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U.S. EPA’s Office of Air and Radiation, Office of Air Quality Planning and Standards (OAQPS), Small Business Assistance Program (SBAP) has launched its new webpage for all interested small business stakeholders. This webpage provides a central place for States, EPA Regions, and small businesses to obtain information, tools, and training about OAQPS regulatory actions that may be of interest to small businesses.
To explore OAQPS SBAP’s new webpage, please visit: https://www.epa.gov/stationary-sources-air-pollution/office-air-quality-planning-and-standards-oaqps-small-business.
To receive emails about different EPA actions that might impact small businesses you can also sign up for the OAQPS SBAP Email ListServ. To subscribe, send an email to: join-oaqps_small_business_outreach@lists.epa.gov
(The following is an article written by Julie LaRose, DNR Waste Management Specialist, for the printing industry associations as an element of their Green Tier Charter to promote improved environmental performance among the industry. The key points in the message can be applied to any industry affected by the waste management requirements.)
“Accurate waste determinations are the cornerstone of proper waste management. If a hazardous waste is misclassified as non-hazardous, a host of regulatory issues ensues.”
According to Mike Ellenbecker, Hazardous Waste Program Coordinator with the DNR, the foundation on which hazardous waste compliance is built consists of a thorough understanding of generated waste streams. Depending on the nature of the hazards, mischaracterizing a waste stream can result in superficial to catastrophic failures. The most devastating outcomes can result in the loss of life or irreparable damage to the environment.
The waste determination process is also compromised when non-hazardous waste is mistakenly identified as hazardous. Gary Jones, Director of Environmental Health and Safety (EHS) Affairs at Printing United Alliance, explains “Improperly classifying non-hazardous waste as hazardous can create regulatory burdens that are unnecessary and costly.”
If a company has never experienced an unannounced hazardous waste compliance inspection the prospect may seem daunting, but these inspections follow a predictable path that can provide the company with an opportunity to evaluate and improve their waste management efforts. During an inspection, department compliance specialists examine waste streams and the associated waste determinations to ensure that hazardous waste is properly characterized, handled, accumulated, transported, treated, and disposed of. When a company’s waste determination process is flawed, it can lead to areas of non-compliance and in some cases, enforcement actions. To strengthen your waste management program, it is valuable to have an awareness of both the common stumbling blocks that businesses experience and a knowledge of the available resources.
To protect both workers and the environment, the hazards of each generated waste must be well understood and communicated. Companies that rely solely on the expertise of third parties such as consultants, brokers, transporters or treatment, storage and disposal facilities (TSDFs) run the risk of waste mischaracterization and potential compliance issues as the regulatory responsibility for waste determinations resides solely with the generator. Companies should not assume that their waste hauler or TSDFs test every hazardous waste stream or that these third parties can identify unknown hazards. Often, TSDFs only test parts of incoming loads for limited parameters or characteristics. This disconnect can create hazardous conditions for the generator, the transporter and the TSDF.
For example, a facility may assume their computer-to-plate printing operations are ecofriendly and do not generate hazardous waste. This presumption fails to consider the plate development process that generates a waste stream with a pH above 12.5, making it a corrosive hazardous waste. Conversely, a printing operation that switches to a wash solvent with a flashpoint above 140°F may continue to refer to an outdated waste determination that characterizes the spent solvent as ignitable (i.e., flashpoint below 140°F). This mischaracterization of waste can affect a hazardous waste generator’s regulatory status. Over-classification of waste as hazardous could result in a facility operating under more regulatory requirements than necessary while under-classification could result in a facility not operating in compliance with the required regulation of their actual generator status, not to mention creating hazards for workers and others.
A thorough understanding of the waste determination process is the first step in building a structurally sound waste management program. There are five key steps in the waste determination process which include:
- Identify all waste streams.
- Determine whether each waste stream is a solid waste.
- Determine if each solid waste is excluded from regulation as a hazardous waste.
- Determine whether each solid waste is a hazardous waste.
- Document the information and decisions made in steps 1-4.
The waste determination process falters when any of the steps are skipped or misinterpreted. Early in the determination process, confusion about what meets the definition of a solid waste can lead to an incorrect waste determination. This step is important because if the material in question is not solid waste, it cannot be hazardous waste. Note that the definition of solid waste does not refer to the physical form of the waste. A “solid” waste can be a solid, liquid or containerized gas.
Another challenge can arise when researching the hazards of a waste by relying on Safety Data Sheets (SDS). For example, while conducting a waste determination for a spent developer, the SDS for the developer is reviewed. The SDS indicates that the pH of the developer is 13. With this information, the printing operation assumes that the spent developer also has a pH above 12.5, and the spent developer is characterized as a corrosive hazardous waste. This determination process fails to consider that the pH of the spent developer may be lower than the pH identified on the SDS for the unused product. When using a calibrated pH meter to conduct representative sampling it is discovered that the pH of the spent developer is below 12.5. In fact, this waste stream is not a corrosive hazardous waste.
