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                    For  More Information
                                    t Vnfia Flexography Partnership or the DfE Program, or
To learn more about Design for the Envuronment (Dffi) Flexograp y
to download any of DfE's documents, visit
      www.epa.gov/dfe

 or contact us at

       202-564-8780
       dfe@epa.gov
        P O. Box 42419
        Cincinnati, OH 45242-2419
        Phone:   800-490-9198
                513-489-8190
        Fax:     513-489-8695
                    -™a1@one-net      ,  .  ,.m
                                     Disclaimer
                                                                       -
    endorsement by EPA.
                                            n

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  Flexographic Ink Options:
A Cleaner Technologies Substitutes Assessment
                   VOLUME 1
                     U.S. EPA
            Design for the Environment Program
         Economics, Exposure, and Technology Division
         Office of PoUution Prevention and Toxics (7404)
            U.S. Environmental Protection Agency

                   February 2002
                  EPA 744-R-02-001A
      Developed in Partnership with the Following Associations:
                   naoim
    CRUFORNIR
    FILM 6XTRUD6RS
    & CONVeRTSRS
    RSSOCIflTlON
~"

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                      For More  Information
To learn more about Design for the Environment (DfE) Flexography Partnership or the DfE Program, or
to download any of DfE's documents, visit

       www.epa.gov/dfe                                                         .

or contact us at                                                          ,

       202-564-8780
       dfe@epa.gov

To order additional printed copies of this document or other DfE publications, contact

       U.S. Environmental Protection Agency
       National Service Center for Environmental Publications
       P.O. Box 42419
       Cincinnati, OH 45242-2419
       Phone:   800-490-9198
               513-489-8190
       Fax:     513-489-8695
       e-mail:   nceipmal@one.net
       Internet: www.epa.gov/ncepihom/ordering.htm
                                      Disclaimer

This document 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.
                                            11

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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 provided valuable guidance and feedback
         throughout the project. The Technical Committee included volunteer printers and suppliers,
         who contributed much time, expertise, materials, and the use of their facilities; their
         cooperation was essential to the project. (The next two pages list the participants.)

    •    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, arid
         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 Altaian, Dennis Chang, Cheryl Keenan, Harry (Trey)
         Kellett HI,  and Srabani Roy of Abt Associates, Inc. under EPA Contract 68-W6-0021, Work
         Assignments 3-07,4-05, and 5-08, and EPA Contract 68-W-01-039, Work Assignment 1-2.
         EPA work  assignment managers included Stephanie Bergman, Karen Chu, and James Rea.
                                              111

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               Members of the Flexography Partnership
                               Steering Committee
Robert Bateman
(representing California Film Extruders &
Converters Association)
Roplast Industries
3155 South 5th Avenue
Oraville, CA 95965
phone: 530-532-95000
fax: 530-532-9576
rbateman@roplast.com

Karen Chu
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Mail Code 7406
Washington, DC 20460
phone: 202-564-8773
fax: 202-564-8893
chu.karen@epa. gov

Norma Fox
California Film Extruders & Converters
Association
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
dmonteleone@flexography. org

Gary Cohen
RadTech International, N.A.
400 North Cherry
Falls Church, VA 22046
phone: 703-534-9313
fax: 703-533-1910
uveb@radtech.org

Ram Singhal
Flexible Packaging Association
971 Corporate Boulevard, Suite 403
Linthicum, MD 21090
phone: 410-694-0800
fax: 410-694-0900
rsinghal@flexpak.com
                                        IV

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                               Technical Committee
AJ. Daw Printing Ink Co,.*
Abt Associates Inc.
Akzo Nobel Inks Corp.*
American Inks and Coatings
Anguil Environmental Systems, Inc.
Automated Packaging*
Bema Film Systems, Inc.
Bryce Corporation*
Cello-Foil Products, Inc.*
Coast Converters
Curwood, Inc.
Deluxe Packages*
Dispersion Specialties, Inc.
DuPont Cyrel  ,
Duralam, Inc.
E.I. du Pont de Nemours & Co.*
Emerald Packaging*
Enercon Industries Corp*
Fine Line Graphics*
Flex Pack*
Flint Ink*
Fusion UV Systems, Inc.
Georgia-Pacific
Hallmark Cards
Harper Corporation of America*
 Highland Supply Corporation
 Huron River Watershed Council
 International Paper
INX International Ink Co.*
Kidder, Inc.
Lawson Mardon Packaging USA*
MacDermid Graphic Arts*
Maine Poly, Inc.*
MEGTEC Systems
Mobil Chemical Corp.*
Orange Plastics
Pechiney Plastic Packaging
P-F Technical Services, Inc.
Precision Printing & Packaging, Inc.
Printpack, Inc.
Progressive Inks*
Research Triangle Institute
Roplast Industries*
SC Johnson Polymer
Sericol
Strout Plastics
Sun Chemical Corporation*
U.S.  EPA
UCB Chemicals
University of Tennessee
Waste Management and Research Center
Western Michigan University
Windmueller & Hoelscher Corp.*
 * These companies voluntarily supplied materials for the CTSA or participated in the performance
 demonstrations.

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VI

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                              Contents
Abbreviations

Glossary ....
Xlll
                                                                         xv
                                VOLUME 1
EXECUTIVE SUMMARY
BACKGROUND OF THE DFE FLEXOGRAPHY PROJECT		.... ES-2
     The Flexographic Printing Industry	 ES-2
     EPA's Design for the Environment Program	ES-3
     Background and General Methodology of the Flexographic Inks CTSA  	 ES-3

ENVIRONMENTAL IMPACTS AND HEALTH CONCERNS	 ES-4
     The CTSA Risk Assessment Methodology	 ES-8
     How the CTSA Defined Risk Levels	 ES-10
     Human Health Findings		ES-10
     Environmental Findings	 ES-14

PERFORMANCE	ES-16
     Performance Findings	 ES^IS

COSTS  	ES-20
     Cost Findings	ES-20
                                                                  /
RESOURCE USE AND ENERGY CONSERVATION	 ES-21
     Resources Used and Emissions Generated	 ES-22

CHOOSING AMONG FLEXOGRAPHIC INKS	 ES-23
     Highlights of CTSA Findings	 ES-23
     Choosing Cleaner, Safer Ink Chemicals	 ES-25

REFERENCES	ES-29
                                    VII

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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


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

2.2 MARKET PROFILE OF THE FLEXOGRAPHIC PRINTING INDUSTRY	2-6
     Trends in the Flexographic Printing Industry	2-9
     Inks Used in Flexographic Printing	2-10

2.3 FEDERAL REGULATIONS	2-12
     Clean Air Act	2-13
     Resource Conservation and Recovery Act	2-15
     Tpxic Substances Control Act			2-18
     Clean Water Act	2-22
     Safe Drinking Water Act	2-25
     Comprehensive Environmental Response, Compensation, and Liability Act	2-25
     Emergency Planning and Community Right-to-Know Act  	2-26
     Occupational Safety and Health Act	 2-27

2.4 PROCESS SAFETY	,.. 2-35
     Reactivity, Flammability, Ignitability, and Corrosivity of Flexographic Ink Chemicals .. 2-35
    • Process Safety Concerns	 2-38

REFERENCES	2-41
Chapter 3; RISK	.      	

3.1 INTRODUCTION TO RISK			3-4
     Background	3-4
     Quantitative Expressions of Hazard and Risk	3-5

                                     viii

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      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	3~2°

3.3 CATEGORIZATION OF FLEXOGRAPHIC INK CHEMICALS FOR THIS CTSA  . 3-30
      Chemical Categories by Product Line	3"33

3.4 ENVIRONMENTAL AIR RELEASE ASSESSMENT	3-37
      Environmental Air Release Methodology 	3'37
      Environmental Air Release Results	3"3°

3.5 OCCUPATIONAL EXPOSURE ASSESSMENT	3-41
      Occupational Exposure Methodology	•	3-41
      Occupational Exposure Results 	• •		3~44

3.6 GENERAL POPULATION EXPOSURE ASSESSMENT	 3-47
      General Population Exposure Methodology	3-47
      General Population Exposure Results	•	• • • 3"50

3.7 RISK CHARACTERIZATION	•	•	^-52
      Occupational Risk Results	• • 3"~3
      General Population Risk Results  	•	3"62

REFERENCES	•	; • •	•	'' 3"66


Chapter 4; PERFORMANCE         	:		

4.1 METHODOLOGY	
      Methodology for On-site Performance Demonstrations
      Tests Performed on Samples from Performance Demonstrations and Laboratory Runs ... 4-5
      Inks Used for the Study  	• • •	4~11
      Substrates Used for the Tests	•	4"11
      Image and Plates Used for the Tests	•	•		4"12
      Types of Printing Performed	4~14
      Limitations of the Performance Demonstrations	4~15
      Methodology for Laboratory Runs.			4~16

 4.2 RESULTS OF PERFORMANCE DEMONSTRATION AND LABORATORY RUN TESTS
      — SOLVENT-BASED AND WATER-BASED INKS	4-19
      Adhesive Lamination — Solvent-based and Water-based Inks	4-19
      Block Resistance — Solvent-based and Water-based Inks  	4-20
      ODE L*a*b* — Solvent-based and Water-based Inks  	,	; 4'20
      Coating Weight — Solvent-based and Water-based Inks  	4-22
      Density — Solvent-based and Water-based Inks		• • •	4"25
      Dimensional Stability — Solvent-based and Water-based Inks	4-27
      Gloss — Solvent-based and Water-based Inks	•	4'28
                                        IX

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       Heat Resistance/Heat Seal — Solvent-based and Water-based Inks ...:	4-29
       Ice Water Crinkle Adhesion — Solvent-based and Water-based Inks	4-30
       Image Analysis — Solvent-based and Water-based Inks	 4-31
       Jar Odor — Solvent-based and Water-based Inks	    4-32
       Mottle/Lay — Solvent-based and Water-based Inks .			4-33
       Opacity — Solvent-based and Water-based Inks	4-36
       Rub Resistance — Solvent-based and Water-based Inks		4-36
       Tape Adhesiveness — Solvent-based and Water-based Inks	4-37
       Trap — Solvent-based and Water-based Inks	 4-38
       Highlights of Performance Results for Solvent-Based and Water-Based Inks .'....	4-40

 4.3 RESULTS OF PERFORMANCE DEMONSTRATION AND LABORATORY RUN TESTS
       — UV-CURED INKS	4.40
       Block Resistance — UV-cured Inks	                         " 4.41
       CDBL*a*b* — UV-cured Inks	..................... 4-42
       Coating Weight —UV-cured Inks	'.'.'.'.'.'.'.'.'.'.'. 4-43
       Coefficient of Friction — UV-cured Inks			          4.44
       Density — UV-cured Inks  	'.'.'.'.'.'.'.''  4.45
       Dimensional Stability — UV-cured Inks	     " 4.46
       Gloss — UV-cured Inks		      '.'.'.'.'.[     4.46
       Ice Water Crinkle Adhesion — UV-curedlnks	....].... 4.47
       Image Analysis — UV-cured Inks	'....,	'.'.'.'.'.'.'.'.'. 4-47
       Jar Odor — UV-cured Inks	'.'.'.'.'.'.'.' 4-49
       Mottle/Lay — UV-cured Inks		.                    4_50
       Opacity — UV-cured Inks	..	'.'.'.'.'.'.'.'.'. .4-51
       Rub Resistance — UV-cured Inks	 	4_52
       Tape Adhesiveness — UV-cured Inks	          4-52
       Trap — UV-cured Inks	'.'.'.'.'.'.'.	4-52
       Uncured Residue — UV-cured Inks	4.53
       Summary of Performance Test Results for UV-Cured Inks .		  4-53
       Technological Development in UV~cured Inks 	    4.54

4.4 SITE PROFILES 	.	                 4.56
       Site 1: Water-based Ink#W2 on OPP	'.'.'.'.'.'..".."'.'..'...'......' 4-57
       Site 2: Water-based Ink#W3 on LDPE and PE/EVA ;	••••,--. ^^
       Site 3: Water-based Ink#W3 on LDPE and PE/EVA	'.'.'.'.'.'.'.'.'.	4-61
       Site 4: Water-based Ink#Wl on OPP	'.'.'.'.'.'.'.'.'. 4-63
       Site 5: Solvent-based Ink #S2 on LDPE and PE/EVA 		4.64
       Site 6: UV Ink#U2 on LDPE, PE/EVA, and OPP .............................. 4-66
       Site?:  Solvent-based Ink #S2 on  LDPE and PE/EVA 	'.'.'.'.'.	4-68
       Site 8:  UV Ink#U3 on LDPE, PE/EVA, and OPP :		  	4.70
       Site 9A: Water-based Ink#W4 on OPP	 4-71
      Site9B: Solvent-based Ink #S 1 on OPP	.-	.....'..        4.73
      Site 10:  Solvent-based Ink#S2 on OPP	'.'.'.'.'.'.'.'.'.     	4.74
      Site II:  UV Ink #U1 on LDPE (no slip)	 4-76

REFERENCES	_ _            4.78

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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	• • • •	S'17
      Summary of Cost Analysis Results	5-17
      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



Chapter 6; RESOURCE AND ENERGY CONSERVATION	___

6.1  INK AND PRESS-SIDE SOLVENT AND ADDITIVE CONSUMPTION		6-3
      Methodology	.'	•	 6-3
      Limitations and Uncertainties	• • • •	• • • •	6-5
      Ink and Press-side Solvent 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 	• • • • •		6~24
      Environmental Impacts of Energy Production		6-26
      Limitations and Uncertainties . . .	• • •	^'26

6.4  CLEAN-UP AND WASTE DISPOSAL PROCEDURES	 6-29
      Press Clean-Up and Waste Reduction in the CTSA Performance Demonstrations	6-30

REFERENCES	• • •	6"32
                                        XI

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Chapter 7; ADDITIONAL IMPROVEMENT OPPORTUNITIES 	

7.1 POLLUTION PREVENTION OPPORTUNITIES	7-3

7.2 RECYCLING AND RESOURCE RECOVERY	 7-6
      Silver Recovery	7-6
      Solvent Recovery	7-7
      Solid Waste Recycling	7-7

7.3 CONTROL OPTIONS	7-8
      Sources of Rexographic Ink Pollutants Amenable to Treatment or Control Options	7-8
      Control Options and Capture Devices for Air Releases		7-8
      Control Options for Liquid Releases	7-10

REFERENCES	7-12
Chapter 8; CHOOSING AMONG INK TECHNOLOGIES	

8.1 SUMMARY BY INK SYSTEM AND PRODUCT LINE	8-2
      Introduction	8-2
      Solvent-based Inks	8-13
      Water-based Inks 	8-16
      UV-curedlnks	 8-19

8.2 QUALITATIVE SOCIAL BENEFIT-COST ASSESSMENT	8-23
      Introduction to Social Benefit-Cost Assessment	8-23
      Benefit-Cost Methodology and Data Availability	8-25
      Potential Private and Public Costs	;	8-25
      Potential Private and Public Benefits	8-30
      Summary of Social Benefit-Cost Assessment  	8-33

8.3 DECISION INFORMATION SUMMARY	 8-35
      Introduction 	;	 8-35
      Ink System Comparison	8-36
      Highlights of Chemical Category Information	8-39
      Hazard, Risk and Regulation of Individual CTSA Chemicals	8-45
      Suggestions for Evaluating and Improving Flexographic Inks	8-62

REFERENCES	8-64
                                       xn

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                          VOLUME 2: APPENDICES
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 3-L: 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 Collection 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: Clean-Up and Waste-Disposal Procedures for Each Site
Appendix 6-C: Pollution Generation Reports
                                          Xlll

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XIV

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                           Abbreviations
ADC
ADD
BACT
BCM
BOD
CAA
CAS
CBI
CERCLA
CESQG
CFR
CTG
CTSA
'CWA
DfE
EPA
EPCRA
FPA
FTA
FWPCA
HAP
HQ
HSWA
IARC
LDPE
LEPC
LOAEL
LQG
MACT
MEK
MIBK
MOE
MSDS
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
Code of Federal Regulations
Control Technology Guidelines
Cleaner Technology Substitutes Assessment
Clean Water Act
Design for the Environment
Environmental Protection Agency
Emergency Planning and Community Right-to-Kriow Act
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
                                        xv

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NAICS
NAPIM
NCP
NESHAP
NOAEL
NPDES
OPP
OPPT
OSHA
PE/EVA
POTW
PTE
RACT
RCRA
RfC
RED
SARA
SDWA
SERC
SIC
SQG
TRI
TSCA
TSD
TSS
UST
VOC
North American-Industry Classification System
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
Toxic Substances Control Ace
Treatment, Storage, and Disposal (facility)
Total Suspended Solids
Underground Storage Tank
Volatile Organic Compound
                                         xvi

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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 in 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
                                           XVII

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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
 uridesired 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 photoinitiators 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
                                           XVlll

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Cure


Curing agent

Dermal exposure
Developmental toxicity


Die

Diluent

Direct medical costs


Discounting


Dispersant
Dispersion

Doctor blade

Dose-response assessment


 Dot gain
 Dye

 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
UV inks
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).
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
 an 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.
                                              xix

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 Exposed worker population   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
Exposure assessment
 Epoxy resin

 Extender
 External benefits
 External costs
Externality
Extrusion

Flammability
Flexible packaging

Flexograpblc printing plate
Formulation

Fountain
                             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 often millimeters or
                             less whose shape can be changed readily
                             a plate with a raised image that prints on the desired substrate
                             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
                                            xx

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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
 Ignitability
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 ultraviolet curing in which 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 photochemicalsmog 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.
capability of lighting on fire
                                            xxi

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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
Margin of exposure (MOE)
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.
the process of burning to ashes with the intent of reducing harmful
substances to more benign ones
costs associated with a disease or medical condition resulting from
exposure to a chemical, product or technology, such as 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 work" such as text, display  type, and some
types of 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 tons per year 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
the ratio of the no-observed-adverse-effect-level (NOAEL) to the
estimated exposure dose
                                           xxii

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Material Safety Data Sheet
(MSDS)
Maximum Achievable
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
Control Technology (MACT) maximum reduction of hazardous emissions, taking cost and feasibility
                             into account
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
 Oriented polypropylene
 (OPP)
 Overprinting
 Oxidation
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 to contaminated substances through eating or drinking
ability of,a chemcial to cause injury when  ingested
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
                                           xxin

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Oxidizer

Ozone


Paste ink
Permanent total enclosure

Photoinitiator

Photopolymer

Pigment
Pinholing

Plasticizer

Pollution prevention


Polyethylene

Polymer
Polymerization

Polypropylene

Population risk

Present value
Press-side solvent or additive

Primer
Priority pollutant
 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."
 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.
 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 under the
 Clean Water Act (CWA)
                                           xxiv

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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
 Reference concentration

 Reference dose

 Repeat length

 Reportable quantity


 Reproductive toxicity

 Resin


 Reverse printing
the dkect 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.
the dkect negative effects incurred by industry or consumers from thek
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, which 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

material used in ultaviolet curing that reduces viscosity of ink
property of being able to decompose or react with other chemicals
technology required under the Clean Ak Act to control the emissions of
volatile organic compounds
the practice of reducing envkonmental wastes by recovering and
reprocessing waste materials, thereby reducing the use of vkgin
materials
 material used to alter the body, viscosity, or color strength of ink
 lowest continuous human inhalation exposure that does not have an
 appreciable risk of deleterious, non-cancerous effects during a lifetime
 lowest daily human exposure that does not have an appreciable risk of
 deleterious, non-cancerous effects during a lifetime
 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 Envkonmental 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
                                             xxv

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 Risk characterization


 Scuffing
 Silver recovery
 Smog-related emissions



 Social benefit
 Social cost
 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)
 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).
 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
                                           xxvi

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Toxicity
Trapping
Tropospheric Ozone
Turbidity

Ultraviolet light
UV-cured ink
Vehicle

Viscosity
Volatile Organic Compound
(VOC)

Volatilization

Waste generator


Water-based ink

Wetting

Wide-web press

Willingness-to-pay
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
the process of 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
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.
                                            xxvn

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            XXVlll

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                                                                      EXECUTIVE SUMMARY
                              Executive Summary

              Flexographic  Ink  Options:  A  Cleaner  Technologies  Substitutes  Assessment  (the
              Flexographic Inks CTSA) presents the results of a technical study of the comparative
              environmental impacts, health risks, performance, and cost of the three primary flexographic
              printing ink systems: solvent-based inks, water-based inks, and ultra-violet (UV)-cured inks.
              The study was  initiated through the Flexography  Partnership of the Design for the
              Environment (DfE) Program at the U.S. Environmental Protection Agency (EPA).* The
              broad goal of the CTSA was to develop as complete and systematic a picture as possible of
              competing ink technologies, thereby helping industry incorporate environmental and health
              information into their ink decisions. It is hoped that the CTSA will serve as a resource to
                 •   identify and inform industry about comparative chemical risks in inks, including
                     unregulated ones that present opportunities for  proactive, voluntary  risk
                     management,
                 •   facilitate the use and formulation of cleaner inks, and
                 •   encourage adoption of workplace practices that minimize health and environmental
                     risks from exposure to chemicals of concern.

              The study examined ink systems that are used on wide-web film substrates, a combination
              that presented special technical and environmental challenges for printers. Notably, at the
              time the study was initiated, use of UV-cured inks on wide-web film substrates was
              still in a developmental stage and was just beginning to emerge commercially. One
              of the benefits of the CTSA approach is its ability to provide unbiased insights into
              the environmental and health impacts and competitiveness of emerging technologies.

              Interestingly, the CTSA found that each of the ink systems studied had different advantages,
              as well as health and environmental concerns. Considerable variation was noted even among
              different colors within a single ink product line. Thus, selecting the best formulations is just
              as important for a printer as selecting an ink system. The CTSA results can help printers
              and formulators familiarize themselves with the toxicities of chemicals they use on a daily
              basis, be more aware of their risk concerns, and identify cleaner ink systems, formulationSj
              and chemicals.

              The primary audiences for the Flexographic Inks CTSA are flexographic printers, ink
              manufacturers, environmental health and safety personnel, community groups, and other
              technically informed decision makers.
       * EPA's Design for the Environment Program is located within the Economics, Exposure and Technology
Division, in the Office of Pollution Prevention and Toxics.

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                                                                        EXECUTIVE SUMMARY
              The Flexography Partnership is a voluntary, cooperative effort among EPA, industry,
              academia, public interest groups, and other stakeholders. Project partners participated in all
              stages of  planning and implementing this  CTSA.  They helped define its scope and
              direction, provided technical information, reviewed data and text, and donated time,
              materials, and printing facilities for performance demonstrations. Critical information about
              ink formulations used in the analyses was provided by ink manufacturers.

              In addition to the Flexographic Inks CTSA, the Flexography Partnership has developed a
              summary report, a pollution prevention video, and a number of other materials for printers.
              These may be obtained from the DfE website (www.epa.gov/dfe) or by contacting EPA's
              National Service Center for Environmental Publications (telephone 800-490-9198 or 513-
              489-8190; fax513-489-8695; Internet address www.epa.gov/ncepihom/ordering.htm: e-mail
              ncephnal@one.net).

              This Executive Summary first provides a brief background of the flexographic industry, the
              DfE Program, and the Flexographic Inks CTSA. It then presents key results on the main
              research areas: environmental impacts and health concerns, performance, and costs. It ends
              with some steps that flexographic professionals could take to minimize impacts on the
              environment and worker health.

BACKGROUND OF THE DFE FLEXOGRAPHY PROJECT

       The Flexographic Printing Industry

              Flexography is a process used primarily for printing on paper, corrugated paperboard, and
              flexible plastic materials. Especially well suited to printing on flexible and non-uniform
              surfaces (such as plastic films and corrugated board), flexography is used to print a wide
              range of products we all use, such as snack food and frozen food bags, labels for medicines
              and personal care products, newspapers, drink bottles, and cereal containers (Figure ES. 1).

              Figure  ES.1  Primary Types of Packaging Manufactured in the United States, 2000
                                              (by % of sales dollars)
                               other (including glass
                                  and cans)
                                    32%
                                  labels and tags
                                     9%
  corrugated and
preprinted containers
     27%
 flexible film packaging
       19%
                                               folding cartons
                                                  13%
                                             ES-2

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                                                                EXECUTIVE SUMMARY
       Flexography is a highly visible, growing, national industry that is dominated by small
       businesses. Combined, these businesses have the potential to make a major environmental
       impact, especially on air quality, resource use (e.g., inks and substrates), and solid and
       hazardous waste.

           •   U.S. flexographic printing firms had annual sales of approximately $50 billion in
              1999.1
           •   The sector employs about 30,000 people.2
           •   More than 80% of all flexography firms have fewer than 50 employees.
           •   It has an annual growth rate of about 6%.3
           •   Roughly 60% of flexographic businesses are concentrated in ten states: California,
              Florida, Dlinois, Missouri, New Jersey, New York, North Carolina, Ohio, Texas,
              and Wisconsin.4
           •   Flexographic printing consumed more than 513 million pounds of ink in 2000.5
EPA's Design for the Environment Program
                               The Design for the Environment (DfE) Program is a voluntary
                               partnership program that works directly with industries, usually
                               through industry leaders and trade or technical associations, to
                               integrate health  and environmental considerations into their
                               business decisions. The DfE approach compares the human
                               health and environmental  risks,  performance, and  costs
                               associated with  existing and  alternative  technologies or
                               processes^ DfE  helps businesses design or redesign products,
                               processes, and management systems that are cleaner, more cost-
                               effective, and safer for workers and the public.
U.S. EPA1"
       DfE partnerships may take several approaches to designing for the environment: technology
       assessments, formulator approaches, best practices approaches, greening the supply chain,
       integrated environmental management systems, and  life-cycle assessments. DfE has
       established  partnerships in commercial printing (flexography, lithography, and screen
       printing), garment and textile care, computer monitors, printing wiring boards (used for
       computers  and other  electronics), industrial and  institutional  cleaning  formulations,
       automotive refinishing, adhesives used in foam furniture and sleep products, and automotive
       suppliers.
Background and General Methodology of the Flexographic Inks CTSA

       In the mid-1990s, DfE identified flexography as an important industry sector that
       could benefit from a DfE assessment:
           •   Historically, most flexographic inks had been solvent-based, had high levels of
               volatile organic compounds (VOCs), and contained many chemicals, some of which
               were quite toxic. Although the  printing  industry has addressed a number of
               environmental and health concerns of inks through reformulation of inks, add-on
               pollution control devices, and other improvements to operations and materials, these
               had not resolved all concerns about human health and ecological risks.
           •   Inks are a major use and cost category for printers.
                                      ES-3

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                                                                      EXECUTIVE SUMMARY
                  •  As small businesses, individual flexography firms might not have the resources or
                     expertise to research the environmental implications of competing technologies.
                  •  The industry had been growing rapidly for several years, which increases its
                     impacts.

              The Flexography Partnership decided to perform a cleaner technologies substitutes
              assessment or CTSA for flexographic inks. This methodology allowed the Partners
              to evaluate traditional and alternative technologies for the potential risks they pose
              to human health and the environment, as well as for performance and cost. The
              CTSA methodology is  described in  the DfE document, Cleaner Technologies
              Substitutes Assessment: A Methodology and Resources Guide**  Figure ES.2
              graphically displays the methodology used for this CTSA.

                              Figure ES.2 Flexographic Inks CTSA Methodology
                            Inputs
9 Ink Product Lines
(each with 5 colors)*
2 solvent-based
4 water-based
3 UV-cured

3 Film Substrates"
OPP
LDPE
PE/EVA
— |

->
Data Collection
Performance
Demonstrations
Laboratory Runs
Supplier and
Printer Data

w-

Analyses
Risk
Energy Use
Cost
Performance

Results



                                         * blue, white, cyan, magenta, green.
                                         ** OPP = oriented polypropylene. LDPE = low-density polyethylene.
                                         PE/EVA = polyethylene/ethyl vinyl acetate co-extruded film.
ENAHLRONMENTAL IMPACTS AND HEALTH CONCERNS

              This section describes the risk assessment methodology that was used to obtain and evaluate
              the health and environmental findings for flexographic inks. Findings related to workers
              and the general population are discussed first. Environmental findings follow, including (1)
              ambient air releases, (2) aquatic toxicity, and (3) resource use and energy conservation.

              Over  the past decade, ink manufacturers have made environmental improvements by
              developing inks with lower VOC content. The Flexography Partnership wanted to obtain
              an even deeper understanding of environmental and health implications of ink chemicals,
              to help the industry innovate and select cleaner inks, and to ensure that new formulations
              were not shifting risks from one medium to another (e.g., from ambient air quality to worker
              health).

              The study examined 45 ink formulations, which contained approximately 100 chemical
              substances (Table ES.l). Ink suppliers voluntarily provided the inks, along with complete
       ** See the beginning of this volume (page ii) for ordering information.


-------
                                                         EXECUTIVE SUMMARY
information about the chemical compositions of their formulations. To compare the
environmental and health implications of the three ink systems, the study examined the
toxicity, estimated releases and exposures, and risk concerns for the chemicals. To protect
manufacturers' confidentiality, the formulation information they provided was treated as
confidential business information.
            Table ES.1  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 polymer6
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)c
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
                              ES-5

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                     EXECUTIVE SUMMARY
Category
Ethylene glycol
ethers
Hydrocarbons —
high molecular
weight
Hydrocarbons —
low molecular
weight
Inorganics
Olefin polymers
Organic acids or
salts
Organophos-
phorus
compounds
Organotitanium
compounds
Pigments —
inorganic
Pigments —
organic
Pigments —
organometallic
Polyol derivatives
Propylene glycol
ethers
Chemicals in category
Alcohols, CH-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
C.I. Basic Violet 1 , molybdatephosphate
C.I. Basic Violet 1, molybdate-tungstatephosphate
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
Polyol derivative Ac
Dipropylene glycol methyl ether
Propylene glycol methyl ether , .
Propylene glycol propyl ether
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 v
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
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
ES-6

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                                                                         EXECUTIVE SUMMARY
 Category
Chemicals in category
CAS number
 Resins
Fatty acid, dimer-based polyamide0
Fatty acids, C18-unsatd., dimers, polymers with
   ethylenediamine, hexamethylenediamine, and propionic acid
Resin acids, hydrogenated, methyl esters
Resin, acrylic0
Resin, miscellaneous0
Rosin, fumarated, polymer with diethylene glycol
   and pentaerylhritol
Rosin, fumarated, polymer with pentaerythritol,
   2-propenoic acid, ethenylbenzene, and (1 -
   methylethylenyl)benzenec
Rosin, polymerized                   	       .
NA
67989-30-4

8050-15-5
NA
NA
68152-50-1

NA
                                                                                  65997-05-9
 Siloxanes
Silanamine, 1,1,1 -trimethyl-N-(trimethylsilyl)-,
    hydrolysis products with silica
Siliconeoil
Siloxanes and silicones, di-Me, 3-hydroxypropyl
    Me, ethers with polyethylene glycol acetate
68909-20-6

63148-62-9
70914-12-4
a No data or information available.
b 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 properly data are .estimated from this information.
       The CTSA Risk Assessment Methodology

               A risk assessment has several phases: hazard identification, dose-response assessment,
               exposure assessment, and risk characterization. The CTSA risk assessment (Figure ES.3)
               focused on two areas of interest regarding the chemicals:
                  •   possible health concerns to industry workers and the general population, and
                  •   environmental concerns, including ambient air releases and aquatic toxicity.

