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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                WASHINGTON, D.C. 20460
                                                                         THE ADMINISTRATOR
Message from the Administrator

Over the past 25 years, our nation has made tremendous progress in protecting public health and
our environment while promoting economic prosperity. Businesses as large as iron and steel
plants and businesses as small as the dry cleaner on the corner have worked with EPA to find
ways to operate cleaner, cheaper, and smarter. As a result, we no longer have rivers catching on
fire. Our sides are clearer. American environmental technology and expertise are in demand
throughout the world.

The Clinton Administration recognizes that to continue this progress, we must move beyond the
pollutant-by-pollutant approaches of the past to comprehensive, facility-wide approaches for the
future. Industry by industry and community by community, we must build a new generation of
environmental protection.

Within the past two years, the Environmental Protection Agency undertook its Sector Notebook
Project to compile, for a number of key industries, information about environmental problems and
solutions, case studies and tips about complying with regulations. We called on industry leaders,
state regulators, and EPA staff with many years of experience in these industries and with their
unique environmental issues. Together with notebooks for 17 other industries, the notebook you
hold in your hand is the result.

These notebooks will help business managers to better understand their regulatory requirements,
learn more about how others in their industry have undertaken regulatory compliance and the
innovative methods some have found to prevent pollution in the first instance. These notebooks
will give useful information to state regulatory agencies moving toward industry-based programs.
Across EPA we will use this manual to better integrate our programs and improve our compliance
assistance efforts.

I encourage you to use this notebook to evaluate and improve the way that together we achieve
our important environmental protection goals. I am confident that these notebooks will help us to
move forward in ensuring that — in industry after industry, community after community ~
environmental protection and economic prosperity go hand in hand.
                                                Carol M. Browner
           Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)

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Sector Notebook Project
Printing and Publishing
                                                                      EPA/310-R-95-014
                   EPA Office of Compliance Sector Notebook Project

                    Profile of the Printing and Publishing Industry
                                      August 1995
                                  Office of Compliance
                     Office of Enforcement and Compliance Assurance
                          U.S. Environmental Protection Agency
                              401 M St., SW (MC 2221-A)
                                 Washington, DC 20460
                                For sale by the U.S. Government Printing Office
                       Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328
                                    ISBN 0-16-048Z81-X
September 1995
                SIC 27

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Sector Notebook Project
Printing and Publishing
 This report is one in a series of volumes published by the U.S. Environmental Protection
 Agency (EPA) to provide information of general interest regarding environmental issues
 associated with specific industrial sectors. The documents were developed under contract by
 Abt Associates Inc. (Cambridge, MA), and Booz-Allen & Hamilton, Inc. (McLean, VA).
 This publication may be purchased from the Superintendent of Documents, U.S.  Government
 Printing Office.  A listing of available Sector Notebooks and document numbers are included
 on the following page.
 All telephone orders should be directed to:

 Superintendent of Documents
 U.S. Government Printing Office
 Washington, DC 20402
 (202) 512-1800
 FAX (202) 512-2250
 8:00 a.m. to 4:30 p.m., ET, M-F
Using the form provided at the end of this document, all mail orders should be directed
to:

       U.S. Government Printing Office
       P.O. Box 371954
       Pittsburgh, PA 15250-7954
Complimentary volumes are available to certain groups or subscribers, such as public and
academic libraries, Federal, State, local, and foreign governments, and the media. For further
information, and for answers to questions pertaining to these documents, please refer to the
contact names and numbers provided within this volume.
Electronic versions of all Sector Notebooks are available on the EPA Enviro$en$e Bulletin
Board and via the Internet on the Enviro$en$e World Wide Web.  Downloading procedures
are described in Appendix A of this document.
Cover photograph by Steve Delaney, EPA. Photograph courtesy of United States Government
Printing Office. Special thanks to Barbara Shaw.
September 1995
                SIC 27

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                                     Sector Notebook Contacts

The Sector Notebooks were developed by the EPA's Office of Compliance. Particular questions regarding the
Sector Notebook Project in general can be directed to:

         Seth Heminway, Sector Notebook Project Coordinator
         US EPA, Office of Compliance
         401MSt.,SW(2223-A)
         Washington, DC 20460
         (202) 564-7017 fax (202) 564-0050
         E-mail: heminway.seth@epamail.epa.gov

Questions and comments regarding the individual documents can be directed to the appropriate specialists listed
below.
Document Number
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-

EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
-R-95-001.
-R-95-002.
-R-95-003.
-R-95-004.
-R-95-005.
-R-95-006.
-R-95-007.
-R-95-008.
-R-95-009.
-R-95-010.
•R-95-011.
-R-95-012.
•R-95-013.
•R-95-014.
-R-95-015.
-R-95-016.
•R-95-017.
•R-95-018.

•R-97-001.
•R-97-002.
•R-97-003.
•R-97-004.
•R-97-005.
•R-97-006.
•R-97-007.
R-97-008.
•R-97-009.
•R-97-010.
EPA/310-B-96-003.
    Industry

 Dry Cleaning Industry
 Electronics and Computer Industry
 Wood Furniture and Fixtures Industry
 Inorganic Chemical Industry
 Iron and Steel Industry
 Lumber and Wood Products Industry
 Fabricated Metal Products Industry
 Metal Mining Industry
 Motor Vehicle Assembly Industry
 Nonferrous Metals Industry
 Non-Fuel, Non-Metal Mining Industry
 Organic Chemical Industry
 Petroleum Refining Industry
 Printing Industry
 Pulp and Paper Industry
 Rubber and Plastic Industry
 Stone, Clay, Glass, and Concrete Industry
 Transportation Equipment Cleaning Ind.

*Air Transportation Industry
 Ground Transportation Industry
*Water Transportation Industry
 Metal Casting Industry
 Pharmaceutical Industry
 Plastic Resin and Man-made Fiber Ind.
*Fossil Fuel Electric Power Generation Ind.
* Shipbuilding and Repair Industry
 Textile Industry
*Sector Notebook Data Refresh, 1997

 Federal Facilities
Contact

Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Keith Brown
Suzanne Childress
Jane Engert
Keith Brown
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Maria Eisemann
Maria Malave
Scott Throwe
Virginia Lathrop

Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Jane Engert
Emily Chow
Sally Sasnett
Rafael Sanchez
Suzanne Childress
Belinda Breidenbach
Seth Heminway

Jim Edwards
Phone (202)

564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7013
564-7124
564-7018
564-5021
564-7124
564-7067
564-7003
564-7072
564-7016
564-7027
564-7013
564-7057

564-7057
564-7057
564-7057
564-5021
564-7071
564-7074
564-7028
564-7018
564-7022
564-7017

564-2461
*Currently in DRAFT anticipated publication in September 1997
This page updated during June 1997 reprinting

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 Sector Notebook Project
Printing and Publishing
                     Printing Industry Sector Notebook Contents
 Exhibits Index	iii

 List of Acronyms		 iv

 I.     INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT	1
    A.  Summary of the Sector Notebook Project	1
    B.  Additional Information	2

 H.     INTRODUCTION TO THE PRINTING AND PUBLISHING INDUSTRY	3
    A.  Introduction, Background, and Scope of the Notebook	3
    B.  Characterization of the Printing and Publishing Industry	4
       1.  Industry Size and Geographic Distribution	4
       2.  Product Characterization	7
       3.  Economic Trends	 9

 m.    INDUSTRIAL PROCESS DESCRIPTION	11
    A.  Industrial Processes in the Printing and Publishing Industry  	11
       1.  Imaging Operations  	12
       2.  Platemaking  and Printing	 . 13
       3.  Post-press Operations  	25
    B.  Raw Material Inputs and Pollution Outputs in the Production Line	25

 IV.    CHEMICAL RELEASE AND TRANSFER PROFILE  	31
    A.  EPA Toxic Release Inventory for the Printing and Publishing Industry  	34
    B.  Summary of Selected Chemicals Released	38
    C.  Other Data Sources	42
    D.  Comparison of Toxic Release Inventory Between Selected Industries	44

 V.    POLLUTION PREVENTION OPPORTUNITIES  	47
    A. Pollution Prevention Opportunities for the Printing and Publishing Industry	47
       1.  Pre-press - Image Making Operations	47
      2.  Pre-press - Plate Making/Screen Making Operations	48
      3.  Press Operations	48
      4.  Post-Press Operations	49
September 1995
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Sector Notebook Project
                  Printing and Publishing
VI.   SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS  . 51
   A. General Description of Major Statutes	51
   B. Industry Specific Regulatory Requiremets	63
   C. Pending and Proposed Regulatory Requirements	67

VH.   COMPLIANCE AND ENFORCEMENT HISTORY	69
   A. Printing and Publishing Industry Compliance History  	73
   B. Comparison of Enforcement Activity Between Selected Industries  	75
   C. Review of Major Legal Actions	80
      1.   Review of Major Cases	80
      2.  Supplementary Environmental Projects (SEPs)  	80

VIE.  COMPLIANCE ACTIVITIES AND INITIATIVES  	83
   A. Sector-related Environmental Programs and Activities	83
   B. EPA Voluntary Programs	88
   C. Summary of Trade Associations	89

DC.   CONTACTS/ACKNOWLEDGMENTS/
      RESOURCE MATERIALS/REFERENCES  	99

References	97

Appendix A  	A
September 1995
11
                                  SIC 27

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 Sector Notebook Project
                      Printing and Publishing
                                    Exhibits Index

 Exhibit 1:     Printing Facilities by Number of Employees  	5
 Exhibit 2:     Printing Facilities  	6
 Exhibit 3:     Top U.S. Companies with Printing Operations	7
 Exhibit 4:     Simplified Lithographic Press Layout	15
 Exhibit 5:     Rotogravure Press	17
 Exhibit 6:     Webfed Rotary Flexographic Press  	20
 Exhibit 7:     Rotary Letterpress Press	22
 Exhibit 8:     Two Methods of Screen Printing	24
 Exhibit 9:     Lithography Process: Inputs, and Outputs  .	26
 Exhibit 10:    Gravure Process: Inputs, and Outputs	27
 Exhibit 11:    Flexography Process: Inputs, and Outputs	28
 Exhibit 12:    Letterpress Process: Inputs, and Outputs	29
 Exhibit 13:    Screen Printing Process: Inputs, and Outputs	30
 Exhibit 14:    1993 Releases for Printing Facilities  in TRI,
              by Number of Facilities Reporting	 36
 Exhibit 15:    1993 Transfers for Printing Facilities hi TRI,
              by Number of Facilities Reporting	37
 Exhibit 16:    Top 10  TRI Releasing Printing Facilities	38
 Exhibit 17:    Pollutant Releases	42
 Exhibit 18:    Summary of 1993 TRI Data, Releases and Transfers by Industry  	45
 Exhibit 19:    Toxics Release Inventory Data for Selected Industries  	46
 Exhibit 20:    Five-Year Enforcement and Compliance Summary for Printing  	74
 Exhibit 21:    Five-Year Enforcement and Compliance Summary for Selected Industries . . 76
 Exhibit 22:    One-Year Inspection and Enforcement Summary for Selected Industries ... 77
 Exhibit 23:    Five-Year Inspection and Enforcement Summary
              by Statute for Selected Industries	78
 Exhibit 24:    One-Year Inspection and Enforcement Summary
              by Statute for Selected Industries  	79
 Exhibit 25:    FY-1993-1994 Supplemental Environmental Projects Overview: Printing  . . 79
September 1995
111
SIC 27

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Sector Notebook Project
                   Printing and Publishing
                                List of Acronyms

AFS -       AIRS Facility Subsystem (CAA database)
AIRS -      Aerometric Information Retrieval System (CAA database)
BEFs -       Boilers and Industrial Furnaces (RCRA)
BOD -       Biochemical Oxygen Demand
CAA -       Clean Air Act
CAAA -     Clean Air Act Amendments of 1990
CERCLA -   Comprehensive Environmental Response, Compensation and Liability Act
CERCHS -  CERCLA Information System
CFCs -      Chlorofluorocarbons
CO -        Carbon Monoxide
COD -       Chemical Oxygen Demand
CSI -        Common Sense Initiative
CWA-      Clean Water Act
D&B -       Dun and Bradstreet Marketing Index
ELP -       Environmental Leadership Program
EPA -       United States Environmental Protection Agency
EPCRA -    Emergency Planning and Community Right-to-Know Act
FIFRA -     Federal Insecticide, Fungicide, and Rodenticide Act
FINDS -     Facility Indexing System
HAPs -     Hazardous Air Pollutants (CAA)
HSDB -     Hazardous Substances Data Bank
IDEA -     Integrated Data for Enforcement Analysis
LDR -       Land Disposal Restrictions (RCRA)
LEPCs -     Local Emergency Planning Committees
MACT -     Maximum Achievable Control Technology (CAA)
MCLGs -    Maximum Contaminant Level Goals
MCLs -     Maximum Contaminant Levels
MEK-      Methyl Ethyl Ketone
MSDSs -    Material Safety Data Sheets
NAAQS -   National Ambient Air Quality Standards  (CAA)
NAFTA -   North American Free Trade Agreement
NCDB -     National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP -       National Oil and Hazardous Substances Pollution Contingency Plan
NEIC -     National Enforcement Investigation Center
NESHAP -  National Emission Standards for Hazardous Air Pollutants
NO2 -       Nitrogen Dioxide
NOV -      Notice of Violation
NOX -       Nitrogen Oxide
September 1995
IV
                                  SIC 27

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Sector Notebook Project
Printing and Publishing
NPDES -     National Pollution Discharge Elimination System (CWA)
NPL -       National Priorities List
NRC -       National Response Center
NSPS -      New Source Performance Standards (CAA) .
OAR -       Office of Air and Radiation
OECA -      Office of Enforcement and Compliance Assurance
OPA-       Oil Pollution Act
OPPTS -     Office of Prevention, Pesticides, and Toxic Substances
OSHA -      Occupational Safety and Health Administration
OSW -       Office of Solid Waste
OSWER -    Office of Solid Waste and Emergency Response
OW-        Office of Water
P2 -         Pollution Prevention
PCS -        Permit Compliance System (CWA Database)
POTW -      Publicly Owned Treatments Works
RCRA -      Resource Conservation and Recovery Act
RCRIS -      RCRA Information System
SARA -      Superfund Amendments and  Reauthorization Act
SDWA-     Safe Drinking Water Act
SEPs -       Supplementary Environmental Projects
SERCs -      State Emergency Response Commissions
SIC -        Standard Industrial Classification
SO2 -        Sulfur Dioxide
SOX-        Sulfur Oxides                     .
TOC -        Total Organic Carbon
TRI -        Toxic Release Inventory
TRIS -       Toxic Release Inventory System
TCRIS -      Toxic Chemical Release Inventory System
TSCA -      Toxic Substances Control Act
TSS -        Total Suspended Solids
UIC  -        Underground Injection Control (SDWA)
UST -        Underground Storage Tanks (RCRA)
VOCs -      Volatile Organic Compounds
September 1995
               SIC 27

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 Sector Notebook Project
Printing and Publishing
 I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT

 LA. Summary of the Sector Notebook Project

                     Environmental policies based upon comprehensive analysis of air, water
                     and  land pollution  (such as  economic  sector, and  community-based
                     approaches) are becoming an important supplement to traditional single-
                     media approaches to environmental protection.  Environmental regulatory
                     agencies are beginning to embrace comprehensive, multi-statute solutions
                     to facility permitting, compliance assurance, education/outreach,  research,
                     and regulatory development issues. The central concepts driving the new
                     policy direction are that pollutant releases to each environmental medium
                     (air, water and land) affect each other, and that environmental  strategies
                     must actively identify and address these inter-relationships by designing
                     policies for the "whole" facility.  One way to achieve a whole facility focus
                     is to design environmental policies for similar industrial facilities.  By
                     doing so, environmental concerns that are common to the manufacturing of
                     similar products can be addressed hi a comprehensive manner.  The desire
                     to move forward with this "sector-based" approach within the EPA Office
                     of Compliance led to the creation of this document.

                     The Sector Notebook Project was initiated by the Office of Compliance to
                     provide its staff and managers with summary information for eighteen
                     specific industrial sectors.  As other EPA offices, states, the regulated
                     community, and the public became interested in this project, the Office of
                     Compliance expanded the scope of the original project. The ability to
                     design comprehensive, common sense environmental protection measures
                     for specific industries is dependent on knowledge of several inter-related
                     topics.   For the purposes of this project, the key elements chosen  for
                     inclusion are:  general industry information (economic and geographic); a
                     description of industrial processes; pollution outputs; pollution prevention
                     opportunities; Federal statutory and regulatory  framework; compliance
                     history; and a description of partnerships that have been formed between
                     regulatory agencies, the regulated community and the public.

                     For  any given industry,  each topic described above could alone be the
                     subject of a lengthy volume.  However, in order to produce a manageable
                     document, this project focuses on providing summary information for each
                     topic.  This format provides the reader with a synopsis of each issue, and
                    references where more in-depth information is desired.  Text within each
                    profile  was researched from a variety  of  sources, and  was  usually
                    condensed from more detailed sources pertaining to specific topics.  This
                    approach allows for  a wide  coverage of activities that can be further
September 1995
                SIC 27

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Sector Notebook Project
Printing and Publishing
                    explored based upon the citations and references listed at the end of this
                    profile.  As a check on the information included, each notebook went
                    through an external document review process.  The Office of Compliance
                    appreciates the efforts of all those that participated in this process and
                    enabled us to develop more complete, accurate and up-to-date summaries.

I.B. Additional Information
Providing Comments
                    The  Office  of Compliance plans to periodically  review and  update
                    notebooks and will make these updates available both in hard copy and
                    electronically.  If you have any comments on the existing notebook, or if
                    you would like to provide additional information, please send a hard copy
                    and computer disk to the EPA Office of Compliance, Sector Notebook
                    Project, 401 M St., SW (2223-A), Washington, DC 20460. Comments can
                    also be uploaded to the Enviro$en$e Bulletin Board or the.Enviro$en$e
                    World Wide Web for general access to all users of the system.  Follow
                    instructions in Appendix A for accessing these data  systems.  Once you
                    have logged in, procedures for uploading text are available from the on-line
                    Enviro$en$e Help System.
Adapting Notebooks to Particular Needs
                     The scope of the existing notebooks reflect an approximation of the relative
                     national occurrence of facility types that occur within each sector. In many
                     instances, industries within specific geographic regions or states may have
                     unique characteristics that are not fully captured in these profiles. For this
                     reason, the Office of Compliance encourages state and local environmental
                     agencies  and  other groups to supplement or re-package the information
                     included in this notebook to include more specific industrial and regulatory
                     information that may be available. Additionally, interested states may want
                     to  supplement the  "Summary of  Applicable Federal  Statutes  and
                     Regulations"  section with state and local requirements.  Compliance or
                     technical assistance providers  may also want to develop the "Pollution
                     Prevention" section in more detail. Please contact the appropriate specialist
                     listed on the opening page of this notebook if your office is interested in
                     assisting  us in the further  development of  the information or policies
                     addressed within this volume.

                     If you are interested in assisting in the development of new notebooks for
                     sectors not covered in the original eighteen, please contact the Office of
                     Compliance at 202-564-2395.
 September 1995
                  SIC 27

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 Sector Notebook Project
Printing and Publishing
 H. INTRODUCTION TO THE PRINTING AND PUBLISHING INDUSTRY

                     This section provides  background information on  the  size,  geographic
                     distribution,  employment, production, sales, and economic condition of the
                     printing and  publishing industry.  The type of facilities described within the
                     document are also described in terms  of  their Standard Industrial
                     Classification (SIC) codes.  Additionally, this section contains  a list of the
                     largest companies in terms of sales.

 n. A. Introduction, Background, and Scope of the Notebook

                     The printing and publishing industry, defined most broadly, includes firms
                     whose business is dominated by printing operations, firms  performing
                     operations commonly associated with printing, such  as platemaking or
                     bookbinding, and publishers, whether or not they actually print their own
                     material.   This categorization corresponds to the Standard Industrial
                     Classification (SIC) code 27 used by the Bureau of the Census  to track the
                     flow of goods and services within the economy.  The Census identifies
                     58,000 firms and 62,000 facilities within SIC code 27.1>a

                     From the printing industry's perspective, the industry is  organized by the
                     type of printing process used:  lithography,  (roto)gravure, flexography,
                     screen,  and letterpress.   Trade  associations,  technical foundations,
                     suppliers, and supporting academic institutions are organized along process
                     lines (See Section VDI.C).  For example,  the Screen Printing Technical
                     Foundation  supports the screen printing process  and the Graphic Arts
                     Technical Foundation supports lithographers.  The Rochester  Institute of
                     Technology   specifically supports  gravure  and flexographic  printers.
                     Facilities tend to employ one type of printing process exclusively, although
                     some of the larger facilities may use two  or more types.  Based on the
                     estimated value of shipments from the U.S. printing industry in 1990,
                     lithography dominates the market with a 47 percent market share; gravure,
                     19 percent, flexography, 17 percent; letterpress, 11 percent;  and screen
                     printing, 3 percent.2
     Variation in facility counts occur across data sources due to many factors including, reporting and definitional
differences.  This notebook does not attempt to reconcile these differences, but rather reports the data as they are
maintained by each source.
September 1995
               . SIC 27

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Sector Notebook Project
Printing and Publishing
H.B. Characterization of the Printing and Publishing Industry

                    According to 1987 Census data, the printing and publishing industry was
                    comprised of 58,000 firms operating 62,000 facilities.  This figure does not
                    capture  the  large  number of  "in-plant"  printing  operations  located
                    throughout the manufacturing sectors.  The total number of printing and
                    publishing operations, therefore, could well exceed 100,000.  The printing
                    industry has a high ratio of small operations, with nearly one-half of
                    printing facilities employing  fewer  than  five  employees.   Printing
                    operations are most often located adjacent to population  and business
                    centers and therefore their distribution closely parallels the distribution of
                    the U.S. population.

       n.B.l. Industry Size and Geographic Distribution
                    While the precise number of printing and publishing facilities is difficult to
                    determine,  1987 Census data identified approximately  58,000  firms
                    operating 62,000 facilities.3 Other estimates of industry size are higher, in
                    the range of 70,000,  86 percent of which are  thought to  have press
                    operations, with the remainder performing printing-related operations such
                    as publishing or platemaMng.4 It is important to note that because printing
                    itself is  a process used to transfer images or material to a substrate, "in-
                    plant" printing operations   are  present in facilities  throughout  the
                    manufacturing  sectors.  For example, one of the largest screen printing
                    operations is within Boeing Corporation.  Other examples include firms that
                    print  textiles,  product  manufacturers  that  print  their  label,  and
                    manufacturers of printed circuit boards.  The number of printing and
                    publishing operations, therefore, could well exceed 100,000.

