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printreg, September, 2002
Re: Info Needed in a Storm Water Discharge Permit Application


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From: Matt Kaarlela (mattk@piamidam.org)
Date: Mon, 30 Sep 2002 16:29:12


Just an FYI for on the "clean" pallets issue. Although the language says uncontaminated pallets can be stored outside, I'd caution printers on assuming pallets are ok. The "clean" issue is very subjective. I have personally dealt with EPA and State inspectors several times on this issue. One EPA inspector disagreed with our common sense assumption that if there is no visible contamination on the pallets, they were "clean". The inspector argued the pallets could be contaminated with pressroom chemicals that were clear and so I could not prove the pallets were "clean" without testing. Rather than fight it or submit to expensive testing, the printer opted to move the pallets inside. I have had other inspectors walk past "clean" pallets stored outside without any problems. Just thought I'd share some real life experience with the rule.



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