               For flexographic  workers, exposures were  analyzed for prep room workers and press
               workers, since both of these groups handle inks regularly in the course of their jobs. The
               assessment included exposure to VOCs and hazardous air pollutants (HAPs) through
               fugitive releases, which escape from the printing process into the ambient internal air and
               eventually exit the facility through windows  and doors. Workers therefore can be exposed
               to fugitive emissions in the facility.
                                              ES-7

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                                                          EXECUTIVE SUMMARY
        Figure ES.3 The Flexographic Inks CTSA Risk Assessment Process
  Workplace
  Practices
  Source
  Release
  Assessment
                                Exposure
                                Assessment
  Human
  Health
  Hazards
                                                                 Risk
                                                            Characterization
  Environmental
  Hazards
                                Hazard
                                Assessment
Exposure was "modeled" — that is, it was not based on actual measurements of releases.
A number of assumptions were made about a hypothetical "model facility" in developing
the risk assessment. Most of the assumptions reflect typical operating conditions, and some
facilitated identification of cleaner technologies or comparative analysis. Facilities with
different operating characteristics would have different findings. Some of the assumptions
include the following:
    •   30% of volatile compounds released to air would be uncaptured emissions, and 70%
       would be stack emissions.
   .•   Solvent-based ink systems would have a catalytic oxidizer with a 95% destruction
       efficiency.
    •   Press and prep-room workers would work a 7.5 hour shift, 250 days/year.
    •   Press and prep room workers would have routine two-hand contact (no gloves) with
       ink unless a substance was corrosive.
    •   Press speed would be 500 feet per minute.

In addition, the exposure estimates used for dermal contact were "bounding" estimates,
which provide an upper and lower limit of exposure. The inhalation exposure estimates are
considered "what-if' estimates because their probability of occurrence is not known.

The risk analysis  used published studies  of hazards and toxicity associated with  each
chemical, where available. When published studies were not available, EPA's Structure
Activity Team (SAT) determined 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.  Many
chemicals in flexographic inks have not been studied thoroughly for environmental effects
or health concerns. Chemicals in UV-cured inks, perhaps because they are newer, are much
less likely than solvent- and water-based chemicals to have undergone in-depth testing.
                               ES-8

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                                                                   EXECUTIVE SUMMARY
       Concerns posed by any ink system will vary depending upon many factors, such as the
       specific chemicals in the inks, how the inks are handled and used, the type of toxicity
       (systemic or developmental), and the exposure route (inhalation or dermal).

How the CTSA Defined Risk Levels

       Each chemical substance evaluated was designated as having a "clear," "potential," or "low"
       concern for risk (Table ES.2). Clear concern for risk indicates that for the chemical in
       question, under the assumed exposure conditions of the Flexographic inks CTSA research,
       adverse effects were predicted to occur. Potential concern for risk indicates that for the
       chemical in question, under the assumed exposure conditions, adverse effects may occur.
       Low or negligible concern for risk indicates that for the chemical in question, under the
       assumed exposure conditions, no adverse effects were expected.
                            Table ES.2 Criteria for Risk Levels
Level of
Concern for
Risk
Clear
Potential
Lower
negligible
Hazard Quotient a
>10
1to10
<1
Margin of Exposure b
NOAEL
1 to 10
>10 to 100
>100
LOAEL
1 to 100
> 100 to 1,000
> 1 ,000
SAT Hazard
Rating c
moderate or high
low-moderate
low
 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.
 B NOAEL = No Observed Adverse Effect Level. LOAEL = Lowest Observed Adverse Effect Level. 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 significant adverse effects are observed. The LOAEL is the lowest concentration at which adverse
 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.
 °This column presents the level of risk concern if exposure is expected. If exposure is not expected, the
 level of risk concern is assumed to be low or negligible. 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.
   Human Health Findings

        The toxicity information was combined with estimated releases and exposures to develop
        a risk characterization of individual chemical substances.Each chemical substance was
        analyzed for systemic and developmental toxicity. Systemic toxicity means adverse effects
        on any organ  system following absorption and distribution of a chemical throughout the
        body. Developmental toxicity refers to adverse effects on a developing organism that may
                                         ES-9

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                                                                          EXECUTIVE SUMMARY
               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. Although some inks in the CTSA also contained known or possible human
               carcinogens, there was not enough quantitative information to analyze specific cancer risk
               concerns.

               Worker Health  Risks
               The study assessed possible risks via both the inhalation and dermal (skin) pathways. Each
               ink system contained chemicals that showed clear health risk concerns for workers who
               handle inks in the prep room or pressroom, under the assumptions used for the study.

               Of the roughly 100 chemicals, studied, 24 were found to pose clear worker health risk
               concerns (Tables ES.3 and ES.4).***
                 •  Alcohols, amides and nitrogenous compounds, and acrylated polyols contained the
                    most chemicals found to pose clear worker risk concerns.
                 •  For pressroom workers, exposure was highest with solvent-based inks because of the
                    higher ah" release rate.
                 •  In the three solvent-based ink product lines studied, most of the chemicals presenting
                    a clear occupational risk concern were solvents. Pressroom workers can be exposed
                    to uncaptured (i.e., fugitive) emissions in the facility, while stack emissions from
                    using solvent-based inks are destroyed by oxidizers. The use of oxidizers thus only
                    impacts stack emissions  and does not reduce opcupational health hazards and risk
                    concerns.
                 •  Li water-based formulations, amides or nitrogenous compounds often  presented
                    systemic  risk concerns.
                 •  The use of press-side solvents and additives increased the occupational risk concern
                    for many  of the solvent- and water-based ink formulations. In particular, alcohols and
                    propylene glycol ethers  in solvent-based   inks, and amides  and  nitrogenous
                    compounds, alcohols, and ethylene glycol ethers in water-based inks presented clear
                    or potential occupational risk concerns in certain formulations.
                 •  For UV-cured inks, some acrylated polyols and amides or nitrogenous compounds
                    showed clear inhalation  risk concerns for workers. It is important to understand,
                    however,  that the CTSA studied  uncured UV inks only, due to resource limitations.
                    The concerns  associated  with  cured UV  inks are  not known, but  anecdotal
                    information from industry suggests that curing may greatly reduce such concerns.
          To protect manufacturers' proprietary information, when discussing formulations the risk results group
the specific chemicals into categories rather than presenting results for individual chemicals.
                                              ES-10

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                                                         EXECUTIVE SUMMARY
Table ES.3 Clear INHALATION Risk Concerns for Flexographic Workers
Ink System
Solvent-based
Water-based
UV-cured
Chemical Categories with Chemicals of
Clear Risk Concern
Alcohols
Alkyl acetates
Hydrocarbons (low molecular weight)
Propylene glycol ethers.
Alcohols
Amides or nitrogenous compounds
Ethylene glycol ethers
Acrylated polyols
Amides or nitroqenous compounds
Systemic
Risk Concern
X
X
X
X
X
X
X
X
X
Developmental
Risk Concern
X
X
X
X
  Table ES.4 Clear DERMAL Risk Concerns for Flexographic Workers
Ink System

Solvent-based






Water-based




UV-cured





Chemical Categories with Chemicals of
Clear Risk Concern
Alcohols
Alkyl acetates
Inorganics
Organometallic pigments
Organotitanium compounds
Organic acids or salts
Propylene glycol ethers
Alcohols
Amides or nitrogenous compounds
Ethylene glycol ethers
Organic pigments
Organometallic pigments
Acrylated polyols
Acrylated polymers
Amides or nitrogenous compounds
Inorganic pigments
Organometallic pigments
Orqanophosphorus compounds
Systemic
Risk Concern
X
X
X



X
X
X
X
X
X
X
X
X

X
X
Developmental
Risk Concern
X

X
X
X
X

X
X



X
X
X
X


 Table ES.5 lists the .potential effects on  organ systems (e.g.,  cardiac, respiratory,
 reproductive) from dermal and inhalation exposure to chemicals and chemical categories of
 clear worker health risk concern. "Toxicological endpoints" are the potential effects on
 organ systems that have been reported in the medical literature and other scientific reports
 in association with  use of a chemical. This does not mean, however, that any of these
 effects are necessarily caused by that chemical. Only the chemicals listed for a specific
 category were associated with clear worker risk concerns. Thus, for example, CI Pigment
 Red 23 was the only organic pigment that showed clear worker health risk concerns.  A
 number of the ink chemical categories that were examined in the study (e.g., resins, olefin
 polymers, siloxanes) did not show clear risk concerns and thus are not included in this table.
                               ES-11

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                                                EXECUTIVE SUMMARY
Table ES.5 Toxicological Endpoints of CTSA Chemicals with
          CLEAR Worker Health Risk Concerns
Chemical
Category
Acrylated
polymers
Acrylated
polyols
Alcohols
Alkyl acetates
Amides or
nitrogenous
compounds
Ethylene glycol
ethers
Hydrocarbons
— low
molecular
weight
Chemical
Glycerol propoxylate
triacrylate
Dipropylene glycol
diacrylate (SAT)a
1 ,6-Hexanediol diacrylate
Hydroxypropyl acrylate
Trimethylolpropane
triacrylate
Ethanol
Isobutanol
Isopropanol
Butyl acetate
Ethyl acetate
Ammonia
Ammonium hydroxide
Ethanolamine
Hydroxylamine derivative
(SAT)a
Butyl carbitol
Alcohols, C11 -CIS-
secondary, ethoxylated
(SAT)*
Ethyl carbitol
n-Heptane
Potential Effects on Organ Systems (via oral and dermal
paths) d
tissue necrosis at application site, decreased body weight,
neurotoxic and respiratory effects
genotoxicity, neurotoxicity, oncogenicity, developmental and
reproductive effects, dermal and respiratory sensitization, and
skin and eye irritation
developmental effects
respiratory effects
decreased body weight, skin and neurotoxic effects, changes
in clinical chemistry, altered organ weights, respiratory effects
blood, liver, neurotoxic, and reproductive effects, decreased
cellularity of the spleen, thymus, and bone marrow; dev: fetal
malformations
blood and neurotoxic effects, changes in enzyme levels; dev:
cardiac septal defects
blood and skin effects, tissue necrosis at application site,
increased kidney and liver Weight; liver, neurotoxic,
reproductive, respiratory, and spleen effects, changes in
enzyme levels and clinical and urine chemistry; dev: fetal
death, musculoskeletal abnormalities, fetotoxicity
changes in serum chemistry, fluctuations in blood pressure;
dev: fetotoxicity, musculoskeletal abnormalities
blood, cardiovascular, gastrointestinal, kidney, liver,
neurotoxic, and respiratory effects, decreased spleen and, liver
weight, increased adrenal, lung, and kidney weight
corneal, liver, respiratory, and spleen effects
eye effects, nasal irritation, respiratory effects
respiratory irritation; kidney, liver, neurotoxic, and respiratory
effects
genotoxicity, dermal sensitization, developmental toxicity
blood and skin effect, liver effects
skin irritant; eye irritation and lung effects
no data
auditory and neurotoxic effects, altered serum chemistry
                       ES-12

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                                                                             EXECUTIVE SUMMARY
Chemical
1 Category
Inorganics
Organic acids
or salts
Organo-
phosphorous
compounds
Organotitanium
compounds


Pigments —
organic
Pigments —
organometallic
Propylene
glycol ethers
L 	
Chemical
Barium
Dioctyl sulfosuccinate,
sodium salt
Phosphine oxide, bis(2,6-
dimethoxybenzoyl) (2,4,4-
trimethylpentyl)-
Isopropoxyethoxytitanium
bis(acetylacetonate) (SAT)a
Titanium diisopropoxide
bis(2,4-pentanedionate)
Titanium isopropoxide
Cl Pigment Red 23
D&C Red No. 7
Propylene glycol methyl
ether
Potential Effects on Organ Systems (via oral and dermal
decreased body weight, reproductive and respiratory effects,
ncreased arterial blood pressure; dev: decreased survival and
weight gain, changes in hematology parameters
no data
no'data
neurotoxicity, genotoxicity, oncotoxicity, and developmental/
reproductive toxicity; skin, eye, mucous membrane irritant
SAT: irritation of the eyes, skin, and mucous membranes.
Moderate concern based on release of hydrolysis products: 2,4
pentanedione, inorganic titanium, and isopropanol. 2,4 ,
pentanedione: concern for neurotoxicity, mutagenicity,
oncogenicity, and developmental/reproductive toxicity.
Inorganic titanium: concern for mutagenicity and oncogenicity.
Isopropanol: concern for liver, neurotoxic, reproductive,
respiratory, and spleen effects; changes in enzyme levels and
clinical and urine chemistry; fetal death, musculoskeletai
abnormalities, fetotoxicity, blood and skin effects, tissue
necrosis at application site, increased kidney and liver weight
SAT: irritation of the eyes, skin, and mucous membranes.
Moderate concern based on release of the hydrolysis products,
inorganic titanium and isopropanol. Inorganic titanium:
concern for mutagenicity and oncogenicity. Isopropanol:
concern for liver, neurotoxic, reproductive, respiratory, and
spleen effects; changes in enzyme levels and clinical and urine
chemistry; fetal death, musculoskeletai abnormalities,
fetotoxicity, blood and skin effects, tissue necrosis at
application site, increased kidney and liver weight.
no data
no data
increased mortality; blood, neurotoxic, and skin effects; altered
kidney weights; decreased growth, liver, neurotoxic,
reproductive, and respiratory effects, increased liver and
kidney weights; dev: delayed ossification of vertebrae,
musculoskeletai abnormalities 1
These chemical categories posed risk concerns under the specific conditions of this study; they might be associated
with different risks, or with no risk at all, under different conditions.
Dev = developmental effects. All endpoints not specifically indicated as developmental are systemic.
a SAT:'Structure Activity Team and acute data reports.                                       .
d Developmental risks for SAT-evaluated chemicals were evaluated on a "concern/no concern  basis.
                                                 ES-13

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                                                           EXECUTIVE SUMMARY
 Many of the chemical substances that show hazard or risk concern are commonly used in
 flexographic inks, although they are not necessarily found in every ink formulation. To
 protect workers from such concerns, printing firms can take several steps:
   •   Review ink formulations against CTSA data, MSDS information, Table 8.13 of
       the Flexographic Inks CTSA, and other sources to identify chemicals that may
       present concerns under certain conditions of use.
   •   Establish effective policies that require workers  to wear proper gloves and other
       personal protective gear when working with inks. If workers wear appropriate
       protections, the dermal concern is essentially zero.
   •   Ensure appropriate ventilation to minimize inhalation exposure.
   •   Adopt pollution prevention practices to minimize use and disposal of chemicals
       of concern (e.g., management of chemical inventory).

 General Population Risks
 For the general population (people who live near a printing facility), the study assessed
 possible inhalation risks. No chemical categories showed a clear risk concern to the general
 population. However, alcohols in solvent- and water-based inks, and acrylated polyols in
 UV-cured inks, included one or more chemicals that showed a potential risk concern for the
 general population. Exposures and risk concerns for the general population due to emissions
 from water-based and UV-cured inks were calculated to be significantly lower than those
of solvent-based inks. This is because solvent-based inks showed higher fugitive emissions
(e.g., chemicals released from a long web run between presses), which outweighed the
decrease in stack emissions resulting from the use of oxidizers.
                             ES-14

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                                                                 EXECUTIVE SUMMARY
Environmental Findings

       Ambient Air Releases  .
       Releases to air result from the evaporation of chemicals during the flexographic printing
       process.  Releases to air are used to estimate inhalation exposure to particular chemicals for
       workers and the general population. The CTSA examined two forms of air releases. 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. It was assumed that 30% of the VOCs released to the
       air were fugitive emissions, and 70% were captured by the press system and released
       through a stack. It was also assumed that solvent-based ink releases would pass through a
       catalytic oxidizer with a destruction efficiency of 95%, but that water-based or UV-cured
       ink systems would not utilize an oxidizer.  Environmental releases relate to the rates  of
       vapor generation, which vary depending on press speed, VOC content of the ink mixture,
       equipment operating time, temperature of the ambient air  and ink system, the capture
       efficiency of the press system, and the destruction efficiency of the air control devices.

       The calculated volatilization rates of the solvent-based inks were considerably higher
       than those for the other two ink systems.  The volatilization rates for water-based inks
       were considerably lower than those for solvent-based inks, but the stack releases were
       higher because the use of an oxidizer was not anticipated.  On the other hand, the
       fugitive emissions of the water-based inks were considerably lower than those for
        solvent-based inks because of the lower average VOC content of water-based inks.

        The UV-cured inks showed releases comparable to those of  water-based inks and higher
        than those of solvent-based inks. These figures were calculated with the assumption that
        all VOCs would be released to the air. In reality, however, much of the volatile content
        would be incorporated into the coating during the UV curing process. The decrease in
        emissions under real-world conditions is unknown.

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

        Press speed greatly affected the amount of ink consumed, and thus the releases of
        volatile compounds. Air releases also varied among colors within each ink system; the
        differences were primarily due to different ink consumption rates, which will vary with
        every printing job.
                                       ES-15

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                                                                         EXECUTIVE SUMMARY
               Aquatic Toxicity
               Roughly half of the ink chemicals showed a medium or high aquatic "toxicity (capable of
               causing long-term effects to aquatic organisms, in a concentration of less than 0.1 mg/liter).
               Eighteen chemicals (Table ES.6) were found to have high aquatic toxicity. Another 35
               chemicals showed  medium aquatic toxicity. Because the inks were not expected to be
               released to the aquatic environment, water releases and subsequently related risks were not
               assessed. If any of these inks are in fact released untreated to water, however, there could
               be aquatic risk concern.

                     Table ES.6 CTSA Chemicals With High Aquatic Toxicity
Amides, tallow, hydrogenated
Ammonia
C.I. Basic Violet 1
molybdatephosphate
C.I. Basic Violet 1
molybdatetungstatephosphate
C.I. Pigment Violet 27
Dicyclohexyl phthalate
Distillates, petroleum, hydrotreated
light
2-Ethylhexyl diphenyl phosphate
Glycerol propoxylate triacrylate
n-Heptane
2-lsopropylthioxanthone
4-!sopropylthioxanthone
Mineral oil
Resin acids, hydrogenated,
methyl esters
Styrene
Thioxanthone derivative
Trimethyiolpropane ethoxylate
triacrylate
PERFORMANCE
               Because quality of printing is a critical need of flexographers, the CTSA conducted 18
               performance tests, which examined quality aspects anticipated to be important for a broad
               range of flexographic printers. (See Chapter 4 for details.)

               Eleven performance demonstrations were conducted at printing facilities that volunteered
               to participate, using inks donated by ink companies. The inks used were considered fairly
               representative of ink types commonly in use at that time. Five ink colors (cyan, magenta,
               blue, green, and white) were included,  to allow testing of both process and line printing
               results. The performance demonstrations were brief printing runs of a representative test
               image (Figure ES.4), which was printed using wide-web presses onto three types of film
               substrates:  oriented polypropylene (OPP);  low-density  polyethylene  (LDPE);  and
               polyethylene/ethyl vinyl acetate co-extruded film (PE/EVA). These substrates were chosen
               because they correspond to important flexographic market segments.  To collect baseline
               data, laboratory runs were also conducted in the printing laboratory of Western Michigan
               University. This' was done to give printers a better sense of the actual capabilities of the ink-
               substrate combinations.
                                             ES-16

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                                                    EXECUTIVE SUMMARY
             Figure ES.4 Test Image Used in Demonstration Runs
Performance  tests  were conducted on the samples from both   the  performance
demonstrations and the laboratory runs (Table ES.7).

              Table ES.7  Performance Tests Conducted in CTSA
Adhesive lamination
Block resistance
CIE L*a*b*
Coating weight
Coefficient of friction (COF)
Density
Dimensional stability
Gloss
Heat resistance/heat seal
ice water crinkle adhesion
Image analysis
Jar odor
Mottle/lay
Opacity
Rub resistance
Tape adhesiveness
Trap
Uncured residue (UV-cured inks only)
                            ES-17

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                                                                 EXECUTIVE SUMMARY
Performance Findings

       The quality  of performance  varied widely  across  ink  systems,  substrates, and ink
       formulations. No clear evidence emerged that any one ink system performed best overall.
       For example,
          •   Water-based inks outperformed solvent-based inks on both LDPE and PE/EVA
              substrates.  Solvent-based inks performed better than water-based inks  on the
              adhesive lamination test.
          •   Gloss was highest for solvent-based inks on PE/EVA.  Gloss was low on UV-cured
              inks, despite the fact that high gloss is considered to be a strength of UV finishes.
          •   Odors varied in both strength and type across both ink and substrate type.
          •   Mottle was significantly higher for water-based inks, as well as for blue inks overall.
          •   UV-cured inks displayed good resistance to blocking,  particularly on PE/EVA and
              no-slip LDPE.
          •   UV-cured inks displayed relatively good trapping.
          •   Mottle results for UV-cured inks were better than that of the water-based inks and
              comparable to that of the solvent-based inks.
          •   Coating  weight was greater for UV-cured inks, despite lower ink consumption.
          •   Some UV-cured inks showed unimpressive results on the rub resistance and tape
              adhesiveness tests.

       The variances in results show the importance of a number of factors in the performance of
       these inks:
           •  Substrate type
           •  Type and  amount of vehicle  (e.g., solvent  in solvent-based  ink and water in
              water-based ink), as well as press-side solvents and additives
           •  Functional ink-substrate interactions such as wetting  and adhesion

       Table ES.8 lists the ink system, color, and substrate combinations showing "best in class"
       performance for selected tests that were run.  Most  of these 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. (The "worst" score is also provided, but only to give
       an indication of the large range in scores on almost all tests.) Due to a variety of issues that
       occurred at volunteer facilities, not all ink systems received all tests.
                                     ES-18

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                                                                       EXECUTIVE SUMMARY
        Table ES.8 Selected "Best in Class" Performances on Flexography CTSA Tests
Test
Adhesive
lamination
Block resistance
Density
Gloss
Heat resistance
Ice water crinkle
/
Image analysis
Mottle
Rub resistance,
wet
Best Score
.3040 kg
(highest)
1.0 (lowest) -,
2.1 7 (highest)'-
59.08 (highest)*
0 failures
(lowest), .
no ink removal,*
(least) ''
S f
'324pm2 dot '
- are,a (lowest)
47 (lowest) > r
T0 "failures at 10,
Strokes -
Ink System
solvent"
UV no slip
UV high slip
solvent
solvent13
solvent,
water
solvent
UV no slip
water,
solvent
Substrate
OPP
LDPE
LDPE
PE/EVA
OPP
LDPE,
PE/EVA
PE/EVA
LDPE
LDPE
(PE/EVA)
Color
N/A°
N/A
blue
N/A.
N/A
N/A
cyan
green
N/A
Worst Scoreb3
.2575 kg (lowest)
3.2 (highest)
1 .09 (lowest)
32.31 (lowest)
24 failures (most)
30% ink removal
(most)
1 050 urn2 (highest)
81 2 (highest)
failure at 2.2
strokes
This score represents the opposite end of the range of all scores received on this test for'all ink systems tested.
bUV-cured samples were not tested.
°N/A indicates that the test results were not color-specific.
              These performance demonstrations were completed in 1997, since which time flexographic
              printing technology for UV-cured inks has made significant advances. The test results of
              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.

              In addition, because performance is a function of many factors—including equipment, ink,
              substrate, and operator experience — a printing facility that conducts its own performance
              tests  might obtain different results than the CTSA.   This potential for variability is
              demonstrated by the performance results, which differed widely among formulations within
              the same ink system. The performance variability indicates that there may not be one best
              overall choice of an  ink system for  all performance conditions and applications. A
              flexographic printer cannot simply assume that one ink system or ink-substrate combination
              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 desked
              quality on a consistent basis.

              UV curing technology, especially as  it pertains to wide-web printing on film substrates, was
              in  a developmental stage at the time these tests were conducted. The test results 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-cured inks.
              Since that time, improvements to this ink system have been made on several fronts.  In
              addition,   manufacturers  of  both  solvent-based  and water-based inks  have made
              improvements in formulations since the performance demonstrations were completed. In
                                             ES-19

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                                                                         EXECUTIVE SUMMARY
               particular, changes that have been made to resins and slip additives of inks may yield
               improved adhesive characteristics and other traits.
COSTS
               A number of costs are important to facility profitability and have the potential to highlight
               differences among ink systems. The study evaluated the costs of materials (ink and press-
               side additions), labor, capital, and energy. Substrate costs were not evaluated because they
               are not dependent upon ink use.  Input quantities for materials were obtained during the
               performance demonstrations. Suppliers provided information about costs.

               This analysis  averages industry information, and therefore it may not reflect the actual
               experience of any given printing facility in this short-term demonstration. For example, the
               efficiencies of a long run with familiar products were not achieved. Also, press speed under
               many printing conditions is expected to be different (and in general, higher) than in this
               analysis. While this study focused on those costs that typically account for the majority of
               total costs, other important costs (e.g., waste disposal, regulatory compliance, insurance,
               storage, clean-up, and permitting) should not be overlooked. In addition, press maintenance
               and other conditions may affect ink usage, and therefore ink costs.
       Cost Findings
                  Highlights of the cost analysis include the following:
                  •   Materials  were the highest cost category for the  CTSA printers among  the
                      categories studied. Water-based inks had the lowest material costs of the three
                      systems, showing a higher mileage than solvent-based inks and a much lower per-
                      pound cost than UV-cured inks.
                  •   The analysis did not consider start-up and clean-up labor, and the press speed was
                      assumed to'be the same for all three ink systems. (Labor costs would have differed
                      by ink system if the analysis had captured the costs of preparation, cleanup, etc.)
                      Therefore, labor cost (wages and benefits for two press operators) was identical in
                      the study for all three systems.
                  •   Energy cost (electricity and natural gas) was highest for UV-cured inks. The water-
                      based system showed the lowest energy cost because  it assumed no energy use by
                      oxidizers.  If oxidizers were to be used, much of the water-based system's cost
                      advantage would disappear.
                  •   Water-based inks  had  the lowest capital costs  (press and  other  required
                      components), because the water-based printers did not use oxidizers. Solvent-based
                      inks showed higher capital costs because of the expense of oxidizers. Because UV
                      uses lamps to cure inks, this system also had higher capital costs. However, the
                      capital costs of a new press for all three  technologies were relatively similar.
                      Therefore, they are likely to be only a small factor in the selection of an ink system.
                  •   Assuming a press speed of 500 feet per minute, the CTSA found that the total cost
                      was lowest for  the  water-based system, with the solvent-based and UV-cured
                      systems costing on average 24% and 38% more respectively (Table ES.9).
                                             ES-20

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                                                                       EXECUTIVE SUMMARY
                     Table ES.9 Cost Averages (per 6,000 square feet, at 500 feet per minute)
Ink system
Solvent-based
Water-based
UV-cured
Materials
(lnk&
Additions)
$15.29
$9.55
$18.63
Labor
$5.29
$5.29
$5.29
Energy
$0.53
$0.35
$1.03
Capital
$1 1 .87
$11.41
$11.87
Total
$32.98
$26.60
$36.82
                  Generally speaking, press speed appears to be the most important driver of a printer's
                  total cost, because all costs except that of ink and substrate were impacted by press
                  speed. Thus, press speed is a critical variable in maximizing profitability of flexographic
                  printing, 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.
RESOURCE USE AND ENERGY CONSERVATION

              By minimizing resource and energy use, printers can improve both their bottom line and the
              environment. To identify potential issues on which printers may wish to focus their efforts,
              the study investigated several sources of resource consumption (Table ES. 10) and pollutant
              generation related to the three ink systems studied:
                  •    resources consumed,
                  •    energy used,
                  *    energy-related emissions generated by each ink system, and  .
                  •    possible environmental impacts of energy-related impacts.

                                Table ES.10  Categories of Consumption Studied
          Category of
          Consumption
          Printing-related
          resources
          Energy
          consumed by
          the printing of
          each ink-
          substrate
          combination
Specific elements
Included
Inks, solvents, and press-
side additives
Natural gas and electricity
to ruii presses presses and
ancillary press equipment
(oxidizers, hot air dryers,
drying ovens, corona
treaters, UV-curing lamps
and coolers)
Comments
The ink consumption figures were
calculated during the performance
demonstrations, and were affected by
several site-specific factors, such as type of
cleaning equipment, anildx roll size, and the
level of surface tension of the substrate.
Equipment vendors estimated energy
requirements in kilowatts for electricity and
in Btus/hr for natural gas. These estimates
were used instead of actual site-specific
data to calculate energy consumption for
the study.
                                             ES-21

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                                                              EXECUTIVE SUMMARY
        The energy-related emissions from printing each ink-substrate combination include
        carbon dioxide, carbon monoxide, hydrocarbons, nitrogen oxides, particulate matter,
        dissolved solids, solid wastes, sulfur oxides, and sulfuric acid. With natural gas, the
        emissions are generated at the printing facility, but with electricity, the emissions are
        generated off-site at the power plant. Either way, the printing facility needs to know
        environmental impacts that can be attributed to the printing processes used. This allows
        a facility to plan ways to reduce energy use and the related environmental releases that
        are  generated  by  different types of  energy.  Employing  more energy-efficient
        technologies may benefit printers by reducing production costs, lowering energy-related
        emissions, and improving the facility's public image.

Resources Used and Emissions Generated

    The study examined various specific inputs to the printing processes, including the press
    units, oxidizers, hot air dryers, drying ovens, corona treaters, UV-curing lamps, andcoolers.
    When all of these were taken into consideration,
        •   The energy consumed was estimated to be lowest  for the water-based system
           because no oxidizers or curing lamps were used. The  solvent-based system, which
           used oxidizers to destroy stack emissions, consumed  the most energy.
        •   The estimated emissions were lowest for the water-based system, because much of
           its energy derives from natural gas, which releases less emissions per unit of energy
           than does electricity. Although the UV-cured system consumed little more energy
           than the water-based system, it was estimated to result in the highest total energy-
           related emissions, because all of its energy comes from electricity.

    Table ES.12 lists the amounts of resources consumed by each ink system, as well as the
    amounts of environmental releases of pollutants associated with energy production. Results
    are reported in terms of grams per 6000 square feet of substrate, which allows a direct
    comparison of pollutants generated by the  different ink systems.

          Table ES.11 Average Resource Use and Energy-Related Emissions
                                      (atSOOfpm)
Ink System
Solvent-based
Water-based
UV-cured
Resources
Consumed *
(lb/6,000 ft2)
8.53
4.14
2.16
Energy Consumed
per 6,000 ft2 (Btu)b>c
100,000
73,000
78,000
Energy-Related
Emissions
Generated
(g/GOOOft2)"
10,000
6,800
18,000
   a Ink consumption figures were averaged from the total costs of ink, solvents, and additives for all
   three substrates in Table 6.4; energy consumption figures are from Table 6.11; and energy-related
   emissions are from Table 6.21.
   b Electrical energy was converted to Btus using the factor of 3,413 Btu per kW-hr.
   c Electricity was generated offsite.
   d Energy-related emissions were calculated using a computer model rather than by capturing and
   analyzing actual emissions from the facilities.

   Pollutants that were released during energy production of the CTSA printing runs include
   carbon dioxide,  carbon monoxide, dissolved solids, hydrocarbons, nitrogen oxides,
   particulate matter, solid wastes, sulfur oxides, and sulfuric acid. Again, because UV curing
                                  ES-22

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                                                                       EXECUTIVE SUMMARY
              relies exclusively upon electricity, this ink system was shown to generate more of the
              pollutants that are associated with this form of energy (such as nitrogen oxides, carbon
              dioxide, and sulfur oxides), some of which affect environmental air quality and are
              important to global climate change. Energy use was analyzed using the methodology press
              speed (500 feet per minute) and actual press speed. The amount of pollutants generated was
              associated with press speed, and higher press speed produced fewer grams of pollutants for
              the same number of feet of substrate.

              Overall, the water-based ink system generated the fewest grams of pollutants per 6000 feet
              of substrate printed, and the  UV-cured ink system generated the most. Most of these
              pollutants fall into a category called "use impairment impacts," which includes global
              warming compounds, acid rain precursors, smog formers, corrosives, dissolved solids,
              odorants, and particulatds.                         .

CHOOSING AMONG FLEXOGRAPHIC INKS

              This section summarizes important findings of the Flexographic Inks CTS A by ink system,
              and identifies ways to use the CTSA to incorporate health and environmental irnpacts of
              flexographic ink chemicals in  business decision-making.

