green 7
C.I. Pigment Red 48, barium salt (1:1)
C.I. Pigment Red 48, calcium salt (1:1)
C.I. Pigment Red 52, calcium salt (1:1)
C.I. Pigment Violet 27
D&C Red No. 7 '
Nitrocellulose
Polypi derivative Ac
Dipropylene glycol methyl ether
Propylene glycol methyl ether
Propylene glycol propyl ether
Fatty acid, dimer-based polyamide0
Fatty acids, C18-unsatd., dimers, polymers with
ethylenediamine, hexamethylenediamin'e,
and propionic acid
Resin acids, hydrogenated, methyl esters
Resin, acrylic0
Resin, miscellaneous0
Rosin, fumarated, polymer with diethylene
glycol
and pentaerythritol
Rosin, fumarated, polymer with pentaerythritol,
2-propenoic acid, ethenylbenzene, and (1-
methylethylenyl)benzenec
Rosin, polymerized
Silanamine, 1,1,1 -trimethyl-N-(trimethylsilyi)-,
hydrolysis products with silica
Silicone oil '
Siloxanes and silicones, di-Me, 3-hydroxypropyl
Me, ethers with polyethylene glycol acetate
CAS
number
67989-22-4
1325-82-2
147-14-8
1328-53-6
7585-41-3
7023-61-2
17852-99-2
12237-62-6
5281-04-9
9004-70-0
	 b
34590-94-8
107-98-2
1569-01-3
NA
67989-30-4
8050-15-5
NA
NA
68152-50-1
NA
65997-05-9
68909-20-6
63148-62-9
70914-12-4
               3 No data or information available.
               "Actual chemical name is confidential business information.
               °Some structural information is given for these chemicals. For polymers, the submitter has supplied
               the number average molecular weight and degree of functionality. The physical property data are
               estimated from this information.
        Chemical Categories by Product Line

               This CTSA examined the health risks associated with two solvent-based, four water-based,
               and three UV-cured flexographic  ink product  lines run at 11 different performance
               demonstration sites. Tables 3.5, 3.6, and 3.7 list the chemical categories for each of these
               nine product lines.  The categories are listed alphabetically.  An "x" denotes that a
               chemical within that category is found at least once in the corresponding formulation.
PUBLIC COMMENT DRAFT
3-32
                                                                                September2000

-------
CHAPTERS
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 PUBLIC COMMENT DRAFT
3-33
September 2000

-------
 CHAPTER 3
                                                                            RISK
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PUBLIC COMMENT DRAFT
3-35
September 2000

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CHAPTER 3
                                            RISK
3.4 ENVIRONMENTAL AIR RELEASE ASSESSMENT

               This section of the chapter describes the methodology and results of the assessment of
               releases to air that can occur during makeready and production runs on a flexographic
               press.  Releases to air are used to estimate inhalation exposure to particular chemicals for
               workers and the general population.

               Releases to air result from the evaporation of chemicals during the flexographic printing
               process.  Two  forms of air releases were examined: stack and fugitive.  Stack emissions
               are collected from the press and are released through a roof vent or stack to the outside
               air, sometimes undergoing treatment to reduce the emissions. Fugitive emissions escape
               from the printing process (e.g., from a long web run between presses), and exit the facility
               through windows and doors.

       Environmental Air Release Methodology

               Air releases were calculated based on the amount of ink used and the weight percentages
               and vapor pressures of the ink components.  Releases were estimated for the three types
               of ink (solvent-based, water-based, and UV-cured) and for each of the five colors (blue,
               green, white, cyan, and magenta).  Figure 3.1 illustrates the overall mass balance, for
               which it is assumed that an equal amount of material enters and  exits the system.  The
               mass balance model does not take  into  account air releases from the  use of cleaning
               solutions. For a detailed explanation of the method used to calculate the environmental
               releases and sample calculations, see Table 3-C.l in Appendix 3-C.

               Environmental Air Release Assumptions
               The following assumptions were used to calculate environmental releases:

                  •   Ink components with a vapor pressure greater than or equal to  0.001 mmHg at
                      25°C will volatilize.6
                  •   0.1 % of the volatile components will be retained on the substrate.7
                  •   30% of the volatile compounds released to the air will be fugitive emissions, and
                      70% will be captured by the press system and released through a stack.8
                  •   Solvent-based ink releases will pass through a catalytic oxidizer with a destruction
                      efficiency of 95 % .9 There are no air pollution control devices for the water-based
                      or UV-cured ink systems.
                  •   Ink components that do not volatilize (those with a vapor pressure less than 0.001
                      mmHg  at 25°C) will remain with the substrate, which ends up  as product  or is
                      recycled.
PUBLIC COMMENT DRAFT
3-36
September 2000

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CHAPTERS
                                                                                           RISK
                                                        Stack Release
                                                             t
                                    Fugitive Releases

                                      A         A
                                Oxidizer
                              (Solvent-based
                            Formulations Only)
                Ink

                A
Ink Chamber
Flexographic Press
Ink on Substrate Product

Ink in Cleaning Solution
to Waste
                 Ink Returned to Container
                 After Run
                             Figure 3.1  Mass Balance of Ink During Flexographic Printing
               Environmental Air Release Limitations and Uncertainty
               Uncertainties about the amounts of environmental releases relate to the rates of vapor
               generation, which vary depending on the following factors:

                   •   speed of the printing press
                   •   volatile content of the ink mixture
                   •   equipment operating time
                   •   temperature of the  ambient air and ink system

               In addition, release rates may vary depending on the capture efficiency of the press system
               and the destruction efficiency of the air  control devices.  If the capture or destruction
               efficiency increases, the release rate declines.

        Environmental Air Release Results

               Table 3-D. 1 in Appendix 3-D presents the calculated environmental releases for each ink
               formulation.  This table shows the total amount of chemicals volatilized, fugitive air
               releases,  and stack air releases per press.  Table 3.8, an excerpt from Table 3-D.l,
               presents environmental air release data for Solvent-based Ink #S2 at Site 10 and Water-
               based Ink #W2 at Site 1. Table 3.8 is included in the text to show the format of the data
                and to indicate the magnitude of air releases.

                The calculated volatilization rates of the solvent-based inks were considerably higher than
                those for the other two ink systems.  The total amount volatilized averaged 6.23 g/sec.
 PUBLIC COMMENT DRAFT
                   3-37
                               September 2000

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 CHAPTER 3
                                                                                           RISK
                The  average stack  emissions  (0.216  g/sec)   were considerably lower than fugitive
                emissions (1.87 g/sec), reflecting the anticipated use of oxjdizers with stack emissions.
                Therefore, of the total amount volatilized, only a portion would ultimately be released to
                the atmosphere.

                The volatilization rates for water-based inks  were considerably lower than those  for
                solvent-based inks, with an average rate of 0.347 g/sec.  However, the stack releases,
               • averaging 0.250 g/sec, were calculated to be higher than those for solvent-based inks,
                because the  use of an oxidizer was not anticipated.  On the other hand, the. fugitive
                emissions, with an estimated average of 0.105 g/sec, were anticipated to be considerably
                lower than those for solvent-based inks,  because of the lower average VOC content of
                water-based inks.

                The UV-cured inks were calculated to have releases comparable to those of water-based
                inks, with a  total volatilization rate of 0.438 g/sec.  The estimated stack and fugitive
                releases were calculated to be 0.304 and 0.141 g/sec, respectively.  These estimates should
                be interpreted as an upper limit, because in reality much of the volatile content would react
                to form a solid on the substrate, and thus  would not be released to the air. This reaction
                could not be quantitatively measured for this analysis, however, so the releases are based
                on the volatility of the unreacted ink components.

                Air releases also varied among colors within each ink system; the differences are primarily
                due to  different consumption rates.  White ink had significantly higfrer emission and
                consumption rates than the other colors because it covered a greater percentage of the
                image area (see Table 6.1 in Chapter 6: Resource and Energy Conservation).  Blue and
                green inks had slightly higher air releases and consumption rates than cyan and magenta
                inks.      '

               Press speed also greatly affected the amount of ink consumed. All estimates were made
               assuming a press speed of 500 feet per minute (fpm) for all three ink systems.  With this
               press speed,  ink consumption rates were approximately the same for  the different ink
               formulations.  If the speeds  observed during the performance demonstrations had been
               used instead,  however, the ink consumption rate and environmental air releases would
               have been lower. A reduction in press speed from 500 fpm to 340 rpm (a  32.0 % reduction
               hi press speed) with UV-cured inks would be expected to decrease the consumption rates
               and releases by approximately 32 %. Similarly,  reductions in press speed to 453 fpm and
               394 fpm for solvent-based and water-based systems, respectively, would be expected-to
               cause reductions hi ink consumption rates and environmental releases of 9%  and 21%,
               respectively.

               Adding solvents, reducers, extenders, cross-linkers, and other compounds to a printing ink
               usually increases its volatile content, resulting in greater environmental releases. During
               the CTSA performance demonstrations, solvents were added in greater quantities to the
               solvent-based formulations than to water-based or UV-cured formulations, which further
               increased the releases from solvent-based inks.
PUBLIC COMMENT DRAFT
3-38
                                                                               September 2000

-------
CHAPTER 3
                                                                       RISK

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 PUBLIC COMMENT DRAFT
3-39
September 2000

-------
  CHAPTER 3
                                                                                           RISK
                Press speed also greatly affected the amount of ink consumed. All estimates were made
                assuming a press speed of 500 feet per minute (fpm) for all three ink systems. With this
                press speed, ink consumption rates were approximately the same for the different ink
                formulations. If the speeds observed during the performance demonstrations were used
                instead, however, a reduction in the ink consumption rate and environmental air releases
                would result.  A reduction in UV-cured formulation press speed from 500 fpm to 340 fpm
                (a 32.0% reduction in press speed) would be expected to decrease the consumption rates
                and releases by approximately 32%. Similarly, reductions in press speed to 453 fpm and
                394 fpm for solvent-based and water-based formulations, respectively, would be expected
                to cause reductions in ink consumption rates and environmental releases of 9 % and 21 %,
                respectively.

                Adding solvents, reducers, extenders, cross-linkers, and other compounds to a printing ink
                usually increases its volatile content, resulting in greater environmental releases. During
                the CTSA performance demonstrations, solvents were added in greater quantities to the
                solvent-based formulations than to water-based or UV-cured formulations, which further
                increased the releases from solvent-based inks.


 3.5 OCCUPATIONAL EXPOSURE ASSESSMENT

                This section describes the exposure assessment of flexographic printing plant workers to
                the chemicals in the flexographic ink formulations. An exposure assessment—the third step
                in a risk assessment—defines the expected exposures of an identified population to specific
                chemicals.

                Two scenarios were studied for this exposure assessment: workers in the ink preparation
                room, and workers in the press  room during a print run. Prior to a production run, the
               potential for  exposure exists for  workers transferring and mixing inks  in  the ink
               preparation room.  During the production run, inhalation and dermal exposures can occur
               when workers handle ink cans  and operate the press. Inhalation exposures were estimated
               using the EPA mass balance  model; dermal exposures were estimated using an  EPA
               dermal exposure model.

               The exposure assessment indicates the  relative exposure levels that result from each ink
               system.  It can also indicate whether exposure results from primarily dermal or inhalation
               pathways, and therefore may indicate  whether exposure reduction measures might be
               effective for a given ink system (e.g., if a  facility requires the use of gloves, dermal
               exposure could be nearly eliminated). The two scenarios of the assessment can also assist
               in determining the  variation of exposure depending on a worker's location in a printing
               facility.

        Occupational Exposure  Methodology

               The occupational  exposure assessment used a model facility approach, in which reasonable
               and consistent assumptions were used for each ink type.  Data to characterize the model
               facility were aggregated from a number  of sources, including  flexographic printing
               facilities and industry suppliers in the United States.  The model facility is not entirely
               representative of any existing facility.  Thus, actual exposure (and risk) could vary
PUBLIC COMMENT DRAFT
3-40
                                                                              September 2000

-------
CHAPTER 3
                                                                                         RISK
               substantially depending on site-specific operating conditions,  end-products, and other
               factors.

               For a detailed explanation of the method used to calculate occupational exposures, see
               Appendix 3-E.

               Exposure Scenarios
               In Scenario I, workers were exposed in the ink preparation room while pumping ink from
               a 55-gallon drum into five-gallon cans,  and while mixing inks in the five-gallon cans.
               Under this scenario, one worker was exposed for 48 minutes per formulation per shift.

               In Scenario II, workers were exposed to fugitive emissions released into the printing room
               air, both by operating the printing press for a 7.5-hour shift  and by adjusting the inks in
               the five-gallon cans next to the ink press for 1-2.5 hours,  depending on the ink type.
               Scenario II used the printing room mass balance model to estimate exposures.  The
               following assumptions were made:

                   •  Only one source (ink can) within the work area emits the chemical.
                   •  The concentrations of the chemicals in a mixture are constant throughout the time
                      of dermal absorption.12
                   •  The average surface area of two hands is  1,300 cm2. After coming into contact
                      with a chemical, the quantity of chemical remaining on the hands is assumed to be
                       1-3 mg/cm2. Dermal exposure is modeled assuming that the worker has routine
                      two-hand contact with the inks. Dermal exposures are based on an 8-hour, time-
                      weighted average.12
                   •  There are three shifts per day.  Each worker works 7.5 hours per day  and 250
                      days per year.                          ,
                   •  A total of nine workers are exposed per shift; one worker exposed in Scenario I
                       (one worker per shift) and eight workers exposed in Scenario II (two workers per
                       press per shift, four presses).

                Table 3.9 lists the general facility assumptions that were developed for both scenarios.  See
                Appendix 3-E for a more detailed discussion.
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                                                                        12
          Table 3.9 Occupational Exposure Methodology Assumptions

Assumption	       Value	Source

Temperature of the ink during transfer     25°C

Average ventilation rate in both rooms     7,000 ft3/min


Ventilation/room air mixing factor         0.5

Velocity of the air across the cans         100 fpm

Diameter of the five-gallon cans          1 ft

Press speed                           500 fpm

Exposure time in the ink preparation       48 min/
ro°m                                  formulation

Exposure time adjusting five-gallon ink     2.5 hr
can near the press — solvent-based inks
                                                                    EPA

                                                                    Average of Technical
                                                                    Committee responses

                                                                    EPA12

                                                                    EPA12

                                                                    EPA12

                                                                    Performance methodology

                                                                    Technical Committee
                                                                    response

                                                                    Technical Committee
                                                                    response
Exposure time adjusting five-gallon ink
can near the press — water-based inks
Exposure time adjusting five-gallon ink
can near the press — UV-cured inks
1.0 hr
2.0 hr
Technical Committee
response
Technical Committee
response
               Inhalation Exposure
               The amount of a chemical in a room was calculated as follows:

                  Amount of chemical in a room = the amount of chemical entering the room  + the
                  amount of chemical generated in the room - the amount of chemical leaving the room.

               This analysis used a different mass balance model for each scenario.

                  •   Scenario I used an open surface mass balance model to estimate the volatilization
                      of liquids from open surfaces.  For chemicals with vapor pressures less than 35
                      mmHg at 25°C, one vapor generation rate was used.10 For chemicals with vapor
                      pressures greater than or equal to 35 mmHg at 25°C, a different vapor generation
                      rate was used (see Appendix 3-E).11
                  •   Scenario  II used a printing room  mass balance model to calculate chemical
                      concentrations  in  the printing room based on fugitive emission and  room
                      ventilation rates.
                  •   Inhalation exposures to components with a vapor pressure less than 0.001 mmHg
                      at 25°C were assumed to be negligible.6

              Dermal Exposure
              Dermal exposures may result from contact with the inks during transferring and mixing
              of the inks both before and after the production runs.  A dermal contact model provided
              bounding  estimates and assumed that no gloves or  barrier creams were used by  the
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               workers.12  In situations where the ink formulation was corrosive, dermal exposure to
               workers was considered negligible, because it was assumed that workers wore gloves when
               working with corrosive chemicals.

               Occupational Exposure Limitations and Uncertainty
               Any determination of the occupational exposure levels associated with  flexographic
               printing activities requires making assumptions about the printing process, the workplace
               environment, and health and safety practices. Occupational exposure levels differ among
               facilities because of many variables, including  the following:

                   •   procedures used in handling the ink formulations
                   •   press speed
                   •   capture efficiency of the press system
                   •   equipment operating time
                   •   temperature conditions (ambient and ink)
                   •   volatility of the chemicals in the inks
                   •   ventilation conditions and shop layout
                   •   number of presses per facility
                   •   use of personal protective equipment and safety procedures

        Occupational Exposure Results

               Workers exposed in Scenario I had lower exposures than workers exposed in Scenario II.
               This difference was due to the shorter exposure time in the ink preparation room, and to
               the lower vapor generation rates resulting  from an open can of ink versus those resulting
               from fugitive emissions in the printing room.

               The occupational exposure results indicated that dermal exposure was comparable in the
               ink preparation room (Scenario I) and the press room (Scenario II). However, inhalation
               exposure in the ink preparation room was very low'compared to that in the press room.
               For this  reason, only the results from Scenario II were used in the risk characterization.
               The results of both scenarios are presented in  Appendix 3-F.

               Tables 3-F.l and 3-F.2 in Appendix 3-F present potential inhalation exposure rates,
               minimum dermal exposure rates, and maximum dermal exposure rates for both scenarios.
               Exposure rates are given for each chemical category in each of the five formulations for
               each of the nine product lines: the higher the value (in nig/day), the greater the exposure
               to  that chemical via the given exposure pathway. The minimum and maximum dermal
               exposure rates provide a range for the dermal pathway. Press-side solvents and additives
               were incorporated into the data tables for Scenario II; therefore, Scenario II data were site-
                specific.

                Table 3.10, an excerpt from Table 3-F. 1, presents occupational exposure data for Solvent-
                based Ink #S2 at Site 10 (Scenario II).  Table 3.10  is included in the text to show an
                example of the format of the data and to indicate the magnitude of occupational exposure.

                As discussed in the  environmental release section, solvent-based formulations exhibited
                higher volatilization rates and higher fugitive emissions.  Solvent-based  inks therefore
                created higher inhalation exposures than did water-based or UV-cured formulations.
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                Water-based and UV-cured formulations  resembled each other  in levels of volatile
                emissions and worker inhalation exposures.

                Ink consumption rates affected fugitive emissions and therefore affected occupational
                exposure levels. Because ink consumption rates varied by color, workers were exposed
                to the greatest amounts of volatile compounds from white inks.  Also, the addition of
                solvents, reducers, extenders, cross-linkers, and other compounds to the printing inks
                resulted in greater occupational exposures.
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  PUBLIC COMMENT DRAFT
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  3.6 GENERAL POPULATION EXPOSURE ASSESSMENT

                This section describes the exposure assessment of the general population living near a
                flexographic printing facility to the chemicals in the flexographic ink formulations. The
                general population is anyone not directly involved in the flexographic printing process
                who lives near a printing facility. These people may breathe air containing small amounts
                of vapors from evaporation of products at the facility.

                The amount of exposure to these chemicals by the general population depends on several
                factors:

                   •   distance from the facility
                   •   the actual route of contact (e.g., inhalation)
                   •   the length of time the chemical has been hi the environment
                   •   the way in which the chemical moves through the environment

                Therefore,  measuring internal facility  contaminant  levels may not be sufficient  to
                determine significant general population exposure.  Certain types of controls may move
                the chemical from inside the plant to the outdoors. It is also important to note that some
                chemicals may have a  more significant impact  on a specific  segment of the  general
                population, such as children, than on a typical worker.

                Preliminary modeling was performed for both peak and average exposure.  Short-term
                effects, such as eye irritation, are best predicted  by peak exposure estimates, since the
                effect  occurs within a short period  of  exposure.   Long-term effects, such  as
                carcinogenicity, are better predicted through average exposures because the effects depend
                on the cumulative exposure of an individual.  The analysis also sought to determine
                whether the aggregate  releases  of facilities within a model region result in higher
                exposures for the  general population compared to the releases from a single flexographic
                facility.

        General Population Exposure Methodology

               For this exposure assessment,  it was assumed that fugitive and stack releases  from a
               flexographic printing facility mixed with outside  air.  The resulting air concentrations
             ,  depend on weather conditions.  Stagnant  conditions will not move vapors away quickly,
               so local concentrations of the chemical will be higher near the plant.  Windy conditions
               will transport vapors away faster, thereby reducing local concentrations.

               This assessment addressed acute and chronic exposure  concerns  for  two exposure
               scenarios:  local and regional. The local scenario considered a single facility in normal
               operation that has  certain releases affecting a specific area and specific local population.
               The regional scenario considered the  cumulative impact of all flexographic printing
               facilities within a region;  in this case, Chicago, Illinois was  used  to model regional
               exposure. In both cases a model facility approach was  used to calculate generic releases
               and environmental concentrations.

               For the local exposure scenario, two models that were developed as regulatory models by
               the EPA's Office of Air and Radiation15 were run to separately model the peak and average
               exposures.  A  short-term model, the Industrial Source Complex Short Term (ISCST)
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model was initially used to calculate peak exposures in order to determine acute risk. A
long-term model, the Industrial Source Complex Long Term (ISCLT) model, was used to
determine average exposures and chronic risk.  When results for the peak ISCST model
were used to develop acute risk values, the results indicated that there is an insignificant
likelihood of acute effects within the general population from any of the three ink systems.
Therefore,  the final analysis only considers chronic risk,  which was  determined by
calculating average exposure with the ISCLT model.

Local Exposure Methodology
A model facility  was used to  estimate local exposure by determining a chemical s air
concentration at a specified distance from the printing facility.  San Bernardino, California,
was used for the model because the weather conditions there result in the highest average
concentrations of pollutants around the model facility of any of the approximately 500
weather stations in the United States.14 The average concentrations around San Bernardino
are within an order of magnitude of concentrations expected anywhere else in the country.
That is, if the San Bernardino average concentration were estimated as 10 /*g/m3, then the
average concentration anywhere else in the country would be between 1 and 10 /xg/m3.

To determine the long-term, local, general population exposure, EPA's Office of Pollution
Prevention and Toxics used an implementation of ISCLT in the Graphical Exposure
Modeling System (GEMS).16  Appendix 3-G presents the input parameters used in the
model.

The air concentration at 100 meters from a facility  is often assumed for exposure
 modeling, because this is close enough to the release  site so that  the concentration  is
 conservatively high (concentrations usually lessen with distance), but far enough away that
 a residential  population could reasonably be expected to be  present.   To  obtain the
 concentration at  100 meters, a special polar grid was entered into the model.  Distances
 from the facility  of 100, 200, 300, 400, 500, and 1,000 meters were specified, forming
 concentric circles (i.e., rings) on the grid.  These rings, along with compass points, were
 then used to  define arc-shaped  areas, or sectors.  The  air dispersion model took three
 calculations per sector to obtain average air concentrations of chemical vapors. Finally,
 the compass point with the highest cumulative (i.e., stack plus fugitive) concentration at
 100 meters was  used to  determine general population exposure.   The model indicates
 whether a person at this distance would be exposed, but offers no estimate of the number
 of people that would be exposed.

 From the average concentration in the air, estimated inhalation exposures for an individual
 can be calculated in different  ways, depending on the toxicity factor of the modeled
 chemical.  For the flexographic ink chemicals, the toxicity factors indicated the need for
 Average Daily Dose (ADD) and Average Daily Concentration (ADC) estimates for use
 in non-cancer chronic risk calculations.

  The formulas for ADD and ADC are as follows:

      ADD (mg/kg-day) - [(C)(IR)(ED)(1 mg/1000 ^g)]/t(BW)(AT)]

      ADC (mg/m3) = [(C)(ED)(mg/1000Mg)]/(AT)
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                     where

                      C   =
                      IR  =
                      ED =
                     BW
                     AT
               chemical concentration in air from air dispersion modeling (ug/m3)
               inhalation rate (mVday)
               exposure duration (days): for residential exposures, the average hours per
               day spent at the house multiplied by the average years of residency. This
               factor includes considerations for the average time spent inside, outside, and
               vacation away from the house.
               average body weight (kg)
               average time of exposure/residency (days)

  Appendix 3-G demonstrates how the parameter values were calculated and presents their
  underlying assumptions and references.

  Regional Exposure Methodology
  The regional scenario provides insight into the overall impact of releases from all of the
  flexographic printing facilities in an area to that area's general population. This approach
  permits the estimation of the cumulative exposures resulting from all of the flexographic
  printers in an area. The total residential population exposed to flexographic ink chemicals
  was not available, because the locations of all the flexographic printing facilities across the
  country were not known.

 The regional scenario was partially  modeled using facilities located  in the six-county
 metropolitan area around  Chicago, Illinois, to  provide an example of cumulative
 exposures.   Within this area, the State of Illinois Environmental Protection Agency
 reported six companies with a total of 222 flexographic presses in a land area of 3 717
 square miles. The 1995 population of the area was approximately 7,500 000  I7 The model
 assumed that all of these printers used the same printing formulation at the same time  The
 average concentration of pollutants for the Chicago area was then calculated using local
 weather data by means of the BOXMOD model, also implemented in GEMS.16

 Although a region with many facilities of a given  industry might  have cumulative
 exposures greater than the local exposure estimate, that was not the case here   Instead
 the relatively small number of flexographic printing facilities within the large land area
 meant that the regional exposure values were uniformly only half to a third of the exposure
 levels calculated  at 100  meters from an isolated facility.  Because the  risks  from the
 regional results were insignificant, complete regional modeling was deemed unnecessary
 and separate results are not reported in this CTSA.

 General Population Exposure Limitations and Uncertainty
There is no one value  that  can be  used to describe exposure.  Not only is uncertainty
inherent in both the parameters and  assumptions used in estimating exposure  but the
effects possible within a population are variable. Sources of exposure uncertainty include
the following:

   •   the accuracy with which the model facility used in the assessment characterizes an
       actual facility;
   •   estimated  exposure  levels from averaged data and modeling in the absence of
       measured, site-specific data;                       .
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                   •   data limitations in the Environmental Air Release Assessment (the release values
                      are inputs for the general population modeling);
                   •   the accuracy with which the models and assumptions represent the situation being
                      assessed, and the extent to which the models have been validated or verified; and
                   •   parameter value uncertainty, including measurement error, sampling (or survey)
                      error, parameter variability, and professional judgment.

               EPA's Guidelines for Exposure Assessment document defines and describes how risk (or
               exposure) descriptors are used to provide information about the position of an exposure
               estimate in the distribution of possible outcomes.18 One of four descriptors might be used,
               depending on the type and quality of data used in the analysis:

                   •   central tendency
                   •   high-end
                   •   bounding
                   •   what-if

               In an ideal exposure analysis, all data would have both a value and some information about
               the associated probability  distribution.   If all data are based  on average or  median
               estimates, the analysis would be termed "central tendency," since it represents exposures
               that would typically be encountered. If all data are based on an exposure expected to be
               larger than that experienced by 90 percent of the population, the analysis is described as
                "high-end." An alternate descriptor is that the data represent "bounding" exposures; i.e.,
               calculated exposures are higher than any expected actual exposures.

               In some analyses, however,  probability data are not available  for each piece of
                information. In these cases, data are based on a set of circumstances (without indication
                of how probable that circumstance is). Such analyses are known as  "what-if scenarios."
                Because, along with other factors, the probability of a flexographic facility being similar
                to that of our model facility could not be determined, the exposure analysis in this CTSA
                is considered a "what-if scenario."

         General Population Exposure Results

                Table 3-H.l in Appendix  3-H presents fugitive and stack  chemical concentrations  100
                meters from the model facility  for each chemical category and press-side solvent or
                additive.  Table 3-H.2 in Appendix 3-H presents the Average Daily Dose (ADD)  and
                Average Daily Concentration (ADC) for the general population (residential,  100 meters
                from the facility).

                Tables 3 11 and 3.12, excerpts from Tables 3-H.l and 3-H.2, present general population
                exposure data for Solvent-based Ink #S2 at Site 10. These tables are included in the text
                to show the format of the data and to indicate  the magnitude of general population
                exposure..

                General population exposure quantities depend on many of the same variables  affecting
                environmental  releases and occupational exposures.  As a result, general population
                exposure results  are  affected  in the  same manner that environmental release  and
                occupational exposure results are affected: by the volatility of the inks, ink consumption,
                press speed, and the use of press-side solvents and additives.
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                The general population exposure estimates show solvent-based inks as having the highest
                ADD/ADC values of the three  ink  systems. This indicates that the higher fugitive
                emissions from solvent-based inks outweigh the decrease in stack emissions resulting from
                the use of oxidizers on solvent-based presses. There is no clear difference between the
                ADD/ADC values of water-based and UV-cured inks, but they are both significantly lower
                than those for solvent-based inks.
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  3.7 RISK CHARACTERIZATION
                Risk characterization integrates hazard and exposure information into quantitative and
                qualitative expressions of risk. This final step in a risk assessment enables experts to make
                a realistic estimate of risks to specific groups of people who are exposed to chemicals
                analyzed in earlier steps of the risk assessment.  The accompanying text box describes how
                chemicals are grouped into categories of clear, possible, or low/negligible risk.
                                              Defining Risk Levels

                 Clear risk indicates that there is an inadequate level of safety for the chemical in question
                 under the assumed exposure conditions, and that adverse effects can be expected. A
                 chemical is placed in this category if it has a Hazard Quotient (HQ) (see Note 1 below)
                 greater than 10, or a Margin of Exposure (MOE) (see Note 2) that is equal to or less than
                 10 or 100.(depending on the type of available data). If the chemical does not have a HQ
                 or MOE, but instead was analyzed by the structure activity team (SAT), the chemical is
                 considered to be of clear risk if it has a moderate or high hazard rating (see Note 3). Table
                 3.13 summarizes the HQ, MOE, and SAT criteria.

                 Possible risk indicates that the level of safety is slightly less than desirable and that the
                 chemical may produce adverse effects at the expected exposure level.  A chemical is
                 designated as a possible risk if it has a HQ between 1 and 10, or a MOE that either is
                 between 10 and 100 or 100 and 1,000. A SAT-analyzed chemical is of possible risk if it
                poses a low-moderate hazard (see Note 3).

                Low or negligible risk indicates that there is an adequate level of safety at the expected
                exposure level. A chemical of low or negligible risk has a HQ less than 1, or a MOE that
                is greater than 100 or 1,000.  An SAT-analyzed chemical is of low or negligible risk if it has
                a low hazard rating, (see Note 3).

                Note 1. A Hazard Quotient (HQ) is the ratio of the average daily dose (ADD) to the
                Reference Dose (RfD) or Reference Concentration (RfC), where RfD and RfC are defined
                as the lowest daily human exposure that is likely to  be without appreciable risk of
                non-cancer toxic effects during a lifetime.  The more the HQ exceeds 1, the greater the
                level of concern. HQ values below 1 imply  that adverse effects are not likely to occur.

                Note 2. A Margin of Exposure (MOE) is calculated when a RfD or RfC is not available.
                It is the ratio of the NOAEL or LOAEL  of a chemical to the estimated human dose or
                exposure level. The NOAEL is the level at which no significaht effects are observed. The
                LOAEL is the lowest concentration at which effects are observed. The MOE indicates the
                magnitude by which  the NOAEL or LOAEL exceeds  the  estimated  human dose or
                exposure level. High MOE values (e.g., greater than 100 for a NOAEL-based MOE or
                greater than 1,000 for a LOAEL-based MOE) imply a low  level of risk.   As the MOE
                decreases, the level of risk increases.

                Note 3. The SAT provided hazard levels based on analog date and/or structure activity
                considerations, in which characteristics of the chemicals were estimated in part based on
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                similarities with chemicals that have been studied more thoroughly. SAT-based systemic
                toxicity concerns were ranked according to the following criteria:
                   «   high concern - evidence of adverse effects in humans, or conclusive evidence of
                       severe effects in animal studies
                   •   moderate concern - suggestive evidence of toxic effects in animals; or close
                       structural, functional, and/or mechanistic analogy to chemicals with known toxicity
                   •   low concern - chemicals not meeting the above criteria.   	
                                       Table 3.13 Criteria for Risk Levels
Level of concern
Clear risk
Possible risk
Low or negligible risk
Hazard
Quotient a
>10
1to10
<1
Margin of Exposure"
NOAEL0
1 to 10
> 10 to 100
>100
LOAELd
1 to 100
> 100 to
1,000
> 1,000
SAT Hazard
Rating
moderate or
high
low-
moderate
low
                 a Hazard Quotient = ADD / RfD (RfC).
                 b Margin of Exposure = NOAEL (LOAEL) / Dose or Exposure Level.
                 c No Observed Adverse Effect Level.
                 d Lowest Observed Adverse Effect Level.

                Risk Characterization Limitations and Uncertainty
                Estimated doses assume 100% absorption. The actual absorption rate, however, may be
                significantly lower, especially for dermal exposures to relatively polar compounds.  This
                assessment used the most relevant toxicological potency factor available for the exposure.
                under consideration.

                Dermal exposure values to workers should be regarded as bounding estimates. All other
                exposure estimates are "what-if" estimates.

         Occupational Risk Results

                Chemical Categories of Clear Risk
                Chemical categories that present a clear occupational risk for systemic and developmental
                risks to flexographic plant workers are shown in Tables 3.14 through 3.17.  The type of
                exposure route (inhalation or dermal), the applicable  formulation, and the chemical's
                function in the ink are listed for each formulation. For a presentation of the occupational
                risk data for  systemic and developmental risks via dermal and inhalation pathways, see
                Appendices 3-1 through 3-N.

                Alcohols were the most common category of clear risk found in the solvent-based and
                water-based  ink formulations.  Amides or nitrogenous compounds in water-based ink
                 formulations were also common in presenting systemic risks  to workers.  Acrylated
                 polyols formed the most prevalent category of clear risk in the UV-cured formulations,
                 based on toxicological data.  Based on SAT reports, several other categories, including
                 acrylated polymers and amides or nitrogenous compounds,  presented  a concern for
                 developmental effects.
   PUBLIC COMMENT DRAFT
                                                3-53
September 2000

-------
   CHAPTER 3
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                                                                       September 2000

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                                            3-56
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-------
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   PUBLIC COMMENT DRAFT
3-57
                                                                        September 2000

-------
  CHAPTER 3
                                                                                            RISK
                 Most of the chemical categories presenting a clear occupational risk in solvent-based ink
                 formulations are solvents; many chemical categories presenting clear concern for water-
                 based inks  serve as solvents, dispersants,  vehicles, and buffers.  For UV-cured ink
                 formulations, most categories presenting a clear occupational risk serve as slip additives
                 reactive diluents, oligomers, colorants, plasticizers, and curing agents.

                 Range of Occupational Risk Levels by Chemical Category and Ink System
                 Table 3.18 summarizes the range of occupational risk levels (negligible concern because
                 exposure is not anticipated, low concern, possible concern, or clear concern) for the three
                 ink systems via dermal and inhalation routes. Because concern levels for systemic and
                 developmental risk were very similar for each chemical category, the ranges for the two
                 types of risk were combined. These ranges were based on toxicological data only except
                 for two chemical categories found in UV-cured inks: amides or nitrogenous compounds
                 and aromatic esters.

                 Chemical  categories  within an ink system showed variation in the level of risk (e g
                 ethylene glycol ethers in water-based inks ranged  from no exposure to clear concern)'
                Variation also occurred among ink systems for certain chemical categories (e.g., certain
                alcohols in solvent- and  water-based inks presented clear concern,  but alcohols in UV-
                cured inks presented negligible concern).  Such variations were due to differences in
                physical properties  between chemicals in  a category and/or differences in percent
                composition of an ink formulation.

                Summary of Number of Chemicals of Clear Occupational Risk  by Product Line and Site
                Table 3.19 summarizes of the number of chemicals with clear occupational risk concern
                Solvent- and water-based ink systems each averaged 16 chemicals with clear risk concern
                (based on both toxicological and SAT-based data).   Chemicals  with  clear concern
                comprised 28% of the total number of chemicals  for water-based inks, and 23% for
                solvent-based inks. Two of the three UV-cured inks had relatively few chemicals with
                clear concern; however, UV-cured Ink #U2 had 21 chemicals with clear concern (30%)
                It should be noted that these tallies do not necessarily give a full picture of risk; because
                it is not possible to correlate the nature and  severity of potential adverse effects on an
                aggregate product line level, the comparison shown above should serve only as a crude
                comparative figure.

                The number of chemicals in an ink product line was determined by adding the numbers
                of base chemical ingredients and press-side solvents and additives for each formulation
                within a product line,  and then summing the totals for all five formulations. Using this
               method, a chemical may  be counted more than once if it were found in more than one
               formulation.  For example,  ethanol,  used in three formulations within a product line, is
               considered to be three  "chemicals."  However, if a chemical presented clear risk for both
               dermal and inhalation pathways in  a single  formulation,  it was counted only once.
               Similarly, if a chemical presented a clear risk for both systemic and developmental effects
               it was counted only once.                                                         '
PUBLIC COMMENT DRAFT
                                             3-58
                                                                               September 2000

-------
 CHAPTER 3
                                      RISK
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  PUBLIC COMMENT DRAFT
3-59
September 2000

-------
  CHAPTER 3
                                                                                           RISK
              Table 3.19 Summary of Number of Chemicals with Clear Occupational
                                  Risk, by Product Line and Site
Ink type
Solvent-
based
Water-
based
UV-cured
Product
Line
#S1
#S2
#W1
#W2
#W3
#W4
#111
#U2
#U3
Site
9B
5
7
10
4
1
2
3
9A
11
6
8
Total
Number of
Chemicals3
63
70
71
75
43
48
62
56
66
48
70
46
Toxicological
Dataa-b
Number
15
14
15
17
16
13
15
13
18
1
16
0
Percent
24%
20%
21%
23%
37%
27%
24%
23%
27%
2%
23%
0%
SAT Dataa-b
Number
2
0
0
0
0
3
0
0
0
6
5
9
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0%
0%
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6%
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0%
0%
13%
7%
20%
Total3'"
Number
17
14
15
17
16
16
15
13
18
7
21
9
Percent
27%
20%
21%
23%
37%
33%
24%
23%
27%
15%
30%
20%
Rank
5
10
9
8
1
2
6
7
4
12
3
11
• Chemicals are counted more than once if found in more than one formulation within the same product line. The number
of chemicals may also include site-specific press-side solvents or additives.
b Includes clear risk for systemic or developmental effects via inhalation or dermal routes.
              Occupational Risks From Press-side Solvents and Additives
              The use of additives increased the occupational risk for many of the solvent- and water-
              based ink formulations. In particular, propanol and propylene glycol ethers in solvent-based
              inks, and ammonia, propanol, isobutanol, and ethyl carbitol in water-based inks presented
              possible or clear occupational risk in certain formulations.  UV-cured inks typically do not
              use any press-side additives. In the performance demonstrations, however, one additive was
              used in UV-cured Ink #U2 (green).

              Cancer Risks
              Only a few ink formulations contained chemicals of carcinogenic concern. These included
              Water-based Ink #W1 (Site4) and Water-based Ink #W2 (Site 1), which contained chemicals
              shown to produce tumors in rodents following  dermal and/or inhalation exposures.  An
              inorganic pigment found in every solvent-based, water-based,  and UV-cured ink system is
              a possible carcinogen by the inhalation route of exposure.  However, this compound, like
              other possibly carcinogenic compounds used in  this project, does not pose significant risk
              because the  exposure pathway  for workers  is  different from that  which  results  in
              carcinogenic effects.

       General Population Risk Results

              Chemical Categories of Possible General Population Risk
              Chemical categories that present a possible risk of systemic and developmental effects in the
              general population are shown in Table 3.20.  No categories present a clear risk to  the
 PUBLIC COMMENT DRAFT
3-60
September 2000

-------
CHAPTER 3
                                                                                         RISK
             general population. For a presentation of the general population risk data for systemic and
             developmental risks via inhalation, see Appendices 3-O and 3-P.

             In the solvent-based and water-based ink product lines, alcohols found in Solvent-based Ink
             #S2, Water-based Ink #W2, and Water-based Ink #W3 are the only category of possible
             general population risk based on toxicological data. These alcohols serve as solvents in
             these formulations.  For the UV product lines, acrylated polyols in UV-cured Ink #U2,
             serving as reactive diluents, are the only category of possible risk based on toxicological.
             data. Based on SAT reports, propylene glycol ethers in Solvent-based Ink #S2, amides or
             nitrogenous compounds in UV-cured Inks #U 1 and #U3, and acrylated polyols in UV-cured
             Ink #U2 may present a risk to the general population.

             Range of General Population Risk Risk Levels by Chemical Category and Ink System
             Table 3.21 summarizes the range of general population risk levels for each of the three ink
             systems.  The range of concern levels for systemic and developmental risk are very similar
             for each chemical category and were therefore combined in  the table. These ranges are
             based on toxicological data only, except for two chemical categories in UV-cured inks:
             amides or nitrogenous compounds, and aromatic esters, which have SAT support.

             Most of the chemical categories showed negligible general population risk because little
             exposure was anticipated to the general population in the model, and no categories presented
             a clear risk.  Each of the three ink systems had one category with a possible risk to the
             general population: alcohols in solvent- and water-based inks, and acrylated polyols in UV-
             cured inks. Five additional categories hi water-based inks, three in solvent-based inks, and
             one in UV-cured inks presented a low risk to the general population.

             Summary of Number of Chemicals of Possible General Population Risk by Product Line
             and Site
             Table 3.22  summarizes the number of chemicals with a possible risk  to  the general
             population, by product line and site. Very few chemical categories carry a possible risk for
             the general population: alcohols in Solvent-based Ink #2 (Site 5), Water-based Ink #W2 (Site
             1), and Water-based Ink #W3 (Sites 2 and 3), and acrylated polyols in UV-cured Ink #U2
             (Site 6).  The number of chemicals in a product line was determined by the same method
             used for Table 3.19.
 PUBLIC COMMENT DRAFT
3-61
September 2000

-------
             CHAPTER 3
                                                                                           RISK
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    PUBLIC COMMENT DRAFT
3-63
September 2000

-------
 CHAPTER 3
                                                                                            RISK
                  Table 3.22 Summary of Number of Chemicals with Possible General Population
                                          Risk, by Product Line and Site
Ink type
Solvent-
based
Water-
based
UV-
cured
Product
Line
#S1
#S2
#W1
#W2
#W3
#W4
#U1
#U2
#U3
Site
9B
5
7
10
4
1
2
3
9A
11
6
, 8
Number of Chemicals
With Possible Riska-b
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1
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Chemicals b
63
70
71
75
43
48
62
56.
66
48
70
46
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                b Includes possible risk for systemic or developmental effects via inhalation.
                 Chemicals are counted more than once if found in more than one formulation within a product line.
                The number of chemicals includes site-specific press-side solvents and additives used in the
                performance demonstrations.
               General Population Risks from Press-Side Solvents and Additives
               The use of press-side solvents and additives increased the general population risk for many
               of the solvent- and water-based inks formulations.  In particular, propanol and propylene
               glycol ethers in solvent-based inks; and ammonia, propanol, isobutanol, and ethyl carbitol
               in water-based inks, presented low risk to the general population in certain formulations.

               Cancer Risks
               Water-based ink  #W2 (Site 1)  contained a  chemical that  could expose the general
               population by the  inhalation route; there is evidence of this chemical producing tumors in
               one species following inhalation exposure.   Several of the carcinogenic  chemicals
               identified were of negligible general population risk, because incidental exposure of the
               general population to these chemicals was not expected.
PUBLIC COMMENT DRAFT
3-64
                                                                                September 2000.

-------
CHAPTER 3
                                                                                      RISK
REFERENCES

1.      Cothern, C. Richard, William A. Coniglio, and William L. Marcus.  "Estimating Risk to Human
       Health," Environmental Science and Technology.  20:111-116,1986.

2.      Thayer, Ann M.  "Alar Controversy Mirrors Differences in Risk Perceptions," Chemical and
       Engineering News.  August 28, 1989, pp. 7-13.

3.      U.S. Environmental Protection Agency (EPA).   Not dated.   "8e  Submission Criteria  for
       Determination of Level of Concern." Internal memorandum, Office of Pollution Prevention and
       Toxics.

4.     Wagner, P.M., Nabholz, J.V., and Kent, R.J. "The New Chemicals Process at the Environmental
       Protection Agency (EPA): Structure-activity Relationships for Hazard Identification and Risk
       Assessment," Toxicol. Lett.  79: 67-73, 1995.

5.     U.S. Environmental Protection Agency.  Memorandum from Jennifer Seed to Terry O'Bryan
       entitled "Criteria for 8(e) CAP Submissions." March 25, 1994.

6.     Reilly, B.  "Memorandum  from Breeda Reilly  to CEB Staff:  Guidance for Preparing PMN
       Engineering Reports." U.S. Environmental Protection Agency.  June 4, 1994.

7.     American National Can Company, anonymous source. Personal communication with James Rea,
       U.S. Environmental Protection Agency. Specific date unknown.

8.     Warlick, Thomas,  Graphic Packaging Corporation. Personal communication with James Rea,
       U.S. Environmental Protection Agency. November 20, 1997.

9.     Serafano, John, Western Michigan University.  Personal communication with James Rea, U.S.
       Environmental Protection Agency.  1997,  specific date unknown.

 10.   Fehrenbacher, M.C. and A.A. Hummel. "Evaluation of the Mass Balance Model Used by EPA
       for Estimating Inhalation Exposure to New Chemical Substances," American Industrial Hygiene
       Association, submitted for publication.

 11.    Engel, A.J. and B. Reilly. Evaporation of Pure Liquids from Open Surfaces. U.S. Environmental
        Protection Agency, Pre-Publication Draft.

 12.    Chemical Engineering Branch, EPA. Manual for the Preparation of Engineering Assessments.
        U.S. Environmental Protection Agency.  February 1991.

 13.    Brennan, Thomas. U.S. Environmental Protection Agency.  Personal communication with Conrad
        Flessner, U.S.  Environmental Protection Agency.  February 1998.

 14.    General Sciences  Corporation.  Exposure Screening Manual (Draft).   Prepared  for the U.S.
        Environmental Protection Agency. GSC-TR-32-88-015. May 10, 1988.

 15.    U.S.  Environmental Protection Agency.   Industrial Source Complex (ISC2)  User's  Guide.
        Research Triangle Park, NC: Environmental Protection Agency.  EPA-450-4-92-008a.  March
        1992.
  PUBLIC COMMENT DRAFT
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September 2000

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 CHAPTER 3
 17.
 18.
                                                                                      RISK
  16.    General Sciences Corporation. Graphical Exposure Modeling System, GEMS, User's Guide 1991
        GSC-TR-32-91-001.
Kaleel, Rob, State of Illinois Environmental Protection Agency.  Personal communication with
Conrad Flessner, U.S. Environmental Protection Agency. December 23, 1997.


U.S.  Environmental  Protection Agency.    Guidelines for Exposure Assessment; Notice.
Washington, DC: Environmental Protection Agency. Federal Register, pp. 22888-22938  Mav
29, 1992.                                                                          •
PUBLIC COMMENT DRAFT
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                                                                           September 2000

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CHAPTER4
                             PERFORMANCE
                          Chapter 4: Performance
                               CHAPTER CONTENTS
4.1 METHODOLOGY	•	4-4
       Methodology for On-site Performance Demonstrations	4-4
       Tests Performed on Samples from Performance Demonstrations and Laboratory Runs 	4-5
       Inks Used forthe Study	4-11
       Substrates Used for the Tests  	4-11
       Image and Plates Used for the Tests	4-12
       Types of Printing Performed	4-12
       Limitations of the Performance Demonstrations  	4-12
       Methodology for Laboratory Runs  	4-13

4.2 RESULTS OF PERFORMANCE DEMONSTRATION AND LABORATORY RUN TESTS —
SOLVENT-BASED AND WATER-BASED INKS 		4-17
       Adhesive Lamination — Solvent-based and Water-based Inks   	4-17
       Block Resistance — Solvent-based and Water-based inks  	4-18
       CIE L*a*b* — Solvent-based and Water-based Inks 	4-18
       Coating Weight— Solvent-based and Water-based Inks  	4-20
       Density — Solvent-based and Water-based Inks   	4-23
       Dimensional Stability — Solvent-based and Water-based Inks   	4-25
       Gloss — Solvent-based and Water-based Inks 	4-26
       Heat Resistance/Heat Seal — Solvent-based and Water-based Inks   	4-27
       Ice Water Crinkle Adhesion — Solvent-based and Water-based Inks   	4-28
       Image Analysis — Solvent-based and Water-based Inks  	4-29
       Jar Odor — Solvent-based and Water-based Inks  	4-30
       Mottle/Lay — Solvent-based and Water-based Inks  	4-32
       Opacity — Solvent-based and Water-based Inks   	4-34
       Rub Resistance — Solvent-based and Water-based Inks   	4-34
       Tape Adhesiveness — Solvent-based and Water-based Inks   	4-35
       Trap — Solvent-based and Water-based Inks  	4-36
       Highlights of Performance Results for Solvent-Based and Water-Based Inks  	4-38

 4.3 RESULTS OF PERFORMANCE DEMONSTRATION AND LABORATORY RUN TESTS — UV-
 CURED INKS	4-38
       Block Resistance — UV-cured Inks 	4-39
       CIE L*a*b* — UV-cured Inks 	4-40
       Coating Weight — UV-cured Inks  	4-41
       Coefficient of Friction — UV-cured Inks  	4-4:
       Density — UV-cured Inks 	4'43
       Dimensional Stability — UV-cured Inks  	4-4^
       Gloss — UV-cured Inks	4'44
       Ice Water Crinkle Adhesion — UV-cured Inks
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September 2000

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 CHAPTER4
                                                                        PERFORMANCE
       Image Analysis — UV-cured Inks	4.45
       Jar Odor — UV-cured Inks 	4.47
       Mottle/Lay — UV-cured Inks	    4.43
       Opacity — UV-cured Inks	4.49
       Rub Resistance — UV-cured Inks  	4-50
       Tape Adhesiveness — UV-cured Inks 	'	4.50
       Trap — UV-cured Inks	;	      4_50
       Uncured Residue — UV-cured Inks	4-51
       Summary of Performance Test Results for UV-Cured Inks 	4-51
       Technological Development in UV-cured Inks 	4-52

 4.4 SITE PROFILES	4.54
       Site 1:  Water-based lnk#W2 on OPP 	4.55
       Site 2:  Water-based lnk#W3 on LDPE and PE/EVA  	4.57
       Site 3:  Water-based lnk#W3on LDPE and PE/EVA	,. 4.59
       Site 4:  Water-based Ink #W1 on OPP	 4.51
       Site 5:  Solvent-based Ink #S2 on LDPE and PE/EVA	 . 4-62
       Site 6:  UV lnk#U2 on LDPE, PE/EVA, and OPP	4-64
       Site 7:  Solvent-based lnk#S2 on LDPE and PE/EVA  	4-66
       Site 8:  UV lnk#U3 on LDPE, PE/EVA, and OPP	 4-68
       Site 9A: Water-based lnk#W4 on OPP  			4-70
       Site 9B: Solvent-based Ink #S1 on OPP  	4-71
       Site 10: Solvent-based Ink #S2 on  OPP		4.73
       Site 11: UV lnk#U1 on LDPE (no slip)  		4.75

 REFERENCES	4.77
PUBLIC COMMENT DRAFT
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                                                                       September 2000

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CHAPTER4
                                                                             PERFORMANCE
                                     INTRODUCTION

This chapter describes the data collection  that was done to evaluate performance of the different ink
 ystems, and presents highlights of the results.

METHODOLOGY: The methodology of the data collection and tests for this CTSA is summarized in Section
 .1. The methodology section describes the performance demonstrations, the laboratory tests that were
performed on all the ink/substrate combinations, and the specific sites at which the demonstrations were
 •un  (The complete performance demonstration methodology can be found in Appendix 4-A, and other
 nformation relevant to the methodology is  in Appendix 4-B through 4-D.) Western Michigan University
conducted separate laboratory runs on all substrates using water-based and solvent-based inks. The use
of a single press under controlled conditions was intended to provide some consistency and a basis of
comparison for the results of the performance demonstrations. Highlights of the tests that were performed
 or the laboratory runs are discussed in Section 4.2, and more detailed information is provided in Appendix
4-L.

PERFORMANCE DEMONSTRATION TEST RESULTS: The printed  substrates completed at the
 jerformance demonstrations were sent to Western Michigan University, which tested each ink/substrate
 ;ombination. A total of 18 tests were performed to measure a wide range of capabilities for solvent-based,
water-based and U V-cured ink systems. The performance demonstration test results for solvent-based and
water-based inks are summarized in Section 4.2. Because the technology for UV-cured inks was still in a
developmental phase at the time of the performance demonstrations (November 1996 — March 1997), the
results for UV-cured inks are presented separately in Section 4.3. To provide a more current picture of UV-
cured inks,  The section also  discusses some of the relevant advances that have been made in UV
 :echnology'since the performance demonstrations were completed.

 PERFORMANCE DEMONSTRATION SITE PROFILES: Demonstration runs were done at  11 sites, which
 are numbered to protect confidentiality.  Section 4.4 provides detailed data about each of the volunteer
 printing facilities. For each facility, the type of ink used, control  equipment, annual production,  operating
 nours, and average production run are provided. Details are also provided about the presses on which the
 demonstrations were run.

 HIGHLIGHTS OF RESULTS:  At the end of Sections 4.3 and 4.4, readers will find brief summaries of the
 overall test results. This study was set up to explore a wide range of characteristics and interactions between
 inks and substrates that  can be important in flexographic printing. The demonstrations were all performed
 by different press operators at different flexographic facilities under widely varying circumstances, and
 consequently the test scores show considerable variation over both ink systems and substrates, and often
 between individual ink product lines as well. That is, they show the kinds  of differences that are typically
 encountered in the real  world  of flexographic printing. Such variances indicate that printers need to give
 careful consideration to a variety of different factors in determining acceptable quality fortheir facility. These
 factors—among them  cost,  health  and  environmental  risks, energy use, and  pollution prevention
 opportunities—are discussed in other chapters of this CTSA.

