Environmental Compliance and Small Printing Operations
Protecting the environment has recently become one of the more business-critical activities that small printing operations need to embrace. There has been considerable attention dedicated to addressing climate change; plastic waste; the emergence of the circular economy; and environmental, social, and governance (ESG) commitments and reporting. ESG commitments and reporting have the potential to impact small operations more than independent printing operations due to the relationship of the small to the parent organization.
An important aspect of the recent environmental focus is compliance with environmental regulations. Most printing operations are generally aware that they have environmental compliance requirements. The challenge is understanding the specific requirements as they apply to your operation and taking specific steps to ensure compliance.
What surprises many small printing operations is that virtually every environmental regulation applies to printing facilities. The degree in which the regulations apply depends upon several factors, namely geographical location and the thresholds set under each regulation.
Environmental regulations should be viewed as a pyramid, with the Federal Environmental Protection Agency (EPA) sitting at the top, state regulatory requirements in the middle, and local requirements at the bottom. Compliance begins at the bottom with the local requirements first, followed by the state, and then the EPA’s requirements. This is because the federal EPA sets the minimum and state/local regulatory authorities can make their requirements more stringent. They can never be less stringent.
The most common regulations that must be met include those under the following laws:
- Clean Air Act – Regulates emissions of air pollutants. The most common air pollutants emitted by printers are volatile organic compounds (VOCs) and hazardous air pollutants (HAPs), which include conventional and digital inks, fountain solutions, coatings, varnishes, adhesives, and cleaning solvents. Due to the continued problem with unacceptable air quality in many states, the thresholds for air permit and control requirements have been lowered to the point that any printing operations are now required to obtain permits and reduce emissions of air pollutants. At one time, the thresholds were much greater than they are now, and even very small printing operations can be required to meet the rules and obtain an air permit.
- Clean Water Act – Regulates discharges of industrial wastewater and contaminated storm water. Discharges of wastewater to a local sewer authority must meet the acceptable discharge limits that are in the sewer code. Flammable substances cannot be discharged to the local sewer, and discharges of any industrial wastewater to a septic system is strictly prohibited. Under the storm water regulations, all facilities that fall under certain Standard Industrial Classification (SIC) codes that own their building or lease a standalone building must either complete and submit a “no exposure certification” or file for a storm water discharge permit.
- Resource Conservation and Recovery Act – Regulates hazardous waste, nonhazardous waste, universal waste, and underground storage tanks. There have been recent changes in the regulations providing for greater flexibility. The regulatory requirements that need to be met are based on the generator classification (e.g., Very Small Quantity Generator, Small Quantity Generator, and Large Quantity Generator), which is determined by the amount of hazardous waste generated per month. The most common hazardous waste generated by small printers is waste cleaning solvents. Improperly managing hazardous wastes is not uncommon and, in many instances, it is because of an incomplete understanding of what constitutes a hazardous waste and how they are to be properly managed. For example, hazardous wastes must be collected in designated and closed containers that are properly labeled. Solvent contaminated wipes need to be properly collected and managed to ensure that they are not classified as a hazardous waste. Common wastes such as fluorescent light bulbs, other mercury-containing lamps or devices, batteries, CRT screens, and depending upon the state, aerosol cans and some paint wastes, are classified as Universal Wastes and need to be recycled or managed as a hazardous waste.
- Emergency Planning and Community Right-to-Know Act – Requires the reporting of releases of certain hazardous substances above the applicable reportable quantity, submission of annual inventory reports for materials stored above specific thresholds, and annual emission reports for a specific list of chemicals used above specific thresholds. While most printing shops do not store or use enough chemicals to trigger reporting under these regulations, some state and local authorities require reporting for quantities as low as 55 gallons. In addition, the total amount of chemicals stored and used at the entire facility need to be aggregated to determine if a reporting threshold has been exceeded. Plus, certain Persistent Bioaccumulative and Toxic chemicals such as lead have a very low Toxic Release Inventory reporting threshold. For lead, it is only 100 pounds. If a printer is still melting and casting lead, then this threshold is easily exceeded, thus triggering the annual report, which is due every July 1.
- Comprehensive Environmental Response Compensation and Liability Act or SUPERFUND – Regulates the cleanup of abandoned contaminated property. All parties who are identified as contributing waste, even if it was legal to dispose of it at the facility being cleaned up, are responsible for the cleanup costs associated with the contaminated property. Therefore, it is important to know and understand what happens to any industrial waste that is removed from the facility as printing operations have been caught up in Superfund cleanup sites and have had to pay for their portion of the cleanup costs.
Environmental Compliance Action Plan
The above identified regulations are only a broad description of the requirements. An effective environmental compliance program involves two steps: information management and establishing procedures for employees to follow. This is best accomplished with an Environmental Management System (EMS). An EMS is a structured management system specifically designed to address EHS compliance, pollution prevention, and environmental cost containment. In essence, it is a system of policies, procedures, and documentation to ensure:
- Compliance with applicable regulations
- Detection and correction of procedural breakdowns
- Detection and correction of potential violations
- Incorporation of continuous improvement by pollution prevention, reducing wastes and cutting costs
While establishing an EMS may seem overwhelming, the parent organization may already have an EMS program in place. If not, the best approach is to break the process down into smaller steps.
Start by educating yourself on your organization’s and department’s compliance requirements. This will help you identify those regulations applicable to your situation and what steps need to be taken to ensure compliance. The following provides a starting point:
- Identify and coordinate the development and implementation of programs with the person(s) who is responsible for environmental compliance at the parent company.
- Ensure that any environmental requirements are understood and being followed.
- Survey the workplace and current practices to see how chemicals and wastes are being managed, what reports are being completed, and which records are being kept.
- Based on the results of the survey, create job- or task-specific protocols that incorporate environmental requirements. For example, directing that all hazardous wastes are collected in closed and properly labeled containers and the waste is shipped offsite within the prescribed deadline.
- If necessary, provide appropriate personal protective equipment (PPE) along with training on how to properly use it.
- Provide and document all training required by the environmental regulations, especially waste management.
- Conduct regular inspections of the workplace to ensure compliance with requirements is being met and procedures are being followed.
- Keep records of compliance including the following:
- Safety Data Sheets (SDSs) for the materials used. Information on the SDS can be used to apply for permits, calculate facility emissions, submit reports, and determine if a material could be a hazardous waste;
- A copy of your air permit or emission calculations to show an air permit is not required;
- Any wastewater and stormwater monitoring data you collect to demonstrate compliance with applicable local, state, and federal requirements and permits;
- Waste profile sheets, EPA’s 8700 form for generator ID number and renotification, hazardous waste manifests, Landfill Disposal Restriction (LDR) forms, and bills of lading, receipts for shipments of hazardous, universal waste, and nonhazardous wastes;
- Annual air emission reports, Tier Two forms, and other state/local reports;
- Copies of correspondence, permits, applications, surveys, and reports;
- Periodic self-audits to monitor and maintain compliance programs;
- Any other environmental test results including testing protocols; and,
- Employee training records.
Summary and Conclusion
Because your operation is required to meet environmental regulations, knowing and understanding how each one applies is essential to demonstrating compliance. This is accomplished through knowing and understanding what regulations apply to your operation and then establishing an environmental compliance program.
The PRINTING United Alliance’s Government Affairs Department has many resources designed to assist printing operations address their compliance programs. Please contact the Government Affairs Department at firstname.lastname@example.org with your questions.