                    The Bureau of the Census estimates that hi 1987, 1.5 million people were
                    employed in printing and publishing.5  The value of shipments  (revenue
                    associated with product  sales) generated by printing and publishing facilities
                    totaled $135 billion.6  This value of shipments figure omits  up to $100
                    million associated with in-plant and quick printers (operating xerographic
                    copiers or small lithographic presses).7 Sales within the printing industry
                    are expected to grow by 3.5 to 5.3 percent annually between 1990 and the
                    year 2000.8

                    One of the most significant characteristics of the printing industry is the
                    large proportion of very small firms.  Almost one-half of all printing
                    facilities have fewer than five employees; approximately 84 percent employ
                    fewer than 20.9 Flexographic and gravure printers, however, tend to be
                    larger operations and to have more employees.
September 1995
                 SIC 27

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 Sector Notebook Project
Printing, and Publishing
Exhibit 1: Printing Facilities by Number of Employees
Employees per Facility
1-4
5-9
10-19
20-99
100+
Total
Number of Facilities
32,158
17,068
9,800
8,652
2,036
69,714
Percentage of Facilities
46%
24%
14%
13%
3%
100%
Source: U.S. Department of Commerce, Bureau of the Census. 1987 Census of Manufacturers
                     Printing facilities typically serve regional or local markets although some
                     firms, such as those producing books and periodicals, serve national and
                     international  markets.   Consequently,  the  geographic distribution of
                     printing facilities closely parallels the distribution of the U.S. population.
                     Facilities are most frequently located in light industrial areas in or adjacent
                     to  population and business  centers,  although smaller operations are
                     somewhat more likely to be located in residential settings.  Across the
                     U.S., sixty percent of printing facilities are located in just ten states:
                     California (13%), New York (8%), Illinois  (7%), Texas (6%), Florida
                     (5%), Pennsylvania (5%), Ohio (4%), New Jersey (4%), Michigan (4%),
                     and Massachusetts (3%).10
September 1995
                SIC 27

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Sector Notebook Project
Printing and Publishing
                                                        0 to  300
                                                      300 to  800
                                                      800 to  1,500
                                                      1,600 to 3,000
                                                      > 3,000
      Milss
     ZZBi
  0 100200300400
 Source: U.S. EPA, Toxics Release Inventory Database, 1993.
                            Exhibit 2: Printing Faculties

                     Ward's Business  Directory  of U.S.  Private  and  Public Companies,
                     produced by  Gale Research Inc.,  compiles  financial  data  on  U.S.
                     companies including those operating within the printing industry. Ward's
                     ranks U.S. companies, whether they are a parent company, subsidiary or
                     division, by sales volume within the 4-digit SIC  codes that they have been
                     assigned as their primary activity.  Readers should note that: 1) companies
                     are assigned a 4-digit  SIC that most closely  resembles their principal
                     industry;  and 2)  sales  figures  include total company sales,  including
                     subsidiaries and operations not related to printing.  Additional sources of
                     company specific financial information include Standard & Poor's Stock
 September 1995
                  SIC 27

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Sector Notebook Project
Printing and Publishing
                    Report Services, Dun & Bradstreet's Million Dollar Directory, Moody's
                    Manuals, and annual reports.
Exhibit 3: Top U.S. Companies with Printing Operations
Rank8
1
2
3
4
5
6
7
8
9
10
Company"
R.R. Donnelley & Sons Company - Chicago, IL
Times Mirror Company - Los Angeles, CA
Gannett Company, Inc. - Arlington, VA
Hallmark Cards, Inc. - Kansas City, MO
Reader's Digest Association, Inc. - Pleasantville, NY
Cox Enterprises, Inc. - Atlanta, GA
Knight-Ridder, Inc. - Miami, FL
Tribune Company - Chicago, EL
McGraw-Hill, Inc. - New York, NY
Dow Jones and Company, Inc.
1993 Sales
(millions of dollars)
3,915
3,624
3,382
2,800
2,345
2,300
2,237
2,035
1,943
1,725
Note: a When Ward's Business Directory lists both a parent and subsidiary in the top ten,
only the parent company is presented above to avoid double counting. Not all sales
can be attributed to the companies printing operations.
b Companies shown listed SIC 2711, 2721, 2731, 2732, 2741, 2752, 2754, 2759,
2761, 2771, 2782, 2789, 2791, 2796 as primary activity.
Source: Ward's Business Directory of U.S. Private and Public Companies - 1993.
       H.B.2. Product Characterization
                    The printing and publishing industry produces a wide array of printed
                    products as well as materials used in the printing process.  Some of the
                    products produced within the industry include: newspapers, books, greeting
                    cards, checks, annual reports, magazines, and packaging. Products vary
                    in print quality from newsprint to National Geographic Magazine.  Also,
                    firms performing operations commonly associated with printing, such as
                    platemaking or bookbinding, and publishers, whether or not they actually
                    print their own material, are included within the industry.
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                     The SIC codes, developed by the Office of Management arid Budget, divide
                     the printing and publishing industry according to the product manufactured,
                     such as books, newspapers, and greeting cards.  Most facilities identified
                     as printers by SIC code have few, if any, business lines other than those
                     that fall within printing and  publishing.  However,  there are tens of
                     thousands  of in-plant printing  operations at facilities whose predominant
                     lines of business are not printing.  Only if data are collected for multiple
                     SIC codes would it be evident that such facilities engaged in printing. The
                     following list presents the three-digit SIC codes with the associated product
                     they represent, as well  as the printing process  used in the product's
                     manufacture.

       SIC 271 - Newspapers |  Processes used: lithography, flexography and letterpress
       SIC 272 - Periodicals | Processes used: lithography, flexography and letterpress
       SIC 273 - Books | Processes used: lithography, gravure and letterpress
       SIC 274 - Miscellaneous Publishing |  Processes used: lithography, gravure, and letterpress
       SIC 275 - Commercial Printing | Processes used: lithography, gravure, flexography, screen and letterpress
       SIC 276 - Manifold Business Forms |  Processes used: lithography andplateless
       SIC 277 - Greeting Cards | Processes used: gravure and screen
       SIC 278 - Blankbooks, Looseleaf Binders and Bookbinding |  Primarily nonprinting
       SIC 279 - Service Industries for the Printing Trade | Primarily nonprinting

                     Newspapers (SIC 271) and commercial printing (SIC 275) account for 57
                     percent of the total value of  shipments for the printing and publishing
                     industry. Newspapers (SIC 271) include establishments primarily engaged
                     in publishing  newspapers, or in  publishing  and  printing newspapers.
                     Newspaper printers that are not engaged in publishing are classified under
                     Commercial Printing (SIC 275). Commercial printing products include but
                     are not limited to the following: maps, periodicals, coupons, menus,
                     postcards,  stationary, envelopes, magazines, and custom products.  Other
                     three-digit categories comprised of firms involved primarily in printing
                     accounted for an additional 22 percent of the value of shipments.  Other
                     SIC categories include: textile screen printing (SIC 2346) and nameplates
                     (SIC 3993). Firms that may not be involved in printing,  such as publishing
                     of blankbooks, bookbinding and printing trade services  (e.g., platemaking
                     and typesetting),  accounted for the remaining 21 percent of the value of
                     shipments.11
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       n.B.3. Economic Trends
                    The following discussion has been summarized from the U.S. Industrial
                    Outlook, published by the Department of Commerce,  which tracks and
                    forecasts the economic performance of most major sectors of the U.S.
                    economy.  The U.S. is the world's largest market for printed products. In
                    aggregate, the printing and publishing industry accounts for a significant
                    portion of the nation's goods and services; the 1991 value of shipments
                    totaled $161 billion with an estimated payroll of $39 billion for 1.5 million
                    workers.  Printing and publishing is the largest conglomeration of small
                    businesses in the domestic manufacturing sector.  While the industry is
                    large in number, many individual facilities, particularly small letterpress
                    operations are marginally profitable. Industry growth is affected by several
                    factors  including:  business  formations and transactions (which  drive
                    advertising  expenditures), population growth, and  trends  in certain
                    characteristics of the population, such as  leisure time availability and
                    individuals' consumption patterns.12

                    Competitive pressures come from non-print media, such as CD-ROM,
                    other electronic means of transferring information as well as the movement
                    of book printing to offshore facilities where production costs are lower. In
                    1992, the U.S. imported $2.1 billion worth of printed products, principally
                    from Canada, the United Kingdom, Hong Kong, and Germany.  During the
                    same period, the U.S. exported $3.8 billion worth of printed material.  The
                    major export markets for U.S. printed material are Canada, the United
                    Kingdom, Japan, and Mexico.13

                    Once the U.S. economy emerges fully from the recession of 1990/1991,
                    printing and publishing sales are expected to grow by 3.8 to 5.3 percent per
                    year through the year 2000.   The next five years are expected to offer
                    printers several opportunities for business  expansion  due to  the North
                    American Free Trade Agreement (NAFTA) and the Uruguay Round of the
                    General Agreement on Tariffs and Trade (GATT) which will reduce trade
                    barriers to  U.S.  exports and  strengthen  protection of international
                    copyrights.14
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 m. INDUSTRIAL PROCESS DESCRIPTION

                     This section describes the materials and equipment used, and the processes
                     employed within the printing and publishing  industry.  The section is
                     designed for those interested in gaining a general understanding of the
                     industry, and for those interested in the inter-relationship between the
                     industrial process and the topics described in subsequent sections of this
                     profile — pollutant outputs, pollution prevention opportunities, and Federal
                     regulations.    This section does not attempt  to replicate  published
                     engineering information that is available for this industry.  Refer to Section
                     IX for of a list of reference documents that are available.

                     This  section specifically contains a  description of  commonly  used
                     production processes, associated raw materials, the byproducts produced or
                     released, and the materials either recycled or transferred off-site.  This
                     discussion, coupled with schematic drawings of the identified processes,
                     provide a concise description of where wastes may be produced in the
                     process. This section also describes the potential fate (via air,  water, and
                     soil pathways) of these waste products.

 ffl.A. Industrial Processes in the Printing and Publishing Industry

                     The diversity of technologies and products in the printing industry makes
                     it difficult to characterize the processes and the environmental issues facing
                     the  industry  as a whole.  These process differences can lead to distinct
                     environmental concerns and are critical when developing compliance
                     assistance programs.  It is estimated that 97 percent of all printing activities
                     can be categorized within five different printing processes: lithography,
                     gravure, flexography,  letterpress, and screen printing.15  The equipment,
                     applications, and chemicals for each of these processes differ; however,
                     they all print an image on a substrate  following the same basic sequence.
                     The fundamental steps in printing are referred to as imaging,  pre-press,
                     printing, and post-press operations. The type of printing technology that
                     is used depends on a variety of factors, including the substrate used (e.g.,
                     paper, plastic, metal, ceramic, etc.), the length and speed of the print run,
                     the required print image quality, and the end product produced.

                     The first step hi the printing process,  imaging, produces an image of the
                     material  to   be  printed.   Traditionally,  this   image  is  produced
                     photographically, but  with increasing frequency the image is produced
                     electronically. The production of a photographic image involves a variety
                     of chemicals similar to those used in other fields  of photography.  The
                     image on the film is transferred to the image carrier or plate.  In pre-press
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                    operations, an image carrier is produced that can transfer the ink in the
                    image area and can repel the ink in non-image areas.  In printing, ink is
                    applied to the plate and the image is transferred to the substrate.  In the
                    post-press step, the printed material may receive any one of numerous
                    finishing operations, depending on the desired form of the final product.

                    Each of the five predominant printing technologies differ significantly in
                    how the image is transferred from the image carrier to  the substrate in the
                    printing step.  In general, the imaging and post-press operations are fairly
                    similar for all printing technologies. Therefore, imaging and post-press
                    procedures are discussed for all printing technologies, and the platemaking
                    and press operations are discussed separately for each technology.

       HI.A.l. Imaging Operations

                    Imaging  operations begin with composition and typesetting, and are
                    followed by  the  production of a  photographic negative or positive.
                    Composition  involves the  arrangement of art and text into  the desired
                    format. This composition task was performed manually. Today, however,
                    computer systems are commonly used to accomplish the task.  Computers
                    can be equipped with both optical character recognition and photographic
                    image scanners and digitizers so that pre-typed material and images can be
                    incorporated into the document being composed.16

                    Once the desired format and images are assembled, they are photographed
                    to produce transparencies. The printing industry photographic process uses
                    input materials very similar to those used in other fields of photography.
                    The purpose  of this step is to produce a photographic negative (for
                    lithography and letterpress) or a positive (for gravure, screen printing, and
                    other  lithographic processes).  Input materials for the process include
                    paper, plastic film, or a glass base covered with a light-sensitive coating
                    called a photographic emulsion.  This emulsion is usually composed of
                    silver halide salts and gelatin.  The desired image is projected onto the film
                    to  produce a film negative or a  film positive.  When the exposed
                    photographic  emulsion is developed, the silver halide in the  emulsion is
                    converted to metallic silver, in proportion to the amount of exposure it has
                    received.  The developing action is stopped by immersing the film in a
                    fixing bath, which is mainly composed of sodium thiosulfate ("hypo").
                    The fixed photographic emulsion  is then rinsed.  If an image is to be
                    printed as a color reproduction, transparencies are made for  each of the
                    colors to be used on the press. Multi-color printing is done by passing the
                    same substrate through several single-color printing operations.17 Three or
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                     four basic colors are combined on the final product to yield any color
                     desired.

       m.A.2. Platemaking and Printing

                     From photographic negative or positive, a plate is produced that is used in
                     each printing process to carry or transfer ink in the form of the image to the
                     substrate.  The plate must pick up ink only in the areas where ink is to be
                     applied to the  final image on the substrate.  The five basic  printing
                     technologies employ five different types of plates.  The platemaking  step
                     and the printing operations summaries are described below for each
                     technology.

              Lithography

                     In lithography, a planographic plate is used where the image areas and the
                     non-image areas are on the same plane  (they are  neither raised  nor
                     depressed) and are  defined  by  differences  in  their physiochemical
                     properties.  There are several types of lithographic printing, but they all use
                     a planographic plate and they all rely on the fundamental property that oil
                     and water do not mix.  As a result, lithographic inks are oil-based  and
                     traditionally the ink oils are petroleum based.  A metal or paper or plastic
                     printing plate is coated with a light-sensitive chemical which becomes ink
                     receptive when  exposed to light. Through the photographic negative, the
                     coating is exposed to light chemically changing the exposed areas, making
                     the image areas ink-receptive. The non-image areas remain water-receptive.
                     Water-based  mixtures, referred to as fountain solution, are applied to
                     enhance the non-image area's ability to repel ink. Fountain solutions may
                     contain five to  10 percent isopropyl alcohol or  they may contain alcohol
                     substitutes that meet the same needs  but with a lower VOC  content.
                     Through the use of inking rollers, ink is applied to the plate, adhering only
                     to the image areas.  The image is transferred or offset from the plate  to a
                     rubber roller (the blanket), which then transfers the image to  the substrate
                     being printed.  To accelerate drying and control ink flow characteristics,
                     lithographic inks contain solvents.  There are lithographic inks  that are
                     curable using ultraviolet energy  or electron beam, and do not contain
                     solvents.18

                     Depending on the type of substrate or the products printed, the lithographic
                     process is further divided into subprocesses: sheet-fed, heatset web,  and
                     non-heatset web. In lithography, as in most printing technologies, presses
                     are available as sheet-fed or as web-fed. On a sheet-fed press, the substrate
                     is fed into the  press one sheet at a time.  A web-fed press prints on a
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                    continuous roll of substrate, known as a web, which is later cut to size.
                    "Offset" lithography refers to the use of a rubber blanket to transfer the
                    image from  the plate to the substrate. Within the category of web offset
                    lithography, there is heatset web offset and non-heatset web offset. In the
                    heatset process, the ink is dried by evaporating the ink oil with indirect hot
                    air dryers.  This process is potentially the most significant source of VOC
                    emissions in lithography.19

                    Sheet-fed offset lithography is typically used for printing books, posters,
                    brochures, and artwork. Web-fed offset lithography is commonly used for
                    high speed production of magazines, catalogs,  and other periodicals,
                    newspapers,  magazines and catalogs.
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                Exhibit 4: Simplified Lithographic Press Layout
            t
           Feed
           pile
                  Dampening
                    sdlution
                    fountain
                 Plate  .
                 cylinder
                 Blanket
                 cylinder
   t
Impression
 cylinder
Additional units
 for multicolor
   printing
Delivery
  pile
Source: EPA 1994
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              Gravure
                    Gravure printing uses almost exclusively electro-mechanically engraved
                    copper image carriers to separate the image area from the non-image area.
                    Typically, the gravure image carrier is a cylinder. It consists of a steel or
                    plastic base which is plated with copper or a special alloy.  The electro-
                    mechanical engraving is accomplished by the electronic impulses driving
                    the diamond stylus which engraves minute cells at the rate of over 3,000
                    per second.  Today, most of the gravure cylinders are engraved directly
                    from digital files.  Chemical etching, which is a dominant technology for
                    the gravure cylinder imaging in the past, represents a very small percentage
                    of the total engravings done today.  It is used for special applications only.
                    Gravure was the  first printing  process capable of direct  imaging from
                    electronic data.

                    In gravure printing, ink is applied to the engraved cylinder, then wiped
                    from the surface by the doctor blade, leaving ink only on the engraved
                    image area.  The printing substrate is brought into contact with the cylinder
                    with sufficient pressure so that it picks up the ink left in the depressions on
                    the cylinder.  (Exhibit 5)  Low  viscosity inks are  required for  gravure
                    printing in order to fill the tiny depressions on the plate.  To dry the ink
                    and drive off the solvents, drying ovens are placed in the paper path.  The
                    solvent-laden air can be passed through carbon beds to trap and condense
                    the solvent.  Most of the ink solvents are recaptured using this process,  and
                    can either be reused or destroyed by incineration.20 Also, low VOC inks
                    can be used making carbon beds unnecessary.

                    The cost of a gravure cylinder is still considered higher compared to other
                    types of printing plates; however, today gravure is the most mature process
                    in "digital data/direct to plate" technology.  Also, gravure cylinders have
                    a very long useful life.  Several million impressions can be printed before
                    a cylinder needs to be replaced.  Gravure printing is capable of producing
                    high-quality, continuous tone images on a variety of substrates.  It is most
                    commonly  used  for large circulation  catalogs,  magazines,  Sunday
                    supplements, and advertising inserts.  Also, gravure printing is used for a
                    variety of packaging materials, postage stamps, greeting cards, currency,
                    resilient floor coverings, and wall paper.  As in lithography, the two basic
                    types of gravure  presses are sheet-fed and web.  In the US, almost all
                    commercial gravure printing is done on web fed rotogravure presses.
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                               Exhibit 5:  Rotogravure Press
                  Single-Color Station
                                    Dryer

                                      \
           Sheets
                          Impression
                            roller
                =\	Q
          Paper
           roll
                      Doctor
                       blade
                                            Printing
                                            Cylinder
  Ink
fountain
                   Additional Stations for
                     Multicolor Printing
                                                                                    Sheets
                                                                                       Folder
Rewind
Source: EPA 1994
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              Flexography
                     Flexographic  and  letterpress plates are  made using the  same  basic
                     technologies.  Both technologies employ plates with raised images and only
                     the raised images come in contact with the substrate during printing.

                     The traditional method of making these plates begins with the exposure of
                     a metal plate through a negative and processing of the exposed plate using
                     an acid bath.  The resulting metal engraving may be used directly for
                     letterpress (flatbed), or alternatively used to mold a master using a bakelite
                     board.  The board, under pressure and heat, fills the engraving and, when
                     cooled, becomes a master for molding a rubber plate with a raised area that
                     will transfer the graphics.  The second method of making plates employs
                     photopolymers in either a solid or liquid state.  The photopolymer sheet
                     (consisting of monomers) is  exposed to light  through a negative and the
                     unexposed areas washed out by means  of a solvent or water wash.  The
                     result is the relief plate.