                                          CAVEATS

 The use of the terms quality and acceptable print are highly subjective. What one printer finds acceptable
 and salable in a printed product may be considered scrap by another printer. Thus, caution must always be
 used when making statements about what constitutes acceptable printing and high quality.              ,
                                                                       	.	i
  PUBLIC COMMENT DRAFT
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September 2000

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             CHAPTER4
                                                                                          PERFORMANCE
             4.1 METHODOLOGY

                           The Flexography Project Technical Committee (whose members are listed at the front of
                           this CTSA) developed this methodology to investigate the performance of solvent-based,
                           water-based, and UV-cured ink systems on three film substrates. The substrates that were
                           used are low-density polyethylene (LDPE), co-extruded polyethylene/ethyl vinyl acetate
                           (PE/EVA), and oriented polypropylene (OPP). The methodology involved two types of
                           data collection: performance  demonstrations at  11 volunteer  printing facilities,  and
                           laboratory runs conducted at the printing facility of Western Michigan University.'

                    Methodology for On-site Performance Demonstrations

                           Ten commercial printing facilities in the United States, and a press manufacturer's pilot
                           line in Germany, volunteered to participate in this study. All 11  facilities donated press
                           time to print the appropriate ink/substrate combinations on wide-web presses.2 Each
                           ink/substrate combination was run on a standardized image in at least two of the facilities.
                           Table 4.1 lists the ink-substrate combinations run at each of the facilities. Four of the 12
                           sites used a solvent-based ink system, five used water-based, and three used UV-cured
                           Seven sites ran LDPE, six sites ran PE/EVA,  and seven sites ran OPP.

                                      Table 4.1 Ink System and Substrates Tested at Each Site
                            Ink System
                            Solvent-based
                           Water-based
                           UV-cured
Substratefsl
                                                                                  Site
LDPE, PE/EVA
                                                   LDPE, PE/EVA
                                                   OPP
                                                   OPP
LDPE, PE/EVA
                                                  LDPE, PE/EVA
                                                  OPP
                                                  OPP
                                                  OPP
LDPE, PE/EVA, OPP
                                                  LDPE, PE/EVA, OPP
                                                  LDPE
                                                                                  Site5
                               Site?
                                                                                  Site 9B
                                                                                  Site 10
                                                                                 Site 2
                               SiteS
                                                                                 Site 4
                                                                                 Site 1
                                                                                 Site 9A
                                                                                 Site6
                               Site 8
                                                                                 Site 11
                          During each demonstration, the press was run at production speeds (approximately 300 to
                          500 feet/min) for about two hours to produce up to 60,000 feet of printed product
                          Flexographic printing experts from Western Michigan University's (WMU) Department
                          of Paper and Printing Science and Engineering were present at all demonstration runs to
                          ensure consistent adherence to the methodology. At the completion of each demonstration,
                          the printed substrate was sent to Western Michigan University for analysis.
                    One facility, Site 9, ran two different inks at the same location and was separated into two performance
                    demonstrations (Sites 9A and 9B). This made a total of 12 "sites."
           PUBLIC COMMENT DRAFT
                                                               4-4
_
                                                                                        September 2000

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CHAPTER 4
                                                                              PERFORMANCE
               These press runs were intended to provide a "snapshot" of performance under actual
               production conditions, rather than a tightly controlled  experiment. The performance
               demonstrations collected information about the real-world print quality issues associated
               with different ink systems using different film substrates and printed on wide-web presses.
               Additionally, information was collected for the cost, environmental and health risk, and
               energy and natural resources analyses. (These issues are the focus of other chapters of this
               CTSA.)

               The complete performance demonstration methodology, background questionnaires, and
               data collection sheets can be found in Appendices 4-A through 4-D. For more information
               on the volunteer facilities, see Section 4.4, Site Profiles.

        Tests Performed on Samples from Performance Demonstrations and Laboratory Runs

               All the samples collected in both the performance demonstrations and the laboratory runs
               were subjected to an extensive series of tests. A total of 18 different tests were conducted
               to analyze a wide range of ink properties and inks' effects on substrates, focusing on
               aspects that would be important to many flexographic printers. The purpose, procedure,
               and interpretive information for each test are provided in Table 4.2. The inclusion of
               laboratory runs allows comparative analysis about field performance. The results of these
               tests are described in Sections 4.2 and 4.3,  and the details of the laboratory tests can be
               found in Appendix 4-E.
  PUBLIC COMMENT DRAFT
                                                       4-5
September 2000

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                                                                                                                                                        4

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CHAPTER 4
                                                                              PERFORMANCE
       Inks Used for the Study

               Participation in the study  was open to  all ink formulators. The ink companies that
               participated in this study donated all the inks and submitted their formulations to EPA.
               Two different product lines were used for solvent-based inks, four product lines for water-
               based inks, and three product lines for UV-cured inks.  Both line colors and process colors
               were printed, to cover the range of flexographic applications. Colors were printed to
               match colors identified in the Pantone Color Selector/Film Guide.  The colors used in the
               demonstration are listed in Table 4.3.
                                      Table 4.3 Colors Used for the Tests

Line colors
Process colors
Blue
Green
White (opacity
Cyan
target 48%)

Specific Color
Reflex Blue
354 Green
Phthalocyanine Blue
Rubine Red
        Substrates Used for the Tests

                Flexographic printers produce many different products on a variety of substrates.  The
                Flexography Project selected film substrates so that data could be collected on technical
                issues related to printing inks on film (e.g., drying times for non-solvent-based inks) and
                environmental  issues (e.g., VOC emissions from solvent-based inks).  The DfE team,
                along with the Technical Committee, chose  three  commonly used substrates  that
                correspond to particular product segments. The substrates selected were (1) clear low-
                density polyethylene (LDPE), (2) white polyethylene/ethyl vinyl acetate (PE/EVA), and
                (3) clear oriented polypropylene  (OPP).  These three substrates allow a wide range of
                flexographic printers to benefit from the data analysis. Table 4.4 describes the substrates.
                                     Table 4.4 Substrates Used for the Tests

Low-density
polyethylene (LDPE)
Polyethylene / ethyl
vinyl acetate (PE/EVA)
co-extruded film
Oriented polypropylene
Characteristics
1 .25 mil, medium
slip, clear
2.5 mil, high slip,
white, prints on
polyethylene side
0.75 mil, slip
modified
Printing Type
Surface
Surface
Reverse
Typical Products
Shopping bags and
bread bags
Frozen food bags
Snack food bags and
candy bar wrappers
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                 Film manufacturers donated the substrates used in the study. With two exceptions, air the
                 LDPE  was supplied by  one manufacturer,  all  the  OPP was  supplied by another
                 manufacturer, and all the PE/EVA was supplied by another. One exception was Site 11
                 where UV-cured ink was printed  on an LDPE film  that was extruded with no  slip
                 additives. The other exception was Site 7, which received a different PE/EVA substrate.

                 All films used with water-based and UV-cured inks were treated on press with a corona
                 treater to achieve a dyne level specified by each ink manufacturer. The dyne levels of the
                 films treated in  the  demonstration runs ranged between 40 and 44 dynes.   The  one
                 exception was Site 4, for which the surface tension was known to be greater than 44 dynes
                but could not be  measured with the  available equipment.

         Image and Plates Used for the Tests

                The methodology  specified  photopolymer  printing  plates  for  the  performance
                demonstration. The volunteer facilities were given the option of using donated plates or
                plates supplied by their own vendors. The caliper (thickness) of the plates was optimized
                for each press.

                The test image was developed using recommendations made by the Technical Committee.
                The image was 20 inches wide and 16 inches long.  The image included both process tone
                printing in various gradations and two-color line printing. A black and white, size-reduced
                copy of the image can be found in Appendix 4-D.

        Types of Printing Performed

               The test image included process and line printing, to represent a wide range of types of
               flexographic printing. The performance demonstration runs also included both surface and
               reverse printing.  In surface printing, the dried ink film sits on the surface of the product,
               so the physical properties of the ink can be extremely important.  For example,  the
               printing on food packages must be able to withstand extremes of temperature, wetness,' and
               handling. In reverse printing, the ink is trapped between two  layers  of film, protecting it
               from outside physical contact.  The chemical properties of the ink film are essential for
               keeping the substrate layers bound together and ensuring that the ink adheres well to the
               substrate.

        Limitations of the Performance Demonstrations

               Close adherence to the performance methodology was attempted throughout the study.
               Because of the voluntary nature of this project and the manufacturing diversity of the
               flexographic industry, however, occasional adjustments to the methodology were required.
               Overall changes, such as ink or substrate substitutions, were evaluated and approved by
               the Steering Committee, the DfE staff, or the field testing teams as they arose.  Specific
               changes to the methodology made at the individual performance demonstration sites are
               described in the site profiles. Significant deviations from the methodology included the
               following:

               •  Adhering to the full two-hour run time of each ink-substrate combination would have
                  placed an unacceptable burden on the production schedules of the volunteer facilities
                  in six cases (Sites 2, 5, 6, 8, 9, and 10). At these sites, the press crew and DfE team
                  continued the runs only as long as was deemed necessary to get accurate results.
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               •   Some sites experienced shortages of materials, such as substrate, which decreased the
                   run lengths. In addition, the overheating of the chill roller at Site 6 caused the run to
                   be aborted.

               •   Although target ranges for the anilox roll volumes were specified in the methodology,
                   the volunteer facilities did not all have rolls with these specifications available at the
                   time of the performance demonstration. Again, because of the production needs of the
                   volunteer facilities, changing or acquiring anilox rolls to meet the specified targets was
                   impractical.   A summary  of the  actual anilox roll  specifications  for  all of the
                   demonstration sites, along with the target specifications, can be found in Appendix 4-
                   H.

                •   Ink type although the focus of this project, is only one aspect of the very complex
                   printing process.  The project  was not designed to control for other variables, so
                   caution should be used when reviewing the test results.

                .  Although every  effort was made to match the volunteer facility with the type of ink
                   and type of printing that the facility normally runs, this was not possible at Site 9B,
                   which normally  runs water-based inks but ran solvent-based inks for the performance
                   demonstration.  This may have had  an impact on the performance demonstration
                   results.

                In addition, the interpretation of the data is limited by the following caveats:

                    .   Althoughtheperformancemethodologysetforthguidelinesandparametersforthe
                        on-site printing runs, variable conditions between and within printing facilities, the
                        limited number of facilities, and the relatively short duration of the performance
                        demonstrations do not allow the results to be interpreted as definitive performance
                        testing  of the ink systems.

                     .   Press operators' experience with ink systems differs substantially and can affect
                        ink performance.  Some of the information recorded was subjective and depended
                        on the  perception and previous experiences of the operators and the DfE team.

                     .  Standardization of test protocols within the flexible packaging industries is limited.
                        Some of the tests used in this project were developed at WMU. Other procedures
                        were obtained from ink manufacturers  and trade organizations.   In addition,
                        during the testing of the printing products,  some methods were  modified to
                        improve accuracy and efficiency. The test procedures can be found in Appendix
                        4-E.

                     .  Demonstration facilities were chosen based on their ink technology and relative
                        experience with the system, rather than on their ability to attain a close match to
                        all aspects of the performance test design.

          Methodology for Laboratory Runs

                  Industry representatives decided that collecting data under both production and laboratory
                  ctSns would give printers a better sense of the actual capabilities of the ink/substrate
                  combinations  undlr a variety of conditions.  Thus, laboratory runs were  conducted at
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                 Western Michigan University's printing laboratory to collect baseline data  These runs
                 used the same ink/substrate combinations and the same test image.

                 For all solvent-based and water-based ink formulations, laboratory runs were performed
                 on a flexographic press at Western Michigan University (WMU).  This was done to
                 provide  consistency of results and a context in which to interpret the performance test
                 data.J)ue to equipment difficulties, the UV-cured ink combinations were not printed at


                 This section presents technical information about the laboratory facility  and the press
                 Section 4.2 includes relevant data from the laboratory runs as well as the performance
                 demonstration sites.  (Laboratory site codes begin with an  "L".) Appendix 4-L  also
                 provides  a detailed narrative description of the laboratory runs, for readers  who desire
                 more information. All the  results of the laboratory runs are included in the tables in
                 Appendix 4-E, Laboratory Test Procedures and Performance Data.

                 Some general information about the facility at Western Michigan University is provided
                 in I able 4.5.
                     Table 4.5 Summary Facility Background Information for Laboratory Runs
                                       Solvent-based and water-based for education and test runs
                                       only
                 Emission control
                 equipment
None
                 Annual production
This facility is an educational institution, not a commercial
printing facility.
                 Operating hours
n/a
                 Avg. production run
n/a
               The solvent-based and water-based inks used were provided by the same suppliers and
               formulators that supplied inks for the performance demonstrations. Table 4 6 lists the ink
               system, substrate, and product line that correspond to each laboratory run
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                         Table 4.6 Ink-Substrate Combinations for Laboratory Runs
                        Ink System
                        Water-based
                a"L" indicates that this was a laboratory run.
               The laboratory runs were conducted on a pilot press. The press used in the laboratory
               runs has an in-line design.  Information about the press and configuration is shown in
               Tables 4 7 and 4 8  All laboratory runs were completed as designed, with no significant
               deviations from the methodology. A summary of information about the laboratory runs is
               provided in Table 4.9.

                               Table 4.7 Press Information for Laboratory Runs
tem
Press
Size of press
Printing type
Typical production speed
Plates
Corona treater
Ink metering system
Type of doctor blade
Ink pumping and mixing
svstem
Description
si^ssr^si^ss^^^^^^^^^^^^^"
Zerand
24 inches wide, two-color
Surface
500 feet/minute
0.107" Dupont EXL photopolymer:
1 ) Two process plates (magenta and
using compressible stick back
2) Three line plates (green, blue, and
using hard stick back
cyan) mounted
white) mounted
Enercon
Two-roll with doctor blade
Stainless steel
Electric
	 '
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                     Table 4.8 Color Sequence and Anilox Configurations for Laboratory Runs
                  •Deck 1 (white ink) was changed to cyan ink for the PE/EVA substrate.
                   lines per inch
                  cbillion cubic microns per square inch
                              Table 4.9  Summary Information from Laboratory Runs
                 Substrate
                                         Lab
                                        Run#1
                                        LDPE
          Lab
        Run #2
         OPP
        Lab
       Run #3
                                                         OPP
 Lab
Run #4
                         OPP
 Lab
Run #5
                                                                         LDPE
 Lab
Run #6
 ==
 PE/
 EVA
 Lab
Run #7
 -'-'--

 PE/
 EVA
                 nk
                                         #W3
         #W4
                                                         #W2
                          #S2
                                                                         #S2
                                         #W3
                                                                                         #S2
                 Press Speed
 343
231
                                                         292
                         324
                                                                         311
                                          274
                                                                                         305
                 fotal Footage Consumed
41,143
                The laboratory runs were optimized for speed, to maximize quality and drying efficiency
                Because these tests lasted only a few hours, the press speeds listed in Table 4 9 do not
                necessarily reflect running speeds that may be more commonly seen  in flexographic
                printing facilities.                                                            F


                The complete results for each test, including the laboratory runs, are provided in the tables
                in Appendix 4-E, Laboratory Test Procedures and Performance Data.

                Impression on an in-line press is not as accurate as a central impression (CI) flexographic
               press.   As a result, more mottle occurred during printing on all laboratory runs   In
               general, the water-based ink did not wet as well as the solvent-based ink, and more mottle
               was evident. Excessive foaming of the ink was evident for L3 (Water #2)  LI L2  and
               L6 (Water #3, #4) also showed some foaming after 15 minutes. Drying on'the plates and
               poor re-wettability  was noted in L7 (Solvent #2) after 20 minutes.  In all runs  it  was
               necessary to wash the plates during roll changes.

               Block resistance scores were fairly consistent between the laboratory runs and the
               performance demonstrations (slight cling to slight blocking). No test received a score
               higher than 3, indicating that blocking was not a serious problem in this setting.

               For the  gloss test, the laboratory readings tended to be quite a bit lower than the  site
               readings, indicating less gloss. This was especially evident with green water-based ink on
               LDPE, which had gloss readings below 25%.
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               For the opacity test, the average percent opacity was very high for site L5 (solvent-based
               ink on LDPE), but fairly low for the other scenarios. A high score indicates better opacity
               and higher quality of this aspect of the printing.


4.2 RESULTS OF PERFORMANCE DEMONSTRATION AND LABORATORY RUN TESTS -
SOLVENT-BASED AND WATER-BASED INKS

               This  section discusses the results of the performance demonstration tests on solvent-based
               and water-based inks using all three film substrates. These two ink systems are discussed
               together to allow printers to compare how the systems perform with different substrates
               and in different tests.

               The  18 tests (listed in alphabetical order) measure many aspects of appearance, odor, and
               durability of the inks, as well as evidence of interactions between the inks and film
               substrates.  Some of these tests have established quality standards, whereas many do not.
               For example, the adhesive lamination and opacity tests each have a standard below which
               results are  considered unacceptable by the industry. For CIE L*a*b* and coefficient of
               fiction tests, on the other hand, acceptability is a relative concept and depends entirely
               upon the needs of the printing  situation.  Also, some tests, such  as jar odor, which
               measures the amount and type of odor from the different printed ink samples, are clearly
               subjective. Tests such as dimensional stability measure how the ink (and the process that
               applies it)  affect the'structure of the substrate on which  the ink is printed. Table 4.2
               describes the purpose, procedure, and interpretation for  each test that was performed
               during the performance demonstrations and laboratory runs.

               Data for the laboratory tests were obtained by examining up to four different locations on
               the  printed rolls. The locations from which samples were collected  are described in
               Appendix 4-A. A detailed description of each laboratory test procedure and results for the
               performance demonstrations can be found in Appendix 4-E. The tests and results for the
               laboratory runs are included in Appendix 4-L, and particularly interesting results are
               highlighted in the text.

         Adhesive Lamination — Solvent-based and Water-based Inks

                OPP was the only substrate that had a lamination layer to be tested. A clear propylene
                substrate  was laminated to the printed sample at Sites 1 and 4, while a metallized
                propylene substrate was laminated to the printed sample at Site 9. Site 10 did not test for
                adhesive lamination; although the test substrate was intended to be laminated, the site did
                not have lamination capabilities.

                Table 4.10 presents the adhesive lamination data. All four product lines tested had less
                than the minimum 0.350 kg that is considered acceptable. However, the solvent-based ink
                product line displayed a delamination force  16% greater than the  average of the three
                water-based ink product lines.
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                  Table 4.10 Adhesive Lamination Results - Solvent-based and Water-based Inks
Ink
Solvent-
based
Water-based
Film
OPP
OPP
Product Line
#S1
#W1
#W2
#W4
Site
9B
4
1
9A
Average
Delamination
0.3040
0.2649
0.2631
0.2575
Standard
Deviation
0.0132
0.0012
0.0000

         Block Resistance — Solvent-based and Water-based Inks


                Table 4.11 summarizes the block resistance test data.  The averages are based on four
                measurements taken from each site sample. The two variables were the location of the
                sample (e.g., beginning or end of the run) and whether ink transferred to a printed or
                unprinted substrate.  The most successful combinations of ink and substrate were water-
                based inks on LDPE and PE/EVA. The least successful combinations were water-based
                inks on OPP, followed by solvent-based inks on LDPE and PE/EVA.


                  Table 4.11  Block Resistance Results — Solvent-based and Water-based Inks
Ink
Solvent-based
Water-based
Film
LDPE
PE/EVA
OPP
LDPE
PE/EVA
OPP
Average Rating of Blocking
2.9
2.9
1.9
1.2
1.2

                 The Mowing scale was used to assign a numerical score to the test results: 0 = no blocking
                1 - slight cling. 2 = cling.. 3 = slight blocking. 4 = considerable blocking. 5 = complete
                blocking. Table 4-E.1 in Appendix 4-E provides a detailed description of this scale
        CDE L*a*b* — Solvent-based and Water-based Inks


               For most sites, samples were taken at four locations on the substrate during the test run
               Due to the aborted run using the PE/EVA substrate at Site 7, however, samples were taken
               only from the beginning and the end of the run. Sites 8 and 9 also had shorter runs, with
               samples taken only from the beginning, 30 minutes into run, and the end of the run.


               Table 4.12 presents the results of the CIE L*a*b* test. Because this test does not have
               units and should be used for relative comparisons only, no overall statements can be made
               about the results of this test.
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                  Table 4.12 CIE L*a*b* Results — Solvent-based and Water-based Inks
Ink
Solvent-
based













Solvent-
based











Water-based







|
Film
DPE








PE/EVA





PE/EVA



OPP








LDPE








Product
#S2








#S2





#S2



#S1



#S2




#W3








Site
5



7



L5
5



L7

7



9B



10



L4
2



3



L1
Color
magenta
cyan
green
blue
maqenta
cyan
qreen
blue
green
magenta
cyan
qreen
blue
green
cyan
magenta
cyan
qreen
blue
magenta
cyan
qreen
blue
magenta
cyan
qreen
blue
qreen
magenta
cyan
qreen
blue
magenta
cyan
green
blue
green
Average
L*
47.07
59.82
53.42
38.07
50.03
61.75
63.67
42.43
61.73
54.11
62.17
56.78
36.84
65.25
63.30
50.98
61.22
67.69
38.77
51,98
59.97
64.76
47.64
67.01
70.86
56.29
40.01
69.86
51.43
56.38
62.31
34.11
52.46
64.10
61.77
33.43
68.39
Average
a*
58.41
-40.31
-48.59
5.25
54.48
-38.85
-39.34
0.03
-40.73
47.73
-27.49
-55.08
16.46
-37.46
-28.79
54.00
-31 .68
-46.98
13.11
52.20
-37.48
-35.20
-5.21
29.98
-27.42
-47.18
2.51
-35.62
50.55
-27.94
-51.15
16.01
51.31
-32.03
-54.49
17.90
-44.29
Average
b*
-4.83
-13.65
29.56
-50.33
-6.93
-23.90
31.42
-46.95
30.10
-0.38
-37.61
32.32
-57.24
31.32
-37.44
-3.89
-37.12
32.09
-53.87
-3.96
-27.02
30.42
-39.55
-5.73
-12.67
29.39
-46.11
32.38
-1.75
-35.69
34.34
-49.82
-7.16
-21.71
37.65
-50.75
32.33
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                      Table 4.12 CIE L*a*b* Results — Solvent-based and Water-based Inks
                                                 (continued)
Ink
cont.
Film

OPP

Product
Line
#W3
#W1
#W2
#W4

Site
2
3
L6
4
1
L3
9A



L2
Color
magenta
cyan
green
blue
magenta
cyan
green
blue
green
cyan
magenta
cyan
jjreen
blue
magenta
cyan
green
blue
green
magenta
cyan
green
blue
green
Average
55.22
58.57
62.32
33.87
54.03
62.00
62.27
35.01
70.40
64.77
49.22
59.46
53.32
39.75
50.17
57.40
64.19
30.19
72.58
48.53
57.80
61.39
42.17
66.32
Average
48.52
-22.09
-58.16
19.50
55.08
-28.11
-59.70
18.94
-51.59
-28.94
51.22
-32.96
-54.58
1.28
47.82
-30.72
-57.66
15.65
-32.68
52.36
-35.74
-53.33
-1.38
-44.36
Average
-1.05
-40.29
34.05
-4927
-2.54
-39.06
34.92
-50.39
29.28
-37.15
-4.05
-25.57
31.23
-45.48
2.44
-27.87
44.41
-37.30
25.21
4.16
-29.96
32.10
-44.90

L in a site number indicates that the data were taken from a run conducted at Western
Michigan University, not from a volunteer printing facility.
        Coating Weight — Solvent-based and Water-based Inks

               Coating weight was measured for green, blue, and white printed areas on OPP and LDPE.
               Only the green and blue inks were tested oh PE/EVA because it is a white substrate.

               Figures 4.1-4.3 show the average coating weight data: The water-based inks in this study
               had higher solids content than the solvent-based inks, a typical scenario for these ink types.
               Therefore, on average, the water-based inks exhibited higher coating weights than the
               solvent-based inks on PE/EVA and OPP.  This difference was most marked in the case of
               white ink on OPP and for blue and green inks on PE/EVA. For LDPE, on the other hand,
               the coating weight for water-based green ink was substantially lower than that for solvent-
               based green ink.
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              Figure 4.1 Average Coating Weight for LDPE - Solvent-based and
                                  Water-based Inks
                 2.5 -i
Solvent-based ink Water-based ink
H Blue ink

Blue ink :
Green ink
White ink
0 Green ink , Q White ink
Solvent-based ink
1.77


1.98
2.21
Water-based ink
1.61
• 1.39
2.36
                    Figure 4.2 Average Coating Weight for PE/EVA — Solvent-based and
                                          Water-based Inks
                  2.5 -i
                             Solvent-based ink

                                   Blue ink
             Water-based ink

          Green ink

Blue ink
Green ink
Solvent-based ink
• .. 1.22 •
	 1.39
Water-based ink
2.02
1.65
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                        Figure 4.3 Average Coating Weight for OPP — Solvent-based and
                                              Water-based Inks
                  03

                  I

  3.5-1

    3-

  2.5-

    2-

  1.5-
                  o
                  o
P0.5H
                              Solvent-based ink             Water-based ink

                            Blue ink      ^]  Green ink    Q  White ink

Blue ink
Green ink
White ink
Solvent-based ink
1.24
1.2
2.24
Water-based ink
1.39
1.64
3.24
        Coefficient of Friction — Solvent-based and Water-based Inks

               The coefficient of friction (COP) between two layers of imprinted substrate was measured
               to provide a control.  The COF was then measured between printed substrate and
               unprinted substrate, as well as between printed substrate and printed substrate.  Printed
               samples from Sites 1, 4, 9, and 10 were not tested in the laboratory because the OPP
               substrate printed at these sites was laminated to another substrate. The lamination traps
               the ink between the two substrate layers, making it unnecessary to test for COF.

               Table 4.13 .summarizes the COF test results. This test does not have a standard, because
               high COF may be desirable in some printing situations (for  instance, if products are
               stacked on top of one another), whereas a low COF may be equally important in other
               cases. As would be expected, the unprinted controls had the lowest average COF, the
               products  with only one surface printed (Ink-Un) had a higher average  COF, and the
               products with both surfaces printed (Ink-Ink) had the highest average COF. Beyond this,
               however, no clear differences emerged between the two ink systems or among the different
               substrates.
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                 Table 4.13 Coefficient of Friction Results — Solvent-based and Water-based Inks
Ink
Solvent-based
Water-based
Film
LDPE
PE/EVA
LDPE
PE/EVA
Product Line
#S2
#S2
#W3
#W3
Site
5
7
L5
5
7
L7
2
3
L1
2
3
L6
Average Angle of Inclination
(degrees)
Ink-Una
28.4
25.2
20.8
25.6
23.5

27.6
27.8
34.2
24.8
21.6
26.6
Ink-Ink"
36.5
35.4
30.6
38.2
22.2

33.0
29.4
34.2
32.6
32.8
40.0
Control0
22.3
23.3
23.3
16.7
16.7

23.2
23.3
23.3
16.7
17.2
16.7
                 "L" in a site number indicates that the data were taken from a run conducted at Western
                 Michigan University, not from a volunteer printing facility.
                 a"lnk-Un" represents the coefficient of friction for printed substrate on unprinted substrate.
                 b"lnk-lnk" represents the coefficient,of friction for printed substrate on printed substrate.
                 c"Control" represents the coefficient of friction for unprinted substrate on unprinted substrate.
        Density — Solvent-based and Water-based Inks

                Density was measured on areas printed with magenta, cyan, green, and blue inks. Due to
                shortened runs at Sites 7 and 9, samples were taken only at three of the four planned
                locations on the runs. Fewer samples than usual were taken for testing from the laboratory
                runs because they were shorter in duration than the performance demonstration runs.

                Figures 4.4-4.6 show the average density for these four ink colors on each substrate.
                Scores were highest  for blue ink in all scenarios, and blue ink scores were higher for
                water-based inks than for solvent-based inks. Scores for the other colors tended to be fairly
                consistent with each  other. On OPP, density was considerably higher on all water-based
                inks.
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 CHAPTER4
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                 Figure 4.4 Average Density for LDPE - Solvent-based and Water-based Inks

                  2.5-1
Solvent-based ink

ffi  Magenta ink
Vy\  Green ink
                                                        Water-based ink
                                                    Cyan ink
                                                    Blue ink

Magenta ink
Cyan ink
Green ink
Blue ink
Solvent-based ink
1.4
1.39
1.13
1.82
Water-based ink
1.23
1.19
1.35
2.14
                Figure 4.5 Average Density for PE/EVA — Solvent-based and Water-based Inks
                  1.5-

               &
                I  ^
               Q

                  0.5^
                            Solvent-based ink

                            0  Magenta ink
                            H  Green ink
                            Water-based ink
                       Cyan ink
                       Blue ink

Magenta ink
Cyan ink
Green ink
Blue ink
Solvent-based ink
1.32
1.51
1.18
1.85
Water-based ink
1.2
1.2
1.43
1.97
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CHAPTER4
                               PERFORMANCE
                  Figure 4.6 Average Density for OPP — Solvent-based and Water-based Inks
                  1.5
                 o>
                Q
                    H
                  0.5-
                    0
                              Solvent-based ink

                              [Qj   Magenta ink
                                   Green ink
              Water-based ink
          Cyan ink
          Blue ink

Magenta ink
Cyan ink
Green ink
Blue ink
Solvent-based ink
0.82
0.99
0.93
1.74
Water-based ink
1.31
1.36
1.44
1.94
       Dimensional Stability — Solvent-based and Water-based Inks

              Due to shortened runs at Sites 7 and 9, samples were taken only from some of the four
              scheduled locations on the run. Table 4.14 presents the results of the dimensional stability
              test. No statistically significant differences were evident between solvent-based and water-
              based ink systems.
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 CHAPTER 4
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                Table 4.14 Dimensional Stability Results — Solvent-based and Water-based Inks
Ink
Solvent-based
Water-based
Film
LDPE
PE/EVA
OPP
LDPE
PE/EVA
OPP
Product
Line
#S2
#S2
#S1
#S2
#W3
#W3
#W1
#W2
#W4
Site
5
7
5
7
9B
10
2
3
2
3
4
• 1
9A
Average Percent
Change (Width)
0.5%
0.6%
0.6%
0.5%
0.7%
0.6%
0.5%
0.4%
0.5%
0.5%
0.5%
0.7%
0.7%
Average Percent
Change (Length)
2.0%
0.4%
2.4%
1.6%
1.1%
2.5%
1.0%
0.9%
2.3%
1.5%
1.5%
1.6%
1.5%
       Gloss — Solvent-based and Water-based Inks

              Samples from sites 1,  4, 9, and 10 were not subjected to this test because the OPP
              substrate printed at these sites was laminated.  The ink was trapped between the two
              substrate layers, making it unnecessary to test for gloss. Limited data were available from
              Site 7 due to the shortened run on PE/EVA.  Because the laboratory runs were shorter in
              duration than the performance demonstration runs, samples for testing were only cut from
              three locations.

              Figure 4.7 shows the average gloss for samples on LDPE and PE/EVA.  Overall, inks
              showed higher gloss on PE/EVA than on LDPE, and solvent-based inks on PE/EVA had
              the highest gloss.
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CHAPTER 4
                              PERFORMANCE
                   Figure 4.7 Average Gloss for LDPE and PE/EVA — Solvent-based and
                                           Water-based Inks
                 60-i
               ta
               J>50
               'c
               JT40-
                CD
                0)
                •g20
                o
                
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 CHAPTER4
                                                                               PERFORMANCE
                       Table 4.15 Heat Resistance/Heat Seal Results — Solvent-based and
                                               Water-based Inks
Ink
Solvent-
based
Water-
based
Film
OPP
OPP
Product
Line
#S1
#S2
#W1
#W2
#W4
Site
9B
10
L4
4
1
L3
9A
L2
Number of
Passes
9
0
12
9
0
1
6
0
Number
of
Failures
9
18
0
15
24
11
12
12
Average Percent of
Ink Transfer Per
Failure
10%
39%
• —
21%
26%
10%
9%
22%
                "L" in a site number indicates that the data were taken from a run conducted at Western
                Michigan University, not from a volunteer printing facility.
        Ice Water Crinkle Adhesion — Solvent-based and Water-based Inks

               Printed samples from Sites 1, 4, 9, and 10 were not tested because the OPP substrate
               printed at these sites was laminated. This trapped the ink between the two substrate layers,
               making it unnecessary to test the ink on the OPP substrate.

               Ink adhesion was measured for each color on each substrate. Table 4.16 summarizes the
               results of this test. The  solvent-based ink performed successfully on both the LDPE and
               PE/EVA substrates. Water-based ink #W3 was evaluated at two sites.  At Site 2, the ink
               performed successfully on both substrates, but at Site 3 the ink failed on both substrates.
               These results suggest that facility-specific factors other than ink might have affected the
               results.
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                      Table 4.16 Ice Water Crinkle Adhesion Results — Solveht-based and
                                              Water-based Inks
Ink
Solvent-
based
Water-
based
Film
LDPE
PE/EVA
LDPE
PE/EVA
Product
Line
#S2
#S2
#W3
#W3
Site
5
7
L5
5
7
L7
2
3
L1
2
3
L6
Any Ink Removal?
no
no
no
no
no
no
no
yes, less than 5%
no
no
no; less than 5%a
yes, about 30% of the green ink
and less than 1 5% of the blue ink
               "L" in a site number indicates that the data were taken from a run conducted at Western
               Michigan University, not from a volunteer printing facility.
                aThree of the four samples had complete ink adhesion. The fourth sample had less than 5%
               removed.
       Image Analysis — Solvent-based and Water-based Inks

              Due to the shortened run using the PE/EVA substrate at Site 7, samples were taken only
              from the beginning and 30 minutes into the run.  Because Sites 8 and 9 also had shorter
              runs, samples were taken only from the beginning, 30 minutes into run, and the end of the
              run.

              Table 4.17 presents the image analysis results. Because the purpose of this test was  to
              evaluate screened dot detail as used in process color reproduction, only the magenta and
              cyan process inks were analyzed. Table 4.17 presents the average dot area and perimeter
              for these two colors at each performance demonstration site. No statistically significant
              differences were evident between the two ink systems.
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 CHAPTER 4
                                                                            PERFORMANCE
                    Table 4.17 Image Analysis Results — Solvent-based and Water-based Inks
Ink
Solvent-based
Water-based
Film
LDPE '
PE/EVA
OPP
LDPE
PE/EVA
OPP
Product
Line
#S2
#S2
#S1
#S2
#W3
#W3
#W1
#W2
#W4
Site
5
7
5
7
9B
10
2
3
2
3
4
1
9A
Color
magenta
cyan
magenta
cyan
magenta
cyan
magenta
cyan
magenta
cyan
magenta
cyan
magenta
cyan
magenta
cyan
magenta
cyan.
magenta
cyan
magenta
cyan
magenta
cyan
magenta
cyan
Average
Dot Area
(micron2)
953.28
725.86
1049.71
556.95
912.18
721.00
753.80
323.88
620.58
499.75
568.41
'• 967.98
608.53.
925.17
887.76
608.71
705.83
911.05
649.76
840.34
837.88
781.21.
371.59
338.71
715.59
748.80
Average
Dot
Perimeter
(microns)
125.06
104.26
130.64
107.29
118.81
104.70
123.13
103.58
102.60
84.20
122.39
263.90
93.30
120.86
127.30
97.16
107.11
118.63
96.93
114.19
116.53
112.03
97.63
81.61
108.58
95.80
       Jar Odor — Solvent-based and Water-based Inks

              Jar odor was evaluated for both printed and unprinted substrates. Table 4.18 presents the
              results of the jar odor test, listing the strength of the odor present and a description of the
              odor.

              Most of the water-based ink samples had a relatively strong ammonia odor (2 to 3 on a
              scale of 5).  Water-based ink #W1 had a strong, unpleasant odor that was not specifically
              identified as ammonia.  The solvent-based inks had a waxy odor of varying strength (1 to
              3 on a scale of 5) on all substrates.  The one exception was the sample printed with
              solvent-based ink #S2 on PE/EVA film at Site 7; this sample had no odor for the control
              or the printed sample.
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CHAPTER 4
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                      Table 4.18 Jar Odor Results — Solvent-based and Water-based Inks
Ink
Solvent-
based
Water-
based
Film
LDPE
PE/EVA
OPP
LDPE
PE/EVA
OPP
Product
Line
#S2
#S2
#S1
#S2
#W3
#W3
#W1
#W2
#W4
Site
5
7
L5
5
7
L7
9B
10
L4
2
3
L1
2
3
L6
4
1
L3
9A
L2
Relative
Score8
3
1
2
1
0

3
1
1
3
3
3
3
3
1
4
2
2
0
2
Description of
Printed Area
unpleasant
waxy, not a big
difference from
control
mild waxy
not very
different from
control; slightly
like ethyl
acetate
no odor
mild waxy
ethyl acetate
waxy, no
difference from
control
mild waxy
strong ammonia
odor
strong ammonia
odor
strong ammonia
odor
strong ammonia
odor
strong ammonia
odor
mild waxy
unpleasant,
strong
ammonia odor
ammonia odor
no difference
from control
ammonia odor
Description of
Unprinted Area
(control)
very slightly waxy
waxy,
hydrocarbons
very mild waxy
mild waxy
no odor
very mild waxy
mild waxy
waxy
very mild waxy
very slight waxy
no odor
very mild waxy
very slight waxy
very mild waxy
mild waxy
mild
mild
very mild waxy
mild waxy
very mild waxy
                "L" in a site number indicates that the data were taken from a run conducted at Western
                Michigan University, not from a volunteer printing facility.
                 aPrinted samples were scored on a scale from 0 to 5, with 0 signifying no odor, and 5 signifying
                an unpleasant, offensive odor.
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 CHAPTER4
                                                                             PERFORMANCE
        Mottle/Lay — Solvent-based and Water-based Inks

               Mottle was measured on green and blue printed areas.  Figures 4.8-4.10 show much
               higher mottle on the samples printed with water-based inks, especially on LDPE and
               PE/EVA.  Wettability of the substrate plays a role in mottle, and polyethylene substrate
               surfaces generally do not wet as well as OPP. Corona treatment was employed, however,
               on all of the LDPE and PE/EVA substrates where water-based inks were used.

               Mottle also was significantly higher on the blue printed areas of all samples tested. None
               of the variables hi this study are thought to account for the differences between the green
               and blue printed sample results for mottle/lay.  Ink formulation and pigment type are most
               likely the cause for the variations; these variations were evident both ink systems.
                Figure 4.8 Average Mottle Index for LDPE — Solvent-based and Water-based Inks
                               Solvent-based ink

                                 •   Blue ink
                Water-based ink

           Green ink

Blue ink
Green ink
Solvent-based ink
298.7
69.8
Water-based ink
793.75
101
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                             PERFORMANCE
             Figure 4.9 Average Mottle Index for PE/EVA — Solvent-based and Water-based Inks
                 1000^
                  800
               J>  600
               o  400
                  200

                    0
                            Solvent-based ink
                                 Blue ink
              Water-based ink
          Green ink

Blue ink
Green ink
Solvent-based ink
343.25
87.5
Water-based ink
812.25
85
              Figure 4.10 Average Mottle Index for OPP — Solvent-based and Water-based Inks
               o,
600 -n
500-
400-
300-
200-
100-
o-





XV




M
                           Solvent-based ink
                            H   Blue ink
              Water-based ink
          Green ink

Blue ink
Green ink
Solvent-based ink
386.7
78
Water-based ink
531.5
96
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 CHAPTER 4
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        Opacity — Solvent-based and Water-based Inks

               Opacity was measured for samples of white ink on LDPE and OPP.  White samples were
               not printed on PE/EVA because it is a white substrate! The laboratory runs, as well as the
               runs at Site 9, were shorter in duration than the other demonstration runs; samples were
               therefore available only from three locations on these runs.

               Results for both ink systems were considered acceptable by industry standards (opacity
               greater than 48 %). Results were virtually identical for both ink systems on both substrates.

        Rub Resistance — Solvent-based and Water-based Inks

               Samples from sites 1, 4, 9, and  10 were  not tested in the laboratory, because the OPP
               substrate printed at these sites was laminated to another substrate.  This lamination trapped
               the ink between the two substrate layers, making it unnecessary to test for rub resistance.
               Due to the shortened run using the PE/EVA substrate at Site 7, samples were taken only
               from the beginning and end of the run.   Because Site 8 also had a shorter run for the
               PE/EVA substrate, samples were taken only from the beginning,  30 minutes into the run,
               and the end of the run.

               The blue sample was used for rub testing of the samples taken from the performance
               demonstration sites.  Because blue was not printed during the laboratory runs, the green
               samples were tested instead.

               All inks retained close to 95 % of their density after the dry rub test.  Table 4.19 presents
               a summary of the wet rub test results. During the wet rub testing,  the water-based  ink
               printed on LDPE performed the best, with "no failure at ten strokes" being reported on
               the samples from both Sites 3 and LI.  The other ink-substrate combinations had mixed
               results.
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CHAPTER 4
                                                                              PERFORMANCE
                 Table 4.19 Wet Riib Resistance Results — Solvent-based and Water-based Inks
Ink
Solvent-
based
Water-
based
Film
LDPE
PE/EVA
LDPE
PE/EVA
Product Line
#S2
#S2
#W3
#W3
Site
5
7
L5
5
7
L7
2
3
L1
2
3
L6
Failure at Number of Strokes
(average)3
4.2
5.0
no failure at 10 strokes
2.2
5.0
5.7
8.0
no failure at 10 strokes
no failure at 10 strokes
2.5
3.2
two samples had failures at 6
and 7 strokes; one sample had
no failure at 1 0 strokes
                "L" in a site number indicates that the data were taken from a run conducted at Western
                Michigan University, not from a volunteer printing facility.
                aA failure represents ink color transferred from the printed substrate to the unprinted substrate.
                A maximum of 10 strokes were used for the wet rub resistance test. Measurements were taken
                at four locations and averaged.
        Tape Adhesiveness — Solvent-based and Water-based Inks

               Tape adhesiveness was measured on LDPE, PE/EVA, and when appropriate, on OPP. The
               OPP substrates run at the'demonstration sites were not tested in the laboratory because
               these substrates were laminated. Thus, only OPP substrates printed in the laboratory runs
               were tested for tape adhesiveness. Only the colored inks were tested on the PE/EVA
               substrate because it is a white substrate.

               Table 4.20 presents the results of the tape adhesiveness test. Both inks adhered completely
               to LDPE.  Solvent-based and water-based inks showed good adhesion when printed on
               OPP during the laboratory runs.
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 CHAPTER4
                                                                             PERFORMANCE
                 Table 4.20 Tape Adhesiveness Results — Solvent-based and Water-based Inks
Ink
Solvent-
based
Water-based

Film
LDPE
PE/EVA
OPP
LDPE
PE/EVA
OPP

Product Line
#S2
#S2
#S2
#W3
#W3
#W2
#W4
Site
5
7
-L5
5
7
L7
L4
2
3
L1
2
3
L6
L3
L2
Number
of
Passes
4
4
3
2
0
3
3
4
4
3
2
3
0
3
3
Number
of
Failures
0
0
0
2
2
0
0
0
0
0
2
1
3
0
0
Comments



outline of cyan
and magenta
was removed
cyan and
magenta were
slightly removed





blue was
removed
green was
removed
all colors were
removed


                "L" in a site number indicates that the data were taken from a run conducted at Western
                Michigan University, not from a volunteer printing facility.
       Trap — Solvent-based and Water-based Inks

              Each site selected its own color sequence for first-down and second-down colors. Trap
              was measured for both 100% tone (solid) and 80% tone samples printed with magenta and
              cyan.                 •   • ,-

              Figure 4.11-4.12 show the average percent trap for these two ink colors on each substrate.
              The solvent-basedinks demonstrated better trap than the water-based inks on the PE/EVA
              and OPP films. The water-based inks showed slightly better performance than the solvent-
              based on the LDPE substrate.
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September 2000

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CHAPTER 4
                                                                       PERFORMANCE
                   Figure 4.11 Average Trap for LDPE and PE/EVA— Solvent-based and
                                          Water-based Inks
                                   LDPE: Solvent-based ink
                                   LDPE: Water-based ink
                                   PE/EVA: Solvent-based ink
                                   PE/EVA: Water-based ink,
               _DPE: Solvent-based ink
                                                          98.4
               LDPE: Water-based ink
                                                          104.8
               PE/EVA: Solvent-based ink
                                                          98.7
               PE/EVA: Water-based ink
                                                          86.9
                          Figure 4.12 Average Trap for OPP— Solvent-based and
                                          Water-based Inks
                  100
                            Solvent-based ink
          Water-based ink
                 Solvent-based ink
                 98
                87.8
                 Water-based ink
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  CHAPTER 4
                                                                               PERFORMANCE
         Highlights of Performance Results for Solvent-Based and Water-Based Inks

                No clear evidence emerged from these tests that either the solvent-based or the water-based
                system performed better overall. The results of the tests varied widely. On some tests, both
                ink systems performed comparably well on one substrate and poorly on another. COP,
                and in most  cases  density,  dimensional stability, image analysis, opacity, and  rub
                resistance, all displayed results that were fairly consistent from substrate to substrate for
                both ink systems.

                On the other hand, other tests showed wide internal variability.  Solvent-based  inks
                performed an average of 16 % better than water-based inks on the adhesive lamination test.
                Water-based inks had much better ratings than solvent-based inks on both LDPE and
                PE/EVA. Gloss was highest for solvent-based inks on PE/EVA. On OPP, heat resistance
                varied from 9% for one water-based ink to 39% for a solvent-based ink. Odors varied in
                both strength and type across both ink and substrate type. Mottle was significantly higher
                for blue inks and water-based inks. Tape adhesiveness and trap varied by substrate and ink
                system.

                These variances  point out the importance of a number of factors in the performance of
                these inks. Substrate type clearly emerged as a critical component of quality. The type and
                amount of the vehicle (solvent in solvent-based ink and  water in water-based ink), as well
                as press-side solvents and additives, affected the physical properties of ink and substrate.
                In turn, functional ink-substrate interactions such as wetting and adhesion affected several
                of the performance results.

               The variability of the results indicates that there may  not be one best overall choice of an
               ink system for all conditions and applications. One clear conclusion is that a flexographic
               printer cannot make a simple  assumption that any of these ink systems or ink-substrate
               combinations will be best-suited to the firm's overall needs. Careful testing of a potential
               ink system on the various substrates that a printer will  be using most often is critical to
               obtaining desired quality on a consistent basis.


 4.3  RESULTS OF PERFORMANCE DEMONSTRATION AND LABORATORY RUN TESTS -
 UV-CURED INKS

               This section focuses specifically  on the ultraviolet-cured ink system. UV-cured inks are
               treated separately because flexographic printing technology using this ink system was still
               hi a developmental phase at the time this research was performed (November 1996—March
               1997).  The' performance demonstrations using UV-cured ink should be viewed as a
               snapshot of the UV-cured ink technology under field  conditions during that time period.
               Since that tune, improvements in UV-cured inks have  been made that are described in
               more detail at the end of this section (Technological Developments in UV-cured Inks). Due
               to technical limitations, no laboratory runs were performed for UV inks.

               This section discusses the performance of UV-cured inks in the laboratory tests conducted
               to evaluate the performance demonstration samples.  For the methodology or for more
               specific information regarding the performance demonstration tests, please see Section 4.1
               of this chapter and Appendix 4-E. Table 4.2, near the start of this chapter, describes the
               purpose, procedure, and interpretation for each test that was performed.
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CHAPTER 4
                                                                                PERFORMANCE
               Substrate type played a major role in the performance of UV-cured inks during the tests,
               showing that the ink-substrate relationship is very important to the performance of printed
               products.  As is true for the solvent-based and water-based ink systems, the variability of
               the UV-cured ink results also varied widely among tests. Printers need to consider the
               needs of their clients, the type of substrates and products that they most often print, and
               the desired aspects of quality that are most critical overall, when determining which type
               of ink system will be most appropriate for the facility.

        Block Resistance — UV-cured Inks

               Table 4.21 shows the results of this test.  On LDPE the ink showed slight blocking.  Due
               to the absence of successful runs of UV-cured ink on the OPP substrate, no block
               resistance data were available for this ink-substrate combination.
                             Table 4.21  Block Resistance Results — UV-cured Inks
Ink
UV
UV (no slip)
Film
LDPE
PE/EVA
LDPE
Average Rating of Blocking
Resistance3
2.5
1.4
1.0
                 "The following scale was used to assign a numerical score to the test results: 0 = no blocking.  1
                 = slight cling.  2 = cling.  3 = slight blocking. 4 = considerable blocking.  5 = complete blocking.
                 Table 4-E.1 in Appendix 4-E provides a detailed description of this scale.
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  CHAPTER 4
                                                                        PERFORMANCE
        CIE L*a*b* — UV-cured Inks

               Results for LDPE and PE/EVA are shown in Table 4.22. Due to the absence of successful
               runs of UV-cured ink on the OPP substrate, no CIE L*a*b* data were available for this
               ink-substrate combination.
                              Table 4.22 CIE L*a*b* Results — UV-cured Inks
Ink
UV
UV-cured
(no slip)
Film
LDPE
PE/EVA
LDPE
Product
Line
#U2
#U2
#U3
#U1
Site
6
6
8
11
Color
magenta
cyan
green
blue
magenta
cyan
green
blue
magenta
cyan
green
blue
magenta
cyan
green
blue
Average
L*
43.80
61.17
65.54
40.57
47.60
60.78
64.47
38.81
53.21
62.38
70.93
48.64
52.71
59.88
63.86
3460
Average
a*
49.03
-37.58
-50.76
2.25
53.85
-30.65
-57.91
11.30
53.50
-27.22
-53.83
8.45
48.81
-33.27
-56.90
15 39
Average
b*
10.90
-23.76
32.96
-44.73
4.01
-38.58
31.73
-50.42
-2.41
-36.98
6.50
-46.77
-4.70
-24.42
10.70
-51 63
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       Coating Weight — UV-cured Inks

              On LDPE, coating weight was lowest for blue and highest for white inks. Figures 4.13 and
              4.14 show the results. There were no successful runs of UV-cured ink on OPP, so no
              coating weight data were available for this ink-substrate combination.

                      Figure 4.13 Average Coating Weight for LDPE — UV-cured Inks
                <§0.5H
                                  UVink
                          Blue ink
 Green ink
 UV ink (no slip)

I  I   White ink

Blue ink
Green ink
White ink
UVink
1.92
2.77
3.51
UV ink (no slip)
1.94
2.98
3.71
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                     3.5
                         Figure 4.14 Average Coating Weight for PE/EVA — UV-cured Inks
                    Blue ink
                    Green ink
                                                    UVink

                                      Blue ink      g|   Green ink
                                                            UV ink
3.07
                                                             2.1
        Coefficient of Friction — UV-cured Inks
               Results are shown in Table 4.23. UV ink #U3 at Site 11 had the highest COF, as was
               expected since a no-slip film was used. The COF for UV ink #U2 on LDPE (Site 6) was
               higher than the other ink-substrate combinations, particularly for two layers of printed
               substrate. Otherwise, no significant differences between inks tested on the LDPE and
               PE/EVA substrates existed. Due to the absence of successful runs of UV-cured ink on the
               OPP substrate, no COF data were available for this ink-substrate combination.
                            Table 4.23 Coefficient of Friction Results — UV-cured Inks
Ink
UV
UV (no slip)
Film
LDPE
PE/EVA
LDPE
Product
Line
#U2
#U2
#U3
#U1
Site
6
6
8
11
Average Angle of Inclination
(degrees)
Ink-Una
31.2
20.8
25.9
36.9
Ink-Ink"
53.8
21.3
24.7
60+d

23.3
16.7
16.7
45.0
                The angle of inclination was higher than 60 degrees.
                a"lnk-Un" represents the coefficient of friction for printed substrate on unprinted substrate.
                J'lnk-lnk" represents the coefficient of friction for printed substrate on printed substrate.
                ^'Control" represents the coefficient of friction for unprinted substrate on unprinted substrate.
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       Density — UV-cured Inks

              Results are shown in Figures 4. 15 and 4. 16.  On LDPE, the density score for blue ink was
              substantially higher than that for any other color. Density on LDPE was much lower on
              the high-slip substrate. Due to a shortened run at site 8, samples were taken only at three
              of the four planned locations on the runs. Due to the absence of successful runs of UV-
              cured ink on the OPP  substrate, no density data were  available for this ink-substrate
              combination.               ,

                          Figure 4.15 Average Density for LDPE — UV-cured  Inks
                   2.5 -r
                                   UVink
UV ink (high slip)
                                  Magenta ink    Ul  Cyan ink
                                  Green ink       H  Blue ink

Magenta ink
Cyan ink
Green ink
Blue ink
UVink
1.68
1.34
1.17
1.88
UV ink (high slip)
1.09
1.25
1.46
2.17
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                           Figure 4.16 Average Density for PE/EVA — UV-cured Inks
                                                 UVink
                                  Magenta ink
                                  Green ink
Cyan ink
Blue ink

Magenta ink
cyan ink
Green ink
blue ink
UVink
1.43
1.25
1.15
1.51
UV ink (high slip)
n/a
n/a
n/a
n/a
        Dimensional Stability — UV-cured Inks

              Results are shown in Table 4.24.  All three substrates showed similar measurements.
              Because the run at site 8 was shortened, samples were not taken from all scheduled
              locations. Due to the absence of successful runs of UV-cured ink on the OPP substrate,
              no dimensional stability data were available for this ink-substrate combination.
                         Table 4.24  Dimensional Stability Results  — UV-cured Inks
Ink

UV (no slip)
Film
LDPE
PE/EVA
LDPE
Product
Line
#U2
#U2
#U3
#U1
Site
6
6
8
11
Average
54.34
54.24
54.08
54.25
Average Length
77.24
77.92
75.83

       Gloss — UV-cured Inks

              Figure 4.17 shows the results for UV and UV no slip on LDPE. All readings were below
              50%, with UV on,LDPE performing the best (46.83%). UV on PE/EVA averaged
              42.41 %. Limited data were available from Site 8, due to the shortened runs on PE/EVA.
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              Due to the absence of successful runs of UV-cured ink on the OPP substrate, no gloss data
              were available for this ink-substrate combination.