              Choosing an ink system, an ink product line (e.g., solvent-based ink #1), or a specific ink
              formulation (e.g., color within a product line, such as solvent-based ink #1 white) is not a
              simple task. The study found substantial variation within each ink system in health and
              environmental impacts, performance, cost, and resource use. Each aspect of ink use has
              implications — important environmental health  and safety implications as well as
              performance, cost, and energy use .  Every product line analyzed in the CTSA included
              chemicals that are associated with multiple clear health risk concerns for flexographic press
              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).

       Highlights of CTSA Findings

               Solvent-based Inks
                   •   The solvent-based ink system, on average, had total operating costs that were lower
                       than those of UV-cured inks but higher than those  of water-based inks. This higher
                       cost can be attributed mostly to higher material and capital costs of solvent-based
                       technologies. 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.
                  - •   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.
                   •   Oh average, solvent-based inks contained two  to four chemicals  with a clear
                       concern for 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
                                             ES-23

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                                                         EXECUTIVE SUMMARY
       system did not contain any HAPs. For general population risks, two chemical
       categories in one solvent based ink (ink #2) contained chemicals that presented a
       potential concern for 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; they 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 with a clear concern for risk per product line, indicating a
       better chance of reducing occupational health risks compared to solvent-based
       inks.
    •   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.

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 that of solvent-
       based inks,  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
                             ES-24

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                                                                 EXECUTIVE SUMMARY
               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
               of SAT-analyzed compounds present a potential concern for 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 solvent-based inks, and was only slightly higher than that of the water-based
               inks.  The air releases associated with the energy production were higher than
               solvent-based inks, however, because all energy required by the UV system was
               derived from electricity—a more pollution-intensive energy source in comparison
               to natural gas.

Choosing Cleaner, Safer Ink Chemicals

       Because of the importance of the specific formulation to the results of the flexographic ink
       study, printers are advised to pay as much attention to selecting the "cleanest" formulation
       within an ink system as to the ink system itself.

       Table 3-1 provides toxicity and risk screening information on the chemical substances that
       were  included  in this study.  Many of the substances were found in multiple ink
       formulations and are likely to be found in other inks. Whether choosing amongst the ink
       systems or choosing an ink formulation, it is important to consider the health, safety, and
       environmental impacts of the chemical substances that make up a formulated product. The
       DfE Flexographic Inks CTSA can serve  as  a first step in bringing a  more positive
       environmental profile into the printing shop.  The DfE Program encourages printers and the
       ink manufacturer and distributors to actively engage in a dialog on "getting the right mix"
       in the print shop.

       Table  8.13 summarizes hazard and risk information for every chemical category and
       chemical in the study. Flexographic professionals can use this table to compare chemicals
       within and across chemical categories, which can help to identify possible alternatives for
       a chemical that shows concerns. As an example, Table ES.12 below shows a partial entry
       for ethylene glycol ethers from Table 8.13. The Hazard columns indicate that ethylene
       glycol ethers have moderate (M) and moderate-high (M-H) hazards, and the Occupational
       Risk column shows several instances of clear risk concern for this chemical category under
       the conditions of use analyzed in this study.
                                      ES-25

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                                                                    EXECUTIVE SUMMARY
        TableES.12 Summary of Hazard and Risk Data by Chemical Category (Excerpt)
Ink
System
Chemicals
Data
Source
Hazard
Aquatic
Dermal"
Inhalation8"
Occupational Riskc
Dermal
Inhalation
Ethylene glycol ethers
Water
Alcohols, C1 1-1 5-
secondary,
ethoxylated
68131-40-8
Butyl carbitol
112-34-5
Ethoxylated
tetramethyldecyndi
ol
9014-85-1
Ethyl carbitol
111-90-0
Polyethylene glycol
25322-68-3
SAT
Tox
SAT
Tox
Tox
M
L
L
L
- L
M/M
L/L
L-M/NA
M-H/L
UNA
M/M
M/L
L-M/NA
M-H/L
L/NA
clear
clear
potential
clea'r
potential
n.e.
clear
n.e.
clear
n.e.
  I ne tirst letter(s) represents systemic concern, the second represents developmental concerns. L= Low; M =
Medium; H = High; NA = No data or information are available; n.e. = No Exposure
b Inhalation hazard information was not included for compounds that are not expected to be volatile (i.e., that have
a vapor pressure <0.001 mmHg).
0 Dermal occupational risk concern ratings are applicable for press and prep room workers; inhalation risk concern
ratings are applicable for press room workers. The risk concern levels shown here represent the highest observed
risk rating.
         Other Suggestions for Reducing Impacts of Flexographic Inks
         DfE partners, particularly the Steering Committee, include the major trade associations in
         the flexographic ink industry.  These partners are an excellent source of information on both
         industry trends and concerns. Their willingness to maintain continued partnership with DfE
         over  the years demonstrates their commitment to providing  the industry with sound
         environmental information. Trade associations are considered essential DfE partners during
         a project as well as for industry-wide communication and implementation of project results.
         Associations are key to sharing information, including incentives to making change and
         recognition of businesses that have overcome obstacles.

         In addition to your trade association, other useful resources include the EPA's Office of
         Pollution   Prevention   and  Toxic's   (OPPT)  website.     Please  visit  the  site
          to find tools, models, and chemical
         information for better understanding chemicals.

         Also, important information  on  chemical categories can be found at the EPA's New
         Chemicals website . The chemical
         categories broadly describe potential concerns for substances that may fall into a specific
         chemical category. The category  also describes bounds for determining whether a specific
         chemical substance, that would generally fall into a category, actually might be considered
         of concern. A category statement describes the molecular structure a chemical might have
         to be included in the category as well as boundary conditions such as molecular weight,
         equivalent weight, the log of the octanol/water partition coefficient (log P),  or water
         solubility, that would determine inclusion in (or exclusion from) a category, and standard
                                        ES-26

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                                                          EXECUTIVE SUMMARY
hazard and fate tests to address concerns for the category. Currently, there are a total of 45
categories.

A few excellent secondary sources of chemical information include the following:
  •   The Hazardous Substances Data Bank, in TOXNET:
       
  •   Agency for Toxic Substances and Disease Registry (ASTDR):
        
  •   The  National Library of Medicine Toxicology and Environmental Health
     Specialized Information Services:
       
  •   TOXLINE: The National Library of Medicine's extensive collection of online
     bibliographic information covering the biochemical, pharmacological,
     physiological, and toxicological effects of drugs and other chemicals.
       
  •   Integrated Risk Information System (IRIS):
       

 The DfE website (www.epa.gov/dfe) may also serve as a source of information on other
 chemical substances. The DfE Program has reviewed many other substances in similar
 cleaner technology evaluations, including previous partnerships focused on the activities
 of screen and lithographic printers.

 There is another message  here in understanding chemicals in  the workplace:  To be a
 proactive decision-maker, it is critical to have the best information available. Building as
 well as choosing a product formulation with a more positive environmental profile may
 require extra care and scrutiny, especially when selecting raw materials. A material data
 safety sheet (MSDS) and the product label  provide  an  excellent starting place for
 understanding the potential impacts of a chemical; however, the MSDS or label may not
 provide all the information  needed to make a better choice.  Often, chemicals are
 generically described by chemical class or, by trade name. Structural and other differences
 in chemicals of the same general class and makeup may not be apparent from product
 literature or labels, especially for imported  substances. Descriptions in distributor or
 supplier literature and catalogs may define a chemical type but not detail a chemical's
 actual structure (e.g., whether a carbon chain is branched or linear - a key distinction from
 an environmental standpoint since linear chains biodegrade more rapidly than branched).
 Also', sales materials may only list trade names, often an imprecise descriptor, since a name
 might remain the same while the actual product composition may change. The databases
 and resources described above identify chemical substances by specific chemical name; it
 is important to get correct chemical identify information that includes Chemical Abstract
 Service (CAS) names and CAS numbers when doing research on chemical formulations.

 DfE encourages you to visit our website for more information on the DfE formulator
 initiative, at http://www.epa.gov/dfe/projects/formulat/index.htm. The DfE Program offers
 partnership and recognition to companies that act as environmental stewards by improving
 the environmental profile of their formulated products and processes.

 Table ES. 13 presents some  suggestions for how flexographic professionals can quickly and
 easily take actions that may reduce the health and  environmental  impacts  of using
 flexographic inks. The CTSA also includes more general ways to implement  pollution
 prevention  related to the flexographic industry.

             :                  ES-27

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                                                         EXECUTIVE SUMMARY
Table ES.13 Ways to Reduce Environmental and Health Impacts of Flexographic Inks
Suggestion
Read flexographic 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.
Work to make environmental and health
information about inks more accessible and
understandable.
Support research on untested and
inadequately tested flexographic ink
chemicals, especially those with clear or
potential 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
                                 ES-28

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                                                    EXECUTIVE SUMMARY
REFERENCES

1. U.S. Census, 1999 Survey of Manufactures.

2. U.S. Census. 1997. Commercial Flexographic Printing.

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

4. U.S. Census. 1997. Commercial Flexographic Printing.

5.  National Association of Printing Ink Manufacturers. 2001 State of the
   Industry Report, p 4 (Printing Ink 2000 Market).
                            ES-29

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                              EXECUTIVE SUMMARY
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     ES-30

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CHAPTER 1
INTRODUCTION TO THE CTSA
                         Chapter 1: Introduction to the

                Cleaner Technologies Substitutes Assessment


1.1 BACKGROUND AND METHODOLOGY

              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  Design  for the  Environment  (DfE)  Program  comprises  several  voluntary
              partnership-based initiatives 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.

              In accordance with  its  mission, DfE's intention was  to ensure that  all work on the
              Flexography Project, including technical research, analysis,  and outreach, would be
              performed collaboratively.  Toward  this end,  DfE first formed a Steering Committee -
              consisting of representatives of several flexographic trade  associations. The Steering
               Committee provided leadership, technical expertise, and guidance, meeting about once a
               month throughout the Project. In additipn, the Project set up a Technical Committee, which
               included representatives of flexographic  trade associations, ink formulators, printers,
               suppliers to the printing industry, academic institutions, and EPA.  The trade associations
               alone that participated in the Project represent over 1,600 flexographic printers and ink
               manufacturers. (The members of the Steering and Technical Committees are listed in the
               front of this book.)   Also,  to ensure  substantial read-world technical expertise, other
               participants were brought into the Project, including the printing program at Western
               Michigan University, the University of Tennessee's Center for Clean Products and Clean
               Technologies, the Industrial Technology Institute, and a number of technical experts at the
               U.S. Environmental Protection Agency.                               -

               The Project Partners understood that many small fleography companies rarely have the time
               or resources to gather in-depth information on safer and lower-risk alternatives to current
               materials and processes. Therefore, they set a goal of providing information that could help
               flexographers make their businesses more environmentally sound, safer for workers and the
               public, and more cost-effective.
                                              1-1

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CHAPTER 1
INTRODUCTION TO THE CTSA
               The Partners decided to make the Project a comparative assessment of flexographic inks,
               since inks constitute a major cost category and have a variety of environmental and health
               issues. Factors that were considered in selecting this research topic included awareness of
               health issues related to chemicals used in traditional  solvent-based inks, growth of the
               flexographic industry,  significant recent advances  in flexographic technology,  and
               increasing attention to regulations. They decided to particularly study printing of inks on
               film substrates because there was less documentation about some ink systems on these
               substrates and because this area presented technical and environmental challenges, including
               air regulations related to pollutant emissions, worker health and safety issues, and some
               hazardous waste concerns. The Partners  decided to run 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.

               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 ease 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. (See Chapter 2 for an overview
               of the ink systems that were analyzed.)

               The research compared more than 100 flexographic ink chemicals, based upon actual
               printing of the inks on three substrates. The research 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. The industry Partners in the Project felt that a  combination of
               production results from actual printing facilities in addition to laboratory research would
               help give printers a more comprehensive perspective. As with any "real-world" research, the
               Partners were confronted with situations that they could not have anticipated. Occasionally
               this required modifications of the methodology specifications. (Such situations are noted in
               relevant sections of the document.) Therefore, the  results of the research are both more
               extensive and less comparative than they might have been if a smaller set of variables had
               been chosen.

               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 printing 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 types of existing information to
                      analyze the hazards and risks of the ink chemicals and ink systems.
                                               1-2

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CHAPTER
INTRODUCTION TO THE CTSA
              The methodology is described in more detail in the relevant sections of this document. For
              example, the methodology for the performance demonstrations and laboratory runs can be
              found in Chapter 4 (Performance) and its appendices.
1.2 WHAT RESULTS DID THE PROJECT GENERATE?

              Finally, all the information about methodology and findings  was combined into this
              document,  which is called a Cleaner Technologies Substitutes Assessment, or CTSA  The
              foundation for this CTSA was 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 industry include these aspects in business decisions, and  thereby to improve  both
              private business and the larger environment. Although this CTSA focuses on flexographic
              inks, the approach that was used is transferable to other business decisions.

              In addition to the CTSA, the Project has developed a number of other documents and tools
              to help printers, ink formulators, technical assistance providers, and others interested in the
              findings. Case studies, a summary booklet of the CTSA results, a fact sheet that describes
              the Flexography Project's goals and products, and many other materials can be obtained
              from the DfE website (www.epa.gov/dfe).

1.3 WHO WILL BENEFIT FROM THIS RESEARCH?     .

              The CTSA documents what is arguably the most detailed analysis ever performed on
              flexographic ink chemicals. Small printers, ink formulators, 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 using fewer
              chemicals  that pose risks to human health and the environment. Printers can identify
              formulations and ink systems that may print equally well for specific purposes while posing
              fewer  safety,  health, or environmental concerns as well as  possibly easing  regulatory
              compliance. 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  the  most

                                              -,.3

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CHAPTER 1
INTRODUCTION TO THE CTSA
              comprehensive or current information about flexographic printers, inks in general, or results
              on other substrates. On the other hand, although many of the findings are specific to the
              flexographic sector, the systematic process of investigation and much of the data about
              chemicals will be valuable to many other printing professionals.
1.4 OVERVIEW OF THE CTSA

              This CTSA consists of two volumes. Volume I contains the text, and Volume H 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 may help readers locate particular types of information quickly.

              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 this document.

              Results and Implications of the Research: Readers who want a quick overview of the most
              important findings of the research should begin by reading the Executive Summary, 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 Overview: A table of contents and overview are provided in a box at the beginning
              of each chapter to help readers quickly identify and locate relevant information.

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

              Performance Information: The research examined 45  ink formulations. A total of 18
              performance tests were chosen and run, combining performance demonstrations at volunteer
              printing facilities and laboratory runs and analysis.  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 facility where
              performance demonstrations were conducted.

              Environmental Information: Chapter 3 (Risk) discusses  the  environmental issues,
              including hazards to aquatic life, exposure of printing industry employees and the general
              public, and risk concerns that were identified in the research.  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) discussed federal environmental regulations that are relevant to the
              flexographic printing industry.
                                              1-4

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CHAPTER 1
INTRODUCTION TO THE CTSA
              Cost Information: Different aspects of cost are discussed in Chapter 5 (Cost), as well as
              in Chapter 8 (Choosing Among Ink Technologies).

              Supplementary Information: References cited in the text are numbered and listed at the
              end of each chapter. The Appendices, which are provided in Volume 2, contain a great
              quantity of background information and research data 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.
                                             1-5

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CHAPTER 1
INTRODUCTION TO THE CTSA
                                 This page is intentionally blank.
                                       1-6

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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 Systems	•	2'3
       Ink Components ...	:	2'3


2.2  MARKET PROFILE OF THE FLEXOGRAPHIC PRINTING INDUSTRY	2-6
       Trends in the Flexographic Printing Industry	2-9
       Inks Used in Flexographic Printing		•	• • • • 2'10

2.3  FEDERAL REGULATIONS	•		. 2-12
       Clean Air Act	•••••• 2-1
       Resource Conservation and Recovery Act	2-15
       Toxic Substances Control Act	•	2'18
       Clean Water Act	2'22
       Safe Drinking Water Act	2'25
       Comprehensive Environmental Response, Compensation, and Liability Act		2-25
       Emergency Planning and Community Right-to-Know Act	2-26
       Occupational Safety and Health Act	2'27

2.4 PROCESS SAFETY	2'35
       Reactivity, Flammability, Ignitability, and Corrosivity of Flexographic Ink Chemicals	2-35
       Process Safety Concerns	2'38

REFERENCES	• • • •	2"41
                                        2-1

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CHAPTER 2
OVERVIEW OF FLEXOGRAPHIC PRINTING
                                  CHAPTER OVERVIEW

 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 f lexographic inks 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 them. This chapter
 presents an overview of flexographic inks, the printing process used, some significant market trends,
 information about federal regulations that relate to the flexographic printing industry, and safety issues related
 to the printing process. The overview  provides some context for interpreting the specific  research that
 follows later in this document.


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

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

 FEDERAL REGULATIONS: Section 2.3 provides an overview of  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. Also, this is not an official
 guidance document and should not be used to determine regulatory requirements.

 PROCESS SAFETY: Section 2.4 describes safety issues related to the flexographic printing process.
                                            2-2

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CHAPTER 2
                                                     OVERVIEW OF FLEXOGRAPH1C PRINTING
2.1 INTRODUCTION TO FLEXOGRAPHIC INKS

       Ink Systems

               Three primary flexographic ink systems were in use when the CTS A was designed, and they
               differ primarily in the method of drying the ink and in the medium for delivering the ink.
               Solvent-based and water-based inks are dried using evaporation, whereas UV-cured inks are
              'cured by chemical reactions. Solvent-based  inks use solvents as the delivery medium,
               whereas water-based inks use water instead of or in addition to solvents. UV-cured inks do
               not require a medium per se; they utilize liquid components of the inks that are chemically
               cured during the printing process. Each ink system is briefly described below.

               Solvent-based Inks
               Solvent-based inks are widely used in many flexographic printing processes. They were the
               first printing inks to be available commercially. Historically they have been very popular
               because they dry quickly, perform well, and allow printers a wide choice of products.
               Solvent-based inks are generally considered to be the industry standard for ease of use and
               quality of printing.  The solvents in these inks, however, are primarily volatile organic  •
               compounds (VOCs), which have caused concerns for health and safety, as they are usually
               very flammable  and 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
               Water-based inks were first used to print kraft linerboard for decorative corrugated cartons,
               and later developed new applications because of environmental concerns and regulations
               related to use of solvent-based inks. The primary solvent in water-based inks is water, but
               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.

         Ink Components                                                                   '

               A functional flexographic ink must exhibit several qualities.  It needs to 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 chemicals,
                abrasion, and extreme temperatures. Finally, it needs to produce a consistent finish.
                                               2-3

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CHAPTER 2
                                                      OVERVIEW OF FLEXOGRAPHIC PRINTING
               Different types of ingredients contribute to a successful ink.  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 include 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 of 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 dissolve into the liquid solution.
              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 damaged 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. 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 cause ink to adhere to the substrate, disperse the pigment, and provide gloss to the
              finished coating.  They also can impart differing degrees of flexibility, scuff resistance,
              cohesive strength, block resistance, and compatibility with the printing plates.  Resins are
              solid compounds that are soluble in  the solvent and often have complex molecular
              structures.  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,

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OVERVIEW OF FLEXOGRAPH1C PRINTING
              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 photoinitiatdrs. 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
                            •R -f CH, = CH - COOR -» -[CH2 - CR - COOR]n
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2.2 MARKET PROFILE OF THE FLEXOGRAPHIC PRINTING INDUSTRY

              Flexographic printing was developed primarily to print materials used in packaging. Because
              the early quality of flexography was not high, the process was used mainly as a way to print
              low-quality corrugated materials. However, a series of technical advances in flexography
              starting in the late 1980s resulted in dramatic quality improvements and rapid expansion in
              the use of flexography to print high-quality  packaging materials. During  the  1990s,
              flexography experienced an average annual growth rate of about 6%,' which was above the
              average for the printing industry.

              This large market depends upon a relatively small number of businesses. The last Census
              recorded 914 commercial printing  establishments in which flexographic printing was the
              primary print process. These facilities employed more than 30 thousand employees and had
              a payroll exceeding $ 1 billion.2 However, many more printing facilities — a total of about
              2,300 nationally — operate flexographic presses in addition to other printing equipment.3

              Flexographic facilities are typically small, and over 80% have fewer than 50 employees.4
              The smallest facilities tend to focus exclusively on flexographic printing and predominantly
              operate narrow-web presses, whereas larger facilities often include converting and wide-web
              presses. Historically, flexographic printing facilities have been concentrated in the Midwest.
              Although these states continue to dominate,  more facilities have opened in California and
              Texas as the industry has expanded. The majority of flexographic facilities are located in
              California, Florida, Illinois, Missouri, New Jersey, New York, North Carolina, Ohio, Texas,
              and Wisconsin.7

              Despite the small size of most individual flexographic printing companies, the industry
              overall used more than 513 million pounds of ink in 2000.8 Thus, although the majority of
              flexographic facilities are small, combined they have the potential to make  a major
              environmental impact. Also, for several years the industry has seen a trend of mergers and
              acquisitions. As these cause firms to grow in size, ink choices made by individual firms can
              have an increasingly significant effect.

              The flexographic industry is embedded within a number of different industrial codes and is
              not clearly defined by any single one. Table  2.1 shows the U.S. Census Bureau's industry
              classifications  for aspects of the flexographic industry sector, as well  as the estimated
              revenues  attributed to each code. The table provides  information for two  industry
              classification systems. In 1997, the North American Industry Classification System (NAICS)
              replaced the Standard Industrial Classification (SIC) system as the standard classification
              system for the United States, Canada, and Mexico. Although businesses now report required
              information under NAICS codes, some information is available using SIC codes.
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                   Table 2.1 Industrial Codes Related to Flexographic Printing
NAICS
code
322
322221
322222
322223
322224
322225
323
323112
325
325910
326
3261 1 1
326112
1997 NAICS U.S.
Description
Value of
Shioments*
SIC code
1987 SIC U.S. Description
Converted Paper Product 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
$1 .6 billion
$12 billion
$0.5 billion
$2.8 billion
$1.5 billion
2671**
2672
2679**
2673**
2674
3497**
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 Cpated 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)
Printing and Related Support Activities
Commercial Flexographic
Printing
$5.0 billion
2759**
2771**
2782**
Commercial Printing, Not Elsewhere
Classified (flexographic printing)
Greeting Cards (flexographic printing of
greeting cards)
Blankbooks, Loose-leaf Binders and
Devices (flexographic printing of
checkbooks)
Chemical Manufacturing .
Printing Ink Manufacturing
$4.7 billion
2893**
Bronze Ink, Flexographic Ink, Gold Ink,
Gravure Ink, Letterpress Ink,
Lithographic Inc, Offset Ink, Printing
Ink: base or unfinished, Screen
Process Ink, Ink — duplicating
Plastics Product Manufacturing
Unsupported Plastics Bag
Manufacturing
Unsupported Plastics
Packaging Film and Sheet
Manufacturing
$7.8 billion
$4.3 billion
2673**
2671**
Plastics, Foil, and Coated Paper Bags
(plastic bags)
Packaging Paper and Plastics Film,
Coated and Laminated (plastics
packaging film and sheet)
  *Source: U.S. Census, 1999 Survey of Manufactures
  ** This was part of a 1987 Standard Industrial Classification (SIC) category.
               By the year 2000 flexographic printing accounted for nearly a quarter of all U.S. printing
               revenues, including almost three-fourths of printing for the $ 108 billion packaging market.9
               Packaging includes many types of products that commonly utilize flexography (Figure 2.1).
               These product categories are described briefly in the paragraphs that follow.
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                Figure 2.1: Primary Types of Packaging Manufactured in the United States, 2000
                                               (by % of sales dollars)
                                other (including glass
                                    and cans)
                                      32%
                                   labels and tags
                                       9%
            corrugated and
          preprinted containers
                27%,
           flexible film packaging
                 19%
                                                  folding cartons
                                                     13%
               Source: Dowdell, William C. "Flexo 2001." Flexo, January 2001.
               Data represent production across all printing technologies.

               Corrugated and Preprinted 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. Corrugated materials are characterized by irregularities, which in the past
               made it difficult or expensive to print high-quality graphics directly on the 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, technical advances allowed flexography to print directly on corrugated
               substrates with high-quality results, thereby increasing the use of corrugated containers. This
               technological advance  led to expansion  of the  market for corrugated and preprinted
               containers. By 2000 sales volume of these materials totaled $29 billion, or about 27% of the
               total market for  packaging.10 Over  the long term, flexographic printing of corrugated
               materials should continue to grow because the use of complex and colorful graphics in this
               market is expected to increase.

               Flexible Packaging
               Flexible packaging is a package or part of a package with a thickness of ten millimeters or
               less whose shape can be readily changed.  Most printing of flexible packaging is done by
               flexographic processes.  The demand for flexible packaging is driven by food products
               (particularly fresh produce and snackfoods), pharmaceutical products, surgical and medical
               equipment, agricultural products, industrial chemicals, household goods, garden supplies,
               pet food, cosmetics, and retail merchandise.

               Flexible packaging accounts for about a fifth of the  total packaging market." In  199£
               flexible packaging employed 375,000 people. Food products alone account for about half
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               of flexible packaging; medical and pharmaceutical products constitute another 25%.n
               Flexography prints about 85 % of all flexible packaging.13 In 2000, flexographic printing of
               flexible packaging totaled over $20 billion.14

               Folding Cartons
               Folding cartons differ from corrugated containers in the type of substrate used (usually a
               high-quality, smooth paperboard), in the generally fine quality of the graphics, and in the
               types of inks used. Folding cartons are used in a variety of applications requiring colorful,
               complex graphics (foods, personal care products, etc.). About a fifth of all folding cartons
               are printed with flexography. Folding cartons accounted for $14 billion of revenue in 2000
               — about 13% of the total packaging market. Sales of folding cartons grew by about 10% per
               year during much of the 1990s.15

               Tags and Labels
               The tag and label market includes many consumer applications requiring high-quality
               graphics, such as hair care and pharmaceutical products.16 Flexography dominates the
               printing of tags and labels. This segment had revenues of $10.2 billion in 2000, or about 9%
               of the total packaging market.17

        Trends in the Flexographic  Printing Industry

               In the past decade flexographic printing has successfully penetrated new printing markets
               and has grown substantially. Several factors are important in this growth:
                   «   Improved quality of flexographic printing: Early print quality of flexography
                       was typically inferior to that of lithography and gravure.  Many technological
                       advances have greatly improved the quality of flexography,  leading to greater use
                       of color and  more sophisticated and colorful design. These improvements have
                       resulted in increased acceptance of flexography by print buyers.
                   •   Increased use of flexible packaging: General economic growth, increasing market
                       segmentation, and technical improvements in flexible packaging and flexographic
                       printing quality have spurred a shift from rigid to soft packaging as well as a trend
                       toward increasing the alternatives available within a product line. For example,
                       potato chip manufacturers may market a variety of product "segments" such as
                       "light", "low salt", arid "barbecue", where there once was only one product. These
                       trends have increased the use of flexography in packaging of fresh produce, drugs,
                       surgical and  medical products, snack foods, and agricultural products/industrial
                       chemicals.18  These same trends have also led to more  applications for pressure-
                       sensitive labels, which in turn expands opportunities for flexographic printing.
                   •   Shorter printing runs and faster turnaround times: Flexography is technically
                       well positioned to respond to demands for shorter, more  segmented, and more
                       frequent runs.
                   •   UV-cured printing in narrow-web markets: The entry of UV-cured inks into
                       narrow-web  flexographic printing of folding cartons, labels, and tags provided an
                       economical way to produce high-quality small runs.19

                Other general factors that are expected  to influence the future of flexographic printing
                include the following:
                    •   The general  economic climate slowed significantly during 2000.
                    •   Competition, especially in terms of globalization of trade  and imports,  takes on
                       added importance in a more sluggish economy.
                    •   Prices of some raw materials have increased.

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                  •   Uses for electronic/digital technologies have expanded dramatically.
                  •   Industry consolidation has been extremely active  in recent years (although it
                      appears to have slowed in 200020).
                  •   Concerns about the environmental and health impacts of chemical use and printing
                      processes continue to be of major interest nationally.

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

       Inks Used in Flexographic Printing

               The global ink industry had revenues of more than $12.7 billion .in 2000, with the U.S.
               representing the largest share.21 U.S. printing ink sales in 1999 totaled $4.7 billion.22 More
               than 550 U.S. firms manufacture printing inks,23 employing about 14,000 workers.24

               Due to the substantial growth of the flexographic printing industry throughout the 1990s,
               flexographic inks have been the fastest-growing ink segment, with sales of half a billion
               pounds and over $900 million in 200025. Almost three-quarters of all flexographic inks
               ($648 million) were used in flexible packaging.26

               Water-based inks account for more than half of all printing ink revenues27 and for about 65 %
               of inks used (Figure 2.2). Water-based inks are  used for many flexographically printed
               products, including virtually all newsprint,28 a third of all printed film,29 and about half of
               all products printed on wide-web presses.30 Solvent-based inks account for 35% of inks used
               by weight (Figure 2.2).

               Over the past decade or so, UV-cured inks have established a strong foothold in narrow-web
               labels and tags. During the 1990s UV-cured inks showed  technological improvements
               (including a decrease in the amount of photoinitiator needed, which is the most expensive
               component) and market growth, especially in the narrow-web field. These factors caused the
               price of UV inks to drop, so that by 1998 UV-cured inks accounted for at least $85 million
               in ink consumption,31 and their use grew by 15% in 2000.32
                     Figure 2.2: Breakdown of Flexo Ink Market (in millions of wet pounds)
                         EH Solvent-
                          based inks
                             35%
                                                        0 Water-based
                                                             inks
                                                             65%
                       Source: Hess, Jen. Ink World. February 2001. "2001 Flexo Report."
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               The United States exported about 115 million pounds of printing ink in 1998, about a 10%
               increase over 1997. However, exports to Mexico grew by 76.4% during the same period,33
               perhaps because  of  increased trade  opportunities  made  available  through  the North
               American Free Trade Agreement. Exports of black flexographic ink dropped by about 50%
               between 1998 and 1999, while exports of colored flexographic ink increased by 16%. The
               United States also imports printing ink — about 44 million pounds in 1998.34 In 1999,
               however, imports of black ink fell by more than 50%, and imports of colored  ink fell by
               25%.35

               In addition to the trends and events affecting the flexographic sector overall, several factors
               have specifically affected flexographic inks, and may continue to exert an influence in the
               future:
                  •   Concerns about environmental hazards and potential risk concerns of solvent-based
                      inks, as well as regulatory issues, led to improvements in the printability of water-
                      based inks and to expanded applications for their use.
                  •   The technology to remove VOCs and other harmful chemicals from solvent-based
                      and water-based ink emissions has improved markedly.
                  •   Prices of raw materials used for inks began to rise dramatically in the  mid-1990s
                      and accounted for more than half of the value of shipments  in 1995 and 1996.36
                      Faced with increasing raw material costs and aggressive pricing strategies by the
                      largest manufacturers, many manufacturers began to experience decreased rates of
                      sales growth sometime during the second half of the 1990s.
                  •   In 2000, the general economy began to show early signs of a slump. A decrease in
                      advertising and marketing activity negatively affected the printing of packaging and
                      sales of flexographic inks in 2000 and beyond.37 As a result of this more general
                      decline in industries that utilize the majority of flexographic inks, the sales and
                      profits of the printing inks industry increased only marginally in 2000.38 According
                      to NAPIM, the growth experienced by some manufacturers was balanced by the
                      losses at others, so that overall there was very little change.39
                  •   Newer developments have improved UV technology for potential use in packaging
                      that has direct contact with food and medicine. Cationic  inks, because they cure
                      more thoroughly, could play a significant role in expanding these markets.40 These
                      factors may help UV-cured inks to increase market share and make inroads into
                      wide-web printing.
                   •   During the 1990s the printing ink industry experienced  a very active period of
                      mergers and acquisitions. Because the largest companies now control a much larger
                      portion of the total ink market, Sun Chemical and Flint alone accounted for more
                      than half of all ink sales worldwide in 2000 (Table 2.2). Sun Chemical, for example,
                      acquired three companies in 2000, five in 1999, and three in  1998.41
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                           Table 2.2 Leading Ink Manufacturers Worldwide in 2000
Rank
1
2
3
4
5
6
7
8
9
10
11
12
12
14
15
16
16
16
19
20
Company
Sun Chemical
Flint Ink
INX International
Color Converting
Wikoff Color
Toyo Ink America
Superior
SICPA Industries
Nazdar
Van Son
Central Ink
Sericol
Siegwerk
Color Resolutions
Braden Sutphin Ink
DuPont
Environmental Inks
Handschy
Akzo Nobel Inks
Ink Systems
Ink Sales
($ million)
$3,300
$i,400
$300
$90
$81
$79
$75
$68
$65
$64
$56
$50
, $50
$45
$43
$40
$40
$40
$36
$32
                     Source: Ink World, April 2001, The Top 20 Report."
                     (www.inkworldmagazine.com/top20.htm).