                     Typically, flexographic plates are made of plastic, rubber, or some other
                     flexible  material,  which  is  attached  to  a roller or  cylinder  for ink
                     application. Ink is applied to the raised image on the plate, which transfers
                     the image to the  substrate.   There are  three basic  configurations of
                     flexographic press — stack, central impression and in-line. (Presses can be
                     configured to print both sides of the web. (Exhibit 6  illustrates a three-
                     roller webfed rotary press.)b In the typical flexographic printing sequence,
                     the substrate is fed into the press from a roll.  The image is printed as the
                     substrate travels through a series of stations with each station printing a
                     single color.  Each station is made up of four rollers where the first roller
                     transfers the ink from an ink pan to the second roller, the meter roller. The
                     meter roller (also known as an Anilox  Roll) meters the ink to a uniform
                     thickness onto the third roller,  the plate cylinder.  The substrate moves
                     between the plate cylinder and fourth roller.  The plate is attached to the
                     third roller (the  plate  cylinder) and  the fourth  roller (the impression
                     cylinder) applies pressure to the plate cylinder, thereby forming the image
                     on the substrate.  The printed web proceeds  through an overhead dryer
                     section to dry the ink before the next  station.  Upon completion of the
                     printing  of the last color,  the web may then  move through  an overhead
                     tunnel dryer to remove all  residual solvents.  The finished product is
                     rewound onto a roll. The width of flexography presses ranges from 4.5
                     inches up to 115 inches.  The ink tray used on larger flexographic presses
     Information on other flexographic printing configurations, such as, the wide web common impression press and
the wide web stack type press is available from the Flexographic Technical Association (Section IX).
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                     is very long, allowing for significant evaporation of ink (which may have
                     a high alcohol content). Modern presses are now equipped with enclosed
                     doctor blade systems which eliminate the fountain  roller and fountain,
                     thereby reducing evaporation losses. Printers with the more narrow presses
                     (for tags, labels and tapes) generally use water based inks and UV coatings.
                     Using UV inks reduces the volatility of the ink.

                     As in gravure, fast-drying, low-viscosity inks are used. These inks lie on
                     the surface of nonabsorbent substrates and  solidify when solvents are
                     removed, making flexography ideal for printing on impervious materials
                     such as polyethylene, cellophane and other plastics and metallized surfaces.
                     The  soft plates allow quality printing on compressible surfaces such as
                     cardboard packaging.

                     With low cost plates and a relatively  simple two roller press, flexography
                     is  one of the least expensive and  fastest growing printing  processes.
                     According to  the Flexographic Technical  Association,  85 percent of
                     packaging is printed with flexography.21  It is used primarily for packaging,
                     such as plastic wrappers, corrugated  boxes, milk cartons, labels, and foil
                     and paper bags.
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                 Exhibit 6: Webfed Rotary Flexographic Press
             Paper Roll
Three Roller Ink Systems
       Rewind
         Infccd & Tension Control
   Printing & Dying
Outfecd & Rewind
Source: EPA 1994
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              Letterpress
                     Like flexography, letterpress uses a plate with a raised image on a metal or
                     plastic plate. The three types of letterpresses in use today are the platen,
                     flat-bed, and rotary presses. On the platen press, the raised plate is locked
                     on a flat surface. The substrate is placed on another flat surface and pressed
                     against the inked plate.  The flat-bed cylinder press prints as the substrate
                     passes around an impression cylinder on its way from the feed stack to the
                     delivery stack.  These presses are often very slow relative to lithographic,
                     flexographic or  gravure presses. The moist popular letterpress is the web-fed
                     rotary letterpress. Designed to print both sides of the web simultaneously,
                     these presses are used primarily for printing newspapers.

                     Letterpress was once the predominant printing method, but its prevalence
                     has declined dramatically.  It now accounts for an estimated 11 percent of
                     the total value of  the U.S.  printing  industry.   Lithographic printing,
                     gravure, and flexography have all begun to replace letterpress.  Web
                     letterpress, traditionally used to print newspapers, is being replaced by
                     lithography and flexography.  Gravure has largely replaced letterpress for
                     printing long-run magazines and catalogs, while flexography is replacing
                     it for printing paperbacks, labels, and business forms.  Today, letterpress
                     is  primarily used for printing books, business cards,  and advertising
                     brochures.
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                         Exhibit 7: Rotary Letterpress Press
                          Paper roll
                                               Impression
                                               cylinder
                                                                 Folder
                                    Plate
                                   cylinder
                         Inking
                         roller
                       Ink
                     fountain
                             Paper roll
                                                                 Impression
                                                                  cylinder
                                                                  Folder
Source: EPA 1994
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              Screen Printing
                     Unlike the impervious plates used in the other four printing processes, the
                     screen printing process uses a porous polyester mesh.   The  mesh  is
                     stretched tightly over a frame,  and a stencil, which defines the image to be
                     printed, is applied to the mesh.  The squeegee applies pressure to the ink
                     thereby forcing the ink through the open areas of the screen. The thread
                     count and  diameter determine  the  amount  of ink deposited onto the
                     substrate below.

                     The  major chemicals used in screen printing process include organic
                     solvents, adhesives  and inks.  The chemical composition of the ink used
                     varies depending on the substrate printed and the end product produced.
                     There are five main categories  of inks used within the screen  printing
                     process:  UV-curable,  solvent-based,  and  water-based   for  graphic
                     applications, plastisols for textile applications, and water-based for textile
                     applications. Screen printing is an extremely versatile printing process, and
                     can be used to  print on a wide variety of substrates including paper,
                     plastics, glass, metals,  nylon and cotton to  produce a wide  variety of
                     products including, but not limited to, posters, labels, fleet decals, signage,
                     all types of textile garments and membrane circuits.22
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          Exhibit 8: Two Methods of Screen Printing
          Squeegee
          •L
          Paper
          sheets
                Y
                Screen
             Schematic drawing of a flat-screen type press.
             Screens lift after each application, as substrate advances.
          Squeegee
               Screen
                  ooo
             0   IFU   U
                    Magnet force
       Paper roll
           Rotary-screen printing press. Magnet force is applied
           to control the squeegee pressure.
Source: EPA 1994
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              Plateless Technologies

                     Plateless technologies include electrostatic and laser printing, and other
                     printing methods which do not rely upon the use of a separately developed
                     or prepared plate or screen.  Although currently used primarily for low-
                     volume  applications, these methods are likely to see increased use as the
                     technologies continue to develop.

       DI.A.3. Post-press Operations

                     Post-press  processes  include  cutting,  folding,   collating,  binding,
                     perforating,  drilling, and many others.  From an environmental impact
                     viewpoint, binding is the most significant of the post-press operations.
                     Liquid glue used for binding is typically a water-based latex that becomes
                     impervious to water when it dries.23

m.B. Raw Material Inputs and Pollution Outputs in the Production Line

                     Printing operations use materials that may adversely affect air, water, and
                     land: certain chemicals involved in printing volatilize,  which contributes to
                     air emissions from the facility and to  smog formation; other chemicals may
                     be discharged to drains and impact  freshwater or marine ecosystems; and
                     solid wastes contribute to the existing local and regional disposal problems.
                     The five printing processes outlined in the previous section have many
                     common wastes;  however, they also each have outputs that are process
                     specific.  Thus, it is important to note that wastes do differ from process to
                     process and the solutions identified to reduce waste in  one printing process
                     do not necessarily apply to other printing processes.  The following charts
                     outline potential outputs for each of the five printing  processes.
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Exhibit 9: Lithography Process: Inputs, and Outputs
Process
Imaging
PlatemaMng
Printing
Finishing
Inputs
Film
Paper
Developer
Fixer
Wash Water
Cleaning Solutions
Chemical Storage
Containers
Plates
Water
Developer
Fountain Solution
Ink
Paper
Cleaning Solutions
Rags
Paper
Adhesives
Shipping boxes
Outputs
Used film and out-of-date film.
Scrap paper.
May be volatile and contribute to air emissions.
Spent developer (sent to POTW).
May be volatile and contribute to air emissions.
Silver from film is often electrolytically
recovered from the fixer prior to discharge of
spent fixer to POTW.
Used rinse water.
Rags containing solvents (sent to laundry
service or disposed of as hazardous waste).
Empty containers (disposed of or returned to
suppliers).
Used plates.
Used rinse water (discharged to POTW).
Spent developer (may contain alcohol;
contributes to air emissions).
May contain VOCs and contribute to air
emissions.
Waste oil based ink disposed of as hazardous
waste. Solvent-based inks contribute to air
emissions.
Waste paper from bringing press up to required
print quality and from rejected prints.
Solvents used to clean press and remove excess
ink contribute to air emissions.
Ink and solvent-laden rags (sent to laundry
service, disposed of as hazardous waste, or
treated to recover solvents).
Reject prints and edges from trimming.
Possible losses to the air.
Waste issue.
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Exhibit 10: Gravure Process: Inputs, and Outputs
Process
Imaging
Cylinder
Making
Printing
Finishing
Inputs
Digital Data
Film
Paper
Photographic
processing solution
Wash Water
Cleaning Solutions
Chemical Storage
Containers
Copper-clad Cylinder
Acid etching solution
Ink
Heat
Paper
Cleaning Solutions
Paper
Adhesives
Shipping boxes
Outputs
Film or engraved image carrier (cylinder)
Used film and out-of-date film.
Scrap paper.
May be volatile and contribute to air emissions.
Waste solution.
Used rinse water.
Rags containing solvents (sent to laundry
service, disposed of as hazardous waste, or
treated to recover solvents).
Empty containers (disposed of or returned to
suppliers).
Used cylinders.
Waste solution.
Solvent-based inks (toluene-based for mass-
circulation printing and alcohol-based for
packaging) maintain the required low viscosity
and contribute to air emissions. Waste ink
disposed of as hazardous waste.
Ovens are used to drive off the solvents to dry
the ink. Ink solvents are recaptured through
chillers and other equipment.
Waste paper from bringing press up to required
print quality and from rejected prints.
i
Solvents used to remove excess ink contribute
to air emissions.
Reject prints and edges from trimming.
Possible losses to the air.
Waste issue.
September 1995
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                    Printing and Publishing
Exhibit 11: Flexography Process: Inputs, and Outputs
Process
Imaging
Platemaking
Printing
Finishing
Inputs
Film
Paper
Developer
Fixer
Wash Water
Cleaning Solutions
Chemical Storage
Containers
Plate mold
Rubber plate
Etching and wash-out
solutions
Ink
Paper/film
Heat
Cleaning Solutions
Paper/film
Adhesives
Shipping boxes
Outputs
Used film and out-of-date film.
Scrap paper.
May be volatile and contribute to air emissions.
Spent developer (to POTW).
May be volatile and contribute to air emissions.
Silver from film is often electrolytically
recovered from the fixer prior to disposal of
spent fixer to POTW).
Used rinse water.
Rags containing solvents (sent to laundry
service, disposed of as hazardous waste, or
treated to recover solvents).
Empty containers (disposed of or returned to
suppliers).
Used molds, engravings and washes.
Used plates, defective plates and photopolymer.
Waste solution and spent solvents.
Waste ink disposed of as hazardous waste.
Solvent-based inks contribute to air emissions.
Waste paper and film from bringing press up to
required print quality and from rejected prints.
Exhaust heat and odor. High alcohol content of
some inks contribute to air emissions as ink
dries. Water-based inks are used for paper and
some films.
Solvents used to remove excess ink contribute to
air emissions and hazardous wastes.
Reject prints, edges from trimming, box and
bag-making wastes.
Possible losses to the air.
Waste issue.
September 1995
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Sector Notebook Project
                     Printing and Publishing'
Exhibit 12: Letterpress Process: Inputs, and Outputs
Process
Imaging
Platemaking
Printing
Finishing
Inputs
Film
Paper
Developer
Fixer
Wash Water
Cleaning Solutions
Chemical Storage
Containers
Plate mold
Plate
Plate developer
solution
Ink
Paper
Cleaning Solutions
Paper
Adhesives
Shipping boxes
Outputs
Used film and out-of-date film.
Scrap paper.
May be volatile and contribute to air emissions.
Spent developer to POTW.
May be volatile and contribute to air emissions.
Spent fixer (silver from film is often
electrolytically recovered from the fixer prior to
disposal of spent fixer to POTW).
Used rinse water.
Rags containing cleaning solvents (sent to
laundry service, disposed of as hazardous
waste, or treated to recover solvents).
Empty containers (disposed of or returned to
suppliers).
Used molds.
Used plates.
Waste solution.
Waste ink disposed of as hazardous wastewater.
Solvent-based inks contribute to air emissions.
Waste paper from bringing press up to required
print quality and from rejected prints.
Solvents used to remove excess ink contribute
to air emissions.
Reject prints and edges from trimming.
Possible losses to the air.
Waste issue.
September 1995
29
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Sector Notebook Project
                    Printing and Publishing
Exhibit 13: Screen Printing Process: Inputs, and Outputs
Process
Imaging and
Screen Making
Printing
Finishing
Inputs
Emulsion
Photosensitization
solution (needed for
unsensitized films
only)
Screen (polyester,
nylon or wire mesh)
Frame
Developer
Fixer
Chemical Storage
Containers
Ink
Paper or other
printing substrate
Blockout
Screen Reclamation
Chemicals
Water
Paper or other
printing substrate
Adhesives
Shipping boxes
Outputs
Waste emulsion and out-of-date product.
Waste solution.
Excess screen trimmings; used screens.
Reused.
Spent developer (sent to POTW).
Spent fixer.
Empty containers.
Waste ink usually disposed of as hazardous
waste. Solvent-based inks contribute to air
emissions.
Waste paper from bringing press up to required
print quality and from rejected prints.
Removed during screen reclamation and
disposed with screen reclaim chemicals.
Screen reclamation chemicals and ink are
disposed of in rags and in clean-up wastewater.
Water used for screen reclamation is discharged
to POTW; sometimes it is filtered pridFto
discharge.
Reject prints and edges from trimming.
Possible losses to the air.
Waste issue.
September 1995
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Sector Notebook Project
                      Printing and Publishing
IV. CHEMICAL RELEASE AND TRANSFER PROFILE
                    This section is designed to provide background information on the pollutant
                    releases that are reported by this industry.  The best source of comparative
                    pollutant release information is the Toxic Release Inventory System (TRI).
                    Pursuant to the Emergency Planning and Community Right-to-Know Act
                    (EPCRA), TRI includes self-reported facility release and transfer data for
                    over 600 toxic chemicals.  Facilities within SIC Codes  20 through 39
                    (manufacturing industries) that have more than 10 employees, and that are
                    above weight-based reporting thresholds are required to report TRI on-site
                    releases and off-site transfers. The information presented within the sector
                    notebooks is derived from the most recently available (1993) TRI reporting
                    year (which then included  316 chemicals), and focuses primarily on the on-
                    site  releases reported by each sector.  Because TRI requires consistent
                    reporting  regardless  of  sector, it is  an  excellent  tool  for drawing
                    comparisons across industries.

                    Although  this sector notebook does not present historical information
                    regarding TRI chemical releases, please note that in general, toxic chemical
                    releases have been declining.  In fact, according to the 1993 Toxic Release
                    Inventory Data Book, reported releases dropped by 43 percent between
                    1988 and 1993.  Although on-site releases have decreased, the total amount
                    of reported toxic waste  has not declined because the amount of toxic
                    chemicals transferred off-site has increased. Transfers have increased from
                    3.7  billion pounds  in 1991 to 4.7  billion pounds  in  1993.   Better
                    management practices have led to increases  in off-site transfers of toxic
                    chemicals for recycling.  More detailed information can be obtained from
                    EPA's annual Toxics Release Inventory Public Data Release book (which
                    is available through the EPCRA Hotline at 800-535-0202), or directly from
                    the Toxic Release Inventory System database (for user support call 202-
                    260-1531).

                    Wherever possible, the sector notebooks present TRI data as the primary
                    indicator of chemical release within each industrial  category.  TRI data
                    provide the type, amount and media receptor of each chemical released or
                    transferred.   When other sources of pollutant  release data have been
                    obtained, these data have been included to augment the TRI information.
       TRI Data Limitations
                    The reader should keep in mind the following limitations regarding TRI
                    data. Within some sectors, the majority of facilities are not subject to TRI
                    reporting because they are not considered manufacturing  industries, or
September 1995
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                      Printing and Publishing
                     because they are below TRI reporting thresholds.   Examples are the
                     mining, dry cleaning, printing, and transportation equipment cleaning
                     sectors.  For these sectors, release information from other sources has been
                     included.

                     The TRI data presented here does not accurately portray  the printing
                     industry's toxic chemical outputs  due to  the  small number of printing
                     facilities that report under EPCRA §313. The 1992 TRI printing industry
                     data is based on information from 374 facilities, yet the printing industry
                     universe has been  put at approximately  70,000  facilities  by industry
                     sources; the TRI data covers less than one percent of U.S. printers.  Small
                     facilities that do not report to TRI because they are below the reporting
                     thresholds of chemical use and/or employment are also somewhat less likely
                     to be  subject to the same regulatory requirements as  larger facilities.  A
                     comprehensive picture  of the chemical releases and transfers for the
                     printing industry will be difficult without  a  separate release  and transfer
                     profile of the non-TRI-reporting printing facilities.

                     The reader should also be aware that TRI "pounds released" data presented
                     within the notebooks is not equivalent to a "risk"  ranking for each industry.
                     Weighting each pound of release equally  does not factor in the relative
                     toxicity of each chemical that is released. The Agency is in the process of
                     developing an approach to assign lexicological weightings to each chemical
                     released so that one can differentiate between  pollutants with significant
                     differences in toxicity.  As a preliminary  indicator of the environmental
                     impact of the industry's most commonly released chemicals, the notebook
                     briefly summarizes  the lexicological properties of the top five chemicals
                     (by weight) reported by each industry.

Definitions Associated with Section IV Data Tables
General Definitions
                     SIC Code — is the Standard Industrial Classification (SIC) is a statistical
                     classification standard used for all establishment-based Federal economic
                     statistics.  The SIC codes facilitate comparisons between  facility and
                     industry data.

                     TRI Facilities — are manufacturing facilities that have 10 or more full-time
                     employees and are above  established  chemical throughput thresholds.
                     Manufacturing facilities are defined as facilities in Standard Industrial
                     Classification  primary codes 20 through  39.   Facilities must  submit
September 1995
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                      Printing and Publishing
                     estimates for all chemicals that are on the EPA's defined list and are above
                     throughput thresholds.

Data Table Column Heading Definitions

                     The following definitions are based upon standard definitions developed by
                     EPA's Toxic Release Inventory Program. The categories below represent
                     the possible pollutant destinations that can be reported.
                    RELEASES  --  are  an on-site discharge of  a toxic  chemical to the
                    environment. This includes emissions to the air, discharges to bodies of
                    water, releases at the facility to land, as well as contained disposal into
                    underground injection wells.

                    Releases to Air  (Point and Fugitive Air Emissions) — Include all air
                    emissions from industry activity.  Point emission occur through confined
                    air streams as found hi stacks, ducts, or pipes. Fugitive emissions include
                    losses from equipment leaks, or evaporative losses from impoundments,
                    spills, or leaks.                     '

                    Releases to Water (Surface Water Discharges) — encompass any releases
                    going directly to  streams, rivers, lakes, oceans, or other bodies of water.
                    Any  estimates for stormwater runoff and non-point losses must also be
                    included.

                    Releases to Land — includes disposal of toxic chemicals in waste to on-site
                    landfills, land treated or incorporation into soil, surface impoundments,
                    spills, leaks,  or waste piles.  These  activities must occur within the
                    facility's boundaries for inclusion in this category.

                    Underground Injection — is a  contained  release  of a fluid into a
                    subsurface well for the purpose of waste disposal.

                    TRANSFERS — is a transfer of toxic chemicals in wastes to a facility that
                    is geographically or physically separate from the facility reporting under
                    TRI.  The quantities reported represent a movement of the chemical away
                    from the reporting facility.  Except for off-site transfers for disposal, these
                    quantities  do  not necessarily represent entry of the chemical into the
                    environment.

                    Transfers to  POTWs — are wastewaters transferred through pipes or
                    sewers to a publicly owned treatments works (POTW).  Treatment and
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Sector Notebook Project
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                     chemical removal depend on the chemical's nature and treatment methods
                     used.   Chemicals not treated or destroyed by the POTW are generally
                     released to surface waters or landfilled within the sludge.

                     Transfers to Recycling - are sent off-site for the purposes of regenerating
                     or recovering still valuable materials.  Once these chemicals have been
                     recycled,  they may  be returned to  the  originating facility or  sold
                     commercially.

                     Transfers to  Energy Recovery — are wastes  combusted  off-site  in
                     industrial furnaces for energy  recovery.   Treatment of a chemical by
                     incineration is not considered to be energy recovery.

                     Transfers  to  Treatment —  are  wastes  moved  off-site  for either
                     neutralization, incineration, biological destruction,  or physical separation.
                     In some cases, the chemicals are not destroyed but prepared for further
                     waste management.