                           Figure 4.17 Average Gloss for LDPE — UV-cured Inks
                  50
                     1
                $40
                'c

                |30
                CO
                2
                3*20
                -a
                o
                CO

                JlO
                CD
HP
SSfeSSSfi


               UVink
                               UVink
                 UVink (no slip)
                        46.83
                                                            32.31
               UV ink (no slip)

        Ice Water Crinkle Adhesion — UV-cured Inks

               Table 4.25 shows that two of the three UV-cured product lines (UV ink #U1 and UV ink
               #U3) stayed flexible on both substrates, but UV ink #U2 failed on both substrates.
                        Table 4.25 Ice Water Crinkle Adhesion Results - UV-cured Inks
         Image Analysis — UV-cured Inks

               Table 4 26 shows the results of the test. Both average dot area and average dot perimeter
               varied but not consistently with each other. Dot area showed a range from 384 square
               microns (cyan on PE/EVA) to 966 square microns (cyan on LDPE). Dot perimeter varied
               from a low of 80 square microns (cyan and magenta) to a high of almost 139 square
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                microns (cyan). Due to the absence of successful runs of UV-cured ink on the OPP
                substrate, no image analysis data were available for this ink-substrate combination.

                             Table 4.26 Image Analysis Results — UV-cured Inks
                                                                               Average
                                                                                 Dot
                                                                              Perimeter
                                                                               microns
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       Jar Odor — UV-cured Inks

               Table 4 27 lists the results of this test. The UV-cured inks showed more of a range in
               scores than did the other ink types. UV ink #U3 had the mildest odor, both in strength (1)
               and description (mild waxy).  The odor from UV ink #U1 was rated 3 in strength and was
               described as "mild acetic acid."  UV ink #U2 had the strongest odors (4 to 5 on a scale of
               5) and was described as "very strong bitter almond" on the LDPE substrate, and as very
               strong  decayed fish" on the PE/EVA.  It should be noted  that  the controls  for these
            :   samples were, respectively,  "slightly like bitter almond" and "fish."  This implies that
               either the unprinted substrate's odor affected the odor of the ink sample, or that the odor
               of the ink sample affected the entire roll (both printed and unprinted areas). Due to the
               absence of successful runs of UV-cured ink on the OPP substrate, no jar odor data were
               available for this ink-substrate combination.

                                 Table 4.27 Jar Odor Results - UV-cured Inks
	
ik
V
JV
slip)
.
Film
LDPE
PE/EVA
LDPE
— ^^=^=
=====
Product Line
=====
#U2
#U2
#U3
#U1
=====
===
Site
=
6
6
8
11
=====
•
Relative
Score3
=====
4
5
1
3
=====
Description of
Printed Area
=====
very strong
bitter almond
very strong,
decayed fish
very slight odor
acetic acid, mild
=====
Description of
Unprinted Area
(control)
slightly like bitter
almond
fish
mild waxy
waxy
=====
                •Printed samples were scored on a scale from 0 to 5, with 0 signifying no odor, and 5 signifying an
                unpleasant, offensive odor.
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          Mottle/Lay — UV-cured Inks
                Figures 4.18 and 4.19 display the results of the mottle/lay test. Green ink showed little
                mottle on either substrate. Due to the absence of successful runs of UV-cured ink on the
                OPP substrate, no mottle data were available for this ink-substrate combination
                          Figure 4.18 Average Mottle Index for LDPE — UV cured Inks
                     400 -i
                                    UVink

                                     Blue ink
                                         UVink
                                         "281"
                                           73
     UV ink (no slip)

Green ink

       UV ink (no slip)
           382.5
                                                                  47
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                       Figure 4.19 Average Mottle Index for PE/EVA — UV-cured Inks
                  500
                                   Blue ink
UVink

IH  Green ink

Blue ink
Green ink
UVink
491
53.45
UV ink (no slip)
n/a
n/a
        Opacity — UV-cured Inks

               The readings averaged around 55 % but showed high standard deviation values, which may
               indicate poor uniformity of substrate coverage.  Only LDPE data were collected for this
               test. The opacity test was not run on PE/EVA because it is a white substrate, and there
               were no successful runs of UV-cured ink on OPP.
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          Rub Resistance — UV-cured Inks

                 Table 4.28 shows the results of wet rub resistance tests. UV on LDPE performed the best
                 with failure at an average of 5.2 strokes. Due to the absence of successful runs of UV-
                 cured ink on the OPP substrate, no rub resistance data were available for this ink-substrate
                 combination. For dry rub resistance, the ink used on no-slip LDPE (Site 11) received the
                 only score below 90%.

                             Table 4.28 Wet Rub Resistance Results - UV-cured Inks
                                                                 Failure at Number of Strokes
                                                                          average
                                                                             5.2
                                 ^^^                       sub*trate to the imprinted substrate.
                 at four locations and averaged. See Appendix 4-E for specifics.
         Tape Adhesiveness — UV-cured Inks

                Table 4.29 shows the results of the test. Results were mixed. UV no slip on LDPE had no
                failures and 4 passes,  whereas UV on PE/EVA had the reverse showing  Due to the
                absence of successful runs of UV-cured ink on the OPP substrate, no tape adhesiveness
                data were available for this ink-substrate combination.
                           Table 4.29 Tape Adhesiveness Results - UV-cured Inks
                    Ink
                UV
                in
                (no slip)
                             'E/EVA
LDPE
            #U2
                                         #U3
#111
                                                                           white and magenta
                                                                           were removed
                                                                           blue, green, and
                                                                           magenta were
                                                                           removed
                                                                           cyan was slightly
                                                                           removed
       Trap — UV-cured Inks

              This system averaged approximately 90% for trapping. UV inks on PE/EVA scored an
              average of 93 %, whereas on LDPE the inks scored an average of 87 %. Due to the absence
              of successful runs of UV-cured ink on the OPP substrate, no trap data were available for
              this ink-substrate combination.
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       Uncured Residue — UV-cured Inks

               The uncured residue test was performed only for UV-cured inks. The uncured residue test
               was measured in the laboratory with samples collected from Sites 6, 8 and 11.  UV ink
               was not run at any other sites.

               Uncured residue was measured only for green, blue, and white ink, since these colors had
               the largest areas of coverage!  Results are presented in Table 4.30 as average percent (by
               weight) of ink removed. The averages are based on four measurements taken at different
               locations from each site sample. Uncured residue was found only on the blue ink samples.
               Due to the absence of successful runs of UV ink on the OPP substrate, no uncured residue
               data were available for this ink-substrate combination.
                         Table 4.30 Average Uncured Residue Results — UV-cured Inks


Ink

======
UV





Film

=====
LDPE
PE/EVA




Product Line

— 	
#U2
#U2
#U3
#U1


Site

6
6
8
11

Percent of Ink
Removed
(by weight)3
0.00
0.00
6.97
10.42
                 aUncured residue was found on the blue ink samples only.
         Summary of Performance Test Results for UV-Cured Inks

                These performance demonstrations were completed in 1996 and 1997, and flexographic
                printing technology for UV-cured inks has made significant advances since then.  The test
                results recorded in this CTSA provide a snapshot of UV technology early in its technical
                development but do not necessarily lead to any conclusions about current or potential
                abilities of UV inks. In fact, just as for solvent-based and water-based inks, no one test can
                provide a reliable or accurate indicator of overall quality for any printer.  Printers need
                to consider a variety of different factors in determining acceptable quality. These factors
                - among them cost, health and environmental risks, energy use, and pollution prevention
                opportunities — are discussed in other chapters of this CTSA.

                UV-cured inks  performed well on some tests.  The inks displayed good resistance to
                blocking, particularly on PE/EVA and no-slip LDPE. The inks displayed relatively good
                trapping  Mottle was better than that of the water-based inks and comparable to that of the
                solvent-based inks. For the ice water crinkle test, only one UV-cured ink (#U2) displayed
                evidence of removal.   Also, the coating weight was greater than that for solvent- and
                water-based inks, despite lower ink consumption as measured in Chapter 6.

                The test results on these particular UV product lines also showed a need for improvement,
                particularly some physical adherence tests. The rub resistance and tape adhesiveness
                results were unimpressive for inks #U1 and #U3; these results may have been caused by
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                 the incomplete curing observed with these two product lines. The opacity level (measured
                 for white inks  only)  showed a high  standard deviation, which indicated a lack of
                 uniformity. In addition, gloss was low, despite the fact that high gloss is considered to be
                 a strength of UV finishes.   •

                 With any new  technology, changes can  occur rapidly/and UV-cured  inks are  no
                 exception. Some evidence exists that some of the limitations noted in the CTSA have been
                 remedied to some extent. For example, cationic inks (as opposed to the free-radical UV
                 inks studied in this CTSA) may have lower shrinkage rates and improved flexibility which
                 may help with adherence.  Other adjustments in chemistry are being made to 'reduce
                 viscosity  and  improve the  curing  rate of UV, inks.   Furthermore,  improvements  in
                 equipment may lead to overall better coatings.

         Technological Development in UV-cured Inks

                 Since the performance demonstrations were  completed,  UV-cured flexographic ink
                 technology has experienced a  number of changes.   This section describes significant
                 developments  and the improvements they could yield, and  discusses aspects of the
                 technology that continue to pose difficulties.

                Many advances have been made in the past few years that improve the quality of UV inks
                for wide-web flexography. New cationic inks might offer an alternative for printers who
                use porous substrates, need  a more thoroughly cured ink, or print items for which odor
                must be minimized. Improvements have been made with free-radical UV-cured inks- some
                inks can be used on several substrates, the viscosity has been reduced, and the ink is more
                durable when applied.  Equipment improvements have led to better heat management
                which m turn has-provided printers with better energy efficiency, improved equipment
                durability, and high-quality products. Furthermore, technologies such as improved UV
                bulbs are improving curing rates while at the same time requiring that less photoinitiator
                be included in the ink.

                Although  UV wide-web flexography still faces obstacles, technological developments
                indicate that UV will continue to improve and grow in the future.

                Cationic Inks
                Currently,  most UV-cured ink is based on free radical curing,  which involves acrylate
               monomers that, when exposed to high-energy ultraviolet light, undergo a chain reaction
               to bind together in a large polymer.  (For more information on the free-radical curing
               process, see Chapter 2.)  This free radical reaction is beneficial in several ways most
               prominently that the reaction (or "drying") is almost instantaneous when the polymer is
               exposed to the UV light. However, the reaction process causes the ink to shrink which
               affects the ability of the ink to bind to the substrate. Also, the reaction can be inhibited by
               the presence of oxygen,  and  unreacted acrylic molecules can have an unpleasant odor.1

               The evolution of cationic inks is one of the most significant recent developments in UV-
               cured ink technology. Cationic inks work in a similar fashion to free-radical inks in that
               small monomers react to form a cohesive polymer in  the presence of UV rays'  This
               process differs from free radical curing in that the monomer in the ink is usually an
               epoxide rather than an acrylate, and that the reaction occurs  due to  the reaction of
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               electron-deficient ions, rather  than the binding of electronically-neutral but unstable
               radicals.

               One benefit of the cationic system over the free radical system is that the reaction is not
               inhibited by oxygen; therefore, the   curing is usually more complete.  However, the
               reaction can be limited if bases, such as amines, are present in the ink or substrate.2

               Cationic, inks have several other advantages. The epoxide shrinks less than acrylate when
               it polymerizes, and therefore adheres to the substrate better. Cationic inks have less odor,
               because the material dries more thoroughly and because epoxides are inherently less
               odorous than acrylics. Furthermore, cationic inks are less viscous. As a result, they flow
               well without heating, they require corona treatment less frequently, and the applied layer
               is more evenly spread for solid colors. Ink densities are also stronger for cationic inks
               than they might be for free radical inks.3  In addition,  cationic inks can produce a high
               gloss  and good adhesiveness,  and thus can prevent the need for costly lamination on
               certain products.4

               There are several disadvantages, however, that currently make canonic inks a less popular
               option than the more established free radical system. Even though cationic inks may dry
               more thoroughly, the drying process takes longer. This has implications for press speed,
               because additional colors cannot be added until the first  color cures.5  Also,  the final
               product printed with cationic inks does not have as much solvent resistance as free radical
               inks.6 Finally, cationic inks might not cure effectively on high-pH substrates, such as
               paper.   ,

               Other Ink Developments
               Significant advances have been made in adjusting the properties  of both free radical and
               cationic inks.  One such property is the ability to be printed  on more than one substrate.
               Early UV-cured inks were specially formulated for a given substrate, and several sets of
               UV ink chemistries had to be stored on-site if a printer worked with multiple substrates.
               This  practice was inconvenient and increased inventory costs.  Newer UV-cured inks are
               more universal and perform consistently on most substrates.  However, these inks may
               damage the photopolymer plates, which then require more frequent changing.7

               Ink suppliers are now developing UV-cured inks that have less odor, either by reducing
               the amount of photoinitiator and monomer needed, or modifying the chemical structure of
               the monomer so that it  is less pungent.8  Skin irritation sometimes caused by UV-cured
                inks  has been mitigated by using water to reduce the viscosity of the inks rather than
               traditional diluents.9  Also, the resistance of inks to water damage has been improved by
                developing additives that make the ink more durable.10 ,

                Temperature Control
                Temperature management with central impression drum presses (which include most wide-
                web presses) equipped with UV curing equipment has been a challenge. Typically, some
                UV rays reflect off of the drum and heat it in the process.  When the press temperature is
                raised above the standard 32°C, the drum is vulnerable to warping. In addition, heat can
                damage some substrates, including films.                        -

                Adjusting the energy input to the curing lamps has been one approach to reducing press
                temperatures.  One study found that with most UV-cured  inks, smaller diameter bulbs
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                             cured the inks at the same rate but used significantly less energy and thus generated less
                             heat. In addition, specialized bulbs (e.g., D bulbs containing iron for pigmented inks and
                             V bulbs containing gallium for white inks) can reduce the required energy.11

                             Lowering ink viscosity also helps lower temperatures.  Viscous inks often require heating
                             in order to make the ink flow well.  Cationic inks, which generally are less viscous and
                             do not require heating, are a possible solution for printers faced with difficulties in heat
                             management.

                             Equipment suppliers are also improving power supply and ventilation systems used in
                             curing UV inks. Devices can be installed that allow for variable power supply; the press
                             operator can adjust the power so that only the minimum amount of energy is used to cure
                             the ink.  Heat can be removed more efficiently from the bulb and substrate surface by
                            making improvements in ventilation, such as improved lamp housing aerodynamics and
                            variable-speed blowers.12

                             Ultraviolet/Electron Beam (UV/EB) Hybrid Press
                            A combination of a  UV press with a final electron beam (EB) curing station is still
                            considered experimental, but might improve drying and reduce energy demands. An EB
                            curing station emits a higher energy wave than UV lamps, and therefore penetrates thicker
                            layers better.   Because EB lamps  cure  so  much more  thoroughly at the end,  the
                            intermediate UV lamps do not have to be as powerful, and fewer photoinitiator are needed
                            in the inks.13  It has been estimated that a UV/EB hybrid press consumes 35 percent less
                            energy and produces less heat.14  In addition, the UV/EB technology can be used with
                            porous substrates, which standard UV technology cannot since it does not thoroughly cure
                            ink on such substrates. Currently, the major limitation for UV/EB technology is the large
                            capital expenditure required for equipment. In addition, performance properties of the ink
                            might be altered.15

                            Remaining Technical Challenges
                            Despite the advances made during the past few years, several difficulties still remain with
                            UV technology.  One that is particularly evident in film applications is inadequate
                            adhesion. Much of the difficulty stems from the shrinkage that free radical UV-cured inks
                            undergo as they cure. Because shrinkage is less of an issue with cationic inks, further
                            development of cationic inks may help solve this problem.   Ink suppliers are also
                            developing free radical UV-cured inks with improved adhesion.

                           Another issue is the application of even ink layers. Historically, the thick viscosity of UV-
                           cured inks has created discontinuous ink layers and pinholing. The reduced viscosity of
                           current UV inks reduces pinholing but increases dot gain.16-17> 18

            4.4  SITE PROFILES

                           The site  profiles provide background information for each of the volunteer printing
                           facilities  that participated in the performance demonstrations. This section provides
                           information about each facility, as well as technical information about each press.

                           Table 4.31 summarizes the press  speed,  run time, and run  length for each of the
                           performance demonstration sites.
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                Table 4.31 Summary Information about the Performance Demonstration Sites
Site
1
2

3

4
5

6


7

8


9A
9B
10
11
nk
Water-based
Water-based

Water-based

Water-based
Solvent-based

UV


Solvent-based

UV


Water-based
Solvent-based
Solvent-based
UV
Substrate
OPP
LDPE
PE/EVA
LDPE
PE/EVA
OPP
LDPE
PE/EVA
LDPE
PE/EVA
OPP
LDPE
PE/EVA
LDPE
PE/EVA
OPP
OPP
OPP
OPP
LDPE
Average
press speed
(ft/min)b
430
403
403
218
430
450
400
400
344
354
344
450
—
262
262
262
425
415
600
400
Run time
(minutes)3
129
93
102
126
131
123
57
56
92
95
38
148
—
65
63
15
66
80
90
153
Run length (feet)
51,000
37,053
37,868
26,927
47,884
13,160
21,924
20,858
32,431
27,691
6,853
42,000
8,069
2,559
15,912
4,265
34,434
33,641
56,700
38,400
               1 Run time included changing of substrate rolls and getting the press back up to speed.
               b Based on the maximum speed attained during the run.
               Site 1: Water-based Ink #W2 on OPP

                            Table 4.32 Facility Background Information for Site 1

Ink type used
Control equipment
Annual production
Operating hours
Avg. production run

1 00% water-based
None
1.5 million pounds of clear and metallized polypropylene,
polyethylene, and polyester; cellophane and paper
flexographic-printed products
24 hours per day, 363 days per year
Four hours
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                   Table 4.33 Press Information for the Performance Demonstration at Site 1

Press
Size of press
Printing type
Typical production speed
Plates
Corona treater (yes / no)
Ink metering system
Type of doctor blade
Ink pumping and mixing
system

Amber Press, Central Impression
55 inches wide, eight-color
Reverse
500 feet/minute
0.067" Dupont EXL photopolymer:
1) Two process plates (magenta and
using 0.020 hard stick back
2) Three line plates (green, blue, and
using 0.020 hard stick back
cyan) mounted
white) mounted
Pillar, Model DB5673-16
Chambered
Steel
Peristaltic air pump, pumping from semi-covered five-
gallon buckets
                       Table 4.34  Color Sequence and Anilox Configurations for Site 1
Seauence
Deckl
Deck 2 — Not Used
DeckS
Deck 4
Deck 5 — Not Used
Decks
Deck 7 — Not Used
Deck 8
Color
Blue
—
Cyan
Green
—
Magenta
—
White

280
—
800
280
—
800
—
280

7.0
_
1.7
6.4
	
1.7
	
7.5
               lines per inch
               bbillion cubic microns per square inch
               Table 4.35 Summary Information from the Performance Demonstration at Site 1
Substrate
OPP
Press soeed
430 ft/min




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                                         4-56
                                                                        September 2000

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                                                                            PERFORMANCE
              Observations and Comments
              Due to site-specific circumstances, a surface ink was used for the blue in place of a reverse
              ink at the start of the run. The correct reverse ink was added to the surface ink in the ink
              pan after approximately 38,000 impressions.  While a press speed of 500 ft/min might
              have been possible with this press and ink, bounce on the white plate limited the maximum
              obtainable speed to 430 ft/min.  The bounce on the white plate occurred due to mounting.

              Overall, the makeready and demonstration run  were completed with no uncontrollable
              complications.  The printing problems encountered were considered normal and the press
              operators were easily able to adjust the printing environment to obtain the desired quality
              result and achieve production printing speeds and conditions.

              Site 2: Water-based Ink #W3 on LDPE and PE/EVA

                            Table 4.36  Facility Background Information for Site 2
Item
Ink type used
Control equipment
Annual production
Operating hours
Avq production run
Description
100% water-based
None
10,465,000 pounds of polyethylene flexographic-printed
products
24 hours per day, 363 days per year
Five hours, includinq makereadv
                   Table 4.37  Press Information for the Performance Demonstration at Site 2
Item
Press
Size of press
Printing type
Typical production speed
Plates
Corona treater
Ink metering system
Type of doctor blade
Ink pumping and mixing
svstem
Description
UTECO, Quarz 140
54 inches wide, six-color
Surface
500 feet/minute
0.107" Dupont EXL photopolymer:
1) Two process plates (magenta and
using Tessa hard stick back
2) Three line plates (green, blue, and
using Tessa hard stick back
cyan) mounted
white) mounted
Enercon
Chamber
Daetwyler 0.006
Peristaltic pump with air monitors in each five-gallon
bucket
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September 2000

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  CHAPTER4
                                                                              PERFORMANCE
                         Table 4.38 Color Sequence and Anilox Configurations for Site 2a
Sequence
Deck 1
Deck 2
Deck 3 - Not Used
Deck 4
Decks
DeckG
Color
White
Green
—
Magenta
Blue
Cyan
Anilox lpib
360
300
• —
360
280
360

5.05
6.90
—
5.13
6.00
4.90
                "Deck 1 (white ink) not used for the PE/EVA substrate
                blines per inch  •
                cbillion cubic microns per square inch
                 Table 4.39 Summary Information from the Performance Demonstration at Site 2
Substrate
LDPE
PE/EVA
Press speed
403 ft/min
403ft/min
Run time
93 minutes
102 minutes
Run lencith
37,053 feet
37,868 feet
               Observations and Comments
               LDPE
               Pinholing occurred in all colors, and the trap was poor. No blocking or apparent problems
               with dimensional stability  occurred.  The  pinholing and poor trap were considered
               acceptable and typical for this site. The press operator made minor impression adjustments
               in an effort to compensate for the pinholing.

               PE/EVA
               The green and blue samples taken at the beginning of the run failed the adhesiveness test,
               while the magenta and cyan passed.  The printing quality of all colors was poor, and the
               printing appeared dirty, but the lay was acceptable with no blocking.  The trap was
               variable depending on position across the web and impression.  There appeared to be no
               dimensional stability concerns.

               At the end of the run, the green and blue samples continued to fail the adhesiveness test,
               but the magenta and cyan samples passed with no failure or ink removed.  The printing
               still appeared to look dirty.  Trap was acceptable and lay was improved.

               Overall, the makeready and run were completed with no serious complications.  The
               printing problems encountered were considered normal for this site.
PUBLIC COMMENT DRAFT
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                                                                             September 2000

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CHAPTER 4
                                                                    PERFORMANCE
             Site 3: Water-based Ink #W3 on LDPE and PE/EVA




                         Table 4.40  Facility Background Information for Site 3
Item
Ink type used
Control equipment
Annual production
Operating hours
Avg. production run
Description
100% water-based
None
10 million pounds of flexographic-printed flexible packaging
products
24 hours per day, seven days per week
Eight hours including makeready
                 Table 4.41 Press Information for the Performance Demonstration at Site 3
Item
Press
Size of press
Printing type
Typical production speed
Plates
Corona treater
Ink metering system
Type of doctor blade
Ink pumping and mixing
system
Description
Faustel ,
50 inches wide, six-color
Surface
Not given
0.067" Polyfibron photopolymer plates:
1) Two process plates (magenta and cyan) mounted
using compressible stick back
2) Three line plates (green, blue, and white) mounted
using hard stick back
Enercon
Chambered doctor blade, except for white,
two-roll without doctor blade
which is a
Not given
Peristaltic air pump in five-gallon bucket
 PUBLIC COMMENT DRAFT
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September 2000

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 CHAPTER4
                                                                               PERFORMANCE
                         Table 4.42 Color Sequence and Anilox Configurations for Site 3a
Sequence
Deckl
Dsck 2
Deck3
Deck 4
Decks
Deck 6 - Not Used
Color
White
Magenta
Cyan
Green
Blue
—
Anilox lDib
300
500
500
240
240
—
Anilox BCM°
5.2
3.2
3.2
7.8
7.8
—
                 "Deck 1 (white ink) not used for the PE/EVA substrate
                 "lines per inch
                 °billion cubic microns per square inch
                 Table 4.43 Summary Information from the Performance Demonstration at Site 3
Substrate
LDPE
PE/EVA
Press speed
218ft/min
430 ft/min
Run time
126 minutes
131 minutes
Run length
26,927 feet
47 884 feet
               Observations and Comments
               LDPE
               Toward the end of the run, pinholing was evident in the blue and the green samples.
               Also, there was indication of ink drying on the edge of the magenta plate. The pinholing
               was considered minimal  and typical.  The  press operator made minor  impression
               adjustments to  compensate.  Trap and dimensional stability were not considered to be a
               factor in overall quality.

               PE/EVA
               The samples taken at the beginning of the run passed the adhesiveness test, although some
               light dusting occurred in the green and blue. No trap or dimensional problems occurred.
               Poor wetting of the green on white, and pinholing of the blue on white, were evident.

               At the end of the run, the cyan and magenta samples passed the adhesiveness test with no
               ink removed, but the green and blue failed.  The demonstration team noted that these two
               colors should be tested again later after they had more time to dry. When tested again, the
               blue passed the  adhesiveness test, but the green still failed. Increased pinholing was noted
               for both the green and the blue. Trap and dimensional stability were not considered to be
               a factor in overall quality.

               Overall, the makeready and demonstration run were completed with no uncontrollable
               complications.  The printing problems encountered were considered normal for this site.
PUBLIC COMMENT DRAFT
                                             4-60
                                                                             September 2000

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CHAPTER 4
                             PERFORMANCE
             Site 4:  Water-based Ink #W1 on OPP
                          Table 4.44 Facility Background Information for Site 4
Item
Ink type
Control equipment
Annual production
Operating hours
Avq. production run
Description
100% water-based
None
3 million pounds of polyethylene and polypropylene
flexographic-printed products
24 hours per day, five days per week
One week
                 Table 4.45 Press Information for the Performance Demonstration at Site 4
Item
Press
Size of press
Printing type
Typical production speed
Plates
Corona treater
Ink metering system
Type of doctor blade
Ink pumping and mixing
system
Description
Kidder Stacey
46 inches wide, six-color
Reverse
400 feet/minute
0.067" Dupont EXL photopolymer plates:
1) Two process plates (magenta and cyan) mounted
using Foam NY20 stick back with foam lining
2) Three line plates (green, blue, and white) mounted
using Foam NY20 stick back with foam lining
Enercon
Chambered
Unknown
Air powered pump from five-gallon buckets covered
with cardboard
                      Table 4.46 Color Sequence and Anilox Configurations for Site 4
Sequence
Deckl
Deck 2
DeckS
Deck 4
Deck 5 - Not Used
Deck 6
Color
Blue
Cyan
Green
Magenta
—
White
Anilox lpia
250
800
250
600
—
250
Anilox BCMb
6.1
2.2
6.8
2.7
—
6.3
               "lines per inch
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September 2000

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 CHAPTER4
                                                                            PERFORMANCE
                Table 4.47 Summary Information from the Performance Demonstration at Site 4
Substrate
OPP
Press speed
450 ft/mina
Run time
123 minutes
Run lenqth
13, 160 feet
                aThe press speed varied between 400 ft/min and 450 ft/min.
               Observations and Comments
               The press was initially ramped to 400 ft/min for the demonstration run. The speed was
               then increased to 450 ft/min, after 7,500 feet of film had been consumed. Press speed was
               later slowed to 435 ft/min,  and then to 415 ft/min for the last roll  of substrate due to
               drying concerns.

               During the run, the pinholing became worse for the green sample, and was also appearing
               hi all the other colors.  Both pinholing and plugging occurred in the blue.  The pinholing
               and contamination were considered minimal and typical for this site.  The press operator
               made minor impression adjustments to compensate during the run.  Trap and dimensional
               stability were not considered to be factors in overall quality.

               Site 5: Solvent-based Ink #S2 on LDPE and PE/EVA
                            Table 4.48 Facility Background Information for Site 5
Item
Ink type used
Control equipment
Annual production
Operating hours
Avg. production run
Description
100% solvent-based
Four catalytic oxidizers for nine presses
14 million pounds of polyethylene and polypropylene
flexographic-printed products
24 hours per day, six days per week
Two hours
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September 2000

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                                                                         PERFORMANCE
                  Table 4.49 Press Information for the Performance Demonstration at Site 5
Item
Press
Size of press
Printing type
Typical production speed
Plates
Corona treater
Ink metering system
Type of doctor blade
Ink pumping and mixing
system
Description
Windm6ller & Holscher, Central Impression
24 inches wide, six-color
Surface
400 feet/minute
0.107" Dupont EXL photopolymer:
1) Two process plates (magenta and cyan) mounted
using compressible stick back
2) Three line plates (green, blue, and white) mounted
using hard stick back
None
Enclosed doctor blade
Stainless steel
Closed-loop, air-powered
                      Table 4.50 Color Sequence and Anilox Configurations for Site 5a
Sequence
Deckl
Deck 2 - Not Used
DeckS
Deck 4
DeckS
DeckS
Color
.White
—
Green
Blue
Magenta
Cyan
Anilox Ipi"
300
—
240
240
550
550
Anilox BCM°
6.2
—
4.2
4.2
2.0
2.0
               aDeck 1 (white ink) was not used for the PE/EVA substrate.
               blines per inch
               °billion cubic microns per square inch
                Table 4.51 Summary Information from the Performance Demonstration at Site 5
Substrate
LDPE
PE/EVA
Press speed
400 ft/min
400 ft/min
Run time
57 minutes
56 minutes
Run length
21 ,924 feet
20,858 feet
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September 2000

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 CHAPTER 4
                                 PERFORMANCE
               Observations and Comments
               LDPE
               Some slight plate contamination was evident in the blue sample.  Minor pinholing was
               apparent in the green sample. The pinholing and contamination were considered minimal
               and typical. The press operator made minor impression adjustments to compensate. Trap
               and dimensional stability were not considered to be a factor in overall quality.

               PE/EVA
               The samples taken at the beginning of the run passed the adhesiveness test, with no trap
               or dimensional problems. The  lay was acceptable and tones appeared clean and open in
               the light end highlights.  At the end of the run, the samples passed the adhesiveness test
               with no failure of ink removed. There were, however, some slight problems with solid
               formation, which may have been related to impression. The tones were beginning to plug
               in the light end highlights. The press team suggested that the ink drying speed was fast.
               Trap  and dimensional stability were not considered to be a factor in overall quality.

               Overall, the makeready  and demonstration run were completed with no uncontrollable
               complications. The printing problems encountered were considered normal and the press
               operators were easily able to adjust the printing environment to obtain the desired quality
               result.

               Site 6:  UV Ink #U2 on LDPE, PE/EVA, and OPP

                            Table 4.52 Facility Background Information for Site 6
Item
Ink type used
Control equipment
Annual production
Operating hours
Avg. production run
Description
60% solvent-based inks, 35% water-based inks, and
5% UV inks
Charcoal adsorption
8 million pounds of polyethylene, polypropylene, and paper
flexographic-printed products
24 hours per day, 4.5 days per week
Six to eight hours
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September 2000

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                                                                            PERFORMANCE
                   Table 4.53 Press information for the Performance Demonstration at Site 6
Item
Press
Size of press
Printing type
Production speed
Plates
Corona treater
Ink metering system
Type of doctor blade
Ink pumping and mixing
svstem
Description
Cobden Chadwick
32 inches wide, six-color
Surface and reverse
250 to 350 feet/minute
0.107" Dupont EXL photopolymer:
1) Two process plates (magenta and cyan) mounted
using 0.020 compressible stick back
2) Three line plates (green, blue, and white) mounted
using 0.020 hard stick back
Q.C. Electronics
Chambered
Unknown
ARO, model 65736-003, air-powered
, with diaphragm
                        Table 4.54 Color Sequence and Anilox Configurations for Site 6a
Seauence
Deckl
Deck 2
DeckS
Deck 4
DeckS
Deck 6 — Not Used
Color
White
Magenta
Cyan
Green
Blue
—
Anilox loib
250
600
600
360
360
—
Anilox BCMC
7.5
2.8
2.8
4.7
4.7
—
                aDeck 1 (white ink) not used for the PE/EVA substrate
                blines per inch
                °billion cubic microns per square inch
                 Table 4.55 Summary Information from the Performance Demonstration at Site 6
S u bst rst©
LDPE
PE/EVA
OPPb
Press speed
344 ft/mina
354 ft/min
344 ft/min
Run time
92 minutes
95 minutes
38 minutes
Run length
32,431 feet
27,691 feet
6.853 feet
                aPress speed was averaged between the two rolls (337 ft/min and 351 ft/min).
                "The run was aborted due to sample failure of the adhesiveness test and overheating of the chill
                roller.
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September 2000

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  CHAPTER4
                                                                               PERFORMANCE
                Observations and Comments
                LDPE
                Some slight plate contamination and minor pinholing were evident in the white.  The
                pinholing and contamination were considered minimal and typical.  The press operator
                made minor impression adjustments to compensate.   Although there  was still some
                wrinkling of the substrate noted, trap was not considered to be a factor in overall quality.

                PE/EVA
                The samples taken at the beginning of the run revealed that the ink lay was good, but the
                print quality appeared dirty.  These problems were also noted on the samples taken at the
                end of the run.  It was also noted that the density of the magenta had increased during the
                run, and the attempts to reduce it were unsuccessful.  Trap and dimensional stability were
                not considered to be a factor in overall quality.

                Samples taken  at the beginning  of the run failed the  adhesiveness test in all colors.
                Adhesiveness tests were performed on samples taken mid-run, at which time the green and
                blue both passed, but the other colors failed.  By the end of the run, all colors again failed
                the adhesiveness test  except cyan.

                OPP
                The samples taken at the beginning of the run failed the adhesiveness test. The white
                appeared to have low opacity, evidence of pinholing, and the print quality appeared dirty.
               The other colors appeared to have good printability with fair trap.  No major problems
               with dimensional stability or blocking were noted; however, heat from the lamps caused
               wrinkles to form.

               The  main (final) UV lamp was overheating the chill roller during the run,  and  the
               demonstration team decided that the chill roller was not functioning properly.  The
               temperature of the chill roller was 155°F, and the chill roller was smoking. The decision
               was made to abort the run, and no samples were taken for measurement or analysis.

               Site?: Solvent-based Ink #S2 on LDPE and PE/EVA

                             Table 4.56  Facility Background Information for Site 7
Item
Ink type used
Control equipment
Annual production
Operating hours
Ava. production run
Description
100% solvent-based
Two-unit catalytic oxidation
10 million pounds of oriented polypropylene flexographic-
printed products
24 hours per day, five days
weekend
per week plus every other
60 to 60,000 pounds
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                                                                             September 2000

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                                                                         PERFORMANCE
                  Table 4.57 Press Information for the Performance Demonstration at Site 7

Press
Size of press
Printing type
Typical production speed
Plates
Corona treater
Ink metering system
Type of doctor blade
Ink pumping and mixing
Description
Kidder
45.5 inches wide, six-color
Surface
500 feet/minute
0.067" Dupont FAH photopolymer:
1) Two process plates (magenta and cyan) mounted
using 0.20 compressible stick back
2) Three line plates (green, blue, and white) mounted
using 0.20 compressible stick back
None
Chamber
Unknown
Greymill, electric
                       Table 4.58 Color Sequence and Anilox Configurations for Site 7a

Deckl
Deck 2 — Not Used
DeckS
Deck 4
DeckS

Color
White
—
Cyan
Magenta
Green
Blue
Anilox I0ib
200
—
700
700
500
500

8.5
—
2.0
2.0
4.0
4.0
                aDeck 1 (white ink) was not used for the PE/EVA substrate
                blines per inch
                °billion cubic microns per square inch
                 Table 4.59 Summary Information from the Performance Demonstration at Site 7

LDPE


450 ft/min

Run time
148 minutes
—
Run length
42,000 feet
8.069 feet
                aThe run was aborted due to problems with the substrate.
  PUBLIC COMMENT DRAFT
                                            4-67
September 2000

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             CHAPTER 4
                                                                                        PERFORMANCE
                           Observations and Comments
                           LDPE
                           The printing quality of the tones and the lay of the inks were acceptable.  The trap was
                           very good, and no blocking occurred.  No problems with dimensional stability were noted.

                           PE/EVA
                           It was intended that the PE/EVA substrate also be run at this location.  The substrate was
                           mounted on the press, and the "makeready check" was begun. After only 8,069 feet of
                           film were consumed, the run was aborted.  The demonstration team decided that the roll
                           of substrate they were running was not the correct project control film, due to a supplier
                           mix-up.  In addition, the substrate had wrinkles from poor extrusion, the cores were not
                           the correct size, and the cores were crushed.
                                                                                         i

                           No samples were taken from the PE/EVA run, and no measurements were made.

                           Site 8: UV Ink #U3 on LDPE, PE/EVA,  and OPP

                                        Table 4.60 Facility Background Information for Site 8
                           Item
Description
                           Ink type used
                           Control equipment
                           Annual production
                           Operating hours
This facility is a press manufacturing facility in Germany; it is
not a commercial printing facility. Therefore, no production
data are available.
                           Avq. production run
                           Table 4.61 Press Information for the Performance Demonstration at Site 8
Item
Press
Size of press
Printing type
Production speed
Plates
Corona treater
Ink metering system
Type of doctor blade
Ink pumping and mixing
system
Description
Windmoller & Holscher, Soloflex
2
25 inches wide, four-color
Surface and reverse
450 feet/minute
0.067" Dupont photopolymer:
1) Two process plates (magenta
unknown
2) Three line plates (green, blue,
unknown
and cyan), mounting
and white), mounting
Kalwar
Chambered
Steel
Air-powered
           PUBLIC COMMENT DRAFT
_
                                                       4-68
                                                                                       September 2000

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                                                                              PERFORMANCE
                        Table 4.62  Color Sequence and Anilox Configurations for Site 8a

Deck 1 - PE/EVA
Deck 1 - LDPE, OPP
Deck 2
DeckS
Deck 4
Color
Magenta
White
Green
Blue
Cyan
Anilox lpib
724
200
724
724
724

4.5
8.4
4.5
4.5
4.5
                aDeck 1 changed between PE/EVA and LDPE because this site used only a four-color press.
                blines per inch
                cbillion cubic microns per square inch
                 Table 4.63 Summary Information from the Performance Demonstration at Site 8

LDPE
PE/EVA


262 ft/min
262 ft/min

Run time
65 minutes
63 minutes
15 minutes
Run lenqth
16,643 feet
15,908 feet
4.264 feet
                 aThe run was aborted due to sample failure of the adhesiveness test and the discoloration of
                 the OPP to a greenish tint.
 Observations and Comments
                The performance demonstration at Site 8 was conducted on a press manufacturer's pilot
                line, which was not a commercial printing press.

                LDPE
                The samples taken at the end of the run failed the adhesiveness test.  The printing appeared
                dirty in the solid areas of the blue ink, but the other colors had good printability.  The trap
                was good. No problems with dimensional stability were noted, and there was no evidence
                of blocking.

                PE/EVA
                Dirty printing was more evident in the blue solid area on the end of run samples, and the
                green was also starting to appear dirty.  The tones were inspected for cleanliness and
                transfer.  Trap and dimensional stability were not considered to be a factor in overall
                quality.

                OPP
                At the end of the run, the samples failed the adhesiveness test. The printing appeared dirty
                in the blue solid area, and was beginning to  appear dirty in the green as well. The visual
                quality of the other  colors was good. Trap was acceptable, there was  no blocking, and
                there were no  problems with dimensional stability.  During this run, the OPP  substrate
                turned a  greenish tint.  It is believed that the UV lamps caused a photo-reaction in the
                substrate.
  PUBLIC COMMENT DRAFT
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September 2000

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                                                                            PERFORMANCE
               Site 9A:  Water-based Ink #W4 on OPP
                            Table 4.64  Facility Background Information for Site 9A
                Item
Description
                Ink type used
100% water-based
                Control equipment
None
                Annual production
300 million linear feet
                Operating hours
Two 12-hour shifts per day
                Avg. production run
8 to 12 hours
                  Table 4.65  Press Information for the Performance Demonstration at Site 9A
                Item
                                           Description
                Press
                                           Kidder Stacey
                Size of press
      45.5 inches wide, eight-color
                Printing type
      Reverse
                Typical production speed
      500 feet/min
                Plates
      0.067" Dupont PQS photopolymer:
      1) Two process plates (magenta and cyan) mounted
        using 3M 1020, 0.020 compressible stick back
      2) Three line plates (green, blue, and white) mounted
        using 3M 1020, 0.020 compressible stick back
               Corona treater
     Enercon
               Ink metering system
     Chamber
               Type of doctor blade
     White steel
               Ink pumping and mixing
               system	
     Powerwise, air-powered
'UBLIC COMMENT DRAFT
                                          4-70
                                                                          September 2000

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CHAPTER4
                                                                          PERFORMANCE
                      Table 4.66 Color Sequence and Anilox Configurations for Site 9A

Deck 1 — Not Used
Deck 2
DeckS
Deck 4 — Not Used
DeckS
Deck6
Deck 7 - Not Used


—
Blue
Cyan
—
Magenta
Green
—

Anilox lDia
—
400
550
—
550
400
— .
300


4.0
2.7
—
2.7
4.0
—
5.5
                alines per inch
                bbillion cubic microns per square inch
                    Table 4.67 Summary Information from the Performance Demonstration
                                                at Site 9A




Run time
66 minutes

34.434 feet
               Observations and Comments
               The samples taken at the end of the run revealed good printability, good trap, no problems
               with dimensional stability, and no blocking.  Overall, the makeready and demonstration
               run were completed with no uncontrollable complications.


               Site 9B: Solvent-based Ink #S1 on OPP


                            Table 4.68 Facility Background Information for Site 9B
                 Item
                                      Description
                 Ink type used
                   100% water-based
                 Control equipment
                   None
                 Annual production
                   300 million linear feet
                 Operating hours
                   Two 12-hour shifts per day
                 AVI
g. production run
                                      8 to 12 hours
  PUBLIC COMMENT DRAFT
                                             4-71
                                                          September

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  CHAPTER4
                                                                            PERFORMANCE
                 Table 4.69 Press Information for the Performance Demonstration at Site 9B
                 Item
                                            Description
                 Press
                                            Kidder Stacey
                 Size of press
45.5 inches wide, eight-color
                 Printing type
 Reverse
                 Typical production speed
500 feet/min
                 Plates
                                            0.067" Dupont PQS photopolymer:
                                            1) Two process plates (magenta and cyan) mounted
                                              using 3M 1020, 0.020 compressible stick back
                                            2) Three line plates (green, blue, and white) mounted
                                              using 3M 1020, 0.020 compressible stick back
                Corona treater
None
                Ink metering system
Chamber
                 Type of doctor blade
White steel
                Ink pumping and mixing
                system	
Powerwise, air-powered
                       Table 4.70 Color Sequence and Anilox Configurations for Site 9B

Deck 1 - Not Used
Deck 2
Deck3
Deck 4 — Not Used
Decks
Deck 6
Deck 7 - Not Used
Decks
Color
—
Blue
Cyan
—
Magenta
Green
—
White

—
400
550
—
550
400
—
• 300

	
4.0
2.7
—
2.7
4.0

5 5
                alines per inch
                "billion cubic microns per square inch
                    Table 4.71 Summary Information from the Performance Demonstration
                                                at Site 9B

OPP
Press speed
415 ft/min
Run time



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CHAPTER4
                                                                           PERFORMANCE
              Observations and Comments
              Site 9B is normally a 100% water-based ink facility.   Facility staff agreed to do a
              demonstration run with solvent-based inks on OPP for this project. Overall, the makeready
              and demonstration run were completed with no uncontrollable complications. The samples
              taken at the end of the run revealed good  printability,  good trap, no problems with
              dimensional stability, and no blocking.

              Site 10: Solvent-based Ink #S2 on OPP

                            Table 4.72 Facility Background Information for Site 10

Ink type used
Control equipment
Annual production
Operating hours'


100% solvent-based
One thermal oxidizer for three presses
10.5 million pounds — 95% medium-density polyethylene
(MDPE), 5% low-density polyethylene (LDPE)
24 hours per day, 5 days per week, plus 25 Saturdays

                   Table 4.73 Press Information for the Performance Demonstration at Site 10
                 Item
                =^=
                Press
Description
         ^^
Paper Converting Machine Company, model 7067
                Size of press
61 inches wide, eight-color
                Printing type
                                            Reverse
                Typical production speed
750 to 850 feet/minute
                 Plates
0.107" BASF photopolymer:
1) Two process plates (magenta and cyan) mounted
   using 3M 1120 compressible stick back
2) Three line plates (green, blue, and white) mounted
   using 3M 939 hard stick back	
                 Corona treater
                                             None
                 Ink metering system
 Chambered — two-blade
                 Type of doctor blade
 Unknown
                 Ink pumping and mixing
                 system      	
 Powerwise, Underwriters Laboratory, electric, 5 hp,
 3450 rpm. 115 to 230 volts
  PUBLIC COMMENT DRAFT
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   CHAPTER 4
                                                                              PERFORMANCE
                         Table 4.74  Color Sequence and Anilox Configurations for Site 10
                  Deck 2
                                           Green
                                                               250
                                                                                  9.8
                  DeckS
                                            Blue
                                                               250
                                                                                  10.1
                  Deck 4
                                           Cyan
800
                                                                                  1.75
                 Deck 5 - Not Used
                 Deck6
                                          Magenta
800
                                                                                  1.6
                 Deck 7 — Not Used
                 Deck 8
                 'lines per inch
                 bbillion cubic microns per square inch
                     Table 4.75  Summary Information from the Performance Demonstration
                                                  at Site 10
                                Press speed
                                --      ' •
                                600 ft/min
               Observations and Comments
               This site normally prints LDPE, but agreed to print the OPP with a reverse ink system
               The samples taken at the end of the run showed poor solid formation in the magenta with
               all other colors having good printability. The magenta also appeared weak, attributed to
               high amlox line count and low volume.   Trap and dimensional stability  were not
               considered to be factors in overall quality.

               Overall, the makeready and demonstration run were completed with no uncontrollable
               complications.  The printing problems encountered were considered normal and the press
               operators were easily able to adjust the printing environment to obtain the desired quality
               result.                                                                  n   J
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                                            4-74
                                                                            September 2000

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CHAPTER4
                                                                         PERFORMANCE
              Site 11:  UV Ink #U1 on LDPE (no slip)

                           Table 4.76 Facility Background Information for Site 11

Ink type used
Control equipment
Annual production
Operating hours
Avq. production run

80 to 85% water-based, 15 to 20% UV
None
50 million pounds of polyethylene flexographic-printed
products
24 hours per day, five days per week
Three hours to two weeks H
                  Table 4.77 Press Information for the Performance Demonstration at Site 11
                                           Description
                Press
                                           UTECO, Amber 808
                Size of press
                                           61 inches wide, ten-color
                Printing type
                                           Surface
                Production speed
820 feet/minute
                Plates
0.107" Dupont EXL photopolymer:
1) Two process plates (magenta and cyan) mounted
  using compressible stick back
2) Three line plates (green, blue, and white) mounted
  using hard stick back	
                Corona treater
                                           None
                Ink metering system
                                           Chambered
                Type of doctor blade
Unknown
                Ink pumping and mixing
                system
Arrow, air-powered, diaphragm
   PUBLIC COMMENT DRAFT
                                             4-75
                                 September 2000

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  CHAPTER 4
                                                                              PERFORMANCE
                         Table 4.78  Color Sequence and Anilox Configurations for Site 11
                 Deck4-Not Used
                 Decks
                                            Cyan
                   500
                                                                                  2.7
                 Deck6
Green
                                                               360
                                                                                  5.6
                 Deck 7 - Not Used
                 DeckS
                                            Blue
                   360
                                                                                  5.6
                 Deck 9 — Not Used
                  billion cubic microns per square inch
                 Table 4.79 Summary Information from the Performance Demonstration
                                                  at Site 11

LDPEa
Press soeed
400 ft/min




                aThe LDPE was extruded with no-slip additives.
               Observations and Comments
               This site chose to print its normal production LDPE substrate instead of the DfE-control
               LDPE. This site-standard LDPE substrate was extruded with no slip additives. Overall,
               the makeready and demonstration run  were  completed with  no  uncontrollable
               complications.  The printing problems encountered were considered normal and the press
               operators were easily able to adjust the printing environment to obtain the desired aualitv
               result.                                                                       J

               The samples taken at the end of the run continued to show good printability in all colors
               with continued blade streaking in the cyan.  Dry ink was continually evident on the blue
               anilox roll.  Trap and dimensional stability were not considered to be factors in overall
               quality.
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                                            4-76
                                                                            September 2000

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CHAPTER 4
                                                                          PERFORMANCE
REFERENCES

1.
       Schilstra, Durk. "UV Flexo: The European Situation." American Ink Maker, March 1997: 52-
       55,
 2.     Podhajny, Richard M. "UV Flexo - Still Growing, Still Facing Challenges." Paper Film Foil
       Converter, June 1998: 64, 66-67.
 3.

 4.

 5.
 7.
        Schilstra, 1997, op. cit.
        Atkinson, David. "Cationic UV Flexo, An Alternative for Wide-web Film Printing?" Proc. of
        RadTech Europe 97. 16-18 June 1997, Lyon, France: 373-377.

        Schilstra, 1997, op. cit.
        Midlik, Elinor R. "FQC UV Wide Web Committee Prepares for the Year 2002." Flexo May
        1997: 150-153.
        Otton, Dan. "Advancements in UV Ink Technology." Flexo April 1997: 58-59.

 8.     Scheraga, Dan. "Energy Curing Shows Promise in Productivity, Lower Emissions." Chemical
        Market Reporter April 27, 1998: 32.
. 9.     Lawson, Kenneth. "Status of the North American UV/EB Market." Industrial Paint & Powder
        Nov. 1996:22-25.

  10.    Scheraga, 1998, op. cit.
  11.    Zinnbauer, Fred E. "Basking in the Sun With Cool UV." Flexo Aug. 1998: 64-67.

  12.    Ibid.
  13     Gentile, Deanna. "Ink Outlook: Steady Growth and Evolving Technologies." Paint and
         Coatings 86(1996): 40-42.
  14.    Teng, Andy. "Flexo Report." Ink World May/June 1996: 70.

  15.    Ibid.
  16.    Otton, 1997, op. cit.

   17.    Lawson,  1996, op. cit.

   18.    Atkinson, 1997, op.  cit.
   PUBLIC COMMENT DRAFT

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   CHAPTER 4
                                                                    PERFORMANCE
                            This page is intentionally blank.
PUBLIC COMMENT DRAFT
                                      4-78
                                                                 September 2000

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 CHAPTER 5
                                                                             COST
                               Chapter 5i Cost
                             CHAPTER CONTENTS


1 5.1 DEVELOPMENT OF COSTS
       Material Costs
       Labor Costs
       Capital Costs for New Presses
       Capital Costs for Retrofitting a Press
       Energy Costs ........... •
       Uncertainties

1 5.2 COST ANALYSIS RESULTS
       Summary of Cost Analysis Results
       Discussion of Cost Analysis Results

1 5.3 DISCUSSION OF ADDITIONAL COSTS ............................................ ^
       Regulatory Costs ............ ............................................... 5_25
       Insurance and Storage Requirements  ...........................................  "
       Other Environmental Costs and Benefits .........................................


REFERENCES [[[ • .............

                                                                                5-27
IADDITIONAL REFERENCES  [[[

                                   INTRODUCTION

ILis chanter presents a comparative cost analysis of solvent-based, water-based and UV-cured  ink


  systems "and ^theavaSSyofda^^
  the actual experience of any given printing facility.




  costs.








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   CHAPTER 5
                                                                                        COST
                           >: Section 5.2 summarizes the overall costs based on the expense cateqories
                          /stem and by ink-substrate combination. The analysis shows the relative costs
                    and also indicates the cost drivers within each system.  Detailed results of the cost
                    I in Appendix 5-B.


 [DISCUSSION OF ADDITIONAL COSTS: Section 5.3 discusses costs that often are often hidden from
  typical accounting analyses but that can affect company profits. These include regulatory co^lsurance
 [and storage costs, and costs related to worker health and natural resource use.             insurance


                                 HIGHLIGHTS OF RESULTS

      Material costs (ink and additives) and capital costs were the two most significant expense
      categories.  Each accounted for approximately 40% of the costs considered in this analysis

      ^n^nSdhLnck^had *h! I?™,63! material costs Water-based inks were consumed at a lower rate
      than solvent-based ink and had a lower per-pound cost than UV-cured inks
      Labor costs were lowest for solvent-based inks at the observed press speeds primarily because
      solvent-based inks were printed at the fastest speeds.  When labor costs were'calculated  for the
      methodology speed, labor costs were equal across the three ink systems
      Water-based inks had the lowest per-hour capital costs, because the presses did not  require
      poHuton control equ.pment or UV curing lamps. However, solvent-based inks had the lowest pe!
      image capital costs because of the higher observed press speeds.