              The future of the fiexographic ink market may depend both upon the overall economic
              picture and continued advances in printability. Continued improvements in print quality
              could result in flexography taking a larger share of the overall printing market as well as
              continuing to print more packaging and cartons for new high-quality applications.42
23 FEDERAL REGULATIONS
              This section describes federal environmental, health, and safety regulations that may affect
              the  use  of fiexographic  printing chemicals and  inks. Regulatory requirements  have
              significant effects oncosts, equipment requirements, overhead, and owner/operator liability.

              Fiexographic 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)
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                  •   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 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 may be
               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
               Section 112 of the  CAA  requires EPA to establish National Emissions Standards  for
               Hazardous Air Pollutants (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. EPA has promulgated NESHAPs for the printing
               and publishing industry, which cover wide-web flexography and rotogravure. NESHAPs
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               require regulated sources to meet emission standards which represent the maximum degree
               of reduction in emissions that EPA determines is achievable for sources in 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:
                  •   5% of.the organic3 HAPs
                  •   4% of the mass of inks, coatings, varnishes, adhesives, primers, solvents, reducers,
                      thinners, and other materials
                  •   20% 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.  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 in 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).

               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. These permits 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. 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
       * Organic HAPs are a subset of VOCs that excludes certain inorganic compounds.
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               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
Ammonia3
Butyl carbitol
Ethyl carbitol
Styrene
112(b)
Hazardous Air Pollutant

•
•
•
112(r)
Risk Management Plan
•



               ' In concentrations greater than 20%.
        Resource Conservation and Recovery Act

               Hazardous wastes must be treated, stored, and disposed of only by approved methods. 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
               Section 2.4, Process.Safety Assessment, for an explanation of characteristic wastes.)

                   •   RCRA hazardous wastes are categorized by codes.  Categories most relevant to the
                      printing industry follow:
                   •   Characteristic wastes are indicated by a "D" code.
                   •   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.
                                              2-15

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                       Table 2.7 CTSA Chemicals Regulated Under RCRA
Chemical
Barium
Ethyl acetate
Ignitable solvent-based inks
Isobutanol
D Waste Code3
D005
D001
D001
D001
F Waste Code

F003

F005
U Waste Code

U112

U140
                a Characteristic wastes (D code) are regulated as hazardous wastes when they exhibit
                the relevant characteristic (e.g., ignitable 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, recordkeeping, and contingency plans. See Table 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.
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                             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
Conditionally
Exempt Small
Quantity Generator
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)]
Small Quantity
Generator
Required
<;6,000 kg (-13,200
Ibs.)
<: 180 days or s270.
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
Large Quantity
Generator
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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CHAPTER 2
                                                     OVERVIEW OF FLEXCGRAPHIC PRINTING
       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 fprmulators 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.

              Sections
              Section 5 requires manufacturers and importers of new chemical substances (substances not
              previously listed on the TSCA Inventory) to submit a Premanufacture 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.
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                                                     OVERVIEW OF FLEXOGRAPH1C PRINTING
                            TSCA 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
nor triethylene glycol dimethacryiate 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 category for ecotoxicity.
               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 in the Code of Federal
               Regulations (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,

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                                                     OVERVIEW OF FLEXOGRAPHIC PRINTING
              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.

              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.
                                            2-20

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CHAPTER 2
OVERVIEW OF FLEXOGRAPH1G PRINTING
The Ch(
The Chemi
Environmen
chemicals h
risks. Three
• corr
• con
• colli
The ultimate
make inforrr
EPA challen
for which ba
into, the US
Rule data).
testing com
;mical Right-to-Know Initiative and the High Production Volume Challenge Program
sal Right-to-Know (RTK) Initiative was- launched in 1998 in response to studies by the
tal Defense Fund, the American Chemistry Council, and EPA that found that most commercial
ave very little, if any, toxicity information on which to make sound judgements about potential
} key components of the RTK Initiative are to:
iplete baseline testing on the most widely used commercial chemicals
duct extensive testing on chemicals to which children are disproportionately exposed
set TRI release information on high-priority PBT (persistent, bioaccumulative, toxic) chemicals
5 goal of the RTK Initiative is to make this information publicly available so that the public can
led choices and decisions about their health and local environment.
ged industry to voluntarily undertake testing on 2,800 HPV (high production volume) chemicals
seline data are not available. HPV chemicals were defined as those manufactured in, or imported
in amounts equal to or exceeding 1 million pounds per year (based on 1990 Inventory Update
Many of the HPV chemicals have been sponsored by industry, and EPA hopes to have all HPV
Dieted by 2004. The following chemicals in the Flexo CTSA are in the HPV challenge.
Table 2.7 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
C.I. Pigment Yellow 74
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



                                   2-21

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                             Table 2.8 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
"hS-Hexanediol
diacrylate
Hydroxypropyl acrylate
Isobutanol
Isopropanol
Propylene glycol
methyl ether
Silicone oil
Styrene
Urea
Section 4

•
•

•
•

•
•


•





Section 8(a)
PAIR
•


•
•
•
•
•
•
•
•
•
•
•
•
•
•
Section 8(d)



•
•
•
•
•
•


•
•
•
•


Section 12(b)

•
•

•
•

•
•


•





       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 regional or municipal sewer systems, which also are known as
              Publicly Operated Treatment Works (POTWs).
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               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
               (CWA section 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 section 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
                                              2-23

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OVERVIEW OF FLEXOGRAPHIC PRINTING
              as local limits. General prohibitions involve pollutants that may not be introduced by any
              POTW users. These include the following materials:

                  •   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 inhibitbiological 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 by 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 2.9) 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
                      above 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., dioctyl sulfosuccinate,
                      sodium salt) — is found in the inks used in this CTSA.
                              Table 2.9 CTSA Chemicals Regulated Under CWA
Chemical
Ammonia
Ammonium hydroxide
Butyl acetate
Styrene
Surfactants (e.g., dioctyl sulfosuccinate,
sodium salt)
Hazardous
Substance RQ
(Ibs.)
100
1000
5000
1000

Priority Pollutant




•
                                             2-24

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CHAPTER 2
                                                    OVERVIEW OF FLEXOGRAPHIC PRINTING
       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 2.10.
                             Table 2.10 CTSA Chemicals Regulated Under CERCLA
                Chemical
RQ (Ibs.)
                Ammonia
                                                                     100
                Ammonium hydroxide
                                                                    1000
                 Butyl acetate
                                                                    5000
                 Butyl carbitol3
                 Dicyclohexyl phthalate"
                 Ethyl acetate
                                                                    5000
                 Ethyl carbitol3
                 Isobutanol
                                                                    5000
                 atvrene
                                                                     1000
                 1 This chemical is part of the glycol ethers broad category; a reportable quantity is not
                 listed.
                 b This chemical is part of the phthalate esters broad category; a reportable quantity is
                 not listed.
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CHAPTER 2
                                                     OVERVIEW OF FLEXOGRAPH 1C PRINTING
       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 Toxics 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 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, whichever is lower, for an EHS. The EHS used hi
              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 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 Ze 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 2.11 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
              chemicals8 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 (PBTs)in the environment. Although none of the chemicals researched for the
        Flexography Project are PBTs, other flexographic chemicals could be. Information about PBTs can be
        obtained by contacting the RCRA, Superfund, and EPCRA Hotline at the number and website listed at the
        end of this section.
                                            2-26

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OVERVIEW OF FLEXOGRAPHIC PRINTING
                             Table 2.11 CTSA Chemicals Regulated Under EPCRA
Chemical
Ammonia
Barium
Butyl carbitol
Ethyl carbitol
lsopropanolb
^tvrene
EPCRA 302
Extremely Hazardous
Substances
•





EPCRA 31 3
TRI Chemicals
•a
•
•
•
•
•
                "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 established by
                      OSHA, 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.

               OSHA regulations  also  require the use of personal protection equipment  for specific
               situations, such as 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
               must develop a plan to ensure that the energy source of a machine is locked out (with a
                                              2-27

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OVERVIEW OF FLEXOGRAPHIC PRINTING
              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.

              OSHA also regulates 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.

              Many OSHA regulations are concerned with workplace processes. Section 2.4 of this
              chapter (Process Safety) deals with these issues as well.
                                             2-28

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CHAPTER 2
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              Table 2.12 Flexography Federal Regulations Chemical Worksheet
Regulation
Clean Air Act (CAA)
1 1 2(b) Hazardous Air Pollutant
1 1 2(r) Risk Management Plan
Affected Chemicals

Butyl carbitol
Ethyl carbitol
Styrene
Ammonia (in concentrations greater than 20%)
Resource Conservation and Recovery Act (RCRA)
Characteristic Wastes (D Wastes)
Non-specific Source Wastes (F Wastes)
Specific Unused Chemicals (U Wastes)
Toxic Substances Control Act (TSCA)
Section 4
Section 8(a) PAIR
Barium (D005)
Ethyl acetate (D001)
Ignitable solvent-based inks (D001)
Isobutanol (D001 )
Any other waste that exhibits ignitability,
corrosivity, reactivity, or toxicity as defined by
RCRA
Ethyl acetate (F003)
Isobutanol (F005)
Ethyl acetate (U1 12)
Isobutanol (U1 40)

Butyl acetate
Butyl carbitol
Dipropylene glycoi methyl ether
Ethyl acetate
2-Ethylhexyl diphenyl phosphate
n-Heptane
Isobutanol
Ammonia
Dicyclohexyl phthalate
Dipropylene glycoi methyl ether
Ethyl acetate
Ethyl carbitol
2-Ethylhexyl diphenyl phosphate
n-Heptane
1 ,6 Hexanediol diacrylate
Hydroxypropyl acrylate
Isobutanol
Isopropanol
Propylene glycoi methyl ether
Siiicone oil
Styrene
Urea
                                        2-29

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CHAPTER 2
OVERVIEW OF FLEXOGRAPHIC PRINTING
         Table 2.12 Flexography Federal Regulations Chemical Worksheet (continued)
Regulation
Section 8(d)
Section 12(b)
Clean Water Act (CWA)
Hazardous Substances
(Reportable Quantities)
Priority Pollutants
Safe Drinking Water Act (SDWA)
National Primary Drinking Water
Regulations
Affected Chemicals
Dicyclohexyl phthalate
Dipropylene glycol methyl ether
Ethyl acetate
Ethyl carbitol
2-Ethylhexyl diphenyl phosphate
n-Heptane
Isobutanol
Isopropanol
Propylene glycol methyl ether
Silicone oil
Butyl acetate
Butyl carbitol
Dipropylene glycol methyl ether
Ethyl acetate
2-Ethylhexyl diphenyl phosphate
n-Heptane
Isobutanol

Ammonia (1 00 Ibs.)
Ammonium hydroxide (1000 Ibs.)
Butyl acetate (5000 Ibs.)
Styrene (1000 Ibs.)
Surfactants

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.)
                                        2-30

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CHAPTER 2
     OVERVIEW OF FLEXOGRAPH1C PRINTING
         Table 2.12  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
Propyj acetate
Styrene
                                          2-31

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CHAPTER 2	     OVERVIEW OF FLEXOGRAPHIC PRINTING

                    Additional Information on Printing-Related Regulations
GENERAL INFORMATION

Printers' National Environmental Assistance Center (PNEAC)
A website with links to compliance assistance and pollution prevention information and state-specific
requirements
              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 National Service Center for Environmental
Publications. Ask for Document EPA 744-B-94-001.
              Telephone: 800-490-9198 or 513-489-8190
              Website: www.epa.gov/ncepihom/ordering.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)
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

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,
Superfund & EPCRA Hotline. Ask for Document EPA 530-K-97-007.

Understanding the Hazardous Waste Rules: A Handbook for Small Businesses, 1996 Update
A manual  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
how 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.
                                           2-32

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CHAPTERS
OVERVIEW OF FLEXOGRAPH1C PRINTING
 NFORMATION ABOUT THE TOXIC SUBSTANCES CONTROL ACT

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

 FORMATION ABOUT THE CLEAN WATER ACT

EPA's Office of Water, especially the Office of Wastewater Management, can be contacted for information
 m Clean Water Act provisions that relate to the printing industry.
             Telephone: 202-564-5700
             Website: www.epa.gov/ow

 NFORMATION 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
  lOMPENSATION, 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 th
 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 b
 the Office of Pollution Prevention and Toxics.
              Website: www.epa.gov/tri

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CHAPTER 2
                                               OVERVIEW OF FLEXOGRAPHIC PRINTING
The RCRA, Super-fund & 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/   	
                                       2-34

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 CHAPTER 2
OVERVIEW OF FLEXOGRAPHIC PRINTING
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 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, Flammability, Ignitability, and Corrosivity of Flexographic Ink Chemicals

                Table 2.13 lists four safety hazard factors for the nine ink product lines that were tested in
                the performance demonstrations, and Table 2.14 summarizes the safety hazards by ink
                system. (Where available, the reactivity and flammability values were extracted  directly
                from Section One of the 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 in 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.

                    4 — materials that, in themselves,  are readily capable of detonation, explosive
                    decomposition, or explosive  reaction .at normal temperatures and  pressures. If a
                                                2-35

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CHAPTER 2  	    '       	         OVERVIEW OF FLEXOGRAPHIC PRINTING

                  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 Q 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).43 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.44 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.
                                             2-36

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CHAPTER 2
OVERVIEW OF FLEXOGRAPH1C PRINTING
                  Table 2.13 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
b
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 2.14 Summary of Safety Hazard Factors by Ink System

Solvent-based
Water-based
UV-cured
Reactivity
0
0 '
o
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.
                                                2-37

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CHAPTER 2
OVERVIEW OF FLEXOGRAPHIC PRINTING
              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.

      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 arid 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, OSHA' s 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 staff or 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 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
              hi 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
                 •   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
                                            2-38

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CHAPTER 2
OVERVIEW OF FLEXOGRAPH1C PRINTING
                  •   emergency equipment information, such as the location of fire extinguishers and
                      spill control kits.45

               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.46 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.47  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 arid 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 or 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
               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 hi an  easily
               accessible location in the vicinity of the press room.

               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).
                                               2-39

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CHAPTER 2
OVERVIEW OF FLEXOGRAPHIC PRINTING
               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, or that may be absorbed dermally.  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.
                                             2-40

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 CHAPTER 2
                                                         OVERVIEW OF FLEXOGRAPH1C PRINTING
REFERENCES

 1.      Flexo, December 199.8. "1999 Industry Forecasts," p. .32.

 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.      U.S. Department of Commerce.  1999. op.  cit.                       .              .            .

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

 8.      National Association of Printing Ink Manufacturers. 2001 State of the Industry Report, p 4 (Printing Ink
         2000 Market).

 9.      Dowdell, William C.January 2001. "Flexo 2001." Flexo.

  10.     Dowdell, op. cit.                                            .               •           .

  11.     Dowdell, op. cit.

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

  13.      National Association of Printing Ink Manufacturers (NAPIM). 2007 State of the Industry Report.

  14.     Dowdell, op. cit.

  15.     Dowdell, op. cit.

  16.     Flexographic Technical Association (FTA).  1995.  op. cJt.vol 5, p 12.

  17.     Dowdell, op. cit.

  18.     FPA. 1998. op. cit.

  19.     Dowdell, op. cit.

  20.     NAPIM, 2001, op cit.

  21.     "Market introduction." Ink World Magazine (www.inkworldmagazine.com/medial .pdf).

  22.     U. S. Census. May 30.2001. Annual Survey of Manufactures. Table 2: Statistics for Industry Groups and
          Industries — 1999 and Earlier  Years..

  23.     U.S. Census. June 25, 2001. Manufacturing Subject Series, General Summary—Industry Statistics. Table
          1—Id: Industry Statistics for Industry Groups and Industries: 1997.

   24.     U. S. Census. May 30.2001. op. cit.

   25.     NAPIM, 2001, op cit.

   	                                     2-41

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 CHAPTER 2
                                                          OVERVIEW OF FLEXOGRAPHIC PRINTING
 26.

 27.

 28.

 29.

 30.

 31.

 32.

 33.

 34.

 35.

 36.

 37.


 38.

 39.

 40.

 41.

 42.

 43.


 44.


45.


46.

47.
 Flexo, February 1999. op. cit.

 Flexo, February 1999, op. cit.

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

 Flexo, February 1999. op. cit.

 Ink World. June 1999. op. cit.

 Flexo, February 1999. op. cit.

 Hess, Jen. Ink World. February 2001. "2001 Flexo Report."

 NAPIM, 1999.  op. cit.

 NAPIM, 1999.  op. cit.

 NAPIM, 1999.  op. cit.

 NAPIM, 1999.  op. cit.

 Savastano, David, ed. October 2001. "Publication Ink Market." Ink World Magazine
 (www.inkworldmagazine.com/oct01 l.htm).

 Savastano, David. 2001. op. cit.

 NAPIM, 2001, op cit.

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

 NAPIM, 2000 State of the Industry Report.

 Hess, Jen. 2001. op. cit.

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

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

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

Flexo. August 1996."Static Electricity."

Shapiro, Fred. 1997.  Correspondence with Abt Associates Inc., including the brochure, "Checklist for the
Flexographic Print Shop" (author unknown).
                                                2-42

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CHAPTER 3
                                                                              RISK
                               Chapter 3: Risk
                             CHAPTER CONTENTS
3.1 INTRODUCTION TO RISK..	3'4
       Background	
       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"26

3.3 CATEGORIZATION OF FLEXOGRAPHIC INK CHEMICALS FOR THIS CTSA	3-30
       Chemical Categories by Product Line	•	3'33

3.4 ENVIRONMENTAL AIR RELEASE ASSESSMENT	•	3-37
       Environmental Air Release Methodology	• • • 3-37
       Environmental Air Release Results	3'38

 3.5 OCCUPATIONAL EXPOSURE ASSESSMENT	•	3'41
       Occupational Exposure Methodology	•	•	3"41
       Occupational Exposure Results	•	3"44

 3.6 GENERAL POPULATION EXPOSURE ASSESSMENT	•	3-47
       General Population Exposure Methodology	• ••••••	3'47
       General Population Exposure Results	•			3'50

 3.7 RISK CHARACTERIZATION	3'52
       Occupational Risk Results	
       General Population Risk Results	•	• 3"62

 REFERENCES	•• • • • ••	'' 3"66
                                          3-1

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  CHAPTER 3
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                                    CHAPTER OVERVIEW

  This chapter presents the hazards, exposures, and associated health and environmental risks that ma\
  resultfrom the chemicals in the solvent-based, water-based, and UV-cured ink systems studied in the CTSA


  INTRODUCTION TO RISK: 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
 1 described.


  HAZARD IDENTIFICATION: Section 3.2 discusses the human 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  as well as 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 2.


  CHEMICAL CATEGORIES: Section 3.3 describes the chemical categories into which the flexographic ink
 I chemicals were organized for this CTSA.  Subsequent sections of  the risk assessment discuss these
  chemical categories ratherthan specific chemicals, in ordertoprotectthe confidentiality of ink manufacturers
  regarding specific ink formulations. This section also identifies the relevant chemical categories for each ol
 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
 .potential 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,  which yielded  higher exposure rates, are used  for the subsequent Risk
 Characterization. Section 3.6 presents potential inhalation exposures for the general population.


 RISK CHARACTERIZATION: Lastly, Section 3.7 describes the risk characterization for these flexographic
 inks. 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

1
 Useful information can be gleaned from each section of this chapter. However, when comparing the overall
 impacts of ink formulations, the risk characterization (Section 3.7) is the most relevant.  These results are
 based on modeled  assumptions about conditions and practices in  flexographic printing facilities, and
 therefore 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. Several of the important
 findings are noted on the next page.
                                             3-2

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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, ethanol has 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 U V-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.
       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 concern for occupational health. For both
       solvent-based and water-based inks, the chemicals that most commonly were a clear concern for
       risk were solvents, with some  colorants and other chemicals also listed.  For UV-cured inks,
       chemicals of clear concern for 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 concern.
       Potential concern for 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 or other 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. II
       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" concern for 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 concern for risk, therefore, may be slightly above
       the resoective threshold, or mav be far beyond that threshold.                '	
                                             3-3

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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. 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 identification8
                  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 thosetypes 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 population
              "In Europe, hazard is referred to as "toxicity."
                                              3-4

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CHAPTERS
                                          RISK
               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 lexicological potency of the chemical
               to the estimated dose or exposure level received. A key distinction between cancer and
               other lexicological effects is thai 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
               lexicological 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 occur withoul appreciable risk of deleterious,  non-cancerous effecls 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 Effecl Level
               (NOAEL) or Lowest Observed Adverse Effect Level (LOAEL) from an  appropriate
               lexicological or epidemiological study, and then applying various uncertainly and modifying
               factors lo arrive al Ihe RfD or RfC. The NOAEL is ihe highest exposure level thai can occur
               without statistically or biologically significant adverse effecls, and the LOAEL is Ihe lowesl
               exposure level al which adverse effects have been shown to occur. Although some RfDs
               and RfCs are based oh actual human dala, ihey are mosl often calculated from results
               oblained in laboratory animal studies. The following represenls the equation for a RfD:
                                        RfD =
NOAEL (or LOAEL)
      UF*MF
               In this equation, the Uncertainty Factor (UF) 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 thai is of
               less-lhan-lifetime exposure, and the uncertainty in using LOAEL data ralher than NOAEL
               data. The Modifying Factor (MF) is applied based on a professional judgment of ihe quality
               of the data available for Ihe chemical. The defaull value for MF is 1.
                                              3-5

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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 in the ink formulations used in the performance demonstrations.
              These measures are explained in 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.

              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 hot 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
              HighMOE values (e.g., greater than lOOforaNOAEL-basedMOEor 1,000 for aLOAEL-
              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 MOE is 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 peakexposure(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 (B 1 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 nqncarcinogenicity for humans

               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:
                                              3-7

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CHAPTER 3	      '	RISK

                  •   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 ug/m3 (micrograms per cubic meter) in air or as
                      risk per ug/L (micrograms per liter) in water for continuous lifetime exposures.11

                  •   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
                  •   ECso, 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.
               b 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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CHAPTERS
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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 XRTECS)
                      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 lexicological 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.

               Humanhealth hazard profiles were prepared for chemicals about which human lexicological
               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.
                                              3-9

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                                                                                         RISK
              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 3.1A-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.
                  •  Chemical/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 in 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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CHAPTEB3
                                                                                           RISK
               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
               lexicological 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).°
                   •   Twenty presented a medium hazard (moderately toxic at subchronic/chronic oral
                      doses > 50 mg/kg).
                   •   One, ethanol, 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 folio wing are shown in Table 3.1:

                    •  Sixteen chemicals presented a low hazard (no effects or effects seen at oral doses
                       >250 mg/kg/day).
                    •  Four presented a medium hazard (effects seen at oral doses of 50 to 250 mg/kg/day).
                    •  Four (barium,  ethanolamine,  isopropanol, and styrene) presented a high hazard
                        (effects seen at oral doses <;50 mg/kg/day).
                 c 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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                                                                                         RISK
              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 lists each chemical used in the study and 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
              lexicological 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 lexicological 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
              in inhalation exposure. Table 3.1-B presents the hazard information on the colorants; most
              present a low-moderate dermal 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):  Twenty  one  chemicals  were  categorized  as  additives.
              Toxicological data were available for five  chemicals, and the SAT analyzed  12  others.
              There was not enough information available for the SAT to analyze four 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.

              UV-Reactive Compounds (Table 3.1-E): Seventeen chemicals are included in this group.
              Table 3.1-E further  groups  these compounds according to three  functions: monomers,
              oligomers, and photoinitiators. Toxicological data were available for five chemicals, and
              the SAT analyzed the remaining  chemicals.  Monomers were  the most consistently
              hazardous chemicals —  all had medium  hazard concern  for systemic  toxic effects.
                                            3-12

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CHAPTERS
                                                                                         RISK
              However, two photoinitators and an oligomer also were found to have a medium hazard
              level.

              Multiple-Function (Table 3.1-F): This group contains chemical categories for which the
              included chemicals are used in two or more ink functions. For example, the category amides
              and nitrogenous compounds contains chemicals that are solvents or additives.  Of the 18
              chemicals in Table 3.1-F, toxicological data are available for 13, and the others were
              analyzed by the SAT. Six chemicals in this category have either medium or high hazard
              levels for toxic effects (either systemic or developmental).
                                              3-13

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-------
CHAPTER 3
                                                                       RISK
                                      3-23

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CHAPTER 3
                                                                                          RISK
              Summary of Carcinogenic Information
              The available  information  on the carcinogenic characteristics 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:

                  •   Ethanol is an IARC Group 1 chemical, which indicates that there is sufficient
                      evidence that it is 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.  The evidence of carcinogenicity in humans is inadequate,
                      and in experimental animals it is inadequate or limited.
                  •   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 paraffmics, have been shown to cause
              skin tumors in mice. Styrene has been documented to cause mammary tumors hi rats.  It is
              important to note that because there are physiological differences between animals and
              humans, a chemical that produced evidence of carcinogenicity in animal studies will not
              necessarily be carcinogenic in humans. Conversely, because not all chemicals have been
              subjected to carcinogenicity studies, this list does not imply that chemicals not on the list
              are without concern.                          .

              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.
                                            3-24

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CHAPTER 3
                                                                                                    RISK
                     Table 3.2 Carcinogenicity Information for CTSA Chemicals
              Chemical
                                                    Carcinogenicity Information
 Ethanol
                                  ;iassified as Group 1 by IARC: Inadequate evidence for Carcinogenicity of
                                  thanol and of alcoholic beverages in experimental animals, but sufficient
                                  vidence for Carcinogenicity of alcoholic beverages in humans.
 C.I. Pigment White 6
                                 Evidence of lung tumors in rats.
 Kaolin
 Resin, acrylic
 Distillates (petroleum), hydrotreated
 light	
                                 Evidence of skin tumors in mice.
 Distillates (petroleum), solvent-refined
 light paraffinics                	
                                 Evidence of benign skin tumors in mice.
  Jtyrene
                                      Evidence of mammary or breast tumors in rats.
  Propanol
                                 Classified as Group C by U.S. EPA: Possible human carcinogen, based
                                 on no evidence of Carcinogenicity in humans and limited evidence of
                                 Carcinogenicity in experimental animals.
  Amorphous silica
  sopropanol
                                 Classified as Group 3 by IARC: Not classifiable as to its Carcinogenicity to
                                  lumans based on no or inadequate evidence in humans and experimental
                                 animals.
  3olyethylene
  Polytetrafluoroethylene
  Acrylated epoxy polymer
  Acrylated oligoamine polymer
  Acrylated polyester polymer #1
                                  These chemicals had no Carcinogenicity study data, but SAT reports
                                  ndicated low to moderate concern for Carcinogenicity based on analogous
                                 structural, functional, and/or mechanistic data for chemicals with known
                                 Carcinogenicity.
  Acrylated polyester polymer #2
  C.I. Basic Violet 1,
  molybdatephosphate
  C.I. Basic Violet 1,
  molybdatetungstate-phosphate
  C.
. Pigment Red 48, barium salt (1:1)
  C.
. Pigment Red 48, calcium salt (1:1)
  C.
. Pigment Red 52, calcium salt (1:1]
     . Pigment Violet 27
     . Pigment Yellow 14
  Dipropylene glycol diacrylate
  Ethyl 4-dimethylaminobenzoate
  1,6-hexanediol diacrylate
  Isopropoxyethoxytitanium
  bis(acetylacetonate)
  Trimethylolpropane ethoxylate
  triacrylate	
   Trimethylolpropane propoxylate
   triacrvlate
   iee "Definitions of Systemic Toxicity. Deve  pmental Toxicity, and Carcinogenic Effects' in Section 3.1 for more intormation aooui
  cancer classifications.
                                                    3-25

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CHAPTER 3
                                                                                           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 ECJO 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
                 •   Low hazard chemicals: estimated chronic value > 10 mg/L
                                             3-26

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CHAPTERS
RISK
               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 CTS A, 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 in
               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.

               For 26 chemicals, no aquatic toxic effects were expected, because the chemical structures
               are too  large (molecular weight greater  than  600 or 1,000) to pass through  biological
                membranes. Nevertheless, concern concentrations were calculated  whenever possible.
               Concern concentrations ranged from 0.001 to 20 mg/L.
                                               3-27

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CHAPTER 3
                                                                                          RISK
               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 the use  of chemicals that appear in Table 3.3 can help avoid
               potential problems.
                                             3-28

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CHAPTERS
                                  RISK
                           Table 3.3  Chemicals of High and Medium Aquatic Toxicity
                                       (Based on Toxicological Studies)
                                     18 Chemicals of high aquatic toxlcity
                Amides, tallow, hydrogenated
                C.I. Basic Violet 1, molybdatephosphate

                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
                                   35 Chemicals of medium aquatic toxlcity
                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

                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)
                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
                                              3-29

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

              This section describes the categories that each flexographic ink chemical was assigned for
              the purposes of the  CTSA analysis. 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.
                                            3-30

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CHAPTERS
                                                                                RISK
                               Table 3.4 Categorization of Ink Chemicals
Category
Acrylated polyols
Acrylated polymers
Acrylic acid
jolymers
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 methacryiate-
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
                                          3-31

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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
Pigments —
organometallic
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
C.I. Basic Violet 1 , molybdatephosphate
C.I. Basic Violet 1 , molybdate-
tungstatephosphate
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
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
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
                                        3-32

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CHAPTERS
                                                                                           RISK
                             Table 3.4 Categorization of Ink Chemicals (continued)
Category
Polyol derivatives
Propylene glycol
ethers
Resins
Siloxanes
Chemicals in category
Nitrocellulose
Polyol 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, hexamethylenediamine,
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)benzene°
Rosin, polymerized
Silanamine, 1 ,1 ,1-trimethyl-N-(trimethyIsilyl)-,
hydrolysis products with silica
Silicone oil
Siloxanes and silicones, di-Me, 3-
hydroxypropyl
' Me, ethers with polyethylene glycol acetate
CAS
number
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
                a No data or information available.
                b 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 CTS A 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.
                                                3-33

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 CHAPTER 3
                                                                                       RISK

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CHAPTER 3
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                                    3-36

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CHAPTER 3
                                                                                         RISK
3.4 ENVIRONMENTAL AIR RELEASE ASSESSMENT

               Releases to air result from the evaporation of chemicals during the flexographic printing
               process. 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.

