From: Gary Jones (email@example.com )
Date: Fri, 11 Jan 2002 11:28:10
I concur with the previous postings to your question regarding the classification of inks relative to hazardous and nonhazardous under the federal definitions set out by RCRA at 40 CFR 261. However, there are several other considerations that you should be aware of when it comes to classification of ink waste under the hazardous waste regulations.
Since the flashpoint of lithographic inks is about 220oF, they do not exhibit the characteristic of ignitability and are not classified as hazardous under RCRA. However, there are some states that can and do regulated lithographic ink as hazardous under their state regulations and you need to investigate if this is the case in your state. For example, California has classified all "printers ink" as a presumed hazardous waste. In order to have it classified as nonhazardous, testing according to CA code is required.
Solvent-based inks used in flexography and gravure operations generally do flash below 140oF and water-based ones can flash above and in some cases, below 140oF. If you have inks or other liquid wastes such as coatings or fountain solution that contain alcohol and the flash is below 140oF, there is an exemption in the definition of ignitability for certain alcohol containing wastes. Liquid wastes with less than 25% alcohol are not considered ignitable. Alcohol can be found in some flexo and gravure inks and coatings. In fact, many of the water-based coatings used by lithographers can contain small amounts of alcohol as well.
Regarding the presence of "listed" solvents in inks, to the best of my knowledge, there are not any found in lithographic inks. There are some found in certain flexo and gravure inks in various concentrations. As it is difficult to make generalized statements about the presence and classification of these types of inks relative to the "listed' issue, each ink waste needs to be evaluated according to the definitions used in the regulations.
The 10% threshold limit you mentioned only applies to the F001, F002, F004, and F005 classifications. F003 has a different definition and we were recently looking at this very issue relative to a flexo ink. It was classified as a F003 waste, but we were not certain that this classification by the waste hauler was correct and we waiting for the MSDS and other detailed formulation information from the vendor.
In the evaluation of an ink waste relative to its classification, it is also important to understand that the flashpoint and presence of a listed solvent for the ink only reflects the ink that has not been mixed with other wastes such as blanket wash, solvents, or other materials. Mixtures of materials need to be evaluated based on the what is in them as a mixture of lithographic ink and blanket wash may flash below 140oF and of course, mixing a "listed" waste with a nonhazardous one makes the resultant mixture a "listed" hazardous waste. I hope that this response is not confusing, but the evaluation of any waste requires the application of a series of questions and perhaps even testing to confirm the classification. While RCRA does not dictate testing, there are some instances where testing would be required in order to have definitive information relative to waste classification.