                     Transfers to Disposal — are wastes taken to another  facility for disposal
                     generally as a release to land or as an injection underground.

IV. A. EPA Toxic Release Inventory for the Printing and Publishing  Industry

                     The total amount of TRI toxic chemicals generated by the printing industry
                     is a gross profile of the types and relative  amounts of chemical outputs
                     from printing processes. Additional information which can be related back
                     to possible compliance requirements is available from the distribution of
                     chemical releases across specific media within the environment.  The TRI
                     data requires filers to separate the total releases for the printing industry for
                     air,  water, and land releases. This distribution across media can also be
                     compared to the profile of other industry sectors.

                     The printing industry releases 99 percent of its total TRI poundage to the
                     air, while the remaining one percent of releases are split between water and
                     land disposal.  This release profile  differs  significantly from other TRI
                     industries which average approximately 60 percent to air, 30 percent to
                     land, and 10 percent to water release respectively. Examining the printing
                     industry's TRI reported toxic chemicals by chemical highlights the likely
                     origins of the large air releases for the industry (see following table).

                     Of the top ten toxic chemicals in  the list, the  prevalence of volatile
                     chemicals explains the air intensive toxic chemical loading of the printing
                     industry.  Of these ten toxic chemicals, seven are highly volatile. The four
September 1995
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Sector Notebook Project
                       Printing and Publishing
                     top toxic chemicals released,  toluene, methyl ethyl ketone,  xylene, and
                     1,1,1-trichloroethane, are all solvents of high volatility. By far the single
                     largest toxic chemical used (released/transferred) by the printing industry
                     is the solvent toluene; toluene comprises roughly 70 percent of the total
                     chemicals released and transferred by the industry.  Toluene is used heavily
                     in the  gravure printing process  as an  ink  solvent, but is also used
                     throughout printing for cleaning purposes.  Metals on the other hand are
                     typically transferred  off-site, as a  component  of hazardous wastes  or
                     discharged to the sewer.
September 1995
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Sector Notebook Project
                    Printing and Publishing


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Sector Notebook Project
                      Printing and Publishing
                     The TRI database contains a detailed compilation of self-reported, facility-
                     specific chemical releases.  The top reporting facilities for this sector are
                     listed below.  Facilities that have reported only the SIC  codes covered
                     under this notebook appear in Exhibit 16.
Exhibit 16: Top 10 TRI Releasing Printing Facilities0
Rank
1
2
3
4
5
6
7
8
9
10
Facility
Ringier America Inc. - Corinth, MS
R. R. Donnelley & Sons Co. - Warsaw, IN
Quebecor Printing Inc. - Glen Burnie, MD
Quebecor Printing Inc. - Memphis, TN
Quebecor Printing Inc. - Dickson, TN
Brown Printing Co. - Franklin, KY
R. R. Donnelley Printing - Lynchburg, VA
Quebecor Printing Inc. - Providence, RI
R. R. Donnelley & Sons Co. - Gallatin, TN
Quebecor Printing Inc. - Mount Morris, IL
Total TRI
Releases in
Pounds
2,734,080
2,304,148
1,991,284
1,741,875
1,666,416
1,643,881
1,431,502
1,366,140
1,193,120
1,190,988
Source: U.S. EPA Toxic Release Inventory Database. 1993.
rV.B. Summary of Selected Chemicals Released
                     The brief descriptions provided below were taken from the 1993 Toxics
                     Release Inventory Public Data Release (EPA, 1994), and the Hazardous
                     Substances Data Bank (HSDB), accessed via TOXNET. TOXNET is a
                     computer system run by the National Library of Medicine.  It includes a
                     number of lexicological databases managed by EPA, National Cancer
                     Institute,  and the National Institute for Occupational Safety and Health/
                     HSDB contains chemical-specific information on manufacturing and use,
     Being included on this list does not mean that the release is associated with non-compliance with environmental
laws.


     Databases included in TOXNET are: CCRIS (Chemical Carcinogenesis Research Information System), DART
(Developmental and Reproductive Toxicity Database), DBIR (Directory of Biotechnology Information Resources),
EMICBACK (Environmental Mutagen Information Center  Backfile), GENE-TOX  (Genetic Toxicology), HSDB
(Hazardous Substances Data Bank), IRIS (Integrated Risk Information System), RTECS (Registry of Toxic Effects of
Chemical Substances), and TRI (Toxic Release Inventory).
September 1995
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                    chemical and physical properties, safety and  handling, toxicity  and
                    biomedical  effects,  pharmacology,  environmental fate and  exposure
                    potential, exposure standards and regulations, monitoring and analysis
                    methods, and additional references. The information contained below is
                    based upon exposure assumptions that have been conducted using standard
                    scientific procedures.  The effects listed below must be taken in context of
                    these exposure assumptions that are more fully explained within the full
                    chemical profiles in HSDB.  For more information on TOXNET, contact
                    the TOXNET help line at 800-231-3766.

                    Toluene (CAS: 108-88-3)

                    Toxicity.   Inhalation or ingestion of toluene can  cause  headaches,
                    confusion, weakness, and memory loss. Toluene may also affect the way
                    the kidneys and liver function.

                    Reactions of toluene (see environmental fate) in the atmosphere contribute
                    to the formation of ozone in the lower atmosphere. Ozone can affect the
                    respiratory system, especially in sensitive  individuals such as asthma or
                    allergy sufferers.

                    Some studies have shown that unborn animals were harmed when high
                    levels of toluene  were inhaled by their mothers, although the same effects
                    were not seen when the mothers were fed large quantities of toluene. Note
                    that these results may reflect similar difficulties in humans.

                    Carcinogenicity.  There  is currently no  evidence to  suggest that  this
                    chemical is carcinogenic.

                    Environmental  Fate.  The  majority of releases of toluene to land  and
                    water will evaporate.  Toluene may also be degraded by microorganisms.
                    Once volatilized, toluene in the lower atmosphere will react with other
                    atmospheric components contributing  to the formation of ground-level
                    ozone and other air pollutants.

                    Physical Properties.  Toluene is a volatile  organic chemical.

                    OJyr.nl Ethers

                    Data on ethylene glycol mono-n-butyl ether (2-butoxyethanol) are used to
                    represent all glycol ethers because it is the most commonly used glycol
                    ether in printing.                    :
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                    Ethylenp. Crlyr.nl Mnno-n-Butyl TZthp.r (T.-'Butnxye.tha.nnl).

                    Toxicity.  Exposure to moderate concentrations of 2-butoxyethanol may
                    cause central nervous system depression, including headaches, drowsiness,
                    weakness,  slurred speech, stuttering, staggering, tremors, blurred vision,
                    and personality changes.  These symptoms are such that a patient, in the
                    absence of an  accurate  occupational  history,  may be  treated  for
                    schizophrenia or  narcolepsy.  Other symptoms of moderate poisoning
                    include nausea; vomiting; diarrhea; blood toxicity; abdominal and lumbar
                    pain; and lesions in the brain, lung, liver, meninges and heart.  Exposure
                    to higher concentrations may lead to skin, respiratory, and eye irritation;
                    kidney and liver damage; and coma.

                    It appears that 2-butoxyethanol is one of the few materials to which humans
                    are more resistant than experimental animals.  This appears to be at least
                    partly due to the fact that humans are more resistant to the chemical's red
                    blood cell-destroying properties than are most lab animals.

                    Environmental fate.  The chemical 2-butoxyethanol is highly mobile in
                    soils and should not accumulate in organic matter contained in sediments
                    and suspended solids. Limited monitoring data has shown that it can leach
                    to ground water. Hydrolysis, direct photolysis, volatilization, adsorption,
                    and bioconcentration are not important fate processes for 2-butoxyethanol.
                    Biodegradation is likely to be the most important removal mechanism of 2-
                    butoxyethanol from aerobic soil and water.  In the atmosphere,  it reacts
                    with photochemicaUy produced hydroxyl radicals with an estimated half-life
                    of 17 hours.

                    Methyl Kthyl Ketnnp (CAS: 78-93-3)

                    Toxicity. Breathing moderate amounts of methyl ethyl ketone (MEK) for
                    short periods of time  can cause adverse effects on the nervous system
                    ranging from headaches, dizziness, nausea, and numbness in the fingers and
                    toes to unconsciousness. Its vapors are irritating to the skin, eyes, nose,
                    and throat  and can damage the eyes.  Repeated exposure to moderate to
                    high amounts may cause liver and kidney effects.

                    Environmental Fate.   MEK is a flammable liquid.   Most of the MEK
                    released to the  environment will end up in the atmosphere. MEK can
                    contribute to the formation of ah- pollutants in the lower atmosphere. It can
                    be degraded by microorganisms living in water and soil.
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                     1,1, 1-TrlcMnrnp.thnnp (CAS: 71-55-6)

                     Toxicity. Repeated contact of 1,1,1-trichloroethane (TCE) with skin may
                     cause serious skin cracking and infection.  Vapors cause a slight smarting
                     of the eyes or respiratory system if present in high concentrations.

                     Exposure to high concentrations of TCE causes reversible mild liver and
                     kidney dysfunction, central nervous system depression, gait disturbances,
                     stupor, coma,  respiratory depression, and even death.  Exposure to lower
                     concentrations of TCE leads to light-headedness, throat irritation, headache,
                     disequilibrium, impaired coordination,  drowsiness, convulsions and  mild
                     changes in perception.

                     Carcinogenicity.  There is currently  no evidence to suggest that this
                     chemical is carcinogenic.

                     Environmental Fate.  Releases of TCE to surface water or land will
                     almost entirely volatilize.  Releases to air may be transported long distances
                     and may partially return to earth in rain. In the lower atmosphere, TCE
                     degrades very slowly by photooxidation and slowly diffuses to the upper
                     atmosphere where photodegradation is rapid.

                     Any TCE that does  not evaporate from  soils leaches to groundwater.
                     Degradation in soils and water is slow.  TCE does not hydrolyze in water,
                     nor does it significantly bioconcentrate in aquatic organisms.
                           (Mind Tsanu>.rxl (CAS: 1330-20-7)
                    Toxicity.  Xylenes are rapidly absorbed into the body after inhalation,
                    ingestion, or skin contact.  Short-term exposure of humans to high levels
                    of xylenes can cause irritation of the skin, eyes, nose, and throat, difficulty
                    in breathing, impaired lung function, impaired memory,  and possible
                    changes in the liver and kidneys. Both short- and long-term exposure to
                    high  concentrations can  cause effects such  as headaches, dizziness,
                    confusion, and lack of muscle coordination. Reactions of xylenes (see
                    environmental fate) in the atmosphere contribute to the formation of ozone
                    in the  lower atmosphere.   Ozone can  affect the respiratory system,
                    especially in sensitive individuals such as asthma or allergy sufferers.

                    Carcinogenicity.   There is  currently no evidence to suggest that this
                    chemical is carcinogenic.
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                    Environmental Fate.  The majority of releases to land and water will
                    quickly evaporate, although some degradation by microorganisms will
                    occur.

                    Xylenes are moderately mobile in soils and may leach into groundwater,
                    where they may persist for several years.

                    Xylenes are volatile organic chemicals.  As such, xylenes in the lower
                    atmosphere will react with other atmospheric components, contributing to
                    the formation of ground-level ozone and other air pollutants.
IV.C. Other Data Sources

                    The toxic chemical release data obtained from TRI allows for a comparison
                    across years and industry sectors. Reported chemicals are limited however
                    to the 316 reported chemicals. The EPA Office of Air Quality Planning
                    and Standards has compiled air pollutant emmission factors for determining
                    the total air emissions of priority pollutants (e.g., total hydrocarbons, SOX,
                    NOx, CO, particulates,  etc.) from  various industry  sectors including
                    printing facilities.

                    The Aerometric Information Retrieval System (AIRS) contains a  wide range
                    of information related to stationary sources of air pollution, including the
                    emissions of a number of air pollutants which may be of concern within a
                    particular industry.  With the exception of volatile organic compounds
                    (VOCs), there is little overlap with the TRI chemicals reported above.
                    Exhibit 17 summarizes annual releases of carbon monoxide (CO), nitrogen
                    dioxide (NO^, particulate matter  of 10 microns or less  (PM10), total
                    particulates (PT), sulfur dioxide (SO2), and volatile organic compounds
                    (VOCs).
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Exhibit 17: Pollutant Releases (short tons/year)
Industry Sector
Metal Mining
Nonmetal Mining
Lumber and Wood
Production
Furniture and Fixtures
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Rubber and Misc.
Plastics
Stone, Clay and Concrete
Iron and Steel
Nonferrous Metals
Fabricated Metals
Computer and Office
Equipment
Electronics and Other
Electrical Equipment and
Components
Motor Vehicles, Bodies,
Parts and Accessories
Dry Cleaning
CO
5,391
4,525
123,756
2,069
624,291
8,463
166,147
146,947
419,311
2,090
58,043
1,518,642
448,758
3,851
24
367
35,303
101
NO2
28,583
28,804
42,658
2,981
394,448
4,915
103,575
236,826
380,641
11,914
338,482
138,985
55,658
16,424
0
1,129
23,725
179
PM10
39,359
59,305
14,135
2,165
35,579
399
4,107
26,493
18,787
2,407
74,623
42,368
20,074
1,185
0
207
2,406
3
PT
140,052
167,948
63,761
3,178
113,571
1,031
39,062
44,860
36,877
5,355
171,853
83,017
22,490
3,136
0
293
12,853
28
SO2
84,222
24,129
9,419
1,606
541,002
1,728
182,189
132,459
648,155
29,364
339,216
238,268
373,007
4,019
0
453
25,462
152
voc
1,283
1,736
41,423
59,426
96,875
101,537
52,091
201,888
369,058
140,741
30,262
82,292
27,375
102,186
0
4,854
101,275
7,310
Source: U.S. EPA Office of Air and Radiation, AIRS Database, May 1995.
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IV.D. Comparison of Toxic Release Inventory Between Selected Industries

                     The following information is presented as a comparison of pollutant release
                     and transfer data cross industrial categories. It is provided to give a general
                     sense as to the relative scale of releases and transfers within each sector
                     profiled under this project.  Please note that the following figure and table
                     do not contain releases and transfers for industrial categories that are not
                     included in this project, and thus cannot be used to  draw conclusions
                     regarding the total release and transfer amounts that are reported to TRI.
                     Similar information is available within the annual TRI Public Data Release
                     Book.

                     Exhibit 18 is a graphical representation of a summary of the 1993 TRI data
                     for the Printing and Publishing and the other sectors profiled in separate
                     notebooks.  The bar graph presents the total TRI releases and total transfers
                     on the left axis and the triangle points show the average releases per facility
                     on the right axis. Industry sectors are presented in the order of increasing
                     total TRI releases. The graph is based on the data shown in Exhibit 19 and
                     is meant to facilitate comparisons between the relative amounts of releases,
                     transfers, and releases per facility both within and between these sectors.
                     The reader should  note, however, that differences in  the proportion of
                     facilities captured by TRI exist between industry sectors.  This can be a
                     factor of  poor SIC matching and relative differences  in the number of
                     facilities reporting to TRI from the various sectors.  In the case of Printing
                     and Publishing, the 1993 TRI data presented here covers 318 facilities.
                     These facilities listed SIC 2711-2789 (Printing and Publishing) as a primary
                     SIC code.
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V. POLLUTION PREVENTION OPPORTUNITIES

                    The best way to reduce pollution is to prevent it in the first place.
                    Industries have creatively implemented pollution prevention techniques that
                    improve efficiency and increase profits while at the same time minimizing
                    environmental impacts. This can be done in many ways such as reducing
                    material inputs, re-engineering processes to reuse by-products, improving
                    management practices, and employing substitution  of toxic  chemicals.
                    Some smaller facilities are able to actually get below regulatory thresholds
                    just by reducing pollutant releases through aggressive  pollution prevention
                    policies.

                    In order to encourage these approaches, this section provides both general
                    and company-specific descriptions of some pollution  prevention advances
                    that have been implemented within the printing  and  publishing industry.
                    While the list is not exhaustive, it does provide core  information that can
                    be used as the starting point for facilities interested in  beginning their own
                    pollution prevention projects.   When possible,  this  section provides
                    information from real activities that can, or are being  implemented by this
                    sector — including a discussion  of associated  costs, tune frames, and
                    expected rates of return. This section also provides the context (in terms
                    of type of industry and/or type of process affected) in which the pollution
                    prevention technique can effectively be used.

V.A. Pollution Prevention Opportunities for the Printing and Publishing Industry

                    Printers use various chemicals throughout their facilities.  The payoff from
                    many of the possible changes in the printing process  or product choice is
                    unlikely to have a significant effect on a facility's  overall emissions profile
                    because these chemicals and chemical formulations are often used in
                    relatively small quantities.   Instead, pollution prevention for printers
                    involves a longer-term reorientation of production staff and management
                    priorities so that opportunities are recognized and acted upon as they arise.
                    For example, a one-time pollution prevention audit may not identify novel
                    press technologies capable of reducing VOC emissions if the purchase is
                    not likely to occur for several years, but the practice of on-going pollution
                    prevention auditing, once established, will identify  when  the time and
                    conditions are right.

                    This section is structured according to the steps within  pre-press, press and
                    post-press  operations.  Pollution prevention  opportunities for specific
                    printing processes (e.g., lithography) are presented  separately wherever
                    warranted.
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       V.A.I. Pre-press - Image Making Operations

                    Image making most frequently involves typesetting and photodevelopirig.
                    Typical wastestreams include: photographic chemicals, paper and films,
                    silver, and solid wastes. Pollution prevention opportunities include:

                    •     Implementing operational and work practice changes that can extend
                          the life of chemical baths, reduce the amount of chemicals used and
                          reduce wastewater generation;
                    •     Using chemical substitutes, such as non-silver photographic films
                          (under development);
                    •     Replacing the sometimes repetitive steps of photographing, editing,
                          re-shooting, and  the photodeveloping process with electronic
                          imaging (including the capability to edit images on a computer)
                    •     Developing inventory control programs that offer the advantage of
                          reducing spoilage of photodeveloping chemicals and supplies such
                          as paper and film.

       V.A.2. Pre-press - Plate Making/Screen Making Operations

                    Typical  wastestreams include: outdated material and chemicals, damaged
                    or used plates and screens, wastewaters containing acids, alkalis, solvents,
                    plate coatings, developers, screen emulsions, and rinse water.  Pollution
                    prevention opportunities include:

                    •     Changing operational and  work practices to reduce chemical use
                          including recovery and recycling of  spent chemicals and heavy
                          metals, which require steps to reduce contamination of chemical
                          baths; counter-current washing; and filtration of screen making
                          wastewaters to remove particulates;
                    •     Recycling plates and plate materials to the manufacturer or a metal
                          recoverer;
                    •     Researching and commercializing of other major changes in printing
                          plate development, primarily related to alternative chemistries. For
                          example, using water-developed lithographic plates and film instead
                          of solvent processing may eliminate the need for pretreatment of
                          wastewaters if they are being discharged to the sewer;
                    •     Replacing ferrocyanide bleaches with iron-EDTA bleaches which
                          eliminate certain treatment and disposal requirements;
                    •     Reducing environmental releases related to plate-making  and screen-
                          making through new techniques. For example, laser plate making
                          using non-silver plates is under commercial development and could
                          replace chemical development of plates;
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                    •      Reducing wastewater through new technologies such as "washless"
                           processing systems.  While still expensive to install, these systems
                           can reduce wastewater by as much as 97 percent.

       V.A.3. Press Operations

                    During printing, the image is transferred to a substrate of paper or some
                    other material.   Typical wastestreams include: inks, substrate, cleaning
                    solutions,  and in the case of lithography,  fountain solutions.  Pollution
                    prevention opportunities include:
                           Improving housekeeping and better operating practices, such as
                           covering reservoirs and containers, scheduling jobs according to
                           increasing darkness of ink color, using wipes as long as possible,
                           and controlling inventory, can all minimize solvent losses from inks
                           and cleaning solutions.
                           Reducing ink vaporization by using diaphragm pumps which do not
                           heat ink as much as mechanical vane pumps.
                           Recycling waste solvents on-site or off-site. Segregating of solvents
                           may  allow a second use (e.g.,  for equipment cleaning or ink
                           thinning).
                           Recycling of certain waste inks where possible.
                           Recycling of product rejects where possible.
                           Using alternative ink and cleaning products with  reduced  VOC
                           emissions. Lowering the VOC emissions from printing and press
                           cleanup may be accomplished using vegetable oil-based  inks or
                           water-based inks (rather than solvent-based inks) where possible and
                           using low-VOC or VOC-free cleaning solutions.  A new printing
                           system that  features  an oil-based  lithographic ink that  can be
                           converted to a water-soluble state is currently available, allowing a
                           water-based blanket wash to be used.
                           Eliminating the use of chromium-containing fountain solutions to
                           reduce the toxicity of spent fountain solutions.
                           Installing automatic ink levelers help to keep ink conditions optimal.
                           Using automatic cleaning equipment which can often be retrofitted
                           to existing presses and operations.  Typically, lower volumes of
                           cleaning formulations are applied with such cleaning equipment, air
                           contact, and thus volatilization, is reduced, and most are designed
                           to include recycling and reuse of cleaning solutions.
                           Minimizing finished product rejects by  automating (noncontact)
                           monitoring technologies which  detect tears  in  web and  press
                           performance.                 :
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                     •      Using fountain coolers to reduce evaporation from the dampening
                           fountain.

