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When many of the environmental and employee community right-to-know regulations were originally passed in the mid 90's, printers were surprised that they were now part of the "regulated community." A few brave souls made the commitment to comply while others took a "let's wait and see" attitude. But the picture is changing. Cities and state agencies are beginning to face stricter and stricter EPA rules regarding their compliance with air, water, and landfill pollution. Consequently, they look for businesses that generate pollution and place restrictions on them. Since the possibilities of a city inspector visiting a printer are much, much greater than a visit from the EPA or OSHA, more and more printers are making efforts to comply. Non-attainment boundaries broadening to counties adjoining Dallas and Tarrant. Still, many printers are confused as to what the regulations mean and which ones apply. The laws are complex and quite frequently overlap. What applies to Taylor Publishing also applies to a quick printer, yet the regulations are written with Taylor in mind. "I really would like to comply. But it's so confusing and I just don't have time to dig through all the information," says a small commercial printer in Dallas. This complaint is heard quite frequently throughout the state. Yet, because of the potential financial - and in some cases criminal liability - it's imperative that management be aware of all the regulations and make every effort to follow them. This paper presents a general overview. Not all the details of the various regs are included, of course, but it's generally good to know what the regs are designed to do and who's impacted. OSHA & The Grapic Arts Of all the regulations affecting printers, OSHA's (Occupational Safety and Health Administration) requirements impact printers on a daily basis - regardless of whether a printer employs one person or 200. This PIA-Texas publication has been designed to quickly familiarize management with the major htmlects of the regulations. For more specific information, it will be necessary to contact PIA-Texas or purchase one of the regulatory publications produced by PIA that will give detailed information on the desired topic. Some areas of the regulation, such as record keeping, only impact firms with 10 or more employees, while others, such as Hazard Communications, affect all companies in the graphic arts. Log & Summary Report (OSHA No. 200) It is mandatory that this form be posted as an annual summary between February 1 and March 1. A proposed OSHA 300 Form to make record keeping simpler. The form will eliminate columns for illness, and restricted duty. It will also require the employer to retain only the past three (3) year reports instead of five (5) years and update LWD injuries that extend into following years every quarter. Supplementary Record (OSHA No. 101) A new supplementary form (OSHA 301) will be required to accompany each injury recorded on the OSHA #300. The new form will be required to have more accident specific info. Employee Poster Record Retention Other Written Documentation Hazardous Materials Emergency Response - If a potential for uncontrollable release of a hazardous substance (if the substance is a substantial threat or it's a large amount) exists, the company is required to develop a written emergency response plan that will cover:
Noise and Hearing Conservation Program - If noise exposure equals or exceeds 85 db on a time weighted average, a printer is required to establish and administer a Hearing Conservation Plan. The plan should include:
Plant Health & Safety Hazard Communications Standard 1) Develop a written Hazard Communication Policy. This written document/statement must be available to all employees and OSHA officials. It must include:
2) Obtain MSDS for all chemicals in use. Determine their hazards and how they are to be safely used in production. 3) Label all containers storing chemicals in use. Determine their hazards and how they are to be safely used in production. 4) The employer must establish a training and information program for employees at the time of initial assignment or whenever a new hazard (chemical) is introduced. The training program must include:
Bloodborne Pathogens Under the "post" part of the rule (which covers all graphic art firms), any designated first aid providers or "good Samaritans" who render assistance in any situation involving blood or other potentially infectious material, must be offered a full immunization series as soon as possible, but in no event later than 24 hours after the event. If an "exposure incident" takes place, that is a specific eye, mouth, non-intact skin contact, with blood or other potentially infectious materials results from the administration of first-aid, the following procedures must be initiated immediately:
