Digital Print Regulatory Resource

Federal Regulations Applicable to Sign & Graphics Printing Operations

 
Regardless of the size of a particular operation, printers are classified as manufacturers and their operations are subject to relevant federal, state and local regulations. The extent to which a printing operation is affected by these regulations depends on where the business is located and the requirements of the corresponding authorities having jurisdiction. It’s important to understand that a company’s responsibility for compliance with environmental rules is not based on its size or number of employees. For example, facilities operating a relatively small number of wide- or grand-format digital printers might be subject to substantial regulations, depending on their location and whether the equipment uses solvent inks incorporating chemicals classified as Hazardous Air Pollutants (HAPs). For this reason, small printing operators should never assume that their operations are exempt from regulatory requirements.

Two principal regulatory aspects relate to the control of airborne emissions generated by printing operations. The first aspect concerns potential impacts on overall air quality, which is regulated by the Environmental Protection Agency (EPA) in accordance with the Clean Air Act. The second aspect concerns potential health impacts of VOC emissions within the print-shop environment, which are regulated by the Occupational Safety and Health Administration (OSHA).

Additionally, printing operators are responsible for properly profiling and managing their entire waste streams. All hazardous wastes, including items such as residual inks, cleaning solvents and contaminated shop rags/towels, must be properly handled and disposed according to federal, state and local requirements, if applicable, or a printing business can be liable for substantial cleanup costs. Also included in the hazardous waste category are common shop items such as mercury-containing light bulbs, batteries (lead-acid, nickel/cadmium or lithium) and thermostats.

The following link connects to the recently published, revised federal rulemaking on wipes used in connection with solvents:

http://www.epa.gov/wastes/hazard/wastetypes/wasteid/solvents/wipes.htm

Because printing is a manufacturing activity, many of OSHA’s workplace safety requirements apply equally to printing operators. This includes the responsibility to maintain records of occupational illnesses and injuries. Also included are machine-guarding measures, availability/use of personal protective equipment and training, controlling hazardous energy (e.g. lockout/tag-out of electrical devices), training operators of powered industrial trucks (e.g. forkliftin ces), hazard communications, noise exposure and proper materials handling and storage.

Environmental Protection Agency (EPA)

According to the National Ambient Air Quality Standards (NAAQS) incorporated into the Clean Air Act, EPA regulates emissions of Volatile Organic Compounds (VOCs) which have been linked to formation of ground-level ozone in the earth’s atmosphere.

EPA regulates a manufacturer’s facility-wide emissions of VOCs based on Tons per Year (TPY) emitted annually. To estimate a specific facility’s annual emissions, it’s necessary to determine the percentage of all VOCs used which are retained by the substrate(s) in a particular printing operation. The TPY value determining a facility’s annual emissions represents the difference between the amount of VOCs in the printing inks used and the amount retained in the printing substrates. Each facility producing significant quantities of VOCs or other HAPs is responsible for maintaining an inventory of its annual emissions.

From a printer’s perspective, the chief concern stems from the use of solvent inks which commonly are used in applications requiring greater durability, such as outdoor signs and graphics. Solvent inks can release significant amounts of VOCs, particularly in connection with wide- and grand-format printing operations manufacturing products for outdoor use. In certain cases, depending on the jurisdiction involved and the nature of a particular printing operation, a manufacturer might need to install emissions-control equipment.

Compared to inks incorporating strong solvents, inks based on milder solvents, “eco-solvents” and water-based inks produce substantially lower or negligible VOC emissions. Because formulations for both strong and mild solvent inks vary substantially according to the manufacturer, operators should verify an ink’s VOC content based on reviewing the corresponding Material Safety Data Sheet (MSDS). This data is used to calculate the overall quantity of emissions based on the ink consumption rates of equipment.

Because EPA regulates manufacturers based on the overall quantity of VOC emissions, it’s important initially to determine whether a particular operation represents a major or minor emissions source according to EPA criteria. EPA evaluates this classification based on determining a facility’s Potential to Emit and provides the following guidance document for small business operations:

http://www.epa.gov/ttn/atw/1998sbapptebroc.pdf

In certain cases, the environmental regulations of specific states or local jurisdictions might be more stringent than the federal requirements. For example, regulations in Massachusetts are based on calculating a printing operation’s potential emissions instead of actual emissions. The threshold level requiring an air permit in Massachusetts is only 1 TPY of potential emissions, far below the federal thresholds of 10 TPY for a single HAP or 25 TPY for all HAPs. Since potential emissions are based on using printing equipment at full production 24 hours per day, 365 days per year, it’s obvious that many small printers already have been impacted by this and similar state or local requirements. To find the regulations applicable in the area where your business is located, the State Regulations Resource Locator is a useful reference.

EPA offers assistance (including on-site evaluations) through its network of regional compliance coordinators to address questions and other concerns with respect to regulations governing all types of printing operations:

http://www.epa.gov/compliance/contact/cac_regional.html

Additional information on compliance with environmental regulations is available on the Printers’ National Environmental Assistance Center (PNEAC) website:

http://www.pneac.org

Occupational Safety and Health Administration (OSHA)

Printing operations are subject to many of the same federal and state workplace regulations as those applicable to other manufacturers. These regulations include those governing electrical safety; emergency preparedness/response; ergonomics; eye and face protection; fire safety; hand or power tools; hazard communications; hazardous/toxic substances; injury and illness recording/reporting; machine guarding; noise exposure; use of personal protective equipment; powered industrial trucks; shop ventilation and walking/working surfaces.

OSHA has defined Permissible Exposure Limits (PELs) for workers exposed to hazardous substances, either via respiration or absorption through the skin. PELs are based on an 8-hour weighted average exposure:

https://www.osha.gov/dsg/topics/pel/index.html

Also visit the following link to the Department of Labor’s overview of OSHA regulations applicable to various types of printing operations:

https://www.osha.gov/SLTC/printing_industry

OSHA offers on-site consultation services to assist small businesses in their compliance efforts:

https://www.osha.gov/dcsp/smallbusiness/consult.html