       V.A.4. Post-Press Operations

                     The final steps in making a printed product may involve folding, trimming,
                     binding, laminating and embossing.  Typical wastestreams include: scrap
                     substrate  from trimming, rejects from finishing operations,  and VOCs
                     released from adhesives. Pollution prevention opportunities include:

                     •      Collecting and reclaiming recyclable materials is often done.
                     •      Replacing  VOC-based adhesives with water-soluble adhesives
                           (binding adhesives that are not water-soluble may interfere with
                           later  recycling), hot-melt adhesives,  or mechanical methods in
                           binding operations.
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VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS

                    This section discusses the Federal statutes and regulations that may apply
                    to this sector.  The purpose of this section is to highlight,  and briefly
                    describe the applicable Federal requirements, and to provide citations for
                    more detailed information.  The three following sections are included.

                    •      Section VI. A. contains a general overview of major statutes
                    •      Section VLB. contains a list of regulations specific to this industry
                    •      Section VI.C. contains a list of pending and proposed regulations

                    The  descriptions within Section VI are  intended  solely for general
                    information.  Depending upon the nature or scope of the activities at a
                    particular facility, these summaries may or may not necessarily describe all
                    applicable environmental requirements. Moreover, they do not constitute
                    formal interpretations or clarifications of the statutes and regulations. For
                    further information, readers should consult the Code of Federal Regulations
                    and other state or local regulatory agencies.  EPA Hotline contacts are also
                    provided for each major statute.

VI.A. General Description of Major Statutes

Resource Conservation And Recovery Act

                    The Resource Conservation And Recovery Act (RCRA) of 1976 which
                    amended the Solid Waste Disposal Act,  addresses solid (Subtitle D) and
                    hazardous (Subtitle C) waste management activities. The Hazardous and
                    Solid Waste Amendments (HSWA) of 1984 strengthened RCRA's waste
                    management provisions and added Subtitle I, which governs underground
                    storage tanks (USTs).

                    Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts
                    260-299) establish a "cradle-to-grave" system governing hazardous waste
                    from the point of generation  to disposal.  RCRA hazardous wastes include
                    the specific  materials  listed  in  the  regulations  (commercial chemical
                    products, designated with the code "P"  or "U"; hazardous wastes from
                    specific industries/sources,  designated with the code  "K";  or hazardous
                    wastes from non-specific  sources,  designated with  the  code "F")  or
                    materials which exhibit a  hazardous waste characteristic (ignitibility,
                    corrosivity, reactivity, or toxicity and designated with  the code "D").

                    Regulated entities that generate hazardous waste are subject to waste
                    accumulation, manifesting,  and record keeping standards.  Facilities that
                    treat,  store,  or dispose of hazardous  waste must obtain a  permit, either
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                    from EPA or from a State agency which EPA has authorized to implement
                    the permitting program.   Subtitle  C permits contain general facility
                    standards such as contingency plans, emergency procedures, record keeping
                    and  reporting  requirements,  financial  assurance mechanisms,  and
                    unit-specific standards. RCRA also contains provisions (40 CFR Part 264
                    Subpart S and §264.10) for conducting corrective actions which govern the
                    cleanup of releases of hazardous waste or constituents from solid waste
                    management units at RCRA-regulated facilities.

                    Although RCRA is a Federal statute, many  States implement the RCRA
                    program. Currently, EPA has delegated its authority to implement various
                    provisions of RCRA to 46 of the 50 States.

                    Most RCRA requirements  are not  industry specific but apply to any
                    company that generates, transports, treats, stores, or disposes of hazardous
                    waste. Here are some important RCRA regulatory requirements:

                    •      Identification of Solid and Hazardous Wastes (40 CFR Part 261)
                           lays out the procedure every generator should follow to determine
                           whether the material created is considered a hazardous waste, solid
                           waste, or is exempted from regulation.

                    •      Standards for Generators of Hazardous Waste (40 CFR Part
                           262) establishes the responsibilities of hazardous waste generators
                           including obtaining an ID number, preparing a manifest, ensuring
                           proper  packaging and labeling,  meeting standards  for waste
                           accumulation units, and record keeping and reporting requirements.
                           Generators can accumulate hazardous waste for up to 90 days (or
                           180 days depending on the amount  of waste generated) without
                           obtaining a permit.

                    •      Land Disposal Restrictions (LDRs) are regulations prohibiting the
                           disposal of hazardous waste on land without prior treatment. Under
                           the LDRs  (40  CFR 268),  materials  must meet land disposal
                           restriction (LDR) treatment standards prior to placement in a RCRA
                           land disposal  unit (landfill,  land  treatment  unit, waste pile, or
                           surface impoundment).   Wastes  subject to the LDRs include
                           solvents,   electroplating  wastes, heavy  metals,  and  acids.
                           Generators of waste subject to the LDRs must provide notification
                           of such to the designated TSD facility to ensure proper treatment
                           prior to disposal.
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                    •      Used Oil Management Standards (40 CFR Part 279) impose
                           management requirements affecting the storage, transportation,
                           burning, processing, and re-refining of the used oil.  For parties
                           that  merely  generate  used  oil,  regulations  establish  storage
                           standards.  For a party considered a used oil marketer (one who
                           generates and sells off-specification used oil directly to a used oil
                           burner), additional tracking and paperwork requirements must be
                           satisfied.

                    •      Tanks and Containers used to store hazardous waste  with a high
                           volatile organic concentration must meet emission standards under
                           RCRA.  Regulations (40 CFR Part 264-265, Subpart CC) require
                           generators to test the waste to determine the concentration of the
                           waste, to satisfy tank and container emissions  standards, and to
                           inspect and monitor regulated units.  These regulations  apply to all
                           facilities who store such waste, including generators operating under
                           the 90-day accumulation rule.         -

                    •      Underground Storage Tanks (USTs) containing petroleum and
                           hazardous substance are regulated under Subtitle  I  of RCRA.
                           Subtitle I regulations (40 CFR Part 280) contain tank  design and
                           release detection requirements, as  well as financial responsibility
                           and corrective action standards for  USTs. The UST program also
                           establishes  increasingly  stringent  standards, including upgrade
                           requirements for existing tanks, that must be met by 1998.

                    •      Boilers  and Industrial Furnaces (BIFs) that  use or burn fuel
                           containing hazardous waste must comply with  strict  design and
                           operating standards. BIF regulations (40 CFR Part 266,  Subpart H)
                           address  unit  design,  provide performance  standards,  require
                           emissions monitoring, and restrict  the type of waste that may be
                           burned.

                    EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, responds to
                    questions and distributes guidance regarding all RCRA regulations.  The
                    RCRA Hotline  operates weekdays from 8:30 a.m.  to  7:30  p.m.,  ET,
                    excluding Federal holidays.

Comprehensive Environmental Response, Compensation, And Liability Act

                    The Comprehensive Environmental Response, Compensation, and Liability
                    Act (CERCLA), a 1980 law commonly known as Superfund, authorizes
                    EPA to respond to releases, or threatened releases, of hazardous substances
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                   that may endanger public health, welfare, or the environment.  CERCLA
                   also  enables EPA to  force  parties  responsible  for  environmental
                   contamination to clean it up or to reimburse the Superfund for response
                   costs incurred by EPA. The Superfund Amendments and Reauthorization
                   Act (SARA) of 1986 revised various sections of CERCLA, extended the
                   taxing authority for the Superfund, and created a free-standing law, SARA
                   Title  ffl,  also  known as the Emergency Planning  and Community
                   Right-to-Know Act (EPCRA).

                   The CERCLA hazardous substance release reporting regulations (40
                   CFR Part 302) direct the person in charge of a facility to report to the
                   National Response Center (NRC) any environmental release of a hazardous
                   substance which exceeds a reportable quantity.  Reportable quantities are
                   defined and listed in 40 CFR  §302.4.  A release report may trigger a
                   response by EPA, or by one or more Federal or State emergency response
                   authorities.

                   EPA implements hazardous substance responses according to procedures
                   outlined in  the  National  Oil and  Hazardous Substances Pollution
                   Contingency Plan (NCP) (40 CFR Part 300). The NCP includes provisions
                   for permanent cleanups, known as remedial actions, and other cleanups
                   referred to as "removals."  EPA generally takes remedial actions only at
                   sites on the  National Priorities List  (NPL),  which currently includes
                   approximately 1300 sites.  Both EPA and  states can act at  other sites;
                   however, EPA provides responsible parties the opportunity to conduct
                   removal and remedial actions  and encourages community involvement
                   throughout the Superfund response process.

                   EPA'sRCRA/SuperJund/USTHotline, at (800) 424-9346, answers questions
                   and  references guidance pertaining to  the Superfund program.   The
                   CERCLA Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., ET,
                   excluding Federal holidays.

Emergency Planning And Community Right-To-Know Act

                   The  Superfund Amendments and Reauthorization Act (SARA)  of 1986
                   created the Emergency  Planning and Community Right-to-Know  Act
                   (EPCRA, also known as SARA Title HI), a statute designed to improve
                   community access to information about chemical hazards and to facilitate
                   the development of chemical emergency response plans by State and local
                   governments.   EPCRA required the establishment of State emergency
                   response commissions  (SERCs), responsible  for  coordinating  certain
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                    emergency response activities and for appointing local emergency planning
                    committees (LEPCs).

                    EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish four
                    types of reporting obligations for facilities which store or manage specified
                    chemicals:

                          EPCRA §302 requires facilities to notify the SERC and LEPC of
                          the presence of any  "extremely hazardous substance" (the list of
                          such substances is in 40  CFR Part 355, Appendices A and B) if it
                          has such substance in excess of the substance's threshold planning
                          quantity, and directs the  facility to appoint an emergency response
                          coordinator.

                          EPCRA §304 requires  the facility  to notify the SERC and the
                          LEPC in the event of a release exceeding the reportable quantity of
                          a CERCLA hazardous substance or an EPCRA extremely hazardous
                          substance.

                    •      EPCRA §311 and §312 require a facility at which  a hazardous
                          chemical, as defined by the Occupational Safety and Health Act, is
                          present in an amount exceeding  a specified threshold to submit to
                          the SERC, LEPC and local fire department material safety data
                          sheets (MSDSs) or lists  of  MSDS's and hazardous  chemical
                          inventory forms (also known as Tier I and n forms).   This
                          information helps the local government respond in the event of a
                          spill or release of the chemical.

                    •      EPCRA §313 requires  manufacturing facilities included in SIC
                          codes 20 through 39, which have ten or more employees, and which
                          manufacture, process, or use specified chemicals in amounts greater
                          than threshold quantities, to submit an annual toxic chemical release
                          report.   This report, commonly known as the Form R, covers
                          releases and transfers of toxic chemicals to various facilities and
                          environmental media, and allows EPA to compile the national Toxic
                          Release Inventory (TRI)  database.

                    All information submitted pursuant to  EPCRA regulations is publicly
                    accessible, unless protected by a trade secret claim.

                    EPA's  EPCRA  Hotline,  at (800) 535-0202,  answers  questions  and
                    distributes guidance regarding  the emergency planning and community
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                    right-to-know regulations.  The EPCRA Hotline operates weekdays from
                    8:30 a.m. to 7:30p.m., ET, excluding Federal holidays.
Clean Water Act
                    The primary  objective of  the  Federal Water  Pollution Control  Act,
                    commonly referred to as the Clean Water Act (CWA), is to restore and
                    maintain the chemical, physical, and biological  integrity of the nation's
                    surface waters.  Pollutants regulated under the CWA include "priority"
                    pollutants, including various toxic pollutants; "conventional" pollutants,
                    such as biochemical oxygen demand (BOD), total suspended solids (TSS),
                    fecal coliform, oil and grease, and pH; and "non-conventional" pollutants,
                    including any pollutant not identified as either conventional or priority.

                    The CWA regulates both direct and indirect discharges.  The National
                    Pollutant Discharge Elimination System (NPDES) program (CWA §402)
                    controls direct discharges into navigable waters.  Direct discharges or
                    "point source" discharges are from sources  such as pipes  and sewers.
                    NPDES permits, issued by  either EPA or an authorized State (EPA has
                    authorized approximately forty States to administer the NPDES program),
                    contain  industry-specific, technology-based and/or water quality-based
                    limits, and establish pollutant monitoring requirements. A facility that
                    intends to discharge into the nation's waters must obtain a permit prior to
                    initiating its discharge.  A permit applicant must provide quantitative
                    analytical data identifying the types of pollutants present in the facility's
                    effluent.   The permit will then set forth the  conditions and effluent
                    limitations under which a facility may make a discharge.

                    A NPDES permit may also  include discharge limits based on Federal or
                    State water quality criteria  or standards, that were  designed  to protect
                    designated uses of surface  waters,  such as  supporting aquatic  life or
                    recreation.  These standards, unlike the technological standards, generally
                    do not take into account technological feasibility or costs.  Water quality
                    criteria and standards vary from State to State, and site to site, depending
                    on the use classification of the receiving body of water.  Most States follow
                    EPA  guidelines which propose aquatic life and human health criteria for
                    many of the 126 priority pollutants.

                    Storm Water Discharges

                    In 1987 the CWA was amended to require EPA to establish a program to
                    address storm water  discharges.  In  response, EPA promulgated the
                    NPDES  storm water permit application regulations.  These regulations
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                     require that facilities with the following storm water discharges apply for
                     an NPDES permit:  (1) a discharge associated with industrial activity; (2)
                     a discharge from a large or medium municipal storm sewer system; or (3)
                     a discharge which EPA or the State determines to contribute to a violation
                     of a water quality standard or is a significant contributor of pollutants to
                     waters of the United States.

                     The term "storm water discharge associated with industrial activity" means
                     a storm water discharge from one of 11 categories of industrial activity
                     defined at 40 CFR 122.26. Six of the categories are defined by SIC codes
                     while the other five are identified through narrative descriptions of the
                     regulated industrial activity. If the primary SIC code of the facility is one
                     of those  identified in  the regulations, the facility is subject to the storm
                     water permit application requirements.  If any activity at a facility is
                     covered by one of the five narrative categories, storm water discharges
                     from those areas where the  activities  occur are subject to storm water
                     discharge permit application requirements.
                                                         i
                     Those facilities/activities that are subject to storm water discharge permit
                     application requirements are  identified below.  To determine whether a
                     particular facility falls within one of these categories, the regulation should
                     be consulted.

                     Category i:  Facilities subject to storm water effluent  guidelines, new
                     source performance standards, or toxic pollutant effluent standards.

                     Category ii:  Facilities classified as SIC 24-lumber and wood products
                     (except wood kitchen cabinets); SIC 26-paper and allied products (except
                     paperboard containers and products); SIC 28-chemicals and allied products
                     (except drugs and paints); SIC  229-petroleum refining; and SIC 311-leather
                     tanning and finishing.                ;

                     Category iii:  Facilities classified as SIC 10-metal mining; SIC  12-coal
                     mining;  SIC  13-oil and gas extraction; and SIC 14-nonmetallic mineral
                     mining.

                     Category iv:  Hazardous waste treatment, storage,  or disposal facilities.

                     Category v: Landfills, land application sites, and open dumps that receive
                     or have received industrial wastes.

                     Category vi: Facilities classified as SIC 5015-used motor vehicle parts;
                     and SIC 5093-automotive scrap and waste material  recycling facilities.
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                     Category vii:  Steam electric power generating facilities.

                     Category viii:  Facilities classified as SIC 40-railroad transportation; SIC
                     41-local passenger transportation; SIC 42-trucking and warehousing (except
                     public warehousing and storage); SIC 43-U.S. Postal Service; SIC 44-water
                     transportation; SIC 45-transportation by air; and SIC 5171-petroleum bulk
                     storage stations and terminals.

                     Category ix:  Sewage treatment works.

                     Category x:  Construction activities except operations that result in the
                     disturbance of less than five acres of total land area.

                     Category xi:   Facilities classified as SIC 20-food and kindred products;
                     SIC 21-tobacco products;  SIC 22-textile mill products; SIC  23-apparel
                     related products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-
                     furniture and fixtures; SIC 265-paperboard containers and boxes; SIC 267-
                     converted paper and paperboard products; SIC 27-printing, publishing, and
                     allied industries;  SIC  283-drugs;  SIC  285-paints, varnishes,  lacquer,
                     enamels, and allied products;  SIC 30-rubber and plastics; SIC 31-leather
                     and leather products (except leather and tanning and finishing); SIC 323-
                     glass products;  SIC 34-fabricated metal products  (except  fabricated
                     structural  metal);  SIC  35-industrial and commercial machinery and
                     computer equipment; SIC 36-electronic and other electrical equipment and
                     components;  SIC 37-transportation  equipment (except  ship and boat
                     building and  repairing); SIC  38-measuring, analyzing, and controlling
                     instruments; SIC 39-miscellaneous manufacturing industries; and SIC 4221-
                     4225-public warehousing and storage.

                     Pretreatment Program

                     Another type of discharge that is regulated by the CWA is one that goes to
                     a publicly-owned treatment works (POTWs). The national pretreatment
                     program (CWA §307(b))  controls the indirect discharge of pollutants to
                     POTWs by "industrial users." Facilities regulated under §307(b) must meet
                     certain pretreatment standards.  The goal of the pretreatment program is to
                     protect municipal wastewater treatment plants from damage that may  occur
                     when hazardous, toxic, or other wastes are discharged into a sewer system
                     and to protect the quality of sludge generated by these plants. Discharges
                     to a POTW are regulated primarily by the POTW itself, rather than the
                     State or EPA.
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                    EPA has developed technology-based  standards for industrial users of
                    POTWs. Different standards apply to existing and new sources within each
                    category.  "Categorical" pretreatment standards applicable to an industry
                    on a nationwide basis are developed by EPA. In addition, another kind of
                    pretreatment standard, "local limits," are developed by the POTW in order
                    to assist the POTW in achieving the effluent  limitations in its NPDES
                    permit.

                    Regardless of whether a State is authorized to implement either the NPDES
                    or the pretreatment program, if it develops its own program, it may enforce
                    requirements more stringent than Federal standards.

                    EPA's Office of Water, at (202) 260-5700, will direct callers with questions
                    about the  CWA to  the appropriate EPA office.  EPA also maintains a
                    bibliographic database of Office of Water publications  which  can be
                    accessed through the Ground Water and Drinking Water resource center,
                    at (202) 260-7786.

Safe Drinking Water Act

                    The Safe Drinking Water Act (SDWA) mandates that EPA establish
                    regulations to protect human health from contaminants in drinking water.
                    The law authorizes EPA to develop national drinking water standards and
                    to create a joint Federal-State system  to ensure compliance with these
                    standards. The SDWA also directs EPA to protect underground sources of
                    drinking water through the control of underground injection of liquid
                    wastes.

                    EPA has developed primary and secondary drinking water standards under
                    its  SDWA authority.   EPA and authorized States  enforce the primary
                    drinking water standards, which are, contaminant-specific concentration
                    limits that  apply to certain public  drinking water supplies.  Primary
                    drinking water standards consist of  maximum contaminant level  goals
                    (MCLGs),  which are non-enforceable health-based goals, and maximum
                    contaminant levels (MCLs), which are  enforceable  limits set as close to
                    MCLGs as  possible, considering cost and feasibility  of attainment.

                    The SDWA Underground Injection Control  (UIC) program (40 CFR
                    Parts 144-148) is a permit program which protects underground sources of
                    drinking water by regulating five classes of injection wells.  UIC permits
                    include design, operating, inspection, and monitoring requirements.  Wells
                    used to inject hazardous wastes must also comply with RCRA corrective
                    action standards in order to be granted a RCRA permit, and must meet
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                    applicable RCRA land disposal restrictions standards.  The UIC permit
                    program is primarily State-enforced, since EPA has authorized all but a few
                    States to administer the program.

                    The SDWA also provides for a Federally-implemented Sole Source Aquifer
                    program, which prohibits Federal funds from being expended on projects
                    that may contaminate the sole or principal source of drinking water for a
                    given area, and for a State-implemented Wellhead  Protection program,
                    designed to protect drinking water wells and drinking water recharge areas.

                    EPA's Safe Drinking Water Hotline, at (800) 426-4791, answers questions
                    and distributes guidance pertaining to SDWA standards.   The Hotline
                    operates from 9:00 a.m.  through 5:30 p.m., ET, excluding  Federal
                    holidays.

Toxic Substances Control Act

                    The Toxic Substances Control Act (TSCA) granted EPA authority to create
                    a regulatory framework to collect data on chemicals in order to evaluate,
                    assess,  mitigate,  and control risks  which  may  be  posed by  their
                    manufacture, processing, and use.  TSCA provides a variety of control
                    methods to prevent chemicals from posing unreasonable risk.