      !Hatlerrhoa^d ',!lk;!-?ad.the '°West energy costs' The primary reason for tnese lower costs is that
      water-based inks did not require pollution control equipment or UV curing lamps.
      «     ,. --*--•-—-links were the least expensive to use. Solvent-based inks were the next least
                        y UV-cured inks.
                                         CAVEATS


                         D3Sed °" b?h the °bserved press sPeeds and the methodology press speed
              t        r P!TS Spe,6d 'S Cmdal t0 COSt estimates because if more Product can be printed
     H «,         '    n ^ C°StS (e'9" Capital and labor) are distributed across more salable product
     costsm^yL^lfferS        3
                         "
                   n    •               ° not rePresent al1 expenses encountered at a flexographic
                 K ?"? S|9n'^ant factorthat was excluded was substrate (the material, such as film Sat
             )- SubstratesareamaJ°r expense, but because theircosts are independen of the fnks/stem
     Fnir   ^  m?oded ,"! the analysiS- °ther costs'  such  as  those discussed qualitativeHn
     Environmental and Regulatory Costs, also are not included in the quantitative results qua"iaweiy
     Assumptions in this analysis may not apply to all facilities.  For example, it was assumed that pollution
     control equipment is not necessary with water-based ink systems. In some locations ox dize^s in fact
     may be required if inks exceed regulatory minimum VOC content thresholds       OXICM2ers In fac*
PUBLIC COMMENT DRAFT
                                            5-2
                                                                            September 2000

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CHAPTER 5
                                                                                         COST
5.1 DEVELOPMENT OF COSTS
               This section discusses the categories of costs that were analyzed for the different ink
               systems, formulas that were used in calculations, and assumptions that were made. This
               information will allow the reader to understand the basis for the results that are described
               in the next section.

               The primary sources of data were the performance demonstrations and estimates provided
               by flexographic printers and suppliers. The model facility used in the risk assessment
               section was also used for the cost analysis. Model facility assumptions were based on
               averages of the information reported hi the questionnaire completed by each performance
               demonstration site.  A detailed methodology of the cost analysis is in Appendix 5-A.
        Material Costs
               The material costs estimated in this analysis are inks and additives.  Representative
               substrate costs are also presented in this section to give a fuller picture of printing costs,
               but substrate is not included in the rest of the analysis because during production, its costs
               do not vary among ink systems.  The specific prices that any given printer pays for
               materials are expected to vary with the volume purchased and the relationship between
               printer and supplier.

               Ink Costs
               Ink prices vary with the type of ink (solvent-based, water-based, or UV-cured) and color.
               Generally  speaking, white inks are  least expensive, primary colors are slightly more
               expensive, and other colors or custom colors are most expensive.

               For this analysis, one price was estimated for white ink and one for the other four colors.
               These ink prices are listed hi Table  5.1.  It is important to note that these are average
               prices, and the price that a printer pays may be either higher or lower than those presented
               here.
                                          Table 5.1 Average Ink Prices3
Solvent-based ($/lb)
White
Other colors
$1.40
$2.80
Water-based
($/lb)
$1.60
$3.00
UV-cured
($/lb)
$7.25
$10.00
                a Based on November 1998 prices.
                Source: References 1, 2, 3, 4, 5, 6, 7, 8, 9,10, 11,12, 13.
                To determine ink consumption costs, the ink prices were multiplied by the amount of ink
                used for each performance demonstration run. In addition, the test image dimensions and
                repeat length were used in the calculations.  Information about the test image is presented
                below. The repeat length indicates the distance from the beginning of an image to the
                beginning of the first repetition of the image.
  PUBLIC COMMENT DRAFT
5-3
                                                                                  September 2000

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  CHAPTER 5
                                                                                           COST
                 Test Image Information
                 Line colors: blue, green, and white
                I Process colors: cyan and magenta
                 Image dimensions: 16 inches x 20 inches (320 sq. inches or 2.22 sq. feet)
                 Repeat length: 16 inches (1.33 feet)
                The ink costs per 6,000 images and per 6,000 ft2 of image were calculated using the
                following formulas:

                    Ink cost per 6,000 images          = I x 2.22 ftVimage  x 6,000 images
                    Ink cost per 6,000 ft2 of image     = I x 6,000 ft2
                where
                    I    -  ink price ($/lb) x amount of ink used (Ib) / amount of substrate used (ft2)
                        =  ink cost per ft2 ($/ft2)
                Tables 5.2 and 5.3 present the average ink costs for each ink-substrate combination per
                6,000 images and per 6,000 ft2 of image, respectively.  The site-specific ink costs and a
                sample calculation are provided in Appendix 5-B. Both ink and ink additives are included
                in the average costs, and a detailed table providing site-specific consumption data is
                provided in Appendix 6-A.

                Additive Costs
                In most of the performance demonstration runs, additives were mixed with the inks to
                achieve and maintain desired viscosity and performance. Specifically, extenders, solvents
                and/or water were added to the solvent-based and water-based inks.  Also, ammonia^
                reducers, cross-linkers, and/or defoamers were added to the water-based inks, and acetate
                was added to one solvent-based ink (Site 10). No additives were used in the UV-cured ink
                performance demonstrations, with the exception of a low-viscosity monomer added to the
                green ink at one site (Site 11).

                The methodology for estimating ink additive costs was similar to that for inks. Based on
                input from printers and suppliers, the  Dffi team determined average prices for each
               additive.1-3-13-14 Extender was $2.00/lb, solvent Was $1.00/lb, water was given no charge,
               and other solvent- and water-based ink additives were $0.45/lb.  A price for the  UV
               additive (monomer) was not  determined,  because ink manufacturers state  that extra
               monomer is not typically added to UV ink at press side.    '

               The additive costs per 6,000 images and per 6,000 ft2 of image were calculated using the
               same formulas as for the normalized ink costs.

               The estimated average  ink additive costs for each ink-substrate combination also  are
               presented in Tables 5.2 and 5.3.  The  site-specific ink 'additive costs are provided in
               Appendix 5-B.
PUBLIC COMMENT DRAFT
                                              5-4
                                                                               September 2000

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                                                                      COST
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                                                            =  .
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w.2 
-------
  CHAPTERS
                                                                       COST
PUBLIC COMMENT DRAFT
                                    5-6
                                                              September 2000

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CHAPTERS
                                                                                          COST
               Substrate Costs
               Substrate costs are a function of the price of the substrate and the amount of substrate
               used.  Based on input from printers and suppliers, an average price was determined for the
               three types of substrate used in the performance demonstrations — LDPE, PE/EVA, and
               OPP.   Table 5.4 presents the  substrate prices, the conversion factors used to convert
               square feet of substrate to pounds, and the substrate costs. The substrate costs per 6,000
               images and per 6,000 ft2 of image were calculated using the following formulas:
                   Substrate cost per 6,000 images
                   Substrate cost per 6,000 ft2 of image
                                 =  S x 2.22 ft2/image X 6,000 images
                                 =  S x 6,000 ft2
               where

                   S
= substrate price ($/lb) x conversion rate (lb/ft2)
= substrate cost per ft2 ($/ft2)
                      Table 5.4 Average Substrate Costs and Conversion Rates (ft2 to Ibs)
Substrate
LDPE
PE/EVA

Price
($/Ib)
$0.77
$0.82

Conversion
rate (lb/ft2)
0.0134
0.0258
0.0072
Substrate
cost per ft2
($/ft2)
$0.01
$0.02
$0.01
Average cost
per 6,000
images
$138
$282
$144
Average cost
per 6,000 ft2 of
image
$62
$127
$65
                Sources: References 2, 3, 5, 7, 9, 10, 11, 12, 13, 15, 16.
                Substrate costs are not included in the cost analysis.  The price of substrate can be quite
                variable and therefore would  introduce additional uncertainty to the analysis.  Also,
                because substrate consumption does not vary by ink system, it does not need to be included
                in comparisons between systems.  Average substrate costs are supplied above, however,
                to provide a.more complete tally of total costs a printer might encounter.
         Labor Costs
                For this cost analysis, labor costs are primarily a function of printers' compensation rates
                and the time it takes to print the product.  Labor rates include the wage rate of a press
                operator and one assistant, the fringe rate,  and the overhead rate.  This cost analysis
                assumes that labor rates do not vary with the ink system or the substrate.

                Wage Rate
                Industry sector-specific wage rates are typically available from the U.S. Department of
                Labor; however, obtaining an average flexographic industry labor rate was complicated
                by the fact that the flexographic industry sector is combined with other printing sectors in
                SIC 2759. To obtain a wage rate indicative of the industry sector, an average hourly wage
                rate for the industry of $11.49-" was used as a baseline and confirmed by performance
                demonstration site contacts in 1997.2,4,5,7,11,12,15,18
  PUBLIC COMMENT DRAFT
                                                 5-7
                                                           September 2000

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   CHAPTER 5
                                                                                           COST
                 Fringe Rate
                 The average press operator or assistant received fringe benefits of holidays, vacations, sick
                 leave, supplemental pay (premium pay for overtime work on weekends and holidays,'shift
                 differentials, and non-production bonuses such as lump-sum payments provided in lieu of
                 wage  increases), insurance  benefits  (life, health, sickness, and accident), and legally
                 required benefits (Social  Security).  In private industry,  blue-collar workers  had an
                 average fringe rate of 26.5% of total compensation.19 Total compensation of $15 63 per
                 hour includes a fringe rate of $4.14 per hour.

                 Overhead Rate                       t
                 The overhead factor for the flexographic  industry was calculated using the  following
                 formula:                                                                       6

                    Overhead factor = (overhead costs) / (direct labor)

                    Overhead costs  = Rent and heat + fire and sprinkler insurance + indirect labor +
                                      direct supplies  +  repair to equipment  +  general factory  +
                                      administrative and selling overhead


                Using data from the flexographic industry and the above formula, the average industry
                overhead factor was 0.41, or an overhead rate of $6.41/hour. For a detailed look at how
                the overhead rate was calculated, see Appendix 5-A.

                Based on the wage, fringe, and overhead rates listed in Table 5.5, the overall labor rate
                for each worker was $22.04 per hour, or $44.08 per hour for both a press operator and
                assistant.
                                 Table 5.5 Summary of Labor Rate Calculations
Labor cost component Calculation
Wage rate from industry estimates
Fringe rate 26.5% of total compensation3
Overhead rate 0.41 times total compensation3
Total per-worker labor rate
Rate ($/hr)
$11.49
$4.14
$6.41
$22.04
                 Total compensation equals wage plus fringe.
               Total Labor Cost
               To calculate the total labor cost, the labor rate was multiplied by the average amount of
               time generally needed to print 6,000 images and 6,000 ft2 of image (based on press speed)
               This simplified calculation omits makeready and clean-up costs.  The labor cost estimates
               were calculated using the following formulas:

                  Labor cost per 6,000 images       =  L x 2.22 fWimage x 6,000 images
                  Labor cost per 6,000 ft2 of image   =  L X 6,000 ft2
PUBLIC COMMENT DRAFT
                                              5-8
                                                                               September 2000

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CHAPTER;
                                                                                         COST
               where

                  L  ='  labor rate ($/hour) x repeat length per ft2 of image (ft/ft2) / press speed
                          (ft/hour)
                      =  labor cost per ft2 ($/ft2)  '

               Assuming an average press speed for a flexographic  press was extremely difficult.
               Variables such as the test image, the age of the press, the desired quality of the product,
               and the skill of the press operator affect the press speed considerably. The performance
               demonstration methodology dictated a press speed of 300 to 500 feet per minute (fpm).
               Therefore,  the site demonstratio'ns were not illustrative of the potential of a press for a
               specific ink system.  Presses may have been held back from or pushed beyond their
               optimal running speeds.  Using the typical production speed of the press reported by the
               facility was not realistic because of the variety of product quality. For example, one site
               ran at 700 fpm and produced a low quality product whereas another site ran at 350 fpm
               and produced a very high quality product. Finally, few data exist that support an industry
               average press speed for each ink system.

               The cost analysis used the average press speed from  the performance demonstrations
               (Table 5.6) for each ink type to determine labor and  capital costs.  The parenthetical
               numbers in the first row indicate the number of demonstration runs on which the data are
               based.


                   Table 5.6  Average Press Speed Data from the Performance Demonstrations

Average feet per minute
Average feet per hour
Solvent-based
453 (6)
27,200
Water-based
394 (7)
23,600
UV-cured
340 (4)
20,400
                Table 5 7 presents average labor costs for each ink system using the average observed
                press speed and  the  methodology  press speed (500  feet per minute).  When the
                methodology press  speed  is used, the labor costs were neutralized for the  three ink
                systems. When the average observed press speeds are used, the labor cost is lowest for
                solvent-based inks (i.e., these ran at  the fastest press speeds during the demonstrations).
                Compared to solvent-based inks, the labor cost for water-based inks was 15 % higher, and
                the labor rate for UV-curable inks was 33% higher.  The site-specific labor costs and a
                sample calculation are provided in Appendix 5-B.
   PUBLIC COMMENT DRAFT
                                                5-9
Septet

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  CHAPTER 5
                                                                                           COST
                                  Table 5.7  Labor Costs Based on Press Speeds
Ink
Labor
rate
($/hr)
Press
speed
(ft2/hr)
Labor cost
perftz($/ft2)
Average cost
per 6,000
Average cost
per 6,000 ft2 of
Based on Observed Performance Demonstration Press Speeds
Solvent-based
Water-based
UV-cured
$44.08
$44.08
$44.08
45,300
39,400
34,000
$0.000973
$0.00112
$0.00130
$12.96
$14.90
$17.27
$5.84
$6.71
$7.78
Based on Methodology Press Speed- 500 Feet per Minute
Solvent-based
Water-based
UV-cured
$44.08
$44.08
$44.08
50,000
50,000
50.000
$0.000882
$0.000882
$0.000882
$11.74
$11.74

$5.29
$5.29

        Capital Costs for New Presses

                Capital costs are those costs associated with purchasing or modifying the equipment. Two
                scenarios were examined:  buying a new press outfitted for a specific ink technology and
                retrofitting an existing press from one ink technology to another.

                The data used for capital costs were acquired from press manufacturers, suppliers, and
                flexographic printers.   The capital  costs  were  not gathered at the performance
                demonstration sites due to the variances in the ages of the presses and, therefore, in the
                representativeness of the costs.

                The capital cost of a new press included the cost of a base press plus any modifications
                required for each ink system.  The base press was assumed to be an eight-color, 48-inch
                press.  The cost for a base press also included installation.  The cost of a new base press
                ranged   from  $600,000   to  $5  million,  with  an  average  cost  of  about  $2 5
                million.9-10-13-14-16-17-20 The base press cost included the cost of the following:

                   •   chambered doctor blades
                   •  peristaltic ink pumps
                   •   chill rollers
                   •  covered ink/water rollers
                   •  forced hot air dryers (between-color and overhead final)
                   •  electrical drive
                   •  in-feed devices
                   •  ink agitators
                   •  rewind unit
                   •  roll stands/reels
                   •  water union
                   •  web break detectors
                   •  press  installation
                   •   one-week training
PUBLIC COMMENT DRAFT
                                              5-10
                                                                                September 2000

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CHAPTER 5
                                                                                          COST
               The exception to the above list is that a UV press will not require hot air dryers; the base
               price  for  a UV press  therefore would be  reduced to reflect the absence  of this
               approximately $100,000 equipment.21  All other equipment modifications specific to the
               ink systems were added to the base press cost.  These costs included the cost of pollution
               control devices which might have been required if solvent-based inks were used,  the cost
               of UV lamps, etc. A summary of the capital costs is presented in Table 5.8, followed by
               a more detailed discussion of each ink system.

                              Table 5.8 Summary of Capital Costs for New Presses
Ink
Solvent-based
Water-based
UV-cured
Base press
cost ($)
$2.5 million
$2.5 million
$2.4 million
Additional Components
pollution Control
corona treater
corona treater, UV lamps,
power supplies, and
cooling units
Additional
cost ($)
$128,000
$25,000
$200,000
Total capital
cost ($)
$2.6 million
$2.5 million
$2.6 million
               Solvent-based Ink Presses
               The primary additional equipment expense in running solvent-based ink is an oxidizer
               needed for pollution control.  The analysis assumed that an "average" wide web facility
               has four 48" presses and two catalytic oxidizers, with an air flow of 5,800 cubic feet per
               minute (cfm) to each oxidizer.  The cost estimates, based on these characteristics, are
               shown in Table 5.9.

                                       Table 5.9  Catalytic Oxidizer Costs3
                                Component
                                                                    Cost
                        Oxidizer
                        Installation

                        Testing
                   $200,000

                    $50,000

                 $5,000-$6,000
                        Total
                   $255,000
                        aThese costs represent an oxidizer serving two presses. The per-press costs
                        used in the analysis are half of these amounts.
                        Source: References 22 and 23.

                Because each  oxidizer is  assumed in this analysis to control the emissions from two
                presses, this cost is spread over two presses.  Therefore, the cost of a pollution control
                system per press is expected to be $128,000.  This cost may vary depending on facility-
                specific variables, such as  the location of the oxidizer, duct runs, location in the country,
                and whether the duct is insulated.14

                An alternative type of oxidizer is the regenerative thermal oxidizer (see Chapter 7 for
                details).  The cost of purchasing, installing, and testing this system is similar to  that of a
                catalytic oxidizer. During operation, it may result in lower costs because the catalyst does
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                 not need to be replaced.  Including the cost of either type of oxidizer, a press using a
                 solvent-based ink system was estimated to cost $2.6 million.

                 Water-based Ink Presses
                 A new water-based press will come equipped with all necessary equipment, with the
                 exception of a corona treater. A corona treater costs approximately $25,000,24 resulting
                 in a total cost estimate of $2.5 million for a press using a water-based ink system.

                 UV-cured Ink Presses
                 The primary cost for UV-cured ink presses is the UV curing system.  The equipment
                 consists of lamps, power supplies, cooling units, and a corona treater.  According to a
                press manufacturer,  this  equipment costs approximately $200,000 for a wide web
                flexographic printing press.20 This resulted in an estimate of $2.6 million for a press using
                a UV-cured ink system.

                Total Capital Costs for New Presses
                To incorporate capital costs into this cost analysis, the capital costs were annualized (and
                calculated on an hourly basis) per 6,000 images and per 6,000 ft2 of image. The annual
                expense can be translated into an hourly expense by dividing by the annual operating
                hours.

                The annual cost was determined by a present-worth-to-annuity calculation, as follows:
                   A  =  annual capital cost
                   T  =  total cost (price of press)
                   i   =  interest or depreciation rate
                   n   =  lifetime of equipment

               The average annual industry depreciation rate was 15% per year,25 and the estimated
               lifetime of a press not subject to a substantial modification or upgrade is 20 years.21 The
               hourly capital cost estimates were based on the following calculation:
                   Capital cost per 6,000 images
                   Capital cost per 6,000 ft2 of image
                              C x 2.22 fWimage x 6,000 images
                              C X 6,000 ft2
               where
                   C   =
                   and
capital cost per ft2 ($/ft2)
hourly capital cost ($/hr)  x repeat length per ft2 of image (ft/ft2) / average
press speed (ft/hr)
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                  Depreciation rate
                  Annual operating hours
                  Hourly capital cost ($/hr)
=   15%
=   4,200 hours per year
=   A ($/yr) / annual operating hours (hr/yr)
=   A ($/yr) / 4,200 hours per year
               Table 5.10 presents the hourly capital costs of each ink system.
                           Table 5.10 Capital Costs for New Presses

Capital cost
($)
Hourly
capital cost
($)
Cost per ft2
of image
Based on Observed Performance Demonstration Press Speeds
Solvent-based
Water-based
UV-cured
$2.6 million
$2.5 million
$2.6 million
$98.90
$95.10
$98.90
$0.00218
$0.00241
$0.00291
Based on Methodology Press Speed - 500 Feet per Minute
Solvent-based
Water-based

$2.6 million
$2.5 million
$2.6 million
$98.90
$95.10
$98.90
$0.00198
$0.00190
$0.00198
Cost per
6,000
images

$29.08
$32.15
$38.75

$26.35
$25.33
$26.35
6,000 ft2 of
image

$13.10
$14.18
$17.45

$11.87
$11.41
$11.87
        Capital Costs for Retrofitting a Press

               Alternatively a printer may retrofit an existing press for a new technology rather than
               purchase a new press.  The feasibility and costs of a retrofit need to be addressed on a
               case-by-case basis, because retrofitting costs can vary considerably depending on the age
               and type of press. The newer the press, the fewer and easier the changes. For example,
               most newer presses come equipped with diaphragm or peristaltic ink pumping systems and
               chambered doctor blades.   This analysis presents possible  capital costs that may be
               incurred for a retrofit; if newer equipment such as that mentioned above were present, the
               retrofit process would be less expensive.

               In this analysis, retrofit costs included only the additional costs of equipment. The labor,
                training, and downtime costs associated with a retrofit were not included because these
                costs are highly variable and situation-specific.   This analysis assumed a retrofit on an
                older, six-color, 48-inch press.  The following cost estimate of the equipment necessary
                for the change to a new ink system was developed from discussions with printers who have
                changed ink systems and from  discussions  with manufacturers and  suppliers who are
                familiar with the changes.

                Solvent-based to Water-based Ink System
                A retrofit from an older solvent-based ink system to a water-based ink system may require
                some of the following equipment changes depending on the age of the press:16

                    •   reconfiguring anilox rolls
                    •   adding chambered doctor blades
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                    •   adding diaphragm or peristaltic ink pumping systems
                    •   adding a corona treater and auxiliary corona treating material
                    •   adding or retrofitting existing blowers to increase the blowing capacity
                    •   changing plate materials and  mounting

                Estimates to retrofit from a solvent-based to water-based ink system on a 48-inch press are
                in the range of $60,000 to $100,000.9  While a solvent-based  ink system press can run
                water-based ink on well-treated  film and at much  lower  speeds without a retrofit,
                retrofitting improves substrate wettability and/or increases drying capability.3

                Solvent-based to UV-cured Ink System
                A retrofit from a solvent-based to a UV-cured ink system  requires similar equipment
                changes to those required for a retrofit from a solvent-based ink system to a water-based
                ink system.  The changes required for this retrofit may include the following:16

                    •   buying and installing UV-cured lamps and the power units to support the lamps
                    •   purchasing and installing chillers to cool the equipment
                    •   reconfiguring anilox rolls
                    •   adding chambered doctor blades
                    •   adding diaphragm or peristaltic ink pumping systems
                    •   adding a corona treater and auxiliary corona treating  material
                    •   changing plate materials and mounting

                Retrofits from a solvent-based to UV-cured ink system are estimated to be in the range of
                $400,000 to $500,000.9  Given this cost, most printers would probably purchase a new
                press rather than retrofit an existing one.  In addition, many older flexographic printing
                presses cannot be  retrofitted for  UV production.9-14   While the major equipment
                requirements are listed above, additional engineering or "tinkering" may be necessary to
                obtain the product quality required.  Many flexographic printers,  manufacturers, and
                suppliers do not believe this kind of retrofit can produce a saleable product. '•3-10-13-26

                Water-based to UV-cured Ink System
                In retrofitting a press from a water-based to UV-cured ink system, the following equipment
                changes are necessary:16

                   •  adding UV lamps and power units
                   •  removing blowers
                   •  adding chillers
                   •  possibly adding plate materials

               On a six-deck press,  retrofit  costs are expected to be roughly $30,000 per deck, or
               $180,000.5  Water-based ink systems  cannot always be retrofitted for  UV production.
               Many flexographic printers, manufacturers, and suppliers do not believe this kind of
               retrofit can produce a saleable product with an older press, although many new presses are
               being manufactured with retrofits in mind.1-3'10-13'26

               UV-cured to Water-based Ink System
               Although retrofitting from a UV-cured to a water-based ink system is not common,  one
               site using UV decided to return to a water-based system.  The equipment changes included
               removing the UV lamps, power equipment, and chillers, and adding blowers.  If the press
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               had originally been a solvent- or water-based press, then the blowers would simply need
               to be re-installed, at a cost of approximately $32,000.5 If the press had been purchased
               for a UV-cured ink system, it would be necessary to purchase and install a dryer system,
               which is estimated to cost approximately $100,000.21

       Energy Costs

               The energy use for four types of flexographic printing equipment—hot air drying systems,
               catalytic oxidizers, corona treaters, and UV curing systems—was estimated for the three
               ink systems  (see Chapter  6: Energy and  Resource Consumption).  Energy costs were
               calculated using the energy consumption rates for this equipment and national averages of
               electricity and natural gas  costs.  Given the typical size and total sales of a flexographic
               printing facility, an average electricity cost of $0.0448/kWh27 and an average gas cost of
               $3.14/million Btu28 were used; however, these figures can vary substantially depending on
               the location and size of the facility.

               To calculate energy costs, electricity and natural gas consumption figures were taken from
               Chapter 6.  Energy costs per 6,000 images and 6,000 ft2 were then calculated with the
               following equations:

                   Energy cost per 6,000 images      =  (E  + G) x 2.22  ft2/image x 6,000 images
                   Energy cost per 6,000 ft2 of image  =  (E  + G) x 6,000 ft2
               where

                   E
                   G  =
electricity, cost ($/kWh) x [electricity consumption (kWh/hour) / press speed
(ft/hour)] x repeat length per ft2 of image (ft/ft2)
electricity cost per ft2 ($/ft2)

natural gas cost ($/Btu) x [natural gas consumption (Btu/hour) / press speed
(ft/hour)] x repeat length per ft2 of image (ft/ft2)
natural gas cost per ft2 ($/ft2)
        Uncertainties
                Efforts were made to obtain data as representative of the industry as possible. However,
                differences in the ink systems may have had further cost implications that were not
                captured in the data.  Some of the differences may have been difficult to capture in the
                time span of a two-hour run, may not have been easily quantifiable, or may have been too
                minute to identify given the methodology and testing. When interpreting the results of this
                analysis and applying them to a particular operation, the following uncertainties should be
                considered.

                Ink Maintenance
                The print run conditions may affect the level of ink maintenance more significantly than
                was demonstrated at the volunteer sites. UV inks do not dry on anilox rolls or other rolls
                and hence the color strength remains constant; in addition, during multi-day runs the
                number of cleanups can be reduced. Using solvent-based  inks and water-based inks can
                increase the amount of labor, run time, clean-up, and waste because of the need to add or
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                remove ink multiple times during a run.  These differences, which make UV more
                competitive, are not reflected in the cost figures due to difficulties in their quantification.

                Productivity
                Productivity, was  another area that was  not effectively captured in the  performance
                demonstrations. The performance demonstration methodology specified a printing run at
                the rate of 300 to 500 fpm. Some sites, however, had to slow down their runs to increase
                drying times,  whereas other  sites  increased  their press speeds  for some runs.   For
                example, at Site 10, the press speed was 600 fpm due to the facility's standard operating
                procedures. The data do not shed light on the controversial issue of whether one ink can
                be run faster than the others while producing a product quality that is better or comparable
                to that of the other inks.                            '

                Makeready Variables
                The experience of the press operators and the type and age of the press have a greater
                influence on the makeready time than does the type of ink.  This is because the main
                concerns in makeready are registration and the print impression. The amount of substrate
                used in makeready and the time required for makeready are based on the ability of the
                press operator to adjust color and viscosity. However, industry experience indicates that
                proper color strength can be achieved fastest with UV inks.

                Clean-up and Waste Disposal Costs
                Clean-up and disposal practices were observed qualitatively for the three ink systems at
                the performance demonstration sites.   During  the performance demonstrations,  the
                following cleaning agents were used for each ink type:

                   •   Solvent-based ink: alcohol or alcohol/acetate blend
                   •   Water-based ink: water, or water/ammonia/alcohol blend
                   •   UV-cured ink:  alcohol, alcohol/acetate blend, or alcohol/water/soap blend

                Appendix 6-A presents more detailed information for each site, and Section 6.5, Clean-up
                and Waste Disposal Procedures, provides more information on these procedures.

               Differences in the clean-up components among the three ink systems include the following:

                   •  The materials are least expensive for water-based inks.
                   •  The type of press is a major factor  in how long it takes to clean.
                   •  UV presses can be shut down overnight or for extended periods of time without
                      clean-up procedures. If covered, the inks will not cure in the wells, so the press
                      can be started up with minimal ink  preparation.
                   •  Solvent-based ink waste is the most expensive to dispose of because it is often
                      characterized as hazardous waste. Water may or may not require the same costs,
                      depending on the solvent content of the ink and location of the facility. UV waste
                      disposal costs may be substantially lower for two reasons: the wastes often are not
                      designated as hazardous under RCRA, and less waste is generated by UV.

               Clean-up and waste disposal costs were not included in the quantitative analysis, however,
               because it was not possible to calculate reliably the costs associated with these procedures.
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              Site-Specific Limitations
              Each printing site was  unique, which created some challenges  for the performance
              demonstration. For some of the sites, specific questions or data points were not applicable
              because of the ink system, the type of site, insufficient data, or the failure of a test run.
              For these situations,  inconsistencies were identified, the data were omitted, or reliable
              follow-up information was substituted from phone interviews with printers.

              Although most of the sites  were actual printing facilities, one UV site was a press
              manufacturer  in Germany.  The press  used at this site was a demonstration version and
              was not used to print saleable product.  As a result, the data from this site did not contain
              annual or plant-wide costs. Information on clean-up, waste disposal, and ink and substrate
              costs also was not available.  In addition, the makeready at this site was completed before
              the observation team arrived at the site. Therefore,  the makeready data for the time and
              feet run were  not observed by the team.

              Another performance demonstration site (Site 11) used a different substrate than specified
               in the methodology.  Demonstrations  run at this site used LDPE that was extruded with
               no slip additives, in accordance with the facility's standard procedure.


 5.2 COST ANALYSIS RESULTS

               This section presents the results of the cost analysis for each ink-substrate combination.
               This analysis can help the reader to compare costs among solvent-based, water-based, and
               UV-cured ink systems.  Site-specific cost information is shown  in Appendix 5-B.

        Summary of Cost Analysis Results

               Table 5.11 presents an overall summary of the costs per 6,000  images and per 6,000 ft2
               of image, broken out by substrate and ink type.  Table 5.12 provides an average cost
               breakdown of four major cost elements (materials, excluding substrate; labor; capital for
               a new press; and energy costs). Table  5.13 presents cost summaries for each performance
               demonstration site.  These costs do not include substrate, makeready or clean-up.

               For each substrate, water-based inks were the least expensive.  Solvent-based inks were
               slightly more expensive  than water-based inks (1% more for LDPE, 36%  more for
               PE/EVA and 9% for OPP), and UV-cured inks were the most expensive (29% more than
               water-based  inks on LDPE, 46% more for PE/EVA).  When the figures are calculated
               based on the methodology press speed, water would again be the least expensive. Solvent-
               based inks would cost 31 % more, and UV 39 % more than water-based inks. The numbers
                in parentheses in Table 5.11 indicates the number of performance demonstration runs on
                which the data are based.
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                           Table 5.11  Cost Summary for Ink-Substrate Combinations

Solvent-based
Cost per
6,000
images
Cost per
6,000 ft2
of image
Water-based
Cost per
6,000
images
Cost per
6,000 ft2
of image
UV-cured
Cost per
6,000
images
Cost per
6,000 ft2
Based on Observed Performance Demonstration Press Speeds
LDPE
PE/EVA
OPP
$92 (2)
$80 (1)
$72 (2)
$42 (2)
$36(1)
$32 (2)
$91 (2)
$59 (2)
$66 (3)
$41 (2)
$26 (2)
$30 (3)
$117(2)
$86 (2)
$53 (2)
$39 (2)
n/aa
Based on Methodology Press Speed - 500 Feet per Minute
LDPE
PE/EVA
OPP
$85
$72
$72
$38
$33
$32
$62
$52
$59
$28
$24
$27
$103
$57
$46
$26
n/aa
                n/a = not appncaoie; there were no successful runs of UV-cured ink on OPP in the performance
               demonstrations.
               As shown in Table 5.12, material and capital costs (excluding substrate) accounted for the
               majority of costs.  Averaged across the eight ink-substrate combinations, materials (ink
               and additives) represented 38% of the costs, and capital costs were 41% of the total.
               Labor accounted for 14% to 24% of the total cost, and energy accounted for 1 % to 4%.

               Several factors affect press speed, including labor, equipment, and handling.  However,
               because the differing press speeds observed during the performance demonstrations may
               cause a misrepresentation of the comparative  costs associated with  the different ink
               systems, the costs were also calculated based on the methodology speed of 500 fpm. If
               all three ink systems had been run at the methodology speed, the labor cost differences and
               some capital cost differences would have been neutralized.  Water-based inks would still
               have been the least expensive. Solvent-based inks would have been more expensive than
               water-based inks (39% more for LDPE, 38% more for PE/EVA, and 22% for OPP). UV-
               cured inks would have been the most expensive on LDPE (66% more  than water-based
               inks on LDPE),  but would no longer have been the most expensive on PE/EVA (10%
               more than water-based inks, but 21 % less than solvent-based inks).

               Table 5.13 presents a cost summary for each performance demonstration site. A detailed
               breakdown of costs for each site is provided in Appendix 5-B.
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Isl ini IL.l\\/ 	 	 	 . 	 	 	 	 	 	 	 	 : 	
Table 5.12 Cost Breakdown for Ink-Substrate Combinations
If

Substrate
_DPE


PE/EVA
OPP
Ink
Solvent-based
(2 sites)



Water-based
(2 sites)



UV-cured
(2 sites)

Solvent-based
(1 site)
Water-based
(2 sites)
UV-cured
(2 sites)
Solvent-based
(2 sites)
Water-based
(3 sites)

Component
materials
abor
capital
energy
total
materials
labor
capital
energy
total
materials
labor
capital
energy
total
materials
labor
capital
energy
total
materials
labor
capital
energy
total
materials
labor
capital
energy
total
materials
labor
capital
energy
total
materials
labor
capital
energy
total
Average cost
per 6,000
imaqes
$46
$14
$31
$1
$93
$24
$21
$45
$1
$91
$63
$16
$36
$3
$117
$34
$14
$31
$1
$81
$13
$14
$30
$1
$59
$19
$20
$44
$4
$86
$32
$12
$27
$1
$73
$22
$14
$29
$1
$66
per 6,000 ft2 of
imaqe
$21
$6
$14
$1
$42
$11
$9
$20
$1
$41
$28
$7
$16
$1
$53
$15
$6
$14
$1
$37
$6
$6
$14
<$1
$26
$8
$9
$20
$2
$39
$14
$5
$12
$1
$33
$10
$6
$13
<$1
$30
Percent
of total

15%
34%
2%
100%
26%
23%
49%
2%
100%
53%
14%
30%
3%
100%
42%
17%
39%
2%
100%
22%
24%
52%
2%
100%
22%
23%
51%
4%
100%
44%
17%
37%
2%
100%
34%
21%
44%
1%
100%
n/aa
              a n/a = not applicable; there were no successful runs of UV-cured ink on OPP in the performance
              demonstrations.
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                       Table 5.13  Cost Summary for Each Performance Demonstration Site
Substrate
LDPE
PE/EVA
OPP

Ink
Solvent-based
Water-based
UV-cured
Solvent-based
Water-based
UV-cured
Solvent-based
Water-based


UV-cured
Product
Line
#S2
#W3
#U1.
#U2
#S2
#W3
#U2
#U3
#S1
#S2
#W1
#W2
#W4
Site
5
7
2
3
11
6
5
7
2
3
6
8
9B
10
4
1
9A
Cost per
$102
$82
$73
$109
$123
$111
$89
$106
$64
$53
$83
$89
$76
$67
$71
$66
$61
Cost per 6,000
$46
$37
$33
$49
$56
$50
$40
$26
$29
$24
$37
$40
$36
$31
$32
$30
$27
n/aa
               a n/a = not applicable; there were rio successful
               demonstrations.
          runs of UV-cured ink on OPP in the performance
        Discussion of Cost Analysis Results

               Material Costs
               Material costs comprised ink and additive costs. Table 5.14 presents these costs.  Because
               no white ink was used on PE/EVA (a white substrate), ink costs for PE/EVA were the
               lowest.

               A significant difference among the three ink systems was the cost of ink.  For example,
               for the performance demonstration runs on LDPE, water-based inks cost an average of
               $19.19 per 6,000 images, whereas solvent-based inks cost an average of $32.16 (68%
               more than water-based inks) and UV-cured inks cost an average of $40.82 (113% more
               than water-based inks).  The high price per pound of UV inks contributed to their higher
               cost,  in spite of their lower rate of use per unit of substrate.

               Differing ink consumption rates also affected costs. Several factors could have  affected
               consumption rates.   Solvent-based ink evaporates more readily, thereby requiring the
               periodic addition of press-side solvent. (An average of 4.61 pounds ($4.61) of press-side
               solvent were required per 6,000 images during the performance demonstrations). Solvent-
               based inks also have a lower solids content; therefore, to deliver an equivalent amount of
               pigment  to the substrate, a greater volume of ink is required.  The surface tension of
               solvent-based inks is lower, and therefore  more ink is transferred from the anilox roll
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              given similar anilox roll volumes.  Finally, the anilox rolls can dictate the amount of ink
              consumed; rolls with more  volume than necessary may  lead to artificially high ink
              consumption rates.
      Table 5.14 Summary of Average Material Costs from the Performance Demonstrations
===
Substrate
===
LDPE
PE/EVA
OPP
.
Ink
=======
Solvent-based
Water-based
UV-cured
Solvent-based
Water-based
UV-cured
Solvent-based
Water-based
UV-cured
Average ink costs
per
6,000
images
$40.15
$23.22
$62.79
$29.83
$12.78
$18.85
$26.51
$21.58
per
6,000 ft2
of image
'~
$18.08
$10.41
$28.24
$13.44
$5.72
$8.50
$11.92
$9.70
%of
total
—
88%
96%
100%
89%
98%
100%
84%
97%
Average additive costs
per
6,000
images
$5.61
$0.86
a
$3.78
$0.23
$0.00
$5.11
$0.58
per
6,000 ft2
of image
— —
$2.53
$0.39
a
$1.70
$0.10
$0.00
$2.31
$0.27
%of
total
=====
12%
4%
0%
1%
2%
0%
2%
3%
Total
per
6,000
images
$45.76
$24.09
$62.80
$33.61
$13.01
$18.85
$31.62
$22.16
per
6,000 ft2
of image
$20.61
$10.80
$28.24
$15.14
$5.82
$8.50
$14.23
$9.97
There were no successful runs of UV-cured ink on OPP m the performance
 aUV ink manufacturers state that extra monomer is typically not added to UV ink; the printer for this demonstration run
 did add monomer.  The cost of this monomer is not known.
               Labor Costs                                                              .
               The differences in labor costs among the three ink systems were inversely proportional to
               press speed (i.e., the higher the press speed, the lower the cost).  Table 5.15 presents a
               summary of average labor costs from the performance demonstrations. Site-specific labor
               costs and press speeds can be found in Appendix 5-B. Because most of the demonstrations
               were run between 340 and 450 fpm, the labor costs  do not vary much among the
               demonstration sites.  The sites that ran at slower press speeds (Site 3 at 218 fpm and Site
                8 at 262 fpm) had higher labor costs for their respective ink-substrate combinations (water-
               based ink on LDPE and UV-cured on PE/EVA). Conversely, solvent-based ink on OPP
               had the lowest average labor cost, because Site 10  ran at  600 fpm.  These data do not
                reflect qualitative issues,  such as the fact that UV typically requires less  press-side
                adjustment and monitoring.  These issues may also affect press availability.
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                                                                                         COST
                 Substrate
                 LDPE
                                Table 5.15 Summary of Average Labor Costs from
                                        the Performance Demonstrations
                                Solvent-based
per 6,000
 images
  :==
   $13.88
per 6,000
  ft2 of
 image
   —-
    $6.25
                          Water-based
per 6,000
 images
  	
   $20.77
per 6,000
  ft2 of
 image
    —-   -
    $9.35
                                                                               UV-cured
per 6,000
 images
  	
   $15.89
per 6,000
  ft2 of
 image

    $7.15
                 PE/EVA
   $13.88
    $6.25
                                                      $14.13
                                      $6.36
                                     $19.52
                                                                                         $8.78
                 OPP
   $11.98
                demonstrations.
                                            $5.39
              $13.52
                                              successful runs of UV-cured ink on OPP in the performance
                Capital Costs
                Table 5.16 presents capital costs  for each ink system.  Capital  cost data from the
                performance demonstrations were not used, due to the variety and ages of the presses
                Instead, the capital costs used in this analysis were based on estimates from suppliers and
                printers, and also based on average press speeds from the performance demonstrations
                A sample calculation is provided in Appendix 5-A.

                The differences in capital costs were primarily due to the press speeds (i.e., the higher the
                press speed, the lower the cost).   As a result, the solvent-based pr.ess was the least
                expensive ($29.08 per 6,000 images).  The water-based and UV presses were 11 % and
                33% more expensive, respectively, than the solvent-based press.  At the methodology
                speed, capital costs for a water-based press would be the least expensive.  A UV press
                would be approximately 4% more expensive and a solvent press would be approximately
                8% more expensive.

               While both new press and retrofit scenarios are presented in this chapter, only the new
               press scenario was used in the aggregate cost analysis.  However, capital costs would be
               reduced if existing equipment were retrofitted. If a water-based ink press were retrofitted
               from a solvent-based ink press, instead of purchasing a new press, the total cost for using
               water-based inks (per 6,000 images or per 6,000 sq. feet of image) could  be reduced
               approximately 12%. If a UV press were retrofitted from a solvent-based or water-based
               press, the total cost for using UV-cured inks could be reduced approximately 10%
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                                                                             September 2000

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CHAPTERS
                                                                                       COST
                             Table 5.16 Estimated Capital Costs for New Presses

Cost per 6,000 images

Based on Observed Performance Demonstration Press Speeds
Solvent-based (5 sites)
Water-based (7 sites)
-UV-cured (4 sites)
$29.08
$32.15
$38.75
$13.10
$14.48
$17.45
Based on Methodoloav Press Speed - 500 Feet per Minute
Solvent-based (5 sites)
Water-based (7 sites)

$26.35
$25.33
$26.35
$11.87
$11.41
$11.87
               Energy Costs
               Table 5.17 presents energy costs for each ink system. Energy data from the performance
               demonstrations were not used due to the lack of data.  The energy costs used in this
               analysis were based on estimates from suppliers and printers, as well as average press
               speeds from the performance  demonstrations.  A  sample calculation  is provided in
               Appendix 5-B, and details about energy consumption are included in Chapter 6, Resource
               and Energy Conservation.  Energy costs were a minor factor in overall costs, averaging
               47% of the total cost across the eight ink-substrate combinations. Water-based inks were
               the least expensive;  energy  costs were 24%  and  220% higher for  solvent and UV,
               respectively.  At the methodology speed, water-based inks again would have the lowest
               energy costs.  Solvent-based inks would be 52% higher, and UV-cured inks would be
               190% higher than water-based inks.  Energy costs for  UV are particularly  high both
               because the curing lamps require substantial levels  of energy, and because all energy is
               required in the form of electricity.  For water- and solvent-based inks, the dryers can be
               fueled by natural gas, which is considerably less expensive on a per energy unit basis.
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                                                                                         COST
                       Table 5.17  Estimated Energy Costs for Each Ink System
                                                             Average
                                                          natural gas costs
Average electricity costs
                            images I of image
   Based on Observed Performance Demonstration Press Speeds
            Solvent-based
                                                                                $0.91    $0.4
                           There were no successful runs of UV-cured ink on OPP in
                           demonstrations.
                                                the performance
  Based on Methodology Press Speed - 500 Feet per Minute
 5.3 DISCUSSION OF ADDITIONAL COSTS

               This section discusses major categories of financial costs and benefits that are associated
               with environmental regulations, pollution prevention opportunities, and environmental
               practices - items that are often not projected or tracked in conventional  accounting
               measures. It is intended to help the reader focus on additional types of costs that could be
               useful in an environmental analysis of a flexographic printing operation.

               Many environmental costs are obvious, such as purchasing an oxidizer to reduce VOC
               emissions to levels dictated by air regulations.  There are also  less obvious costs- for
               example, an inefficient process that creates waste means that a  company is  paving for
               excess raw materials.

        Regulatory Costs

               As indicated in Chapter 2, several regulations may impact costs for flexographic printers
               Compliance may require a capital investment in equipment, such as treatment and control
               systems,  monitoring  devices,  laboratory  facilities,  safety equipment,  or  ongoing
               monitoring of a system. Regulated wastes may require additional expenditures for on-site
               storage, hauling, and off-site treatment and disposal. New systems may require additional
               personnel and may increase energy use. Additional personnel may be needed to run the
               equipment, analyze wastes, label and handle the wastes, and maintain the paperwork for
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                                                                             September 2000

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CHAPTER 5
                                                                                        COST
               permitting and reporting.
               discussed in Chapter 2.
Some of the relevant federal laws and requirements  are
               Also, various state and local regulations may increase flexographic printing costs.  For
               example, printing facilities using water-based inks may be required to install an oxidizer
               in some states, whereas in other states they may not be required to do so. Also, wastes
               from water-based inks may or may not be regulated as hazardous material, depending on
               the formulation.

               Non-compliance with environmental regulations may lead to additional costs. Companies
               that are not in compliance may face the following direct and indirect costs.

                   •    fines levied by regulatory agencies
                   •    legal, costs
                   •    property damage  and remediation costs
                   •    increased workers' health insurance and compensation
                   •    decreased sales due to negative publicity

        Insurance and Storage Requirements

               Concrete insurance costs  could not be quantified in the performance demonstration runs.
               However,  solvent-based  inks,  in general,  require  additional insurance due to  their
               explosive potential and additional storage requirements.

               Anecdotally, in a project  to reduce ink and cleaning waste for flexographic printers, one
               facility reported savings in insurance premiums  from switching to water-based inks and
               an aqueous cleaner.  The project compared the volume and toxicity of air emissions and
               liquid wastes produced by the printing processes before and after switching to water-based
               inks and an aqueous cleaner, and then determined  the economics  of  such processing
               changes. The facility saved about $500 per year due to lowered insurance premiums based
               on improved working conditions.29

         Other Environmental Costs and Benefits

                Benefits from sound environmental practices can often impact areas other than production
                and the environment.  Sick days taken by employees  may be decreased (and morale
                improved)  by reducing  or eliminating  hazardous compounds in the workplace.   The
                company's relationships  with customers, insurers, investors, and the community can be
                improved by gaining a reputation as a firm that is dedicated to environmental commitment
            "	°  beyond minimal regulatory compliance.

                Many environmental costs and benefits are not solely environmental; utility costs may be
                categorized as overhead or production costs, and greater profits may result from increased
                efficiency  and improved morale.  More efficient use of raw materials will also lead to
                 greater profits.  An analysis of the environmental costs  may yield  a more accurate
                 accounting of a company's expenses and reveal opportunities for cost reduction.
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                                                                                         COST
   REFERENCES


   1.      Argent, Dave.  Progressive Inks. Written comments to Laura Rubin, Industrial Technology
          Institute.  June  1997.                                                             5J


   2.      Bateman, Robert. Roplast Industries. Telephone discussion with Laura Rubin, Industrial
          Technology Institute.  May 27, 1997.


   3.      Daigle Maurice.  Schuster Flexible Packaging.  Written comments to Laura Rubin, Industrial
          Technology Institute.  June 1997.


  4.     Figueria, Lou.  FlexPak.  Telephone discussion with Laura Rubin, Industrial Technology
         Institute.   May  23, 1997.


  5.     Neal, Robert. Maine Poly. Telephone discussion with Laura Rubin, Industrial Technology
         Institute.  May 26, 1997.                                                         By


  6.     Nigam, Brijesh.  Sun Chemical Ink. Written comments to Dennis Chang, Abt Associates Inc
         November 20, 1998.                                                            '


  7.      Root, Dave. Georgia Pacific.  Telephone discussion with Laura Rubin, Industrial Technology
         Institute.  May 22, 1997.                                                           &y


  8.      Ross, Alexander. Radtech. Written comments to Karen Doerschug, US EPA. November 12
         1998.                                                                            '


  9.      Shapiro, Fred. P-F Technical Services, Inc. Written comments to Laura Rubin, Industrial
         Technology Institute.  June  18, 1998.


  10.     Siciliano, Mike.  Bema Film Systems. Written comments to Laura Rubin  Industrial
         Technology Institute.  July 1997.


 11.    Steckbauer, Steve.  Deluxe Packaging. Telephone discussion  with Laura Rubin Industrial
        Technology Institute.  May 26, 1997.


 12.    Timmerman, Mark.  Trinity Packaging. Telephone discussion with Laura Rubin Industrial
        Technology Institute.  May 20, 1997.


 13.    Zembrycki, Jerry. Strout Plastics.  Written comments to Laura Rubin, Industrial Technology
        Institute. June 1997.                                                               ey


 14.     Ellison, Dave.  American National Can Company.  Written comments to Laura Rubin
        Industrial Technology Institute.  June 1997.


 15.     Serafano, John. Western Michigan University.  Personal Communication with Laura Rubin
        Industrial Technology Institute.  March 26, 1997.


 16.     Rizzo, Tony. Lawson Marden Label.  Telephone discussion with Laura Rubin  Industrial
        Technology Institute. May 22, 1997.


 17.     Darney, Arsen J., editor. Manufacturing USA; Industry Analysis, Statistics, and Leading
        Companies.  4th   Edition,  Volume 1. Gale Research, Inc., Detroit; pp.733., 1994.

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                                                                             September 2000

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CHAPTERS
18.    Yeganah, John. Bryce Corporation. Telephone discussion with Laura Rubin, Industrial
       Technology Institute.  May 23, 1997.
19.    Jacobs, Eva.  Handbook of U.S. Labor Statistics Employment, Earnings, Prices, Productivity,
       and other Labor Data: 1996 Edition., 1996

20.    Steemer, Hans. Windmoeller and Hoelscher.  Telephone discussion with Laura Rubin,
       Industrial Technology Institute.  May 6, 1997.

21.    Heiden, Corey. Kidder Press. Telephone discussion with Trey Kellett, Abt Associates Inc.
       July 1, 1999.
22.    Bemi, Dan and Steve Rach. MEGTEC Systems.  Telephone discussion with Trey Kellett, Abt
       Associates Inc. July  14, 2000.
23.    Kottke, Lee. Anguil Environmental Systems, Inc. Telephone discussion with Trey Kellett, Abt
       Associates Inc. August 2, 2000.

 24.    Markgraft, Dave.  Enercon. Telephone discussion with Laura Rubin, Industrial Technology
       Institute.  February 1998.
 25     National Association of Printers and Lithographers. NAPL Heatset and Non-Heatset Web Press
        Operations  Cost Study; 1989-1990. Teaneck, NJ, 1990.

 26.    Bateman, Robert. Roplast Industries. Dffi Flexography Project Steering Committee Conference
        call. March 1999.
 27.    U.S. Department of Energy. Electric Power Monthly. Energy Information Administration,
        February 2000.
 28.    U.S. Department of Energy. Natural Gas Monthly. Energy Information Administration,
        February 2000.
 29.    Miller, Gary, et al. "Ink Cleaner Waste Reduction Evaluation for Flexographic Printers. "
        EPA/600/R-93/086, 1993.


 ADDITIONAL REFERENCES

 Tamm,  Rex. Daw Ink Company. Written comments to Laura Rubin, Industrial Technology Institute.
 June 1997.
  U.S. Department of Commerce.  7987 Census of Manufacturers.  Bureau of the Census,  MC87-1-27B.

  Windmoeller and Hoelscher.  Personal communication with sales representative of Windmoeller and
  Hoelscher (401-333-2770).  May 1997.
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                            This page is intentionally blank.
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                                                                  September 2000

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  [APTER 6
                                              RESOURCE AND ENERGY CONSERVATION
          Chapter 6:  Resource and Energy Conservation
                              CHAPTER CONTENTS
6.1 INK AND PRESS-SIDE SOLVENT AND ADDITIVE CONSUMPTION 	6-3

       Methodology 	
       Limitations and Uncertainties  	
       Ink and Press-side Solvent and Additive Consumption Estimates	6-71
16.2 ENERGY CONSUMPTION	
       Methodology  	
       Limitations and Uncertainties  ..
       Energy Consumption Estimates
6-10
6-10
6-16
6-17
1 6.3 ENVIRONMENTAL IMPACTS OF ENERGY REQUIREMENTS .......................... 6-22

       Emissions from Energy Production
       Environmental Impacts of Energy Production .....
       Limitations and Uncertainties  .

1 6 4 CLEAN-UP AND WASTE DISPOSAL PROCEDURES  ................................ 6-28
        Press Clean-Up and Waste Reduction in the CTSA Performance Demonstrations ......... 6-29
 REFERENCES
                                                                                  6-31
                                   INTRODUCTION


 This chapter discusses resource and energy use in flexographic printing and identifies opport^ities for
 conservation. By minimizing resource and energy use, companies can improve the env.ronment as well as
 their bottom line  Data presented in this chapter are based on information collected dunng the on-s.te
 perfonSe demonstration runs and information from equipment vendors. Ink and energy consumption
 dataTesented in this chapter are used in the cost analysis (Chapter 5) to calculate ink and energy costs.
 rnkLnsumpfen data are also used to estimate environmental releases forthe risk characterization (Chapter

 3)-

  INK AND PRESS-SIDE SOLVENT AND ADDITIVE CONSUMPTION: Section6.1 presents; the comparative
  nk and press side solvent and additive consumption rates for solvent-based water-based, and UV-cured
  inksvstems  This analysis is based on the weights of inks, solvents, and additives, and on the substrate
  usagerecorded by an o^ site observer from Western Michigan University (WMU) at each demonstration
 I site.

