This section outlines regulatory and compliance issues found in each step of the flexographic printing process, as well as the "Top 10" compliance issues found in a typical flexographic printing facility. This section also contains links to key fact sheets, checklists, service providers and other resources to help answer regulatory questions which apply to waste generated in typical conditions at a flexographic printing facility. 

Regulated Wastes and Outputs from the Flexographic Printing Process  

PREPRESS - Imaging Process (Overview)  

http://www.p2rx.org/topichubs/externallink.cfm?l=7598

PRODUCTION - Printing Process (Overview)

http://www.pneac.org/printprocesses/

Outputs Regulation(s)  

Volatile organic compounds (VOCs) air emissions from solvent based ink and alcohols in water based inks. Clean Air Act Hazardous air pollutants from cleaning solvents, thinning solvents, and inks Clean Air Act Waste or obsolete ink Hazardous Waste or Solid Waste (RCRA) Waste water used in cleaning Clean Water Act, Hazardous Waste Regulations (RCRA) Waste solvent used in cleaning Hazardous Waste Regulations (RCRA), Clean Water Act Solid waste from unacceptable prints, make-ready, and trim scrap paper. Solid Waste Rags and towels containing inks, solvents, grease and oils. Hazardous Waste or Solid Waste Regulations (RCRA) 

FINISHING - Post Press Operations (Overview)  

http://www.pneac.org/printprocesses/

Outputs Regulation(s)  

Reject prints and trim scrap Solid Waste Used boxes and shipping materials Solid Waste Rags containing oil, grease, solvents, and adhesives Hazardous Waste (RCRA) or Solid Waste Waste wash water containing adhesives and/or solvents Clean Water Act, Hazardous Waste (RCRA) VOC emissions from solvent based adhesives Clean Air Act VOC emissions from cleaning solvents Clean Air Act Solvent parts washer waste Hazardous Waste (RCRA) and Clean Air Act 

Why Change?

• To reduce risk exposure for employees.
• To reduce workers compensation, fire and liability insurance costs.
• To improve credit worthiness as a result of reduced risk of contaminated property concerns.
• To improve operational efficiency (reduce material costs).
• To improve product and work environment.
• To gain or maintain market advantage.
• To reduce or eliminate applicability of environmental regulations (reduce disposal costs and annual permit fees).

• Benchmark operations using compliance & pollution prevention checklists.
• Identify options/alternatives for action.
• Consider ramifications of not making a change, review future risk.
• Consider how recent changes in regulation apply to past activities that were at one time legal.
• Act on best alternative.
• Evaluate change and document measurable reductions. This may require a long-term evaluation/review.
• Obtain assistance from trade associations, peers, and environmental assistance organizations (State & University programs).

• Film fixer & developer - Silver in solution can cause a local wastewater treatment infraction, and can be a hazardous waste issue.
• Solvents - Total consumed counts towards Clean Air Act permit status; volume that does not evaporate can be a hazardous waste.
• Plate Processing Solvents - Total solvent consumed counts towards Clean Air Act permit status; volume that does not evaporate can be a hazardous waste.
• Volume of waste ink and clean-up waste, if characteristically hazardous, counts toward waste generator status. Generator status compliance requirements increase with the volume of waste generated.

• A Hazardous Waste Inspector will look for proper labeling of product and waste containers.
• A Hazardous Waste Inspector will look for failure to make a hazardous waste determination.
• A Hazardous Waste Inspector will look for drips, stains, spills and puddles within and outside the facility.
• A Hazardous Waste Inspector will look for illegal disposal of a hazardous waste (e.g. they will look in dumpsters and outside the building before ever knocking on the facility's door).
• An Air Inspector will look for improper determination of "potential to emit" VOCs, HAPs, and particulates.
• An Air Inspector will look at pollution control device (PCD) operation records to determine proper operation and evidence that the PCD has been by-passed.
• A Hazardous Waste or an Air Inspector will look for open/closed containers of volatile or hazardous materials.
• A Hazardous Waste or an Air Inspector will look for leaking valves and venting systems.
• A Water Inspector will look into streams and gullies on or near your property, and in drains and man holes on your property in search of evidence of illegal discharges. The inspector looks for things such as flammable vapors, discoloration, and oily sheen in the water.
• A Water Inspector will ask to review your NPDES/Stormwater permits and self-inspection records.
• A Water Inspector will inquire how the facility determined that an NPDES permit is not required at the facility.
• All inspectors [Hazardous Waste, Air, Water or OSHA (different agency)] will look for availability and accessibility of current MSDS information.
• All inspectors will look for and question personnel to determine operator knowledge of hazards and risks associated with chemicals used in the work place.
• All inspectors will look for responsible party's knowledge of regulations.
• All inspectors will look at your compliance history.
• All inspectors can and may request supporting information for regulatory status.
• All inspectors will keep an eye open for the most common violations (e.g. see OSHA's Top 10 Violations list on their web site).