                    TSCA standards may apply  at any point during a chemical's life cycle.
                    Under TSCA §5, EPA has established an inventory of chemical substances.
                    If a chemical is not already on the inventory, and has not been excluded by
                    TSCA, a premanufacture notice (PMN) must be submitted to EPA prior to
                    manufacture or import. The PMN must identify the chemical and provide
                    available information on health and environmental effects.  If available data
                    are not sufficient  to evaluate  the  chemicals  effects, EPA can impose
                    restrictions pending the development of information on its  health and
                    environmental effects.   EPA can also restrict significant new uses of
                    chemicals based upon factors such as the projected volume  and use of the
                    chemical.

                    Under TSCA §6,  EPA can  ban  the manufacture  or distribution in
                    commerce, limit the use, require labeling, or  place other restrictions on
                    chemicals that pose unreasonable  risks.   Among  the  chemicals EPA
                    regulates under §6 authority are asbestos, chlorofluorocarbons (CFCs), and
                    polychlorinated biphenyls (PCBs).

                    EPA's TSCA Assistance Information Service, at (202) 554-1404, answers
                    questions and distributes guidance pertaining to Toxic Substances Control
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                    Act standards.  The Service operates from 8:30 a.m. through 4.-30 p.m.,
                    ET, excluding Federal holidays.
 Clean Air Act
                    The Clean Air Act (CAA) and its amendments, including the Clean Air Act
                    Amendments (CAAA) of 1990, are designed to "protect and enhance the
                    nation's air resources so as to promote the public health and welfare and the
                    productive capacity of the population," The CAA consists of six sections,
                    known as  Titles, which direct EPA to establish national  standards for
                    ambient air quality and for EPA and the States to implement, maintain, and
                    enforce these standards  through a  variety of mechanisms.  Under the
                    CAAA, many facilities will be required to obtain permits for the first time.
                    State and local governments oversee, manage, and enforce many of the
                    requirements of the CAAA.  CAA regulations  appear at 40 CFR Parts
                    50-99.

                    Pursuant to Title I of the CAA, EPA has established national ambient air
                    quality standards  (NAAQSs)  to limit levels of "criteria pollutants,"
                    including carbon monoxide, lead, nitrogen dioxide,  paniculate matter,
                    ozone, and sulfur dioxide.  Geographic areas that meet NAAQSs for a
                    given pollutant are classified as attainment areas; those that do not meet
                    NAAQSs are classified as non-attainment areas. Under §110 of the CAA,
                    each  State must develop a State Implementation Plan  (SIP) to identify
                    sources of air pollution and to determine what reductions are required to
                    meet Federal air quality standards.

                    Title I also authorizes EPA to establish New Source Performance Standards
                    (NSPSs),  which  are  nationally uniform  emission  standards  for  new
                    stationary sources falling within particular industrial categories.  NSPSs are
                    based on the pollution control technology available to that category of
                    industrial source but allow the affected industries the flexibility to devise
                    a cost-effective means of reducing emissions.

                    Under Title I, EPA establishes and enforces National Emission Standards
                    for Hazardous Air Pollutants (NESHAPs), nationally uniform standards
                    oriented towards controlling particular hazardous air pollutants (HAPs).
                    Title ffl of the CAAA further directed EPA to develop a list of sources that
                    emit any of 189 HAPs, and to develop regulations for these categories of
                    sources. To date EPA has listed 174 categories and developed a schedule
                    for the establishment of emission standards. The emission standards will
                    be developed for both new and existing sources based on "maximum
                    achievable control technology" (MACT).   The MACT is defined as the
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                    control technology achieving the maximum degree of reduction in the
                    emission of the HAPs, taking into account cost and other factors.

                    Title n of the CAA pertains to mobile sources, such as cars, trucks, buses,
                    and planes. Reformulated gasoline, automobile pollution control devices,
                    and vapor recovery nozzles  on gas pumps are a few of the mechanisms
                    EPA uses to regulate mobile air emission sources.

                    Title IV establishes a sulfur dioxide emissions program designed to reduce
                    the formation  of acid rain.  Reduction of sulfur dioxide releases will be
                    obtained by granting to certain sources  limited  emissions allowances,
                    which,  beginning in 1995,  will  be set below previous levels of sulfur
                    dioxide releases.

                    Title V of the CAAA of 1990 created a  permit program for  all  "major
                    sources" (and certain other sources)  regulated under  the CAA.  One
                    purpose of the operating permit is to include in a single document all air
                    emissions requirements that apply to a given facility.  States are developing
                    the permit programs in accordance with  guidance and regulations from
                    EPA.  Once a State program is approved  by EPA, permits will be issued
                    and monitored by that State.

                    Title VI is intended to protect  stratospheric ozone by phasing out the
                    manufacture  of ozone-depleting chemicals and  restrict their use  and
                    distribution.   Production of Class I substances,  including 15 kinds of
                    chlorofluorocarbons (CFCs),  will  be phased out entirely by the year 2000,
                    while certain hydrochlorofluorocarbons (HCFCs)  will be phased out by
                    2030.

                    EPA's Control Technology Center, at (919) 541-0800, provides general
                    assistance and information on CAA standards. The Stratospheric Ozone
                    Information Hotline, at (800)  296-1996, provides general information about
                    regulations promulgated under Title W of the CAA, and EPA's EPCRA
                    Hotline, at (800) 535-0202, answers questions about accidental  release
                    prevention under CAA  §112(r).   In addition, the Technology Transfer
                    Network Bulletin Board System (modem access (919) 541-5742)) includes
                    recent CAA rules, EPA guidance documents, and updates  of EPA activities.
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VLB. Industry Specific Regulatory Requiremets
                    While the list of environmental statutes potentially  affecting  printers
                    includes all of the major media-oriented statutes, the actual number is much
                    smaller.   In general, printers' relatively  small size.and  lower chemical
                    usage place them below many of the thresholds which would trigger
                    regulatory requirements.  For example, the 70 percent of printers with
                    fewer than ten employees  typically  face only RCRA manifesting and
                    discharge limits  established  by the local publicly owned wastewater
                    treatment works (POTW).  Larger facilities,  however,  may have to meet
                    Clean Air Act requirements  in ozone nonattainment areas, Emergency
                    Planning and Community Right-to Know Act requirements, as well as state
                    requirements established by the State Implementation Plan (SIP) process.
                    These statutes are most frequently triggered because of solvent  releases
                    from image developing, inks and cleaning operations.

                    A fairly complete list of environmental regulations affecting the  printing
                    industry  is available from the Agency's Design for  the Environment
                    Program  or,  more  specifically,   the   document   entitled   Federal
                    Environmental Regulations Potentially Affecting the Commercial Printing
                    Industry (Contact:  Stephanie Bergman 202-260-1821).  Most importantly,
                    it includes examples connecting chemicals  used in the printing industry to
                    applicable  regulations.    More accurate profiles  of  the  regulatory
                    requirements for printing facilities may become available in the near future
                    as projects in  support of consolidated reporting are completed.
       Clean Air Act (CAA)
                    Title  I  - Provisions for Attainment and Maintenance of the  National
                    Ambient Air Quality Standards (NAAQS):
                          •      Reasonably Available Control Technologies (RACTs) as
                                 defined in State Implementation Plans (SIPs) are required at
                                 major sources in "nonattainment" areas, defined by severity
                                 of air quality problems. NAAQS have been established for
                                 six pollutants: ozone, carbon monoxide particulate matter,
                                 sulfur dioxide, nitrogen dioxide  and lead.   Regulations
                                 relating to ozone (VOCs react to form O3),  NQ  and
                                 particulates are likely to have a significant  impact on the
                                 printing industry. Control Technology Guidelines (CTGs)
                                 exist for gravure and flexographic printing, and fabric and
                                 paper coating.  These  CTGs apply primarily  in  ozone
                                 nonattainment areas to sources with potential uncontrolled
                                 VOC emissions (ozone precursors) of 25 tons or more per
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                                  year depending  on the  severity  of the non-attainment
                                  classification. (Contact: David Salman 919-541-0859)
                           •      There are also New Source Performance Standards for the
                                  construction, operation or modification of presses, coalers,
                                  control devices, boilers, cyclones, evaporators, distillation
                                  units, and some bindery equipment.

                    Title V - Permits:
                           •      A new permit system will require all major sources to obtain
                                  operating  permits  to   cover all  applicable   control
                                  requirements.   States were  required to  develop and
                                  implement the program in 1993 and the first permits are
                                  likely to be issued in late  1995.  Although revisions to the
                                  definition of what constitutes a major source were being
                                  negotiated at the time that this document went to press, it is
                                  important to note that major source determination will likely
                                  be based on a faculty's potential emissions and not its actual
                                  emissions; require emissions monitoring, and record keeping
                                  and reporting.

       Resource Conservation and Recovery Act (RCRA)

                    Hazardous waste generators are divided in three categories: large quantity
                    generators  (1,000 kg  or more/month  or  more than  one kg/month  of
                    extremely hazardous  waste); small quantity generators (100  to  1,000
                    kg/month and less than one kg/month of extremely hazardous waste); and
                    conditionally exempt small generators (less than 100 kg/month and less than
                    one kg/month of extremely hazardous waste).  Each generator  bears the
                    responsibility for determining whether or not a waste is hazardous and the
                    appropriate waste code.

                    •      Facility Status  (40  CFR Part 262) - Facilities may possibly  be
                           classified as Treatment Storage or Disposal Facilities (TSDFs) if
                           they do not send their waste off-site before the applicable tune limit
                           (90 to 180 days depending upon the volume).
                           Waste Containers (40 CFR §§262.32, 262.34,  265.171, 265.172
                           and 265.173) - Wastes must be properly stored to meet basic safety
                           requirements and prevent leaks, and must be labeled as hazardous
                           waste and dated at the tune that accumulation begins.
                           Hazardous  Waste Shipments  (40 CFR §262.20) -  A  Uniform
                           Hazardous Waste Manifest must be completed and accompany the
                           shipment.  Wastes must be sent to a RCRA C permitted facility.
                           An exception report must be filed with the relevant regulatory
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                           agency if the manifest copy is not received within 45 days of
                           shipment.  Also, an  exemption is allowed for small quantity
                           generators from the manifest requirement if their waste is shipped
                           under contract, records are maintained for three years, and the
                           vehicle used to haul the waste is owned by the reclaimer.
                           Land  Disposal  Restrictions  (40  CFR  §268.7)  -  Additional
                           notification must be sent along with each manifest to the destination
                           facility.
                     •      Biennial Reporting (40 CFR §262.41) - Large quantity generators
                           must  submit  a  report  of hazardous  waste  generation  and
                           management activities by March 1 of every even-numbered year.
                     •      Record Keeping (40  CFR §268.7) -  Copies of each manifest,
                           biennial report (if a large quantity generator), exception report, test
                           analysis, and inspection log must be kept for three years.
                           Training  (40 CFR §262.34 (a)(4),(d)(5)(iii)) -  Facilities storing
                           waste  for longer than the 90-180 day threshold must ensure that
                           employees are familiar with hazardous waste handling procedures
                           or provide training.
                           Release or Threat of Release Reporting (40 CFR §262.34) - In case
                           of a release to the environment,  the generator  must contact the
                           National Response Center.

       Emergency Planning and Community Right-to-Know Act (EPCRA)

                     •      Emergency Planning (§302(A)) - Businesses that produce, use, or
                           store "hazardous  chemicals" at  or above  "threshold planning
                           quantities" must submit: 1) material safety data  sheets or the
                           equivalent and 2) Tier I/Tier H annual inventory report forms to the
                           appropriate local emergency planning commission.  Those handling
                           "extremely hazardous substances" are also required to  submit a one-
                           time notice to the state emergency response commission.
                     •      Emergency Notification of Extremely Hazardous Substance Release
                           (§304) -  A business  that unintentionally releases a  reportable
                           quantity of an extremely hazardous substance must report that
                           release to  the state emergency planning commission and the local
                           emergency planning commission.
                     •      Release Reporting (§313) - Manufacturing businesses with ten or
                           more employees that manufactured, processed, or otherwise used a
                           listed toxic chemical in excess of the "established threshold" must
                           file annually a Toxic Chemical Release form with  EPA and the
                           state.   Approximately 318 printers  nationwide  submitted forms
                           summarizing their chemical releases in  1993.   Documentation
                           supporting release estimates must be kept for three years.
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       Clean Water Act (CWA)

                    •      Discharges  to  a POTW (40 Part 403) - Facilities  discharging
                           wastewater  to  a sewer are often subject to  restrictions required
                           under the Clean Water Act and established by the local sewerage
                           authority to prevent  significant interference with the treatment
                           facility or pass-through of pollutants not removed by treatment.
                           The  specific requirements include:  notifying  the  POTW  of
                           discharges that could cause problems at the POTW, monitoring and
                           recordkeeping as established by the POTW, and a one-tune notice
                           of the discharge of hazardous waste, specifically, if more than 33
                           pounds/month.
                    •      Direct discharges  (40  CFR  Parts  116  and 117)  -  Facilities
                           discharging hazardous substances are required to notify the federal
                           government (33 §153.203) when discharges meet or exceed the
                           reportable quantity.
                    •      The Storm Water Rule (40 §122.26(b)(14) subpart (xi)) requires
                           that printing facilities falling within any of 11  categories defined in
                           40 CFR 122.26 is subject to  storm  water permit application
                           regulations.

       Occupational Health and Safety Administration (OSHA)

                    A more up-to-date summary of OSHA regulations may be available from
                    OSHA. The following is a summary taken from industry literature.

                    Exposure Monitoring (29 CFR §1910.1045) standard requires initial and
                    periodic monitoring when an employer suspects exposure levels could
                    exceed Permissible Exposure Limits  (PELs).   Also requires employee
                    notification and recordkeeping.

                    Permissible Exposure Limits (PELs) (29 CFR §1910.1000) for chemicals
                    released during printing operations, such as glycol ethers, toluene and
                    methylene chloride.

                    Respiratory Protective Equipment (29 CFR §1910.134) established new
                    standards for protective equipment.

                    Methods of Compliance (29 CFR §1910.1000 and §1910.134) allows the
                    use of a respirator in lieu of administrative or engineering controls during
                    installation of engineering controls or upset conditions.
State Statutes
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                    A 1992  Source Reduction Review Project (SRRP) review of state air
                    regulations found that thirty states (AL, CO, CT, DE, DC, FL, GA, AL,
                    KS, KY, LA, MD, MA, MI, MO, NH? NJ, NY, NC, OH, OK, OR, PA,
                    RI, SC, TN, UT, VA, WA and WI) regulate volatile organic compounds
                    emitted from printing and publishing operations.  In general, all employ the
                    same type  of  standards  with  potential release  triggers of  50,000
                    pounds/year to 500 pounds/day. Typical standards include: 1) specifying
                    a maximum  volatile fraction  (e.g., 25 percent by volume) of ink;  2) a
                    minimum water volume (e.g., 75 percent or a "waterborne ink"); or 3) a
                    minimum nonvolatile fraction (e.g.,  "high solids inks").  In addition,
                    control technologies (i.e., carbon adsorption, incineration, or comparable
                    alternative) are required to reduce or destroy VOCs.  Specific efficiencies
                    are established for gravure and flexographic printing.

                    Illinois, although not included in the 1992 SRRP, is known to have air
                    regulations similar to those described above.

                    California  has emergency  planning  requirements  similar  to those
                    established by EPCRA but the state's lower thresholds result in smaller
                    operations being subject to the planning requirements.

                    California's South Coastal Air Qualify Management District and the Air
                    Pollution  Control District for the County of San Diego have issued
                    regulations affecting graphic arts operations.  These regulations establish
                    standards  for the VOC  content  of inks, cleaning solvents,  fountain
                    solutions, as well as work practices and record-keeping.

VI.C. Pending and Proposed Regulatory Requirements

                    Several regulatory requirements are currently pending that will potentially
                    affect printers.  The Clean Air Act Amendments of 1990 and RCRA are
                    both potential sources of new regulatory requirements.

       Clean Air Act Amendments  of 1990 (CAAA)        :

                    The Clean Air Act Amendments of 1990 included a number of provisions
                    for which the Agency will develop regulations likely to affect printers
                    directly.  A  draft lithography  Control Technology Guidance (CTG)  was
                    announced in the Federal Register in November of 1993 to be used by state
                    and Regional air programs as the basis for controls of VOCs released from
                    lithographic printing operations in ozone nonattainment areas. In June of
                    1994, a lithography Alternative Control Technology  (ACT) was issued in
                    response to the comments received regarding the CTG.
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                    Title I -  Provisions for Attainment and Maintenance of the National
                    Ambient Air Quality Standards (NAAQS):
                    •      Ozone nonattainment areas are classified as: marginal, moderate,
                           serious, severe, or extreme.  "Major" stationary sources are defined
                           as  having potential emissions of 50 tons of VOCs per year in
                           serious areas; 25 tons per year in severe areas; and 10 tons or more
                           in  extreme areas. For all other areas, a major source is one that
                           releases 100 tons of VOCs per year.
                    •      An Alternative Control Techniques Guideline (ACT) was developed
                           for offset lithographic printing which will affect formulations of
                           fountain solutions and cleaning solvents. (Contact: Dave Salman
                           919-541-0859)
                    •      Printers not subject to a CTG but designated a major source are
                           subject to  Reasonably Available  Control  Technology  (RACT)
                           requirements. The state must develop and adopt non-CTG RACT
                           rules for such sources.

                    Title HI - National Emissions Standards for Hazardous Air Pollutants
                    (NESHAP):
                    •      Maximum Achievable Control Technology (MACT) standards are
                           scheduled for a list of 189 Hazardous Air Pollutants (HAPs) listed
                           in §112.  MACT standards for the commercial printing industry are
                           scheduled  for 1994.  The Agency is studying the feasibility and
                           benefits of MACT standards for publication and packaging gravure
                           and wide web flexographic sources. (Contact: Bob Blaszczak 919-
                           541-5432)

       Resource Conservation and Recovery Act (RCRA)

                    •      While  developed  for wastes  such  as  batteries,  simplified
                           recordkeeping and manifesting for a number of waste streams with
                           hazardous constituents, such as rags and wipes containing inks and
                           solvents may apply to printers. (Contact: Ronald Josephson 202-
                           260-6715)

                    •      Additional RCRA listings of solvents and chemicals used by printers
                           are also under investigation.
September 1995
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                       Printing and Publishing
 VH. COMPLIANCE AND ENFORCEMENT HISTORY

        Background

                     To date, EPA has focused much of its attention on measuring compliance
                     with specific environmental statutes.  This approach allows the Agency to
                     track compliance with the Clean Air Act, the Resource Conservation and
                     Recovery Act,  the Clean Water Act, and other environmental statutes.
                     Within the last several years, the Agency has begun to supplement single-
                     media compliance indicators with facility-specific, multimedia indicators
                     of compliance.  In doing so, EPA is in a better position to track compliance
                     with all statutes  at the facility level, and within specific industrial sectors.

                     A major step in building the capacity to compile multimedia data for
                     industrial  sectors  was  the   creation ,of -EPA1 s  Integrated  Data  for
                     Enforcement Analysis (IDEA) system.  IDEA  has the capacity to "read
                     into" the Agency's single-media databases, extract compliance records, and
                     match the records to individual facilities. The IDEA system can match Air,
                     Water, Waste, Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket
                     records  for  a given facility,  and generate a  list of historical  permit,
                     inspection, and  enforcement activity.  IDEA also has the capability to
                     analyze data  by  geographic area and corporate holder.

       Compliance and Enforcement Profile Description

                     Using inspection, violation and enforcement data from the IDEA system,
                     this  section provides information regarding the historical compliance and
                     enforcement activity of this sector. In order to mirror the facility universe
                     reported in the Toxic Chemical Profile, the data reported within this section
                     consists  Of records only  from the TRI  reporting  universe.  With this
                     decision, the selection criteria are consistent  across sectors with certain
                     exceptions.  For  the  sectors  that do not normally report to the TRI
                     program, data have been provided from EPA's  Facility Indexing  System
                     (FINDS) which tracks facilities in all media databases.  Please note, in this
                     section, EPA  does not attempt to define the actual number of facilities that
                     fall within each sector. Instead,  the section portrays the records of a subset
                     of facilities within the sector that are well defined within EPA databases.

                    As a check on the relative size of the full sector universe, most notebooks
                    contain an estimated number of  facilities within the sector according to the
                    Bureau of Census (See Section IT).   With sectors dominated  by small
                    businesses, such as metal finishers and printers, the reporting universe
                    within the EPA  databases may be small in comparison to Census data.
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                    However, the group selected for inclusion in this data analysis section
                    should be consistent with this sector's general make-up.

                    Following this introduction is a list defining each data column presented
                    within this section.  These values represent a retrospective summary of
                    inspections or enforcement actions, and solely reflect EPA, state and local
                    compliance assurance activity that have been entered into EPA databases.
                    To identify any changes in trends, the EPA ran two data queries, one for
                    the past five calendar years (August 10, 1990 to August 9, 1995) and the
                    other for the most recent twelve-month period (August 10, 1994 to August
                    9, 1995).  The five-year analysis gives an average level of activity for that
                    period for comparison to the more recent activity.