  ENERGY CONSUMPTION: Section 6.2 discusses the energy requirements of the drying systems, corona
             SlutTon control equipment (catalytic oxidizers) typically used with the different ink systems.
            we and/or gas  consumption  data were collected by WMU and supplemented by energy
                *"m.nt vendors. Due to the variability among equipment and operatin procedures^
  PUBLIC COMMENT DRAFT
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                                                    RESOURCE AND ENERGY CONSERVATION
^
                                              S' rather than Site-s»ecific data- « -ed in the cost
   ENVIRONMENTAL IMPACTS OF ENERGY REQUIREMENTS: Section 6.3 presents the environmental
   impacts of electr-aty - generation and natural gas combustion, using software tha?quantifies eSons The

   Seed r500Cftt n      f f " 'n^yStem baS6d °n the fate °f energy «»»umpllon at the methodology press
   speed (500 feet per minute) and the average press speeds observed at the performance demonstrations.


   CLEAN-UP ANDWASTEDISPOSALPROCEDURES:Section6.4discusseStheclean-upproceduresused
                                    " ^ aS «"" °f the br°ader life^ ^ Associated with'
                                HIGHLIGHTS OF RESULTS


               •rf   ^- 13d the '°WeSt 'nk consumPtion rates. In addition, UV inks required almost no
         added'at pressS?' S°'Vent~based inks had the hi9hest consumption rates for ink and materials

                       cs consumed the least amount of energy (assuming pollution control equipment
         rnncnmor h * f«,  * PTeSS ***** ** 5°° feet *** ™muie'  W™^ ™te were the next lowest
         consumer but at the press speeds observed during the performance demonstration, solvent-based
         inks were the second-lowest energy consumer per unit of image.
         Forsplvent-ancI water-based inks, air recirculation in dryer units can significantly reduce energy
         requirements by increasing the temperature of the incoming air.
         The environmental impacts due to energy production were lowest for water-based inks  This
         ink system consumed the least amount of energy, and much of the energy it did use was derived from
         natural gas.  Based on a national average of energy emissions by source, the CTSA found that
         natural gas released less emissions per unit of energy than  electricity.   Depending  on the
         geographical location of a flexographic printing facility (and  thus the  specific electricity source)
         emissions could be very different.
         Most solvent-based and some water-based ink wastes are classified as hazardous waste  Non-
        hazardous waste (e.g., waste substrate and some cleaning solutions) can be recycled or reused.


                                        CAVEATS


        •'nu ^T^u" W3S calculated durin9the performance demonstrations by recording the amount of
        ink added to the press and subtracting the amount removed during cleanup  Several site-specific
        Sfci^nH th^? afff ?d ^ ca'culated ink consumption figures: type of cleaning equipment, anilox
        roll size, and the level of surface tension of the substrate.
        The energy consumption section only considers equipment that would differ among the ink systems
        Therefore, drying/curing equipment is included, but substrate winding equipment and ink pumps are

        Exceptfor corona treaters, information was not available about the difference in energy requirements
        when equipment is run at different press speeds.  UV lamps also will have different energy demands
        rnnS ThnSrF ^f*' ** ft * assumed in this analvsis  that their energy  consumption is
        constant. Therefore, the energy consumption of UV lamps may be overestimated at lower press

        The  clean-up and waste disposal procedures  section  presents  the methods observed at the
        performance demonstration sites. These procedures were developed independently by the individual
      _sites, and do not represent recommended practices by EPA
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CHAPTER 6
                                                  RESOURCE AND ENERGY CONSERVATION
6.1 INK AND PRESS-SIDE SOLVENT AND ADDITIVE CONSUMPTION

              By reducing resource consumption, businesses can increase process efficiency, decrease
              operating costs, and decrease demand for natural  resources.   Ink is one. of the mam
              resources consumed by the flexographic printing process. The amount of ink required to
              print an image not only affects printing costs, but also influences the potential risk to
              workers and the environment from exposure to ink constituents.  This section of the CTSA
              presents average consumption of inks and  press-side additions from the performance
              demonstrations. The data are in units of pounds of ink consumed per 6,000 images and per
              6,000 ft2 of image, as printers commonly use these terms  in estimating and  comparing
              costs.

        Methodology

               The amounts of ink, press-side materials, and substrate consumed during the performance
               demonstrations are shown in Appendix 6-A.

               The on-site observer weighed the pre-mixed ink components (extender, water, solvent
               etc ) that were put in the ink sump at the beginning of makeready and whenever ink
               components were added to the sump.  During clean-up, the observer weighed the ink
               remaining in the sump, the ink scraped or wiped out of the press, the cleaning so ution
               (water detergent, or solvent) added to  the press,  and the ink and cleaning  solution
               removed from the press. The total ink consumed during makeready and the demonstration
               run for each color was calculated from the following equation.
Itotal    = Ve + Dadd-mk + L W " IT
                                                        + Cin ' Co
                where

                   I,

                   I
 total
                    pre
                    Ij-'-add-pr

                    IT
                    I
total amount of ink plus press-side solvents and additives consumed
(printed or evaporated) during makeready and the demonstration run
amount of  pre-mixed ink  put in  the  ink  sump at the beginning of
makeready
the sum of additional  ink components put in the  ink  sump during
makeready
the sum of the ink components added to the system during the press run
amount of ink remaining in the sump at the end of the run
amount of ink scraped or wiped out of the press at the end of the run
amount of cleaning solution added to the press during clean-up
amount of  cleaning solution and ink mixture removed from the press
during clean-up
                 information:
                                 was  calculated for  each demonstration  site using the following
                        total amount of ink consumed during makeready and the press run (Itotal)
                        amount of substrate printed (S)
                        total area of the image (16 by 20 inches with a 16-inch repeat)
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                                                      RESOURCE AND ENERGY CONSERVATION
                    the      f                                 meter at ±e be§inning of makeready,
                    the end of makeready, and at the end of the press run  for each substrate  The
                 consumption numbers are listed in Appendix 6-A.
                                  I0" Wnit6' Water-based ink at Site 1 follow, to help readers understand
                 the methodology and to allow reproducibility of results. The complete data are provided
                 **i •**-cnQi   ~
                     Total white ink consumed (Itotal) = 56.4 pounds (Ibs)
                     Total substrate consumed including makeready (S) = 62,892 linear feet (ft)
                     Total area of image = 2.22 square feet (ft2)
                     Repeat length of image = 1.33 ft
                    Number of images (N)
                    Ink per 6,000 images
— S / 1.33 feet per image
= 62,892 feet / 1.33 feet per image
= 47,200 images

= (WN) X 6,000 images
= (56.4 lbs/47,200 images) x 6,000 images
= 7.17 Ibs per  6,000 images
                    Ink per 6,000 ft2 of image   = (Itotal/N) x 6,000 ft2 of image / Area of image
                                             = (56.4 lbs/47,200 images) x 6,000 ft2 / 2.22 ft2 per
                                            image
                                             = 3.23 Ibs per 6,000 ft2 of image

                White ink was not printed on the PE/EVA substrate. Thus, PE/EVA substrate is excluded
                from ink consumption calculations for white ink.

                Table 6.1 presents the percent area of coverage for each ink. White dominates the ink
                coverage of the image (60.8 %), blue and green (line colors) account for 24.1 % coveragT
                and cyan and magenta (process colors) account for 5.2% coverage.                 '
                                        Table 6.1 Image Area by Color
                                                                       Percent coverage (%V
               the total percent coverage does not equal 100% because of overlapping colors and imprinted area
               Facilities running more than one substrate did not clean the press between substrates
               Thus only total weights, not the weight of ink applied to each substrate, are available'
               For the purposes of this analysis, it is assumed that the weight of ink consumed per unit
               area is not a function of the film type.                                      P
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              Press-side Solvent and Additive Consumption
              During the course of a print run, printers may add solvent or water to correct the viscosity
              of the ink or other components, such as extenders or cross-linkers, to improve the
              performance of the ink. Solvent and additive weights were calculated assuming the weight
              of each component consumed is directly proportional to the component weight added to
              the system. The solvent and additive consumption rates were then calculated in a manner
              similar to the ink consumption rates.

              The method for calculating  ink weights assumes equal volatilization rates for each
               component   It does not account for solvent emissions from the ink sump or  ink pan.
               Because solvents are expected to volatilize at a more rapid rate than other components, this
               method slightly underestimates solvent consumption rates and slightly overestimates rates
               for the other components.  Sample calculations for solvent and additive weights using
               solvent-based, blue ink data from Site 5 follow, with numbers taken from Table 6-A.12
               in Appendix 6-A:

                  Weight of blue ink added to system (Iadded) = 20.90 Ibs
                  Weight of solvent added to the blue ink (Sadded) = 4.81 Ibs
                  Total ink used (IT) =  18.16 Ibs

                   Total components  added  (T) = Iadded + Sadded
                                             = 20.90 Ibs  + 4.81 Ibs
                                             = 25.71 Ibs
                   Ratio of !„„« to T(R,)

                   Ratio of Sadded to T (Rs)


                   Weight of ink consumed
•= 20.90 Ibs/25.71 Ibs
 = 0.81
 = 4.81 Ibs / 25.71 Ibs
 = 0.19

 = IT X R!
 = 18.16 Ibs x 0.81
 = 14.8 Ibs
                    Weight of solvent consumed = IT x Rs
                                              = 18.16 Ibs x 0.19
                                              = 3.4 Ibs

         Limitations and Uncertainties

                 The limitations of and uncertainties in the data are related to the limited number of
                 demonstration sites, variability among the equipment and operating procedures at the test
                 sites, and uncertainties  in the measured ink component weights.  Each of these are
                 discussed below.

                 Limitations Due to the Number of Demonstration Sites
                 Ink consumption data were collected during twelve performance demonstrations^ at ten
                 flexographic printing facilities across the United States and one press manufacturer s pilo
                     in Germany.  As such, the data represent a "snapshot" of how the inks performed a
                    tL of the performance demonstrations (November 1996 - March 1997 under actual
                          condUions at a limited number of facilities.  Because no two printing plants are
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                                                    RESOURCE AND ENERGY CONSERVATION

              identical, the sample may not be representative of all flexographic printing plants (although
              there is no specific reason to believe they are not representative).

              Variability among Equipment and Operating Procedures
              Several operating parameters  were  specified  in  the performance  demonstration
              methodology (see Appendix 6-B) in an attempt to ensure consistent conditions across
              demonstration sites. These included target specifications for anilox rolls (screen count and
              amlox volume) which directly affect the amount of ink applied to print an image

              The specified target ranges  for the anilox rolls were not always met.  Because of the
              production needs of the volunteer facilities, changing anilox rolls or acquiring new anilox
              oils  to meet the specified targets was impractical.  Table 6.2 lists the Srget  anilox
              specifications and the average configurations by ink type for the anilox rolls actually used
              at Ae demonstration sites. The Site Profiles section of the Performance chapter (Chapter
              4) lists the particular anilox configurations used at each of the test sites.  Facilities using
              anilox volumes and screen counts greater than the specifications would be expected to
              consume more ink to print-the test image.  Similarly, facilities using anilox volumes and
              screen counts less than the specifications would be expected to consume  less ink to print
             the test  image   Also, these  specifications do not  address the  fact that the anilox  roll
             volume would differ depending on the color printed; for example, the volumes for ligh
             colors would be larger than those for dark colors                                 8
                 Table 6.2 Average Anilox Configurations and Target Anilox Specifications
                   Ink
              Target
              Specifications
             Solvent-
             based
             Water-based

===

DOS

3d
	
Screen count (lpi)a
Line
(color)
440

350
290
480
=====
Line
(white)
^S^^I^SIE
150

260
300
250
=========
Process
====== 	 H
600 to
700
650
580
610
1
1
Volume (BCIVI^ |
Line
(color)
4 to 6

5.5
6.3
4.9
Line
(white)
6 to 8

6.8
5.9
•
7.3
Process
— i
1.5

2.1
3.0
3.3
             UV-cured
            "lines per inch
            bbillion cubic microns per square inch
            Uncertainties in Ink Component Weights

            folvtntr8! veVi°US1^ ^ °n"Site °bSerVer C°lleCted inf«ion on the amounts of ink
            so vents addmves, and cleaning solution added to or removed from the system during
            makeready,  the press run, and clean-up.  In some cases,  however, site operating

            sonTenft?'     " ^ ^ °J^^ ***** ^ USed' Prevented measuremen7f
            some of these parameters.  In these cases, the weights were estimated based on other site
                                                                           September 2000

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APTER6
                                                RESOURCE AND ENERGY CONSERVATION
     Ink and Press-side Solvent and Additive Consumption Estimates

            Tables 6 3  and 6.4 present the average ink and and press-side solvent and additive
            consumption rates for the performance demonstration sites by ink type, substrate, and
            color.  Site-specific consumption rates can be  found in Tables 6-A.3 and 6-A.4 in
            Appendix 6-A.

            In general  the UV-cured ink formulations used substantially less ink than the solvent-
            based or water-based formulations. On LDPE, the UV-cured ink systems used 57% less
            ink than the solvent-based ink systems and 28 % less than the water-based ink systems. On
            PE/EVA the UV-cured ink systems used 82 % less ink than the solvent-based ink systems
            and 56%' less than the water-based ink systems. These results are consistent with the
            general expectation that less UV-cured ink is needed because nearly all of the ingredients
            are incorporated into  the dried coating, unlike with solvent- and water-based inks.

            Components added to the water-based ink formulations included water, extender, solvent,
            ammonia  cross-linker, slow reducer, and defoamer. Components added to the solvent-
            based formulations were primarily solvents, but one company also added extender to the
             ink  whereas another added acetate. Water-based ink solvents and additives tended to
             comprise  a smaller percentage of the overall total weight than did solvent-based ink
             solvents and additives. In the solvent-based systems, these additions accounted for about
             25% of total consumption.  No additives were used at the UV-cured ink demonstration
             sites, except for a low-viscosity monomer added to the green ink at Site 11.
PUBLIC COMMENT DRAFT
                                             6-7
                                                                             September 2000

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   CHAPTER 6
                                                       RESOURCE AND ENERGY CONSERVATION!
   6.2 ENERGY CONSUMPTION
                 Energy conservation is an important goal for flexographic printers who strive to cut costs
                 and seek to improve environmental performance. This section of the CTSA discusses the
                 electricity and natural gas consumption rates of the flexographic printing equipment listed
                 in Table 6.5, including background information and assumptions.  Energy consumption
                 rates are used in the cost analysis (Chapter 5) to calculate energy costs.  They are also
                 used in Section  6.3  to evaluate  the life-cycle environmental impacts  of energy
                 consumption.                                                                 *y
                              Table 6.5 Equipment Evaluated in the Energy Analysis
                 Hot air drying
                 system
Dries the ink between stations and in
the overhead tunnel (main) dryer.
                  ;atalytic
                 oxidizer"
Converts VOCs to carbon dioxide and
water.
                 Corona treater
Increases the surface tension of the
substrate to improve ink adhesion.
                                 Cures UV-cured ink applied to
                 ln some states, oxidizers may be required for water-based inks with high VOC content
                Energy estimates were to be prepared from the individual site data for each  of the
                performance demonstration sites, similar to the site-specific ink consumption estimates
                presented in Section 6.1. However, limited or no energy data were available for one or
                more pieces of equipment at several of the sites, particularly for catalytic oxidizers used
                at solvent-based sites.  In addition, press size,  age, and condition of presses varied
                significantly across sites,  as  did  equipment  operating conditions, such  as  dryer
                temperature. For these reasons, equipment vendor estimates, rather than site-specific data
                are used in the cost analysis to calculate energy costs.
        Methodology
               This section presents the methodology used to estimate energy requirements and provides
               background information and key assumptions on the types of equipment evaluated- hot air
               drying systems, catalytic oxidizers, corona treaters, and UV curing systems.

               Energy Consumption
               Equipment vendors estimated  equipment energy  requirements in kilowatts (kW)  for
               electrical power and British thermal units (Btu) per hour for natural gas. This information
               was then converted into energy consumption rates for each ink type in Btus per 6 000
               images and per 6,000 ft2 of printed substrate. Table 6.6 lists the press, substrate 'and
               image characteristics used in the energy estimates. These characteristics are consistent
               with assumptions used in the cost analysis and with the substrates and image printed during
               the on-site performance demonstrations.  Where  applicable, two sets of estimates were
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CHAPTER 6
                                                  RESOURCE AND ENERGY CONSERVATION
              made- one using the project methodology press speed of 500 feet per minute (fpm) for all
              three ink types, and one using the average press speed achieved for each ink type at the
              performance demonstration facilities. Additional assumptions for each type of equipment
              and energy rate calculations are listed in the sections below.
                 Table 6.6 Press, Substrate, and Image Information for Estimating Energy Use
                           48-inch, 6-color, Cl press; new, average
                           quality
                                     Press costs are presented in
                                       hapter 5.
                Press
                speed
Solvent-based ink: 500 fpm and 453 fpm
Water-based ink:  500 fpm and 394 fpm
UV-cured ink: 500 fpm  and 340 fpm
Two scenarios for each ink
system are used in the
corona treatment energy
estimates.
                Substrates
LDPE, PE/EVA, OPP
                Web width
20 inches
A second case assuming a
40-inch web was used in
oxidizer and corona treater
energy estimates.
               Sample calculations based on the average press  speed  at water-based sites follow.
               Estimates were provided by equipment vendors.

                   Drying oven natural gas consumption = 500,000 Btu/hour
                   Blower electricity = 30 kW
                   Corona treater electricity = 1.6 kW
                   Total electricity = 31.6 kW
                   Average press speed (P) = 394 feet per minute
                   Image size = 2.22 ft2
                   Image repeat (R) = 1.33 feet

                   Images printed per minute     = P/R
                                               = 394 feet per minute / 1.33 feet per image
                                               = 296 images/minute
                                               = 17,800 images/hour
                   Time to print 6,000 images    = 6,000 images / 17,800 images/hour
                                               = 0.34 hours
                   Natural gas  per 6,000 images  = 500,000 Btu/hour  X 0.34 hours
                                                =  170,000 Btu
                   Electricity per 6,000 images    = 31.6 kW x 0.34 hours
                                                =  llkW-hr
                    Images per 6,000 ft2

                    Time to print 6,000 ft2
                     = 6,000 ft2 / 2.22 ft2 per image
                     = 2,700 images
                     = 2,700 images / 17,800 images/hour
                     = 0.15 hours
   PUBLIC COMMENT DRAFT
                                              6-11
                                                                               September 2000

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  CHAPTER 6
                                                     RESOURCE AND ENERGY CONSERVATION
                    Natural gas per 6,000 ft2

                    Electricity per 6,000 ft2
= 500,000 Btu/hour x 0.15 hours
= 76,000 Btu
= 31.6kW x 0.15 hours
= 4.7 kW-hr
                Hot Air Drying Systems
                Most solvent-based and water-based presses are equipped with between-color (interstation)
                dryers (BCDs) and an overhead (main) dryer. Supply and exhaust blowers are used to
                provide air flow through the dryers and maintain negative pressure within the dryer.  The
                supply blowers draw air into the drying system to be heated by the burners. Most printers
                draw the dryer make-up air from the ambient environment outside the plant.1  Exhaust
                blowers are used to draw the heated air though the dryers to the exhaust outlet.

                The BCDs are positioned after each print station. They dry each color as it is applied to
                the web to prevent pick-up or tracking when the next color is applied. The overhead dryer
                consists of a tunnel located above the print stations, through which the web passes to
                further dry the ink before the web is rewound.

                The energy consumed by hot air drying systems includes electrical power for the supply
                and exhaust blowers and natural gas for the drying oven.  Typically, the gas energy
                required to heat the process air is greater than the energy needed to dry the ink.2

                Kidder, Inc., a press manufacturer, provided energy estimates for hot air drying systems
                based on the press, substrate, and image details listed in Table 6.6, the  average  ink
                consumption rates listed in Table 6.3, and the hot air drying system assumptions listed in
                Table 6.7. Dryer energy estimates for both solvent- and water-based inks are based on the
                same air flow rates but different dryer temperatures.  New presses are now designed to
                work with either water-based or solvent-based inks. Usually, a press operator will reduce
                the amount of heat instead of the air flow when using solvent-based inks.3 Air flow rates
                are given  in units of cubic feet per minute (cfm).
                                 Table 6.7 Hot Air Drying System Assumptions

BCD air flow rate
Main dryer air flow rate
Dryer temperature
(solvent-based Inks)
Dryer temperature
(water-based inks)
Make-up (outdoor) air
temperature
Percent recirculation
of dryer air
Assumption
2800 cfm
3000 cfm
150°F
200°F
0°F, 50°F,
70°F
0%, 50%

Four dryer boxes at 700 cfm/box, based on
average BCD flow rate of 15 cfm/inch of
width/dryer boxa
Typical value for 48-inch press3
Typical temperature for Project substrates3
Typical temperature for Project substrates3
Three scenarios
Two scenarios
              * Reference 4.
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CHAPTERS
                                                    RESOURCE AND ENERGY CONSERVATION
               The assumed dryer temperature for water-based inks is higher than the maximum
               temperature to which some film substrates can be subjected without potentially damaging
               the film.  However, in practice, the film temperature would be less  than the dryer
               temperature due to impression cylinder cooling and evaporative cooling.5

               The hot air drying system energy estimates  were prepared for six different operating
               scenarios, assuming three different outside air temperatures for the make-up air and two
               dryer air  recirculation scenarios (no recirculation  and 50%  recirculation).   All  six
               scenarios  were analyzed to illustrate the influence make-up air temperature  and air
               recirculation on dryer costs.  The different air temperatures represent the range of air
               temperatures that might be encountered in different seasons. If make-up air is taken from
               tte outdoor environment (as is typically done), dryer costs will be significantly higher in
               winter than in summer. The 50°F temperature was used in the cost analysis to represent
               an annual average. Most new presses are designed to recirculate dryer air, either to save
               on dryer  air  heating costs  or to reduce the air  flow to the pollution control device.
               However, many older presses do not have dryer air recirculation, and retrofitting may be
               ineffective with smaller, low air flow presses. A recirculation rate of 50 % was used in the
               cost analysis since this is more  representative of a new press, the  subject of the cost
               analysis.

               Catalytic  Oxidizers
               A catalytic oxidizer is a type of add-on emissions control equipment used to convert VOC
               emissions  to carbon dioxide and  water by high  temperature oxidation.  Catalytic
               incinerators  employ a catalyst  bed to facilitate the overall  combustion reaction  by
               increasing the reaction rate.  This enables conversion at lower reaction temperatures than
               in thermal oxidizers.  Oxidizers are used primarily with solvent-based inks, but may be
               required with water-based inks in some states.

               A basic catalytic oxidizer assembly consists of a heat exchanger, a burner, and a catalyst.
               First, the dryer exhaust stream is preheated  by heat exchange with the oxidizer effluent
               and, where necessary; further heated to the desired catalyst inlet temperature by a natural
                gas-fired burner.  The heated stream then passes through the catalyst where VOCs  are
                converted to carbon dioxide and water.  The. combustion reaction between oxygen and
                gaseous pollutants in the waste stream occurs at the catalyst surface. The oxidizer effluent
                is then recirculated back to the heat exchanger and may also be recirculated to the dryer
                to save drying fuel.

                Two oxidizer  suppliers, Anguil Environmental Systems, Inc. and MEGTEC Systems
                [formerly Wolverine (Massachusetts) Corporation], provided energy estimates based on
                the press, substrate, and image details listed in Table 6.6 and  the additional oxidizer
                assumptions presented in Table 6.8.7  As with the other equipment, the oxidizer energy
                estimates represent energy requirements for a particular set of circumstances (e.g., solvent
                loading,  dryer exhaust temperature, flow rate), and they are not necessarily representative
                of other  operating conditions.
   PUBLIC COMMENT DRAFT
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  CHAPTER 6
                                                       RESOURCE AND ENERGY CONSERVATION
                                     Table 6.8  Catalytic Oxidizer Assumptions
Parameter
Number of
presses vented
to oxidizer
Solvent content
Heat exchanger
efficiency
Air flow to
oxidizer
Dryer exhaust
temperature
Catalyst inlet
temperature
Solvent loading
two cases)
Assumption
Two
1 3,000 Btu/lb
70%
5800 cfm
150°F
600°F
70 Ib/hr
140 Ib/hr
^ — 	 	 -— — — — — — -----
Comments ||

Average of typical values provided by two oxidizer
suppliers
Typical efficiency value based on vendor input.
Equipment vendors also provided oxidizer energy
estimates for 65%, 75%, and 80% efficiencies
Combined air flow after recirculation for two 48-inch
presses; same as air flow used in dryer energy
estimates
Dryer temperature assumed for drying oven energy
calculations
Depending on solvent type, catalyst inlet
temperatures can vary from 475°F to 650°F8A1ai1'a
Solvent loading for two presses; solvent loading at
Derformance demonstration sites averaged 35 Ib/hr
or one press.
Solvent loading assuming each 48-inch press is
running two 20-inch images, side by side (i.e., solvent
oading for a 40-inch web width)
                The catalytic oxidizer energy estimates were prepared assuming two different solvent
                loadings (70 and 140 Ib/hr).  The solvent loadings were based on two web widths (20-inch
                and 40-inch). A solvent loading of 70 Ib/hr was used in the cost analysis.

                Two scenarios for solvent loading are provided because it would be very unusual for a
                facility with a 48-inch press to run a 20-inch image, which reduces solvent loading to the
                oxidizer. Oxidizer energy costs decrease with increased solvent loading until the oxidation
                reaction becomes self-sustaining (e.g., requires no make-up fuel).  Using a 20-inch image
                on a 48-inch press and the associated lower solvent loading would tend to overestimate
                energy costs. Solvent loading of 140 Ib/hr portrays a more realistic situation, in which two
                20-inch images are run side by side on a 48-inch press.

                A heat exchanger efficiency  of 70%, a typical efficiency, was used in the cost analysis
                The other values (65%, 75%, and 80%) were submitted by oxidizer vendors to illustrate
               the effect of heat exchanger efficiency on oxidizer energy costs.
         Technology developments are allowing for decreased catalyst inlet temperatures. A published estimate
         notes that a typical catalyst inlet temperature is 550-700°F. Another industry estimate notes that with
         solvent loading, the typical temperature can rise to 650°F.  However, some new oxidizers are capable of
         operating at 500 °F.
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                                                                               September 2000

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CHAPTER 6
                                                   RESOURCE AND ENERGY CONSERVATION
              Corona Treaters
              Corona treatment is a process that increases the surface energy of a substrate to improve
              ink adhesion.   It can be performed three ways: by the substrate supplier,  when the
              substrate is on the printing press, or both by the substrate supplier and on press. On-press
              corona treatment systems may be used with all three ink types, but are mainly used with
              water-based and UV-cured inks, which typically have lower surface energy than solvent
              inks.  None of the performance demonstration sites running solvent-based inks used corona
              treatment on the press.

              A corona treatment assembly consists of a power supply and treater station. The power
              supply accepts standard utility electrical power and converts it into a single-phase, higher-
              frequency power that is supplied to the treater station.  The treater station applies the
              higher frequency power to the surface of the material via a pair of electrodes.12

              The energy consumed by a corona treatment system can depend on a number of factors,
               including web width,  production speed, type of substrate (e.g., material, slip additives),
               and watt density (watts per unit area per unit time) required to treat the substrate. Table
               6.6 presents press, substrate, and image details. Enercon Industries Corporation, a corona
               treater supplier, provided corona treatment energy estimates, including the power supply
               size and input power.  Input power represents the actual power drawn from the utility grid.
               Watt density was not specified, so the equipment suppliers determined the appropriate watt
               density.

               UV Curing Systems
               UV presses employ UV lamps, which emit UV radiation to polymerize or cross-link the
               UV-cured ink monomers.  In addition to the lamps, a UV curing system has supplemental
               cooling capacity to counter the infrared heat produced by the UV lamps.  The curing
               system may also  include a blower to extract ozone generated  during the  UV curing
               process, and an anilox heater to pre-heat the ink.  Only one of the three UV performance
               demonstration sites had a separate ozone blower and anilox heater.

               Energy estimates for UV curing systems were developed based on operating data collected
               during the performance demonstrations; supplemental information from Windmoller &
               Holscher, an  equipment  supplier; and  information from another equipment supplier,
               Fischer & Krecke, Inc.  Table 6.9 presents the UV curing system assumptions. Lamp
               output is assumed to be constant at both press speeds evaluated (i.e., at 500 fpm and 340
               fpm). However, hi most UV systems lamp power increases with press speed up to some
               maximum power output  level, depending on the press.  For example, lamp output
               provided by one press manufacturer ranged from 48 watts per centimeter of press width
               (W/cm)  at a press speed of 100 fpm to  160 W/cm at 820 fpm.13 In another example,
               manufacturer  data for lamp output at a performance demonstration site ranged from 80
               w/cm at standby to 200 w/cm at 200 fpm. No data were available to accurately account
               for the differences in lamp output at.the two project press speeds. Lamp energy in watts
               was calculated by multiplying the lamp output in watts per inch by the press width (48
                inches) and by the total number of lamps (six).
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September 2000

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  CHAPTER 6
                                                     RESOURCE AND ENERGY CONSERVATION
                                   Table 6.9 UV Curing System Assumptions
Parameter
Lamp output
Number of
lamps
Lamp cooling
Assumption
175 watts per cm of
press width
Six
60 kW
Comments
Average value based on site and vendor data
Four lamps between colors and two main
lamps
Average value based on site data and vendor
data
        Limitations and Uncertainties

                The limitations of and uncertainties in the energy analysis stem from the lack of energy
                data at many of the  demonstration sites, the limitations in the number of operating
                scenarios evaluated, limitations in the data for different press speeds, and uncertainties
                inherent in using estimated data rather than measured data.  Each of these limitations is
                discussed below.

                Lack of Energy Data at Performance Demonstration Sites
                The performance demonstration methodology called for energy data collection at the 11
                performance demonstration sites in order to develop a "snapshot" of energy requirements
                under  actual operating conditions at a limited  number of facilities.   As discussed
                previously, little or no energy data were available for one or more pieces of equipment at
                several of the sites, particularly for catalytic oxidizers used at solvent-based sites.  In
                addition, press size, age, and condition varied significantly across sites, as did equipment
                operating  conditions, such as dryer temperature.  For these reasons, equipment vendor
                estimates, rather than site-specific data, are the focus of the energy analysis. As  a result,
                the data are  estimated based on hypothetical operating conditions and do not necessarily
               represent energy demand experienced at the performance demonstration sites.

               Limitations in the Number of Operating Scenarios
               The operating conditions and assumptions used in the energy analysis were  developed
               based  on the test  image,  substrates,  and operating conditions at the performance
               demonstration sites, as well as using typical operating conditions provided by equipment
               vendors.  As such, the energy estimates represent a "snapshot"  of equipment energy
               Limitations in the Data for Different Press Speeds
               The energy consumed by printing equipment is often a direct or indirect function of press
               speed.  For example, the power outputs of UV lamps and corona treaters usually vary
               directly with the press speed. The amount of make-up fuel required for a catalytic oxidizer
               depends on the solvent loading, which varies with the ink, image, and press speed, among
               other factors.  However, except for corona treaters, no quantitative data were available to
               determine the differences in equipment energy draw at the different project press speeds
               (e.g., the average press speeds  observed at  performance  demonstration sites and the
               methodology press speed of 500 fpm). This can result in either an overestimation of energy
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CHAPTER 6
                                                   RESOURCE AND ENERGY CONSERVATION
              requirements at the lower press speeds or an underestimation of energy requirements at
              the higher press speeds.

              Uncertainties in Estimated Data
              Equipment energy requirements were estimated by equipment vendors for use in the cost
              analysis. Attempts were made to get estimates from at least two vendors for each type of
              equipment, but in some cases only one estimate was available. Vendor energy estimates
              were compared to each other, to performance demonstration data,  and to other data
              sources as available, to check for reasonableness and completeness.  Either averages or
              the most complete and representative data are presented in the results below and used in
              the cost analysis.

       Energy Consumption Estimates

              Table 6.10 presents the equipment vendor energy  estimates  used to develop energy
              consumption rates. Table 6.11 presents gas and electrical energy consumption rates in
              Btus.  Results from the latter table were used in the cost analysis (Chapter 5). The energy
              consumption results for each type of equipment across the three ink systems are discussed
              in more detail in the following sections. For the estimated energy costs for each ink system
              and substrate combination, see Table 5.17 in the Cost chapter.

              Under the particular operating parameters and assumptions used in this analysis, the water-
              based system consumed the  least energy at both press speeds.  UV energy consumption
              rates were most  influenced by the press speed, due to the lower average press  speed
              achieved at UV performance demonstration sites.  However, as noted previously, no data
               were available to account for the lower lamp energy draw that can occur at lower press
               speeds.  Solvent-based systems have lower drying energy requirements than water-based,
              but have higher overall energy requirements when the oxidizer energy requirements are
               taken into account. These results would be reversed (e.g., water-based inks would require
               more energy than solvent-based-inks) if the solvent-loading to the oxidizer was sufficient
               to make the  oxidizer self-sustaining and/or  recirculation of dryer air was not taken into
               account for water-based systems.

               The results of the energy analysis in Table 6.11 can be compared to a similar analysis of
               energy consumption undertaken by a press manufacturer that supplies both hot air and UV
               cured systems.14  That study evaluated the relative energy consumption of a 55-inch press
               running the  different ink systems.  Table 6.12 shows the results of that analysis,  which
               suggest that solvent-based  and water-based systems have roughly the  same energy
               requirements if pollution control equipment is required for both ink types, while UV-cured
               inks have slightly greater energy requirements.
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September 2000

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 CHAPTER 6
                                                 RESOURCE AND ENERGY CONSERVATION
                          Table 6.10  Equipment Vendor Energy Estimates Used to
                                      Develop Consumption Rates
Ink
Solvent-
based
Water-
based
UV-
cured

Equipment
Drying
oven
Dryer
blowers
Oxidizer
Oxidizer
blower
Drying
oven
Dryer
blowers
Corona
treater
UV lamps
Lamp
cooling
Corona
treater
Natural gas
(Btu/hr)
360,000
n/a
290,000
n/a
500,000
n/a
n/a
n/a
n/a
n/a
Electricity
(kW)
n/aa
30
n/a
25
n/a
30
2.1, 1.6
130
60
2.1, 1.6
Comments
Based on an outdoor air
temperature of SOT and 50%
recirculation of dryer air
Average of values
recommended in dryer energy
audits from some performance
demonstration sites and by
equipment vendor
Average of values from two
equipment vendors; based on
70 Ib/hr solvent loading
Average of values from two
equipment vendors
Based on an outdoor air
temperature of 50°F and 50%
recirculation of dryer air
Average of values
recommended by two
performance demonstration
sites and by equipment vendor
Based on worst case substrate
(PE/EVA) running at 500 and
394 fpm, respectively
See Table 6.9 for basis
See Table 6.9 for basis
Based on worst case substrate
(PE/EVA) running at 500 and
394 fpm respectively
              n/a. not appucaoie
                    Table 6.11  Average Energy Consumption Rates for Each Ink System
Ink
Solvent-based
Water-based
UV-cured
Press speed
(fpm)
500
453b
500
394b
500
340b
Energy per 6,000
images (Btu)a
220,000
240,000
160,000
220,000
174,000
260,000
Energy per 6,000 ft2 of
imacjG (Btu)a
100,000
110,000
73,000
96,000
78,000
120 000
              electrical energy was converted to Btus using the factor of 3,413 Btu per kW-hr.
              Average press speed for the performance demonstration sites.
PUBLIC COMMENT DRAFT
6-18
                                                                        September 2000

-------
CHAPTER 6
                                                   RESOURCE AND ENERGY CONSERVATION
                            Table 6.12 Energy Consumption per Job by Ink Type3
Equipment
Dryer"
Pollution control"
Corona treatment
UV lamps
Temperature conditioning

Total
Energy consumption by ink type (Btu/hr)
Solvent-based
=310,000
=200,000
n/a
n/a
n/a
=200,000
=710,000
Water-based
=310,000
(200,000)d
17,000
n/a
n/a
=200,000
530,000-730,000
UV-cured
n/ac
n/a
= 17,000
=550,000
=85,000
=200,000
=850,000
               bHeater plus blower
               °n/a:  not applicable
               dPollution control may or may not be required with water-based inks.


               Hot Air Drying Systems
               As discussed previously, six scenarios were evaluated for the natural gas requirements of
               a hot air drying system, based on three different ambient air temperatures and the presence
               or absence of dryer air recirculation. Table 6.13 presents the results of these analyses.
               The  energy requirements for hot air drying systems were calculated using a proprietary
               formula that considers make-up air temperature, dryer temperature, and air flow.16 As
               shown in the table, recirculation can greatly reduce energy load.  There are many factors
               involved, but in this scenario dryer energy with recirculation can be calculated assuming
               a relationship of 40% fuel savings for 60% recirculation.17  Whenever recirculating air is
               used with solvent-based inks, however, it is imperative that the lower explosive limit
               (LEL) be monitored and controlled to safe limits.18


                      Table 6.13 Natural Gas Energy Estimates for Hot Air Drying Systems
Ambient air
temperature (°F)
0
0
50
50
70

Percent air
recirculation (%)
0
50
0
50
0
50
Natural gas energy (Btu/hr)
Solvent-based
720,000
480,000
530,000
360,000 -
440,000
290.000
Water-based
890,000
600,000
740,000
500,000
670,000
450,000
                Source: Reference 19.
                Dryer gas energy data collected during the performance demonstrations were largely
                incomplete.  Data that were collected varied widely due to differences in press sizes and
                operating conditions. For example, gas energy data were only available from four of eight
                sites (one of which ran both solvent- and water-based ink systems) and ranged from gas
  PUBLIC COMMENT DRAFT
6-19
                                                                                September 2000

-------
  CHAPTER 6
                                                      RESOURCE AND ENERGY CONSERVATION
                 burner capacity data to energy estimates from dryer energy audits.  The average gas
                 consumption rates reported by solvent-based and water-based sites were  2.4 million
                 Btus/hr and 1.5 million Btus/hr, respectively. These values are significantly higher than
                 the values estimated in Tables 6.10 and 6.13. Differences may be attributed in part to the
                 larger press sizes at these sites (average 54 inches), press age, dryer temperatures and flow
                 rates, and the amount of dryer air recirculation.

                 Catalytic Oxidizers
                 Oxidizer vendors were asked to estimate oxidizer energy requirements for two scenarios
                using the assumptions in Table 6.8: The first scenario is two 48-inch presses  running the
                performance demonstration image vented to the same oxidizer (70 Ib/hr solvent loading).
                The second scenario is two presses fully loaded with two performance demonstration
                images (140 Ib/hr solvent loading).  The first scenario is consistent with assumptions used
                in the cost analysis (Chapter 5) and was used to generate the energy consumption rates in
                Tables 6.10 and 6.11.  The second scenario illustrates the effect of solvent loading on
                energy  requirements.  In  general, as solvent  loading  increases,  natural gas  energy
                decreases until the solvent loading is sufficient to make the reaction self-sustaining.

                In addition to the two scenarios described above, the  oxidizer vendors  prepared energy
                estimates based on heat exchanger efficiencies of 65 %, 70 %, 75 %, and 80 %.  Table 6.14
                presents the catalytic oxidizer energy estimates for the various solvent loadings and heat
                exchanger  efficiencies  and the specific assumptions  in Table 6.8.   Other operating
                parameters that can significantly affect the  overall energy requirements of an oxidizer
                include the solvent heat content, the air flow to the oxidizer, and the inlet air temperature.
                                 Table 6.14  Catalytic Oxidizer Energy Estimates3
Solvent
loading
70 Ib/hr
140 Ib/hr
Equipment
Burner (Btu/hr)
Damper/blower
(kW)d
Burner (Btu/hr)
Damper/blower
(kW)d
Energy estimates by heat exchanger efficiency
65%b
560,000
17"
16,000
17"
70%b
260,000
17"
16,000
17e
70%c
320,000 •
32f
70,000
32f

130,000
32f
.n/a9
n/a

70,000
32f
n/a
n/a
                — --*** --		—— -	~ .^wuiiii^uv^iio in Table 6.8 plus additional assumptions made by
               equipment vendors. Values do not necessarily represent the relative energy efficiency of the vendor's
               equipment.
               bSource: Reference 20.
               "Source: Reference 21.
               dOnekW-hr=3,413Btu                                               ;
               "Based on 22 hp blower
               'Based on 40 hp motor with volume blower
               fln/a:  not applicable, unit is at minimum Btu/hr usage with another heat exchanger.
               Corona Treaters
               Corona treatment energy requirements were estimated for two press speeds (500 fpm and
               the performance demonstration site averages) and two web widths (20 inch and 40 inch).
PUBLIC COMMENT DRAFT
                                              6-20
                                                                                September 2000

-------
CHAPTER 6
                                                  RESOURCE AND ENERGY CONSERVATION
              One corona treater supplier provided power supply and input power estimates for the worst
              case substrate (2.5 mil PE/EVA, high slip) only, while the other provided watt density and
              power supply data for all of the substrates, but did not provide input power estimates.
              Because the remainder of the energy analysis is based on input power rather than power
              supply, estimates provided by the first supplier were used to generate the results in Tables
              6.10 and 6.11.  Table 6.15 lists corona treater energy estimates for a 500 fpm press speed.
              Table 6.16 lists corona treater energy estimates  for the average press speed at the
              performance demonstration sites.
               Table 6.15 Corona Treater Energy Estimates (Press Speed of 500 Feet per Minute)
Ink
Water-
based
UV-
cured
Substrate
LDPE
PE/EVA
OPP
LDPE
LDPE (no slip)
PE/EVA

Watt density
(watts/m2/min)
20"
3,100
3,100
3,100
3,100
2,300
3,100

40"
weba
6,200
6,200
6,200
6,200
4,600
6,200
6,200
Power supply
(kW)
20"
weba
3.0
3.0
3.0
3.0
3.0
3.0
3.0
40"
weba
7.5
7.5
7.5
7.5
5.0
7.5
7.5
20"
webb
NDC
2.0
ND
ND
ND
2.0
ND
40"
web"
ND
3.5
ND
ND
ND
3.5
ND
Input power
(kW)
20"
web"
ND
2.1
ND
ND
ND
2.1
ND
40"
webb
ND
3.6
ND
ND
ND
3.6
ND
               aSource: Reference 22.
               "Source: Reference 23.
               °ND = no data
                   Table 6.16 Corona Treater Energy Estimates (Average Press Speeds at the
                                      Performance Demonstration Sites)
Ink
Water-
based
UV-
cured
Substrate
LDPE
PE/EVA
OPP
LDPE
LDPE (no slip)
PE/EVA

Watt density
(watts/mz/min)
20"
2,400
2,400
2,400
2,100
1,600
2,100

40"
4,700
4,700
4,700
4,200
3,100
4,200
4,200
Power supply
(kW)
20"
weba
3.0
3.0
3.0
3.0
1.5
3.0
3.0
40"
weba
5.0
5.0
5.0
5.0
3.0
5.0
5.0
20"
webb
ND°
1.5
ND
ND
ND
1.5
ND
40"
webb
ND
3.0
ND
ND
ND
2.5
ND
Input power
(kW)
20"
webb
ND
1.6
ND
ND
ND
1.6
ND
40"
webb
ND
3.1
ND
ND
ND
2.6
ND
                aSource: Reference 24.
                "Source: Reference 25.
                CND = no data
  PUBLIC COMMENT DRAFT
                                              6-21
September 2000

-------
  CHAPTER 6
                                                     RESOURCE AND ENERGY CONSERVATION
                 Table 6.17 presents power output data (e.g., power applied to the web) read by WMU
                 representatives from the corona treater power supply box during the performance
                 demonstration runs. In some cases, WMU representatives also measured power input in
                 volts and amps during the print run.  However, these data are not reported because corona
                 treater suppliers have indicated they cannot be used to calculate power input in kilowatts
                 without knowing site-specific power efficiency factors.26
                  Table 6.17 Corona Treater Power Output at Performance Demonstration Sites
Ink
Water-based
UV-cured
'•" ' —
Substrate
OPP
LDPE, PE/EVA
LDPE, PE/EVA
OPP
OPP
OPP, LDPE, PE/EVA
OPP, LDPE, PE/EVA
LDPE (no slip) 	
Site
1
2
3
4
9A
6
8
11
Power output (kW)

6.4
1.9
4.0
3.0
ND
11.0
2.2
n/ab
===^ — i

NDa
ND
4.0
3.0
ND
ND
ND
n/a
                INU. MU uaia
                n/a: not applicable; Site 11 did not have a corona treater.
               UV Curing Systems
               Lamp energy estimates for either press speed were obtained at 160 watts/cm of press
               width, 174 watts/cm, and 185 watts/cm. Larger differences were seen in the supplemental
               lamp cooling estimates, which ranged from 25 kW to 90 kW.  The smaller value is for a
               water-cooled system; reportedly, most UV lamp systems are air-cooled.27


 6.3 ENVIRONMENTAL IMPACTS OF ENERGY REQUIREMENTS

               The energy requirements of the solvent-based, water-based and UV ink systems presented
               in Section 6.3 result in energy  costs to printers (see Chapter 5, Cost).  Environmental
               releases from energy production also result hi indirect costs to society. Examples of the
               types of pollutants released during energy production include carbon dioxide (CO2), sulfur
               oxides (SOX), carbon monoxide (CO), sulfuric acid (H2SO4),  and particulate matter. The
               potential environmental and human health impacts of these releases include health effects
               to humans and wildlife, global warming, acid rain, and photochemical smog. For more
               information on the potential impacts of printing on society, see Chapter  8 Choosing
               Among Ink Technologies.

               This section quantifies the types  and amounts of pollutants released into the environment
               from energy production and discusses the potential environmental impacts of the pollutant
               releases. For electrical energy, pollutants are typically released at electrical power plants
               outside the printing facility. Releases from natural gas combustion may occur at the print
               shop where the combustion process occurs.
PUBLIC COMMENT DRAFT
                                            6-22
                                                                             September 2000

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CHAPTER 6
                                                   RESOURCE AND ENERGY CONSERVATION
       Emissions from Energy Production

              The emissions from energy production during the performance demonstrations were
              evaluated using a computer program developed by the EPA National Risk Management
              Research Laboratory.28 This program, which is called P2P-version 1.50214, can estimate
              the type and quantity of pollutant releases resulting from the production of energy, as long
              as the differences in energy consumption and the source of the energy used (e.g., hydro-
              electric, coal, natural gas, etc.)  are known.   The program compares  the pollution
              generated by different processes (e.g., extraction and processing of coal or natural gas for
              fuel).

              Electrical power derived from the average national power grid was selected as the source
              of electrical energy, while natural gas was used as the source of thermal energy for this
              evaluation.  Energy consumption rates per 6,000 ft2 from Table 6.11 were  used as the
              basis for the analysis.

              Results of this analysis are presented in Table 6.18. Appendix 6-C contains printouts from
              the P2P program. Water-based systems generally had the lowest levels of pollutants from
               energy production at either press speed,  followed  by solvent-based systems.  The
              pollutants associated with the production of energy for the UV ink system exceeded those
               from water-based or  solvent-based  systems ,for  every pollutant  category  except
               hydrocarbons. Hydrocarbon emissions were greater for the water-based and solvent-based
               systems, because of  the natural gas consumed by the hot-air dryers used with these
               systems. Greater emissions from energy production were seen at lower press speeds for
               all of the systems, due to the longer run times needed to print a given quantity of substrate.
               However, as noted in Section 6.2, no data were available to estimate the differences in
               energy draw at  different press speeds.   Emissions from energy production would be
               reduced if equipment powers down at decreased press speeds.
  PUBLIC COMMENT DRAFT
                                               6-23
September 2000

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-------
CHAPTER 6
                                                   RESOURCE AND ENERGY CONSERVATION
              The higher overall emissions for UV systems were due primarily to the differences in fuel
              mixes used by the three systems (both electrical and natural gas energy for water-based
              and solvent-based systems, as compared to electrical energy alone for UV).  The U.S.
              electric grid is mainly comprised of coal, nuclear, hydroelectric, gas and petroleum-fired
              power plants.  In 1997 the majority of U.S. electrical energy (57%) was produced from
              coal-fired generators,29 which tend to emit greater quantities of pollutants than gas-fired
              energy  systems. For example, at a 500 fpm press speed, the UV system consumed an
              estimated 23 kW-hr /6,000ft2 of electricity, which is equivalent to 78,000 Btu/6,000ft2.
              At the  same press  speed, the solvent-based system consumed an estimated 6.6 kW-
              hr/6,000ft2 of electricity plus 78,000 Btu/e.OOOft2 of natural gas, for a total of 100,000
              Btu/e^OOft2 .  However, although the UV system consumed less overall energy than the
              solvent-based  system,  it  still  had higher emissions  from energy production for the
              pollutants evaluated, except hydrocarbons.

        Environmental Impacts of Energy Production

               Table 6.19 lists the pollution categories, pollutant classes, and media of release assigned
               by the P2P software. Table 6.20 lists total pollution generated by pollutant category and
               class, and Table 6.21 provides totals for each pollution category.

               Based on the pollutant loadings shown in Tables 6.21 and 6.22, the water-based systems
               showed the lowest potential environmental impacts from energy production, including
               human health, use impairment, or disposal capacity impacts, followed by solvent-based
               systems.  The UV systems had the greatest potential environmental impacts from energy
               production in each of the  pollution categories and classes.

        Limitations and Uncertainties

               These pollutant loadings can only be used as indicators of relative potential impacts, not
               as an assessment.of risk. Assessing risk from  energy production also would require
               knowledge of the location and concentration of release, and  proximity to surrounding
               populations.  It would also require more information on the specific chemicals emitted,
               for example the exact identity of the hydrocarbons emitted during natural gas combustion'
               as compared to the hydrocarbons emitted during  coal combustion.

               The potential environmental impacts of energy requirements for the three ink systems are
               based  on the  energy  estimates described in Section 6.2 and are subject to  the same
               limitations and uncertainties.
  PUBLIC COMMENT DRAFT
6-25
                                                                                September 2000

-------
  CHAPTER 6
                                                       RESOURCE AND ENERGY CONSERVATION
                           Table 6.19 Pollution Categories, Classes and Media of Release
Pollution Category _,
Human Health Impacts
Use Impairment Impacts

Disposal Capacity Impacts
Pollutant Class
Toxic Inorganics3
Toxic Organics3
Acid Rain
Precursors
Corrosives
Dissolved Solids"
Global Warmers
Odorants
Particulates0
Smog formers
Solid Wastes
Pollutants
Nitrogen oxides,
sulfur oxides
Carbon monoxide
Nitrogen oxides,
sulfur oxides
Nitrogen oxides,
sulfur oxides
Sulfuric acid
Dissolved solids,
sulfuric acid
Carbon dioxide,
nitrogen oxides
Hydrocarbons
Particulates
Carbon monoxide,
hydrocarbons,
nitrogen oxides
Solid Wastes
Affected
Air
Air
Air
Air
Water
Water
Air
Air
Air
Air
Soil,

                b Toxic organic and inorganic pollutants can cause adverse health effects in humans and wildlife
                 Paniculate releases can promote respiratory illness in humans.
               The program uses data reflecting the national average pollution releases per kilowatt-hour
               derived from particular sources.  It does not account for differences in emission rates at
               different power plants,  nor does it necessarily account for the latest in pollution cpntrol
               technologies applied to power plant emissions.

               The P2P program primarily accounts for emissions of pollutant categories and not emissions
               of the individual chemicals or materials known to occur from energy production, such as
               mercury.  Nor does it provide information on the spatial or temporal characteristics of
               releases. Thus, the P2P software provides emissions estimates in grams per functional unit
               (grams per 6,000ft2 of printed surface, in this case) and assigns them to pollution (impact)
               categories and classes rto develop pollutant loadings by impact category.  As discussed
               previously,  these pollutant loadings can be used as an  indicator of relative potential
               environmental impacts, but are not an assessment of risk.
PUBLIC COMMENT DRAFT
                                              6-26
                                                                               September 2000

-------
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  CHAPTER 6
                                                     RESOURCE AND ENERGY CONSERVATION
                             Table 6.21 Summary of Pollution Generated by Category
Pollution
Category
Human Health
Impacts
Use Impairment
Impacts
Disposal
Capacity
Impacts
GvenajJ
.IHylropment

Solvent
(500 fpm)
79
9,500
570
10,000
Pollution Generated •
(g/per 6,000ft2)
Solvent
(453 fpm)
87
10,000
630
11,000
Water
(500 fpm)
48
6,500
340
6,800
Water
(394 fpm)
60
8,100
410
a.S.00
uv
230
16,000
2,000
18,000
UV
350
24,000
2,900
27,000

 6.4  CLEAN-UP AND WASTE DISPOSAL PROCEDURES

                This section of Chapter 6 discusses the types of cleaning solutions and clean-up methods
                used for the three different flexographic ink technologies studied in the CTS A performance
                demonstrations,  and describes the disposal procedures for the various types of wastes
                generated in each case.

                All flexographic printing operations result in waste ink and substrate, soiled shop towels,
                and cleaning solutions that need to be disposed. However, the volume of waste ink and
                the specific chemical makeup of wastes differ, depending on the type of ink system that
                a printer uses. Therefore, the clean-up methods, waste disposal procedures, and overall
                environmental impacts of a printing process also differ for each ink system.

               Most printers employ the same basic procedures to clean solvent-based or water-based ink
               from a press.  Excess ink may be wiped or scraped down and drained from the press. The
               system is then flushed with a cleaning solution to remove additional ink and prepare the
               press for a fresh run. Shop towels, usually wetted with a cleaner, are used to wipe down
               the  anilox rolls,  doctor blades, or other press parts.  UV ink cleaning procedures are
               similar, except that different cleaners or dry shop towels may be used to wipe down the
               press.

