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printreg, June, 2002
Re: Ink as an Oil under SPCC?


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From: Gary Jones ( gjonesprinting@aol.com )
Date: Mon, 3 Jun 2002 11:56:21


I am assuming that your question pertains to lithographic ink and you have asked a question on a topic that seems to have garnered some interest lately from certain printers. The concern for the lithographic segment of the printing industry is that litho ink and some cleaning solvents can be considered "oil" and printers will exceed the above ground threshold due to ink storage, lubricating oil, and other solvents derived from petroleum and are possibly subject to the regulation. After investigating the regulatory definition of "oil" and case law, it became apparent that litho ink due to the presence of ink oil could meet the broad definition of oil. In fact, even vegetable oil is considered regulated oil under this set of regulations so even soy ink would be included.

The good news is that since litho ink does not readily flow and in most cases would not contaminate a waterway, the impact of the full regulation may not be applicable to every printer exceeding the storage threshold. However, there remains a big problem in that the printer must be able to prove that this will not occur. In order to accomplish this, a set of calculations or computer model needs to be developed that could be used by a printer to show that the ink, if released, would not flow into a navigable waterway. Unfortunately, there is to the best of my knowledge no computer model or calculations that is available. We here at GATF would like to pursue developing such calculations and computer model, but due to funding limitations, we have not been able to work on them.



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