Date:Mon, 05 Mar 2001 07:06:37
I would like to add to Gary's response. In my previous job as an environmental manager at a printing company one of the corporation's plants received a non-compliance notice because one out of 20 or so drums was tested by the state RCRA inspector and the liquid contents exceeded the limits for heavy metals. This was not the norm for the waste stream, it happened because a specialty ink that contained higher levels of pigment containing this particular heavy metal was used in production and that particular drum contained waste from the press clean-up using that ink. My advice is err on the side of conservative and be very diligent about tracking the toxicity/characteristics of each material as it comes in the door. If it has potential to be a compliance problem carefully monitor the volume of usage and the concentration in each waste drum. This is not particularly hard to do if you are tracking the materials that go into each job for costing purposes.