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What is proper ink waste disposal?

"Dispose of in compliance with all local, state and federal regulations." What is the real meaning of this ever-too-familiar phrase found on the material safety data sheets (MSDS) for inks? Does it mean that ink can go down the drain because it is water-based material? How about the silver recovery unit? Far too often, new equipment is installed in a lab prior to completing the process of defining if the process will generate waste, how that waste needs to be handled, and the realities of dealing with the waste.

In the past couple of months, PMA Answerline has had some calls asking about the disposal of ink wastes. One caller asked if it could be put through silver recovery units. The answer was a prompt "no." This practice can quickly render silver recovery columns useless and hinder any and all metallic exchange activity that could occur after the ink is put in the system. Another question that was raised was whether it was acceptable to dump waste ink down the drain. While it may appear on the surface to be acceptable since the material is 70 percent water, it is not an acceptable practice for two reasons. First, every sewer code has boiler plate language that prevents the introduction of dyes or other materials that will impart adverse colors to the wastewater. Second, until you know that the material does not contain heavy metals, organics or other materials that would violate the sewer discharge limits, it should not be disposed of in that manner.

PMA[R] has begun to work on defining this problem. Some of the analytical data that has been shared with PMA indicate that ink wastes could indeed be a regulated (hazardous) waste. Tests on other inks indicate there is not a disposal issue, but please do not interpret this to mean that the ink waste can go down the drain.

So this really brings us back to the basics of waste management. It is the responsibility of every business to define the proper disposal of each and every waste material that it generates. Discussions with one ink manufacturer revealed that they have defined the proper disposal of the material. Why that data is not being distributed to the users is a topic that will have to be discussed in another edition of In Compliance.

What does this all mean for proper disposal of inks? Are they a hazardous waste? Or are they not a hazardous waste? PMA's position has and will always be that a waste is a regulated material unless you have knowledge that the chemical composition of the material is such that the material can be disposed of in the trash. To get to that point, a careful plan needs to be followed that will allow you to define the proper handling and disposal of waste inks. The first step should be to review the MSDS for the ink (or other material) in question. If the document only contains generic information, call the supplier or manufacturer and have them define for you how the material should be handled. Require that they send you documentation that supports the guidance they share with you. Do not accept the MSDS as acceptable documentation unless it is definitive on how the material has to be disposed. Remember, a MSDS is a safety and health related document and not necessarily an environmental document.

If you go through these steps and still do not have a good feeling that you have defined how to effectively manage this waste stream, contact the PMA Regulatory Activities office for assistance.
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Publication:In Compliance
Date:Jul 1, 2007
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