               Most solvent-based  ink wastes are classified  as hazardous  waste  and are disposed of
               accordingly. Water-based ink wastes, however, may or may not be classified as hazardous
               waste, depending on the solvent content. Though solvent-based waste disposal costs may
               be reduced because it can be burned and used for heat production, this is not possible with
               water-based wastes.  Therefore, some printers using low-solvent water-based inks use an
               "ink splitter" to separate the solids from fluids in their waste ink and cleaning solutions.
               This substantially reduces  the amount of hazardous waste that needs to be disposed. The
               waste water usually can be reused in-house or discharged to the public water system, but
               if the original waste qualified as hazardous, the solids also will need to be treated as
               hazardous waste.  (See the  Control Options section of Chapter 7 for more information on
               ink splitters.)
PUBLIC COMMENT DRAFT
                                             6-28
                                                                              September 2000

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CHAPTERS
                                                   RESOURCE AND ENERGY CONSERVATION
              Multi-day runs of UV-cured printing may generate less ink waste than solvent-based or
              water-based printing for printers who shut down overnight, such as some smaller printers.
              In this case, the ink can remain indefinitely on the press or in the reservoirs without curing
              on press parts or the sump.3b The press is shut down, the ink reservoirs should be covered
              to prevent dust from getting in, and the press is turned on to resume printing the next day.
              Also, because correct color adjustment is achieved more quickly at the beginning of a UV
              run using process colors on dedicated stations, under these  conditions UV may generate
              somewhat less waste of ink and substrate. However, because UV inks are too thick to be
              modified easily, correct color adjustment may not be achieved more quickly when using
              matched/Pantone colors that require toning.31

        Press Clean-Up and Waste Reduction in the CTSA Performance Demonstrations

               Table  6.22  summarizes  the  types of  cleaning solutions  used  at the  performance
               demonstration sites. For solvent-based systems, three sites utilized a blend of alcohol and
               acetate solutions, and one  site reported using alcohol alone. The cleaning solutions used
               for UV-systems were the same as those for solvent-based systems, except for one site that
               used an alcohol/water/soap blend. Water, at times mixed with a little alcohol  and/or
               ammonia,  was used for clean-up  of the water-based ink systems.
                    Table 6.22 Cleaning Solutions Used at Performance Demonstration Sites
Ink System
Solvent-based
Water-based
UV-cured
Cleaning Solution
Alcohol/acetate blend ( 3 sites)
Alcohol (1 site)
Water only (2 sites)
Water/alcohol blend (1 site)
Water/ammonia blend (1 site)
Water/ammonia/alcohol blend (1 site)
Alcohol (1 site)
Alcohol/acetate blend (1 site)
Alcohol/water/soap blend (1 site)
                The clean-up and waste disposal procedures employed at the performance demonstration
                sites are summarized in Table 6.23.  Appendix 6-B describes these procedures in more
                detail.  All but one site  employed reusable shop towels to clean the press.  All sites
                recycled some or all of their waste substrate.
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  CHAPTER 6
                                             RESOURCE AND ENERGY CONSERVATION
                    Table 6.23 Clean-up and Waste Disposal Procedures at Performance
                                       Demonstration Sites
Ink System
Solvent-based
Water-based
UV-cured
Shop Towels
Sent to industrial
laundry (3 sites)
Landfilled ( 1 site)
Sent to industrial
laundry (5 sites)
Sent to industrial
laundry (2 sites)
No data (1 site)
-==========
Ink and Cleaning Solution
Disposition
Solvent mix to cement kiln (1 site)
On-site distillation; still bottoms to
cement kiln (1 site)
Reused 3 times then disposed as
hazardous waste (1 site)
No data (1 site)
Mixture incinerated (2 sites)
Separated water and solids;
incinerated solids (2 sites)
Diluted mixture and discharged to
POTW(lsite)
Reused once before sending to
cement kiln (1 site)
On-site distillation; still bottoms
disposed (1 site)
No data (1 site)
=======
Waste
Substrate
Partially or all
recycled
(4 sites)
Partially or all
recycled
(5 sites)
Partially or all
recycled
(3 sites)
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                                                                 September 2000

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CHAPTER 6
                                                  RESOURCE AND ENERGY CONSERVATION
REFERENCES


1.     Barnard, Harris. 1998a. Kidder, Inc. Personal communication with Lori Kincaid, University
       of Tennessee Center for Clean Products and Clean Technologies.  April 24, 1998.

2.     Barnard, Harris. 1998b. Kidder, Inc. Personal communication with,Lori Kincaid, University
       of Tennessee Center for Clean Products and Clean Technologies.  April 30, 1998.

3.     Ibid.

4.     Ibid.

5.     Ibid.

6.     Barnard, Harris. 1998d.  Kidder, Inc.  Personal communication with Lori Kincaid, University
       of Tennessee Center for Clean Products and Clean Technologies. May 12,  1998.

7.     Reschke, Darren.  1998. MEGTEC Systems [formerly Wolverine (Massachusetts)
       Corporation]. Personal communication with Lori Kincaid, University of Tennessee Center for
       Clean Products and Clean Technologies.  May 18, 1998.

 8.     Ibid.

 9      Foundation of Flexographic Technical Association.  1999. Flexography: Principles and
        Practices, 5th ed. Volume 3. Ronkonkoma, NY: Foundation of Flexographic Technical
        Association.

 10.    Kottke, Lee. Anguil Environmental Systems, Inc. Personal communication with Trey Kellett,
        Abt Associates. August 2, 2000.

 11.    Bemi, Dan and Steve Rach. MEGTEC Systems. Personal communication with Trey Kellett,
        Abt Associates. July 14, 2000.

 12.    Enercon Industries Incorporated. Not dated. "Corona Treatment,"
        http://www.enerconind.com/surface/papers/overview.

 13.    Flathmann, Kurt.  1998a. Fischer & Krecke, Inc. Personal communication with Lori Kincaid,
        University'of Tennessee Center for Clean Products and Clean Technologies.  June 1, 1998.

  14.    Flathmann, Kurt.  1998a. Op. cit. June 1, 1998.

  15.    Ibid.

  16.    Barnard, Harris.  1998c.  Kidder, Inc.  Personal communication with Lori Kincaid,  University
         of Tennessee Center for Clean Products and Clean Technologies. May 1,  1998.

  17.    Ibid.

  18.    Ibid.
  PUBLIC COMMENT DRAFT
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September 2000

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   CHAPTER 6

   19.    Ibid.

   20.
                                            RESOURCE AND ENERGY CONSERVATION
  21.

  22.


  23.


  24.

  25.

  26.
 28.


 29.


 30.


 31.
 Kottke, Lee.  1998.  Anguil Environmental, Inc. Personal communication with Lori Kincaid
 University of Tennessee Center for Clean Products and Clean Technologies.   May 8, 1998. '

 Reschke, Darren.  1998.  Op. cit. May 18, 1998.

 Smith, Alan.  1998.  SOA International, Inc.  Personal communication with Lori Kincaid
 University of Tennessee Center for Clean Products and Clean Technologies.  June 3, 1998.

 Gilbertson, Tom.  1998.  Enercon Industries, Inc.  Personal communication with Lori Kincaid
 University of Tennessee Center for  Clean Products and Clean Technologies.  May 18, 1998.  '

 Smith, Alan. 1998. Op. cit. June 3, 1998.

 Gilbertson, Tom.  1998.  Op. cit. May 18, 1998.

 Markgraf, David.  1998.  Enercon Industries, Inc.  Personal communication with Lori Kincaid
 University of Tennessee Center for Clean Products and Clean Technologies. May 11, 1998.  '
 27.    Flathmann, Kurt.  1998b. Op cit. June 3, 1998.
 U.S. EPA. 1994. P2P-Version 1.50214 computer software program.  Office of Research and
 Development, National Risk Management Research Laboratory.

 Energy Information Administration. 1999. Electric Power Monthly, February 1999 (with data
 for November 1998), DOE/EIA- 0223(99/02).

 Ross, Alexander.  1999.  RadTech. Personal communication with Trey Kellett Abt
 Associates. June 9, 1999.

Shapiro, Fred. 2000. P-F Technical Services. Personal communication with Lori Kincaid
University of Tennessee Center for Clean Products and Clean Technologies.  February 22,
PUBLIC COMMENT DRAFT
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                                                                           September 2000

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CHAPTER?
                                               ADDITIONAL IMPROVEMENT OPPORTUNITIES
           Chapter 7: Additional Improvement Opportunities
                               CHAPTER CONTENTS
7.1 POLLUTION PREVENTION OPPORTUNITIES  	7'3
 7.2 RECYCLING AND RESOURCE RECOVERY
       Silver Recovery	
       Solvent Recovery  	
       Solid Waste Recycling  	
 7.3 CONTROL OPTIONS
 7-8
 7-8
 7-8
 7-8

 7-9
        Sources of Flexographic Ink Pollutants Amenable to Treatment or Control Options   	7-9
        Control Options and Capture Devices for Air Releases  	7-10
        Control Options for Liquid Releases	
7-12
 REFERENCES
                                                                                      7-14
                                     INTRODUCTION

 This chapter discusses some techniques beyond alternative ink systems and printing processes that
 flexographic printers can use to prevent pollution, reduce chemical consumption, and minimize waste. This
 chapter includes sections on pollution prevention, recycling and resource recovery, and control options.

 Pollution prevention, also known as source reduction, involves reducing or eliminating environmental
 discharges at their source (that is, before they are generated). Pollution prevention requires taking active
 steps to implement changes in workplace practices, technology, and materials, such as the type of ink
 used. By reducing the amount of waste produced in the first place, disposal and compliance issues are
 minimized.  Each step in the printing process offers opportunities for pollution prevention.  Flexographic
 printers may be able to receive several benefits from following pollution prevention practices,  including cost
 savings, improved productivity, better product quality, reduced health risks to workers, reduced pressures
 of regulatory compliance, and of course reduced environmental impacts. Pollution prevention is discussed
 in Section 7.1.

 Recycling, which is also sometimes called resource recovery, is the focus of Section 7.2. Although recycling
 is not pollution prevention, since it does not reduce the amount of pollution being generated, it too has
 benefits for flexographers, including reductions in the need for new materials and for solid waste disposal.
 Thus, recycling can help printers  reduce the costs of doing business. Silver, solvents, and many solid
 wastes can all be recycled.
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                                                  ADDITIONAL IMPROVEMENT OPPORTUNITIES
  In addition, several pollution control options are possible for both liquid and gaseous forms of flexographic
  ink chemicals. Section 7.3 discusses several common control options.  These technologies can be very
  successful in reducing waste and emissions in the flexographic industry. Control options that are discussed
  in Section 7.3 include oxidizers, adsorption systems, permanent total enclosures (capture devices thatwork
  with control options but do not destroy harmful emissions by themselves), and ink splitters. Control options,
  however, often require a major capital investment, and must receive regular maintenance to function
  efficiently. Also, even control options that destroy virtually all harmful emissions have no effect on the types
  and amounts of chemicals being purchased and used by flexographic printers. That is, they do not prevent
  pollution from being generated.
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CHAPTER?
                                                 ADDITIONAL IMPROVEMENT OPPORTUNITIES
7.1  POLLUTION PREVENTION OPPORTUNITIES

               Pollution  prevention,  also  known  as  source  reduction,  reduces  or  eliminates
               environmental discharges at their source - that is, by avoiding their creation.  Pollution
               prevention can be achieved by  changing  workplace  practices,  substituting safer
               alternatives for harmful chemicals, and modifying equipment to reduce waste. In addition
               to reduced environmental impacts, pollution prevention may yield the following benefits:

                   •   cost savings
                   •   improved productivity and product quality
                   •   minimized risks to worker health
                   •   reduced pressures of regulatory compliance

               A strategy to prevent pollution should be customized to fit each printer's objectives and
               production process. The first step is to construct a process flow diagram that identifies
               each stage of the production process.  The next step is to consider the inputs and outputs
               of each process stage.  Once the inputs and outputs are identified, waste streams can be
               prioritized and the source of those waste streams can be targeted. Pollution prevention
               options that target these inputs can then be implemented to reduce or  eliminate the
               corresponding waste stream.

               Pollution prevention requires commitment from both management and employees. While
               management action is required for process changes, employees - who are closest to the
               process - often are best placed to identify pollution prevention alternatives. Pollution
               prevention involves taking a proactive stance and frequently reviewing the production
               processes to find new and better ways of doing  business. Figure 7.1 lists the specific
 	  process  steps in the  three major  stages of the  flexographic  printing process where
                pollution prevention opportunities exist.

                Table 7  1 expands upon Figure  7.1  by identifying  and describing specific pollution
                prevention opportunities. Each  of the major stages of the printing process provides many
                opportunities to  increase efficiency and  potentially save money while improving and
                maintaining performance standards.  Facility-wide opportunities to practice pollution
                prevention are included at the end of the table. Also, two case studies and a video that
                further describe pollution prevention activities in the flexography industry are available
                from the U.S. EPA. Complete ordering information is provided at the end of this chapter.
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   CHAPTER 7
                                                  ADDITIONAL IMPROVEMENT OPPORTUNITIES
                       Figure 7.1 Traditional Process Steps in Flexographic Printing
                  Pre-Press
                             Printing
                                  Post-Press
1. Artwork and Product Design
2. Negatives and Color Proofs
3. Platemaking
4. Mounting and Proofing
5. Makeready
6. Printing
7. Cleaning
8. Laminating and Coating
9. Converting
                           Table 7.1 Pollution Prevention Opportunities
   Printing Stage
   Pre-Press
 Pollution Prevention
     Alternative
    =====
Computerized Design
                   Computerized Proofs
                  Photopolymer Plates
                  Photopolymer Plate
                  Washing —
                  Alternative Solvents
                    Description

                    ======	
Designing and editing the artwork using computer software
can reduce the amount of chemicals that the printer uses.
                      By using computers to generate graphics and negatives
                      printers can skip the photographic developing stage of the
                      process, thereby eliminating the use of darkroom
                      chemicals.
                     Use of traditional nitric acid baths to etch designs into
                     metal plates may generate wastewater that is low in pH
                     and high in metal content, requiring regulation under the
                     Clean Water Act (CWA). Printers can eliminate this waste
                     stream by switching to photopolymer plates. Use of
                     Photopolymer plates also eliminates the metal engravings
                     and wastes generated from the production of conventional
                     molded rubber plates. These wastes may be subject to
                     Resource Conservation and Recovery Act (RCRA) and
                     Toxic Release Inventory (TRI) reporting.
                     Perchloroethylene, a Hazardous Air Pollutant (HAP), is
                     traditionally used in photopolymer plate washing. To avoid
                     hazardous waste regulations, printers may be able to use
                     alternative cleaners such as-citrus-based terpene solvents
                     n many cases, substitutes have performed satisfactorily
                     although slower processing times have sometimes been'
                     noted. However, there are some concerns about the
                     quality and durability of the photopolymer plates made with
                     hese alternative solvents.1
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                                                                           September 2000

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iHAPTERT
                                                ADDITIONAL IMPROVEMENT OPPORTUNITIES
                   Table 7.1  Pollution Prevention Opportunities (continued)
 Printing Stage    Pollution Prevention
                      Alternative
                                           Description
 Printing
Containing Volatiles
                 Monitoring and
                 Maintaining Ink
By keeping all cans, drums, and open ink fountains
covered, printers can reduce odors and worker health risks
by minimizing fugitive VOC emissions.	
                  Installing Enclosed
                  Doctor Blade
                  Chambers
                       By regularly monitoring pH and viscosity of the ink during a
                       press run, printers can reduce the downtime and amount
                       of additives needed to optimize print quality.	
                       Enclosed doctor blade chambers reduce ink evaporation
                       for better control of ink usage, more consistent color, and
                       improved performance of the inks on press. The system
                       reduces the amount of diluent that will evaporate during
                       operation, allowing the press operator to have better
                       control of the ink being transferred.  By switching from an
                       open fountain, the enclosed system also minimizes VOC
                       emissions and worker exposure to VOCs.   	
                  Printing a Thinner Ink
                  Film Thickness
                  Reworking Press
                  Return Ink
                   Computerized Ink
                   Blending
                       Printers can increase efficiency by printing a thinner ink
                       film thickness. While this may require some changes, a
                       thinner ink film allows for faster drying times and higher
                       press speeds. To print a thinner film, printers may need to
                       minimize the anilox roll cell volume, use ink that has a high
                       pigment loading, and install doctor blades.   	
                        Reworking press return ink can increase efficiency, reduce
                        ink purchases, and reduce hazardous waste if
                        contamination issues can be addressed. Ink can be
                        reworked by blending press return ink with virgin ink of the
                        same color, mixing press return ink with virgin ink to make
                        new colors, and mixing press return ink with other colors to
                        make black ink.                                   	
                   Four-Color Printing
                        Software and equipment are available that can help
                        printers blend ink, reduce surplus ink, and reuse press
                        return ink.                                 	
                   Co-Extruded Film
                        The limited number of inks in four-color process printing
                        can minimize the amount of mixed colored inks used and
                        eliminate residues of unusual colors at the end of each job.
                        With the new chambered doctor blade systems, the
                        increased use of process printing to produce a broad
                        spectrum of colors has become more easily attainable.
                        Films can be co-extruded to have panels of color in a clear
                        field.  This has been done for bread bags and garment
                        bags. White panels are extruded into the clear film.
                        Printing is accomplished without the need to lay down a
                        heavy coverage of white ink.	
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   CHAPTER 7
                                                    ADDITIONAL IMPROVEMENT OPPORTUNITIES
   | Printing Stage    Pollution Prevention
                         Alternative
  Table 7.1 Pollution Prevention Opportunities (continued)
                                           ======
                                           Description
    Printing
Methanol Substitution
One of the most commonly used chemicals in printing is
methanol, which is a HAP.  Methanol is relatively
inexpensive but has a high  evaporation rate, so that a
great deal of it may be used during a print run.  Also,
because of its high evaporation rate  and classification as a
HAP, the emission of methanol if strictly regulated.  Many
printers have been able to substitute isopropyl alcohol (a
less volatile compound) for  methanol in their solvent
blends.
                    MEK and MIBK
                    Substitution
                   Running Lighter Color
                   Jobs First
                      Methyl ethyl ketone (MEK) and methyl isobutyl ketone
                      (MIBK), both HAPs, are used in very minute quantities as
                      denaturants. These can be removed from ethanol blends
                      without any loss of performance characteristics.
                   Wash Tubs
                      By running lighter jobs before darker jobs, printers can
                      reduce the number of necessary clean-ups.
                   On-Press Cleaning
                      Cleaning of rollers, doctor blade components, pumps, and
                      other removable parts of the ink train can be accomplished
                      in covered wash tubs with a relatively small quantity of
                      cleaning solution. The solution can be either a slow-
                      evaporating, penetrating solvent or a caustic solution It is
                      helpful to squeegee parts before dipping them into the
                      wash tubs to remove excess inks. Wash tubs generate far
                      less hazardous waste than traditional hand-cleaning.
                  Multi-Stage Cleaning
                  With Solvents
                     Automatic, on-press cleaning systems are being
                     developed.  One current model features a built-in air jet
                     spray system to clean the doctor blade assembly and
                     anilox roll, using much less cleaning solution than hand
                     cleaning in a very short cycle time.
                     Solvent use can be reduced by using a multi-stage
                     cleaning procedure for the printing decks.  This procedure
                     reduces solvent use by reusing solvents that are otherwise
                     discarded. Pre-used solvent is used in the first stage to
                     remove the majority of the ink.  In the second stage a
                     cleaner but still pre-used solvent is employed to  remove
                     more ink.  In the third stage, clean solvent removes any
                     remaining ink. Once the solvent in the first stage becomes
                     too dirty, it is discarded and is replaced by the solvent from
                     the second stage. The third stage solvent is then used in
                     the second stage, and virgin solvent is used in the third
                     stage.
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CHAPTER
                                                 ADDITIONAL IMPROVEMENT OPPORTUNITIES
                    Table 7.1  Pollution Prevention Opportunities (continued)
 [printing Stage  | Pollution Prevention
                       Alternative
  Printing
  Post-Press
  Facility-Wide
Using Alternative
Methods to Clean
Anilox Rolls
Material Substitution
                     Description

                    ===^=
Printers can choose among many alternative options for
cleaning anilox rolls to reduce or eliminate the need for
traditional cleaning solvents. These alternatives use dry
ice, lasers, polyethylene beads, or sodium bicarbonate.
                  Solventless Adhesives
Solvent-based coatings and adhesives can be replaced
with water-based ones, minimizing VOC emissions.
                       The use of solventless adhesives reduces VOC emissions.
                  Safer Cleaning
                  Solvents
 Segregate Hazardous
 Waste
                   Returnable Containers
                       Replacing traditional cleaning solvents with safer cleaning
                       solvents reduces risks to worker health and VOC
                       emissions.
 Segregating hazardous wastes allows disposal of pure
 instead of mixed wastes. Because pure wastes are much
 easier to treat than mixed ones, they are not only less
 expensive to dispose of, but also require less energy.
                   Inventory Tracking
                       Using returnable containers prevents unnecessary waste
                       generation and results in additional cost savings.	
                   Monitor Employee
                   Practices
                   Management
                   Commitment
                       Tracking chemical purchases and disposal can help to
                       maintain a minimum inventory on the shelf, thus reducing
                       the amount of materials wasted.  For example, hazardous
                       waste can be minimized by labeling inks with the date and
                       having a "first-in, first-out" rule, i.e., rotating the inks so that
                       the oldest inks are used first. This avoids disposing of
                       expired ink as hazardous waste. Tracking systems using
                       bar codes take inventory control to an even higher level.
                        Periodic monitoring helps ensure that source reduction
                        practices are followed.	;    	
                        Management should establish, communicate, and
                        demonstrate their commitment to the concept of pollution
                        prevention, to encourage company-wide source reduction
                        in everyday practice. Management can assemble pollution
                        prevention teams of employees, incorporate pollution
                        prevention into job responsibilities, and provide incentives
                        for employees to prevent pollution.	
                    Acknowledge
                    Employee Initiatives
                        Positively acknowledging pollution prevention initiatives by
                        company personnel can stimulate innovative ideas for
                        source reduction.  This may be especially beneficial
                        because employees who are closest to the process are
                        often in the best position to recommend change.	
                    Training
                         Pollution prevention training for company personnel may
                         facilitate process changes by educating workers on the
                         need for such change. Training also helps to encourage
                         general source reduction and stimulate pollution
                         >revention ideas by personnel.
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  CHAPTER 7
                                                   ADDITIONAL IMPROVEMENT OPPORTUNITIES
  7.2 RECYCLING AND RESOURCE RECOVERY

                Recycling (also known as resource recovery) helps reduce the need for virgin (never
                previously used) materials and lowers demand for solid waste disposal. Municipal and
                local governments  often  sponsor recycling  programs  and waste exchanges.   By
                incorporating recycling, flexographic printers may be able to avoid or reduce the costs
                of handling, permitting, shipping, and disposing of wastes, as well as the regulatory and
                legal liabilities and costs.

         Silver Recovery

                Silver in wastewater is toxic, and its disposal is regulated locally by publicly owned
                treatment works (POTWs). Silver is used for film development in pre-press operations.
                Printers can recover silver from the wastewater coming out of their imaging operations.
                There are three main methods for recovering silver: metallic replacement, electrolytic
                silver recovery, and ion exchange.

                Metallic Replacement
                Wastewater is passed through one or more steel wool filters in which silver is chemically
                replaced by iron.  The silver is collected in the form of sludge, which is then treated off-
                site to extract the usable metal.  This method is used in many pre-press and print shops,
                and is relatively inexpensive.

                Electrolytic Silver Recovery
                An electric current passes between two electrodes in silver-laden wastewater, plating the
                silver on the cathode in a virtually pure form.  The silver is easily removed from the
                cathode for reuse.  This system is more expensive to purchase and maintain than the
                metallic replacement system.  This is often used in conjunction with a steel wool filter.

               Ion Exchange
               Ion exchange can remove an extremely high percentage of silver, but  is only suitable for
               dilute solutions. In addition, this method requires a  greater capital investment and
               handling time than the other two methods.

        Solvent Recovery

               Flexographic printers who use solvent-based inks and cleaners can recover much of the
               solvent for reuse in the facility. A solvent recovery system captures VOC emissions, and
               uses a separation/distillation unit to separate, and collect the solvent. Recycled solvent
               sometimes needs further treatment before it can be reused. Recycled solvent is often used
               in cleaning operations and saves the printer the cost of buying virgin solvent.

        Solid Waste Recycling

               Flexographic printing operations generate solid waste that must be disposed of in landfills
               or incinerated. Printers have found that recycling solid waste can reduce shipping and
               disposal costs, and that items can be reused in the shop or by the supplier. Flexographic
               printers can reduce solid waste hi any of the following ways:
                  •   Require suppliers to take back all containers and packaging.

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CHAPTER?
                                                 ADDITIONAL IMPROVEMENT OPPORTUNITIES
                  •   Work with local government to establish recycling practices.

                  •   Choose materials (e.g., substrates) that can be recycled.

                  •   Minimize coatings that hinder recycling.

               Some specific examples of solid waste recycling include the following ideas:

                  •   Bale paper waste, corrugated cartons, and pallet tote boxes for recycling.

                  •   Return cores that are used to wind rolls of films, papers, and paperboard to the
                      supplier for  reuse.

                  •   Collect and return shrinkwrap films for recycling. Segregate plastics by type to
                      enable efficient reuse of the materials.

                  •   Clean and reuse cans, bottles, plastic jugs, drums and other containers.

                  •   Recycle  photographic chemicals and platemaking  chemicals.  Negatives and
                      photographic papers can be treated to recover silver.

                   •   Pelletize unusable rubber, photopolymer plates, and mixed substrate wastes (e.g.,
                      laminations  and pressure-sensitive materials) to use as alternative fuel at cement
                      kilns and power generation plants.

                   •  In some  states, printers can recycle components of fluorescent lamps, including
                      hazardous wastes like mercury.
 7.3 CONTROL OPTIONS

                Control technologies minimize the toxicity and volume of flexographic pollutants by
                destroying them or capturing them for reuse,  recycling, or disposal. Specific control
                option choices need to be based on many considerations, such as regulations, the facility's
                printing equipment, the ink systems and chemicals that  the facility uses, cost and
                performance needs, and risks to the safety and health of workers and the environment.

                Control systems can be costly, must be maintained, and have the potential to fail. Using
                chemicals that contain or generate pollutants  carries risks for  workers and the
                environment, and may present a public relations problem. Disposal of regulated wastes
                may require a printer to obtain status as a hazardous waste generator. The potential
                disadvantages  of control systems make it important for printers to  consider pollution
                prevention, which can reduce the need for control systems in flexographic facilities.

         Sources of Flexographic Ink Pollutants Amenable to Treatment or Control Options

                Pollutants that are related to flexographic printing inks and that can be mitigated using
                treatment or control options fall into several categories:
  PUBLIC COMMENT DRAFT,
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September  2000

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  CHAPTER?
                                                    ADDITIONAL IMPROVEMENT OPPORTUNITIES
                     •   Air emissions
                     •   Hazardous liquid wastes, especially solvents
                     •   Non-hazardous liquid wastes, including many waste inks, additives, and colored
                         wash-water

          Control Options and Capture Devices for Air Releases

                 All solvent-based and some water-based flexographic inks contain significant amounts of
                 volatile organic compounds (VOCs). Some flexographic inks also contain one or more
                 hazardous air pollutants (HAPs), as defined by the Clean Air Act.3

                 Several types  of control options" for handling air emissions related to working with
                 flexographic inks are currently  available and will be discussed in this section.   In
                 addition, a capture device such as a permanent total enclosure (PTE) may be installed in
                 conjunction with control options  and are part of  the overall control  efficiency.  Three
                 types of devices associated with emission control  are discussed in this section.

                    •   permanent total enclosures
                    •   oxidizers (thermal, catalytic, and regenerative)
                    •   adsorption systems

                 Capture Devices
                A permanent total enclosure (PTE) is a structure that captures all fugitive emissions from
                a source (e.g.,  a single  press  or an entire press room) and sends  them to  a
                destruction/recovery device. A PTE alone only captures emissions; it neither destroys
                them nor reduces their use, but is part of the overall control  efficiency or capture
                efficiency.  Because of this, a PTE is used in combination with an oxidizer, adsorption
                system, or biofiltration device, which separates or destroys VOCs.

                Regulations  controlling air emissions are expected to continue to be strict across the
                country for the foreseeable future. A  PTE is currently the only  capture tool that
                effectively captures 100%  of fugitive emissions.2  Because a  PTE is  a  permanent
                structure, only one demonstration inspection is required for a new PTE. Thereafter, as
                long as the facility continues to use the PTE in the same way without significant structural
                modifications, additional air inspections are not necessary.

                A specific method and criteria have  been set forth by EPA for constructing a PTE that
                will pass inspection. Depending upon the scope and size of the  work that  is needed,
               * Smaller amounts of ozone also may be generated by the use of corona treaters and UV lamps
               but ozone can be easily destroyed at the source by relatively inexpensive devices supplied (often
               with the primary equipment) by the manufacturer/distributor. Ozone that is destroyed
               immediately upon creation does not present an environmental concern.

               b Biofiltration, also known as bioremediation, is a currently experimental method of destroying
               VOCs. This technology uses microbes that eat and digest VOCs, breaking diem down into more
               environmentally benign chemicals. Biofiltration may hold promise for flexographic printing in
               the future, if the technology can be improved to enable reliable destruction of virtually all
               VOCs.
PUBLIC COMMENT DRAFT
                                              7-10
                                                                                September  2000

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CHAPTER 7
ADDITIONAL IMPROVEMENT OPPORTUNITIES
               construction of a PTE can be fairly modest, or it can involve a substantial capital
               investment ranging up to tens of thousands of dollars.3 The installation of a PTE also
               may involve compliance with local fire codes that designate the enclosed area as a
               hazardous area (H occupancy) and require steps or devices such as emergency ventilation,
               fire  containment (fire walls and doors), an  emergency  egress route, and  spill
               containment.4  However, since most of the cost relates to capital and construction rather
               than operation and maintenance, hi the long run some printers may find a PTE to be quite
               economical.

               A well-designed PTE captures all fugitive emissions and eliminates fugitive air emissions
               to the local community. In addition, some printers may be able to benefit economically
               from PTEs, as more areas introduce the use of transfer credits for air emissions. Because
               a PTE guarantees 100%  capture  efficiency, printers in areas that require  a lower
               percentage of capture efficiency may be allowed  to sell or trade their credits.5 For all
               these reasons, PTEs are expected to continue to be an important method of controlling
               fugitive air emissions for flexographic printers.

               Oxidizers
               Oxidizers burn air that contains VOCs and sometimes other pollutants generated in
               flexography. An oxidizer breaks down VOCs into water, carbon dioxide, and other gases.
               Oxidation works by mixing the emissions  from the press exhaust with oxygen and heat.
               There are several types of oxidizers, including catalytic, thermal, thermal recuperative,
               and regenerative oxidizers. All types of oxidizers have the potential to  achieve virtually
               complete destruction of VOCs.  Straight thermal oxidizers require high operating
               temperatures (typically at least 1600°F), whereas thermal recuperative oxidizers recover
               much of the waste heat from exhaust gases and thus are more economical.  Catalytic
               oxidizers can operate at lower temperatures than thermal types (up to about  1250°F) and
               use less fuel. Regenerative oxidizers may be either thermal or catalytic, as defined
               above.6

               Catalytic oxidizers are more common in the flexographic printing industry than are
               thermal oxidizers; however, recent technical advances in thermal systems may make these
               appropriate for some printers.7 Because of their lower operating temperatures, catalytic
               oxidizers create a very low percentage of NOx (nitrogen oxide) emissions0 compared to
               thermal oxidizers. However, catalytic oxidizers  may not be  effective in treating gases
                from certain silicone ink additives, because silicone masks or poisons  the catalyst.8

                Oxidizers usually involve a significant capital and installation investment, as well as
                substantial operating expenses.   The total capital cost of an oxidizer can range from
                $150,000 to $400,000 or more, depending upon the size and needs of the facility. •  •  •
                Energy consumption considerations for catalytic oxidizers are discussed in Chapter 6.

                Adsorption Systems
                These devices contain a bed of activated carbon, zeolite (an aluminum-silicate crystal),
                or polymers. This substance attracts VOCs, which adsorb (concentrate) on  the surface of
                the medium. Adsorption separates but does not destroy VOCs. The  air that  no longer
                contains VOCs then can be released, and the VOCs can be reused or recycled. A typical
                 : Nitrogen oxides are ozone precursors.
  PUBLIC COMMENT DRAFT
                                                                                September 2000

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  CHAPTER 7
                                                   ADDITIONAL IMPROVEMENT OPPORTUNITIES
                adsorption system alone has the potential to remove 95% or more of VOCs,6 and is
                normally used in conjunction with a PTE to ensure virtually complete removal of VOCs.

                Carbon adsorption systems work most efficiently in capturing a single solvent or a very
                dilute stream of VOCs, and they are not necessarily compatible with all inks. Because
                flexography typically uses  a large number  of solvents,  carbon adsorption  was not
                appropriate for most printers at the time of publication of this CTSA.6

                The  costs of adsorbent systems ranges widely depending on a number of factors,
                including the type and size of the facility, the type of absorbent system, state regulatory
                requirements, and permitting issues. Systems can cost from several thousand to several
                hundred thousand dollars.  Also, since an adsorption system  is normally  used in
                conjunction with a PTE,  that cost must be considered as well.  For these  reasons, a
                meaningful cost range for this technology is beyond the scope of this document."1

        Control Options for Liquid Releases

                Flexographic facilities need to pay attention to three characteristics of liquid ink wastes:
                percentage  of solvents, turbidity (discoloration), suspended  solids, and  hazardous
                substances.

                The maximum solvent content allowed in wastewater is site-specific. For facilities using
                only water-based inks, if the percentage of petroleum-based solvents is below the level
                allowed by the facility's municipal wastewater facility (Publicly Owned Treatment Works,
                or POTW) or permit (if applicable), the liquid waste might not be regulated as hazardous
                waste. Facilities using only UV  inks typically will not have solvent-containing liquid
                wastes.

                For all types of inks, EPA considers discoloration of water to constitute "turbidity,"
                which is a pollutant category. Pigments and other discoloring substances may have to be
                removed before the water can be discharged to a POTW. Also, ink wastes may have
                other substances that are regulated as hazardous (e.g., metals) and must be removed
               before discharge. Please see Chapter 2, Federal Regulations, for more information on
               chemicals in this CTSA that may be regulated as hazardous wastes.

               Ink splitters are used to separate out the solids in wastewater.  The water then can be
               released to a POTW and the pigment-containing sludge sent to a landfill. The capital cost
               of an ink splitter  can range from several thousand dollars to more than $30,000, which
               can be offset by lower disposal costs and POTWS fees. The relatively low cost of ink
               splitters and their benefits in helping printers to comply with water emissions  standards
               can make this technology useful to many flexographers.
               d The U.S. EPA's Office of Air Quality Planning and Standards "EXPOS Control Cost Manual"
               (5lh Ed., February 1996, document EPA 453/B-96-001), provides detailed procedures, data, and
               equations for sizing and estimating capital and operating costs of thermal regenerative carbon
               adsorption systems.
PUBLIC COMMENT DRAFT
                                             7-12
                                                                              September 2000

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CHAPTER 7
                                               ADDITIONAL IMPROVEMENT OPPORTUNITIES
REFERENCES
1.     Shapiro, Fred. 1997. P-F Technical Services, Inc. Pollution Prevention for the Flexographic
       Printer.  Internal document for the Design for the Environment Flexography Project.

2.     Bemi, Dan, MEGTEC Systems. Personal communication, September 23, 1999.

3.     Mike Lukey, Pacific Environmental Science, cited in Bemi, Dan: Permanent Total Enclosure
       Technology Part 2. Flexo, April 1998, p 69.

4.     Mostafaei, Anooshehi "Environmental Corner." Die-Line. California Film Extruders &
       Converters Association. January 2000.

5.     Bemi, Dan, MEGTEC Systems. Personal communication, September 23, 1999.

6.     EPA-CICA: Air Pollution Technology Fact Sheets: Catalytic, thermal, recuperative, and
       regenerative incinerators.

7.     Rach, Steve, and Bemi, Dan: Emission controls. In The Flexo Environment (prepublication
       draft), June 11, 1999.

8.     Green, David A, and Northeim, Coleen M: Alternate VOC control technique options for small
       rotogravure and flexography facilities. EPA Publication 600-R-92-201, October 1992.

9.     Ellison, Dave. American National Can Company. Written comments to  Laura Rubin, Industrial
       Technology Institute. June 1997.

 10.    Rizzo, Tony. Lawson Marden Label. Telephone discussion with Laura Rubin, Industrial
       Technology Institute. May 22, 1997.

 11.     Steemer, Hans. Windmoller and Holscher. Telephone discussion with Laura Rubin, Industrial
        Technology Institute. May 6, 1997.

 12.     National Association of Printers and Lithographers. NAPL Heatset and Non-Heatset Web Press
        Operations Cost Study; 1989-1990. Teaneck, NJ, 1990.
  PUBLIC COMMENT DRAFT
7-13
                                                                             September 2000

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 CHAPTER 7
                                         ADDITIONAL IMPROVEMENT OPPORTUNITIES
                           This page is intentionally blank.
PUBLIC COMMENT DRAFT
                                     7-14
                                                                September 2000

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CHAPTER 8
                                                   CHOOSING AMONG INK TECHNOLOGIES
          Chapter 8: Choosing Among Ink Technologies
                               CHAPTER CONTENTS
 J.1 SUMMARY BY INK SYSTEM AND PRODUCT LINE	8-2
              Introduction 	8-2
              Solvent-based Inks  	8-14
              Water-based Inks	8-17
              UV-cured Inks  	:	8-2°

 8.2 QUALITATIVE SOCIAL BENEFIT-COST ASSESSMENT  ...	8-24
              Introduction to Social Benefit-Cost Assessment  	8-24
              Benefit-Cost Methodology and Data Availability  	8-26
              Potential Private and Public Costs  	8-26
              Potential Private and Public Benefits  	8-31
              Summary of Social Benefit-Cost Assessment	8-34

 8.3 DECISION INFORMATION SUMMARY 	8-36
              Introduction	8-36
              Ink System Comparison	8-37
              Highlights of Chemical Category Information	8-41
              Hazard, Risk and Regulation of Individual CTSA Chemicals  	8-46
              Suggestions for Evaluating and Improving Flexographic Inks  	8-63

 REFERENCES	8'66
                                    INTRODUCTION

 Earlier chapters of this CTSA presented the findings of the research regarding risk, performance, cost, and
 resource requirements.  This chapter takes a different look at some of that information.  Section 8.1
 summarizes the individual ink systems and product lines, using the solvent-based ink system as the baseline
 and providing comparisons to water-based and UV-cured inks.  Performance tests, environmental and
 health impacts, and resource conservation are discussed.

 Section 8.2 provides a qualitative social benefit-cost assessment of the different ink system, analyzing the
 private (printer) and social  implications of the CTSA findings.  Social costs and benefits are those that do
 not affect the flexographic facility directly, but that do affect the larger population and the environment. This
 viewpoint is one that is rarely considered within an industry setting.

 Section 8 3 compares the three ink systems broadly.  This section  describes the chemical categories
 analyzed in the CTSA, and identifies the hazards and risks of each chemicals. Flexographic professionals
 can use this information to identify chemicals that they either may wish to avoid or that they may to use as
 safer alternatives.
 PUBLIC COMMENT DRAFT
                                            8-1
September 2000

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  CHAPTERS
                                                       CHOOSING AMONG INK TECHNOLOGIES
  8.1  SUMMARY BY INK SYSTEM AND PRODUCT LINE

         Introduction

                The results of the DfE Flexography Project, as shown in this CTSA, present information
                about several important factors that contribute to the selection of a flexographic ink. The
                performance, human and environmental risk, and operational costs associated with an ink
                are issues that a printer must consider when choosing among ink technologies.  Though
                this research is not an exhaustive analysis of all flexographic inks, it provides an indication
                of how nine product lines of solvent-based, water-based, and UV-cured inks compare on
                wide-web film substrates. Individual printers will have conditions (and results) that vary
                from those encountered in this analysis, but the results in this report will be a starting point
                for determining how changes might affect the circumstances of a particular facility.  Ink
                formulators also may gain from this analysis by learning how  the  hazards posed by
                chemicals in isolation translate into health and environmental risks when the chemicals are
                placed in the context an ink mixture used in a printing facility.

                The DfE Flexography Project studied solvent-based, water-based, and UV-cured inks on
                three wide-web films:  low-density polyethylene (LDPE), co-extruded polyethylene/ethyl
                vinyl acetate (PE/EVA), and oriented polypropylene  (OPP).   For each type of ink,
                between  two and four specific product lines were tested.  Table  8.1 indicates which
                substrates were used with each product line.

                                  Table 8.1 Ink and Substrate Combinations
Product Line
Solvent-based #1
Solvent-based #2
Water-based #1
Water-based #2
Water-based #3
Water-based #4
UV-cured #1
UV-cured #2
UV-cured #3
Substrate
OPP
LDPE, PE/EVA, OPP
OPP
OPP
LDPE, PE/EVA
OPP
LDPE
LDPE, PE/EVA
PE/EVA
               The performance chapter (Chapter 4) discussed the results of 18 tests on the nine product
               lines that were studied hi the CTSA. Five of these tests were selected to highlight in this
               summary (Table 8.2).1  These  performance tests were  selected because they were
               measured for all three systems; they display a range of important ink properties; and they
               were minimally Dependent on external factors such as press equipment and operator
               expertise. Please see Chapter 4 for the results of the other performance tests.
PUBLIC COMMENT DRAFT
                                             8-2
                                                                                September 2000

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CHAPTER 8
                                                      CHOOSING AMONG INK TECHNOLOGIES
                         Table 8.2 Selected Key Performance Indicators
 Indicator      Description
                                                 Scale     Interpretation
  Blocking      Measures the bond between ink and substrate
                when heat and pressure are applied.  Ink transfer
                from a printed substrate to a surface in contact with
                the print indicates that blocking has occurred.
                                                 0-5       0 = no blocking
                                                           and a good ink-
                                                           substrate bond.
                                                           5 = complete
                                                           blocking or removal
  Gloss
Measures the reflected light directed at the surface
from an angle. The test was only performed on
LDPE and PE/EVA substrates, because gloss is
irrelevant on laminated substrates (such as the
OPP product in this project).     	
0-100     Higher numbers
          indicate higher
          reflectivity
  Ice Water     Measures the integrity and flexibility of the ink on
  Crinkle       the substrate when exposed to refrigerator and
                freezer conditions.  The sample was submerged in
                a container of ice water for 30 minutes, then
                removed and twisted rapidly 10 times.     	•
                                                 0-100     0 = intact ink finish
                                                           100 = complete
                                                           removal of finish
  Mottle        Measures the spottiness or non-uniformity of an ink
                film layer.
                                                 Open-    Lower values
                                                 ended    indicate a more
                                                           consistent finish.
                                                           Higher values
                                                           indicate a more
                                                           variable finish.
  Trap
 Measures the ability of an ink to adhere to an
 underlying ink. This trait is important where inks are
 printed on top of one another in .order to generate
 precise color hues.	
                                                                 0-100%   100% = ideal
                The operating cost information developed in this CTSA includes costs for materials,
                labor, capital,  and energy, calculated per 6,000 square feet of image based on the
                methodology press speed of 500 feet per minute.

                The energy consumption of each ink system is calculated per 6,000 square feet of image.
                Equipment included in this calculation includes hot air dryers, blowers, oxidizers, UV
                curing lamps, and corona treaters.

                The  results of the selected  performance tests  and the operating  cost  and energy
                consumption analyses are summarized in Table  8.3.   Data for these three categories are
                presented for each product line (e.g., solvent-based ink #1), and also are averaged across
                the whole ink system.  The solvent-based ink system is considered the baseline for this
                analysis; each water-based and UV-cured product line is compared to the baseline results
                in Table 8.3 through the use of ft  (better than the baseline) or  X (worse than the
                baseline).
  PUBLIC COMMENT DRAFT
                                                8-3
                                                                  September 2000

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 CHAPTER 8
                                                        CHOOSING AMONG INK TECHNOLOGIES
                Table 8.4 summarizes the human health risks of each product line. Three categories of
                information are included in this table.

                    •  Range of chemicals with clear risk:  This column shows the total number of
                       compounds with a clear health risk3 to pressroom workers for each formulation in
                       a product line.  For example, if two chemicals with clear risk were found in one
                       formulation of solvent-based #1, four were found in another formulation, and the
                       other three formulations had numbers  between these, the range would be 2-4.
                       This range incorporates compounds that are expected to pose clear occupational
                       risk to flexographers based on either toxicological studies or EPA's Structure
                       Activity Team (SAT) assessments.

                    •  Chemical categories with clear risk: Lists the chemical categories that presented
                       clear inhalation risk to pressroom workers and clear dermal risks to press- and
                       prep-room workers. Superscripts next to each category name indicate whether the
                       compounds presented a clear risk through inhalation (inhal) or dermal  (derm)
                       exposure. Categories are denoted with "(SAT)" if the compound with clear risk
                       was analyzed by the SAT. An SAT evaluation is considered to be a less accurate
                       measurement method than toxicological information. (See explanation in Chapter
                       3:  Risk.)

                    •   Toxicological endpoints: In toxicological tests,  researchers record observed
                       effects of the given chemical. These qualitative observations, called toxicological
                       endpoints,  indicate  effects  that  have  been associated  with compounds  in
                       formulations in each of the respective product lines. The information is separated
                       based on the exposure route, because  effects may be different depending on
                       whether a  compound  is absorbed  dermally or by  inhalation. Toxicological
                       endpoints can be useful for highlighting the scope of potential human health effects
                       of the ink systems.  The user of flexographic inks should be aware that the risk of
                       health effects may be present with any ink.  Toxicological endpoints provide an
                       indication of such potential effects, but only offer a broad perspective.  "Liver
                       effects," for  example, may range in significance from  liver enlargement to
                       cirrhosis or changes in liver cells that may lead to the growth of tumors. The first
                       effect may have little practical importance, but the latter may jeopardize survival.
                       The table does not indicate the seventy of effects, nor does  it imply that all of the
                       effects would be observed at the exposure levels in typical flexographic prep or
                      press rooms.

               Table 8.5 presents indicators of safety and environmental concerns associated with each
               product line.

                   •   Safety information: Three categories of safety hazards are included: reactivity,
                       flammability, and ignitability. Reactivity and flammability are based on scales of
                       0-4; 0 indicates that a compound is stable and will not burn, respectively, and 4
                       indicates that it is readily explosive or flammable.  Ignitability is characterized as
                       yes or no; a compound is ignitable if it has a flashpoint below 140°F.
               "Clear risk indicates that there is an inadequate level of safety for the chemical in question under the
               assumed exposure conditions, and that adverse effects can be expected. See Section 3.7 of the Risk chapter
               for more information about risk rankings.
PUBLIC COMMENT DRAFT
8-4
                                                                                  September 2000

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CHAPTER 8
       CHOOSING AMONG INK TECHNOLOGIES
                     Smog-related emissions: The flexographic printing process emits pollutants that
                     cause smog in two ways.  First, VOCs are released directly from the  ink
                     formulations as ink is applied to the substrate. Second, VOCs, nitrogen oxides,
                     and carbon monoxide are produced during the production of the electricity and
                     heat used in printing.

                     Ink content: Two  important indicators  of possible  air  impacts  are  the
                     concentration of VOCs and HAPs.  The concentrations of both were taken from
                     the ink MSDSs and averaged across each formulation within each product line.
 PUBLIC COMMENT DRAFT
8-5
September 2000

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  CHAPTER 8
                                                        CHOOSING AMONG INK TECHNOLOGIES
         Solvent-based Inks

                Solvent-based inks were considered the baseline for this analysis because they traditionally
                are used by the most printers. There were two solvent-based product lines.  Solvent-based
                ink #1 was used with OPP at one facility, and solvent-based ink #2 was used with all three
                substrates (LDPE, PE/EVA, and OPP) at three facilities.

                Performance
                Solvent-based inks performed relatively well on each performance test.  The blocking
                resistance test produced results that were not ideal, but were acceptable in most cases.
                Solvent-based ink #1, printed in OPP, displayed a result of 1.8 (between slight cling and
                cling). Solvent-based ink #2 displayed an average result of 2.7 (between cling and slight
                blocking).  For Solvent-based  ink #2, the results may  have been affected by facility-
                specific conditions.  The eight samples taken at Facility 5 (four each on LDPE  and
                PE/EVA) yielded an average score of 2.1. In contrast, the results at Facility 7 (also four
                samples each on LDPE and PE/EVA) had an average score of 3.6 (between slight blocking
                and considerable blocking).

                Gloss was measured for solvent-based ink #2, which was printed on LDPE and PE/EVA.
                For this product line, the average gloss was 53. Within these results, the values appear
                to have  been  affected  by both  substrate and facility conditions.   The ink appeared to
                produce a glossier finish on PE/EVA;  the average value on this substrate was 59 in
                comparison to the average 51 on LDPE. Also, higher gloss was found at Facility 7 than
                Facility 5; the average  values were 57 and 51, respectively.

                The ice water crinkle test was performed with solvent-based ink #2.  All samples of this
                ink resisted removal during this  test, resulting in a 0% removal rate.  These  results
                indicated that this solvent-based  ink would be appropriate for use in cold, wet conditions.

                Mottle was measured for both  solvent-based inks.  Solvent-based inks #1 and #2 had
                values of 192 and 217, respectively, on the mottle scale.  Though mottle does not have an
                industry  standard, these values were lower than those for the other two ink systems.  It
                should be noted, however, that although the average mottle rating for the two product lines
                were similar, there was significant variation between the two measured formulations within
                each product line.  Blue inks were much more mottled than green inks. This difference
               was consistent across all substrates and facilities.

               Trap  measurements for both solvent-based product lines were consistently near 100%.
               The two  solvent-based inks attained near-complete trapping; i.e., the top ink adhered to
               the underlying ink as well as it did to exposed substrate.

               Overall, the solvent-based inks performed quite well in these tests.   They exhibited good
               physical  characteristics through the blocking, ice water crinkle,  and trap tests, and
               displayed comparatively good visual results in the gloss and mottle tests.  For more detail
               on these tests or others, please see Chapter 4: Performance.

               Environmental and Health Impacts
               Table  8.4 shows the number of  chemicals with clear worker  risk for each formulation
               within the solvent-based product lines (presented as a range).  In addition, the table lists
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               the chemical categories that present clear pressroom worker health risk, and identifies the
               exposure route of concern for each.

               In the occupational risk assessment, solvent-based ink #1 contained between two and four
               chemicals  with clear occupational risk in each formulation. - All chemicals of concern
               presented a dermal risk, and two categories (alcohols and alkyl acetates) also presented a
               clear occupational risk via inhalation. Solvent-based ink #2 also had between two and four
               chemicals with clear risk in each formulation. Three chemical categories presented clear
               risk: alcohols presented clear risk via both dermal and inhalation exposure, low molecular
               weight hydrocarbons presented a clear risk via inhalation exposure, and organometallic
               pigments presented risk via dermal exposure.

               Across both product lines, the inhalation risk stems from chemical categories that are
               solvents and multiple-function compounds. The compounds presenting clear dermal risk
               are solvents, colorants, additives, and compounds listed as multiple-function.

               The toxicological endpoints column of Table 8.4 presents possible health impacts of these
               chemicals with clear risk. For solvent-based inks, health effects are possible via both
               dermal and inhalation exposure.

               The safety hazards  of the solvent-based  inks, as presented  in  Table  8.5,  included
               significant rankings for both flammability and ignitability.  The flammability score of 3
               indicated  that the ink could be easily  ignited under  almost  all normal temperature
               conditions and that water may be ineffective in controlling or extinguishing such a fire.
               Both product lines also were ignitable, indicating that they had a flashpoint (the lowest
               temperature at which vapor is sufficiently concentrated that it  can ignite in air) below
               140°F.

               Table 8^5 shows estimated air emissions of smog-related air releases resulting from inks
               and energy use.  Although the estimates for the solvent-based product  lines assumed that
               an  oxidizer would  be used to control emissions from the inks,  the assumed capture
               efficiency was only 70%.   This resulted in a relatively high amount  of uncaptured
               emissions, so that overall, the two product lines were estimated to release 757 and 1,070
               grams of smog-related emissions per 6,000 ft2 of image, respectively. Emissions from
               solvent-based presses with  an oxidizer may vary; they can be  lower  if the capture
               efficiency is better, but emissions may be higher if the oxidizer is not operated optimally
               and consistently.

               Table 8.5 indicates that, as expected, both solvent-based.inks have a relatively high VOC
               content, at an average of 58% by weight, Neither product line contained any chemicals
               designated as HAPs.

               Operating Costs
               The operating costs associated with using these solvent-based inks are shown in Table 8.3.
               The costs of ink, labor,  capital, and energy per 6,000 square feet of substrate (at a press
               speed of 500 feet per minute) were expected to be $31.89 for solvent-based ink #1 and
               $34.06 for solvent-based ink #2.

               For both of these product lines, the ink costs were the highest expense (between $14 and
                $24 per 6,000  ft2, depending  on the consumption rate at the individual  performance
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                demonstration sites).  Capital costs were the second-largest component of the operating
                costs, at $11.87 per 6,000 ft2, and labor and energy the least significant part of overall
                cost, at $5.29 and $0.53 per 6,000 ft2, respectively.

                Two factors drove the operating costs of solvent-based ink relative to the other two ink
                systems.  First, this system required the use of an oxidizer.  This component added
                approximately $128,000 to the capital cost of the press, which in turn increased the per-
                hour capital cost by $3.80,  assuming a 15% annual depreciation rate over 20 years.
                Second, the high evaporation rate of solvent from solvent-based inks required the press-
                side addition of additional  solvent.   This  led to a  high rate of press-side solvent
                consumption.

