Printech Archive
Re: Regional Ink Disposal Service Offered By PIA of Texas

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From: Matt Kaarlela (
Date: Mon Jun 28 1999 - 08:44:08 CDT


You bring up a valid point. Before we started the program, the concern was
passed to our legal council and they had some reservations. Obviously,
anyone should consult their own legal council before attempting a similar
program since not all states and certainly not all waste haulers operate
the same way.

OK so much for the weasel clauses, our attorney felt it was important that
PIA never actually received the waste or got involved in the scheduling or
picking up of the wasteso there is no direct link to PIA-Texas. That isn't
to say that if there were a disaster, the EPA couldn't attempt to draw us
in as a PRP. However, we would not be the primary pockets to go after.

I spent 5 years working with EPA's superfund program and my experience was
they go after the generators, hauler and disposal company first. We make
sure the hauler we use has generous insurance limits to cover accidents. I
also inspect both the hauler/fuels blender and the cement kiln once a year
to make sure they are maintaining good housekeeping, etc. Bottom line is
there is always some risk involved. You can do things to minimize the risk
but you just have to decide if the benefits to your membership outway the

Good luck and we sure could use some of that cool air down here to Texas.
The weatherman said it was going to reach 100 degrees today and it is only

>Gary & Matt.
>What kind of legal liabilities is PIA-Texas assuming by playing a
>middle-man role in the transportation and disposal/recycling of a
>hazardous waste (ink mixed with HW solvents)? Should there be
>mismanagement of this waste and it develops into a superfund site could
>PIA-Texas become a PRP? I am no lawyer by any stretch of the
>imagination but it seems to me that if a problem does arise with this
>service in the future, the printers may have a claim against PIA-Texas
>for making faulty arrangements with HEAT. Please let me know what your
>law firm thinks about this group buying plan and the risks/liabilities
>involved. Thanks.
>Scott Schuler
>Environmental Director
>Printing Industry of Minnesota, Inc.
>2829 University Avenue SE, Suite 750
>Minneapolis, MN 55414-3222
>Fax: 612-379-6030

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