               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 millimeters of
                      mercury (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.
                                               3-37

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CHAPTER 3
                                                                                           RISK
                                                         Stack Release
                                                              t
                                    Fugitive Releases

                                              .   A
           Oxidizer
        (Solvent-based
      Formulations Only)
                            Ink Chamber
Flexographic Press
Ink on Substrate Product

Ink in Cleaning Solution
to Waste
                Ink Returned to Container
                After Run
                            Figure 3.1 Mat* 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.l 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, ard 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. The
                                              3-38

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CHAPTER 3
                                                                                           RISK
               average stack emissions (0.216 g/sec)  were considerably lower than fugitive emissions
               (1.87 g/sec), reflecting the anticipated use of oxidizers 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 figures were calculated
               with the assumption that 100 percent of the volatile components of the inks would be
               released to the air. In reality, much of the volatile content would be incorporated into the
               coating during the  UV curing process.  The decrease  in  emissions under real-world
               conditions is unknown.

               Air releases also varied among colors within each ink system; the differences are primarily
               due to  different consumption rates.   White ink had significantly higher 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 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. Equipment specifics, such as the choice of anilox roll volume, also may affect
                ink consumption rates. In particular, UV-cured inks often require lower-volume anilox rolls
                than the  other two ink systems because less UV-cured ink generally is needed per unit of
                printed area.

                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
                CTS A performance demonstrations, solvents were added in greater quantities to the solvent-
                based formulations than to water-based or UV-cured formulations, which further increased
                releases  from solvent-based  inks.      .     .      •
                                                3-39

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                                                                       RISK
                                   3-40

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                                                                                          RISK
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 substantially depending
               on site-specific operating conditions, end-products, age of pollution control equipment, and
               other factors.d

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

               Exposure Scenarios
               In Scenario I, workers were assumed to be 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 assumed to be exposed for 48 minutes per
               formulation per shift.
                dMany facilities conduct exposure monitoring to measure worker exposure rates. If monitoring
                data are available, they can be used with other data in this analysis to determine whether facility-
                specific conditions pose a low, potential, or clear concern for risk according to the scale used in
                this study. To do this, a reader should compare exposure data to the hazard data reported in
                Appendix 3-B. By following the procedures outlined in Section 3.7 and Table 3.13, the reader
                can conduct a site-specific comparative risk assessment.

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                                                                                         RISK
              In Scenario n, workers were assumed to be 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 n 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 n (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 of the model facility parameters.
                                             3-42

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CHAPTERS
RISK
                         Table 3.9  Occupational Exposure Methodology Assumptions
Assumption
Temperature of the ink during transfer -
Average ventilation rate in both rooms
Ventilation/room air mixing factor
Velocity of the air across the cans
Press emissions capture rate
VOC destruction efficiency of oxidizer
Diameter of the five-gallon cans
Press speed
Exposure time in the ink preparation
room
Exposure time adjusting five-gallon ink
can near the press — solvent-based
inks
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
Value
25°C
7,000
ft3/min
0.5
100fpm
70%
95%
1ft
500 fpm
48 min/
formulation
2.5 hr
1.0 hr
2.0 hr
Source
EPA12
Average of Technical
Committee responses
EPA12
EPA12
Technical Committee
response8
Technical Committee
response
EPA12
Performance methodology
Technical Committee
response
Technical Committee
response
Technical Committee
response
Technical Committee
response
                The capture rate for newer or retrofitted presses will be considerably higher, (approximately
                85%) due to the use of enclosed doctor blades.
               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).'!
                  •  Scenario n used a printing room mass balance model  to calculate chemical
                      concentrations in the printing room based on fugitive e i nission and room ventilation
                      rates.
                                              3-43

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CHAPTER 3
RISK
                  •   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 upper
              and lower "bounding" estimates of dermal exposure. Because glove usage is not universal
              in the printing industry, the data were calculated based on the conditions for a worker who
              does not use gloves  or barrier creams.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

              The results indicated that workers under Scenario I would have lower exposures than
              workers exposed in Scenario n. 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 IT).  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 n 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 mg/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 n data were site-
              specific.
                                             3-44

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CHAPTER 3
                                                                                           RISK
               Table 3.10, an excerpt from Table 3-F.l, presents occupational exposure data for Solvent-
               based Ink #S2 at Site 10 (Scenario IT). 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. 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.
                                                3-45

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CHAPTER 3
                                                                                                    RISK
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CHAPTER 3
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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 in 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) 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
                                              3-47

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CHAPTER 3
RISK
               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 jig/m3, then the
               average concentration anywhere else in the country would be between  1 and 10 ug/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)]/[(BW)(AT)]

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

                  where

                   C    =  chemical concentration in air from air dispersion modeling Gug/m3)
                   IR   -  inhalation rate (m3/day)
                                              3-48

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CHAPTERS
                                                                                          RISK
                   ED  =   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.
                   BW =   average body weight (kg)
                   AT  =   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 7,500,000.17 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;
                   •   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.
                                               3-49

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CHAPTER 3
                                                                                           RISK
              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 foizr 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.
              Li 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 CTS A 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.

              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 solve" t-based inks outweigh the decrease in stack emissi > ,ns 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.
                                             3-50

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CHAPTER 3
                                                               RISK
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CHAPTER 3
                                                                                      RISK
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, potential, or low/negligible concern for risk.
                                           Defining Risk Levels

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

              Potential concern for risk indicates that for the chemical in question under the assumed
              exposure conditions,  adverse effects may occur.  A chemical was designated as a
              potential concern for  risk if it had a HQ between 1 and 10, or a MOE that either was
              between  10 and 100 or 100 and 1,000. A SAT-analyzed chemical was evaluated as a
              potential concern for risk if it posed a low-moderate hazard and exposure was predicted
              (see Note 3).

              Low or negligible concern for risk indicates that for the chemical in question under the
              assumed exposure conditions, no adverse effects were expected.  A chemical of low or
              negligible concern for risk had a HQ less than 1, or a MOE greater than 100 or 1,000.  An
              SAT-analyzed chemical was evaluated as a low or negligible concern for risk if it had 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 significant adverse effects are observed. The
              LOAEL is the lowest  concentration at which adverse 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., greaterthan 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 Structure Activity Team (SAT) determined hazard levels based on analog data
              and/or structure activity considerations, in which characteristics of the chemicals were
                                            3-52

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CHAPTERS
RISK
               estimated in part based on 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
Potential risk
Low or negligible risk
Hazard
Quotient *
>10
1 to 10
<1
Margin of Exposure"
NOAELC
1 to 10
>10 to 100
>100
LOAEL d
1 to 100
> 100 to
1,000
> 1,000
SAT Hazard
Rating8
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.
                "This column presents the level of risk concern if exposure is expected.  If exposure is not
                expected, the level of risk concern is assumed to be low or negligible.
               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 lexicological potency factor available for the exposure
               under consideration.

               Dermal exposure values to workers should be regarded as bounding estimates.  The
               inhalation exposure estimates are "what-if' estimates.
        Occupational Risk Results

                Chemicals of Clear Concern for Risk
                Categories with chemicals that present a clear concern 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.
                                               3-53

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            CHAPTER 3
RISK
                          The alcohols chemical category contained the most chemicals of clear concern for risk in
                          the  solvent-based  and water-based ink  formulations.  Several amides or nitrogenous
                          compounds in water-based ink formulations also presented a clear concern for systemic risks
                          to workers. The acrylated polyols category contained many of .the chemicals posing a clear
                          concern for risk in the UV-cured formulations, based on lexicological data. Based on SAT
                          reports, several other categories, including acrylated polymers and amides or nitrogenous
                          compounds, contained chemicals that presented a clear concern for developmental effects.
                                                          3-54
_

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                                               3-57

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   CHAPTER 3
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                                         3-58

-------
CHAPTER 3
                                                                                         RISK
               Most of chemicals presenting a clear occupational risk concern in solvent-based ink
               formulations are solvents; many chemicals presenting clear risk concern for water-based
               inks serve as solvents, colorants, and multi-function chemicals.  For UV-cured ink
               formulations, most chemicals presenting a clear occupational risk concern serve as additives,
               monomers, oligomers, colorants, and the multiple function category.

               Range of Occupational Risk Concern Levels by Chemical Category and Ink System
               Table 3.18 summarizes the range of occupational risk concern levels (low concern, potential
               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 lexicological data only, except for two chemical categories found in UV-cured
               inks: amides or nitrogenous compounds and aromatic esters, which had SAT data.

               Each ink system contained chemicals with a clear concern for risk:
                   •   Solvent-based inks had five chemical categories that contained chemicals of clear
                      risk.
                   •   Water-based inks had five chemical categories that contained chemicals of clear
                      risk.
                   •   UV-cured inks had four chemical categories that contained chemicals of clear risk.

               Chemical categories within an ink system showed a wide variation in the level  of risk
               concern. For example, ethylene glycol ethers in water-based inks ranged from low concern
               to clear concern. Variation also occurred among ink systems for certain chemical categories
               (e.g., certain alcohols in solvent- and water-based inks presented  a clear concern, but
               alcohols in  UV-cured inks presented a low  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 Concern by Product Line
               and Site
               Table 3.19 summarizes of the number of chemicals that were found to be of concern for
               clear occupational risk.   Solvent- and water-based ink product lines each included an
               average of 16 chemicals with clear risk concern (based on both toxicological and SAT-based
               data): an average of 29% 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 concerns, because it is not possible to correlate the
               nature and severity of potential adverse effects on an aggregate product line level.

               The total number of chemicals in an ink product line was determined by adding the numbers
               of base chtmical 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 was counted more than once if it were found hi more than one
               formulation. For example, ethanol, used in three formulations within a product line, was
                considered to be three "chemicals." However, if a chemical presented a clear risk concern
                for both dermal and inhalation pathways in a single formulation, it was counted only once.
                Similarly, if a chemical presented a clear risk concern for both systemic and developmental
                effects, it was counted only once.
                                               3-59

-------
 CHAPTER 3
                                                                                      RISK
 
-------
CHAPTERS
                                                                                           RISK
             Table 3.19 Summary of Number of Chemicals with Clear Occupational
                             Risk Concern, by Product Line and Site
Ink type
Solvent-
based
Water-
based
UV-cured
Product
Line
#S1
#S2
#W1
#W2
#W3
#W4
#U1
#U2

Site
9B
5
7
10
4
1
2
3
9A
11
6
R
Number of
Chemicals"
63
70
71
75
43
48
62
56
66
48
70
46
Toxicoiogical
Data"'"
Number
15
14
15
18
16
13
15
13
18
1
16
0
Percent
24%
20%
21%
24%
37%
27%
24%
23%
27%
2%
23%
0%
, SATData"'"
Number
2
0
0
0
0
3
0
0
0
6
5
9
Percent
3%
0%
0%
0%
0%
6%
0%
0%
0%
13%
7%
20%
Total Chemicals of Clear
Risk Concern''"
Number
17
14
15
18
16
16
15
13
18
7
21
9
Percent
27%
20%
21%
24%
37%
33%
24%
23%
27%

30%
20%
Rank6
5
10
9
7
1
2
6
8
4

3
11
 ^1 HJIIIIOCIIO Ql w wWWi tiwM 11 »wi w n •*•*!« *" iw ii i v wi »»• ••• ...•—.•—• ...—-- - — - —	               •
of chemicals may also include site-specific press-side solvents or additives.
b Includes clear concern for risk for systemic or developmental effects via inhalation or dermal routes.
c The ranking  orders the product lines from the highest to  lowest percentage of chemicals with clear concern for
occupational risk.


                Occupational Concern for Risk 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 methyl ether in
                solvent-based inks, and ammonia, propanol, isobutanol, and ethyl carbitol in water-based
                inks presented potential or clear occupational risk concerns 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).

                Concern for Cancer Risk                                    .
                Only a few ink formulations contained chemicals  posing a concern for cancer.  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.
                                                3-61

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CHAPTER 3
                                                                                        RISK
       General Population Risk Results

              Categories with Chemicals of Potential General Population Concern for Risk
              Categorieb with chemicals that present  a potential risk  concern for systemic  and
              developmental effects in the general population are shown in Table 3.20. No chemicals
              presented a clear concern for risk to the 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 were the only category with
              chemicals of potential general population risk concern based on toxicological data.  (The
              alcohols served as solvents in these formulations.)  For the UV product lines, acrylated
              polyols in UV-cured Ink #U2, serving as reactive diluents, were the only category with
              chemicals of potential risk concern based on toxicological data.  Based on SAT reports,
              certain propylene glycol ethers in Solvent-based Ink #S2, amides or nitrogenous compounds
              in UV-cured Inks #U1 and #U3, and acrylated polyols in UV-cured Ink #U2 may present a
              risk to the general population.

              Range of General Population Risk Concern 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 chemicals presented a negligible concern for general  population  risk
              because the model anticipated little exposure to the general population in the model,
              and no chemicals presented a clear concern for risk. Each ink system had one category with
              chemicals  that posed a potential risk concern for the general population: alcohols in solvent-
              and water-based inks, and acrylated polyols in UV-cured inks. Five additional categories
              in water-based inks,  three in solvent-based inks, and one in UV-cured inks contained
              chemicals  of low concern for risk to the general population.

              Summary  of Number of Chemicals of Potential General Population Risk  Concern by
              Product Line and Site
              Table 3.22 summarizes the number of chemicals with a potential risk concern for the general
              population, by product line and site. Very few chemical categories include chemicals that
              carry a potential risk concern 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.
                                             3-62

-------
CHAPTER 3
                                                                       RISK
                                                                        o
                                    .  3-63

-------
CHAPTER 3
                                                                       RISK
                                   3-64

-------
CHAPTER 3
                                                                                         RISK
                Table 3.22 Summary of Number of Chemicals with Potential General Population
                                   . Risk Concern, 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 Potential Risk
Concern8'"
0
3
0
0
0
1
1
1
0
0
1
0
Number of Total
Chemicals b
63
70
71
75
43
48
62
56
66
48
70
46
Percent
0%
4%
0%
0%
0%
2%
2%
2%
0%
0%
1%
0%
a Includes potential risk concern for systemic or developmental effects via inhalation.
b 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 Risk Concern from Press-Side Solvents and Additives
               The use of press-side solvents and additives was found to increase the concern for risk to
               the general population 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 cpncern for risk
               to the general population in certain formulations.

               Concern for Cancer Risk
               Water-based ink #W2 (Site  1)  contained one 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 found to be of negligible general population risk concern, because incidental exposure
               of the general population to these chemicals was not expected.
                                              3-65

-------
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, RJ. "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.
                                            3-66

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CHAPTER 3
RISK
16.    General Sciences Corporation. Graphical Exposure Modeling System, GEMS, User's Guide, 1991.
       GSC-TR-32-91-001.

17.    Kaleel, Rob, State of Illinois Environmental Protection Agency.  Personal communication with
       Conrad Flessner, U.S. Environmental Protection Agency. December 23, 1997.

18.    U.S. Environmental Protection Agency. Guidelines for Exposure Assessment; Notice. Washington,
       DC:  Environmental Protection Agency. Federal Register, pp. 22888-22938.  May 29, 1992.
                                             3-67

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CHAPTER 3
RISK
                             This page is intentionally blank.
                                         3-68

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CHAPTER 4
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 for the Study	4-11
       Substrates Used for the Tests	4-11
       Image and Plates Used for the Tests	4-12
       Types of Printing Performed	•	4-14
       Limitations of the Performance Demonstrations		.	,		4-15
       Methodology for Laboratory Runs	^	4-16

4.2 RESULTS OF PERFORMANCE DEMONSTRATION AND LABORATORY RUN TESTS —
SOLVENT-BASED AND WATER-BASED INKS	4-19
       Adhesive Lamination — Solvent-based and Water-based Inks	4-19
       Block Resistance — Solvent-based and Water-based Inks	 4-20
       CIE L*a*b* — Solvent-based and Water-based Inks	 v 4-20
       Coating Weight — Solvent-based and Water-based Inks	4-22
       Density — Solvent-based and Water-based Inks			4-25
       Dimensional Stability — Solvent-based and Water-based Inks  	4-27
       Gloss — Solvent-based and Water-based Inks	4-28
       Heat Resistance/Heat Seal — Solvent-based and Water-based Inks	 4-29
       Ice Water Crinkle Adhesion — Solvent-based and Water-based Inks		4-30
       Image Analysis — Solvent-based and Water-based Inks		4-31
       Jar Odor — Solvent-based and Water-based Inks	4-32
       Mottle/Lay — Solvent-based and Water-based Inks	4-33
       Opacity — Solvent-based and Water-based Inks	 4-36
       Rub Resistance — Solvent-based and Water-based Inks	 4-36
       Tape Adhesiveness — Solvent-based and Water-based Inks	4-37
       Trap — Solvent-based and Water-based Inks	,	4-38
       Highlights of Performance Results for Solvent-Based and Water-Based Inks	 4-40
                                           4-1

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CHAPTER 4
PERFORMANCE
4.3  RESULTS OF PERFORMANCE DEMONSTRATION AND LABORATORY RUN TESTS — UV-
CURED INKS			4-40
      Block Resistance — UV-cured Inks  	4-41
      CIE L*a*b* — UV-cured Inks	 4-42
      Coating Weight— UV-cured Inks	4-43
      Coefficient of Friction — UV-cured Inks	4-44
      Density — UV-cured inks	4-45
      Dimensional Stability — UV-cured Inks	4-46
      Gloss — UV-cured Inks	4-46
      Ice Water Crinkle Adhesion — UV-cured Inks	 4-47
      Image Analysis — UV-cured Inks	4-47
      Jar Odor — UV-cured Inks	4-49
      Mottle/Lay— UV-cured Inks	4-50
      Opacity — UV-cured Inks	4-51
      Rub Resistance — UV-cured Inks	 4-52
      Tape Adhesiveness — UV-cured Inks	 4-52
      Trap — UV-cured Inks	4-52
      Uncured Residue — UV-cured Inks	4-53
      Summary of Performance Test Results for UV-Cured Inks		4-53
      Technological Development in UV-cured Inks	 4-54

4.4  SITE PROFILES	.	4-56
      Site 1: Water-based Ink #W2 on OPP	,	4-57
      Site 2: Water-based Ink #W3 on LDPE and PE/EVA	 4-59
      Site 3: Water-based Ink #W3 on LDPE and PE/EVA	4-61
      Site 4: Water-based Ink #W1 on.OPP	4-63
      Site 5: Solvent-based Ink #S2 on LDPE and PE/EVA		4-64
      Site 6: UV Ink #U2 on LDPE, PE/EVA, and OPP	4-66
      Site 7: Solvent-based Ink #S2 on LDPE and PE/EVA	4-68
      Site 8: UV Ink #U3 on LDPE, PE/EVA, and OPP	4-70
      Site 9A: Water-based Ink #W4 on OPP	'.	4-71
      Site 9B: Solvent-based Ink #S1  on OPP	4-73
      Site 10: Solvent-based Ink #S2  on OPP 	4-74
       Site 11: UV lnk#U1 on LDPE (no slip)	4-76

REFERENCES			 4-78
                                          4-2

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CHAPTER 4
PERFORMANCE
                                   CHAPTER OVERVIEW

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

METHODOLOGY: The methodology of the data collection and tests for this CTSA is summarized in Section
4.1. 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 run.
 The complete performance demonstration methodology can be found in Appendix 4-A, and other information
relevanttothe methodology is in Appendix 4-B through 4-D.) Western Michigan University conducted separate
 aboratory 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 for the laboratory runs are
discussed in Section 4.2, and more detailed information is provided in many of the appendices to Chapter
4, particularly Appendices 4-A through 4-E.

PERFORMANCE DEMONSTRATION TEST RESULTS: The printed substrates completed  at  the
 Derformance demonstrations were sent to Western Michigan University, which tested each ink/substrate
combination. A total of 18 tests were performed to measure a wide range of capabilities for solvent-based,
water-based, and UV-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 technology
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 hours, 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 for their 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 anc
 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.
                                              4-3

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CHAPTER 4
PERFORMANCE
4.1 METHODOLOGY

               TheHexography 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.

       Facility Selection Process

               Ten commercial printing facilities in the United States, and a press manufacturer's pilot line
               in Germany, volunteered to participate in this study. To participate in the project, facilities
               needed to be proficient with the ink system and the product-substrate combination that they
               would test, In some cases,  this use of "real world" facilities and conditions required
               modifying the specifications, because all printers do not necessarily have the precise mixture
               of requirements desired. All facilities that participated donated press time to  print the
               appropriate ink/substrate combinations on wide-web presses.4

               Each facility that volunteered to participate in the project also contributed a significant
               amount of technical information via  a  detailed Facility Background Questionnaire
               (Appendix 4-B). The Site Profiles in Section 4.4 present much of this information.

       Methodology for On-site Performance Demonstrations

               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. Appendix 4-A
               details the specifications of the printing presses, plates, substrates, and demonstration runs.
       1 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."
                                              4-4

-------
CHAPTER 4
PERFORMANCE
                           Table 4.1  Ink System and Substrates Tested at Each Site
Ink Svstem Substrate(s) Site
Solvent-based
Water-based
UV-cured
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
Site 5
Site 7
Site 9B
Site 10
Site 2
Site 3
Site 4
Sitel
Site9A
Site 6
SiteS
Site 1 1
               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.

               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 and data collection sheets can be
               found in Appendices 4-A and Appendix 4-C.

        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 test  procedures and
               performance data can be found in Appendix 4-E.
                                              4-5

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Interpretation

Procedure (detailed demonstration and
laboratory procedures described in
Appendix 4-E)a








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Minimizing mottle is a particular challenge when
printing large solid areas, which are typical in line
printing. There are no industry standards for "goo
or "bad" mottle. The values should be used only f
comparative analysis. The higher the Mottle Inde:
the lower the print quality. Also, the higher the
standard .deviation, the more variable the print
quality..
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Multiple density measurement points (250-50
were collected with a Mottle Tester during 20
linear scans over the sample area.
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Opacity is expressed as the percentage of light
blocked. Average values greater than 48% are
generally considered desirable. Factors such as
anilox roll volume play a greater role in opacity thi
does ink type. High opacity is best achieved by
using inks with high solids content and high
application weights as governed by the anilox roll
Opacity is also a function of substrate and plate
wettability. When interpreting opacity data, the
anilox roll volumes, printing viscosity, and substra
must be evaluated as a complete system.

Samples were taken using a Datacolor
Spectraflash 600 and a Diano-BLN opacity
meter. The measurements were averaged to
obtain one reading for each location.
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                                                                                         4
                                                       o

-------
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
Color (as listed in the text)
Line colors
Process colors
Blue
Green
White (opacity target 48%)
Cyan
Maaenta
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. This
               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 represent a common selection of films to 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
Substrate
Low-density
polyethylene (LDPE)
Polyethylene / ethyi
vinyl acetate (PE/EVA)
co-extruded film
Oriented polypropylene
(OPP)
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
                                              4-11

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CHAPTER 4
PERFORMANCE
              Film manufacturers donated the substrates used in the study. With two exceptions, all 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 with the intent of covering the technical spectrum of printing
              on film at the time.the project was designed, 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 reduced-size copy
              of the image below and in Appendix 4-D.
                                             4-12

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CHAPTER 4
PERFORMANCE
                           Test Image Used in CTSA
                                   4-13

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CHAPTER 4
PERFORMANCE
       Printing Presses Used

               There are three major types of flexographic printing presses: in-line, stack, and central
               impression  (CI).  The  CI press was selected for use  in the CTSA performance
               demonstrations.  In many ways the CI press represents the standard for quality in the
               flexographic printing industry, especially in converting. This type of press has a particular
               advantage in holding tight register, which allows it to be used for technically demanding
               multiple-color jobs on many different substrates. The CI press is distinguished and named
               for its structural configuration, in which different color stations are arranged around a single
               large (central impression) drum. The number of stations can vary. Most Cl.presses have
               six color stations, but presses are now being built with eight and ten stations.

                                     Diagram of Central Impression Press
                     (from Flexography: Principles and Practices, 5th edition, volume 6, page 6)
                                                                          '-Q
               The performance demonstrations required wide-web CI presses, with a target width of 24
               inches, six color stations, and capability of running the film substrates selected for the
               project. Suggested specifications of the presses chosen for the performance demonstrations
               are listed in Appendix 4-A. The point of choosing this type of press was to gather data about
               the three primary ink systems on commonly used presses running film substrates. At the
               time the project was designed this combination represented some of the most complex
               printing situations, as well as the anticipated future direction of flexographic printing. Wide-
               web printing in particular can pose many challenges. As a case in point, at the time this
               project was being developed, UV-cured inks were making inroads in narrow-web printing
               but not yet in wide-web printing.

        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.
                                              4-14

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CHAPTER4
PERFORMANCE
       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.

                   •   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-F.

                   •   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:

                   •   Although the  performance methodology set forth guidelines and parameters for the
                      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.
                                              4-15

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CHAPTER 4
PERFORMANCE
                   •   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
               conditions would give printers a better sense of the actual capabilities of the ink/substrate
               combinations under a variety of conditions.  Thus, laboratory runs  were conducted at
               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. Due to
               equipment difficulties, the UV-cured ink combinations were not printed at WMU.

               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".) Appendices 4-E and 4-L
               provide a narrative description of the laboratory procedures and runs. All the results of the
               laboratory runs are included in the tables in Appendix 4-E.

               Some general information about the facility at Western Michigan University is provided in
               Table 4.5.
                    Table 4.5 Summary Facility Background Information for Laboratory Runs
Item
Ink type used
Emission control
equipment
Annual production
Operating hours
Avg. production run
Description
Solvent-based
only
and water-based for education and test runs
None
This facility is an educational institution, not a commercial
printing facility.
n/a
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.
                                              4-16

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CHAPTER 4
PERFORMANCE
                          Table 4.6  Ink-Substrate Combinations for Laboratory Runs
Site3
L1
L2
L3
L4
L5
L6
L7
Ink System
Water-based
Water-based
Water-based
Solvent-based
Solvent-based
Water-based
Solvent-based
Substrate
LDPE
OPP
OPP
OPP
LDPE
PE/EVA
PE/EVA
Product Line
W3
W4
W2
S2
S2
W3
S2
                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
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
Zerand
24 inches wide, two-color
Surface
500 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 _
Enercon
Two-roll with doctor blade
Stainless steel
Electric
                                             4-17

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CHAPTER 4
PERFORMANCE
                   Table 4.8  Color Sequence and Anilox Configurations for Laboratory Runs'
Sequence
Deckl
Deck 2
Color
White
Green
Anilox lpib
220
440
Anilox BCMC
6.4
2.8
                "Deck 1 (white ink) was changed to cyan ink for the PE/EVA substrate.
                blines per inch
                cbillion cubic microns per square inch
                             Table 4.9  Summary Information from Laboratory Runs

Substrate
Ink
Press Speed
Total Footage Consumed
Lab
Run#1
LDPE
#W3
343
41,143
Lab
Run #2
OPP
#W4
231
27,732
Lab
Run #3
OPP
#W2
292
35,097
Lab
Run #4
OPP
#S2
324
38,851
Lab
Run #5
LDPE
#S2
311
37,263
Lab
Run #6
PE/
EVA
#W3
274
32,930
Lab
Run #7
PE/
EVA
#S2
305
36,875
               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.

               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%.
                                              4-18

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CHAPTER 4
PERFORMANCE
               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 CDE 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
               suclj 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 4-1,  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.
                                              4-19

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CHAPTER 4
PERFORMANCE
                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
Force (kg)
0.3040
0.2649
0.2631
0.2575
Standard
Deviation
(kq)
0.0132
0.0012
0.0000
0.0158
       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
Resistance"
2.9
2.9
1.9
1.2
1.2
3.2
               "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.
       CIEL*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.
                                             4-20

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CHAPTER 4
PERFORMANCE
                  Table 4.12 CIE L*a*b* Results — Solvent-based and Water-based Inks
Ink
Solvent-
based
Solvent-
based
Water-based
Film
LDPE
PE/EVA
PE/EVA
QPP
LDPE
Product
Line
#S2
#S2
#S2
#S1
#S2
#W3
Site
5
7
L5
5
L7
7
9B
10
L4
2
3
L1
Color
magenta
cyan
green
blue
magenta
cyan
green
blue
green
magenta
cyan
green
blue
green
cyan
magenta
cyan
green
blue
magenta
cyan
green
blue
magenta
cyan
green
blue
green
magenta
cyan
green
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
54.1 1
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
r44.29
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
-46.1 1
32.38
-1.75
-35.69
34.34
-49.82
-7.16
-21.71
37.65
-50.75
32.33
                                       4-21

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CHAPTER 4
PERFORMANCE
                     fable 4.12 CIE L*a*b* Results — Solvent-based and Water-based Inks
                                                 (continued)
Ink
Water-based,
cont.
Film
PE/EVA
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
green
blue
magenta
cyan
green
blue
green
magenta
cyan
green
blue
green
Average
L*
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
a*
48.52
-22.09
-58.16
19.50
55.08
-28.1 1
-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
b*
-1.05
-40.29
34.05
-49.27
-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
28.26
                "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 on 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.
                                              4-22

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CHAPTER 4
                    PERFORMANCE
              Figure 4.1 Average Coating Weight for LDPE — Solvent-based and
                                   Water-based Inks
                            Solvent-based ink
    Water-based ink
H Bh
Blue ink
Green ink
White ink
je ink Y/\ Green ink
Solvent-based ink
1.77
1.98
2.21
|_| White ink
Water-based ink
1.61
1.39
2.36
                   Figure 4.2 Average Coating Weight for PE/EVA — Solvent-based and
                                          Water-based Inks
                  2.5-1
                cS>
                  1.5-
               f
                0)
                o
               o
                  0-5-
                            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
                                         4-23

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CHAPTER 4
                                                 PERFORMANCE
                      Figure 4.3 Average Coating Weight for OPP — Solvent-based and
                                             Water-based inks
                   3.5-1
                &
                 •B.2.5-
                 §   2
                 11-5
                 i   -
                 50.5
                     0
   Solvent-based ink

Blue ink      H  Green ink
                                                           Water-based ink

                                                                 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 (COF) 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.
                                             4-24

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CHAPTER 4
                                                                                  PERFORMANCE
                 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.
                 °"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.
                                                4-25

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CHAPTER 4
                                                                        PERFORMANCE
                Figure 4.4 Average Density for LDPE — Solvent-based and Water-based Inks

                  2.5 -i
                            Solvent-based ink
                                 Magenta ink
                                 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
                   2-1
                 1.5-
                CO
                
-------
CHAPTER 4
                      PERFORMANCE
                  Figure 4.6 Average Density for OPP — Solvent-based and Water-based Inks
                    2-1
                   1.5-
                 
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CHAPTER 4
PERFORMANCE
                 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.
                                            4-28

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CHAPTER 4
             PERFORMANCE
                    Figure 4.7 Average Gloss for LDPE and PE/EVA — Solvent-based and
                           -                 Water-based Inks
                                                   VVW
                                                   xxxxx
                                                   xxxxx
                                                   vv/v
                                                   xxxxx
                                                   vv/v
                                                   xxxxx
                                                    v/v
                                     LDPE: Solvent-based ink
                                     LDPE: Water-based ink
                                     PE/EVA: Solvent-based ink
                                     PE/EVA: Water-based ink
              LDPE: Solvent-based ink
50.4
LDPE: Water-based ink
PE/EVA: Solvent-based ink
PE/EVA: Water-based ink
42.19
59.08
54.09
       Heat Resistance/Heat Seal — Solvent-based and Water-based Inks

              Only samples printed on OPP and then laminated were tested. Heat resistance/heat seal was
              measured on blue, green, and/or white printed areas. Table 4.15 presents a summary of the
              heat seal data. A range of 12 to 24 measurements were taken from each site.  The number
              of measurements depended on where they were taken (e.g., beginning, middle, or end of the
              run), what ink color was tested, and whether ink transferred to a printed or imprinted
              substrate.

