A waste is hazardous if:
- It is listed with U.S. EPA as hazardous;
- It is hazardous by characteristic (ignitable, corrosive, reactive or toxic);
It is a mixture of solid waste and a hazardous waste; or
It is a derivative from the treatment of a listed waste.
There are four separate lists of hazardous wastes. The listing is often defined by industrial processes, but all wastes are listed because they contain particular chemical constituents. These constituents are listed in Appendix VII to 40 CFR Part 261 with code letters F, P, K, and U.
For wastes from non-specific sources and including wastes generated by industrial processes that may occur in several different industries, the code always begins with F. F001 through 005 designate various types of spent solvent waste. Examples include methylene chloride, 1,1,1,-trichloroethane, xylene, acetone, benzene, and n-butyl alcohol. The second category of listed wastes includes hazardous wastes from specific sources; these wastes have codes that begin with the letter K, but are not identified in the printing industry.
The remaining lists cover commercial chemical products that have been or are intended to be discarded; these have two letter designations, P and U. Waste codes beginning with P are considered acutely hazardous, while those beginning with U are simply considered hazardous. No chemicals used in the printing industry are considered as acutely hazardous Code P.
Best Management Practices & Pollution Prevention
Reduce volume of waste by going up stream to the source of the waste. Implement good management practices, such as smarter clean-up procedures to reduce the actual volume of cleaning needed.
Use alternative ink systems where feasible, such as water-based, UV or EB curable inks.
Use less hazardous, alternative cleaning products.
Reuse cleaning solvents as many times as possible to reduce the cost of raw materials and the cost of waste disposal.
For additional resources, see the PNEAC fact sheet directory and the P2Rx Flexographic Printing Topic Hub.
For access to vendors who may supply alternative materials and equipment, see the PNEAC Vendor Directory.
If any of the wastes from a printing facility is on any of these lists, the facility is considered a "generator" and subject to regulation under the Resource Conservation and Recovery Act (RCRA).
U.S. Department of Transportation (DOT) regulations apply to hazardous waste. Containers must be labeled with appropriate hazard warning label, i.e. flammable warning.
Placards must be displayed on vehicles transporting hazardous materials in quantities at or above the thresholds specified in 49 CFR 172.504. Placards provide information on the hazards of the material being transported. DOT (See 49 CFR 172.519(c)) requires that hazardous materials placards specified in the regulations meet certain size requirements. A placard must have a minimum measurement of 273 mm (10.8 inches) on each side. Also, a solid line border must be displayed on the placard at a distance of about 12.7 mm (0.5 inch) from each edge. The hazard class number and text on the placard must be printed in numbers/letters that are at least 41 mm (1.6 inches) in height, unless an exception is noted in the regulations.
Generators of hazardous waste who offer the material for transport must obtain a U.S. EPA waste generator identification number. Depending on the generator status of the facility, they may also be required to obtain a U.S. DOT hazardous waste generator/shipper identification number and pay a fee to DOT. The registration requirements, at 49 CFR 107.601 - 620, apply to anyone who offers for transportation and meets the criteria specified in the rule.
If the waste generator is classified as a large quantity generator, a written pollution prevention plan must be in place and being implemented.
Depending on the volume of waste generated, an emergency response plan and training may be required by U.S. EPA and U.S. DOT regulations.
Generators may be subject to the U.S. DOT's Security Requirements for Hazmat Transportation as well. For details about the requirements that took affect September 23, 2003 see 49 CFR Part 172.800
Each state has different specific waste generator and handling requirements that must be followed as well.
Health & Safety
Strict safety precautions should be observed when handling hazardous waste. Employees should don appropriate personal protective equipment.
Employees should be trained in the safe handling of the waste and what procedures to follow in case of a release/spill.
Only properly training employees should be permitted to handle hazardous waste.