                Some factors were not considered in this analysis that may affect the cost of solvent-based
                inks, as well as water-based and UV-cured inks.  These include the ability of an ink to
                print at higher press  speeds, ink monitoring requirements,  and cleaning difficulties.
                Factors such as these may vary among ink systems and alter their relative costs.

                Resource Conservation
                Energy use was the highest for solvent-based ink, at 100,000 Btu per 6,000 ft2 of image.
                The dryers and associated blowers were the most significant consumers  of energy,
                consuming  approximately 460,000 Btu/hour, or 55,000 Btu/6,000 ft2.   The oxidizer
                accounted for much of the remaining energy demand. It should be noted, however, that
                it has become more common to recirculate exhaust from the oxidizer into the dryers. 'This
                practice lowers energy requirements for the dryers so that the net effect on energy use by
                adding an oxidizer is minimal.

                Ink consumption, as discussed in the operating cost summary above, also was relatively
                high. Based on performance demonstrations excluding those on PE/EVA (for which white
                ink was not used), an average of 7.07 lbs/6,000 ft2 of solvent-based ink was consumed,
                and an average of 2.48 lbs/6,000 ft2 of additives were used.  This high consumption rate
                is due to the relatively low solids content of solvent-based inks, which in turn necessitates
                anilox rolls with larger volumes.

                Summary of Solvent-based Inks
                The solvent-based inks performed well on the performance tests, but they had liabilities
                with respect to worker health risks, safety hazards, operating costs, and the consumption
                of ink and energy.

                   •  This system produced ideal results on the ice water crinkle and trap  tests, and
                      produced comparatively good results on the blocking, gloss, and mottle tests (for
                      which no industry standards are available).
                   •  The formulations in both product lines contained chemicals with clear worker risk
                      for both inhalation and dermal exposure routes, presented both flammability and
                      ignitability characteristics,  and had high VOC emissions  despite the use  of
                      oxidizers.
                  •  Operating costs were  relatively high,  due to the required use of oxidizers and
                      higher ink consumption rates.
                  •  Ink and press-side additive consumption rate was high, due to the high evaporation
                      rates of solvents.
                  •  Energy consumption was high, because of the added energy demands of oxidizers.
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       Water-based Inks
              Four water-based inks were tested in this analysis. Water-based inks #1 and #2 were
              tested on OPP at one facility each.  Water-based #3 was tested on LDPE and PE/EVA at
              two sites. Water based ink #4 was tested on OPP at one site.

              Performance
              The results varied considerably among water-based product lines. Blocking was one of
              the tests in which the results were inconsistent across the product lines. Water-based ink
              #1 displayed the worst results,  with an average score of 4.0 (considerable blocking).
              Water-based inks #2 and #4 performed slightly better, with scores of 3.0 and 2.5 (slight
              blocking and  between cling and slight-blocking),  respectively.. Water-based  ink #3
              performed quite well, with an average  score of 1.3  (between slight cling and cling).
              Unlike for the solvent-based inks, the results did not appear to be facility-specific.  Water-
              based ink was used at both Facility 2 and Facility 3; at each, the average value was 1.3.
              The system as a whole compared unfavorably to the results for the solvent-based inks .for
              blocking resistance.

              Gloss was measured for water-based ink #3, the one  product line tested on LDPE and
              PE/EVA. The average measurement was 46.5, which was somewhat lower (i.e., less
              desirable) than the average for solvent-based inks.  Like for the solvent-based inks, the
              results seemed to be influenced by the substrate; on LDPE, the average gloss was 42.3,
              and on PE/EVA, the average gloss was 54.1.  Overall, this water-based product line did
              not provide quite as glossy a finish as the solvent-based inks that were tested.

              Ice water crinkle was also only tested for water-based ink #3.  Of the 16 samples tested,
              part of the coating was partially removed on five of  them.  In each case, only  a small
              fraction (about 5%) of the coating was removed; most of this removal was associated with
              the blue and green formulations.  The results appeared to be facility-specific; no removal
              was observed at Facility 2.  At Facility 3, however, five of the eight samples had some
               removal (including all four samples on LDPE).  These  results were worse than the solvent
              baseline, with which no removal was observed.

               The mottle results also showed a wide range among the product lines.  Water-based inks
               #1 and #3 had scores of 592 and 478, respectively, which were much higher  (worse) than
               those for solvent-based inks. In contrast, the scores for water-based inks #2  and #4 were
               186 and 115,  respectively — comparable or much lower than those for the solvent-based
               inks. Overall, the mottle scores for water-based inks were higher (worse) than the solvent
               baseline. Like for the solvent-based inks, the blue water-based inks overall were much
               more mottled than the green inks.

               The wafer-based inks had fairly consistent scores for  trapping - between 87 and 93%.
               The results may have been facility-specific; at Facility 2 (using water-based ink #3 on
               LDPE and PE/EVA), the average was 84% and at Facility 3 (also using ink  #3 on LDPE
               and PE/EVA), the average score was 101.5%.

               Overall, the performance of the water-based inks was marked by inconsistency. In several
               cases, such as blocking resistance with water-based ink #3 and mottle with inks #2 and #4,
               the inks produced results better than those seen for either of the solvent-based inks.
               However, several tests of the water-based inks produced results worse than  the baseline.
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                In addition, there was variation between facilities  using the same product line and
                substrates for the ice water crinkle and trap tests.  The results may indicate that it is
                possible for water-based inks to obtain or exceed the level of performance of solvent-based
                inks for some parameters, but that it may be necessary to match the ink closely to the
                substrate being printed and to  control other operating conditions carefully.

                Environmental and Health Impacts
                In the occupational risk assessment, the water-based product lines, as indicated in Table
                8.4,  had between one and  four chemicals with clear worker  health risk in each
                formulation. Water-based inks #1 and #2 both had the same range of chemicals with clear
                risk as the solvent-based inks — between two and four.  The range for water-based ink #3
                was between one and four, and that for ink #4 was between three and four chemicals with
                clear risk per formulation.

                In each product line, alcohols and amides or nitrogenous compounds produced clear
                worker risk via dermal exposure and in most cases via inhalation as well. Other chemical
                categories with clear  risk included ethylene glycol ethers,  organic pigments,  and
                organometallic pigments.   The risk  in these water-based inks, therefore,  arose from
                solvents, pigments, and multiple-function compounds.

                Table 8.4 presents toxicological endpoints associated with compounds in the water-based
                inks. As with the solvent-based inks, effects may occur both via dermal and inhalation
                exposure.

                The safety hazard characteristics of the water-based inks in this analysis were variable,
                as indicated in Table 8.5. None were reactive or ignitable. Likewise, for flammability,'
                water-based inks #2 and #3 both had ratings of 0 or 1. In contrast, however, water-based
                inks #1 and #4 had flammability ratings of 3 for some formulations.  This difference
                illustrates  that despite the common classification as  "water-based", the  content  of
                flammable solvents can vary considerably.

               The VOC content data also demonstrate the differences among product lines.  In Table
               8.5, inks #1 and #4 were comprised of 9 and 14 % VOCs by weight, respectively. Printers
               who use water-based ink to comply with the Clean Air Act generally use inks with less
               than 4% VOC content and minimize their use of VOC press-side solvents and additives.
               It should be noted, however, that although product lines #2 and #3 contain only small
               levels of VOCs (1% in each), they also contain small concentrations of HAPs.

               Table 8.5 presents the estimated  smog-related air emissions associated with the use of
               water-based inks.  Despite the lack of an oxidizer, emissions were  calculated to be
               considerably lower than those for the baseline.  Inks and press-side materials were
               expected to release between 110  and.250 grams per 6,000 ft2, with another 63 grams
               released due to energy consumption.

               Overall, the risk associated with water-based inks is quite variable.  Water-based inks #2
               and #3 had an equal or lower number of chemicals with clear worker health risk compared
               to the baseline, had flammability ratings of 1, and had among the lowest releases of smog-
               related compounds  of the three  systems.  In contrast, water-based inks #1 and #4 had an
               equal  or higher number of chemicals with clear risk compared to the baseline, had
               flammability ratings that for several formulations were equal to that of the baseline, and
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              produced high levels of smog-related compounds. It is clear, then, that the risks associated
              with these water-based inks were very much formulation-specific.

              Operating Costs
              For all product lines, water-based ink was less expensive than the baseline.  The costs for
              materials, labor, capital and energy ranged between $24 and $30 per 6,000 ft2 of image,
              but on average the water-based inks were $6.40 less expensive to use than the solvent-
              based inks.  Two effects were responsible for this difference: the lack of an oxidizer and
              the lower consumption of ink and press-side fluids.

              The oxidizer generates a strain both bn capital and energy costs.  As discussed in the
              solvent-based ink summary, an oxidizer used on two presses may cost approximately
              $250,000 to purchase and install.  In addition, depending on the amount of solvent
              loading, energy costs for the oxidizer can be approximately $2.11 per hour, or $0.25 per
              6,000 ft2 of image.

               In addition, the ink and additive costs were lower for water-based inks. The per-pound
               price of water-based inks was actually higher: $1.60 and $3.00 per pound for white and
               colored water-based inks, respectively, compared to $1.40 and $2.80 per pound for the
               solvent-based inks.  However, the consumption rate was considerably lower for water-
               based inks, which led to the overall lower costs.

               Resource Consumption
               As indicated in Table 8.3, energy consumption was the lowest for water-based  inks.
               Among the gas-heated air dryer and electric blower and corona treater, the  water-based
               inks were expected to demand 610,000 Btu/hour,  or 73,000 Btu/6,000 ft2 of substrate.
               The  dryers were expected  to consume considerably more energy than those for solvent-
               based ink (500,000 Btu/hour for the water-based inks compared to 360,000 Btu/hour for
               solvent-based ink), because water is more difficult to dry than organic solvents; however,
               the lack of an oxidizer more than offset the difference.

               Ink consumption also was lower for water-based ink compared to the baseline. On average
               (excluding ink usage on PE/EVA,  the white substrate), 4.73 Ibs of ink and 0.31 Ibs of
               press-side solvents and additives were consumed per 6,000 ft2 for the water-based system.
               This represents a 33%  decrease in ink consumption and an 88% decrease in press-side
               solvent and additive consumption compared to the baseline.

               Summary of Water-based Inks
               The water-based inks studied in this CTS A were very diverse in their performance and risk
               results and chemical composition, but had better operating cost and resource  consumption
               characteristics.

                    •   Individual product lines performed equal to or better than the baseline in blocking
                       and mottle.  However,  many of the results for these and other tests were  worse
                       than the baseline,  highlighting the importance of carefully choosing the specific
                       product when using a water-based ink.
                    •   With  respect to  the chemical composition  and worker health  risks  of the
                       formulations, as indicated in Table 8.5, these inks contained from 1% to 14%
                       VOCs and from 0% to 3.4% HAPs by weight.  The relatively high VOC content
                       in two of the product lines had significant impacts on the safety hazard ratings,
                       and the presence of HAPs may have increased the number of chemicals with clear
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                       worker risk.  Though water-based inks are often considered to be safer than
                       solvent-based  inks, the  results  indicate that water-based  inks are not always
                       "clean." It should be noted that the health concerns associated with cross-linkers
                       were not addressed by this study.  These chemicals, which can be added to water-
                       based inks to improve adhesion,  are thought to cause worker health concerns but
                       were not used  hi the performance demonstrations.
                       The operating costs and energy  consumption  of water-based inks were
                       substantially better than the baseline. Much of the difference was due to the lack
                       of an oxidizer; for water-based  inks with VOC contents above state-mandated
                       control levels,  this cost and energy advantage may be reduced substantially.
         UV-cured Inks
                UV-cured inks  were considered a "new  developing technology"  for wide-web film
                applications when the performance demonstrations were planned and conducted in 1996.
                Significant changes and improvements have been made to the system and equipment since
                then.

                Three UV-cured inks were used in this analysis.  UV-cured ink #1 was tested on LDPE,
                UV ink #2 was tested on LDPE and PE/EVA,  and UV-cured ink #3  was tested on
                PE/EVA; each ink was tested at one location.

                Performance
                As with water-based inks, some performance results were better than those of the baseline,
                but many were not.  Blocking was one test in which UV-cured inks performed very well!
                UV-cured inks #1 and #3 both scored an average of 1.0, indicating only slight cling. UV-
                cured ink #2 had an average score of 2.1, which indicates more substantial cling but very
                little actual blocking. In contrast, the average score for the solvent baseline was 2.3. This
                indicates that these UV-cured inks performed well in conditions of heat and pressure.

               The ratings for gloss were substantially lower (worse) than those for the baseline. The
               average score  for the three coatings was  38.4, compared to the baseline value of 53.0.
               This is an unexpected result,  since high gloss is generally thought of as a feature of UV-
               cured inks. The reason for this discrepancy is unknown, but it may indicate that if a high-
               gloss UV-cured ink is needed for a given application, the specific formulations should be
               chosen carefully.

               The ice  water crinkle test results were perfect on UV-cured inks #1 and #3 - no ink
               removal was observed.  However, ink #2 was partially  removed on each of the eight
               samples  tested.  This removal was observed on both LDPE and PE/EVA substrates,
               indicating that the effect may not be simply substrate-dependent.  It may be possible that
               the removal is  due to  the  formulation itself or  to  variables  at the performance
               demonstration site.

               Mottling associated with UV-cured inks was slightly worse than the solvent baseline, but
               better than that of the water-based inks.  UV-cured  ink #2 was equal to the baseline, with
               a mottle  index of 205, but inks #1 and #3  were higher at 271 and 273, respectively. As
               for solvent- and  water-based inks, the  blue inks in each product line displayed more
               mottling.
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               The formulations showed a range of trapping values, but ultimately the average was close
               to that of the water-based inks. The trapping value of UV-cured ink #3 was 95 %, which
               approached the value of the baseline. However, ink #1 had a scorq of only 82%.  The
               average among the three product lines was 89 %.

               As for water-based inks, UV ink performance results varied considerably.  Even within
               a product line, the performance could vary from test to test. For example, UV-cured ink
               #3 performed very well on the physical tests (a blocking score of 1.0, no removal with the
               ice water crinkle test,  and  a trap value of 95%).  However,  it received relatively poor
               gloss and mottle scores. The converse was true for ink #2; it had the best gloss and mottle
               scores of the UV inks, but  had the worst blocking and ice water crinkle results.

               Environmental and Health Impacts
               Overall  the risks associated  with UV-cured inks are marked by uncertainty. In the
               occupational risk assessment, few of the chemicals have been subjected to toxicological
               testing  Though the EPA Structure Activity Team (SAT) analyzed the chemicals based on
               their molecular structure and similarity to chemicals that have been tested, the information
               is considered to be less certain than that based on direct toxicological research. Testing
               is necessary to better understand the risks associated with this ink system. The results are
               based on the risks of the uncured inks, such that risk results may be overestimated if the
               harmful components chemically react and are integrated into the finished coating.

               For UV-cured inks #1 and #3, one or two chemicals per formulation presented a clear
               occupational risk.  This range was lower than that of the baseline.  However, UV-cured
               ink #2 had four or five chemicals with clear risk per formulation, which was higher than
               the baseline range.  Across the three product lines, the chemicals with clear worker risk
               were monomers, oligomers, colorants, and multiple function compounds. In their uncured
               form, some of these chemicals were reported to present clear risk through both dermal and
                inhalation exposure routes.

                The toxicological endpoints associated with compounds in UV-cured inks are presented
                in Table 8 4.  In contrast to the solvent-based and water-based inks, fewer types of
                possible human health effects associated with  inhalation of the  UV-cured inks were
                reported  It is not known, however, whether there were fewer observed effects because
                UV-cured inks are safer  or  simply because less research has been undertaken on the
                compounds used in this ink system.

                The safety hazard information provided in Table 8.5  is not fully available for UV-cured
                chemicals because the MSDSs for two of the product lines were generated according to
                guidelines other than those of the U.S. The one product line for which information was
                available showed a reactivity level of 1, a flammability level of 1, and it was not igmtable.
                These levels represent a  lesser flammability  and ignitability concern compared to  the
                baseline, but the (minimal) reactivity score indicates that the ink should be stored in a dry
                 location that is not subject to high temperatures or pressures.

                 The potential difference in air releases before and after curing can be seen by ^paring
                 the Smog-Related Emissions and Ink Content columns in Table 8.5.  Particularly for UV-
                 cured#2  substantial VOCs could be released from the uncured ink.  When combined with
                 the emissions associated with the system's high demand for electricity  the  overall
                 emissions could be significant. However, the emissions associated with the UV-cured inks
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                 were all considerably lower than those of the solvent baseline at the assumed emissions
                 capture rate.

                 In contrast, the VOC content for the cured formulations is expected to be less than 1 %
                 by weight. The volatile matter that was found in the uncured material would be chemically
                 transformed and incorporated into the finished product upon curing.

                 Overall, the UV-cured inks appeared to have fewer chemicals of concern compared to the
                 solvent baseline, and these concerns may decrease further for cured ink. However more
                 research is needed into the potential health effects of the chemicals for which no direct data
                 were available. Furthermore, though UV-cured inks #1 and #3 had fewer chemicals with
                 clear worker risk and lower emissions than the baseline, the opposite was true for UV-
                 cured ink #2. The risks associated with UV-cured ink formulations, therefore  mav varv
                 significantly.                                                                  J

                 Operating Costs
                The cost of operating a UV-cured system was calculated to be higher than for the other
                two systems. The average cost was $3.80 higher than the baseline per 6,000 ft2. One ink
                UV-cured ink #3, had lower operating costs than the baseline, but much of this is due to
                the fact that it was only printed on PE/EVA, and therefore white  ink was not necessary.

                Several factors contributed to these higher operating costs. First, the prices of UV-cured
                inks are approximately $6 more for white ink and $7 more for colored inks, per pound
                Ink consumption per square inch of substrate is lower for UV inks, but if anilox rolls are
                not optimized for these inks, the lower consumption would not be fully realized  Another
                factor is that UV-cured systems also run exclusively on electricity.  In contrast, solvent-
                and water-based inks typically fuel dryers and oxidizers with natural gas, which is less
                expensive. Finally, the capital cost of a UV-cured press  is higher than that  of a water-
                based ink press.  Though a UV-cured press does not require hot-air dryers, the UV curing
                lamps are more expensive than these dryers.  (The cost of a UV-cured press  is expected
                to be similar to that of a solvent-based press, however, which also has an oxidizer system.)

                Resource Conservation
                UV-cured inks had both lower energy and ink consumption rates compared to the baseline
                The UV-cured process consumed approximately 650,000 Bra/hour,  or78,000 Btu/6 000
                ft2 at a press speed of 500 feet per minute.  Both  the energy costs and air releases are
               higher for UV than for the other two systems, though; this is because all of the energy is
               obtained from electricity,  which is both more expensive and is produced inefficiently in
               comparison to on-site natural gas combustion.

               The consumption rate of UV-cured inks was the lowest among the three systems.  On non-
               PE/EVA substrates, an average of 3.47 Ibs (and almost no additives) were consumed per
               6,000 ft2.  When comparing this figure to the amount of ink and additives consumed by
               the baseline, UV-cured inks consumed six pounds less material per 6,000 ft2.

               Summary of UV-cured Inks
               Like water-based inks, UV-cured inks displayed variability among the product lines.

                   •   The performance  tests had mixed results  - improving upon  the  baseline for
                      blocking but mostly trailing the baseline for the other tests.
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                      For worker risk, the UV-cured inks on average contained fewer chemicals with
                      clear risk per formulation than the baseline. However, one ink (#2) had relatively
                      high  VOC air emission rates and more chemicals with clear risk, indicating a
                      potential variability among the UV-cured product lines. The comparatively high
                      number of chemicals with a clear worker health risk that only were analyzed by
                      the SAT signals two issues. Specifically for this analysis, it indicates that there is
                      considerable uncertainty associated with the UV risk analysis.  More generally,
                      it may indicate that compounds used in UV-cured inks are of concern but that their
                      risks are poorly understood.    These  results indicate that research on these
                      chemicals should be a priority.
                      Operating  costs of the UV-cured inks were higher compared to the solvent
                      baseline, primarily because of the price of ink.
                      The  UV-cured  inks produced  better  results than the baseline for  resource
                      conservation; they  required less  energy and considerably less ink.
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  8.2 QUALITATIVE SOCIAL BENEFIT-COST ASSESSMENT

          Introduction to Social Benefit-Cost Assessment

                  Social benefit-cost analysis3 is a tool used by policy makers to systematically evaluate the
                  impacts to all of society resulting from individual decisions. A social benefit-cost analysis
                  seeks to compare the benefits and costs of a given action, considering both the internal and
                  external costs and benefits.b Such an approach is unlike business decision making, which
                  generally only  considers the internal (or private) costs and benefits of an action without
                  taking  into account any accompanying externalities.

                  The decision evaluated  in this assessment  is the choice of a flexographic ink system
                  Flexographic printers have a number of criteria they may use to assess which ink system
                  technology or product line they will use.  For example, a printer might consider what
                  impact their choice of an ink system might have on operating costs, liability costs,
                  insurance premiums, or the cost of compliance with environmental regulations.  These
                  criteria are all part of the  internal decision making process;  they  do not  include
                  considerations that may be of importance to society as a whole.

                  This benefit-cost assessment considers both the impact of choosing between various  ink
                  systems and product lines on the printer (internal costs and benefits) and on other members
                  of society (external costs and benefits), such as reductions in environmental damage and
                  reductions in the risk of illness for the general public.  Table 8.6  defines a number of
                 terms used in this benefit-cost assessment, including externality, and public (external) costs
                 and benefits.
                The term  analysis" is used here to refer to a more quantitative analysis of social benefits and costs  where
                a monetary value is placed on the benefits and costs to society of individual decisions  Examples of'
                quantitative benefit-cost analyses are the regulatory impact analyses done by EPA when developing federal
                environmental regulations. The term "assessment" is used here to refer to a more qualitative examination
                of social benefits and costs.  The evaluation performed in the CTSA process is more correctly termed an
                assessment because many of the social benefits and costs of flexographic ink technologies are identified but
                not monetized.                                                                       '

                ^Private costs typically include any direct costs incurred by the decision maker and are generally reflected
                in the manufacturer's balance sheet. In contrast, public costs are incurred by parties other than the primary
                participants to the transaction. Economists distinguish between private and public costs because each will
                affect the decision maker differently. Although public costs are real costs to some members of society
                they are not incurred by the decision maker, and firms do not normally take them into account when  '
                making decisions.  A common example of these "externalities" is an electric utility whose emissions are
                reducing crop yields for the farmer operating downwind.  The external costs experienced by the farmer in
                the form of reduced crop yields are not considered by the utility when making decisions regarding
                electricity production.  The farmer's losses do not appear on the utility's balance sheet
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CHAPTERS
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                         Table 8.6 Glossary of Benefit-Cost Analysis Terms
    Term
                                                      Definition
  ost of
  ness
              financial term referring to the liability and health care insurance costs a company must pay to
             rotect itself against injury or disability to its workers or other affected individuals.  These costs are
             nown as illness benefits to the affected individual.
  xposed
  opulation
             he estimated number of people from the general public or a specific population group who are
             xposed to a chemical through wide dispersion of a chemical in the environment (e.g., DDT). A
             pecific population group could be exposed to a chemical due to its physical proximity to a
             lanufacturing facility (e.g., residents who live near a facility using a chemical), use of the chemical or
              product containing a chemical, or through other means.
               he estimated number of employees in an industry exposed to the chemical, process, and/or
              echnology under consideration.  This number may be based on market share data as well as
               stimations of the number of facilities and the number of employees in each facility associated with
               ie chemical, process, and/or technology under consideration.
 xposed
 Vorker
 opulation
  xternality
              cost or benefit that involves a third party who is not part of a market transaction; "a direct effect on
              nother's profit or welfare arising as an incidental by-product of some other person's or firm's
              igitimate activity."2 The term "externality" is a general term which can refer to either external
              enefits or external costs.
 Human
 Health
  Jenefits
             deduced health risks to workers in an industry or business as well as to the general public as a result
              f switching to less toxic or less hazardous chemicals, processes, and/or technologies. An example
             would be switching to a less volatile organic compound, lessening worker inhalation exposures as
             yell as decreasing the formation of photochemical smog in the ambient air.
               ftSll CIO LICWI CCTOII ly LI 1^ IVI I I iMtiwi 4 \st ffi iv WM» iv • ..»».. —. . • —^ -- - -•	
               "he cost of adverse human health effects associated with production, consumption, and disposal of
               rm's product. An example is respiratory effects from stack emissions, which can be quantified by
               nalyzing the resulting costs of health care and the reduction in life expectancy, as well as the lost
               vages as a result of being unable to work.
Human
Health
 Dosts
  ndirect
  Medical
   osts
             ndirect medical costs associated with a disease or medical condition resulting from exposure to a
              hemical or product  Examples would be the decreased productivity of patients suffering a disability
              .r death and the value of pain and suffering borne by the afflicted individual and/or family and friends
               rhe direct gain received by industry or consumers from their actions in the marketplace.  One
               3xample includes the revenue a firm obtains in the sale of a good or service. Another example is the
               "iatisfaction a consumer receives from consuming a good or service.
 rivate
 Internal)
Benefits
  Private
  Internal)
   losts
              "he direct costs incurred by industry or consumers in the marketplace. Examples include a firm's
             cost of raw materials and labor, a firm's costs of complying with environmental regulations, or the co
              o a consumer of purchasing a product.
  Public
   External)
  Benefits
             A positive effect on a third party who is not a part of a market transaction. For example, if an
             educational program results in behavioral changes which reduce the exposure of a population group
              o a disease, then an external benefit is experienced by those members of the group who did not
             participate in the educational program.  For the example of nonsmokers exposed to second-hand
             smoke, an external benefit can be said to result when smokers are removed from situations in which
              hey expose nonsmokers to tobacco smoke.
  3ublic
  External)
   iosts
             A negative effect on a third party who is not part of a market transaction.  For example, if a steel mill
             emits waste into a river which poisons the fish in a nearby fishery, the fishery experiences an externa
             cost as a consequence of the steel production. Another example of an external cost is the effect of
             second-hand smoke on nonsmokers.
  Social
   ;osts
             The total cost of an activity that is imposed on society.  Social costs are the sum of the private costs
             and the public costs. Therefore, in the example of the steel mill, social costs of steel production are
             the sum of all private costs (e.g., raw material and labor costs) and the sum of all public costs (e.g.,
              the costs associated with the poisoned fish).
  Social
  Benefits
             The total benefit of an activity that society receives, i.e., the sum of the private benefits and the pubh
             benefits For example, if a new product yields pollution prevention opportunities (e.g., reduced waste
             in production or consumption of the product), then the total benefit to society of the new product is th
             sum of the private benefit (value of the product that is reflected in the marketplace) and the public
             benefit (benefit society receives from reduced waste).
  Willingness
  to-pay
              Estimates used in benefits valuation are intended to encompass the full value of avoiding a health 01
              environmental effect.  For human health effects, the components of willingness-to-pay include the
              value of avoiding pain and suffering, impacts on the quality of life, costs of medical treatment, loss o
              income, and, in the case of mortality, the value of life.		
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                                                         CHOOSING AMONG INK TECHNOLOGIES
                Internal benefits  of selecting an alternative ink system may include increased profits
                resulting from improved worker productivity and'conlpany image, a reduction in energy
                use, or reduced property and health insurance costs due to the use of less hazardous
                chemicals.  External benefits may include improved public health from a reduction in
                pollutants emitted to the environment or reduced use of natural resources.  Costs of the
                alternative ink systems may include private costs such as changes in operating expenses
                and public costs such as change in the price of the product charged to the consumer. Some
                benefits and cost  are both internal and external.  For example, use of an alternative  ink
                system may result in natural resource savings.' This may benefit the printer in the form
                of reduced water usage and a reduction in payments for water, and society as a whole in
                the form of reduced consumption of shared resources.,


        Benefit-Cost Methodology and Data Availability

                The methodology for conducting a social benefit-costs assessment can be broken down into
                four general steps: 1) obtain information on the relative human and environmental risk,
                performance, cost, process safety hazards, and energy and natural resource requirements
                of the baseline and the alternatives; 2) construct matrices of the data collected; 3) when
                possible, monetize the values presented within the matrices; and 4)  compare the data
                generated for the alternative and the baseline in order to produce an estimate of net social
                benefits.   Section 8.1  presented the results of the first two  tasks  by summarizing
                performance, cost, energy use, risk, and safety hazard information for the baseline and
                alternative ink system technologies. The remainder of Section 8.2 interprets the presented
                data hi the context of social benefit-cost assessment: the first part presents an analysis of
                the potential private and public costs, the second part discusses the potential private and
                public benefits.

                Ideally, this benefit-cost chapter would quantify all of the social benefits and costs of using
                the different ink systems and identify the technology whose use results in the largest net
                social benefit. However, because of resource and data limitations and because some of the
                observations in the demonstrations were very site-specific,  the analysis  presents a
                qualitative  description of the economic implications of the risks and other external effects
                associated with each technology.  Benefits derived from a reduction in risk are described
                and discussed, but not quantified. Nonetheless, the information presented can provide
                useful insights when deciding between different ink systems or product lines.

                The following discussions provide examples  that qualitatively illustrate some of the
                important benefit and cost considerations. However, no overall recommendation is given.
                Rather, personnel in each individual facility  will need  to examine  the information
               presented and identify, based on their own concerns and priorities, the best choice of ink
                system and product line for their facility.
        Potential Private and Public Costs

               It not possible to obtain comprehensive estimates of all private costs of the alternative ink
               systems.   However,  some cost components were quantifiable.  For example, the cost
               analysis estimated the average operating costs associated with each ink system, including
               the material costs (ink and additive costs), labor costs for a press operator and assistant,
               overhead  costs (rent and heat, fire and sprinkler insurance, indirect labor, repair to
               equipment, and administrative and sales overhead), average capital costs (base equipment,
               required add-ons, and installation), and energy costs  (electricity and natural gas).  Other
               cost components may contribute significantly to overall operating  costs, but were not
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CHAPTERS	CHOOSING AMONG INK TECHNOLOGIES

               quantified because they could not be reliably estimated. These cost components include
               press cleaning costs, wastewater costs, sludge recycling and disposal costs, and other solid
               waste disposal costs.

               External costs are those costs that are not included in the printer's pricing and printing
               decisions. These costs are commonly referred to as "externalities" and are costs that are
               borne by society and not by the individuals who are part of a market transaction. These
               costs occur in a variety  of ways in the printing process.  For example, if a printer uses
               large  quantities of a non-renewable resource during the printing process, society will
               eventually bear the cost of depletion of this natural resource.  Another example of an
               external cost are health effects on the population living in the communities surrounding the
               facility  which may result from the emission of chemicals from a printing facility.  The
               printer does not pay for any illnesses that occur outside the facility even if they are caused
               by the facility's air emissions. Society must bear these costs in the form of medical
               payments or higher insurance premiums.

               Differences in the operating costs estimated in the cost analysis are summarized below.

               Private Costs
               Operating costs are arguably the most obvious  and measurable factor influencing a
               business's choice of ink technologies.  Lower operating costs are a direct and immediate
               benefit to the printer because they will directly influence the facility's bottom line.  In
               addition, lower operating costs may allow the printer to reduce the cost per image to  the
               consumer, thus placing  the printer into a more competitive position in the market.

               Table 8.7 presents the overall  operating costs for all  ink systems  studied in  the
               performance demonstrations, as well as  a comparison between the average costs for the
               alternatives and the baseline.  All cost data are presented for 6,000 square feet of image
               created at a press speed of 500 feet per minute. The data in Table 8.7 show that water-
               based inks (Alternative  1) had a lower average operating cost than the baseline (solvent-
               based inks) during the demonstrations.  Water-based inks averaged a operating cost of
               $26.60 per 6,000 square feet of image, while solvent-based inks averaged $33.43.  In
               addition, the range for water-based inks ($24.23 to $30.04) fell well below the range for
               the baseline ($31.89 to  $34.06). UV-cured inks (a new developing technology for wide-
               web film applications) showed an average cost of $36.82, higher than both the baseline  and
               Alternative 1. However, the lower bound of the  range for this technology ($23.69)  fell
               below the average costs for both the baseline and Alternative 1.  The large  range in costs
                for this technology ($23.69 to $51.00) is not surprising given that UV-cured  inks are a
                new developing technology.  With further technological developments, this technology is
                likely to become more  cost competitive with the more established ink technologies.

                Table 8.7 also presents  a breakdown of costs used to calculate the operating cost number.
                Labor  costs  were constant across all ink systems at $5.29.  Capital and energy costs
                changed across the systems but did not change at the product line level, with the lowest
                costs occurring in the water-based system at $11.41 and $0.35 respectively.  Material costs
                were the only costs that differed by product line within an ink system. Material costs are
                the sum of the costs for color inks, white inks, and additives used during the performance
                demonstrations. With  the exception of one UV  product line, water-based inks had the
                lowest material costs.

                It should be noted that these calculations are based on the costs of printing on three
                different substrates used during the performance  demonstrations. One of the substrates,
                PE/EVA, does not require white ink and therefore has a lower material cost than substrates
                that do require white ink. Since all three systems were tested on all three substrates during

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                the performance demonstrations, and a similar image can be created on all three substrates,
                the cost estimates presented in Table 8.7 are based on all results.  However,  actual
                material costs for specific systems or product lines may be higher than in the performance
                demonstrations if a substrate other than PE/EVA were used.  Each individual printer
                should determine the specific costs of a system and product line, based on the substrate and
                facility-specific conditions, before making decisions on a system or product line.
         Table 8.7 Operating Cost Breakdown per 6,000 ft2 of Image at 500 Feet per Minute
Product Line
Material Cost
Labor Cost
Capital Cost
Energy Cost
Total Cost
Baseline: Solvent-based Ink Systems
Solvent-based #1
Solvent-based #2
Average across
Solvent-based Inks
$14.20
$16.37
$15.29
$5.29
$5.29
$5.29
$11.87
$11.87
$11.87
$0.53
$0.53
$0.53
$31.89
$34.06
$32.98
Alternative 1: Water-based Ink Systems
Water-based #1
Water-based #2
Water-based #3
Water-based #4
Average across
Water-based Inks
$12.99
$9.73
$8.31
$7.18
$9.55
$5.29
$5.29
$5.29
$5.29
$5.29
$11.41
$11.41
$11.41
$11.41
$11.41
$0.35
$0.35
$0.35
$0.35
$0.35
$30.04
$26.78
$25.36
$24.23
$26.60
New Developing Technology: UV-cured Ink Systems
UV-cured#1
UV-cured #2
UV-cured #3
Average across
UV-cured Inks
$32.81
$17.59
$5.50
$18.63
$5.29
$5.29
$5.29
$5.29
$11.87
$11.87
$11.87
$11.87
$1.03
$1.03
$1.03
$7.03
$51.00
$35.78
$23.69
$36.82
               While lower operating costs are likely to be an important factor in a printer's choice of an
               ink system, it is important to note that additional costs associated with the conversion from
               one ink system to another may negate some or all of the cost savings discussed above.  For
               example, substantial capital investments may be required to switch from one system to
               another. Examples of the costs of purchasing a new press and retrofitting a press from one
               system to another are presented in Table 8.8. A switch to an alternative ink system also
               may involve costs to retrain employees on the new printing equipment.  Another influence
               on private costs is the press speed of the new system. In the cost chapter of the CTSA
               where costs were calculated at both the methodology speed and the speeds observed during
               the performance demonstrations,  the  per-image costs  for labor,  capital, and energy
               decreased at the same rate that press speed  increased. Press speed is, a critical cost driver,
               and its impacts should be assessed when an ink system switch is considered.  Issues such
               as the level of required monitoring, along with differences in setup and cleanup, may also
               impact a decision among ink systems. The decision to switch from one ink technology to
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CHAPTER 8
                                                        CHOOSING AMONG INK TECHNOLOGIES
               another is necessarily site^-specific and should be made based on all costs relevant to the
               facility and the ink system under consideration.

               Public Costs
               In addition to profitability considerations, there are potential cost savings to the consumer
               associated with the operating cost differentials among the ink system technologies.  A
               switch to a cheaper technology by large parts of the flexographic ink market might enable
               the printers to reduce the price charged to consumers.3 However, this would only be the
               case if overall costs, including potential capital costs  and training costs associated with
               switching to a different ink system, were lower than the baseline costs.  Alternatively, a
               switch to a more expensive technology may lead to an increase in the cost to the consumer.
                 "In a competitive market, each individual firm is assumed to be a price-taker. Therefore, a benefit in terms
                 of reduced prices to the consumer would only be possible if the number of printers switching to a cheaper
                 technology is large enough to exert an influence on prices.
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CHAPTERS
       CHOOSING AMONG INK TECHNOLOGIES
       Potential Private and Public Benefits

               To provide the necessary information for the overall private benefit-cost comparison, a
               qualitative discussion of private benefits, including occupational health risks and safety
               hazard considerations, is presented. While these benefits could not be monetized or even
               quantified,  they have the potential to directly affect a facility's costs and profits, and
               should therefore be carefully considered in the decision-making process.

               Public, or external, benefits are those that do not benefit the printer directly. For example,
               an alternative that produces less air pollution results in both private and public benefits:
               the printer  pays for fewer raw materials and society in general benefits from better air.
               The potential external benefits associated with the use of an alternative ink system include
               reduced health risk  for the general public, reduced ecological risk,  and reduced use of
               energy and natural resources.

               Private Benefits
               Performance Related Benefits
               In addition to costs, performance  is  generally of greatest importance to any business
               operating in a competitive market.  Performance is closely linked to the  quality and
               appearance of the delivered product. In general,  performance improvements lead to
               increased product revenues, and performance shortcomings lead to decreased customer
               satisfaction and revenues.

               The CTSA assessed performance with 18 standard tests (see Chapter 4: Performance).
               Five of these tests were selected as summary performance tests based on their importance
               and  quantifiability (see  Section 8.1,  Table  8.3). Average performance demonstration
               results of Alternative #1 (water-based inks)  in the five summary tests were close to, but
               lower than, those of the baseline (solvent-based inks). The average  performance results
               of the developing technology (UV-cured inks) were also close to,  but lower than, the
               baseline in four of five tests. However, it is important to note that performance results of
               individual product lines and formulations varied considerably, so that there is substantial
               overlap in  the performance range of the three systems. This indicates that flexographers
               may be able to achieve many of the performance parameters needed  for their products
               from any of the three systems. The variation in performance by demonstration site also
               underscores the need to  optimize ink  performance (via formulation and equipment
               selection as well as  the use of press side solvents and additives) with all systems.

               Ideally, flexographers would always choose the best-performing ink system with the lowest
               cost. However, this CTSA indicates that there may be some cost-performance tradeoffs.
               Lower-cost systems and formulations may yield lower performance.  Alternatively, the
               CTSA indicates that printers may want to consider using systems and formulations with
               equal or better performance and higher costs if those higher costs  are accompanied by
               environmental benefits. Three examples of private environmental benefits in the CTSA
               are  discussed below — reduced occupational health risk, reduced safety  hazards and
               regulatory costs,  and reduced energy use.

               Occupational Health Risk
               Occupational health risk refers  to any health impairments that may result from the
               workers'  exposure to hazardous  chemicals.   Improved occupational health may have
                several tangible benefits to the facility: it may lead to fewer sick days, improved worker
                satisfaction, improved worker productivity, and reduced insurance or compensation costs.
                In the context of this CTSA, occupational health risk refers to press room workers subject;
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                to dermal and inhalation exposure and prep room workers subject to dermal exposure of
                hazardous chemicals contained in the various ink formulations.

                Table 8.4 in Section 8.1 presents a range of chemicals of concern for each product line
                used in the performance demonstrations.  The average number of chemicals with clear
                SAT occupational risk associated with both Alternative 1 (1 to 4 chemicals) and the new
                developing technology (1 to 5 chemicals) was slightly lower th\an that of the baseline (2
                to 4 chemicals).  This CTSA uses the number of chemicals with occupational concern as
                an indication of the potential risk to press room workers. However, other factors, such
                as the concentration of chemicals of concern, also play an important role in assessing
                occupational health risks.

                Lower risk to workers may have a number of monetary benefits for the printer: Reduced
                health risk may  lead to reduced illnesses by the facility's workers, which positively
                influences the facility's productivity.  In addition, better worker health is also likely to
                increase worker satisfaction (or decrease worker dissatisfaction), which can also influence
                worker productivity.  A less hazardous working environment may also lead to lower health
                insurance  premiums, part  of which the facility may pay,  and  reduced workers
                compensation expenditures.

                Safety Hazard and Regulatory Costs
                Additional private  benefits of reducing the number of chemicals of concern may  be
                realized from reduced safety hazards  at the facility and reduced regulatory compliance
                requirements.  Safety hazards associated with flexographic  inks  include reactivity,
                flammability, and ignitability. Improved chemical characteristics with respect to these
                hazards may lead to a reduction in the  insurance premiums paid by the printer, as well as
                a potential reduction in waste disposal and storage costs.  In addition, by switching away
                from hazardous chemicals, a facility may be able to avoid certain regulatory and reporting
                requirements associated with hazardous materials.  Similarly, a reduction in reporting and
                regulatory requirements would also produce public benefits for government, and therefore
                taxpayers.  These benefits may stem from permit writers having to issue permits to fewer
                facilities or for a reduced number of  chemicals, or less  enforcement actions being
                required.

               Table 8.5  in Section 8.1 summarizes safety hazard results for the three ink systems.  Of
               the three ink systems, only solvent-based inks pose ignitability  concerns, resulting in a
               greater safety hazard. Data were incomplete for reactivity and flammability characteristics
               of UV inks. The water-based ink technology compared favorably to the solvent-based
               technology in terms of flammability (a range of 0 to 3 compared to 3 for solvent based
               inks), while no difference in reactivity  was observed between the two systems (both
               showed zero reactivity).

               Energy Use
               Energy use is another direct cost of production to  the printing facility.  Employing more
               energy efficient technologies may benefit a printer by reducing production costs as well
               as improving the facility's public image. With increasing environmental consciousness by
               the public, facilities  using environmentally friendly production technologies may be able
               to create considerable goodwill in their communities and take advantage of advertising
               opportunities in addition to providing benefits to the environment and society as a whole.

               The energy used by each ink system is expressed in terms of the number of British thermal
               units (Btu) used to produce 6,000 square  feet of image.  Table 8.3 in Section 8.1 shows
               that waters-based inks and UV inks use less energy  than solvent-based inks, with averages
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               of 73,000 and 78,000 Btu, respectively, compared to 100,000 Btu used bj the solvent-
               based ink technology. This reduced energy use may result in private and/Ocial benefits,
               as discussed above.                                           7 "•' -  —

               All  things equal, choosing an ink technology that uses less energy, during" the printing
               process will have public benefits as well as private benefits.  A reduction in energy use
               conserves natural  resources, a benefit to society as a whole and future generations.
               However, it is interesting to note that the environmental impacts of energy use (and
               therefore public benefits) differ by energy source.  For example, natural gas is relatively
               clean-burning compared to some sources of electricity, such as high-sulfufeoal. Thus the
               public benefit  of switching to a more energy-efficient process" may Be decreased if that
               switch entails a fuel source change from gas to coal-derived electricity;

               Public Benefits                                           '  •
               Public Health Risk
               A reduction in the number of chemicals of concern not only presents private benefits to
               the  printer but may also produce several public benefits.   Society may benefit from
               reductions in air releases from the printing facility, which can lead to such health effects
               as asthma, red eyes, nausea, or headaches.3 When present, these .health effects can lead
               to sick days among  the general public and workers living near the facility, and cause
               absenteeism at those workers' place of employment. A reduction in air emissions may also
               lead to a reduction in private and public health care costs.       .  ,-;

               Table 8.5 in Section 8.1 summarizes smog-related emissions associated with the different
               product lines.  The table shows that at the assumed capture efficiency of 70%, solvent-
               based emissions of smog-related compounds from ink and energy sources;are considerably
               higher than those from the other two systems. Solvent-based emissions ranged from 757
               to 1070 g/6,000 ft2. In contrast, water-based inks ranged from 173 to 313 g/6,000 ft2, and
               UV-cured inks ranged from  187 to 523 g/6,000 ft2. Table 8.5 also compares the product
               lines tested for the three ink systems in terms of VOC and HAP content. No HAP content
               was measured for  solvent-based and UV-cured inks, whereas the HAP content for water-
               based inks ranged from 0 to 3.4% by weight. UV-cured inks have the lowest calculated
               VOC content,  with  1 % reported for each of the  three tested product lines.  The VOC
               content for water-based inks ranges from  1 to 14% by weight, while solvent-based inks
               record a range of  54 to 67%.          •

               In addition to air emissions, there is a potential for chronic general population exposure
               via  other pathways (e.g.,  drinking water, fish ingestion,  etc.), or acute short-term
               exposures to high levels  of hazardous chemicals when there is a spill, fire, or other one-
               time release.  Again, these potential risks are reduced when the number of chemicals of
               concern used  at a  facility is  lowered.

               Partially because  of the chemical diversity of  ink formulations within each system,
               potential public health benefits from a switch hi ink technologies could not be quantified
               for this  CTSA. However,  some general examples can illustrate the potential economic
                impacts  that  less  exposure to hazardous chemicals  may have.   Table 8.10 presents
                estimates of the economic costs of some of the  illnesses or symptoms associated with
                exposure to fiexographic printing chemicals.   To the extent that flexographic printing
                chemicals are not the only factor contributing to the illnesses described, individual costs
                a Asthma, red eyes, and headaches have been associated with ozone, a product of VOCs released from inks
                and from energy production.  Lung and neurotoxic effects, which may include asthma and headaches,
                respectively, have been associated with compounds of possible general population risk.
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                may overestimate  the  potential  benefits to society from substituting  alternative ink
                technologies for the baseline ink system. In addition, if an alternative ink system contains
                some of the same chemicals, the full economic benefit may not be realized.

                Eye irritation, headaches, nausea, and aggravation of previously existing respiratory
                problems are effects associated with ozone (derived from VOCs in inks or released during
                energy production) or with individual compounds of possible general population risk.  The
                economic  literature provides estimates of the costs  associated with  eye  irritation,
                headaches, nausea, and  asthma  attacks.   An analysis by  Unsworth  and  Neumann
                summarizes the existing literature on the cost of illness  based on estimates of how much
                an individual would be willing to pay to avoid certain acute effects for one symptom day.3
                These estimates are based upon a survey approach designed to elicit estimates of individual
                willingness-to-pay to avoid a single-day incidence of the illness. They do not reflect the
                lifetime costs of treating the disease.

                Table 8.9  presents a summary of the low, mid-range,  and high estimates of individual
                willingness-to-pay to avoid eye irritation, headaches, nausea, and asthma attacks.  These
                estimates provide an indication of the benefit per affected individual that would accrue to
                society if switching to a substitute ink technology reduced the incidence  of these health
                endpoints.

                     Table 8.9  Estimated Willingness-to-Pay to Avoid Morbidity Effects for
                                        One Symptom Day (1995 dollars)
Health Endpoint
Eye Irritation4
Headache5
Nausea6
^^sthma Attack7
Low
$21
$2
$29
$16
Mid-Range
$21
$13
$29
$43
High
$46
$67
$84
$71

               Ecological Risk
               A potential ecological benefit of using ink formulations with fewer hazardous chemicals
               is reduced aquatic toxicity and less hazardous waste that needs to be disposed of in the
               community.  Aquatic toxicity can negatively affect fish populations near the points of
               discharge and lead to a reduction in the variety of fish species  (particularly species
               intolerant of environmental stressors) or a reduction in the size of fish populations. Such
               impacts on fish populations can impair recreational and commercial fishing opportunities.
               An ink system that results hi the discharge of fewer  chemicals of concern to aquatic
               populations  could therefore  lead  to direct  economic  benefits  in  the  communities
               surrounding the facility.

       Summary of Social Benefit-Cost Assessment

               The following sections present a summary of each of the three ink system technologies
               across the benefit and cost categories discussed in this chapter.

               Solvent-based Inks

                   •  The solvent-based ink system, on average, had lower total operating costs than
                      UV-cured inks, but higher than water-based ink systems. This higher cost can be
                      attributed mostly to higher material and capital costs of solvent-based technologies.
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                                                           •\
                      In particular, average material costs for solvent-based systems (per 6,000 square
                      feet of image) were approximately $5.00 higher than those  for water-based
                      .systems.
                  •   In the performance area, the solvent-based system on average outperformed both
                      water-based and  UV-cured systems.  This system was the best with respect to
                      gloss and trap and among the best on the other three summary performance tests.
                  •   On average,  solvent-based inks  contained two to four chemicals  of  clear
                      occupational risk, slightly higher than the ranges for water-based and UV-cured
                      inks.  This may indicate a higher occupational risk.
                  •   Public health risk was evaluated through releases of smog-related compounds,
                      VOC  and HAP content, and the systemic and developmental risks to  the general
                      population.  Despite the fact that this  system used oxidizers,  emissions were
                      calculated to be considerably higher than the emissions of the other systems.  VOC
                      content was, as expected, much higher than either of the two other systems. This
                      system did  not contain any HAPs. For general population risks, two  chemical
                      categories in Solvent #2 presented a possible risk.
                  •   In terms of process safety, solvent-based inks had more concerns than the other
                      systems,  although the results for UV-cured inks were incomplete.  Only solvent-
                      based inks presented  an ignitability  concern  and  also presented  a higher
                      flammability concern than water-based inks.
                  •   Solvent-based inks were shown to use more energy to produce the same square
                      footage of image.

               Water-based Inks

                  •   Operating costs were lowest for the water-based ink product lines. In fact, in all
                      cost categories,  water-based  ink systems had the lowest average  cost.  Cost
                      savings were particularly pronounced for material costs.
                  •   Though water-based ink formulations #2 and #4 had the best mottle scores of all
                      product lines, overall the water-based inks did not perform as well as  the solvent-
                      based inks in the five summary performance categories.  The system also was
                      outperformed by the UV-cured inks in three categories. While this may indicate
                      a lower quality product, it is important to note that in many cases the differences
                      were small and may be insignificant.
                   •   In the occupational health area,  water-based inks presented  a lower average
                      number of chemicals clear or clear SAT risk per product line, indicating a better
                      chance of reducing occupational health risks compared to the baseline.
                   •  The amount of smog-related emissions that resulted from ink releases and energy
                      production with the water-based system was considerably lower than that from
                      solvent-based system, and was comparable to that from the UV-cured system.
                      Water-based inks had a much lower  VOC content than solvent-based inks, but
                      were the only inks that contained HAPs.
                   •  Like  with solvent-based inks, printers often add VOC solvents and additives at
                      press side to water-based inks. In substantial amounts, these materials compromise
                      the low-VOC content of the ink and can pose clear pressroom  worker risks.  At
                      one site using water-based inks (Site 3), over half of the emissions resulted from
                      materials added  at press-side.
                   •  The safety of water-based inks was better than that of solvent-based  inks.  There
                      was no indication of ignitability or reactivity.  However, water-based inks had a
                      higher flammability risk than UV-cured inks.
                   •  As for energy expenditures, water-based inks had the lowest average energy use.
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                UV-cured Inks

                   •   The UV-cured inks had the highest average operating costs. However, since it is
                       a new developing technology for wide-web film, these costs are likely to fall as
                       the technology develops.   The biggest cost differential was the material costs,
                       falling approximately $8.00 per 6,000 ft2 of image above the average costs for
                       water-based inks. It is also worth noting that energy costs of the UV systems were
                       considerably higher — nearly two times the cost for solvent-based inks and nearly
                       three times the cost for water-based inks.
                   •   The performance of the UV-cured inks was generally worse than the solvent-based
                       baseline, though this system had better blocking resistance, and individual product
                       lines had ice water crinkle and mottle results that were equal to the solvent-based
                       results. The performance results were slightly better than those of the water-based
                       inks.
                   •   The UV-cured inks presented the lowest chance of occupational health risk, and
                       with respect to public health, had the lowest HAP and VOC contents.  A couple
                       SAT-analyzed compounds  may present a possible  general population risk,
                       however,  indicating that research on some compounds is needed.
                   •   Safety hazard  data were incomplete for UV inks.  However, UV inks were the
                       only inks that present the potential for reactivity.
                   •   Finally, the energy used by UV-cured systems was approximately 22% less than
                       that of the baseline, and was only slightly higher than that of the water-based inks.
                       The  air releases associated with the energy production were higher than the
                       baseline, however,  because all energy required by the UV system was derived
                       from electricity — a more  pollution-intensive energy source in comparison to
                       natural gas.

               The intent of this benefit-cost assessment is to illustrate the possible benefits and costs of
               switching ink systems and  to give individual printers insight into the  potential  social
               benefits and costs of their current ink system.  When drawing conclusions from the above
               discussion in this chapter, it is important to note that many of the results are based on the
               performance demonstrations conducted for this report.  Printers may therefore find that
               an individual facility will not experience similar results in some or all of the benefit-cost
               categories. If a printer chooses to make a change in ink systems, it  is important  to
               consider the specific needs and requirements of the facility and the printer's customers.
8.3 DECISION INFORMATION SUMMARY

       Introduction

               This CTSA presents comparative information on the relative risk, performance, costs, and
               resource conservation of the three flexographic ink systems. However, it does not provide
               recommendations or judgments about whether or not to implement an alternative.  This
               section may assist decision makers in choosing the most appropriate ink technology for
               individual circumstances.  There are three parts in this section:

               The ink system comparison summarizes the findings of Sections 8.1 and 8.2 with respect
               to solvent-based, water-based, and UV-cured inks. By integrating the findings of the first
               section and the practical benefits and  costs described in the second,  this comparison
               describes the anticipated impacts of each system based on the findings of the research in
               this CTSA.
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               After an ink system is selected, it is necessary to select specific formulations.  The
               chemical categories section presents the hazard, risk, and regulatory characteristics of the
               groups  of chemicals in this CTSA.   This section may be useful for printers and ink
               formulators alike  who wish to identify chemicals that should be avoided or that are
               potentially safer substitutes for harmful ingredients.