Keeping waste determinations up to date is challenging when process changes that can affect the waste streams are not evaluated or documented well. When contemplating a change, a best management practice would be to keep the person responsible for compliance in the loop to ensure that waste determinations continue to be accurate. For example, if the pressroom elects to switch to a solvent wash with a lower flashpoint, the possible health and safety implications need to be weighed prior to the change and a waste determination will need to occur that takes the change into account. It is difficult to implement a successful a waste management program when waste streams change or emerge without the knowledge of compliance personnel.
To strengthen the waste determination process, there are several resources available. For a detailed discussion of the waste determination and recordkeeping process, refer to the guidance document WA-1152 Waste Determinations and Recordkeeping. A detailed resource for printing operations continues to be the Printer Portal, which outlines environmental compliance and sustainability resources specific to the printing industry. A recent addition to the portal includes a fillable waste determination checklist. While completion of the checklist is not a regulatory requirement, it provides a helpful tool to clearly document and communicate the determinations for each waste stream. Additionally, it is recommended that facilities retain the evaluation and associated documents for all waste determinations regardless of whether the waste is determined to be hazardous or non-hazardous.
An accurate and complete set of waste determinations provides a solid foundation for the proper management of hazardous waste, and the correct identification of the applicable requirements. Facilities enjoy the benefits of improved occupational safety and environmental health outcomes, and the resulting efficiencies provide cost savings.
Upcoming WisCon Webinar Training Events
WisCon is beginning a new monthly free webinar training series! These webinars will occur on the third Thursday of every month with a start time of 9:30 a.m. and are projected to be 1.5-2 hours in length.
Topics will focus on both national and regional emphasis programs, as well as some of the most cited OSHA standards. The webinars are designed to help breakdown complex OSHA standards, go over programs (where required), offer real world examples, and allow time for attendee questions.
The first webinar of the series takes place on Mar. 16, 2023 and will focus on OSHA’s Hazard Communication Standard.
The webinars are free, but registration is required through Eventbrite. Participant capacity is limited, so register today! Email questions to Kelli.humber@slh.wisc.edu.
Future topics:
Webinar On Plastic Recycling And Labels
The Wisconsin Printing Industry Council is teaming up with TLMI (Tag and Label Manufacturers Institute) as part of the Green Tier Printing Charter, a cooperative agreement with the DNR and printing trade associations, to promote a webinar to learn about “The Association of Plastic Recyclers' Meets Preferred Guidance Program for Labels”. The webinar is on Mar. 29, 2023, at 12:00 PM CDT.
The Association of Plastic Recyclers’ Meet Preferred Guidance program can save label converters money and time on testing, and get labels that enable plastic recycling to market quickly. With EPR (Extended Producer Responsibility) requirements expanding, brands are asking for labels that are not detrimental to plastic recycling. The knowledge gained from this webinar is something printers can add to their sustainability toolbox.
Please register for the webinar. After registering, you will receive a confirmation email containing information about joining the webinar from TLMI.
Public Notice Of Intent To Modify The Mineral (Nonmetallic) Mining and/or Processing WPDES General Permit
The DNR is proposing to modify the Wisconsin Pollution Discharge Elimination System (WPDES) Mineral (Nonmetallic) Mining and/or Processing General Permit. Modifications based on new information are proposed under s. NR 203.136, Wis. Adm. Code, to the following areas:
- Modify the sampling frequency for pH, TSS, and additives for new, non-industrial, nonmetallic aggregate mines that discharge to surface water, to be consistent with the pH, TSS, and additives sampling required for existing facilities.
- Delay the requirement for metals monitoring for discharges of process wastewater to groundwater until the second year of the permit.
- Delay the due date for discharge screening results for discharges of process wastewater to surface water by 90 days (to 180 days from the effective date of the permit).
Comments on the draft permit are due April 8, 2023. The draft general permit and fact sheet may be accessed on the Wastewater Public Notice webpage.
Water Quality Guidance Document For Review
A new Water Quality document, "Establishing Nitrogen Limitations in WPDES Permits at Industrial Land Treatment Facilities," is currently available for public review. Public input will be accepted via email through the end of the day on Thursday, April 13, 2023.
To review and provide comments on this document:
- Visit the Water Quality Program Policy and Guidance page and find the document in the table at the bottom of the page.
- Feedback related to the document should be emailed to the staff member listed in the table row.
DNR staff will review comments that are submitted and make revisions, as needed, to improve the quality of the document.
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