I received a call the other day from an imaging facility. They wanted to know how to produce a “green” product. The first point of discussion focused on the definition of a green or sustainable product. With the release in 2012 of the Federal Trade Commission’s updated “Green Guides,” the use of environmental claims for marketing purposes has been clarified. The second statement made by the facility indicated that he wished to run two separate production lines: one dedicated to producing his green product line, and the other to producing his normal, or non-green, items. This was an interesting scenario and one that truly perplexed me. When, I inquired as to why, the reply was that for the green product line, he did not need to worry about environmental issues as all his products would be green. This is both a very circular argument as well as a false assumption.
Somewhere in the discussion of green and sustainability, facilities have arrived at the false conclusion that if they are producing green products or using environmentally preferable products, then compliance issues are no longer relevant. Let’s look at the issue of green products. The only standards available are the policies issued by the Federal Trade Commission. Within the screen and digital arenas, standards for green products have not been developed for our industry sector, nor are there any product certifications available. Yes, there are testing methods one can use to validate certain claims; however, these claims are only for one part of the final product, such as the substrate or ink. These claims are not for the final piece of work that is moving out the door.
To produce this product, a facility still uses ink systems and printing devices that may indeed lead to compliance issues. Simply because an ink or solvent system is labeled “eco-friendly” does not mean there are no environmental impacts associated with the use of that product. Facilities should still read the Safety Data Sheet and make inquiries to the manufacturer. A facility should know the volatile organic compound (VOC) content of any solvent-based product being used. In certain areas of the country, use of VOC-containing products requires the facility to obtain an air permit. For example, in the South Coast Air Quality Management District, any printing press, including a wide-format digital press, that emits more than three pounds of VOCs per day are required to obtain an air operating permit. The District does not make a distinction between an eco-friendly ink and one that is simply labeled “Ink.” They are more interested in the VOC content of the ink used.
Let’s take a look at another state: Ohio. Facilities operating in this state have the option of applying for a permit-by-rule. A permit-by-rule (PBR) is a specific permit exemption a company may use to exempt an air pollution source from the air permit process, but not from the applicable air pollution regulations and compliance requirements. It is a much simpler approach to air permitting. To qualify as a small printer, a digital facility can use no more than 2,425 gallons of inks, clean-up solutions. and other solvent-containing materials annually. Please note that this regulatory requirement does not state, unless you are using products that may be labeled environmentally friendly, eco-friendly, or eco-solvent.
Facilities need to educate themselves regarding their environmental compliance responsibilities regardless of the types of input materials used or the final product produced. The use of alternative products does not exempt facilities from both understanding and complying with these regulations.
A baseline of compliance with all relevant environmental, health, and safety regulations was quickly incorporated into the certification criteria for the Sustainable Green Printing (SGP) Partnership Program. Stakeholders representing consumer product companies indicated that compliance was the first benchmark utilized when discussing sustainable business practices. It became very clear that in order to be sustainable, a company first needed to understand and be in compliance with all applicable requirements. In fact, the SGP Program requires that all companies undergoing certification undergo an environmental as well as safety and health audit. Additionally, the program requires that facilities developed a policy and procedure for ensuring compliance as well as taking corrective actions where necessary.
Using alternative products as a means of reducing environmental impact is a strong step in the right direction. However, use of these products should not be confused with the facility’s obligation to meet all environmental, safety, and health regulations. If you have any questions or need answers, help is only a phone call or email away. Feel free to contact me at 703-359-1313 or [email protected] and mention that you read this article. I just may have the answer you are seeking.