In-plants and Environmental Compliance

Protecting the environment has become business-critical for in-plant printing operations. 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. The last item has the potential to impact in-plants more than independent printing operations due to the relationship of the in-plant to its parent organization.

Most in-plants are generally aware they have environmental compliance requirements. The challenge is understanding the specific requirements that apply to your operation and taking steps to ensure compliance. What surprises many in-plant operations is that virtually every environmental regulation applies to printing facilities. The degree to which the regulations apply depends upon several factors, namely geographical location and the thresholds set under each regulation.

Basic Requirements

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, followed by the state, and then 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 many 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 stormwater. 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 are strictly prohibited. Under the stormwater 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 stormwater discharge permit.
• Resource Conservation and Recovery Act — Regulates hazardous waste, nonhazardous waste, universal waste, and underground storage tanks. Recent changes in the regulations provide 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. For in-plants, the amount of hazardous waste they generate must be added to the amount of hazardous waste generated by the remainder of the organization. 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 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 hazardous wastes.

• 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 operations 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 must be aggregated to determine if a reporting threshold has been exceeded. Plus, certain Persistent, Bioaccumulative and Toxic Chemicals (PBTs) such as lead have a very low Toxics Release Inventory (TRI) reporting threshold. For lead, it is only 100 lbs. 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 that are identified as contributing waste, even if it was legal to dispose of it, are responsible for cleanup costs associated with the contaminated property. Therefore, it is important to 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 their portion of cleanup costs.

Environmental Compliance Action Plan

The regulations identified here 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.

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.

PRINTING United Alliance has many resources designed to assist printing operations address their compliance programs. Please contact the Alliance’s Government Affairs Department at govtaffairs@printing.org with your questions.