              The solvent-based and water-based inks exhibited mixed results for heat resistance/heat seal.
              For instance, Solvent-based ink #S2 experienced 100% failure at Site 10 but 100% success
              at Site L4. These results suggest that other factors, such as the lamination process, might
              have affected the results.
                                           4-29

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CHAPTER 4
           PERFORMANCE
                      Table 4.15 Heat Resistance/Heat Seal Results •
                                              Water-based Inks
• Solvent-based and
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.
                                             4-30

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CHAPTER 4
                                                                               PERFORMANCE
                      Table 4.16 Ice Water Crinkle Adhesion 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
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.
               ajhree 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 ran. 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.
                                             4-31

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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
maqenta
cyan
magenta
cyan
magenta
cyan
magenta
cyan
magenta
cyan
magenta
cyan
maqenta
cyan
maqenta
cyan
maqenta
cyan
magenta
cyan
maqenta
cyan
maqenta
cyan
maqenta
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
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 imprinted 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.
                                               4-32

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CHAPTER 4
PERFORMANCE
                       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
Score'
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.
                "Printed samples were scored on a scale from 0 to 5, with 0 signifying no odor, and 5 signifying
               an unpleasant, offensive odor.


       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
                                              4-33

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CHAPTER 4
                                                                             PERFORMANCE
              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 in 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
                                             4-34

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CHAPTER 4
                                         PERFORMANCE
               Figure 4.9 Average Mottle Index for PE/EVA — Solvent-based and Water-based
                                              Inks
                 1000-1
                  800


                  600


                  400


                  200


                     0
                            Solvent-based ink

                            KS  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
                  600-1

                  500-

                W400-
                
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CHAPTER 4
                                                                              PERFORMANCE
       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.
                                             4-36

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CHAPTER 4
PERFORMANCE
                Table 4.19 Wet Rub 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)9
4.2
5.0
no failure at 1 0 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 10 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.
                                              4-37

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CHAPTER 4
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-based inks 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.
                                             4-38

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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
              LDPE: Solvent-based ink
       98.4
LDPE: Water-based ink
PE/EVA: Solvent-based ink
PE/EVA: Water-based ink
104.8
98.7
86.9
                  100
                ex
                S
                         Figure 4.12 Average Trap for OPP— Solvent-based and
                                         Water-based Inks
                           Solvent-based ink
Water-based ink
                Solvent-based ink
       98
                Water-based ink
      87.8
                                         4-39

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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. COF, 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 performance 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 separately on the ultraviolet-cured ink system, because flexographic
               printing technology using this UV inks on  wide-web presses, particularly using film
               substrates, was still in a developmental phase at the time this research was performed
               (November 1996—March 1997).  Therefore, the results using UV-cured inks should be
               viewed as a snapshot of the technology under field conditions during that time period rather
               than as representative of the capabilities of UV inks now or in general.  Since that time,
               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.

               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.

               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
                                             4-40

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CHAPTER 4
PERFORMANCE
               products.  As is true for the solvent-based and water-based ink systems, 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
Resistance8
2.5
1.4
1.0
                aThe 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.
                                              4-41

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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 GEE 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
qreen
blue
magenta
cyan
qreen
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
34.60
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
                                           4-42

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CHAPTER 4
                PERFORMANCE
       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
                                  UV ink
                          Blue ink
Green ink
UV ink (no slip)

    White ink

Blue ink
Green ink
White ink
UV ink
1.92
2.77
3.51
UV ink (no slip)
1.94
2.98
3.71
                                           4-43

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CHAPTER 4
                                                              PERFORMANCE
                       Figure 4.14 Average Coating Weight for PE/EVA •
                   3.5 -i
                                                       • UV-cured Inks
                     3-
                 $2.5 H
o
*5
                     2-
                 CO
                 *  1-1
                 TO  1 -
                 CO
                 80.5-
                                                   UVink
                                      Blue ink
                   Blue ink
                                        Green ink
                                          UVink
                                           3.07
                   Green ink
       Coefficient of Friction — UV-cured Inks
                                            2.1
               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-tin"
31.2
20.8
25.9
36.9
Ink-Ink"
53.8
21.3
24.7
60+d
Control"
23.3
16.7
16.7
45.0
                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.
                ""Control" represents the coefficient of friction for unprinted substrate on unprinted substrate.
                "The angle of inclination was higher,than 60 degrees.
                                              4-44

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CHAPTER 4
                     PERFORMANCE
       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 -|
                                   UVink

                                  Magenta ink
                                  Green ink
    UV ink (high slip)
Cyan ink
Blue ink

Magenta ink
Cyan ink
Green ink
Blue ink
UV ink
1.68
- 1 .34
1.17
1 .88
UV ink (high slip)
1.09
1.25
1.46
2.17
                                            4-45

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CHAPTER 4
                     PERFORMANCE
                          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
UV (no slip)
Film
LDPE
PE/EVA
LDPE
Product
Line
#U2
#U2
#U3
#U1
Site
6
6
8
11
Average
Width (mm)
54.34
54.24
54.08
54.25
Average Length
(mm)
77.24
77.92
75.83
77.86
        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.  Due to the
                                            4-46

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CHAPTER 4
                     PERFORMANCE
              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-i
               UVink
                               UVink
UV ink (no slip)
       46.83
               UV ink (no slip)                     |               32.31

       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
Ink
UV
UV
(no slip)
Film
LDPE
PE/EVA
LDPE
Product
Line
#U2
#U2
#U3
#U1
Site
6
6
8
11
Any Ink Removal?
yes, less than 1 5%
yes, less than 1 5%
no
no
        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 microns
                                            4-47

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CHAPTER 4
PERFORMANCE
              (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
Ink
uv
UV (no slip)
Film
LDPE
PE/EVA
LDPE
Product
Line
#U2
#U2
#U3
#U1
Site
6
6
8
11
Color
magenta
cyan
magenta
cyan
magenta
cyan
magenta
cyan
Average
Dot
Area
(micron2)
716.28
966.98
672.38
892.23
480.28
384.78
456.52
571.66
Average
^Dot
Perimeter
(microns)
113.05
134.64
101.13
138.79
91.78
80.60
80.80
93.08
                                           4-48

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CHAPTER 4
PERFORMANCE
       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
Ink
UV
UV
(no slip)
Film
LDPE
PE/EVA
LDPE
Product Line
#U2
#U2
#U3
#U1
Site
6
6
8
11
Relative
Score'
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.
                                             4-49

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CHAPTER 4
                                                                            PERFORMANCE
       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
                                    UVink
UV ink (no slip)
1
Blue ink
Green ink
| Blue ink |22 (
UVink
281
73
Breen ink
UV ink (no slip)
382.5
47
                                             4-50

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CHAPTER 4
                          PERFORMANCE
                        Figure 4.19  Average Mottle Index for PE/EVA — UV-cured Inks
                   500-i
                                    Blue ink
UVink

     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.
                                           4-51

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CHAPTER 4
PERFORMANCE
       Rub Resistance — UV-cured Inks
                                                                                            1
              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
Ink
UV
UV (no slip)
Film
LDPE
PE/EVA
LDPE
Product Line
#U2
#U2
#U3
#U1
Site
6
6
8
11
Failure at Number of Strokes
(average)3
5.2
4.2
2.3
2.2
                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.  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
UV
(no slip)

Film

LDPE
PE/EVA
LDPE


Product Line

#U2
#U2
#U3
#U1


Site

6
6
8
11

Number
of
Passes
2
0
1
4

Number
of
Failures
2
4
2
0


Comments

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.
                                             4-52

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CHAPTER 4
PERFORMANCE
       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
UV (no slip)
Film
LDPE
PE/EVA
LDPE
Product Line
#U2
#U2
#U3
#U1
Site
6
6
8
11
Average
Percent of Ink
Removed
(bv 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 1997, since which time flexographic
              printing technology for UV-cured inks has made significant advances.  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 hi 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 the
              incomplete curing observed with these two product lines. The opacity level (measured for
                                             4-53

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CHAPTER 4
PERFORMANCE
               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.

       Technological Development in UV-cured Inks

               With any new technology, changes can occur rapidly, and UV-cured inks are no exception.
               Recent formulation and equipment improvements are addressing some of the limitations for
               UV-cured inks seen in the performance demonstrations for this  CTSA.  For example,
               cationic inks (as opposed to the free-radical UV inks in the 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. 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 in 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 hi 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. Early concerns with cationic inks included 1) that the reaction process causes the
               ink to shrink, which can affect the ability of the ink to bind to the substrate,  2) the reaction
               can be inhibited by the presence of oxygen for some applications, and 3) unreacted epoxide
               molecules can have an unpleasant odor.1  These concerns have  largely been addressed
               through formulation and equipment improvements.2

               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 electron-deficient ions,
               rather than the binding of electronically-neutral but unstable radicals.
                                              4-54

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CHAPTER 4
PERFORMANCE
               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.3

               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.4 In addition, cationic inks can produce a high gloss and
               good adhesiveness, and thus can prevent the need for costly lamination on certain products.5

               Several disadvantages, however, currently make cationic 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.6  The final product printed with cationic
               inks does not have as much solvent resistance as free radical inks.7 The drying of cationic
               inks are can be affected by moisture and high humidity, so that until the problem is resolved,
               cationic inks cannot be used universally in all geographic locations.8 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.9

               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.10 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.11  Also, the resistance of inks to water damage has been improved by developing
               additives that  make the ink more durable.12

               Temperature  Control
               Temperature management with central impression drum presses (which include most wide-
               web presses) equipped with UV curing equipment has been a challenge.  If the conditions
               are not managed properly by the press manufacturer, 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 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.13
                                              4-55

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                                                                              PERFORMANCE
              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.14 Another recent improvement has been the development of special dichroic
              reflectors, which absorb infrared energy while directing UV rays to the desired coating.15

               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.16
               It has been estimated that a UV/EB hybrid press consumes 35 percent less energy and
              produces less heat.17 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.18

               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 could affect dot gain.19-20> 21
 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.
                                              4-56

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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
Ink
Water-based
Water-based

Water-based

Water-based
Solvent-based

0V


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
ffi/minV
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
              a 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
Item
Ink type used
Control equipment
Annual production
Operating hours
Avg. production run
Description .
100% 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
                                           4-57

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PERFORMANCE
                  Table 4.33 Press Information for the Performance Demonstration at Site 1
Item
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
Descrlotion
Amber Press, Central Impression
55 inches wide, eight-color
Reverse
500 feet/minute
0.067" Dupont EXL photopolymer:
1) Two process plates (magenta and cyan) mounted
using 0.020 hard stick back
2) Three line plates (green, blue, and white) mounted
using 0.020 hard stick back
Pillar, Model DB5673-1 6
Chambered
Steel
Peristaltic air pump, pumping from semi-covered five-
gallon buckets
                       Table 4.34 Color Sequence and Anilox Configurations for Site 1
Sequence
Deckl
Deck 2 — Not Used
Decks
Deck 4
Deck 5 — Not Used
Deck6
Deck 7 — Not Used
DeckS
Color
Blue
—
Cyan
Green
—
Magenta
—
White
Anilox ID!"
280
—
800
280
—
800
—
280
Anilox BCMb
7.0
—
1.7
6.4
—
1.7
—
7.5
               alines per inch
               "billion cubic microns per square inch
                Table 4.35 Summary Information from the Performance Demonstration at Site 1
Substrate
OPP
I Press speed
I 430ft/min
I Run time
I 129 minutes
i Run lenath I
I 51 .000 feet I
                                           4-58

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               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
Ava. 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, includina 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
system
Description
UTECO,Quarz140
54 inches wide, six-color
Surface ,
500 feet/minute
0.107" Dupont EXL phptopolymer:
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
                                            4-59

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CHAPTER 4
PERFORMANCE
                       Table 4.38 Color Sequence and Anilox Configurations for Site 2"
Seauence
Deck 1
Deck 2
Deck 3 — Not Used
Deck 4
DeckS
Deck 6
Color
White
Green
—
Magenta
Blue
Cyan
Anilox loib
360
300
—
360
280
360
Anilox BCM°
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
IS u b st rsto
LDPE
PE/EVA
Press soeed
403ft/min
403 ft/min
Run time
93 minutes
102 minutes
Run lenath
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 duty, 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.
                                              4-60

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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, which is a
two-roll without doctor blade
Not given
Peristaltic air pump in five-gallon bucket
                                        4-61

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CHAPTER 4
PERFORMANCE
                       Table 4.42 Color Sequence and Anilox Configurations for Site 3"
Seciuence
Deck 1
Deck 2
Deck 3
Deck 4
DeckS
Deck 6 — Not Used
Color
White
Magenta
Cyan
Green
Blue
—
Anilox lpib
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
                cbillion cubic microns per square inch
                 Table 4.43 Summary Information from the Performance Demonstration at Site 3
Substrate
LDPE
PE/EVA
Press soeed
218ft/min
430 ft/min
Run time
126 minutes
131 minutes
Run lenath
I
26,927 feet I
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.
                                              4-62

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              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
Ava. production run
Description
1 00% 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
Seauence
Deck 1
Deck 2
Decks
Deck 4
Deck 5 — Not Used
Deck 6
Color
Blue
Cyan
Green
Magenta
—
White
Anilox loia
250
800
250
600
—
250
Anilox BCMb
6.1
2.2
6.8
2.7
— -
6.3
               alines per inch
               "billion cubic microns per square inch
                                          4-63

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                                                                            PERFORMANCE
                Table 4.47  Summary Information from the Performance Demonstration at Site 4
Subst 1*3^6
OPP
Press soeed
450 ft/mina
Run time
123 minutes
Run lenath I
13,1 60 feet |
                    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
              in 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
ItGITI
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
                                             4-64

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CHAPTER 4
                                                                           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
Windmoller & Holscher, Central Impression
24 inches wide, six-color
Surface
400 feet/minute
0.1 07" Dupont EXL photopolymer:
1 ) Two process plates (magenta and cyan)
using compressible stick back
2) Three line plates (green, blue, and white)
using hard stick back
mounted
mounted
None
Enclosed doctor blade
Stainless steel
Closed-loop, air-powered
                      Table 4.50 Color Sequence and Anilox Configurations for Site 5a
Seauence
Deckl
Deck 2 — Not Used
Deck 3
Deck4
Decks
Decks
Color
White
• . —
Green
Blue
Magenta
Cyan
Anilox ID!"
300
—
240"
240
550
550
Anilox BCMC
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 lenath
21 ,924 feet
20,858 feet
             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
                                          4-65

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CHAPTER 4
                                                                             PERFORMANCE
              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
Itorn
Ink type used
Control equipment
Annual production
Operating hours
Avg. production run
Description
60% solvent-based inks, 35% water-based inks,
5% UV inks
and
-\_
Charcoal adsorption
8 million pounds of polyethylene, polypropylene,
flexographic-printed products
and paper
24 hours per day, 4.5 days per week
Six to eight hours
                    Table 4.53  Press Information for the Performance Demonstration at Site 6
                 Item
                                             Description
                 Press
                                             Cobden Chadwick
                 Size of press
32 inches wide, six-color
                 Printing type
Surface and reverse
                 Production speed
250 to 350 feet/minute
                 Plates
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	
                 Corona treater
Q.C. Electronics
                 Ink metering system
Chambered
                 Type of doctor blade
Unknown
                 Ink pumping and mixing
ARO. model 65736-003. air-powered, with diaphragm
                                              4-66

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CHAPTER 4
PERFORMANCE
                        Table 4.54 Color Sequence and Anilox Configurations for Site 6a
Seauence
Deck 1 -
Deck 2
Deck 3
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
                "lines per inch
                cbillion cubic microns per square inch
                Table 4,55 Summary Information from the Performance Demonstration at Site 6
Substrate
LDPE
PE/EVA
OPPb
Press soeed
344 ft/mina
354ft/min
344 ft/min
Run time
92 minutes
95 minutes
38 minutes
Run lenath
32,431 feet
27,691 feet
6.853 feet
                "Press 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.
               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.
                                              4-67

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              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 7: 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
AVQ 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
                   Table 4.57 Press Information for the Performance Demonstration at Site 7
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
Descriotion
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
                                            4-68

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CHAPTER 4
PERFORMANCE
                       Table 4.58 Color Sequence and Anilox Configurations for Site T
Seauence
Deck 1
Deck 2 — Not Used
Decks
Deck 4
Deck 5
Deck 6
Color
White
—
Cyan
Magenta
Green
Blue
Anilox loib
200
—
700
700
500
500
Anilox BCMC
8.5
—
2.0
2.0
4.0
4.0
                aDeck 1 (white ink) was not used for the PE/EVA substrate
                "lines per inch
                cbillion cubic microns per square inch
                Table 4.59 Summary Information from the Performance Demonstration at Site 7
Substrate
LDPE
PE/EVAa
Press speed
450 ft/min
—
Run time
148 minutes
—
Run lenath
42,000 feet
8.069 feet
                aThe run was aborted due to problems with the substrate.
               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.

               No samples were taken from the PE/EVA run, and no measurements were made.
                                             4-69

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CHAPTER 4
                                         PERFORMANCE
              Site 8: UV Ink #U3 on LDPE, PE/EVA, and OPP


                            Table 4.60 Facility Background Information for Site 8
               Item
I Description
               Ink type used
               Control equipment
               Annual production
               Operating hours
               Ava. production run
 This facility is a press manufacturing facility in Germany; it is
 not a commercial printing facility.  Therefore, no production
 data are available.
               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
svstem
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
                       Table 4.62  Color Sequence and Anilox Configurations for Site 8a
Sequence
Deck 1 — PE/EVA
Deck 1 — LDPE, OPP
Deck 2
DeckS
Deck 4
Color
Magenta
White
Green
Blue
Cvan
Anilox lDib
724
200
724
724
724
Anilox BCM°
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
                                            4-70

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CHAPTER 4
PERFORMANCE
                 Table 4.63 Summary Information from the Performance Demonstration at Site 8
Substrate
LDPE
PE/EVA
OPPa
Press speed
262 ft/min
262ft/min
262 ft/min
Run time
65 minutes
63 minutes
15 minutes
Run lenath
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.

               Site9A:  Water-based Ink #W4 on OPP
                             Table 4.64 Facility Background Information for Site 9A
Item
Ink type used
Control equipment
Annual production
Operating hours
AVQ, production run
Description
100% water-based
None
300 million linear feet
Two 1 2-hour shifts per day
8 to 12 hours
                                              4-71

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CHAPTER 4
PERFORMANCE
                 Table 4.65 Press Information for the Performance Demonstration at Site 9A
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
Kidder Stacey
45.5 inches wide, eight-color
Reverse
500 feet/min
0.067" Dupont PQS photopolymer:
1 ) Two process plates (magenta and cyan) mounted
using 3M 1 020, 0.020 compressible stick back
2) Three line plates (green, blue, and white) mounted
using 3M 1020, 0.020 compressible stick back
Enercon
Chamber *
White steel
Powerwise, air-powered
                      Table 4.66 Color Sequence and Anilox Configurations for Site 9A
Sequence
Deck 1 — Not Used
Deck 2
DeckS
Deck 4 — Not Used
DeckS
Deck 6
Deck 7 — Not Used
Deck 8
Color
—
Blue
Cyan
—
Magenta
Green
—
White
Anilox loia •
—
400
550
—
550
400
—
300
Anilox BCM"
—
4.0
2.7
—
2.7
4.0
—
5.5
               "lines per inch
               'trillion cubic microns per square inch
                   Table 4.67 Summary Information from the Performance Demonstration
                                               at Site 9A
I Substrate
LOPP
I Press speed
I 425ft/min
I Run time
I 66 minutes
I Run lenqth I
I 34.434 feet I
                                           4-72

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CHAPTER 4
PERFORMANCE
              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.

              Site9B: Solvent-based Ink #S1 on OPP
                           Table 4.68 Facility Background Information for Site 9B
Item
Ink type used
Control equipment
Annual production
Operating hours
Avg. production run
Description
1 00% water-based
None
300 million linear feet
Two 1 2-hour shifts per day
8 to 12 hours
               Table 4.69 Press Information for the Performance Demonstration at Site 9B
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
45.5 inches wide, eight-color
Reverse
500feet/min
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
None
Chamber
White steel
Powerwise, air-powered
                                           4-73

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CHAPTER 4
                                             PERFORMANCE
                      Table 4.70 Color Sequence and Anilox Configurations for Site 9B
Sequence
Deck 1 — Not Used
Deck 2
Decks
Deck 4 — Not Used
Deck 5
Deck6
Deck? — Not Used
Decks
Color
—
Blue
Cyan
—
Magenta
Green
—
White
Anilox loia
—
400
550
—
550
400
—
300
Anilox BCMb
—
4.0
2.7
—
2.7
4.0

5.5
               alines per inch
               bbillion cubic microns per square inch
                   Table 4.71 Summary information from the Performance Demonstration
                                                at Site 9B
              I Substrate
Press speed
Run time
Run length
OPP
415ft/min
I 80 minutes
33.641 feet
              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
Item
Ink type used
Control equipment
Annual production
Operating hours
Ava. production run
Description
100% solvent-based
One thermal oxidizer for three presses
1 0.5 million pounds — 95% medium-density polyethylene
(MDPE), 5% low-density polyethylene (LDPE)
24 hours per day, 5 days per week, plus 25 Saturdays
24 hours
                                            4-74

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CHAPTER 4
                         PERFORMANCE
                  Table 4.73 Press Information for the Performance Demonstration at Site 10
Item
Press
Size of press
Printing type
Typical production speed
Plates
Corona treater
Ink metering system
Type of doctor blade
Ink purnping and mixing
svstem
Descriotion
Paper Converting Machine Company, model 7067
61 inches wide, eight-color
Reverse
750 to 850 feet/minute
0.107" BASF photopolymer:
1 ) Two process plates (magenta and cyan) mounted
using 3M 1 120 compressible stick back
2) Three line plates (green, blue, and white) mounted
using 3M 939 hard stick back
None
Chambered — two-blade
Unknown
Powerwise, Underwriters Laboratory, electric, 5 hp,
3450 rom . 1 1 5 to 230 volts
                      Table 4.74 Color Sequence and Aniiox Configurations for Site 10
Sequence
Deck 1 — Not Used
Deck 2
Decks
Deck 4
Deck 5 — Not Used
Deck 6
Deck 7 — Not Used
Decks
Color
—
Green
Blue
Cyan
- —
Magenta
—
White
Aniiox toia
—
250
250
800
—
800
—
250
Aniiox BCMb
—
9.8
10.1
1.75
—
1.6
—
9.0
               a!ines per inch
               "billion cubic microns per square inch
                   Table 4.75 Summary Information from the Performance Demonstration
                                                at Site 10
               I Substrate	I  Press speed
I Run time
I Run length
IOPP
600 ft/min
I 90 minutes
I 56.700 feet I
              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
                                           4-75

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CHAPTER 4
PERFORMANCE
              anilox 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 ea'sily able to adjust the printing environment to obtain the desired quality
              result.

              Site 11: UVInk#UlonLDPE(noslip)

                            Table 4.76 Facility Background Information for Site 11
Item
Ink type used
Control equipment
Annual production
Operating hours
Ava. production run
Description
80 to 85% water-based, 1 5 to 20% U V
None
50 million pounds of polyethylene flexographic-printed
products
24 hours per day, five days per week
Three hours to two weeks
                  Table 4.77  Press Information for the Performance Demonstration at Site 11
Item
Press
Size of press
Printing type
Production speed
Plates
Corona treater
Ink metering system
Type of doctor blade
Ink pumping and mixing
svstem
Descriotion
UTECO, Amber 808
61 inches wide, ten-color
Surface
820 feet/minute
0.107"DupontEXLphotopolymer: '
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
Chambered
Unknown
Arrow, air-powered, diaphragm
                                            4-76

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CHAPTER 4
PERFORMANCE
                       Table 4.78 Color Sequence and Anilox Configurations for Site 11
Seauence
Deck 1
Deck 2
Deck3— Not Used
Deck 4 — Not Used
DeckS
Deck6
Deck 7 — Not Used
DeckS
Deck 9 — Not Used
Deck 10 — Not Used
Color
White
Magenta
—
—
Cyan
Green
—
Blue
—
—
Anilox lpia
300
500
—
— •
500
360
—
360
• —
— •
Anilox BCM"
6.0
2.7
— .
—
2.7
5.6
—
5.6
—
—
                alines per inch
                bbillion cubic microns per square inch
                Table 4.79  Summary Information from the Performance Demonstration
                                                  at Site 11
I Substrate
I LDPEa
Press speed
400 ft/min
Run time
153 minutes
Run lenath I
38.400 feet I
                aThe LQPE 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 quality result.

              The samples taken at the end of the run continued to show good printability hi 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.
                                             4-77

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CHAPTER 4
PERFORMANCE
REFERENCES

1.     Schilstra, Durk. "UV Flexo: The European Situation." American Ink Maker, March 1997: 52-55.

2.     RadTech International, N.A.  Written comments to EPA, September 12, 2001.

3.     Podhajny, Richard M. "UV Flexo - Still Growing, Still Facing Challenges." Paper Film Foil
       Converter, June 1998: 64, 66-67.

4.     Schilstra, 1997, op. cit.

5.     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.

6.     Schilstra, 1997, op. cit.

7.     Midlik, Elinor R. 'TQC UV Wide Web Committee Prepares for the Year 2002." Flexo May
       1997: 150-153.

8.     RadTech International, N.A., 2001, op. cit.

9.     Otton, Dan. "Advancements in UV Ink Technology." Flexo April 1997: 58-59.

10.    Scheraga, Dan. "Energy Curing Shows Promise in Productivity, Lower Emissions." Chemical
       Market Reporter April27, 1998: 32^

11.    Lawson, Kenneth. "Status of the North American UV/EB Market." Industrial Paint & Powder
       Nov. 1996: 22-25.

12.    Scheraga, 1998, op. cit.

13.    Zinnbauer, Fred E. "Basking in the Sun With Cool UV." Flexo Aug. 1998: 64-67.

14.    Ibid.

15.    RadTech International, N.A., 2001, op.cit.

16.    Gentile, Deanna. "Ink Outlook: Steady Growth and Evolving Technologies." Paint and Coatings
       86(1996): 40-42.

17.    Teng, Andy. "Flexo Report." Ink World May/June 1996: 70.

18.    Ibid.

19.    Otton, 1997, op. cit.

20.    Lawson, 1996, op. cit.

21.    Atkinson, 1997, op. cit.
                                            4-78

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CHAPTER 5
COST
                                 Chapter 5: Cost
                                CHAPTER CONTENTS


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	.7.	 5-17
       Summary of Cost Analysis Results	5-17
       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


                                 CHAPTER OVERVIEW

This chapter presents a comparative cost analysis of  solvent-based, water-based, and UV-cured ink
systems. The costs evaluated include material, labor, capital, and energy costs. These elements were
chosen because of their importance to facility profitability, their potential to highlight differences among ink
systems, and the availability of data. Because this analysis averages industry information, it may not reflect
the actual experience of any given printing facility.

Printers who are considering switching ink systems also should evaluate other hidden costs such as
regulatory compliance, insurance, storage, clean-up, waste disposal, and permitting.  Although estimating
these cost factors is beyond the scope of this analysis, this chapter provides a qualitative discussion of these
costs.

DEVELOPMENT OF COSTS: Section 5.1 discusses the data sources and methodology used to determine
the costs of the four expense categories studied: material, labor, capital, and energy. Because each of
these costs were derived quite differently, they are discussed separately. In general, data were collected
from three types of sources: performance demonstration observations, industry surveys, and estimates by
industry contacts. Some of the costs are highly sensitive to press speed; as a result, some of the figures
are calculated based on both the press speeds observed during the performance demonstrations and the
speed specified in the project's methodology.  Uncertainties of the cost analysis are also presented. A
detailed methodology of the cost analysis is located in Appendix 5-A.
                                            5-1

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CHAPTER 5
COST
COST ANALYSIS RESULTS: Section 5.2 summarizes the overall costs based on the expense categories.
Costs are presented by ink system and by ink-substrate combination. The analysis shows the relative costs
of each ink system, and also indicates the cost drivers within each system. Detailed results of the cost
analysis are provided 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 costs, insurance
and storage costs, and costs related to worker health and natural resource use.


                               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.
     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 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
     pollution control equipment or UV curing lamps.  However, solvent-based inks had the lowest per-
     image capital costs because of the higher observed press speeds.
     Water-based inks had the lowest energy costs. The primary reason for these lower costs is that
     water-based inks did not require pollution control equipment or UV curing lamps.
     Overall, water-based Inks were the least expensive to use. Solvent-based inks were the next least
     expensive, followed by UV-cured inks.


                                        CAVEATS

     Costs were calculated based on both the observed press speeds and the methodology press speed
     of 500 feet per minute. Press speed is crucial to cost estimates because if more product can be printed
     in a given time, then fixed costs  (e.g., capital and labor) are distributed across more salable product.
     If customary press speeds at a facility are significantly different from those used for this analysis, actual
     costs may be different.
     The costs presented in this analysis do not represent all expenses encountered at a flexographic
     printing facility. One significant factor that was excluded was substrate (the material, such as film, that
     is printed). Substrates are a major expense, but because their costs are independent of the ink system,
     they were not included  in the  analysis.   Other costs, such  as  those  discussed qualitatively in
     Environmental and Regulatory Costs, also are not included in the quantitative results.
     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, oxidizers in fact
     may be required if inks exceed regulatory minimum VOC content thresholds.
                                            5-2

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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 in 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 in 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 Prices*

White
Other colors
Solvent-based ($/lb)
$1.40
$2.80
Water-based
($flb)
$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.
                                              5-3

-------
CHAPTER 5
                                                                                         COST
              Test Image Information
              Line colors: blue, green, and white
              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 ft2/image 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-subbtrate combination also are
               presented in Tables 5.2 and  5.3.  The site-specific ink  additive costs are provided  in
               Appendix 5-B.
                                               5-4

-------
CHAPTER 5
                                                            COST
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                                   5-5

-------
CHAPTER 5
                                              COST
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                                             5-6

-------
CHAPTER 5
                                   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 ftYimage x 6,000 images
=   Sx 6,000ft2
               where
                      = 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
OPP
Price
($/lb)
$0.77
$0.82
$1.50
Conversion
rate (lb/ft2)
0.0134
0.0258
0.0072
Substrate
cost per ft2
($/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 $11.4917 was used as a baseline and confirmed by performance
               demonstration site contacts in 1997.2,4,5,7,11,12,15.18
                                              5-7

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                                      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
              The overhead factor for the flexographic industry was calculated using the following
              formula:

                  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 $44.08 per hour for both a press operator and assistant.
                                Table 5.5 Summary of Labor Rate Calculations
Labor cost component
Wage rate
Fringe rate
Overhead rate
Calculation
from industry estimates
26.5% of total compensation*
0.41 times total compensation3
Total per-worker labor rate
Rate ($/hr)
$1 1 .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
                   Labor cost per 6,000 ft2 of image
=   L x 2.22 ft2/image x 6,000 images
=   L x 6,000 ft2
                                               5-8

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                                                                                          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 demonstrations 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
Averaae feet oer hour
Solvent-based | Water-based
453 (6)
27.200
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.
                                              5-9

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                                                                                          COST
                                Table 5.7 Labor Costs Based on Press Speeds
Ink
Labor
rate
($/hr)
Press
speed
(ftVhr)
Labor cost
per ft2 ft/ft2)
Average cost
per 6,000
images
Average cost
per 6,000 ft2 of
image
Based oh 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
$4408
50,000
50,000
50 000
$0.000882
$0.000882
$0 000882
$11.74
$11.74
$1 1 .74
$5.29
$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
                                                5-10

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               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 Costs*
Component
Oxidizer
Installation
Testing
Total
Cost
$200,000
$50,000
$5,000,$6,000
$255,000
                       These 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 hi 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
               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.
                                              5-11

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               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:
                                          = T*-
                   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      =  C x 2.22 fWimage x 6,000 images
                   Capital cost per 6,000 ft2 of image  =  C x 6,000 ft2

               where

                   C   =  capital  cost per ft2 ($/ft2)
                       =  hourly capital cost ($/hr) x repeat length per ft2 of image (ft/ft2) / average
                          press speed (ft/hr)

                   and

                   Depreciation rate          =   15%
                   Annual operating hours    =   4,200 hours per year
                   Hourly capital cost ($/hr)   =   A ($/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.
                                               5-12

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                           Table 5.10 Capital Costs for New Presses

Capital cost
($)
Hourly
capital cost
f$)
Cost per ft2
of image
Cost per
6,000
imaaes
Cost per
6,000 ft2 of
imaae
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
$29.08
$32.15
$38.75
$13.10
$14.18
$17.45
Based on Methodology Press Speed - 500 Feet per Minute
Solvent-based
Water-based
UV-cured
$2.6 million
$2.5 million
$2.6 million
$98.90
$95.10
$98.90
$0.00198
$0.00190
$0.00198
$26.35
$25.33
$26.35
$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
                   •   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-
                                              5-13

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COST
               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 i"rom 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.1'3'10'13'26

               Water-based to UV-cured Ink System
               Li 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.s 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
               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
                                              5-14

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CHAPTERS
                                                                COST
        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
                   Energy cost per 6,000 ft2 of image
                          =  (E + G) x 2.22 ft2/image x 6,000 images
                          =  (E + G) x 6,000 ft2
               where
                   E  =
                   G  =
electricity cost ($/kWh) x [electricity consumption (kWh/hour) / press speed
(ft/hour)] x repeat length per ft2 of image (ft/ft^)
electricity cost per ft2 ($/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 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.  Also, industry
               feedback suggests that UV-cured inks can operate with smaller-volume anilox rolls than
               were used in the study, the use of smaller-volume rolls would reduce ink consumption for
               this system relative to the other ink systems.
                                              5-15

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COST
              Productivity
              Productivity was  another, area that was not effectively captured in the  performance
              demonstrations. The performance demonstration ^ethodolbgy 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.