                    Because most inspections focus  on single-media requirements,  the data
                    queries presented in this section are taken from  single media databases.
                    These databases do not provide data on whether inspections are state/local
                    or EPA-led. However, the table breaking down the universe of violations
                    does give the reader a crude measurement of the EPA's and states' efforts
                    within each media program.  The presented data illustrate the variations
                    across regions for certain sectors.6  This variation may be attributable to
                    state/local data entry variations,  specific geographic concentrations,
                    proximity to population centers,  sensitive  ecosystems, highly  toxic
                    chemicals used in production, or historical noncompliance.  Hence, the
                    exhibited data do not rank regional performance or necessarily reflect
                    which regions may have the most compliance problems.

Compliance and Enforcement Data Definitions

General Definitions

                    Facility Indexing System (FINDS) - this system assigns a  common
                    facility number  to  EPA single-media permit  records.   The FINDS
                    identification  number  allows EPA to compile  and review all permit,
                    compliance, enforcement and pollutant release data for any given regulated
                    facility.

                    Integrated Data for Enforcement Analysis (IDEA) - is a data integration
                    system that can retrieve information from the major EPA program office
d Reg EPA ions include the following states: I (CT, MA, ME, RI, NH, VT); H (NJ, NY, PR, VT); m (DC, DE, MD,
PA, VA, WV); W (AL, FL, GA, KY, MS, NC, SC, TN); V (EL, IN, MI, MN, OH, WT); VI (AR, LA, NM, OK, XX);
VH (IA, KS, MO, NE); VIE (CO, MT, ND, SD, UT, WY); DC (AZ, CA, HI, NV, Pacific Trust Territories); X (AK,
ED, OR, WA).
September 1995
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                      Printing and Publishing
                    databases. IDEA uses the FINDS identification number to "glue together"
                    separate data records from EPA's databases.  This is done to create a
                    "master  list" of data records for any given facility.  Some of the data
                    systems accessible through IDEA are:  AIRS  (Air Facility Indexing and
                    Retrieval System,  Office of Air and Radiation), PCS (Permit Compliance
                    System,  Office of Water), RCRIS (Resource Conservation and Recovery
                    Information System, Office of Solid Waste), NCDB (National Compliance
                    Data Base,  Office of Prevention,  Pesticides, and Toxic  Substances),
                    CERCIIS  (Comprehensive  Environmental  and Liability  Information
                    System, Superfund), and TRIS (Toxic Release Inventory System).  IDEA
                    also contains information from outside sources such as Dun and Bradstreet
                    and the Occupational Safety and Health Administration (OSHA).  Most
                    data queries displayed in notebook sections IV and Vn were conducted
                    using IDEA.

Data Table Column Heading Definitions

                    Facilities in Search — are based on the universe of TRI reporters within the
                    listed SIC code range. For industries not covered under TRI reporting
                    requirements, the notebook uses the FINDS universe for executing data
                    queries.  The SIC code range selected for each search is defined by each
                    notebook's selected SIC code coverage described in  Section n.

                    Facilities Inspected —  indicates the level of EPA and state  agency
                    inspections for the facilities in this data search. These values show what
                    percentage of the facility universe is inspected in a 12 or 60 month period.

                    Number of Inspections —  measures the total number of inspections
                    conducted in this  sector.  An inspection event is counted each time it is
                    entered into a single media database.

                    Average Time Between Inspections — provides an average length of time,
                    expressed in months, that a compliance inspection occurs at a facility  within
                    the defined universe.

                    Facilities with One or More Enforcement Actions ~ expresses the
                    number of facilities that were party  to at least one enforcement  action
                    within the defined time period. This category is broken down further into
                    federal  and  state  actions.    Data  are obtained  for administrative,
                    civil/judicial, and criminal enforcement actions.  Administrative actions
                    include Notices of Violation (NOVs).  A facility  with multiple enforcement
                    actions is only counted once in this column (facility with three enforcement
                    actions counts as one).
September 1995
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                    Total Enforcement Actions — describes the total number of enforcement
                    actions identified for an industrial sector across all environmental statutes.
                    A facility with multiple enforcement actions is counted multiple times (a
                    facility with three enforcement actions counts as three).

                    State Lead Actions — shows what percentage of the total enforcement
                    actions are taken by state and local environmental agencies.  Varying levels
                    of use by states of EPA data systems may limit the  volume of actions
                    accorded  state  enforcement activity.   Some states extensively  report
                    enforcement activities  into EPA data systems, while other states may use
                    their own data systems.

                    Federal Lead Actions ~ shows what percentage of the total enforcement
                    actions are taken by the United States Environmental Protection Agency.
                    This value includes referrals from state agencies.  Many of these actions
                    result from coordinated or joint state/federal efforts.

                    Enforcement to Inspection Rate — expresses how  often enforcement
                    actions result from inspections.  This value is a ratio of enforcement actions
                    to inspections,  and is presented for comparative purposes only.  This
                    measure is a  rough indicator of the relationship between inspections and
                    enforcement.   Reported inspections  and enforcement actions under the
                    Clean Water Act  (PCS), the  Clean Air Act (AFS)  and the Resource
                    Conservation  and  Recovery Act (RCRA)  are  included  in  this ratio.
                    Inspections and actions from the TSCA/FIFRA/EPCRA database are not
                    factored into this  ratio because most of the actions  taken under these
                    programs  are not the  result of facility inspections.  This ratio  does not
                    account for enforcement actions arising from non-inspection compliance
                    monitoring activities (e.g., self-reported water discharges) that can result
                    in enforcement action within the CAA, CWA and RCRA.

                    Facilities  with One or More Violations Identified  - indicates the
                    percentage of inspected facilities having a violation identified in one of the
                    following  data categories:  In  Violation or Significant Violation Status
                    (CAA); Reportable  Noncompliance,   Current  Year Noncompliance,
                    Significant Noncompliance  (CWA);  Noncompliance and  Significant
                    Noncompliance (FEFRA, TSCA, and EPCRA); Unresolved Violation and
                    Unresolved High Priority Violation (RCRA). The values presented for this
                    column reflect  the extent of noncompliance within the measured time
                    frame, but do not distinguish between the severity of the noncompliance.
                    Percentages within this column may exceed 100 percent because facilities
                    can be in violation status without being inspected.  Violation status may be
September 1995
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                      Printing and Publishing
                    a precursor to an enforcement action, but does not necessarily indicate that
                    an enforcement action will occur.

                    Media Breakdown of Enforcement Actions  and Inspections — four
                    columns identify the proportion of total inspections and enforcement actions
                    within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases.
                    Each column is a percentage of either the "Total Inspections," or the "Total
                    Actions" column.

Vn.A. Printing and Publishing Industry Compliance History

                    Exhibit 20 provides  an  overview of the reported compliance  and
                    enforcement data for the printing industry over the past five years (August
                    1990 to August 1995).  These data are also broken out by EPA Region
                    thereby permitting geographical comparisons. A few points evident from
                    the data are listed below.

                    •     The number of different printing facilities inspected was only
                          slightly  more than one quarter  of those identified hi the IDEA
                          search. Also, these facilities were inspected on average only every
                          four years.

                    •     A significantly smaller proportion of facilities had enforcement
                          actions brought against them than were inspected.  On average 17
                          percent of those facilities inspected faced enforcement actions.

                    •     Those facilities with one or  more enforcement actions  had,  on
                          average,  over the five year period, almost three enforcement actions
                          brought against them.
September 1995
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Sector Notebook Project
                                                        Printing and Publishing
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September 1995
                                74
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 Sector Notebook Project
                      Printing and Publishing
      . Comparison of Enforcement Activity Between Selected Industries

                     Exhibits 21 and 22 allow the compliance history of the printing sector to be
                     compared to the other industries covered by the industry sector notebooks.
                     Comparisons between Exhibits 21 and 22 permit the identification of trends
                     in compliance and enforcement records of the industry by comparing data
                     covering the last five years to that of the past year.  Some points evident
                     from the data are listed below.

                     •      Of those  sectors listed, the printing industry has been one of the
                           least frequently inspected industries over the past five years based
                           upon  its high number of months between inspections.

                     •      State lead actions have dominated the total number of enforcement
                           actions taken against the printing industry.

                     •      Over the past five years, the printing industry has had one of the
                           lowest rates of enforcement actions per inspection of the sectors
                           listed, and the rate has remained constant over the past year.

                     Exhibits 23  and  24 provide a more  in-depth comparison between  the
                     printing industry and other sectors by breaking out the compliance and
                     enforcement  data by environmental statute.  As in the previous Exhibits
                     (Exhibits 21 and 22), the data cover the last five years (Exhibit 23) and the
                     last one year (Exhibit 24) to facilitate the identification of recent trends.
                     A few points evident from the data are listed below.

                     •      The number of inspections carried out under the Clean Air Act and
                           RCRA over the past five years account for over ninety percent of
                           inspections and of total enforcement actions within the sample.
                           This figure has remained constant over the past year.

                     •      Proportional to the number of inspections conducted  under each
                           statute, significantly more enforcement actions are taken under
                           RCRA (with an enforcement to inspection rate of 0.15) than under
                           CAA  (with an enforcement to inspection rate 0.05)
September 1995
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                   Printing and Publishing





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                                      77
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                                        78
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Sector Notebook Project






































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September 1995
79
                                    SIC 27

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Sector Notebook Project
                     Printing and Publishing
VII.C. Review of Major Legal Actions
                    This section provides summary information about major cases that have
                    affected this sector, and a list of Supplementary Environmental Projects
                    (SEPs).  SEPs are compliance agreements that reduce a facility's stipulated
                    penalty in return for an environmental project that exceeds the value of the
                    reduction.  Often, these projects fund pollution prevention activities that
                    can significantly reduce the future pollutant loadings of a facility.

       VH.C.1. Review of Major Cases

                    The Office of  Regulatory  Enforcement  does not  regularly compile
                    information related to major cases and pending litigation within an industry
                    sector. The staff are willing to pass along such information to Agency staff
                    as requests  are  made.  (Contact: Office of Enforcement Capacity and
                    Outreach,   202-260-4140)    In  addition,  summaries of completed
                    enforcement actions are published each fiscal year in  the Enforcement
                    Accomplishments Report;  the summaries are not organized by industry
                    sector. (Contact:  Office of Enforcement Capacity and Outreach, 202-260-
                    4140)

       Vn.C.2. Supplementary Environmental Projects (SEPs)

                    Supplemental environmental projects  (SEPs)  are enforcement options that
                    require the non-compliant facility to complete specific projects. Regional
                    summaries of SEPs undertaken in federal fiscal year 1993 and 1994 were
                    reviewed.  Two SEPs were undertaken  that involved printing facilities, as
                    shown in the following table.

                    EPCRA violations engendered one SEP and RCRA violations engendered
                    the other SEP.  Due to differences in regional descriptions, the specifics of
                    the original violations are not known.  Both of the projects  resulted in a
                    reduction  hi the use  or release of  volatile organic chemicals (VOCs).
                    Implementation  costs were  over $1.7 million  for one of  the projects
                    involving major process changes or capital investments in equipment.  The
                    second project cost $26,150 and consisted of a process chemical change.

                    Both of the SEPs were done in Region VII. However, Region  Vn has only
                    six percent of U.S. printing facilities (third lowest of all Regions) and only
                    eight percent of all inspections (fifth hi rank of all Regions).  The small
September 1995
80
SIC 27

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 Sector Notebook Project








































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September 1995
81
SIC 27

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 Sector Notebook Project
                      Printing and Publishing
 Vm. COMPLIANCE ACTIVITIES AND INITIATIVES

                     This section highlights the activities undertaken by this industry sector and
                     public  agencies  to  voluntarily improve  the  sector's  environmental
                     performance.  These  activities include those independently initiated by
                     industrial trade associations.  In this section, the notebook also contains a
                     listing and description of national and regional trade associations.

 Vm.A. Sector-related Environmental Programs and Activities

 Design for the Environment (DfE) Printing Industry Project

                     The Design for the Environment (DfE) Printing Industry Project (Contact:
                     Stephanie  Bergman 202-260-1821) is  a joint and  cooperative project
                     between the EPA and participating printing industry  sectors (screen,
                     lithographic, and flexographic printing).  Its purpose is to provide printers
                     cost, risk, and performance information of various chemical, technology,
                     and work practice substitutes to enable them to make informed decisions
                     about incorporating lower risk chemicals into their production processes.

                     The draft Cleaner Technologies Substitutes Assessment (CTSA) for screen
                     reclamation  products  and technologies  (used in screen printing)  was
                     published in September 1994 and was  circulated for comment through
                     January 1995. It summarizes the comparative risk, performance, and costs
                     of eleven substitute product systems used to reclaim screens as well as
                     substitute work practices and technologies.  A draft CTSA for lithographic
                     blanket washes will be available in 1995.

                     Pollution prevention case studies and other outreach materials (e.g., videos,
                     software packages, training workshops,  and other information products)
                     will be disseminated to printers by various means  including a network of
                     volunteer printers.  The state of Washington is working with U.S. EPA
                     Region X to disseminate DfE materials and integrate DfE efforts with the
                     state's own "snapshots" initiative (Contact: U.S. EPA Region X - Jayne
                     Carlin 206-553-4762).

                     The DfE Program has also developed a number of background documents,
                     including the following: Printing Industry and Use Cluster Profile; Federal
                    Environmental Regulations Potentially Affecting the Commercial Printing
                    Industry; and Summary of Focus Group Discussions with Screen Printers
                    and Lithographers for the Design for the Environment Printing Project.
                    For more information about these documents or to  request copies of these
September 1995
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Sector Notebook Project
                     Printing and Publishing
                    documents,  please  contact  the  Pollution  Prevention  Information
                    Clearinghouse at 202-260-1023.

       Common Sense Initiative

                    The  EPA's  Common  Sense Initiative was  formally announced by
                    Administrator Browner in July of  1994  to  encourage  sector-based
                    regulatory policy in six pilot industrial sectors including: iron and steel,
                    electronics, metal plating and finishing, automobiles, printing, and oil
                    refining.   The program shifts regulatory focus from concentrating on
                    individual  pollutants  and media,  to  industry-wide  approaches  to
                    environmental problems. An EPA team is involved with other stakeholders
                    from industry, environmental groups, environmental justice groups, labor,
                    and  state and local government agencies to identify opportunities  to
                    coordinate rulemaking  and to streamline record-keeping and permitting
                    requirements.   The teams will also  work with industry to  identify
                    innovative approaches  in pollution  prevention  and  environmental
                    technology, and compliance and enforcement.

                    EPA CSI contacts for printing are as follows:

                           Ginger Gotliffe, Agency Lead (OECA) 202-564-7072
                           Brian Holtrop (OW) 202-260-6814
                           Dave Salman (OAR) 919-541-0859
                           Stephanie Bergman (OPPTS) 202-260-1821
                           Jim O'Leary (OSWER) 202-260-0724
                           Adam Saslow (OPPE) 202-260-2857
                           Paul Shapiro (ORD) 202-260-4969
                           Jim Curtin (OGC) 703-235-5304

       Tfie Great Printers  Project

                    The  Great Printers Project, co-sponsored by the Environmental Defense
                    Fund (EDF), Printing Industries of America (PIA), and Council of Great
                    Lakes  Governors (CGLC), is investigating potential improvements in
                    regulatory implementation and environmental protection.  CGLC,  PIA,
                    U.S. EPA, Great Lakes state regulatory agencies, and EDF have examined
                    the possibility of re-orienting both regulatory  activities  and technical
                    support for lithographic printers toward a whole-facility approach.  One of
                    the first  efforts  was an investigation of the  regulatory requirements
                    currently  facing  printing facilities so that proposals  for consolidated
                    permitting can be developed. Great Printers Project participants published
                    their  first  report  in  July   1994,  "The  Great  Printers  Project:
September 1995
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 Sector Notebook Project
                      Printing and Publishing
                     Recommendations to Make Pollution Prevention a Standard Practice in the
                     Printing Industry," which covers issues from regulatory design to technical
                     outreach. (Contact: Kevin Mills 202-387-3500)

       Environmental Leadership Program

                     In FY94, the Agency's Environmental Leadership Program (ELP) solicited
                     proposals for innovative  approaches to environmental management and
                     compliance at the facility level.  Forty  proposals were received  from
                     companies, trade associations, and federal facilities representing many
                     manufacturing and service sector facilities. In ELP, the EPA will work
                     with individual facilities  to study and evaluate the implementation of a
                     variety of proposed pilot programs.  The information collected from the
                     pilot ELP programs will be used to develop  a full-scale ELP program. The
                     John Roberts Company was one of 12 proposals selected to participate In
                     the  pilot program.   The John Roberts  Company is a medium sized
                     commercial lithographic printer located in Minneapolis Minnesota, who
                     will work on developing  the concept of mentoring as  an environmental
                     auditing tool to proactively and voluntarily verify compliance effectiveness.
                     Other  proposals  are available  for  review  from  the Environmental
                     Leadership  Program.    (Contact:  tai-ming  Chang,  ELP  Director,
                     202-564-5081)
       Project XL
                     Project XL was initiated in March 1995 as a part of President Clinton's
                     Reinventing Environmental Regulation  initiative.  The projects seek to
                     achieve cost effective environmental benefits by allowing participants to
                     replace or modify existing regulatory requirements on the condition that
                     they  produce  greater  environmental  benefits.    EPA  and  program
                     participants will negotiate and sign a Final Project Agreement,  detailing
                     specific objectives that the regulated entity shall satisfy. In exchange, EPA
                     will allow the participant a certain degree of regulatory flexibility and may
                     seek  changes  in underlying regulations  or  statutes.  Participants  are,
                     encouraged to seek stakeholder support from local governments, businesses,
                     and environmental groups.  EPA hopes to implement fifty pilot projects in
                     four categories including facilities, sectors,  communities, and government
                     agencies regulated by EPA.  Applications will be accepted on a rolling
                     basis and projects will move to implementation within six months of their
                     selection.  For additional information regarding XL Projects, including
                     application procedures and criteria, see the May 23, 1995 Federal Register
                     Notice, or contact Jon Kessler at EPA's Office of Policy Analysis (202)
                     260-4034.
September 1995
85
SIC 27

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Sector Notebook Project
                    Printing and Publishing
       Waste Reduction Innovation Technology Evaluation

                    EPA's Office of Research and Development has supported a variety of
                    Waste Reduction  Innovative Technology Evaluation (WRITE) projects
                    related to printing operations including evaluations of water-based inks for
                    wide-web flexographic printing (Erie County, NY) and soy-based inks for
                    lithographic printers (EL) (Contact: Paul Randall 513-569-7673)
       Region I
       Connecticut
       Region IV
       Region VIII
       Region IX
                    Region I's Waste Management Division is giving a grant to Vermont to
                    establish model facilities illustrating compliance and pollution prevention,
                    which may include a printing facility.  A grant to the Printing Industries of
                    New  England  (PINE), also a DfE participant,  provides for on-site
                    compliance outreach, pollution prevention assistance and hazardous waste
                    management assistance to roughly 75 facilities in the Commonwealth of
                    Massachusetts.  (Contacts: Abby Swaine - Region I, 617-565-4523 or Mark
                    Mahoney - Region I, 617-565-1155)
                    The Connecticut Department of Environmental Protection has developed a
                    site assessment tool for printers.
                    Region IV1 s VOC Initiative is hi the planning stages. Once developed, it
                    may impact printers. (Contact: Bill Klutz, Air Enforcement Branch 404-
                    347-2904)
                    Pollution prevention training for printing and metal finishing industries will
                    be open to municipalities with approved pretreatment programs.
                    Geographic Initiative focused in  Southern  California will target  many
                    industries.
September 1995
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Sector Notebook Project
                      Printing and Publishing
Printing, Lithographic and Photo Processing Initiative (Washington State)

                    The Washington Department of Ecology's Hazardous Waste and Toxics
                    Reduction Program is targeting the printing and photo processing industry
                    as one of a series of single industry initiatives.  The assistance is being
                    funded with an EPA pollution prevention grant. The assistance includes:
                    outreach training, seminars and publications, responses to inquiries, hotline
                    and/or on-site assistance to individual facilities.  Local governments and
                    industry trade  associations  in  King  County-Metro  are  participants.
                    (Contacts: U.S. EPA Region X - Nancy Helm  206-553-8659 or Jayne
                    Carlin 206-553-4762; WADEC - Darrin Rice 206-407-6743)

       Oregon Printing Industry Initiative

                    The Oregon Department of Environmental Quality (DEQ) is providing
                    compliance  assistance  to printing,  lithographic,  and photo processing
                    facilities in the state.   Assistance will  be  provided through training,
                    seminars and publications.  (Contacts: Region X - Jayne Carlin 206-553-
                    4762 or Kris Colt 206-553-8577; Oregon DEQ - Marianne Fitzgerald 503-
                    229-5946)

       State Pollution Prevention Roundtable

                    The State Pollution Prevention  Roundtable will soon be publishing a
                    member survey which will summarize state-level  expertise and initiatives
                    according to industry.
September 1995
87
SIC 27

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Sector Notebook Project
                     Printing and Publishing
Vm.B. EPA Voluntary Programs
       33/50 Program
                    The "33/50 Program" is EPA's voluntary program to reduce toxic chemical
                    releases and transfers of seventeen chemicals from manufacturing facilities.
                    Participating companies pledge to reduce their toxic chemical releases and
                    transfers by 33 percent as of 1992 and by 50 percent as of 1995 from the
                    1988 baseline year. Certificates of Appreciation have been given out to
                    participants meeting their 1992 goals.  The  list of chemicals includes
                    seventeen high-use chemicals reported in the Toxics Release Inventory.

