Federal Regulations
The Federal EPA implements rules covering air emissions, waste disposal, and water discharges. Below discusses how these rules affect ink manufacturers and the graphic arts market.
Printing Inks & Hazardous Waste
The Resource Conservation & Recovery Act (RCRA) regulations cover cradle-to-grave management of hazardous waste and apply to every facility which generates such waste. Exemption from some of the rules is given to very small waste generators and bona fide in-house reclaiming and resource recovery operations are generally exempted.
The regulations pertaining to the management of hazardous waste are set forth in 40 CFR Parts 190-299 and may be purchased from the Government Printing Office, Washington, DC 20402. Explanations of the RCRA regulations are also to be found in a variety of other sources including publications of EPA, printing and converting trade associations, and consultants. For the convenience of the reader, some of the basic provisions of the hazardous waste rules are summarized below. EPA regulations for characterizing hazardous waste. Waste printing inks when subject to the RCRA rules are regulated as characteristic wastes: ignitable; toxic; reactive; corrosive.
Litho Inks
Generally, non-energy curable heat-set and cold-set inks are non-hazardous from a Federal RCRA waste disposal perspective. Some states regulate “oily waste”. Energy-curable inks may be regulated depending on the photoinitiator used.
Flexo and Gravure Inks
Generally, water-based flexo inks are non-hazardous from a Federal RCRA waste disposal perspective. Solvent-based flexo inks are generally regulated based on flammability. Energy-curable inks may be regulated depending on the photoinitiator used.
Barium-based Pigments
Printing inks containing barium-based pigments (e.g. warm reds) may exceed the Toxicity Characteristic Leaching Procedure (TCLP) barium limit of (100 mg/l).
Solvent Contaminate Wipes
On July 31, 2013, EPA issued a final rule that modifies the hazardous waste management regulations for solvent-contaminated wipes under the Resource Conservation and Recovery Act (RCRA). Each delegated state must adopt the rule. Check your state requirements here.
Air
The Clean Air Act was last amended in 1990. This amendment addressed environmental issues like acid rain, toxic pollutants, areas still not at regulation standards, and ozone layer depletion. Massive decreases in certain gas emissions were mandated to control acid rain; increased regulation of toxic pollutants; deadlines for non-compliant areas; and three major chemical contributors to ozone layer depletion were phased out.
The federal Environmental Protection Agency (EPA) is ultimately responsible for establishing standards and enforcing the Clean Air Act, although much of the daily business of fighting air pollution takes place at the state and local levels. The Clean Air Act defines EPA’s responsibilities for protecting and improving the nation’s air quality and the stratospheric ozone layer.
From an ink manufacturing and graphic communications market perspective the primary compliance responsibilities relate to volatile organic compounds (VOC) and hazardous air pollutants (HAP).
VOC Definition
The definition used by the Federal EPA for volatile organic compounds can be found at 40 CFR 51.100(s). Accordingly, “Volatile organic compounds (VOC) means any compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate, which participates in atmospheric photochemical reactions.”
Calculating VOC Content
The use of component raw material(s) VOC content to calculate the VOC content of the mixture is permissible. Appropriate quality control measures should be employed to insure the accuracy and validity of the calculated values.
Ink Oil Retention Factors
Heatset inks have 5% substrate retention; coldest 20% substrate retention EPA Control Techniques Guidelines Offset and Letterpress
Zero VOC Inks
NAPIM Bulletin covering zero VOC printing inks
VOC Test Methods
- EPA Reference Method 24 (includes references to both ASTM 2369 and ASTM 6419)
- Method 24—Determination (ASTM 2369) of volatile matter content, water content, density, volume solids, and weight solids of surface coatings
- Method 24A — Determination of volatile matter content and density of publication rotogravure inks and related publication rotogravure coatings
- ASTM D6419 -Standard Test Method for Volatile Content of Sheet-Fed and Coldset Web Offset Printing Inks
VOC Determination for UV/EB Inks: There is no EPA-approved VOC test method for these ink types. The VOCs of the individual, mixture of component materials can be used to calculate the VOC content of the finished ink.
HAP’s Ink Manufacturers
Ink manufacturers producing printing inks containing HAPs may be subject to the Miscellaneous Organic NESHAP.
Printer Customer
Applies to HAP containing inks above the de minimis levels (1% and 0.1%) Ink manufacturers can use the SDS or a Certified Product Safety Data Sheet (CPDS) to communicate HAP content information to their customers.
HAP Test Method
Method 311 – Hazardous Air Pollutant Compounds in Paints and Coatings
CPDS
Certified Product Safety Data Sheet (CPDS) means documentation furnished by a coating supplier or an outside laboratory that provides the VHAP content, VOC content, solids content, and density of finishing material, strippable booth coating adhesive, or solvent, measured using EPA Methods 24 and 311, or an equivalent or alternative method (or formulation data if the coating meets the criteria specified in Subsection 35.8.1(b)). The purpose of the CPDS is to assist the facility in demonstrating compliance with the emission limitations presented in Sections 35.3, 35.4, and 35.5 of this regulation. Therefore, the VOC and VHAP content should represent the maximum VOC and VHAP emission potential of the finishing material, strippable booth coating, or solvent.