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Printing -- Flexography Topic Hub: Regulatory Compliance

Basic information on flexographic printing, including pollution prevention options and links to additional resources.

Top Compliance Issues

The most common compliance issues for flexographic printers involve the following:

  • Film fixer & developer: Silver in solution can cause a local wastewater treatment infraction and can be a hazardous waste issue.
  • Solvents, including plate processing solvents: Total solvent consumed counts towards Clean Air Act permit status. Volume that does not evaporate can be a hazardous waste.
  • Volume of waste ink and clean-up waste: If characteristically hazardous, counts toward waste generator status. Generator status compliance requirements increase with the volume of waste generated.

Regulated Wastes and Outputs

This section contains a step-by-step outline of the regulatory and compliance issues in flexographic printing process, as well as the most common compliance issues found in a typical flexographic printing facility.

Prepress - Imaging Process

Outputs Regulation(s)
Exposed, waste, and out-of-date film Hazardous waste or solid waste (RCRA), TRI
Scrap paper Solid waste
Air vapors and odors Clean Air Act
Spent film developer Clean Water Act, hazardous waste (RCRA), TRI
Used rinse water from film processing Clean Water Act
Rags containing solvents Hazardous waste or solid waste (RCRA), Clean Water Act
Waste paper from disposable towels Hazardous waste or solid waste (RCRA), Clean Water Act
Waste solvents Hazardous waste (RCRA), Clean Water Act
Empty chemical containers Hazardous waste or solid waste (RCRA), DOT container testing & reuse regulations, Clean Water Act 

Production - Printing Process

Outputs Regulations(s)
Volatile organic compounds (VOCs) air emissions from solvent based ink and alcohols in water based inks Clean Air Act
Hazardous air pollutants from cleaning solvents, thinning solvents, and inks Clean Air Act
Waste or obsolete ink Hazardous Waste or Solid Waste (RCRA) 
​Waste water used in cleaning Clean Water Act, Hazardous Waste Regulations (RCRA) 
Waste solvent used in cleaning Hazardous Waste Regulations (RCRA), Clean Water Act 
Solid waste from unacceptable prints, make-ready, and trim scrap paper Solid Waste 
Rags and towels containing inks, solvents, grease and oils Hazardous Waste or Solid Waste Regulations (RCRA) 

Finishing - Post Press Operations

Outputs Regulation(s)
Reject prints and trim scrap Solid Waste 
Used boxes and shipping materials Solid Waste 
Rags containing oil, grease, solvents, and adhesives  Hazardous Waste (RCRA) or Solid Waste
Waste wash water containing adhesives and/or solvents Clean Water Act, Hazardous Waste (RCRA)
VOC emissions from solvent based adhesives Clean Air Act 
VOC emissions from cleaning solvents Clean Air Act 
Solvent parts washer waste

 Hazardous Waste (RCRA) and Clean Air Act 

Common Issues During Inspections

Here are some common things inspectors look for when they visit a plant.

Hazardous waste inspections

  • Proper labeling of product and waste containers.
  • Failure to make a hazardous waste determination.
  • Drips, stains, spills and puddles within and outside the facility.
  • Illegal disposal of a hazardous waste (e.g. they will look in dumpsters and outside the building before ever knocking on the facility's door).
  • Open/closed containers of volatile or hazardous materials.
  • Leaking valves and venting systems.

Air inspections

  • Improper determination of "potential to emit" VOCs, HAPs, and particulates.
  • Pollution control device (PCD) operation records to determine proper operation and evidence that the PCD has been by-passed.
  • Open/closed containers of volatile or hazardous materials.
  • Leaking valves and venting systems.

Water inspections

  • Look into streams and gullies on or near your property, and in drains and man holes on your property in search of evidence of illegal discharges. The inspector looks for things such as flammable vapors, discoloration, and oily sheen in the water.
  • Ask to review your NPDES/Stormwater permits and self-inspection records.
  • Inquire how the facility determined that an NPDES permit is not required at the facility.

All inspections

All inspectors, including hazardous waste, air, water, or health and safety (OSHA) will look for the following:

  • Availability and accessibility of current SDS information.
  • Question personnel to determine operator knowledge of hazards and risks associated with chemicals used in the work place.
  • Inquire about responsible party's knowledge of regulations.
  • Consider your compliance history.
  • Can and may request supporting information for regulatory status.
  • Seek out the most common violations (e.g. see OSHA's Top 10 Violations list on their web site).