Like many other businesses, the printing ink industry is facing a host of regulatory issues. To bring members up to date on the latest topics, George Fuchs, director, regulatory affairs and compliance for the National Association of Printing Ink Manufacturers (NAPIM), hosted a webinar on June 10, 2020.
During his webinar, titled “2020 Regulatory and Technical Review,” Fuchs noted that while the current US administration is pushing for deregulation, that hasn’t translated into changes on the federal agency regulatory level.
“There has been somewhat of a deregulatory environment under the current administration, but that hasn’t stopped agencies from moving forward with implementation of existing rules,” he noted. In addition, “there is increasing demand from our customers and our customers’ customers for zero risks that we have to discuss.”
COVID-19 has been a huge issue throughout the world, and Fuchs noted that the ink industry was deemed an essential business.
“We worked with Department of Homeland Security’s Cyber Infrastructure Security Administration (CISA) to designate printing ink as an essential industry, and sent notices to all of the governors,” he reported.
Much of the webinar focused on substance-specific issues, beginning with PFOA and PFS.
“EPA is doing a regulatory determination to see if they should be regulated under the Safe Drinking Water Act,” Fuchs reported. “That would limit the ability to discharge to municipal wastewater streams. TSCA is also thinking about adding these for possible prioritization, while the FDA and OSHA have reported no concern at this time. We don’t believe they should be regulated under these broad categories, but as a substance-specific rather than as a whole class of compounds.”
In February 2020, the European Chemicals Agency (ECHA) classified titanium dioxide (TiO2) as a Category 2 inhalation carcinogenic. Fuchs noted that this is very similar to what happened years ago to carbon black.
“In ink, there is no potential for inhalation of the dry powder as it is in a liquid matrix,” he added. “But if you are working with dry TiO2, there is potential for inhalation exposure, and you need to be aware of it. You can use PPEs (personal protective equipment) as an interim measure, but the use of PPE is really for incidental, non-routine exposure. Your first step is engineering controls and work practice improvements, such as limiting exposure through area ventilation.
“Most materials we handle do not have exposure limits, but that doesn’t mean you shouldn’t take steps to have appropriate ventilation,” he noted. “There should be 13 to 17 air changes per hour in the production area as a rule of thumb – some environments require more. You should be focused on dust and vapor control.”
Then there are polychlorinated biphenyls, or PCBs, which can be present in low parts per million (ppm) as unintended by-products of the manufacturing. Some states are concerned about the presence of PCBs in inks in the water stream after recycling. Fuchs noted that Washington state set a limit at low parts per quadrillion level, which is a rather challenging limit. The ink and pigment industries strongly disagree that minuscule water concentrations of PCBs are related to the recycling of paper.
On other topics:
• The Toxic Substance Control Act (TSCA) gave PV 29 a low-risk classification. Fuchs noted that some non-profit organizations are suing the EPA about that designation. “Much of the information was proprietary, and the EPA is being sued under the Freedom of Information Act. It will be interesting to see how this plays out,” he observed.
• The EPA is looking to change the Stormwater/MSGP regulations. “Most of our members have put their operations inside their facilities,” Fuchs said.
• Fuchs said he has received a lot of questions about the regulation of antiviral/anti-microbial coating properties. “These are regulated by the EPA,” he reported. “You have to register with the EPA if you make that claim, and there is limited testing.”
• NAPIM has revitalized its ASTM ink and vehicle test methods. They have all been reviewed and updated and are due to be reinstated.
• OSHA inspections are a topic, with Fuchs noting that NAPIM’s members report that most inspections are the result of complaints or if companies cannot produce their OSHA 300 reports. “The most frequently cited violations are hazard communication standards, respiratory protection, control of hazardous energy (lockout/tag out) and machine guarding,” he added.
Along those lines, Fuchs reported some good news: “The Bureau of Labor Statistics published illness and injury data for the ink industry in 2018. Our total case rate was 1.4 and lost workday cases were 0.6. Those are very good numbers. It’s a good indicator of the safety of our plants, and workers compensation uses this data to set their rates.”
Upcoming Events
As has been the case for most trade shows, NAPIM has had to cancel physical events, including NAPIM’s Annual Convention and NAPIM’s Summer Course.
“The summer course is one of our favorite events, and Clemson is a terrific venue for us,” Fuchs noted. He added that the NAPIM Technical Conference is still scheduled for Oct. 13-16 at The Drake Hotel in Oak Brook, IL. “We are making preparations in case we have to hold this over the Internet,” he noted. “We are looking forward to the 2021 convention in St. Petersburg, FL, next April and the 2021 Summer Course.”
The theme for this year’s Technical Conference is “Formulating for the Circular Economy.”
“We have a great keynote speaker formerly from General Mills, and are working with the American Coatings Association, who will be giving a series of talks,” Fuchs said. “We’re going to again partner with Printed Electronics Now and Ink World for the Electronic and Conductive Ink Conference.”
For more information, contact Fuchs at gfuchs@napim.org, and see the website at wew.napim.org.