               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
                                              5-16

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                                                                                         COST
               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 24% more, and UV 38% 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.
                                            5-17

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CHAPTER 5
                                                                                       COST
                          Table 5.11  Cost Summary for Ink-Substrate Combinations


Solvent-based
Cost per
6,000
Cost per
6,000 ft2
Water-based
Cost per
6,000
Cost per
6,000 ft2
of image
UV-cured
Cost per
6,000
images
Cost per
6,000 ft2
of image
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)
p««jprf on Methodoloav Press Speed - 500 Feet /
LDPE
PE/EVA

$85
$72

$38
$33

$62
$52
$59
$41 (2)
$26 (2)
$30(3)
$117(2)
$86 (2)
$53 (2)
$39 (2)
n/aa
yer Minute
$28
$24
$27
$103
$57

$46
$26
n/aa
               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 amisrepresentation 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.
                                              5-18

-------
CHAPTERS
COST
                        Table 5.12 Cost Breakdown for Ink-Substrate Combinations
Substrate
LDPE
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)
UV-cured
Component
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
capita)
energy
total
materials
labor
capital
energy
total
Average cost
per 6,000
images
$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
Average cost
per 6,000 ft2 of
image
$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
49%
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.
                                           5-19

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CHAPTER 5
                                                                                        COST
                     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
6.000 images
$102
$82
$73
$109
$123
$111
$89
$106
$64
$53
$83
$89
$76
$67
$71
$66
$61
Cost per 6,000
ft2 of Image
$46
$37
$33
$49
$56
$50
$40
$26
$29
$24
$37
$40
$36
$31
$32
$30
$27
r\/ar
                n/a = not applicable; there were no successful runs of UV-cured ink on OPP in the performance
               demonstrations.
        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 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.
                                              5-20

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CHAPTER 5
                                                                                         COST
     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
linages
$40.15
$23.22
$62.79
$29.83
$12.78
$18.85
$26.51
$21.58
per
6,000ft2
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 in the performance
demonstrations.
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.
                                             5-21

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CHAPTER 5
                                                                                         COST
                              Table 5.15 Summary of Average Labor Costs from
                                      the Performance Demonstrations
Substrate
LDPE
PE/EVA
OPP
Solvent-based
per 6,000
images
$13.88
$13.88
$1 1 .98
per 6,000
ft2 of
image
$6.25
$6.25
$5.39
Water-based
per 6,000
Images
$20.77
$14.13
$13.52
per 6,000
ft2 of
Image
$9.35
$6.36
$6.08
UV-cured
per 6,000
images
$15.89
$19.52
per 6,000
ft2 of
image
$7.15
$8.78
n/aa
               an/a = not applicable; there were no successful runs of UV-cured ink on OPP in the performance
               demonstrations.                                            .
               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 press 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%.
                                               5-22

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CHAPTERS
COST
                             Table 5.16 Estimated Capital Costs for New Presses
Ink
Cost per 6,000 images
Cost per 6,000 ft2 of image
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 Methodology Press Speed - 500 Feet per Minute
Solvent-based (5 sites)
Water-based (7 sites)
UV-cured (4 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 4.7% 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.
                                             5-23

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CHAPTER 5
                                                                                        COST
                    Table 5.17 Estimated Energy Costs for Each Ink System



Average electricity costs
per
6,000
per
6,000 ft2
of image
%of
total
Average
natural gas costs
per
6,000
images
per
6,000 ft2
of image
%of
total
Total
per
6,000
Images
per 6,000
ft2 of
image
Based on Observed Performance Demonstration Press Speeds
.DPE
PE/EVA
OPP
Solvent-based
Water-based
UV-cured
Solvent-based
Water-based
UV-cured
Solvent-based
Water-based
UV-cured
$0.77
$0.67
$3.09
$0.77
$0.45
$3.80
$0.67
$0.43
$0.35
$0.30
$1.39
$0.35
$0.20
$1.71
$0.30
$0.19
55%
47%
100%
55%
47%
100%
55%
47%
$0.64
$0.74
$0.00
$0.64
$0.50
$0.00
$0.55
$0.48
$0.29
$0.33
$0.00
$0.29
$0.23
$0.00
$0.25
$0.22
45%
53%
0%
45%
53%
0%
45%
53%
$1.41
$1.40
$3.09
$1.41
$0.95
$3.80
$1.22
$0.91
$0.64
$0.63
$1.39
$0.64
$0.43
$1.71
$0.55
$0.41
There were no successful runs of UV-cured ink on OPP in the performance
demonstrations.
Based on Methodoloav Press Speed - 500 Feet per Minute

Solvent-based
Water-based

$0.66
$0.38
$2.29
$0.30
$0.17
$1.03
55%
48%
100%
$0.53
$0.41
$0.00
$0.24
$0.18
$0.00
45%
52%
0%
$1.19
$0.78
$2.29
$0.53
$0.35
$1.03
 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 paying for excess
               raw materials.

        Regulatory Costs

               As indicated in Chapter 2, several regulations may impact costs for flexographic printers.
               Compliant-- 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 permitting and
               reporting. Some of the relevant federal laws and requirements are discussed in Chapter 2.

-------
CHAPTER 5
COST
              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 environmentafcosts 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.
                                             5-25

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CHAPTER 5
                                                                                COST
REFERENCES

1.     Argent, Dave. Progressive Inks. Written comments to Laura Rubin, Industrial
       Technology Institute. June 1997.

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.

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.

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.

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.
                                          5-26

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CHAPTER 5
COST
17.    Darney, Arsen J., editor. Manufacturing USA; Industry Analysis, Statistics, and Leading
       Companies. 4th   Edition, Volume 1.  Gale Research, Inc., Detroit; pp.733., 1994.

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. DfE 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.  7957 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.
                                        .  5-27

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CHAPTER 5
COST
                             This page is intentionally blank.
                                         5-28

-------
CHAPTER 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	6-3
       Limitations and Uncertainties	6-5
       Ink and Press-side Solvent 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	 6-24
       Environmental Impacts of Energy Production 	,			6-26
       Limitations and Uncertainties	6-26


6.4  CLEAN-UP AND WASTE DISPOSAL PROCEDURES	6-29
       Press Clean-Up and Waste Reduction in the CTSA Performance Demonstrations	6-30


REFERENCES	-	• 6-32
                              CHAPTER OVERVIEW

This chapter discusses resource and energy use in flexographic printing and identifies opportunities for
conservation. By minimizing resource and energy use, companies can improve the environment as well as
their bottom line.  Data presented in this chapter are based on information collected during the on-site
performance demonstration runs and information from equipment vendors.  Ink and energy consumption
data presented in this chapter are used in the cost analysis (Chapter 5) to calculate ink and energy costs.
Inkconsumption data are also used to estimate environmental releasesforthe risk characterization (Chapter
3).                                                    .

INK AND PRESS-SIDE SOLVENT AND ADDITIVE CONSUMPTION: Section 6.1 presents the comparative
ink and press-side solvent and additive consumption rates for solvent-based, water-based, and UV-cured
ink systems. This analysis is based on the weights of inks, solvents, and additives, and on the substrate
usage recorded by an on-site observer from Western Michigan University (WMU) at each demonstration
site.

ENERGY CONSUMPTION. Section 6.2 discusses the energy requirements of the drying systems, corona
treaters, and pollution control equipment (catalytic oxidizers) typically used with the different ink systems.
Electrical power and/or gas consumption data were collected by WMU and supplemented by energy
estimates from equipment vendors. Due to the variability among equipment and  operating procedures at
                                         6-1

-------
CHAPTER 6
RESOURCE AND ENERGY CONSERVATION
the different test sites, equipment vendor estimates, rather than site-specific data, are used in the cost
analysis to calculate energy costs.

ENVIRONMENTAL IMPACTS OF ENERGY REQUIREMENTS:  Section 6.3 presents the environmental
impacts of electricity generation and natural gas combustion, using software that quantifies emissions. The
results are calculated for each ink system based on the rate of energy consumption at the methodology
press speed (500 feet  per  minute) and the average press  speeds  observed at the performance
demonstrations.

CLEAN-UP AND WASTE DISPOSAL PROCEDURES: Section 6.4 discusses the clean-up procedures
used at the performance demonstration sites, as well as some of the broader life-cycle issues associated
with energy and natural resource use.


                             HIGHLIGHTS OF RESULTS

   »   UV-cured inks had the lowest ink consumption rates. In addition, UV inks required almost no
       press-side additions.  Solvent-based inks had the highest consumption rates for ink and materials
       added at press-side.
   •   Water-based inks consumed the least amount of energy (assuming pollution control equipment
       is not needed).  At a press speed of 500 feet per minute, UV-cured inks 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.
   •   For solvent- and 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

   •   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 could have 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 section only considers equipmentthat would differ among the ink systems
       Therefore, drying/curing equipment is included, but substrate winding equipment and ink pumps are
       not.
   •   Except for 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 at different energy speeds, but it is assumed in this analysis that their energy
       consumption is constant. Therefore, the energy consumption of UV lamps may be overestimated
       at lower press speeds.
   •   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.	
                                            6-2

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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 main 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 solution (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.
                                       iHadd-pr ~ *r " ^s "*" On "
              where
                 Ipre =
                 IT

                 Is
 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
k =  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
              Ink Consumption
              Ink consumption was  calculated for  each demonstration  site  using  the  following
              information:

                 •   total amount of ink consumed during makeready and the press run (Itotai)
                 •   amount of substrate printed (S)
                 •   total area of the image (16 by 20 inches with a 16-inch repeat)

              Substrate consumption was recorded from the press meter at the beginning of makeready,
              at the end of makeready, and at the end of the press run for each substrate. The consumption
              numbers are listed in Appendix 6-A.
                                            6-3

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CHAPTER 6
        RESOURCE AND ENERGY CONSERVATION
              Sample calculations for white, water-based ink at Site 1 follow, to help readers understand
              the methodology and to allow reproducibility of results. The complete data are provided in
              Appendix 6-A.
                  Total white ink consumed (1^) = 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
= 8/1.33 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  = (WN) 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% coverage,
               and cyan and magenta (process colors) account for 5.2% coverage.
                                        Table 6.1 Image Area by Color
Color
Blue
Green
White
Cyan
M3.G6ntcL
Area (in2)
43.5
33.5
194.7
8.2
8.2
Area (ft2)
0.30
0.23
1.35
0.06
0.06
Percent coverage (%)"
13.6
10.5
60.8
2.6
2.6
               The total percent coverage does not equal 100% because ot overlapping colors ana unprmu
               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.

               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
                                              6-4

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CHAPTERS
RESOURCE AND ENERGY CONSERVATION
              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:
    = 20.90 Ibs
    ^J = 4.81 Ibs
                  Weight of blue ink added to system
                  Weight of solvent added to the blue ink
                  Total ink used (IT) = 18.16 Ibs
                  Total components added (T) = Iadded+	
                                            = 20.90 lbs"+4.81 Ibs
                                            = 25.71 Ibs
                                            = 20.90 Ibs / 25.71 Ibs
                                            = 0.81
                  RatioofSaddedtoT(Rs)      = 4.81 Ibs 725.71 Ibs
                                            = 0.19

                  Weight of ink consumed = IT x Rj
                                            = 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 pilot
              line in Germany. As such, the data represent a "snapshot" of how the inks performed at the
              time of the performance demonstrations (November 1996 — March 1997) under actual
              operating conditions at a limited number of facilities. Because no two printing plants are
              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.
                                             6-5

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CHAPTER 6
                                                    RESOURCE AND ENERGY CONSERVATION
               These included target specifications for anilox rolls (screen count and anilox volume) which
               directly affect the amount of ink applied to print an image.

               The specified target ranges for the anilox rolls were hot always met.  Because of the
               production needs of the volunteer facilities, changing anilox rolls or acquiring new anilox
               rolls to meet the  specified targets  was impractical.  Table 6.2 lists the target anilox
               specifications and the average configurations by ink type for the anilox rolls actually used
               at the 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 light colors would
               be larger than those for dark colors.
                   Table 6.2 Average Anilox Configurations and Target Anilox Specifications
Ink
Target
Solvent-
based
Water-based

Screen count (lpi)a
Line
(color)
440
350
290

Line
(white)
150
260
300
250
Process
600 to
700
650
580
610

Line
(color)
4to6
5.5
6.3
4.9
Line
(white)
6 to 8
6.8
5.9
7.3
Process
1.5
2.1
3.0
3.3 -
                alines per inch
                bbillion cubic microns per square inch
                Uncertainties in Ink Component Weights
                As discussed previously, the on-site observer collected information on the amounts of ink,
                solvents, additives, and cleaning solution added to or removed from the system during
                makeready, the press run, and clean-up. In some cases, however, site operating procedures,
                such as the type of. cleaning system being used, prevented measurement of some of these
                parameters. In these cases, the weights were estimated based on other site data.

         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
                                                6-6

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CHAPTERS
RESOURCE AND ENERGY CONSERVATION
              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-eured ink demonstration sites, except for
              a low-viscosity monomer added to the green ink at Site 11.
                                            6-7

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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 CTS A 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.
                            Table 6.5 Equipment Evaluated in the Energy Analysis
Equipment
Hot air drying
system
Catalytic
oxidizer"
Corona treater
UV curing
system
Function
Dries the ink between stations and in
the overhead tunnel (main) dryer.
Converts VOCs to carbon dioxide and
water.
Increases the surface tension of the
substrate to improve ink adhesion.
Cures UV-cured ink applied to
substrate.
Ink system
Solvent-
based
•
•


Water-
based
•

•

UV-
cured


•
•
                In some states, oxidizers may be required for water-based inns witn nign vuo comeni
               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 made:
               one using the project methodology press speed of 500 feet per minute (fpm) for all three ink
                                              6-10

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CHAPTERS
     RESOURCE AND ENERGY CONSERVATION
              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
Parameter
Press
Press
speed
Substrates
Web width
Image size
Description
48-inch, 6-color, Cl press; new, average
quality
Solvent-based ink: 500 fpm and 453 fpm
Water-based ink: 500 fpm and 394 fpm
UV-cured ink: 500 fpm and 340 fpm
LDPE, PE/EVA, OPP
20 inches
1 6 in x 20 in (2.22 ft2)
Comments '
Press costs are presented in
Chapter 5.
Two scenarios for each ink
system are used in the
corona treatment energy
estimates.

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

                  Natural gas per 6,000 ft2
= 6,000 ft2 / 2.22 ft2 per image
= 2,700 images
= 2,700 images / 17,800 images/hour
= 0.15 hours
= 500,000 Btu/hour x 0.15 hours   "
                                            6-11

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CHAPTER 6
     RESOURCE AND ENERGY CONSERVATION
                  Electricity per 6,000 ft2
= 76,000 Btu
= 31.6 kWx 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 T3-1-""-*
              blowers are used to draw the heated air though the dryers to the exhaust outlet.
                                        Exhaust
               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
PdrdiviQt&r
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 recirculatibn of
diver air
Assumption 1 Comments
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 box8
Typical value for 48-inch press3
Typical temperature for Project substrates8
Typical temperature for Project substrates8
Three scenarios
Two scenarios
                cfm = cubic feet per minute.
                a Reference 4.
                                               6-12

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CHAPTER 6
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 recirculatiori 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 the 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.6 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.
                                              6-13

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                                                     RESOURCE AND ENERGY CONSERVATION
                                   Table 6.8 Catalytic Oxidizer Assumptions
Parameter
Number of
presses vented
io 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 cf m
150°F
600°F
70 Ib/hr
140lb/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°F8A10-11'a
Solvent loading for two presses; solvent loading at
performance demonstration sites averaged 35 Ib/hr
for one press.
Solvent loading assuming each 48-inch press is
running two 20-inch images, side by side (i.e., solvent
loading 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.
        a 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.
                                               6-14

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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, in 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).,
                                            6-15

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CHAPTER 6
                                                    RESOURCE AND ENERGY CONSERVATION
                                  Table 6.9 UV Curing System Assumptions
Dora motor
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 requirements under
               a particular set of conditions. They are not necessarily indicative of the range of energy
               requirements that might be experienced for different images, substrates and operating
               conditions, nor are they intended to represent this range.

               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 facto-s. 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
                                               6-16

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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 tor 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.
                                             6-17

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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 50°F 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 applicable
                                      6-18

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CHAPTER 6
RESOURCE AND ENERGY CONSERVATION
                      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
340"
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
image (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.
               bAverage press speed for the performance demonstration sites.
                             Table 6.12  Energy Consumption per Job by Ink Type8
Equipment
Dryer"
Pollution control"
Corona treatment
UV lamps
Temperature conditioning
Driving motors/pumps
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/a°
n/a
=17,000
=550,000
=85,000
=200,000
=850,000
               "Source: Reference 15. Source did not specify the type or length of job evaluated.
               "Heater plus blower
               °n/a: not applicable
               "Pollution 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
                                              6-19

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CHAPTER 6
                                                    RESOURCE AND ENERGY CONSERVATION
                     Table 6.13  Natural Gas Energy Estimates for Hot Air Drying Systems
Ambient air
temperature (°F)
0
0
50
50
70
70
Percent air
recirculation (%)
0
50
0
50
0
50
Natural gas energy (Biu/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
               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 hi 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 ah- flow to the oxidizer, and the inlet air temperature.
                                               6-20

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CHAPTERS
RESOURCE AND ENERGY CONSERVATION
                               Table 6.14  Catalytic Oxidizer Energy Estimates8
Solvent
loading
70 Ib/hr
140lb/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
17e
16,000
17e
70%b
260,000
17e
16,000
" 17"
70%c
320,000
32*
70,000
32f
75%°
130,000
32f
n/a3
n/a
80%c
70,000
32'
n/a
n/a
               "Energy estimates are based on the assumptions 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.
               "Source: Reference 20.
               "Source: Reference 21.
               dOnekW-hr = 3,413Btu
               "Based on 22 hp blower
               'Based on 40 hp motor with volume blower
               9n/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).
               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.
                                              6-21

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CHAPTER 6
RESOURCE AND ENERGY CONSERVATION
              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
OPP
Watt density
(watts/mVmln)
20"
web"
3,100
3,100
3,100
3,100
2,300
3,100
3,100
40"
web"
6,200
6,200
6,200
6,200
4,600
6,200
6,200
Power supply
(kW)
20"
web"
3.0
3.0
3.0
3.0
3.0
3.0
3.0
40"
web"
7.5
7.5
7.5
7.5
5.0
7.5
7.5
20"
web"
ND°
2.0
ND
ND
ND
2.0
ND
40"
web"
ND
3.5
ND
ND
ND
3.5
ND
Input power
(kW)
20"
webb
ND
2.1
ND
ND
ND
2.1
ND
40"
webb
ND
3.6
ND
ND
ND
3.6
ND
              "Source: Reference 22.
              "Source: Reference 23.
              CND = 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
OPP
Watt density
(watts/mVmin)
20"
weba
2,400
2,400
2,400
2,100
1,600
2,100
2 100
40"
web*
4,700
4,700
4,700
4,200
3,100
4,200
4,200
Power supply
(kW)
20"
web"
3.0
3.0
3.0
3.0
1.5
3.0
3.0
40"
web'
5.0
5.0
5.0
5.0
3.0
5.0
5.0
20"
webb
NDC
1.5
ND
ND
ND
1.5
ND
40"
webb
ND
3.0
ND
ND
ND
2.5
ND
Input power
(kW)
20"
web"
ND
1.6
ND
ND
ND
1.6
ND
40"
webb
ND
3.1
ND
ND
ND
2.6
ND
               "Source: Reference 24.
               •"Source: Reference 25.
               CND = no data
               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
                                             6-22

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CHAPTER 6
RESOURCE AND ENERGY CONSERVATION
                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)
Makereadv
6.4
1.9
4.0
3.0
ND
L_ 11-°
2.2
n/ab
Print run
NDa
ND
4.0
3.0
ND
ND
ND
n/a
               ND: no data
              bn/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 in indirect costs to society. Examples of the types of air
              emissions 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 emissions released into the environment
              from energy production and discusses the potential environmental impacts of the releases.
              For electrical energy, emissions 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.
                                            6-23

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CHAPTER 6
                                                    RESOURCE AND bNERGY CONSERVATION
       Emissions from Energy Production

               Energy-related emissions — both at and away from the facility — can be a significant part
               of the total life-cycle environmental impact of printing. Emissions are released fromnatural
               gas-burning dryers and oxidizers as well as from the electricity generation process at offsite
               power plants. The level of emissions can vary considerably among printing technologies,
               depending on the fuel type and process efficiency.

               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 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, and 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. It should be noted that the location of the environmental impacts will vary
               by energy type; natural gas releases will occur onsite, while electricity-related releases will
               occur at offsite power plants.                '

               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 emissions from
               energy production at either press speed, followed by solvent-based systems. The releases
               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, data were not available for all equipment 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.
                                               6-24

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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 release greater quantities of emissions .than gas-fired energy
              systems. For example, at a 500 fpm press speed, the UV system consumed an estimated 23
              kW-hr/6,OOOft2 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,OOOft2 of electricity
              plus 78,000 Btu/6,000ft2 of natural gas, for a total of 100,000 Btu/6,000ft2 .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 release rates shown in Tables 6.21 and 6.22, the water-based systems showed
              thelowestpotentialenvkonmentalimpactsfromenergyproduction,includinghumanhealth,
              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
                                                                                          j
              These release rates 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.
                                              6-26

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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 Inorganics8
Toxic Organics3
Acid Rain
Precursors
Corrosives
Dissolved Solids'3
Global Warmers
Odorants
Particulates0
Smog formers
Solid Wastes
Chemicals
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
Resource
Air
Air
Air
Air
Water
Water
Air
Air
Air
Air
Soil,
groundwater
                ' Dissolved solids are a measure of water purity and can negatively affect aquatic life as well as the
               future use of the water.
               b Toxic organic and inorganic pollutants can cause adverse health effects in humans and wildlife.
               c Particulate 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 control
               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 to develop release rates by impact category. As discussed previously,
               these release rates can be used as an indicator of relative potential environmental impacts,
               but are not an assessment of risk.
                                               6-27

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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
'I
Pollution Generated *
(g/per 6,000ft2)
Solvent
(500
fpm)
79
9,500
570
^_
Solvent
(453
fpm}
87
10,000
630
Water
(500
fpm}
48
6,500
340
^-^*™»
Water
(394
fpm)
60
8,100
410
	
uv
(500
fpm)
230
16,000
2,000
_«»«»
UV
(340
fpm}
350
24,000
2,900
               * All numbers have been rounded to two significant figures.
 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 CTSA 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
               anilpx 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. Although solvent-based waste disposal costs may be reduced because it can be
               burned and used for heat production, this is not always possible with water-based wastes.
               Regulations prohibit hazardous waste from being mixed with fuel and burned if it has an
               energy value of less than 5,000 Btu/lb.30  Therefore, some printers using low-solvent
               water-based inks use an "ink splitter" to separate the solids from fluids in their waste ink and
                                             6-29

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CHAPTER 6
RESOURCE AND ENERGY CONSERVATION
              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.)

              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.31  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.32

       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.
                                             6-30

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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)
Landfilied ( 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 (1 site)
Reused once before sending to
cement kiln (1 site)
On-site distillation; still bottoms
disposed (1 site)
No data (1 site)
Waste
Substrate
Disposition
Partially or all
recycled
(4 sites)
Partially or all
recycled
(5 sites)
Partially or all
recycled
(3 sites)
                                     6-31

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CHAPTER 6
RESOURCE AND ENERGY CONSERVATION
REFERENCES
1.     Barnard, Harris. In98a. 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 J'CT Clean Products and Clean Technologies.  May 1, 1998.

17.    Ibid.

18.    Ibid.
                                             6-32

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CHAPTERS
RESOURCE AND ENERGY CONSERVATION
19.    Ibid.

20.    Kottke, Lee. 1998. Anguil Environmental, Inc. Personal communication with Lori Kincaid,
       University of Tennessee Center for Clean Products and Clean Technologies. May 8,1998.

21.    Reschke, Darren. 1998. Op. cit. May 18,1998.

22.    Smith, Alan. 1998. SOA International, Inc. Personal communication with Lori Kincaid,
       University of Tennessee Center for Clean Products and Clean Technologies. June 3,1998.

23.    Gilbertson, Tom. 1998. Enercon Industries, Inc. Personal communication with Lori Kincaid,
       University of Tennessee Center for Clean Products and Clean Technologies. May 18,1998.

24.    Smith, Alan. 1998. Op. cit. June 3, 1998.

25.    Gilbertson, Tom. 1998. Op. cit. May 18,1998.

26.    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.

28.    U.S. EPA.  1994. P2P-Version 1.50214 computer software program.  Office of Research and
       Development, National Risk Management Research Laboratory.

29.    Energy Information Administration. 1999. Electric Power Monthly, February 1999 (with data for
       November 1998), DOE/EIA-0223(99/02).

30.    Ellison, David. 2001. Pechlney Plastic Packaging. Personal communication with Trey
       Kellett,  Abt Associates Inc. September 26, 2001.

31.    Ross, Alexander. 1999. RadTech.  Personal communication with Trey Kellett, Abt Associates.
       June 9, 1999.

32.    Shapiro, Fred. 2000. P-F Technical Services/Personal communication with Lori Kincaid,
       University of Tennessee Center for Clean Products and Clean Technologies. February 22, 2000.
                                           6-33

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CHAPTER 6
RESOURCE AND ENERGY CONSERVATION
                          This page is intentionally blank.
                                      6-34

-------
 CHAPTER 7
                                               ADDITIONAL IMPROVEMENT OPPORTUNITIES
            Chapter 7: Additional Improvement Opportunities
                                CHAPTER CONTENTS
 7.1  POLLUTION PREVENTION OPPORTUNITIES	.7.3

 7.2 RECYCLING AND RESOURCE RECOVERY	7-6
        Silver Recovery	_               '  7.6
        Sofvent Recovery	7.7
        Solid Waste Recycling	[                    7.7

 7.3  CONTROL OPTIONS	7.8
        Sources of Flexographic Ink Pollutants Amenable to Treatment or Control Options  	7-8
        Control Options and Capture Devices for Air Releases	7-8
        Control Options for Liquid Releases	    7_10
 REFERENCES
                                                                                    7-12
                                CHAPTER OVERVIEW

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.


 'Dilution 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
n Section 7.1.


Recycling, which is also sometimes called resource recovery, is the focus of Section 7.2. Although recycling
s 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
vastes can all be recycled.                                              ~
                                           7-1

-------
                                               ADDITIONAL IMPROVEMENT OPPORTUNITIES
                                   	     ____——.,—————————•==^^=^ga^=^^=
In additiorTseveral pollution control options are possible for both liquid and gaseous forms of f lexographic
ink chemicals. Section 7.3 discusses several common control options.  These technologies car. be very
successfuIinreducingwasteandemissionsintheflexographicindustry.Controloptionsthatared.scussed
in Section 7.3 include oxidizers, adsorption systems, permanent total enclosures (capture dev.ces hat work
wifhcontroloptionsbutdonotdestroyharmfulemis^
however,  often require a major capital investment, and must receive  regular mamtenance to function
efficiently  Also, even control options that destroy virtually all harmful emissions have no effect on he types
andamounVsof chemicals being purchased and used by flexographic printers. That is, they do not prevent
pollution from being generated.

-------
CHAPTER 7
   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,  m  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.
                    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
                                            7-3

-------
CHAPTER 7
                                                 ADDITIONAL IMPROVEMENT OPPORTUNITIES
               Decision-makers throughout the flexo industry also have many other opportunities to
               encourage environmental improvements and cleaner, more "sustainable" operations.
               Pollution prevention involves reducing or eliminating environmental discharges 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 obtain a number of 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. Control
               options are less desirable than pollution prevention because they manage pollutants that
               have already been created. Control technology also can break down, and require
               expensive capital and maintenance costs.

               Some opportunities for pollution prevention in flexo printing follow.

               Pre-Press
                   •   Use Computers for Proofs.and Plates:  By using computers to generate all
                       proofs and plates, printers can skip photographic development and eliminate the
                       use of darkroom chemicals.
                   •   Switch from Rubber to Photopolymer Plates: 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.
                       Photopolymer plates eliminate this waste stream as well as the metal engravings
                       and wastes generated from the production of conventional molded rubber
                       plates.
                Printing
                   •   Cover Volatile Materials: By keeping all cans, drums, and open ink fountains
                       covered, printers can reduce odors and worker health risks by minimizing
                       fugitive VOC emissions.
                    •   Install Enclosed Doctor Blade Chambers: Enclosed doctor blade chambers
                       reduce ink evaporation, which results in better control of ink usage, more
                       consistent color, and improved performance of the inks on press. Making this
                       change to an older press may greatly reduce ink evaporation, thus minimizing
                        worker exposure to hazardous chemicals.
                    •    Use Higher Linecount Anilox Rolls: This enables printers to apply smaller ink
                        droplets closer together, to achieve much finer ink distribution, easier drying,
                        and potentially faster press  speeds.
                    •   Rework Press Return Ink: 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
                        or other press return inks.                                 ,
                    •   Use Computerized Ink Blending: Software and specialized equipment help
                        printers blend ink, reduce surplus ink, and reuse press return ink.
                    •   Print with Four-Color Process: The limited number of inks in four-color process
                        printing can minimize the amount of mixed colored inks used and eliminate

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ADDITIONAL IMPROVEMENT OPPORTUNITIES
                      residues of unusual colors at the end of each job.  With chambered doctor blade
                      systems, the increased use of process printing to produce a broad spectrum of
                      colors has become more easily attainable.
                  •   Co-Extrude Colored Film: Films can be co-extruded to have panels of color in a
                      clear field, which eliminates the need for heavy coverage with colored ink.
                  •   Run Light Colors First: By running lighter jobs before darker jobs, printers can
                      reduce the number of clean-ups.
                  •   Standardize Repeat Print Jobs: Make-ready times and wate materials can be
                      greatly reduced if the press operators knows the anilox roll linecount and cell
                      volume, the sequence of colors, applied, ink parameters such as pH and
                      viscosity, and other set-up information.
                  •   Standardize Anilox Roll Inventory: This saves time during makeready and
                      reduces waste.
                  •   Use Multi-Stage Cleaning: 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.
                  •   Install Automatic On-Press Cleaning: When paired with solvent recovery, on-
                      press cleaning systems use much less cleaning solution than hand cleaning,
                      while also having a very short cycle time.
                  •   Clean Anilox Rolls Promptly: Prompt attention will prevent the inks from
                      setting, thereby reducing the need for harsh chemicals. Clean rolls also produce
                      more predictable ink densities, potentially reducing on-press waste and
                      improving quality.
                  •    Use Alternative Methods to Clean Anilox Rolls: Printers can choose among
                      many alternatives for cleaning anilox rolls to reduce or eliminate the need for
                      traditional cleaning solvents.  These alternatives use sonic cleaning, dry ice,
                      lasers, polyethylene beads, and sodium bicarbonate.
                  •    Recirculate warm press air: Both solvent-and water-based printers can
                      significantly reduce their energy requirements by recirculating warm air from
                      dryers.
              Throughout the Printing Process
                  •    Use Safer Chemicals: Switching to inks, cleaning agents, and adhesives that
                     contain a lower percentage of VOCs and fewer HAPs may reduce risks to
                     worker health and the environment.
                  •   Segregate Hazardous Waste: 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.
                  •   Return Containers: Using returnable containers prevents unnecessary waste
                     generation and results in additional cost savings.
                  •   Track Inventory: 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" rale, i.e., rotating the inks so
                                             7-5

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                                                ADDITIONAL IMPROVEMENT OPPORTUNITIES
                     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.
                     Make a Management Commitment: Management should establish,
                     co.nmunicate, 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.
                     Train Employees: 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 prevention ideas by personnel.
                      Monitor Employee Practices: Periodic monitoring helps ensure that source
                      reduction practices are followed.
                      Seek Out and Encourage Employee Initiatives: Supporting, encouraging, and
                      actively 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.
                      Develop an Environmental Management System (EMS): An EMS is a set of
                      management tools and principles designed to guide a company to integrate
                      environmental concerns into its daily business practices.
 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 loc*u
               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 ir 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.
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ADDITIONAL IMPROVEMENT OPPORTUNITIES
               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

               Rexographic 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 in any of the following ways:

                  •   Require suppliers to take back all containers and packaging.