Lockout/Tagout The printer is responsible for establishing procedures and making sure that affected employees are trained. The training must include all employees that are authorized to operate the equipment (maintenance personnel) as well as the equipment's operators. The policy, as well as training, should cover the lockout/tagout procedure, the type of device for lockout (shape, color, format), as well as when it is to be used. The regulations require that lockout/tagout procedures be used if: A guard or other safety device is bypassed or removed Personnel are required to place any part of their body into an area on a machine or piece of equipment where work is performed Where an associated danger zone exists during machine operation In the printing industry, this standard is typically applicable for cleaning and washing operations, oiling and lubricating, equipment replacement operations, and unjamming paper runs. Since makereadies and changeovers often require the operator to place hands into areas of the machinery where he may be at risk, it is imperative that the "stop/safe/ready" button be used properly in order for the operator not to be required to lockout the equipment. Anytime that the operator is at risk, e.g., cleaning blankets, clearing a paper jam, etc., the procedure shall be "inch / safety-on / clean / safety-off / inch." A continuous slow roll of the blanket while cleaning is not allowed. Emergency Evacuation Plan
If the fire suppression system is activated during an emergency, a responsible person must be designated for reactivation of the suppression system after the emergen cy and the fire department has left. General Plant Safety Issues Fire Extinguishers - These devices need to be inspected on a regular basis as having the appropriate extinguisher near the potential fire hazard it's been designated to fight. Their location must be clearly marked and access to the extinguisher must not be blocked. The top of the extinguisher can not be more than five feet off the floor, and it if weighs more than 40 pounds, it can not be more than three and one-half feet off the floor. Fire extinguisher static tests every three (3) years and internal tests every five (5) years. Fire hoses must be tested five (5) years after new and every three (3) years after that. Grounding - Everything electrical in the shop must be grounded. Container Labeling - All chemical containers must be
properly labeled. A label must list the manufacturer, product
and hazard information. The only exception to the labeling requirement
is when the liquied will be consumed within one shift or a color
coded labeling system is adopted. Power Panels - Fuse switches and panels need to be labeled regarding the equipment they control. There also has to be a four-foot clear area in front of these panels. Unrestricted access at all times. Wiping Towels - Used press rags must be stored in a proper (closeable) container after they've been used. Soiled rags should be transferred to sealed containers daily or when collection cans become full. Towels used to "sop" up oil should not be left in the open since OSHA inspectors have been known to fine for this infraction. Compressed Air Cleaning - The use of compressed air for cleaning when the pressure is greater than (30) psi is an OSHA violation. Air pressure regulators should be set for no more than 30psi or nozzle defusers (holes drilled in the side of air nozzles) must be used. Aisle Markers - Aisles must be clearly marked using white, yellow, or black/yellow combination aisle tape. Minimum width or 28" is required. Keep aisles clear of skids and equipment. Skids/Press Dollies - Skids should not be stored on end but flat. Dollies with casters need to be stored so that they will not create a walking hazard in the pressroom. Exits - All exits need to be clearly marked. If a door might be confused as an exit, mark it "No Exit" (closed, washroom, etc.). Make sure that exits are not blocked and exit door opens out. Belts & Guards - This is probably one of the most frequently violated OSHA rules. All safety. guards on equipment (side frames, cylinder guards, belt guards, etc.) must be in place and not altered to facilitate operation. Electrical - Make sure that extension cords are the right length as well as grounded. All electrical junction and fuse boxes must be closed at all times. Check for loose wiring and worn insulation. Make sure that wiring is not oil soaked. All electrical service not contained in conduit is considered temporary and must be removed or properly installed in a reasonable amount of time. Offset Powder - This is a potential fire hazard, so make sure that equipment and surrounding areas are kept free and clear of powder. First Aid - A cabinet with contents in individual packages must be available to all employees. It is always a good safety practice to have first aid kits available to all employees. Emergency Eyewash - An eye wash fountain must be available if employees may be exposed to corrosive chemicals (developer, plate developer, and fountain etch fall in this category). By no means is this list exhaustive. There are quite a few potential infractions in a print shop - from not having personal protective equipment available to employees, to not storing ladders properly, to not training fork lift operators in safety practices. For more information, contact PIA-Texas or your local OSHA office. Resource Material PIGC OSHA Hazcom Compliance Manual & Video - This publication available through PIA-Texas outlines the methods that a company needs to follow in order to comply with this set of regs. An employee training video is also included. Hazard Communications Manual - This publication produced by PIA details all of the information necessary to comply with OSHA's Employee right-to-know regulation. Also included are MSDS definitions and a "boilerplate" haz com policy. PIA Safety Manual & Video - This helpful text and video provides an insight into developing a safety program which can improve plant safety and help in complying with OSHA regulations. OSHA Bloodborne Pathogen Rule - PIA Management Portfolio (September 1992). SARA Title III (Community Right-to-Know Law) This law tracks the use of dangerous chemicals and makes the general public aware of any releases of these chemicals