                    Of the target chemicals, toluene, methyl ethyl ketone, xylenes, and 1,1,1-
                    trichloroethane  are released and transferred most frequently by the printing
                    and publishing industry.  These four toxic chemicals account for roughly
                    86 percent of TRl releases and transfers for printing facilities. Twenty-five
                    companies listed under SIC  27 (printing and publishing)  are currently
                    participating in the 33/50 program.  They account for 12 percent of the 206
                    TRI reporting companies under SIC 27, which is approximately the average
                    level  of  participation  for all  industries  (14 percent).    (For  more
                    information, contact: Mike Burns,  U.S. EPA, 202-260-6394 or 33/50
                    Program 202-260-6907.)
       WasteWi$e Program
                    The WasteWi$e Program was started in 1994 by EPA's Office of Solid
                    Waste and Emergency Response.  The program is  aimed at reducing
                    municipal solid wastes by promoting waste minimization, recycling
                    collection, and the manufacturing and purchase of recycled products.  As
                    of 1994, the program had about 300 companies as members, including a
                    number of major corporations.  Members agree to identify and implement
                    actions to reduce their solid wastes and must provide EPA with their waste
                    reduction goals along with yearly progress reports.  EPA, in turn, provides
                    technical assistance to member  companies  and allows the use  of  the
                    WasteWi$e logo for promotional purposes.  (Contact: Lynda Wynn 202-
                    260-0700 or the WasteWi$e Hotline at 800-372-9473)
       Climate Wise Recognition Program
                    The Climate Change Action Plan was initiated in response to the U.S.
                    commitment to reduce greenhouse gas emissions in accordance with the
                    Climate Change Convention of the  1990 Earth Summit.  As part of the
                    Climate Change Action Plan, the Climate Wise Recognition Program is a
September 1995
88
SIC 27

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 Sector Notebook Project
                       Printing and Publishing
                     partnership initiative run jointly by EPA and the Department of Energy.
                     The voluntary program is designed to reduce greenhouse gas emissions by
                     encouraging reductions  across all  sectors of the economy,  encouraging
                     participation in the full range of Climate Change Action Plan initiatives,
                     and fostering innovation.  Participants in the program are required to
                     identify and commit to actions that reduce greenhouse gas emissions.  The
                     program, in turn, gives organizations early recognition for their reduction
                     commitments; provides  technical assistance through consulting  services,
                     workshops, and guides;  and provides access to the program's centralized
                     information  system.   At EPA,  the program is operated by the Air and
                     Energy Policy Division within the  Office  of Policy  Planning  and
                     Evaluation.  (Contact: Pamela Herman 202-260-4407)
       NICE?
                     The U.S. Department of Energy and EPA's Office of Pollution Prevention
                     are jointly administering a grant program called The National Industrial
                     Competitiveness through Energy,  Environment, and Economics (NICE).
                     By providing grants of up to 50 percent of the total project cost,  the
                     program encourages industry to reduce industrial waste at its source and
                     become  more  energy-efficient  and cost-competitive  through  waste
                     minimization efforts.   Grants  are used  by industry to design, test,
                     demonstrate, and assess the feasibility of new processes and/or equipment
                     with the potential to reduce pollution and increase energy efficiency.  The
                     program  is open to all industries;  however, priority is given to proposals
                     from participants in the pulp and  paper, chemicals, primary  metals, and
                     petroleum and  coal  products sectors.  (Contact: DOE's  Golden Field
                     Office, 303-275-4729)
Vm.C. Summary of Trade Associations
                    The trade and professional organizations serving the printing industry are
                    divided along printing processes as well as type of product produced.  For
                    example, there are several trade groups for lithographers as well as the
                    American Newspaper Publishers Association, which typically print using
                    lithographic presses.  The large number of small facilities in this industry
                    results in two important characteristics of the trade associations. First, a
                    large number of facilities  are not affiliated with any trade associations.
                    Second, a significant portion of the industry research is conducted through
                    trade associations and/or technical foundations which serve the needs of the
                    many smaller members who would otherwise have limited or indirect access
                    to research.
September 1995
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SIC 27

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Sector Notebook Project
                     Printing and Publishing
                    Printing industry membership in trade organizations is approximately 50
                    percent. The majority of printers not associated with trade groups are small
                    printers with fewer than ten employees.  Outreach efforts to unaffiliated
                    small printing shops have been problematic for the printing industry trade
                    associations.   The In-Plant Management  Association's  membership,
                    however, includes in-house operations that would otherwise be difficult to
                    identify or contact as the main business is not printing. Industry officials
                    reported  that the trade press, which may be read by nonmembers, and
                    suppliers of equipment and chemicals, offer two vehicles for reaching
                    unaffiliated small printers.
September 1995
90
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 Sector Notebook Project
                      Printing and Publishing
 LITHOGRAPHY
 Printing Industries of America
 100 Daingerfield Rd.
 Alexandria, VA 22314
 Phone: (703) 519-8100
 Fax: (703) 548-3227
     Members: 13,200
     Staff: 70
     Budget: $12,000,000
     Contact: Tom Purcell
 Since its inception in 1887, Printing Industries of America (PIA) has grown to be the largest trade
 group for the printing sector, with the largest membership and budget.   PIA  focuses on
 lithographic printing, although their membership includes other printing processes and suppliers.
 Technical service and support to members occurs through more than 30 strong regional organiza-
 tions.  PIA publishes a variety of periodicals including The Capital Letter,  a monthly dedicated
 to government regulatory issues.  They are involved in the DfE Printing Industry Project, the
 Common Sense Initiative, and the Great Printers  Project and  have developed a voluntary
 environmental management program for printers.  Affiliated trade  associations are located
 throughout the United States.
Graphic Arts Technical Foundation
4615 Forbes Ave.
Pittsburgh, PA 15213
Phone: (412) 621-6941
Fax: (412) 621-3049
     Members: 7,000
     Staff: 72
     Budget: $6,000,000
     Contact: Gary Jones
Graphic Arts Technical Foundation (GATF), established in 1924, is a scientific, technical and
educational organization  serving the graphic communications industries.  Members represent
printers, packagers, binders, publishers, design houses, and suppliers.  They provide in-facility
technical support and training to members as well as evaluations of and educational outreach for
advancing technologies.  GATF performed laboratory testing of alternative lithographic blanket
washes for the DfE Printing Industry Project.
September 1995
91
SIC 27

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Sector Notebook Project
                    Printing and Publishing
National Association of Printers and
Lithographers
780 Palisade Ave.
Teaneck, NJ 07666
Phone: (201) 342-0700
Fax: (201) 692-0286
    Members: 3,700
    Staff: 38
    Budget: $5,000,000
The National Association of Printers and Lithographers (NAPL), founded in 1933, is actively
engaged  in  presenting conferences, seminars,  and workshops on management  topics for
lithographic printers.  It holds over 50 such functions each year. NAPL focuses on business and
management planning rather than technical  support for the shop-level employee. They publish
the Environmental Advisor newsletter and  Printing Manager magazine.  NAPL officials also
participate in the DfE Printing Industry Project.
Printing and Graphic Communications Association
7 West Tower
1333 H Street, NW
Washington, DC 2005
Phone: (202) 682-3001
September 1995
92
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 Sector Notebook Project
                      Printing and Publishing
 GRAVURE
 Gravure Association of America
 1200-A Scottsville Rd.
 Rochester, NY 14624
 Phone: (716) 436-2150
     Members: 250
     Staff: 20
 The Gravure Association of America (GAA),  founded in 1987, promotes the use of gravure
 printing in publications and the general advancement of gravure printing techniques. The GAA
 compiles statistics about the gravure industry, coUects/analyzes/disseminates current and historical
 information on environmental issues, government regulations, marketing, and gravure technology,
 and runs a seminar/lecture series. The Rochester Institute of Technology provides GAA and its
 members with academic research, testing facilities and personnel training. It is unique in that all
 types of  suppliers (e.g., waste management vendors,  chemical and equipment suppliers) are
 members  and are active participants hi many GAA activities.  The GAA publishes GAA Today,
 which covers environmental regulations, ink and solvent testing, as well as other topics.
September 1995
93
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Sector Notebook Project
                    Printing and Publishing
FLEXOGRAPHY
Flexographic Technical Association
900 Marconi Ave.
Ronkonkoma, NY 11779
Phone: (516) 737-6020
                Members: 1,400
                Staff: 20
Founded in 1958, the Flexographic Technical Association (FTA) is the major industry trade group
for the flexographic process.  FTA's stated purpose is to "advance the art and science of
flexographic printing and assist and recommend developments in flexography."  Membership
includes suppliers as well as printers.  The FTA leads regional workshops for production,
supervisory, and management personnel and publishes a monthly magazine entitled Flexo, which
has a circulation of 9,200.
 September 1995
94
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Sector Notebook Project
                      Printing and Publishing
SCREEN PRINTING
Screenprinting and Graphic Imaging
Association International (SGIA)
10015 Main Street
Fairfax, VA 22031
Phone: (703) 385-1335
Fax: (703) 273-0456
     Members: 3,000
     Staff: 29
     Budget: $2,900,000
     Contact: Marcia Kinter
Founded in 1948, the Screenprinting and Graphic Imaging Association International (SGIA)
represents  the interests of the screen printing industry throughout the world.   SGIA  offers
technical assistance on all matters concerning the screen printing and graphic imaging industry;
conducts educational programming for the industry; compiles industry statistics; and offers a wide
variety of management and government related services.

SGIA was the industry partner in the DfE assessment of spreen reclamation products.  The
Association is closely associated with the Screen Printing Technical Foundation (SPTF).  SPTF
conducts research into the  screen printing process.  The foundation also participated in the DfE
screen printing project by providing the laboratory evaluation of alternative screen reclamation
products submitted to the project.
September 1995
95
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Sector Notebook Project
                     Printing and Publishing
OTHER ASSOCIATIONS
In-Plant Management Association
1205 W. College Ave.
Liberty, MO 64068
Phone: (816)781-1111
    Members: 2,700
    Staff: 5
Founded in 1964, the In-Plant Management Association represents managers of in-plant printing
and graphics operations. Members are most frequently located within academic institutions (20
percent) and insurance companies (12 percent). They offer training, educational, and certification
programs. IPMA conducts research, surveys and studies on industrial and technological trends.
National Association of Quick Printers
401 N. Michigan Ave.
Chicago, EL 60611
Phone: (312) 644-6610
    Members: 3,400
    Staff: 4
Founded in 1975, the National Association of Quick Printers (NAQP) serves printers that offer
"printing-while-you-wait" as well as suppliers.  Many of their members are franchise operators.
The technology is typically turnkey, xerographic printing, but there is increased use of small
lithographic presses in the industry.
Environmental Conservation Board
of the Graphic Communications Industries
1899 Preston White Drive
Reston, VA 22091-4367
Phone: (703) 648-3218
    Contact: Mark Nuzzaco
The Environmental Conservation Board (ECB) was founded in 1972 to provide a unified and
coordinated approach to environmental issues affecting the graphic communications industry.
ECB is an intra-industry organization for environmental affairs for the printing, publishing,
newspaper, packaging,  and metal decorating industries and their suppliers.  Members are
predominantly  other trade associations,  not individual companies.  Work  is conducted by
subcommittees convened to address specific issues.  Current projects include: review of draft CTG
for lithography, participation in DfE Core Group and in the Common Sense Initiative, information
dissemination at trade shows, ECB Environmental Conference, and a newsletter and information
database.
September 1995
96
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 Sector Notebook Project
                     Printing and Publishing
 National Association of Printing Ink
 Manufacturers
 47 Halstead Ave.
 Harrison, NY 10528
 Phone: (914) 835-5650
     Members: 140
     Staff: 5
The National Association of Printing Ink Manufacturers (NAPIM) was founded in 1914 and
represents manufacturers of all types of printing inks.  NAPIM publications include Printing Ink
Handbook, Raw Materials Data Handbooks, as well as bulletins and booklets.
September 1995
97
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                      Printing and Publishing
 EX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/REFERENCES f

                     For further information on selected topics within the petroleum refining
                     industry a list of contacts and publications are provided below:

 Contacts
Name
Ginger Gotliffe
David Salman
Ron Josephson
Stephanie Bergman
Organization
EPA/OECA
EPA/OAR
EPA/OSW
EPA/DfE
Telephone
(202) 564-7072
(919) 541-0859
(202) 260-6715
(202) 26-1821
Subject
Regulatory requirements and compliance
assistance. CSI lead.
Industrial processes and regulatory
requirements (Air)
Industrial processes and regulatory
requirements (RCRA)
Nonregulatory initiatives and DfE.
OECA: Office of Enforcement and Compliance Assistance
OAR: Office of Air and Radiation
OSWER: Office of Solid Waste and Emergency Response
DfE: Design for the Environment Program


General Profile
Printing Industry and Use Cluster Profile, U.S. EPA.  June 1994. EPA 744-R94-003.

U.S. Industrial Outlook 1994, Department of Commerce.

Graphics Arts Monthly: The Magazine of the Printing Industry, 249 W.  17th St. New York, NY
10011  (212) 463-6834

Bruno, Michael H.  1991. Michael H. Bruno's Status of Printing, 1991 Update: A State of the
An Report.  Salem, NH: GAMA Communications.

Lewis, A.F.  1991. Blue Book Marketing Information Reports: Graphic Arts Industry Analysis
by Plant Size, Equipment, Product Specialties. New York, NY: A.F. Lewis & Co., Inc.
      Many of the contacts listed above have provided valuable background information and comments during the
development of this document.  EPA appreciates this support and acknowledges that the individuals listed do not
necessarily endorse all statements made within this notebook.
September 1995
99
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Sector Notebook Project
                     Printing and Publishing
HRA (Packaging, Paper, Printing and Publishing, and Nonwovens Abstracts) database, available
through the DIALOG Information Retrieval Service.  PIRA provides coverage of the literature
of the pulp and paper, packaging, printing, publishing, and nonwovens industries.

See summary of trade associations (Section m.C.4) for periodicals targeted to establishments
using specific printing processes.
Process Descriptions and Chemical Use Profiles	

Printing Industry and Use Cluster Profile, U.S. EPA.  June 1994.  EPA 744-R94-003.

Cleaner Technologies Substitutes Assessment for Screen Printing: Screen Reclamation, U.S. EPA,
DfE Printing Industry Project, Draft September 1994.

Draft National Emission Standards for the Printing  and Publishing Industry - Background
Information Document, U.S. EPA, OAR- OAQPS.
Regulatory Profile	

Federal Environmental Regulations Possibly Affecting the Commercial Printing Industry, U.S.
EPA, DfE Printing Industry Project, EPA744B-94-001, March 1994.

Tlie Great Printers Project: Recommendations to Make Pollution Prevention a Standard Practice
in the Printing Industry, Council of Great Lakes Governors, Printing Industries of America, and
Environmental Defense Fund, July 1994.

For a listing of all state environmental agency contacts relevant to the printing industry, refer to
the March, 1995 issue of Graphic Arts Monthly.

Pollution Prevention	

Guides to Pollution  Prevention: The Commercial Printing Industry, EPA/625/7-90/008, U.S.
EPA, August 1990.

Technical Information Publication  PRINTING,  New Jersey  Department of Environmental
Protection.

Blanket Wash Technology Study: An Evaluation of Commercially Available Blanket Washes, The
Massachusetts  Toxics Use Reduction Institute, Technical Report No. 16, 1994.
September 1995
100
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 Sector Notebook Project
                      Printing and Publishing
 Cleaner Technologies Substitutes Assessment for Screen Printing: Screen Reclamation, U.S. EPA,
 DfE Printing Industry Project, Draft September 1994.

 Replacement of Hazardous Material in Wide Web Flexographic Printing Process, Kranz, P.,
 Williamson, T., and Randall, P., funded by Risk Reduction Engineering Laboratory, U.S. EPA.

 Guides to Pollution Prevention: The Photoprocessing Industry, EPA/625/7-91/012, U.S. EPA,
 October 1991.


 Innovative Clean  Technologies Case Studies, EPA/600/R-93/175, U.S. EPA, August 1993.

 Innovative Clean Technologies Case Studies Second Year Project Report, EPA/600/R-94/169
 U.S. EPA, April  1994.


 Waste Reduction Evaluation of Soy-Based Ink at a Sheet-Fed Offset Printer, EPA/600/SR-94/144,
 U.S. EPA, September 1994.

 On-site Waste Ink Recycling, EPA/600/SR-92/251, U.S. EPA, February 1993.

 Ink and Cleaner  Waste Reduction Evaluation for Flexographic Printers, EPA/600/SR-93/086
 U.S. EPA, July 1993.


 Several of the documents listed above can be obtained from the Pollution Prevention Information
 Clearinghouse (PPIC) at (202) 260-1023.
September 1995
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                    Printing and Publishing
                                    References

1.    U.S. Department of Commerce, Bureau of the Census. 1987 Census of Manufacturers.

2.Bruno, Michael H. Michael H. Bruno's Status of Printing, 1991 Update: A State-of-the-Art
Report.  Salem, NH: GAMA Communications, 1991.

3.    U.S. Department of Commerce, Bureau of the Census. 1987 Census of Manufacturers.

4.    Lewis A.F. Blue Book Marketing Information Reports: Graphic Arts Industry Analysis by
      Plant Size, Equipment, Product Specialties.  New York, NY:  A.F. Lewis & Co., Inc.,
      1991.

5.    U.S. Department of Commerce, Bureau of the Census. 1987 Census of Manufacturers.

6.    U.S. Department of Commerce, Bureau of the Census. 1987 Census of Manufacturers.

7.    EPA, Printing Industry and Use Cluster Profile. June 1994. EPA 744-R94-003.

8.    SRI.  Printing 2000.  Prepared by SRI International, Menlo Park, CA for the Printing
      2000 Task Force, Printing Industries of America, Alexandria, VA.  1990.

9.    U.S. Department of Commerce, Bureau of the Census. 1987 Census of Manufacturers.

10.   Lewis A.F. Blue Book Marketing Information Reports: Graphic Arts Industry Analysis by
      Plant Size, Equipment, Product Specialties.  New York, NY: A.F. Lewis & Co., Inc.,
       1991.

11.   U.S. Department of Commerce, Bureau of the Census. 1987 Census of Manufacturers.

12.   U.S. Department of Commerce.  U.S. Industrial Outlook 1994.  January 1994.

13.   U.S. Department of Commerce.  U.S. Industrial Outlook 1994.  January 1994.

14.   U.S. Department of Commerce.  U.S. Industrial Outlook 1994.  January 1994.

15.   Bruno, Michael H.  Michael H. Bruno's Status of Printing, 1991  Update: A State-of-the-
      Art Report.  Salem, NH: GAMA Communications, 1991.

16.    EPA, Printing Industry and Use Cluster Profile.  June 1994. EPA 744-R94-003.

17.    EPA, Guides to Pollution Prevention: The Commercial Printing Industry.  August 1990.
       EPA 625-7-90-008.

18.    University of Northern Iowa Waste Reduction Center. Pollution Prevention Manual for
       Lithographic Printers, 1995.
 September 1995
102
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Sector Notebook Project
                      Printing and Publishing
 19.    EPA, Control Techniques Guideline for Offset Lithographic Printing.  July 12, 1993.

 20.    EPA, Printing Industry and Use Cluster Profile. June 1994. EPA 744-R94-003.

 21.    Telecon.  Keenan, Cheryl, Abt Associates Inc., Cambridge,  MA, with Flexographic
       Technical Association.  July 1994.

 22.    EPA, Printing Industry and Use Cluster Profile. June 1994. EPA 744-R94-003.

 23.    EPA, Printing Industry and Use Cluster Profile. June 1994. EPA 744-R94-003.
September 1995
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                                APPENDIX A
       INSTRUCTIONS FOR DOWNLOADING THIS NOTEBOOK

          Electronic Access to this Notebook via the World Wide Web (WWW)
This Notebook is available on the Internet through the World Wide Web. The Enviro$en$e
Communications Network is a free, public, interagency-supported system operated by EPA's Office
of Enforcement and Compliance Assurance and the Office of Research and Development. The
Network allows regulators, the regulated community, technical experts, and the general public to
share information regarding: pollution  prevention and innovative technologies; environmental
enforcement and compliance assistance; laws, executive orders, regulations, and policies; points of
contact for services and equipment; and other related topics.  The Network welcomes receipt of
environmental messages, information, and data from any public or private person or organization.

ACCESS THROUGH THE ENVIROSENSE WORLD WIDE WEB

      To access this Notebook through the Enviro$en$e World Wide Web, set your World Wide
      Web Browser to the following address:
      http ://eS . inel . gOV/OeCa - then select "EPA Sector Notebooks"

      Or after 1997, (when EPA plans to have completed a restructuring of its web site) set
                      your web browser to the following address:


      WWW.epa.gOV/OeCa -  then select the button labeled Gov't and  Business
                                     The Notebook will be listed.

      HOTLINE NUMBER FOR E$WWW: 208-526-6956

      EPA E$WWW MANAGERS: Louis Paley 202-564-2613
                                Myles Morse 202-260-3151
(This page-updated June 1997)
Appendix A

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