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Jan 1, 2005 12:00 AM
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Smaller printers frequently assume they are exempt from certain Occupational Safety and Health Administration (OSHA) and Environmental Protection Agency (EPA) regulations. But as you'll learn, compliance isn't optional. Here are the facts about some common issues.
"OSHA regulations don't apply to me because I have fewer
than 10 employees."
Fact: OSHA has a set of regulations that cover manufacturing operations. Because printing is classified as manufacturing, printers must comply with all applicable general industry standards, including hazard communication, machine guarding, lockout/tagout, fire safety, personal protective equipment, hearing conservation, and injury and illness recordkeeping.
Did you know? There are only two common exemptions from OSHA regulations that apply to printers with fewer than 10 employees: completing the new Form 300, injury and illness recordkeeping paperwork, and having a written emergency evacuation plan.
"My old equipment doesn't need machine guards because it is grandfathered."
Fact: According to OSHA's regulations and interpretations, there is no grandfather clause applicable to existing equipment. Old equipment is not exempt from the machine guarding standard. It is the printer's—rather than the equipment vendor's—responsibility to ensure that equipment is properly guarded. OSHA's regulations require guarding for all ingoing nip points, rollers, wheels, pinch points, sprockets, pulleys, chains, rotating shafts and other hazardous equipment areas. OSHA's regulations do not require that the guards be interlocked.
"Because I have cord-and-plug equipment and maintenance contracts, lockout/tagout doesn't apply."
Fact: Cord-and-plug equipment isn't subject to lockout/tagout requirements, provided that it is unplugged during servicing/maintenance and the plug remains in clear view of the employee performing the service. For all non-cord-and-plug equipment, however, a hazard analysis must be performed and specific lockout/tagout procedures must be developed and implemented for any servicing/maintenance procedures. OSHA has issued several letters of interpretation, one in 1992 and the other in 2004, that allow the printing industry to use alternative procedures for minor servicing and maintenance such as clearing certain types of paper jams, changing blankets and plates, cleaning blankets and plates, making equipment adjustments, etc.
"I don't have to conduct a job safety analysis, because we've never had an accident."
Fact: The requirement for conducting a formal and documented job hazard analysis under OSHA's Personal Protective Equipment standard depends on the hazards present in a particular job. Accident history has nothing to do with it. Each hazard must be identified by job category and appropriate personal protective equipment. Once identified, employees must be trained in the equipment's use, limitations and proper maintenance.
"I have collected Material Safety Data Sheets (MSDSs) for my products. Therefore, I am in compliance."
Fact: Collecting your MSDSs only puts you about one-fifth of the way to full compliance. Under OSHA's Hazard Communication Standard, simply collecting MSDSs is insufficient to demonstrate compliance. Obtaining and maintaining MSDSs is one of five basic requirements that must be met under the Hazard Communication Standard. Other requirements include:
"We're so small, I don't have to obtain an air pollution permit."
Fact: The requirement for a construction and/or operating permit depends on the location and the amount of air emissions that can be generated from individual pieces of equipment or the facility as a whole. Areas that do not meet EPA's ozone standard are classified as "nonattainment" and have low air permit thresholds, which are typically based on the amount of volatile organic compound (VOC) or hazardous air pollutant (HAP) emissions per hour, day or year.
Many states have lowered their air permit thresholds and now require small printers to obtain a permit to legally operate their businesses. Some air pollution control agencies set their air permit threshold based on the amount of VOC-containing material used per year. For example, Illinois requires a permit for all printers who use more than 750 gallons of VOC-containing material per year. Maryland requires an air permit for any sheetfed offset press greater than 18 inches. It is important to know and understand your state and/or local air permit threshold and ensure that if a permit is necessary, one is obtained.
Bet you didn't know: In addition to these thresholds, which are based on actual emissions, some thresholds are based on potential emissions. Potential emissions require printers to assume that they are using their equipment at maximum production conditions or coverage 24 hours per day, 365 days per year. For example, the threshold for a permit in Massachusetts is 1 ton per year of potential VOC emissions. The federal threshold for a major source of HAPs is 10 tons for a single HAP and 25 tons for all HAPs combined.
"Digital equipment is green and does not cause air pollution."
Fact: Digital technologies are not necessarily "green." Direct-to-plate imaging systems, for example, could have a high-pH developing effluent that must be neutralized. And if the platesetter is silver-halide based, users must recover the silver and neutralize the effluent.
Bet you didn't know: Some digital output devices, such as wide-format inkjet systems, can generate tons of VOC and HAP emissions. Many of these systems are subject to air permitting, which means a construction and/or operating permit is necessary prior to the unit being delivered and used. Other digital presses use a liquid toner system that contains VOCs and also is subject to permitting. If the wide-format inkjet printer is using a solvent that is also an HAP, then having as few as three of these units could cause the printing company to be classified as a major source for HAPs, subject to Title V air permit requirements.
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