into the water or atmosphere. Very few printing companies in Texas are covered by this regulation. One provision, which requires extensive reporting, may affect some printers if: "The printer stores 10,000 pounds or more of a chemical defined as hazardous and/or stores 500 pounds or more of any chemical listed as extremely hazardous." There are currently 366 chemicals listed by the EPA as hazardous or extremely hazardous. Here's a partial list of those chemicals which might be found in a printing company: Propylene Glycol (Solvents) Section 313 of the Act requires a company with at least 10 full-time employees and stores 10,000 pounds or more of any chemicals requiring a MSDS to document annually their releases to the environment of listed toxic chemicals. These releases must also include transfers to offsite facilities. Fortunately, most printers aren't large enough to be covered by this regulation, which prior to the 1990 Clean Air Act, was one of the most onerous of all the regulations. Summary: If more than 500 pounds of any specific chemical (not mixture, but a single chemical, such as Formaldehyde) was consumed, it will be necessary to determine if it is on the EPA's list of hazardous chemicals. In addition, if more than 10,000 pounds of any one chemical (regardless whether it's listed or not) was used, this triggers reporting under Section 313. Source Material Texas Tier Two Reporting (Texas Community Right-to-Know Law) The State of Texas has a reporting regulation very similar to the federal SARA Title III. Printers who at any time during the year used a chemical in quantities of more than 10,000 pounds are required to file a Texas Tier Two report. This report must be filed by March 1 with the Texas Department of Health, the County Local Emergency Planning Committee (LEPC), and the local fire department having jurisdiction. Prior to 1993, the reporting threshold was 500 pounds. Source Material Hazardous Waste Regulations If a business offers typesetting, photographic, plate, and/or press services, varying amounts of hazardous waste are being generated. Federal law requires that any waste determined to be hazardous, "must be disposed of in an approved manner." Although this is a federal law, it is left to the state (TNRCC and the local municipalities to determine what is considered a hazardous waste. The city has to meet the state's guidelines, but may adopt guidelines that are more stringent. In reality, it is the city that determines what is hazardous. For example, the federal and state guidelines assert that any spent fixer solution with more than 5 milligrams (mg) per liter of silver is considered to be hazardous. Yet, every Texas city has a differing level. Here are the silver thresholds (as of 1992) for the major cities in Texas: Amarillo - 1 Mg/liter Typically, electrolytic silver reclaiming will bring the silver level of fixer down to approximately 1.5 mg/l. As can be seen, in some cities the reclaimed fixer solution would nevertheless still be considered hazardous (San Antonio) but in others it could be legally disposed of in the sewer (Dallas). Here are the steps necessary to comply with this regulation: 1. Determine if a waste stream is hazardous given local or state regulations. This process may include, but is not limited to, knowledge of process and EPA approved laboratory testing. If the waste stream is hazardous, ascertain if the waste can by recycled, or the process/chemistry be changed so that a hazardous waste is not produced. 2. If the waste stream is considered hazardous, assign it a hazardous waste number per prescribed TNRCC procedures. 3. File for a TNRCC Hazardous Waste Generator number as well as an EPA ID number. 4. Select the method of disposal. Keep in mind that the regulators hold the printer responsible from the moment the chemical is purchased until the final disposal/recycling of any waste by-products. Waste disposal should be handled by a certified hazardous waste hauler with an EPA license. These haulers must "manifest" (i.e., complete an EPA approved shipping document) for any shipments made. By law, within 90 days of pickup, a copy should be returned to the generator along with the disposal site acknowledgements showing receipt of the material. Current recommended disposal options include recycling, recovery, and incineration. Landfill disposal is a possible means of toxic waste handling, but it is not recommended due to the potential legal and environmental ramifications. Storage of accumulated waste is possible, but limited by the classification of the generator. Most printers fail in two categories: Conditionally Exempt Small Quantity Generator - If a firm generates hazardous waste from 1 kilogram (2.2 pounds) up to 100 kilograms per month, it falls under this classification, and may store waste indefinitely as long as the amount does not exceed 1,000 kilograms. Small Quantity Generator - A company generating more than 100 kilograms but less than 1,000 kilograms per month falls under this classification. It may store up to 6,000 kilograms of waste but for a period no longer than 180 days. Generator classification is based on how many pounds of hazardous waste is disposed of in a month. Waste that is recycled or legally disposed of in the sewer is not included in this count. Conditionally Exempt Small Quantity Generators are exempt from reporting requirements (other than manifesting). Small Quantity Generators are required to perform monthly and annual reporting. Summary: It will first be necessary to determine if the printer generates any hazardous waste. If waste