Printreg Archive
Re: Liability

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From: Daniel A. Boehm (SHWEC) (
Date: Thu Aug 01 1996 - 09:16:28 CDT

Something related to liability. . .
Liability for printers is potentially found in other areas besides
those listed in Ed's message. For example, we have been hearing
repeatedly that printers are liable for determining the accuracy of
VOC content information being reported by manufacturers on MSDSs.

Technical Assistance providers and regulators often tell printers to
refer to MSDSs when completing Potential To Emit (PTE) calculations.
However, there isn't a requirement for VOC information to be
recorded on MSDSs, which has led to claims that some solvent
manufacturers do not record factual information about VOCs. It is my
understanding that VOCs should be measured and recorded using EPA
Method 24. If this test method is listed on the MSDS it should
provide some assurance that the information is accurate, but at least
one manufacturer has claimed that they've seen the competition list a Modified
EPA Method 24, which isn't an "official" test method.

(1) Have any regulators out there in PRINTREG land
attempted to address the problem of inaccurate information being
recorded on MSDSs?

(2) Can the liability for accuracy of VOC content information be
projected back onto the manufacturer or is this truly an additional
liability for printers?

The severity of inaccurate VOC content information on MSDSs is
apparent. PTE and actual emission calculations would be inaccurate.


> I am working on a project to develop a tool for the printing industry
> to evaluate potential liability. The purpose is to allow printers to
> measure the difference in potential liability among different process
> options; e.g., how much would liability decrease by switching from a
> solvent to a citrus-based cleaner. Such information would allow
> printers to make better decisions regarding their operations.
> I am trying to get a handle on what the potential liabilities facing a
> printing shop are. Superfund? RCRA fines? State fines? Litigation
> damages from personal injury or property damage suits? etc. I would
> greatly appreciate any info or insight anyone might have on what
> issues are pertinent and what data might be available.
> Thanks.
> Ed Reiskin
> Tellus Institute
> 11 Arlington St
> Boston, MA 02116-3411
> (617) 266-5400
Daniel A. Boehm, P.E.
Graduate Assistant
UW-Madison, Solid & Hazardous Waste Education Center
610 Langdon Street, Rm. 530
Madison, WI 53703
Office: (608)262-1083 FAX: (608)262-6250

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