               The final section, suggestions for improvements, summarizes the steps that can be taken
               by printers and ink companies  to minimize the health and environmental risks of inks and
               considerations for selecting the best ink formulations for a facility.

       Ink System Comparison

               As indicated in Sections 8.1 and 8.2, the results did not identify any one ink system as a
               best choice for all situations.   This section discusses the relative benefits and drawbacks
               that were found with each system.

               Baseline: Solvent-based inks
               The solvent-based inks were  the baseline for this  analysis, and they displayed  solid
               performance characteristics and reasonable costs — two factors of primary concern to
               many decision makers.  However, the analysis indicated that they fared poorly on other
               factors, such as health risks, safety hazards, regulatory costs, and energy use.

               The strength of the solvent-based inks in this CTSA was performance. On average, this
               system produced the best performance results on four of the five  tests discussed in this
               chapter.  The results indicated that these particular inks may  be the most appropriate for
               particularly challenging printing tasks,  such when process colors  must be  matched
               precisely or when the product is intended for use in cold, wet conditions.

               Health risks,  safety  hazards, regulatory costs, and energy use generally were negative
               aspects of the solvent-based inks. As indicated in Table 8.4, solvent-based inks had the
               highest average number of chemicals of clear worker risk per formulation (3.2). Most of
               the chemicals of clear risk were solvents, with some of those added at press side. The
               solvent-based inks had the highest VOC  content— an average  of 58% by weight.  This
               directly affected the emissions rate of smog-related compounds — the average rate (914
               g/6,000 ft2) was more than three times the average rate for  water-based and UV-cured
               systems (221 and 300 g/6,000 ft2, respectively) at the  assumed capture efficiency rate.
               The solvent-based inks were the only formulations that were classified as ignitable, and
               they also had a relatively high flammability rating of 3 (on a scale of 0-4).

               Under the operating parameters assumed for this analysis, the high health risk and safety
               hazard indicators  suggest that these solvent-based inks may result in costs to the firm in
               the  form of more worker sick days, decreased worker satisfaction, decreased worker
               productivity,  and increased insurance premiums.  These costs would result  in lower
               profits.  Possible social impacts of solvent-based inks include increased sick days among
               the general public and an increase in health care costs.  The flammability and ignitability
               of the formulations may require more effort to comply with environmental and fire
               regulations, thereby increasing waste disposal and storage costs.  (Note,  however, that
               solvent-based waste can be incinerated for energy recovery or distilled for reuse. Either
               of these  practices may reduce waste  disposal costs.)  Finally, because oxidizers are
               required when using solvent-based inks, energy use was the highest for this system. The
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               emissions associated with this energy consumption, however, were comparable to those
               of the other two systems, because much of the energy was derived from relatively clean-
               burning natural gas.

               As shown in Table 8.6, the average operating cost of the solvent-based inks ($32.98 per
               6,000 ft2) was higher than that of the water-based inks ($26.60 per  6,000 ft2), but lower
               than that of the UV-cured inks ($36.82 per 6,000 ft2).  Costs were increased by the use of
               an oxidizer and the high ink consumption rate but were moderated by the relatively low
               per-pound price of ink.

               Alternative #1:  Water-based inks
               The water-based inks that were evaluated had both private advantages and disadvantages;
               however, the social impacts of water-based inks appear to be of less concern in comparison
               to the solvent baseline.

               This ink  system had inconsistent performance test results.  Though  some individual test
               results were better than the baseline, the average outcome of the water-based inks for each
               test was poorer than that of the solvent-based inks.  Such a decrease in quality may either
               prevent printers from switching technologies or may require them to take steps to improve
               the quality. Two water-based product lines had better mottle results than the baseline, and
               in general the gloss and blocking were  comparable to the solvent-based  inks.  Under
               conditions  where  the product is subjected to minimal physical demands, the visual
               characteristics of water-based inks, may be similar  to  those  of  solvent-based inks.
               However, if the ink were to be exposed to cold or wet conditions — like those measured
               by the ice water crinkle test — these product lines may compare unfavorably to solvent-
               based inks or may require modifications.

               By some measures, a switch to water-based inks may yield both private and social benefits
               with respect to health risks and safety hazards. In terms of safety hazards, none of the inks
               were ignitable or reactive. The flammability of the water-based inks ranged from 0-3, in
               contrast to solvent-based inks which were all rated 3.  The VOC content was an average
               of 6 % by weight, compared to the concentration of nearly 60 % in solvent-based inks.  For
               inks  with low flammability and  VOC content,  improvements  may be seen  in lower
               insurance premiums, worker's compensation expenditures, and regulatory costs compared
               to those for the baseline. From a social perspective, a reduction of VOC emissions may
               have impacts  beyond the printing facility, possibly including a reduction in cases of
               asthma, red eyes, and headaches. The economic benefit of avoiding additional cases of
               these  ailments  potentially  could include  reduced medical expenditures,  increased
               productivity, and reduced pain and suffering.

               Other health risk and safety measures indicated that the water-based  inks may have been
               comparable to or worse than the baseline.  There was an average of 3.1 compounds of
               clear or moderate worker health risk in the water-based inks, which  was close to the 3.2
               found hi the solvent-based inks. Some of this risk — one compound of clear concern per
               formulation on average — resulted from the press-side addition of solvent and additives.
               Three of the four water-based ink product lines contained HAPs, while none were found
               in the other two systems.  The variability of health risks and safety hazards of these water-
               based inks  relative to  the baseline  highlights the importance of carefully scrutinizing
               information about particular formulations.
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              Benefits associated with a switch to the water-based inks in this analysis also include a
              decrease hi energy use and costs. The system used approximately 73,000 Btu per ft2 of
              image — the lowest  among the ink systems and 27%  less than the solvent-based inks.
              Private benefits of reduced energy use include reductions in the cost of energy.  Social
              benefits include lower emissions at the sources of energy generation (i.e., electric power
              plants and the exhaust stack of natural gas furnaces), reduced demand for fossil fuels, and
              decreased strain on the capacity of the power grid.

              The cost of using the water-based inks also was lower.  This system was, on average,
              $6.40 less  expensive than the baseline per 6,000 ft2 of image.  The lower cost resulting
              from a switch to these water-based inks has obvious benefits for a printer's profitability,
              and also may result in benefits to the public in the form of  lower prices for printed
              products.  When considering a switch from the baseline to a  water-based ink system,
              additional costs for the retraining of workers would be incurred.  These costs should be
              taken into account in the overall decision.

              New Emerging Technology: UV-cured Inks
              Research in this CTSA indicated that a switch to the tested UV-cured inks may present
              higher private  costs  in comparison to the baseline,  because of lower performance and
              higher operating costs. It is worth noting that developing technologies often have higher
              operating costs. However, performance shortcomings indicate  there is room to improve
              UV-cured  formulations and to optimize UV equipment for wide-web film applications.

              The performance results for the UV-cured  inks were mixed. They performed better than
              the baseline on one test (blocking resistance), but produced mostly poorer results on the
              other tests. These results indicate that UV-cured inks may be an appropriate choice for
              certain film applications that require pressure and heat resistance, but that a UV system
              may require modifications,  such  as  different-sized anilox  rolls, to  improve other
              performance characteristics.  The performance of these inks  may represent a cost to
              printers who are switching in that either a lower quality product is produced  or that
              significant effort  is  required to improve the quality.   Lower quality products affect
              consumers in that printed products, such as packaging, may have less realistic colors and
              lower durability.

              These inks showed potential for greater social benefits arising from reduced health risks
              and safety  hazards, An average of 2.4 compounds of clear or moderate occupational risk
              concern were found in the UV  formulations,  which was lower than the average for the
              baseline. There were no HAPs in the formulations, and based  on post-curing estimates,
              the system had a VOC content below 1 %. Safety hazard information was incomplete, but
              the  formulations for which information was available had a reactivity level of 1, a
              flammability of 1 (both on 0-4 scales of increasing  severity), and no ignitability.  UV-
               cured product lines #1 and #3 were calculated to have smog-related emissions of 187 and
               191 g/6,000 ft2 of product, respectively (based on the uncured formulations). These were
               the  lowest emission  rates of all product lines in the three systems. In contrast to these
               relatively low figures, however, UV-cured ink #2 had VOC emissions expected to be 523
               g/6,000 ft2. The benefits of switching to a UV-cured ink, therefore, may be formulation-
               specific. It should be noted that many  compounds used in UV-cured inks have not been
               subjected to toxicological studies. As a result, conclusions about the risks associated with
               these inks can not be  as certain  as  conclusions based primarily  on  toxicological
               information.
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               The UV-cured inks consumed less energy (78,000 Btu per 6,000 ft2) than the solvent
               baseline (100,000 Btu per 6,000 ft2), but more than the water-based inks (73,000 Btu per
               6,000 ft2). As indicated in Table 8.5, the releases of smog-related compounds associated
               with UV-cured energy consumption  were the greatest  among those  of the three ink
               systems, because electricity — the sole form of energy used by the UV system — is more
               pollution-intensive than natural gas. This pollution is not evident at the facility, however,
               because the emissions are released at the site of the power plant.

               The UV-cured inks had the lowest ink consumption rate of the three systems. An average
               of 2.78 pounds of UV-cured ink and additives were consumed per 6,000 ft2 of image; in
               contrast, the water-based system consumed 4.57 pounds of ink and additives per 6,000 ft2,
               and solvent-based inks consumed 8.11 pounds per 6,000 ft2.

               With regard to costs, the  UV ink  system was  the most expensive of the three, costing
               approximately $3.80 per 6,000 ft2 of image more than the solvent baseline and $10 more
               than the water based system.  Two factors drove this high cost.  The per-pound ink price
               was the highest of the three ink systems. One reason for this is that higher-grade pigments
               are required in order to minimize product performance issues.8  Another factor is that the
               system exclusively uses electricity, which is more expensive than natural gas.  A switch
               to these UV-cured inks could result in a private cost to printers,  and may negatively affect
               consumers, because the cost might be translated into higher prices for materials printed
               with UV-cured inks.

               Summary
               No ink system is inherently free of human health risks and safety hazards. There are many
               tradeoffs  in  every system.    Many  solvent-based   inks have undergone  technical
               reformulating in recent years to reduce the use of some of the more hazardous substances.
               Also, printers using solvent systems are required to use oxidizers, which can substantially
               reduce VOC  air  emissions from  these inks.   (Oxidizers do not,  however,  protect
               pressroom workers from the effects of solvents.) UV inks, because they are much newer,
               contain many more untested chemicals,  and the risks of exposure to many  of them are
               largely unknown.  Water-based inks gained popularity initially in part because they were
               thought to be safer than solvent inks.

               However,  as shown by  this CTSA, the relative occupational risk reductions are
               formulation-specific.  Some water-based inks do potentially pose a lower risk than some
               solvent-based inks.  There were fewer chemicals of clear worker health risk in some
               formulations, and water-based ink #2 did not contain compounds with clear developmental
               risks.  This was not true for water-based ink #4, however; the range in the number of
               chemicals of clear occupational risk was slightly higher than the baseline, and this product
               line had a VOC content of 14% by weight.  For a water-based ink, it is important to keep
               the VOC content as low as possible since no emission controls  are used with these inks.

               Another issue that emerged from the results are that press side solvents and additives can
               increase the risk to workers using ink.  In both solvent-based and water-based inks, some
               solvents and additives added at press side presented a clear occupational risk.  In water-
               based inks in particular, a third of the chemicals  of clear concern were added at press side.
               This point highlights both the risks associated with working with press side solvents and
               additives and the worker health improvements that can be made by minimizing their use.
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       Highlights of Chemical Category Information

               As noted in earlier sections of this chapter, there can be significant variation in the risks
               of different ink product lines, even within one ink system.  The risk associated with a
               formulation often can be driven by just a few individual compounds. This section includes
               information about the hazard, risk, and regulatory information for each compound used
               in this CTSA, grouped by chemical category.  This information may be helpful for printers
               who  wish to identify compounds  that may present issues  for  human health and  the
               environment.  Ink formulators may use this  information to help identify  chemical
               compounds that contribute to the overall risk of a formulation, as well as compounds that
               are worth considering as possible safer alternatives.

               This  section presents an overview and interpretation of the hazard, risk, and regulatory
               information. The following section — Hazard, Risk, and Regulation of CTSA Chemicals
               — consists of a more detailed description of each chemical category.

               Hazard and risk
               Hazard represents  a compound's inherent ability  to  cause  harm  to health, that is,
               regardless of its concentration in  an ink.   Risk describes  the  relationship between a
               compound's hazard level and its potential for exposure.  Because potential for exposure
               is a factor of the compound's concentration in the ink as well as its chemical properties,
               the concentration of a chemical in a formulation affects its risk. As shown in Table 8.13
               in the next section, a chemical can have a low hazard score and a high risk score if the
               chemical is  used in fairly high concentrations in an ink formulation.  Thus, it is  not
               necessarily true that pressroom workers can be safely exposed to inks even if they do not
               contain any highly hazardous chemicals.

               The reverse may also be true. A chemical with a high hazard score can receive a low risk
               score because it has a very small concentration hi the ink that was tested for the  CTSA.
               That does not indicate, however, that the chemical is safe in all ink formulations. If the
               same chemical had been present in a high concentration in another formulation, it might
               have received a high risk score as well. Thus, it is important to pay close attention to both
               hazard and risk when this information is available.

               It is also important to consider aquatic risk.  Though it was assumed in this CTSA that ink
               would not be released to the aquatic environment, accidental releases are possible.  As
               noted in Chapter 3 (Risk), 18 of the compounds were of high hazard concern for aquatic
               effects, and another 35 were  of  medium hazard concern.   The aquatic  hazard of
               ingredients should considered in order to minimize the impacts associated with potential
               discharges of ink.

               Toxicological and SAT data
               Ideally, a chemical's ability to cause harm in animals and humans is measured by
               toxicological studies. However, less than half of the compounds used in this CTSA have
               been subject to toxicological testing. (This situation is generally true beyond the inks that
               were used in this CTSA. Many hundreds of new chemicals enter the market each year,
               and  testing has not kept up  with these advances.)   For CTSA  chemicals with no
               toxicological data,  EPA's Structure Activity Team (SAT) estimated toxicity based on the
               compound's molecular structure and its similarity to compounds that have been studied.
               SAT findings, although developed by experts and far better than no information, are
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                inherently less reliable than toxicological studies, because they are not based upon actual
                tests of the chemical in question.

                It is important, therefore, to know more about chemicals for which no toxicological data
                are available. As discussed in the hazard and risk section, a chemical with a low SAT risk
                concern may in fact be present in a particular formulation in a high enough concentration
                to be a worker health issue.

                Exposure via dermal and inhalation routes
                Flexographic workers can come into contact with all chemical  compounds in ink
                formulations through dermal (skin) exposure, particularly if they do not consistently wear
                contact-barrier gloves while working with or in the immediate vicinity of inks. In contrast,
                workers are only subject to inhalation exposure from compounds that are volatile (have a
                vapor pressure at ambient temperatures). For compounds in this CTSA that did not have
                a significant vapor pressure (0.001 mm Hg or greater), their inhalation risk is noted as "no
                exposure."

                Fifteen chemicals that were tested in the CTSA presented a clear dermal risk, and eleven
                others had a possible dermal risk, documented with toxicological data. These chemicals
                spanned all ink systems, and  a number of them are not explicitly regulated under any
                federal acts included in the table. SAT findings indicate that many other chemicals may
               also be of concern for dermal  exposure. This finding indicates that flexographic workers
               can come into skin contact with multiple chemicals that carry significant health and safety
               risks. The compounds that presented clear risk as determined by toxicological data or the
               SAT are presented in Table 8.10.

               Dermal exposure can be avoided mostly thorough implementation of a policy that requires
               workers to wear contact-barrier gloves while working with ink (and other chemicals),
               whether or not they expect to contact the ink directly.  Butyl (preferred) and nitrile gloves
               are considered appropriate for inks. Latex gloves offer little or no protection because they
               degrade rapidly after being exposed to  many ink chemicals.
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                                Table 8.10  Compounds of Clear Dermal Risk
Chemical Category
Acrylated polyols
Acrylated polymers
Alcohols
Alkyl acetates
Amides or nitrogenous compounds
Ethylene glycol ethers
Inorganics
Organophosphorous compounds
Organotitanium compounds
Pigments — organic
Pigments — organometallic
Chemical
Dipropylene glycol diacrylate
1 ,6-Hexanediol diacrylate
Hydroxypropyl acrylate
Trimethylolpropane triacrylate
Glycerol propoxylate triacrylate
Ethanol
Isopropanol
Butyl acetate
Ammonia
Ammonium hydroxide
Ethanolamine
Hydroxylamine derivative
Alcohols, C11-15-secondary,
ethoxylated
Butyl carbitol
Ethyl carbitol
Barium
Phosphine oxide, bis(2,6-
dimethoxybenzoyl) (2,4,4-
trimethylpentyl)-
Isopropoxyethoxytitanium bis
(acetylacetonate)
Titanium diisopropoxide bis(2,4-
pentanedionate)
Titanium isopropoxide
C.I. Pigment Red 23
D&C Red No. 7
Data Source
SAT
SAT
Tox
Tox
Tox
Tox
Tox
Tox
Tox
Tox
Tox
SAT
SAT
Tox
Tox
Tox
Tox
SAT
SAT
SAT
Tox
Tox
               For inhalation risk, twelve chemicals showed a clear inhalation risk to pressroom workers
               based on toxicological data. SAT findings indicate that three more chemicals present a
               clear inhalation risk.  These chemicals are listed in Table 8.11.

               It is much more difficult to protect pressroom workers from inhalation exposure to ink
               chemicals than from dermal exposure.  This is of particular concern for chemicals that
               have a clear or possible inhalation risk from toxicological studies, as well as those of
               moderate to high inhalation risk via SAT findings.  Inhalation exposure can be minimized,
               however, by using enclosed doctor blades and providing sufficient ventilation.
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                               Table 8.11 Compounds of Clear Inhalation Risk
                      Chemical Category
             Chemical
                                   Data Source
Acrylated-polyols '
Alcohols
Alkyl acetates
Amides or nitrogenous compounds
Ethylene glycol ethers
Hydrocarbons — low molecular
weight
Dipropylene glycol diacrylate
1 ,6-Hexanediol diacrylate
Hydroxypropyl acrylate
Ethanol
Isobutanol
Isopropanol
Butyl acetate
Ethyl acetate
' Ammonia
Ammonium hydroxide
Ethanolamine
Hydroxylamine derivative
Butyl carbitol
Ethyl carbitol
n-Heptane
SAT
SAT
Tox
Tox
Tox
Tox
Tox
Tox
Tox
Tox
Tox
.SAT
Tox
Tox
Tox
              Regulatory status
              Some of the compounds in this CTSA are regulated under major federal environment,
              health and safely acts.  The following federal regulations were considered:

                  •   Clean Air Act (CAA)
                  •   Resource Conservation and Recovery Act (RCRA)
                  •   Toxic Substances Control Act (TSCA)
                  •   Clean Water Act (CWA)
                  •   Safe Drinking Water Act (SDWA)
                  •   Comprehensive Environmental Response,  Compensation, and  Liability Act
                     (CERCLA)
                  •   Emergency Planning and Community Right to Know Act (EPCRA)
                  •   Occupational Safety and Health Act (OSH Act)

              Table 8.13 shows the regulation (last column) for each explicitly regulated compound. In
              addition, chemicals that appear to be  "unregulated" in fact may be regulated due to their
              properties; for example, many compounds are regulated as VOCs because they match the
              definition (all organic compounds except those that are determined by EPA to be negligibly
              photochemically reactive).

              Of the more than 100 chemicals studied hi this CTSA, only 25% are explicitly regulated
              by any of the major federal environmental and health acts.  Of the roughly 75 other
              compounds, 11 presented a clear occupational risk and another 36 presented possible
              occupational risk. Table 8.12 presents the compounds that posed a clear or possible
              occupational risk based on either* toxicological data or SAT evaluations that are not
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              explicitly listed in regulations.  The large number of compounds not explicitly regulated
              that were of clear or possible risk concern indicates that at least for the flexographic inks
              studied in this analysis, significant risk may be present in a formulation despite a lack of
              regulatory requirements.

                 Table 8.12 Compounds of Clear or Possible Occupational Risk Not Explicitly
                                                Regulated8
Chemical
C.I. Pigment Red 23
D&C Red No. 7
Glycerol propoxylate triacrylate
Phosphine oxide, bis(2,6-dimethoxybenzoyl)
(2,4,4-trimethylpentyl)-
Trimethylolpropane triacrylate
Alcohols, C11-15-secondary, ethoxylated
Dipropylene glycol diacrylate
Hydroxylamine derivative
Isopropoxyethoxytitanium bis (acetylacetonate)
Titanium diisopropoxide bis(2,4-
pentanedionate)
Titanium isopropoxide
C.I. Pigment Green 7
Diphenyl (2,4,6-trimethylbenzoyl) phosphine
oxide
Distillates (petroleum), solvent-refined light
paraffinic
2-Hydroxy-2-methylpropiophenone
2-Methyl-4'-(methylthio)-2-
morpholinopropiophenone
Propylene glycol propyl ether
Acrylated epoxy polymer
Acrylated oligoamine polymer
Acrylated polyester polymer (#s 1 and 2)
Acrylic acid polymer, insoluble
Butyl acrylate-methacrylic acid-methyl
methacrylate polymer
C.I. Basic Violet 1 , molybdatephosphate
C.I. Basic Violet 1,
molybdatetungstatephosphate
C.I. Pigment Red 48, barium salt (1:1)
C.I: Pigment Red 48, calcium salt (1:1) ,
C.I. Pigment Red 52, calcium salt (1:1)
Data
Source
ox
ox
ox
ox
Tox
SAT
SAT
SAT
SAT
SAT
SAT
Tox
Tox
Tox
Tox
Tox
Tox
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
Dermal Risk
Level
lear
Clear
Clear
Clear
Clear
Clear
Clear
Clear
Clear
Clear
Clear
Possible
Possible
Possible
Possible
Possible
Possible
Possible
Possible
Possible
Possible
Possible
Possible
Possible
Possible .
Possible
Possible
Level
.e.
.e.
.e.
.e.
.e.
.e.
Clear
Clear
n.e.
n.e.
n.e.
n.e.
n.e.
Possible
Possible
n.e.
Possible
n.e.
n.e.
n.e.
n.e.
n.e.
n.e.
n.e.
n.e.
n.e.
n.e.
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                   Table 8.12 Compounds of Clear or Possible Occupational Risk Not Explicitly
                                             Regulated (continued)
Chemical
C.I. Pigment Violet 27
C.I. Pigment White 7
C.I. Pigment Yellow 14
Distillates (petroleum), hydrotreated light
Ethoxylated tetramethyldecyndiol
Methylenedisalicylic acid
Nitrocellulose
Paraffin wax
Polyethylene glycol
Propyl acetate
Rosin, polymerized
Siloxanes and silicones, di-Me, 3-
hydroxypropyl Me, ethers with polyethylene
glycol acetate
Silanamine,1,1,1 -trimethyl-N-(trimethylsilyl)-,
hydrolysis products with silica
Solvent naphtha (petroleum), light aliphatic
Styrene acrylic acid polymer (#s 1 and 2)
Styrene acrylic acid resin
Thioxanthone derivative
rrimethylolpropane ethoxylate triacrylate
rrimethylolpropane propoxylate triacrylate
Data
Source
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
Dermal Risk
Level
Possible
Possible
Possible
Possible
Possible
Possible
Possible
Possible
Possible
Possible
Possible
Dossible
Possible
Possible
Possible
3ossible
Possible
Possible
Possible
Inhalation Risk
n.e.
n.e.
n.e.
Possible
n.e.
n.e.
n.e.
n.e.
n.e.
Possible
n.e.
n.e.
n.e.
Possible
n.e.
n.e.
n.e.
n.e.

                n.e.: No exposure via indicated exposure route
                • This list contains chemicals that are not explicitly listed under federal laws and regulations.
                Chemicals in this list may be subject to general requirements, such as those that address VOCs.
        Hazard, Risk and Regulation of Individual CTSA Chemicals

               This section contains hazard, risk, and regulatory information for each compound used in
               this CTSA. The intent of this section is to summarize the hazard and risk findings of the
               CTSA for the decision maker. It is intended to be a starting point in the evaluation of a
               chemical for use in new formulations.  The data are presented in Table 8.13.

               The hazard and risk  information is presented separately  for inhalation and dermal
               exposure.  For both exposure routes, hazard effects can be either systemic (affecting an
               organ system of the body, such as the lungs) or developmental (associated with the growth
               and maturation of an organism).  The notation used in Table 8.13 allows presentation of
               both systemic and developmental effects for each chemical category. The first letter that
               appears in each human health hazard column of  the table  represents the concern for
               systemic effects; the  second represents the concern for developmental  effects.   For
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               example, the second compound in the table, 1,6-hexanediol diacrylate, has "M/L" under
               Dermal Hazard. This indicates a moderate hazard of systemic effects, and a low hazard
               of developmental effects.

               Table 8.13 also includes the results of the risk analysis performed in this CTSA.  Risk
               incorporates  a compound's hazard level  and  its potential for exposure to produce an
               overall risk ranking. Dermal risk levels were determined based on model assumptions of
               routine two-hand contact by workers in both the preparation room and the press room, and
               are considered high-end estimates. Inhalation risks were expected only for press room
               workers.  Because potential for exposure depends on the compound's concentration in the
               ink as well as its chemical properties, the risk rating of a chemical can vary among ink
               formulations if its concentration is different.  Table 8.13 lists the highest observed risk
               rating.

               The final column of Table 8.13, Regulatory Concern, lists the regulations under which
               each compound is explicitly regulated. It should be noted that this is not an exhaustive list
               of regulatory requirements associated with each compound.

               The  following paragraphs summarize the hazards and risks of the  chemicals in each
               chemical category.  Though hazards  and  risks can vary among chemicals within a
               category, there are trends in exposure pathways and the magnitudes of concern that can
               be-useful to printers and formulators who use  chemicals in these categories.

               Aery lated polyols
               Compounds in this category were used in  UV-cured inks as monomers. Of the four
               compounds, two (hydroxypropyl acrylate and trimethylolpropane triacrylate) have been
               subjected to toxicological testing. Both had a medium hazard concern for systemic effects
               via dermal exposure, and both were found hi the inks in sufficient quantities to present
               clear risk via dermal exposure.  Hydroxypropyl acrylate also posed a medium systemic
               hazard concern and clear risk via inhalation. Trimethylolpropane triacrylate did not have
               an appreciable vapor pressure and therefore  did not pose  a hazard or risk concern via
               inhalation. Both of these compounds had a medium aquatic hazard level, but neither had
               a cancer hazard rating.

               The two compounds analyzed by the Structure Activity Team (SAT), dipropylene glycol
               diacrylate and 1,6-hexanediol diacrylate, presented medium hazard and clear risk concern
               by both dermal and inhalation exposure routes.  The two compounds presented moderate
               and high hazard levels, respectively, for  aquatic effects, and both were expected to have
               a low-moderate hazard level for carcinogenic effects.

               Two compounds in this category,  1,6-hexanediol diacrylate and hydroxypropyl acrylate,
                are regulated under TSCA.  In general, these compounds presented a clear occupational
                risk concern but have not been well studied.

               Aery lated polymers
                These six compounds were used in UV-cured inks as monomers and polymers.  One
                compound, glycerol propoxylate triacrylate,  was determined based on toxicological data
                to have a medium systemic dermal hazard level, and because of its concentration in the
                formulations, presented a clear dermal occupational risk. It also had a high aquatic hazard
                level.
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                             For each of the other five compounds, the SAT found that they had a low-moderate dermal
                             hazard level and possible dermal occupational risk.  No exposure via inhalation was
                             expected.  Of these compounds, trimethylolpropane ethoxylate triacrylate had a high
                             aquatic hazard level, trimethylolpropane propoxylate triacrylate had a medium aquatic
                             hazard level,  and the other three - acrylated epoxy polymer, acrylated ologoamine
                             polymer, and acrylated polyester polymer - had a low aquatic hazard level. All five of
                             the SAT-evaluated compounds had a low-moderate cancer hazard level.

                             Aside from those that qualify as VOCs, none of the compounds are regulated under the
                             federal regulations discussed in this report.

                            Acrylic acid polymers
                            Compounds in this category were  used as oligomers in water-based inks.   Four
                            compounds, acrylic acid-butyl  acrylate-methyl methacrylate  styrene polymer, butyl
                            acrylate-methacrylic acid-methyl methacrylate polymer, and acidic acrylic acid polymers
                            #1 and #2 were assigned low dermal hazard levels by the SAT and possible risk ratings.
                            The other four compounds were assigned low-moderate hazard ratings and possible
                            occupational risk ratings  via dermal exposure by the SAT. Five of the compounds  -
                            acidic acrylic acid polymers #1  and #2, styrene acrylic acid polymers #1 and #2, and
                            styrene acrylic resin — were assigned medium aquatic hazard ratings and the other three
                            compounds were assigned low ratings.  None of the compounds were known to present a
                            cancer hazard, nor are they explicitly regulated under the federal regulations discussed in
                            this report.

                            Alcohols
                            Alcohols were used in all three ink systems as solvents.  All except tetramethyldecyndiol
                            have received toxicological testing and had human health hazard and occupational risk
                            concern via both dermal and inhalation exposure. Most compounds presented only low
                            or medium  hazard concern, but because of their typically high concentrations, their
                            occupational risk  levels  were higher.   Three had  a clear inhalation risk  (et'hanol,
                            isobutanol, and isopropanol), and two had a clear dermal risk (ethanol and isopropanol)'
                            Tetramethyldecyndiol, as determined by the SAT, had a medium aquatic hazard level; the
                            other compounds had a low aquatic hazard level.

                           Ethanol has been assigned by the International Agency for Research on Cancer (IARC) as
                           a Group 1 compound, indicating that it is carcinogenic to humans.  Isopropanol has been
                           assigned as an IARC Group 3 compound, indicating that its characteristics with respect to
                           cancer are not classifiable.  Propanol has been assigned as an EPA Group C compound,
                           indicating that it is a possible human carcinogen.

                           Three compounds hi this category have OSHA Personal Exposure Limits (PELs); for
                           ethanol, it is 1000 ppm, for isobutanol, it is 100 ppm, and for isopropanol, it is 400 p'pm.
                           Three compounds are regulated by TSCA, and RCRA, CERCLA, and EPCRA regulations
                           apply to one compound.

                           Alkyl acetates
                           The three compounds in this category were used as solvents in solvent-based inks.  Butyl
                           acetate and ethyl acetate have been subjected to toxicological testing. Like alcohols, they
                           had fairly low human health hazard levels, but their relatively high concentrations in'these
                           inks caused both compounds to have a clear occupational risk concern via inhalation
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              exposure.  Butyl acetate also presented a clear occupational risk via dermal exposure.
              Propyl acetate,  which was studied by the SAT,  was given low-moderate hazard and
              possible risk concern levels via both exposure pathways. All three compounds presented
              a medium aquatic hazard, and none were known to pose a cancer hazard.

              Butyl and ethyl acetate are regulated under CERCLA, TSCA, and have OSHA PELs of
              150 ppm and 400 ppm, respectively.  In addition, butyl acetate is regulated under CWA
              and ethyl acetate is regulated under RCRA.

              Amides or nitrogenous compounds
              This is a broad category, incorporating compounds serving a variety of functions in all ink
              systems.  Four  compounds — ammonia,  ammonium hydroxide,  ethanolamine, and
              hydroxylamine derivative — presented a clear occupational risk concern via both dermal
              and inhalation exposure routes. Ethanolamine also presented a high human health hazard
              for developmental effects by both exposure routes. In contrast, the other three compounds
              presented low hazard and  occupational risk levels.  Two compounds — hydrogenated
              tallow amides and ammonia — presented  a high aquatic hazard, and three others —
              ammonium hydroxide, ethanolamine, and hydroxylamine derivative—presented a medium
              aquatic hazard concern. None of the compounds were known to present a cancer hazard.

              Ammonia and  ammonium hydroxide are subject to CWA,  CERCLA, and  EPCRA
              requirements, and ammonia is also subject to CAA, SARA, TSCA and has an OSHA PEL
              of 50 ppm.   Ethanolamine has an OSHA PEL of 3 ppm, and urea is regulated  under
              TSCA.

              Aromatic esters
              This category was comprised of two compounds found in UV-cured inks. Dicyclohexyl
              phthalate was an additive (a plasticizer)  and ethyl  4-dimethylaminobenzoate was  a
              photoinitiator.  Dicyclohexyl phthalate has been subjected to toxicological testing and
              presented a  low concern for both human health hazard and occupational risk, but a high
              concern for  aquatic hazard. The other, ethyl 4-dimethylaminobenzoate, was  analyzed by
              the SAT and was given a low-moderate human health hazard level and a possible risk level
              for  both dermal and inhalation pathways, a medium aquatic  hazard level, and a low-
              moderate cancer hazard  level.   Dicyclohexyl phthalate is regulated  under CWA,
               CERCLA, and TSCA.

              Aromatic ketones
               The seven compounds in this category were used as photoinitators in the UV-cured inks
               of this CTSA. One compound, 2-hydroxy-2-methylpropiophenone, presented a moderate
               hazard and  possible risk via both inhalation and dermal exposure based on toxicological
               data. For the other compounds, the concern was limited to dermal exposure. 2-methyl-4'-
               (methylthio)-2-morpholinopropiophenone presented moderate hazard concern and possible
               risk concern via dermal exposure based on toxicological data.  The other compounds had
               low human health hazard and low or possible  dermal  occupational risk concern.  2-
               Isopropylthioxanthone, 4-isopropylthioxanthone and thioxanthone derivative were found
               by the SAT to have a high aquatic hazard concern; three others  had a medium aquatic
               hazard concern.  None of the compounds were known to present a cancer hazard or are
               explicitly regulated under the federal regulations discussed in this document.
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                Ethylene glycol ethers
                These compounds were used as solvents in water-based inks.  Two compounds — butyl
                carbitol and ethyl carbitol — present clear occupational risk concern via both dermal and
                inhalation  exposure based  on toxicological data.  The three other compounds were
                analyzed by the SAT.  Ethoxylated C11-C15 secondary alcohols was given a moderate
                hazard level and clear occupational risk level via dermal exposure,  and no inhalation
                exposure was expected. The other two compounds, ethyoxylated tetramethyldecyndiol and
                polyethylene glycol, were given moderate hazard levels and possible dermal occupational
                risk levels. Ethoxylated Cl 1-C15 secondary alcohols presented a medium aquatic hazard;
                all others had a low aquatic hazard level. None of the compounds were known to present
                a cancer hazard.

                Both butyl  and ethyl carbitol are regulated under CAA, CERCLA, EPCRA, and TSCA.

                Hydrocarbons —high molecular weight
                The four compounds included in this category were used as  additives in solvent- and
                water-based inks. Based on toxicological data, solvent-refined light paraffinic distillates
                and paraffin wax were found to pose a possible occupational risk level by dermal
                exposure, and solvent-refined light paraffinic distillates also posed a possible occupational
                risk by inhalation exposure. Hydrotreated  light distillates were found by  the SAT to
                present a possible occupational risk by both dermal and inhalation exposure. Hydrotreated
                light distillates and mineral oil both presented high aquatic hazard, and hydrotreated light
                distillates  and  solvent-refined light paraffinic  distillates  have shown evidence  of
                carcinogeniciry in animals (but have not been evaluated formally by IARC or EPA).

               Mineral oil has been assigned an OSHA PEL of 5 mg/rn3.

               Hydrocarbons—low molecular weight
               The three compounds included in this category were found "in solvent- and water-based
               inks and performed different functions.  Heptane, though it posed only a  low hazard
               concern for both dermal and inhalation exposure based on toxicological data, presented
               a clear occupational risk .concern for inhalation, in part because of its greater concentration
               in some formulations. In contrast, styrene posed a high concern for developmental effects
               via inhalation based on toxicological data, but its relatively low  concentration resulted in
               just a rating of possible risk concern for inhalation effects. Light aliphatic solvent naphtha
               was given a low-moderate hazard and possible occupational risk rating for both dermal and
               inhalation exposure by the SAT. Heptane and styrene presented a high aquatic hazard
               concern, and light aliphatic solvent naphtha presented a medium aquatic hazard. There
               is evidence hi animals that styrene may be carcinogenic, but it has not been evaluated bv
               IARC or EPA.

               Two compounds are regulated under multiple federal  acts.  Heptane is regulated under
               TSCA and has an OSHA PEL of 500 ppm.  Styrene is regulated under CAA, CWA
               SDWA, CERCLA, SARA, EPCRA, TSCA, and has an OSHA  PEL of 100 ppm.

               Inorganics
               The compounds in this category perform a diverse set of functions in solvent- and water-
               based inks and have all been subjected to toxicological testing.  One of the compounds,
               barium, is of particular concern. It had a high hazard concern for developmental effects
               via dermal exposure, and had clear occupational dermal risk. The other two compounds,
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              kaolin and silica, had low human health hazard and occupational risk concern ratings, and
              all three compounds had low aquatic hazard ratings.  Two compounds may present a
              cancer hazard: silica in its crystalline form is classified by IARC as a Group 1 compound
              (carcinogenic to humans), and amorphous silica is classified as a Group 3 compound (not
              classifiable as to its carcinogenicity in humans); and kaolin has been reported to cause
              cancer in animals but has not been evaluated formally.

              Barium  and  kaolin have OSHA PELs of 0.5 mg/m3  and  15  mg/m3  (total  dust),
              respectively.  Barium is also regulated under RCRA, SDWA, SARA, and EPCRA.

              Olefin polymers
              The two compounds in this category, polyethylene and polytetrafluoroethylene, were used
              as  additives  (waxes)  in  solvent-based and UV-cured inks.   Polytetrafluoroethylene
              presented low dermal hazard and risk concern based on toxicological information.
              Polyethylene was determined through SAT evaluation to have a low hazard and possible
              dermal risk concern.  Both have been studied by IARC for cancer hazards and found to
              be Group 3 compounds (not classifiable). No inhalation exposure was expected from these
              compounds, both presented a low aquatic hazard, and neither is explicitly regulated under
              the federal acts discussed in this report.

               Organic acids or salts
               These compounds performed a variety of functions as additives in solvent- and water-based
               inks.   Citric acid, the  only  compound for  which toxicological  data  were available,
               presented low concern for human health hazard and occupational risk via dermal exposure.
               The other two compounds, dioctyl sulfosuccinate  sodium salt and methylenedisalicylic
               acid, were analyzed by the SAT and found to present low-moderate hazard and possible
               risk concern via dermal exposure. All three presented a moderate aquatic hazard.  None
               of the compounds were expected to result in inhalation exposure, and none are explicitly
               regulated under the federal acts discussed in the CTSA.

               Organophosphorous compounds
               The three compounds included in this category were used in solvent-based and UV-cured
               inks as either plasticizers or initiators and have been  subjected to toxicological testing.
               One compound, bis(2,6-dimethoxybenzoyl)(2,4,4-trimethylpentyl) phosphine oxide,  had
               a moderate dermal hazard and clear occupational  dermal risk concern. The other two,
               diphenyl (2,4,6-trimethylbenzoyl) phosphine oxide and 2-ethylhexyl diphenyl phosphate,
               presented low and low-moderate dermal hazard concern, respectively, and possible
               occupational risk by dermal exposure. 2-Ethylhexyl diphenyl phosphate presented a high
               aquatic hazard and the  other two presented a medium aquatic hazard.  None of the
               compounds were expected to result in inhalation exposure. One compound, 2-ethylhexyl
               diphenyl phosphate, is regulated under TSCA.

               Organotitanium compounds
               These three compounds were used in solvent-based inks as additives (adhesion promoters).
               Each was studied by the SAT and found to have medium human health hazard and clear
                occupational  risk levels for  dermal  exposure.    Isopropoxyethoxytitanium   bis
                (acetylacetonate) and titanium diisopropoxide bis (2,4-pentanedionate) presented a medium
                aquatic hazard concern. Isopropoxyethoxytitanium bis (acetylacetonate) also presented a
                low-moderate cancer hazard concern. Inhalation exposure was not expected from any of
  PUBLIC COMMENT DRAFT
                                              8-51
September 2000

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  CHAPTER 8
                                                       CHOOSING AMONG INK TECHNOLOGIES
                the compounds.   None of the compounds are  explicitly regulated under the federal
                regulations discussed in this document.

                Pigments —inorganic
                This category was comprised of two chemicals and was seen in all three ink systems. C.I.
                Pigment White 6 had a low dermal hazard rating but a possible dermal risk rating based
                on toxicological data. C.I. Pigment White 7 was analyzed by the SAT and found to have
                a low-moderate hazard and possible risk ranking for dermal exposure.  Both compounds
                had a low aquatic hazard  rating, but C.I. Pigment White 6 has displayed evidence of
                carcinogenicity in animals.  Inhalation exposure was not expected from either of the
                compounds.  C.I. Pigment White 6 has an OSHA PEL of 15 mg/m3 (total dust).

                Pigments —organic
                This category was comprised of six compounds and were seen in all three ink systems.
                Toxicological data were available for only one compound, C.I. Pigment Red 23, which
                was found to have clear dermal concern.  The other compounds in this category were
                analyzed by the SAT and found to have low or low-moderate human health hazard and low
                or possible occupational risk levels.  C.I. Pigment Blue 61 presented a medium aquatic
                hazard; the others had a low aquatic hazard concern. C.I. Pigment Yellow 14 was found
                to present a low-moderate cancer hazard concern. Inhalation exposure was not expected
                for any of these compounds, and none of the compounds are explicitly regulated under the
                federal regulations discussed in this document.

                Pigments — organometallic
                Nine organometallic pigments were used in all three  ink systems. One compound, D&C
               Red No.  7, presented medium dermal systemic hazard and clear dermal risk based on
               toxicological data.  One other compound subjected to toxicological testing, C.I. Pigment
               Green 7, presented a possible dermal risk level.  Most of the other inks, as determined by
               the  SAT, presented low-moderate dermal hazard and possible dermal occupational risk
               concern.   Most of the compounds had a medium or  high aquatic hazard level, and all of
               the  SAT-analyzed compounds  presented  a low-moderate cancer  hazard.  Inhalation
               exposure  was not expected for any of these compounds, and none of the compounds are
               explicitly regulated under the federal regulations discussed in this document.

               Polyol derivatives
               These  compounds were used in solvent-based and UV-cured inks as resins.  For
               nitrocellulose, the SAT assigned a low-moderate human health hazard and possible
               occupational risk level by dermal  exposure and  a  low  aquatic hazard level.   Polyol
               derivative A had low human health  hazard and  occupational  risk  ratings via dermal
               exposure and a low aquatic hazard rating.  Inhalation exposure was not expected for either
               compound,  and neither of the compounds is  explicitly regulated under the federal
               regulations discussed in this document.

               Propylene glycol ethers
               These compounds  were used as solvents in solvent-  and water-based inks, and have all
               been subjected to toxicological testing.   Propylene  glycol propyl ether,  based on
               toxicological data, presented a moderate systemic human health hazard concern via both
               dermal  and  inhalation  exposure routes,  and  had possible dermal  and  inhalation
               occupational risk concern.  The other two compounds, dipropylene glycol methyl ether
               and propylene glycol methyl ether, presented a low hazard concern and a low occupational
PUBLIC COMMENT DRAFT
                                            8-52
                                                                              September 2000

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CHAPTER 8
                                                     CHOOSING AMONG INK TECHNOLOGIES
              risk for both exposure pathways at the concentrations observed in the inks used in this
              CTSA. All three compounds had a low aquatic hazard, and none were known to present
              a cancer hazard.

              Two compounds, dipfopylene glycol methyl ether and propylene glycol methyl ether, are
              regulated under TSCA. In addition, dipropylene glycol methyl ether has an OSHA PEL
              of 100 ppm.

              Resins
              Resins were found in solvent- and water-based inks. One compound, polymerized rosin,
              presented a low-moderate human health hazard and a possible risk concern as determined
              by the SAT. All other compounds in this category presented low human health hazard and
              low occupational risk for dermal exposure. One chemical - resin acids, hydrogenated,
              methyl esters - had a high aquatic hazard rating, and acrylic resin had a medium aquatic
              hazard rating.  Acrylic resin  also may pose a cancer hazard based  on evidence  of
              carcinogenicity in animals.  Inhalation exposure  was not expected for any of these
              compounds,  and none of the compounds are explicitly regulated under the  federal
              regulations discussed in this document.

               Siloxanes
               These compounds are used in all three systems as additives  (defoamers and  wetting
               agents).  Silicone oil, as determined through toxicological data, was anticipated to have
               moderate developmental hazard concern via dermal exposure, and possible dermal risk.
               The  other  two  compounds,  l,l,l-trimethyl-N-(trimethylsilyl)-silanamine  hydrolysis
               products with silica and dimethyl 3-hydroxypropyl methyl siloxanes and silicones, ethers
               with polyethylene glycol acetate, were analyzed by the SAT and determined to have a low-
               moderate human health hazard and a possible dermal risk concern. All of the compounds
               had a low aquatic hazard rating, and none were known to present a cancer hazard. No
               inhalation exposure  is anticipated for any of these compounds. Silicone oil is regulated
               under TSCA.
  PUBLIC COMMENT DRAFT
                                              8-53
                                                                                 September 2000

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CHAPTER 8
                                                      CHOOSING AMONG INK TECHNOLOGIES
       Suggestions for Evaluating and Improving Flexographic Inks

               As this CTSA shows, several factors are involved in the selection of a flexographic ink.
               Because flexographic printing facilities are different, the criteria for identifying the best
               ink for each facility inevitably will vary. Therefore, the ultimate decision will have to be
               made based on considerations as they apply to the specific facility.

               Likewise, ink formulators will have different considerations. In the process of improving
               the performance of inks, formulators will encounter the opportunity to substitute ink
               components that pose health concerns with those that are safer for press workers and the
               environment.

               The following sections describe some of the steps that can help printers in identifying, and
               formulators in creating, safer flexographic inks.  They range from steps that relate directly
               to information and ideas contained in the CTSA to those that will require processes outside
               of those considered in this analysis.

               Printers
               The  selection of a specific ink is a complex process that is highly dependent on facility-
               specific factors. Some general considerations are presented below.

                   •   Know your inks:  Evaluate your current ink system by considering all aspects of
                       its use, including performance, worker and environmental  risk, and costs.  You
                       can use this CTSA to determine whether  chemicals present in your inks may
                       present hazards and risks to your workers  and the environment. Consider that
                       choices of an ink system,  and within that, the  specific product lines and
                       formulations,  have  many  implications, some of  which  you may not have
                       considered in  the past.  Another important  source that can help  provide this
                       information is your ink supplier,  who may  be able to provide safety information
                       specific to your inks.

                    •   Consider alternatives: Use this CTSA to identify possibly safer ink alternatives
                       and to  help you determine whether you are using the best, safest, and most cost
                       effective ink system for  your facility's situation.  You may also wish to discuss
                       your options with ink suppliers, trade associations, technical assistance providers,
                       other printers, and your customers.

                    •  Evaluate your current practices: Even if you are using the safest ink possible, you
                       may be increasing the risk to workers by using it inefficiently.  As seen with the
                       solvent- and water-based inks in this CTSA, solvent and additives added at press
                       side increased the number of chemicals of clear worker risk. By minimizing or
                       eliminating the need for these materials — using enclosed  doctor blades and ink
                       fountains,  minimizing ink  film thickness, and closely  monitoring ink pH and
                       viscosity — the risk to workers  can be reduced.  For presses with an oxidizer
                        system, it is important to  clean the catalyst when necessary and to  keep  the
                        equipment operating at the optimum temperature so that it destroys as much VOC
                        material as possible.

                    •   Protect workers:  Experienced and responsible employees are essential to a
                        successful printing operation. Maintain their health and motivation by maximizing
  PUBLIC COMMENT DRAFT
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September 2000

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  CHAPTER 8
                                                         CHOOSING AMONG INK TECHNOLOGIES
                        air quality and reducing the presence of hazardous materials. These steps may
                        also yield savings with respect to regulatory and storage costs.  You can also
                        protect workers by ensuring that people who handle ink use gloves. Butyl and
                        nitrile  gloves are  considered best  for  inks, and will  minimize exposure  to
                        chemicals that may pose a health risk.

                    •   Look at all aspects of your printing operation: Though this CTSA focuses on ink,
                        several other steps in the flexographic printing process are sources of waste and
                        candidates for process improvement.  Read Chapter 7: Additional Improvement
                        Opportunities for pollution prevention  ideas  that range  from  measures for
                        particular process steps to facility-wide concepts. Systematic approaches, such as
                        an Environmental Management System (EMS) or full-cost accounting, can help
                        flexographers identify areas for improvement in their management of resources.

                Ink Formulators and Suppliers
                Ink companies have  several important  resources  at  their  disposal: knowledgeable
                researchers, financial resources, and a communication network of sales representatives.
                Ink formulators have the ability to evaluate the feasibility of the substitution of different
                and safer chemicals, and can  thoroughly test  new  formulations for performance
                characteristics.  Supplier representatives have the ability to articulate the benefits of safer,
                better performing or less costly inks to printers.

                   •   Support environmental and health risk research:  Research is needed on several
                       categories of chemicals:
                       0  those that are not regulated and pose risks
                       0  new chemicals (usually not regulated and not tested)
                       0  chemicals that have not undergone toxicological testing  and have clear or
                          possible risk concerns
                       0  high production volume chemicals*
                      The point of such research is to ensure that the flexographic industry has access
                      to  as  much information as possible about  the  chemicals they work with.
                      Information is the most important key to improving inks.

                      Make  improved  ink  safety a  top goal  of research and development:  The
                      flexographic printing  industry constantly demands new  inks  that can meet
                      increasing  performance needs.   In addition to performance research,  ink
                      formulators can meet the needs of printers by looking for substitute ingredients
                      that are less harmful to workers and the environment.

                      Communicate the safety aspects of inks with printers: When sales representatives
                      discuss different  ink  options  with printers,  inform  the printers  of  any
                      improvements in the environmental and worker risks associated with each product
                      line. Because inks with minimized environmental and worker risks can result in
                      cost savings as  well as improved working conditions and less liability, printers
              * High production volume (HPV) chemicals are manufactured in or imported into the United States in
              amounts greater than one million pounds per year. EPA has initiated a HPV Challenge Program to gather
              test data for all these organic chemicals (about 2,800). The CTSA includes 40 chemicals that appear on the
              HPV Challenge Program Chemical List.

>UBLIC COMMENT DRAFT
                                              8-64
                                                                                 September 2000

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CHAPTER 8
       CHOOSING AMONG INK TECHNOLOGIES
                     may be interested in this information.  Research has indicated that for printers,
                     environmental and health risk issues are an important criteria when selecting an
                     ink — second only to performance.9
 PUBLIC COMMENT DRAFT
8-65
September 2000

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  CHAPTER 8
                                                     CHOOSING AMONG INK TECHNOLOGIES
 REFERENCES
 2.

 3.
 5.
 6.

 7.
8.

9.
 Lodewyck, Paul. Progressive Ink Company. 2000. Personal Communication with Trey Kellett,
 Abt Associates Inc. March 26, 2000.

 Mishan, EJ. Cost-Benefit Analysis. New York: Praeger, 1976.

 Unsworth, Robert E. and James E. Neumann.  1993.  Industrial Economics, Inc.
 Memorandum to Jim DeMocker, Office of Policy Analysis and Review.  Review of Existing
 Value of Morbidity Avoidance Estimates: Draft Valuation Document. September 30, 1993.

 Tolley, G.S., et al. January 1986.  Valuation of Reductions in Human Health Symptoms and
 Risks. University of Chicago.  Final Report for the U.S. EPA. As cited in Unsworth, Robert
 E. and James E.  Neumann, Industrial Economics, Incorporated. Memorandum to Jim
 DeMocker, Office of Policy Analysis and Review. Review of Existing Value of Morbidity
 Avoidance Estimates: Draft Valuation Document. September 30, 1993.

 Dickie, M., et al. September 1987.  Improving Accuracy and Reducing Costs of Environmental
 Benefit Assessments.  U.S. EPA, Washington, DC. Tolley, G.S., et al.  Valuation of
 Reductions in Human Health Symptoms and Risks.  January 1986. University of Chicago.
 Final Report for the U.S. EPA.  As cited in Unsworth, Robert E. and James E. Neumann,
 Industrial Economics, Incorporated.  Memorandum to Jim DeMocker, Office of Policy
 Analysis.and Review. Review of Existing Value of Morbidity Avoidance Estimates: Draft
 Valuation Document.  September 30, 1993.

 Tolley, et.al.

 Rowe, R.D. and L.G. Chestnut. Oxidants and Asthmatics in Los Angeles: A Benefit Analysis.
 Energy and Resource  Consultants, Inc. report to U.S. EPA, Office of Policy Analysis, EPA-
 230-07-85-010. Washington, DC March 1985. Addendum March 1986. As cited in
 Unsworth, Robert E. and James E. Neumann, Industrial Economics, Incorporated,
 Memorandum to Jim DeMocker, Office of Policy Analysis and Review, Review of Existing
 Value of Morbidity Avoidance Estimates: Draft Valuation Document. September 30,1993.

 Chris Patterson, Flint  Ink. Written comments to Karen Doerschug, U.S. EPA, July 6, 2000.

ICF Consulting. 2000. Internal document for the EPA Design for the Environment Project.
January 18, 2000.
PUBLIC COMMENT DRAFT
                                    8-66                             September 2000
                                        &U.S. GOVERNMENT PRINTING OFFICE: 2000-523-356/95173

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