is generated, the printer will have to classify the waste stream and determine how much waste is being generated in a month. Once this is done the printer must acquire the appropriate permits from the state and EPA. All hazardous waste must be disposed of in an approved manner and manifested. Sources Storm Water Discharge Permitting This 1991 regulation has the potential to affect every printer in the state. Although the industry is presently exempt from federal requirements, as of the fall of 1994 there were proposed federal regulations covering the industry. The law is designed to minimize the amount of chemicals from exposed storage areas that leak into storm water sewers during heavy rainfalls. If permitting is required, the local municipality will make the printer aware of the process. Printers may have to permit if any chemical or hazardous waste storage is exposed to the elements. Thus, if a company is storing solvent drums outside of its building (because OSHA and the fire department won't let them be kept inside), a permit might be required. If the printer's industrial waste container (dumpster) is not covered, and it has potential to leak during a rainstorm, the company may have to obtain a permit. The permitting process may require extensive monitoring and testing of water runoff. These tests are not inexpensive. There is also the possibility that if chemical runoff is discovered (from some other source) on the printer's property, the printer would be required to remedy the problem - a potentially expensive alternative. The solution_ Don't store any chemicals outside! Comply with the regulation by not exposing chemical or waste containers to possible storm water runoff. Cover trash bins (bins with covers are fine - but the covers need to be closed at all times). Clean Air Act of 1990 This regulation is just starting to be interpreted and its full impact probably won't be felt until the late '90s. The Clean Air Act targets Volatile Organic Compounds (VOCs). In the printshop, this includes solvents, ink oils, and alcohol. These chemicals, when exposed to sunlight, create ozone in the lower atmosphere (there are other chemicals - CFC's that destroy ozone in the upper atmosphere - but that's another story). If a company has more than 15 employees, there is a high probability that it will be impacted. But in the long run all printers will be affected because of the mandated chemistry changes which will be placed on the industry over the next three - five years. Here are the existing and proposed regulations as they pertain to the industry. Existing Regulations 1. All printing companies or trade services using VOCs are required to be permitted by the Texas Natural Resource Conservation Commission (TNRCC), unless they meet specific exemption requirements. A printing company is exempt if: No single printing press generates more than 15 tons of VOCs (this limit will probably be lowered to 10 tons in the future; Total emissions of the plant are less than 25 tons of VOCs. 2. Permits are specifically required of all heatset web presses installed since January 11, 1985. There is presently discussion at the TNRCC to require permitting of all heatset webs regardless of installation date. 3. Companies that are exempt, must nevertheless file an exemption form with the TNRCC. Given that there is a good possibility that the regulations will become more stringent in the future, PIA-Texas recommends that all printers, regardless of size, file for an exemption and track the amount of VOCs being generated on a once-a-year basis. The exemption will only hold until permitting or reporting thresholds are exceeded. 4. Printers in the Dallas/Fort Worth area (Tarrant, Dallas, Denton, and Collin counties) and in El Paso are located in serious ozone non-attainment areas. Any printer in these areas generating more than 10 tons of VOCs must complete an annual emissions inventory listing the VOC chemicals and other listed hazardous air pollutants (HAP). 5. Companies required to permit must follow specific EPA established guidelines (known as the Offset Printing Control Techniques Guidelines (CTG)) regarding the amount of alcohol and types of solvents used in production. Along with the chemical constraints, there are also requirements as to how ink towels will be handled as well as mandated reduction of total VOC emissions. 6. Printers will be able to "bank" inventory emission reductions. These reductions can be sold at a future date to "major source generators" (companies generating more than 100 tons of VOCs). As of today, this is still a very ambiguous part of the law since there are no VOC "banks" in place nor are there any specific guidelines established for sellers to show that the reductions actually occurred. Proposed Regulations Fountain Solutions Sheetfed Web-Heatset Web-Non-heatset Companies must also document their use of IPA. At the beginning of a shift or when a new batch of fountain solution is prepared, the press operator must document the percentage of alcohol being used as well as the temperature of the fountain solution. Firms running an alcohol substitute cannot use IPA as an additive, and the total amount of VOCs in the fountain solution cannot exceed 3%. Cleaning Solutions Summary: It's imperative that printing companies inventory their VOC emissions in order to create a baseline and determine whether or not they have to complete annual inventories or permit with the TNRCC. Any company that does not have to permit should file for a standard exemption (Form PI-7) with the TNRCC. It also behooves companies to study