                  •   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.
                                              7-7

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ADDITIONAL IMPROVEMENT OPPORTUNITIES
                      Peiletize 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:

                   •   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.a

               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,
               1 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 them 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.

                                                7-8

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CHAPTER 7
ADDITIONAL IMPROVEMENT OPPORTUNITIES
               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.1 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,
               construction of a PTE can be fairly modest, or it can involve a  substantial capital
               investment ranging up to tens of thousands of dollars.2 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.3
               However, since most of the cost relates to capital and construction rather than operation
               and maintenance, in 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.4 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
                                              7-9

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CHAPTER 7         .       	ADDITIONAL IMPROVEMENT OPPORTUNITIES
                                                                                              5
       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.'

       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.6  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.7

       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.8'9'10'11
       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 adsorption
       system alone has the potential to remove 95% or more of VOCs,6 and is normally used in
       conjunction with aPTE 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.4

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,
                0 Nitrogen oxides are ozone precursors.

                d The U.S. EPA's Office of Air Quality Planning and Standards "EXPOS Control Cost Manual"
                (5th 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.

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CHAPTER 7
ADDITIONAL IMPROVEMENT OPPORTUNITIES
               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.               .
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                                               ADDITIONAL IMPROVEMENT OPPORTUNITIES
REFERENCES
1.     Bemi, Dan, MEGTEC Systems. Personal communication, September 23, 1999.

2.     Mike Lukey, Pacific Environmental Science, cited in Bemi, Dan: Permanent Total Enclosure
       Technology Part 2. Flexo, April 1998, p 69.

3.     Mostafaei, Anoosheh. "Environmental Corner." Die-Line. California Film Extruders &
       Converters Association. January 2000.

4.     Bemi, Dan, MEGTEC Systems. Personal communication, September 23,1999.

5.     EPA-CICA: Air Pollution Technology Fact Sheets: Catalytic, thermal, recuperative, and
       regenerative incinerators.

6.     Rach, Steve, and Bemi, Dan: Emission controls. In The Flexo Environment (prepublication
       draft), June 11,1999.

7     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.

8.     Ellison, Dave. American National Can Company. Written comments to Laura Rubin, Industrial
       Technology Institute. June 1997.-

9.     Rizzo, Tony. Lawson Marden Label. Telephone discussion with Laura Rubin, Industrial
       Technology Institute. May 22,1997.

 10.    Steemer, Hans. Windm6ller and Holscher. Telephone discussion with Laura Rubin, Industrial
       Technology Institute. May 6,1997.

 11.    National Association of Printers and Lithographers. NAPL Heatset and Non-Heatset Web Press
       Operations Cost Study; 1989-1990. Teaneck, NJ,  1990.
                                             7-12

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 CHAPTERS
CHOOSING AMONG INK TECHNOLOGIES
           Chapter 8: Choosing Among Ink Technologies
                               CHAPTER CONTENTS
8.1 SUMMARY BY INKSYSTEM AND PRODUCT LINE	8-2
       Introduction	s-2
       Solvent-based Inks	8-13
       Water-based Inks	-..;.-.	8-16
       UV-cured Inks	8-19

8.2 QUALITATIVE SOCIAL BENEFIT-COST ASSESSMENT	 8-23
       Introduction to Social Benefit-Cost Assessment	8-23
       Benefit-Cost Methodology and Data Availability	8-25
       Potential Private and Public Costs			8-25
       Potential Private and Public Benefits ,	8-30
       Summary of Social Benefit-Cost Assessment	8-33

8.3 DECISION INFORMATION SUMMARY	8-35
       Introduction	8-35
       Ink System Comparison	 8-36
       Highlights of Chemical Category Information	8-39
       Hazard, Risk and Regulation of Individual CTSA Chemicals	8-45
       Suggestions for Evaluating and Improving Flexographic Inks	 8-62

REFERENCES				8-64
                                CHAPTER OVERVIEW

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 chemical.  Flexographic professionals
 an use this information to identify chemicals that they either may wish to avoid or may use as safer
alternatives.
                                          8-1

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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 in 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.
                                               8-2

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CHAPTER 8
CHOOSING AMONG INK TECHNOLOGIES
                        Table 8.2 Selected Key Performance Indicators
Indicator
Blocking
Gloss
Ice Water
Crinkle
Mottle
Trap
Description
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 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).
Measures the integrity and flexibility of the ink on
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.
Measures the spottiness or non-uniformity of an ink
film layer.
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.
Scale
0-5
0-100
0-100
Open-
ended
0-100%
Interpretation
0 = no blocking and
a good ink-substrate
bond.
5 = complete blocking
or removal
Higher numbers
indicate higher
reflectivity
0 = intact ink finish
100 = complete
removal of finish
Lower values indicate
a more consistent
finish. Higher values
indicate a more
variable finish.
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 with the baseline results in Table 8.3 through the
              use of &• (better than the baseline) or X (worse than the baseline).

              Table 8.4 summarizes the human health risks of each product line. Three categories of
              information are included in this table.
                                             8-3

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CHAPTER 8
                                                      CHOOSING AMONG INK TECHNOLOGIES
                  •   Range of chemicals with clear concern for risk: This column shows the total
                      number of compounds with a clear health risk" to pressroom workers for each
                      formulation in a product line. For example, if two chemicals with a clear concern
                      for 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 a  clear concern for occupational  risk to  flexographers based on either
                      lexicological studies or EPA's Structure Activity Team (SAT) assessments.
                  •   Categories with chemicals of clear concern for risk: Lists the chemical categories
                      that contained at least one chemical with a clear concern for inhalation risk to
                      pressroom workers or dermal risk to press- and prep-room workers. Superscripts
                      next to each category name indicate whether the compounds presented a clear
                      concern for risk through inhalation (inhal) or dermal (derm) exposure. Categories
                      are denoted with "(SAT)" if the compound with  a clear concern for risk was
                      analyzed by the SAT.  An SAT evaluation is considered to be a less  accurate
                      measurement method than toxicological information. (See 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 severity 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.
                   •   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.
                "Clear concu n for risk indicates that for the chemical in question under the assumed exposure
                conditions, adverse effects are predicted to occur. Section 3.7 of the CTSA has more information
                about risk rankings.
               —.                      -       —                        -            -      -

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                     CHOOSING AMONG INK TECHNOLOGIES
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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 in the wide-web film industry segment. 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 a clear concern for worker risk  for each
               formulation within the solvent-based product lines (presented as a range). In addition, the
                                              8-13

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CHAPTER 8
CHOOSING AMONG INK TECHNOLOGIES
               table lists the categories with chemicals that present a clear risk concern for pressroom
               workers, and identifies the exposure route of concern for each category.

               In the occupational risk assessment, solvent-based ink #1 contained between two and four
               chemicals with clear concern for occupational risk in each formulation. All chemicals of
               concern presented a concern for dermal risk, and two categories (alcohols and alkyl acetates)
               also preseuied a clear concern for occupational risk via inhalation. Solvent-based ink #2
               also had between two and four chemicals with a clear concern for risk in each formulation.
               Three chemical categories contained chemicals that presented a clear concern for risk:
               alcohols presented clear concern for risk via both dermal and inhalation exposure, low
               molecular weight hydrocarbons presented a clear concern for risk via inhalation exposure,
               and organometallic pigments presented a clear concern for risk via dermal exposure.

               Across both product lines, the concern for inhalation risk stems from chemicals that are
               solvents and multiple-function compounds. The compounds presenting a clear concern for
               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 a clear concern for 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 (presses equipped
               with enclosed doctor blades can have a capture efficiency of approximately 85%), 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
                demonstration sites). Capital costs were the second-largest component of the operating
                                               8-14

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CHAPTER S
CHOOSING AMONG INK TECHNOLOGIES
               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 a clear concern for
                      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.
                                              8-15

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CHAPTER 8
                                                      CHOOSING AMONG INK TECHNOLOGIES
       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 water-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. 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-
                                               8-16

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CHAPTERS
CHOOSING AMONG INK TECHNOLOGIES
              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 a clear concern for worker health risk in each
              formulation. Water-based inks #1 and #2 both had the same range of chemicals with a clear
              concern for 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 a clear risk concern per formulation.
                                        v

              In each product line, alcohols and amides or nitrogenous compounds produced a clear
              concern for worker risk via dermal exposure and in most cases via inhalation as well.  Other
              chemical categories chemicals, that presented a clear concern for risk included ethylene
              glycol ethers, organic pigments, and organometallic pigments. The concern for risk in these
              water-based  inks, therefore, arose from solvents, pigments,   and multiple-function
              compounds.

              Table 8.4 presents lexicological 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 concern for risk associated with water-based inks is quite variable. Water-based
              inks #2 and #3 had an equal or lower number of chemicals with a clear concern for 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 a clear concern for risk
              compared to the baseline, had flammability ratings that for several formulations were equal
              to that of the baseline, and produced high levels of smog-related compounds. It is clear,
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              then, that the concern for risk associated with these water-based inks was 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 on 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 CTSA 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 concern for 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 concern
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                      for 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 1.3 added to water-based inks
                      to improve adhesion, are thought to cause worker health concerns but were not used
                      in 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#l 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 ii-Jex of 205, but inks #1 and #3 were higher at 2711 fid 273, respectively.  As for
               solvent- and water-based inks, the blue inks in each product line displayed more mottling.

               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
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              approached the value of the baseline.  However, ink #1 had a score 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 concern for risk associated with UV-cured inks is marked by uncertainty. In the
              occupational risk assessment, few of the chemicals have been subjected to lexicological
              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
              concern for occupational risk. This range was lower than that of the baseline. However,
              UV-cured ink #2 had four or five chemicals with a clear concern for risk per formulation,
              which was higher than the baseline range. Across the three product lines, the chemicals
              with a clear concern for worker risk were monomers, oligomers, colorants, and multiple
              function compounds. In their uncured form, some of these chemicals were reported to
              present a clear concern for 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 ignitable.
               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.

               As shown in the Smog-Related Emissions columns of Table 8.5, the exclusive dependence
               of UV-cured inks on electricity causes the energy-related emissions to be the highest of any
               ink system. When combined with the potential emissions from the inks themselves, the UV-
               cured ink system has the second-highest emissions rate, behind the solvent-based  system.

               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
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              were available. Furthermore, though UV-cured inks #1 and #3 had fewer chemicals with
              a clear concern for worker risk and lower emissions than the baseline, the opposite was true
              for UV-cured ink #2.  The concern for risk associated with UV-cured ink formulations,
              therefore, may vary significantly.

              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 Btu/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.
                  •  For worker risk, the UV-cured inks on average contained fewer chemicals with a
                    clear concern for risk per formulation than the baseline.  However, one ink (#2) had
                    relatively high VOC air emission rates and more chemicals with a clear concern for
                    risk,  indicating a potential variability among the  UV-cured product lines.  The
                    comparatively high number of chemicals with a clear concern for worker health risk
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                                                      CHOOSING AMONG INK TECHNOLOGIES
                      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 analysis'" 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.0 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 for
               wide-web film applications. 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 fanner in die 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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                         Table 8.6 Glossary of Benefit-Cost Analysis Terms
    Term
                                                      Definition
 Cost of
 Illness
              ^ 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.
 Exposed
 Population
             The estimated number of people from the general public or a specific population group who are
             exposed 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
             manufacturing facility (e.g., residents who live near a facility using a chemical), use of the chemical
              ir a product containing a chemical, or through other means.
 Exposed
[Worker
1 Population
 Externality
             The 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
              astimations of the number of facilities and the number of employees in each facility associated with
              tie chemical, process, and/or technology under consideration.
             A cost or benefit that involves a third party who is not 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
              egitimate activity."2 The term "externality" is a general term which can refer to either external
              aenefits or external costs,
               deduced health risks to workers in an industry or business as well as to the general public as a
               esult of 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 well as decreasing the formation of photochemical smog in the ambient air.
1 Human
 I Health
 [Benefits
 I Human
 Health
 Costs
              The cost of adverse human health effects associated with production, consumption, and disposal of
              a firm's product. An example is respiratory effects from 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.
 Indirect
 || Medical
 Costs
              ndirect medical costs associated with a disease or medical condition resulting from exposure to a
              chemical or product. Examples would be the 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
              riends.
  Private
  (Internal)
  Benefits
              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
              he satisfaction a consumer receives from consuming a good or service.
  Private
  (Internal)
 I Costs
              The direct costs incurred by industry or consumers in the marketplace. Examples include a firm1!
              cost of raw materials and labor, a firm's costs of complying with environmental i
              cost to a consumer of purchasing a product.
I regulations, or the
  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
              to 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
              they expose nonsmokers to tobacco smoke.
  Public
  (External)
  Costs
 [Social
  Costs
              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 as a consequence of the steel production. Another example of an external cost is the
              effect of second-hand smoke on nonsmokers.
              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).
 1 Social
 I Benefits
              The total benefit of an activity that society receives, i.e., the sum of the private benefits and the
              public 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 the 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 or
               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 of
               income, and, in the case of mortality, the value of life.

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               Internal benefits of selecting an alternative ink system may include increased profits
               resulting from improved worker productivity and company 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 in 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 quantified

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               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, to
               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. to 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). U V-
                curedinks (anew 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.
                                                                   ,'i
                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 the

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              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. F'
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               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 .d 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.
                dln 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
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                                     8-29

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CHAPTER 8
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 to dermal and
              inhalation exposure and prep room workers subject to dermal exposure of  hazardous
              chemicals  contained in the various ink formulations.
                                              8-30

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               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 assessed by the SAT
               with a clear concern for occupational risk associated with both Alternative  1 (1 to 4
               chemicals) and the new developing technology (1 to 5 chemicals) was slightly lower than
               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 les,s 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 i/> 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
               water-based inks and UV inks use less energy than solvent-based inks, with averages of
               73,000 and 78,000 Btu, respectively, compared to 100,000  Btu used by the solvent-based
               ink technology.  This reduced energy use may result in private and social benefits, as
               discussed above.
                                              8-31

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               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-sulfur coal. 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.' 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 in 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 8.9 presents estimates of the
               economic costs of some of the illnesses or symptoms associated with exposure  to
               flexographic printing chemicals. To the extent that flexographic printing chemicals are not
               the only factor contributing to the illnesses described, individual costs 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.
               6 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 with a potential concern for
               general population risk.
                                               8-32

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               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 with a possible concern for 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
vlausea6
Asthma 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 offish 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 in 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
                     aiii jbuted mostly to higher material and capital costs OA solvent-based technologies.
                     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.
                                             8-33

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                                                      CHOOSING AMONG INK TECHNOLOGIES
                  •   On average, solvent-based inks contained two to four chemicals with a clear
                      concern for 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 contained chemicals that presented a potential concern for
                      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.
                   •   Li the occupational health area, water-based inks presented a lower average number
                      of chemicals with a clear  concern for 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. Atone 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.

                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

              ~          ~~~~8-34

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                      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 content (none) and VOC content.
                      A couple of SAT-analyzed compounds present a potential concern for 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 ah- 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 GTSA 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.

               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.
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               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 with a clear concern for worker risk per formulation
               (3.2). Most of the chemicals with a clear concern for 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 many types of ink
               wastes can be blended with fuel 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 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
                                              8-36

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CHOOSING AMONG INK TECHNOLOGIES
               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 with a
               clear or potential concern for worker health risk in the water-based inks, which was close
               to the 3.2 found in 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.

               Benefits associated with a switch to the water-based inks in this analysis also  include a
               decrease in 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.
                                              8-37

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               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 with a clear or potential concern for
               occupational risk 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.

               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-cu.-ed 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
                                              8-38

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              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 hi 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 with a clear concern for  worker health risk in some
              formulations, and water-based ink #2 did not contain compounds with a clear concern for
              developmental risks. This was not true for water-based ink #4, however; the range in the
              number of chemicals with a clear concern for 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 imporunt to keep the VOC content as low as possible since no emission controls are
              used with these inks in most locations.

              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 concern for 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.                                                                .

       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 fbrmulators  may use this information  to help identify chemical
                                             8-39

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CHAPTER 8
                                                      CHOOSING AMONG INK TECHNOLOGIES
               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 hi the ink as well as its chemical properties, the concentration of
               a chemical hi 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 in 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 hi 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
               lexicological 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 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,

                                               8-40            '.   ~~~

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               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 concern for dermal risk,
               and eleven -others had a potential concern for 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 a clear concern for 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.
                                             8-41

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                                                     CHOOSING AMONG INK TECHNOLOGIES
                        Table 8.10 Compounds with a Clear Concern for 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, CH-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
Propvlene qlvcol methvl ether
Data Source
SAT
SAT
Tox
Tox
Tox
Tox
Tox
Tox
Tox
Tox
Tox
SAT
SAT
Tox
Tox
Tox
Tox
SAT
SAT
SAT
Tox
Tox
Tox
               For inhalation risk, thirteen chemicals  showed a clear concern for inhalation risk to
               pressroom workers based on lexicological data.  SAT findings indicate that three more
               chemicals present a clear, concern for 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 potential concern for inhalation risk from toxicological studies, as well as those
               with a moderate to high concern for inhalation risk via SAT findings. Inhalation exposure
               can be minimized, however, by  using enclosed doctor blades and providing sufficient
               ventilation.
                                              8-42

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                       Table 8.11 Compounds with a Clear Concern for Inhalation Risk
Chemical Category
Acrylated polyols
Alcohols
Alkyl acetates
Amides or nitrogenous compounds
Ethylene glycol ethers
Hydrocarbons — low molecular
weight
Propylene glycol ethers -
Chemical
Dipropylene glycol diacrylate
1 ,6-Hexanediol diacrylate
Hydroxypropyi acrylate
Ethanol
Isobutanol
Isopropanol
Butyl acetate
Ethyl acetate
Ammonia
Ammonium hydroxide
Ethanolamine
Hydroxylamine derivative
Butyl carbitol
Ethyl carbitol
n-Heptane
Propylene glycol methyl ether
Data Source
SAT
SAT
Tox
Tox
Tox
Tox
Tox
Tox
Tox
Tox
Tox
SAT
Tox
Tox
Tox
Tox
              Regulatory status
              Some of the compounds in this CTS A are regulated under major federal environment, health
              and safety 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 in 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 concern for occupational risk and another 36 presented a potential
              concern for occupational risk.  Table 8.12 presents the compounds that posed a clear or
              potential  concern  for occupational  risk based  on  either  lexicological data  or  SAT
                                            8-43

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CHAPTER 8
CHOOSING AMONG INK TECHNOLOGIES
              evaluations that are not explicitly listed in regulations. The large number of compounds not
              explicitly regulated that posed a clear or potential concern for risk 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 with a Clear or Potential Concern for Occupational Risk
                                          Not Explicitly Regulated3
Chemical
C.I. Pigment Red 23
D&C Red No. 7
Glycerol propoxylate triacrylate
'hosphine 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)
C.I. Pigment Violet 27
C.I. Pigment White 7 .
Data
Source
Tox
Tox
Tox
Tox
Tox
SAT
SAT
SAT
SAT
SAT
SAT
Tox
Tox
Tox
Tox
Tox
Tox
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
Dermal Risk
Concern Level
Clear
Clear
Clear
Clear
Clear
Clear
Clear
Clear
Clear
Clear
Clear
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Inhalation Risk
Concern Level
n.e.
n.e.
n.e.
n.e.
n.e.
n.e.
Clear
Clear
n.e.
n.e.
n.e.
n.e.
n.e.
Potential
Potential
n.e.
Potential
n.e.
n.e.
n.e.
n.e.
n.e.
n.e.
n.e.
n.e.
n.e.
n.e.
n.e.
n.e.
                                             8-44 .

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                Table 8.12  Compounds with a Clear or Potential Concern for Occupational Risk
                                     Not Explicitly Regulated (continued)
Chemical
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
Trimethylolpropane ethoxylate triacrylate
Trimethylolpropane propoxylate triacrylate
Data
Source
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
SAT
Dermal Risk
Concern Level
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Potential
Inhalation Risk
Concern Level
n.e.
Potential
n.e.
n.e.
n.e.
n.e.
n.e.
Potential
n.e.
n.e.
n.e.
Potential
n.e.
n.e.
n.e.
n.e.
n.e.
                n.e.: No exposure via indicated exposure route
                a 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 hi 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 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
                                              8-45

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              risk concern ranking.  Dermal risk concern 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 concern rating of a
              chemical can vary among ink formulations if its concentration is different.  Table 8.13 lists
              the highest observed risk concern 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.

              Acrylated 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 lexicological testing. Both had a medium hazard concern for systemic effects
              via dermal exposure, and both were found in the inks in sufficient quantities to present a
              clear concern for risk via dermal exposure. Hydroxypropyl acrylate also posed a medium
              systemic hazard concern and clear concern for 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.

              Acrylated polymers
              These six compounds were used in UV-cured inks as  monomers and polymers.  One
              compound, glycerol propoxylate triacrylate, was determined based on lexicological data to
              have a medium systemic dermal hazard level, and because of its concentration in the
              formulations, presented a clear concern for dermal occupational risk. It also had a high
              aquatic hazard level.

              For each of Ihe olher five compounds, Ihe SAT found that they had a low-moderate dermal
              hazard level and a potential concern for 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.
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              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 additives 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 potential risk concern ratings. The other
              four compounds were assigned ratings of low-moderate hazard and potential concern for
              occupational risk 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 ratings were higher. Three had a clear concern for inhalation risk (ethanol,
              isobutanol, and isopropanol), and two had a clear concern for 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.  Propanol has been
              assigned as an EPA Group C compound, indicating that it is a possible human carcinogen.
              Isopropanol has been assigned as an IARC Group 3. compound, indicating that  its
              characteristics  with  respect to cancer  are not classifiable.   The evidence of the
              carcinogenicity of isopropanol in humans is inadequate, and in experimental animals it is
              inadequate or limited.

              Four compounds in this category have OSHA Personal Exposure Limits (PELs); for ethanol,
              it is 1,000 ppm; for  isobutanol, it is  100 ppm;  for isopropanol, it is 400 ppm; and for
              propanol it is 200 ppm. 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
              exposure.  Butyl acetate also presented a clear concern for occupational risk via dermal
              exposure. Propyl acetate, which was studied by the SAT, was given low-moderate hazard
              and  potential  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. Propyl acetate has an OSHA PEL of 200 ppm.
                                             8-47

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              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 concern for occupational risk 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  concern  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 lexicological 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 potential concern for
              risk via 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 a potential concern for risk via both inhalation and dermal exposure based on
              lexicological data. For the other compounds, the concern was limited to dermal exposure.
              2-methyl-4'-(melhyllhio)-2-morpholinopropiophenone presented moderate hazard concern
              and potential risk concern via dermal exposure based  on lexicological  dala. The olher
              compounds had  low human health hazard and low  or potential concern for dermal
              occupational risk.  2-Isopropyllhioxanlhone,  4-isopropylthioxanthone and Ihioxanlhone
              derivative were found by Ihe SAT to have a high aquatic hazard concern; Ihree olhers had
              a medium aquatic hazard concern. None of the compounds were known to present a cancer
              hazard or are explicilly regulated under Ihe federal regulations discussed in ihis document.

              Ethylene glycol ethers
              These compounds were used as solvents in water-based inks. Two compounds — butyl
              carbitol and elhyl carbilol — presenl a clear concern for occupational risk via bolh dermal
              and inhalation exposure based on lexicological data.  The three olher compounds  were
              analyzed by Ihe SAT. Elhoxylaled C11-C15 secondary alcohols was assigned a moderate
              hazard level and a clear concern for occupational risk via dermal exposure, and no inhalation
              exposure was expected. The olher Iwo compounds, elhyoxylaled tetramelhyldecyndiol and
              polyethylene glycol, were given ratings of moderate hazard and potential concern for dermal
              occupational risk. Elhoxylaled C11-C15 secondary alcohols presented a medium aquatic
              hazard; all others had a low aquatic hazard level. None of Ihe compounds were known to
              present a cancer hazard.
                              !      '•   !      8-48

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CHAPTER 8
CHOOSING AMONG INK TECHNOLOGIES
              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 potential concern for  occupational risk by dermal
              exposure, and solvent-refined light paraffinic distillates also posed a potential concern for
              occupational risk by inhalation exposure. Hydrotreated light distillates were found by the
              SAT to present a potential concern for 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 carcinogenicity in animals (but have not been evaluated formally by IARC or
              EPA).

              Mineral oil has been assigned an OSHA PEL of 5 mg/m3.

              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 concern
              for occupational risk via 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 potential concern for risk via inhalation effects. Light aliphatic solvent naphtha
              was found to be a low-moderate hazard and a potential concern for occupational risk 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 in animals that styrene may be carcinogenic, but it has not been
              evaluated by 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 a clear concern for occupational dermal risk. The other two
              compounds, kaolin and silica, had low human health hazard and occupational risk concern
              ratings, and all three compounds had low aquatic hazard ratings.  Two of the compounds
              may present a cancer hazard: amorphous silica is classified as an IARC 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 am' kaolin have OSHA PELs of 0.5 mg/m3 and 15 mg'.n3 (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
                                            __

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CHAPTER 8
CHOOSING AMONG INK TECHNOLOGIES
              determined through SAT evaluation to have a low hazard and a low concern for dermal risk.
              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 lexicological 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 potential 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 a clear concern for occupational dermal risk. The other two,
              diphenyl (2,4,6-trimethylbenzoyl) phosphine oxide and 2-ethylhexyl diphenyl phosphate,
              presented low and low-moderate dermal hazard, respectively, and a potential concern for
              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 concern 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 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 potential dermal risk concern rating
              based on toxicological data. C.I. Pigment White 7 was analyzed by the SAT and found to
              have a low-moderate hazard and a potential concern for risk via 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
                                             __

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CHAPTERS
CHOOSING AMONG INK TECHNOLOGIES
              potential concern for occupational risk. 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 a clear concern for dermal risk based
              on lexicological data. One other compound subjected to lexicological testing, C.I. Pigment
              Green 7, presented a potential concern for dermal risk. Most of the other compounds, as
             ' determined by the SAT, presented low-moderate  dermal hazard and potential 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 a  potential
              concern for occupational risk by dermal exposure, and a low  aquatic hazard level. Polypi
              derivative A had low human health hazard and occupational risk concern 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 lexicological testing. Propylene glycol propyl elher, based on lexicological
              data, presented a moderate systemic human health hazard concern via both dermal and
              inhalation exposure  routes,  and had a  potential concern for dermal and inhalation
              occupational risk. Propylene glycol melhyl elher presented a low hazard co'ncern bul a clear
              concern for risk for bolh exposure palhways based on  lexicological dala.  Dipropylene
              glycol melhyl ether and propylene glycol methyl ether, presented a low hazard concern and
              a low  concern for occupational risk for bolh exposure palhways al Ihe concenlralions
              observed in the inks used in this CTSA. All Ihree compounds had a low aquatic hazard, and
              none were known to presenl a cancer hazard.

              Two compounds, dipropylene glycol melhyl elher and propylene glycol melhyl ether, are
              regulated under TSCA.  In addition, dipropylene glycol melhyl ether has an OSHA PEL of
               100 ppm.

              Resins
               Resins were found in solvenl- and water-based inks.  One compound, polymerized rosin,
               presented a low-moderate human health hazard and a potential risk concern as determined
               by Ihe SAT. All olher compounds in this category presented  low human health hazard and
               a low  concern for occupational risk for dermal exposure. One chemical — resin acids,
               hydrogenated, melhyl 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 carcinogenicily in animals. Inhalation exposure v/as nol expected for any of
               Ihese compounds, and none of Ihe compounds are explicitly regulated under Ihe federal
               regulations discussed in this document

-------
CHAPTER 8
CHOOSING AMONG INK TECHNOLOGIES
              Siloxanes
              These compounds are used in all three systems as additives (defoamers and wetting agents).
              Silicone oil, as determined through lexicological data, was anticipated to have moderate
              developmental hazard concern via dermal exposure, and a potential concern for dermal risk.
              Theothertwocompounds, l,l,l-trimethyl-N-(trimethylsilyl)-silanaminehydrolysis 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 potential concern for dermal  risk.  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.
                                             8-52

-------
CHAPTER 8
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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
                      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
                                              __        ,

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CHAPTERS
CHOOSING AMONG INK TECHNOLOGIES
                      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:
                      <>   those that are not regulated and pose risks
                      <>   new chemicals (usually not regulated and not tested)
                         chemicals that have not undergone lexicological testing and have clear or
                          potential risk concerns
                      0   high production volume chemicals1

                      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 risk concerns can result in cost
                      savings as well as improved working conditions and less liability, printers 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
               fHigh 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 39 chemicals that appear on the
               HPV Challenge Program Chemical List.
                                       ,       ___       ,

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CHAPTER 8
CHOOSING AMONG INK TECHNOLOGIES
REFERENCES

1.     Lodewyck, Paul. Progressive Ink Company. 2000. Personal Communication with Trey Kellett,
       Abt Associates Inc. March 26,2000.

2.     Mishan, EJ. Cost-Benefit Analysis. New York: Praeger, 1976.

3.     Unsworth, Robert E. and James E. Neumann.  1993. Industrial Economics, Inc. Memorandum to
       JimDeMocker, Office of Policy Analysis and Review. Review of Existing Value of Morbidity
       Avoidance Estimates:  Draft Valuation Document.  September 30, 1993.

4.     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.

5.     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 JimDeMocker, Office of Policy Analysis and Review. Review of
       Existing Value of Morbidity Avoidance Estimates:  Draft Valuation Document. September 30,
       1993.

6.     Tolley, etal.

7.     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.

8.     Chris Patterson, Flint Ink. Written comments to Karen Doerschug, U.S. EPA, July 6,2000.

9.     ICF Consulting. 2000. Internal document for the EPA Design for the Environment Project.
       January 18,2000.
                                            8-64

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