their existing chemistry, and see if they can use alcohol substitutes and solvents that have lower VOC constituents in order to avoid permitting or annual reporting. Once the regulations are finalized (Early 1995), PIA-Texas and the Texas Natural Resources Conservation Commission will publish the final regulations. Sources CFC Labeling Requirements The Clean Air Act Amendments of 1990 placed stringent labeling requirements on companies that "manufacture" products with chemicals that may deplete stratospheric ozone. Printing companies are receiving correspondence from their customers requesting that they certify whether a printed product is or is not manufactured with one or more of these chemicals. The law requires the labels to be in place by October 15, 1993, and more and more companies will be receiving the requests in the future. Title IV of the Clean Air Act This breakdown causes the hole in the ozone layer that in turn allows harmful amounts of ultraviolet (UV) radiation to reach the earth's surface. (This depletion of upper atmosphere ozone is quite separate from the increase in ozone at ground level, a participant in smog formation.) The U.S. Environmental Protection Agency issued a proposed regulation on May 4, 1992, to implement the law. This rule lists the substances of concern as well as the specific labeling requirements for products containing or manufactured with the ozone-depleting materials. The Chemicals Printers normally would not be using CFCs and HCFCs, except in coolants and refrigerants, or halons, except those found in fire extinguisher apparatus. There is a fairly high use, however, of methyl chloroform in press or blanket cleaners. The use of this product has been greatly reduced since this regulation was passed in 1990. The question that arises is whether these uses require a label. Action Required You must check the Material Safety Data Sheets (MSDS) for the materials that are part of the final product - the inks, coatings and glues - and they must be evaluated for the Class I and II chemicals. If any are found, the best course of action is to replace the materials with one that does not contain any of the chemicals of concern. Not replacing the material would require you to label your products and probably lose the business of the customers who do not want their products labeled. If no ozone-depleting chemicals are contained in the printed materials, the next step is to determine if they are manufactured with one of the Class I chemicals. The question here hinges on the EPA definition of "manufactured." The EPA proposed in the original notice that manufactured means that a product is produced using a controlled substance but it does not contain that substance at the point of sale to the final customer. EPA also proposed to exclude from the definition incidental uses of the chemical in the manufacturing process. This exclusion is important because one example EPA gave of incidental use was that of a textile mill where the machinery is maintained with methyl chloroform. This is certainly the equivalent of cleaning the presses with products containing methyl chloroform or other Class I materials, so it seems justified to say that printed materials are not manufactured with any of the ozone-depleting chemicals. However, while it is unlikely that printers will have to label their products because they are "manufactured" with ozone-depleting chemicals, use of fountain solutions or automatic blanket washes containing these materials could prove problematic. Fountain solutions are a perfect example of materials incorporated in the manufacturing process: They are applied to the product but evaporate before the product reaches the customer. Thus, if the fountain solution contains one of the Class I chemicals, a label would be required. The case for blanket wash in automatic blanket washers is more difficult to ascertain. If a blanket wash containing one of the Class I chemicals is applied to the blanket, it is certainly absorbed by the paper. However, since this only occurs for a small percentage of the printed material and is not part of the manufacturing process but rather a part of the press maintenance process, it seems fair to conclude that this use does not require labeling. No guidance has been issued by EPA but it does appear justified under the circumstances. The best solution is to rid your shop of all Class I and II chemicals except those in the air conditioner and fire extinguishers. Products are available which do not contain any of the listed chemicals. Summary The Class I and II chemicals will be phased out of production before the year 2000 as listed in the Clean Air Act Amendments of 1990; therefore, you should be making a very strong effort to find replacements for the products you are using. Local Ordinances The State of Texas has a multitude of municipalities and counties - all with differing regulations regarding water and air pollution. For example, both the cities of Houston and Dallas require air pollution permits of printing companies. Fees range from as low as $300 upwards of $1,500 per year. The city of Austin is presently considering a like requirement. |
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Having problems trying to figure out what you need to do to make sure your shop is is compliance with OSHA, the EPA and state and local agencies_ PIA-Texas is offering a service targeting printers who can't justify the expense of a full time employee to handle their safety and environmental issues. PIA-Texas/OSHA Safety First Partnership It Pays To Be a Member |