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Update On Environmental and Regulatory Issues Gary Jones, Assistant VP EHS Affairs Printing Industries of America Bill Upton, Vice President of Operations Edwards Brothers Malloy Jac Garner, President Webcrafters Today’s Agenda Update on BMI/AAP Task Force Examining “Environmental Best Management Practices” Update on Sustainable Green Printing Partnership Webcrafter’s experience Update on various ENGO activities Changes in government regulations Air pollution control requirements Q&A BMI/AAP Task Force Goal is to develop “environmental best practices” for book manufacturing Two elements – product and manufacturing process Two meetings have been held Most recent was on October 22nd Conversations have focused more on general topics of interest Additional conversations are necessary to formulate a strategy Sustainable Green Printing Partnership Launched August 28, 2008! www.sgppartnership.org Eligible Companies – US and Canadian Printers, packaging, newspapers, in-plants, schools Binding, finishing, and loose leaf operations Applies to individual facilities Participation so far…. Certified Facilities 41 SGP Applicants 15 Patrons 22 Sustainable Green Printing Partnership What is the SGP Partnership? Independent Nonprofit Certification Organization Credible system identifying “Sustainable Green” graphic arts facilities for customers and consumers Third-party audit required for certification Holistic approach to the development & certification of sustainable business practices Publically vetted criteria defining “Sustainable Green” printing facilities Finished Product Responsibility Environmental Responsibility Social Responsibility Sustainable Green Printing Partnership Being Certified Means a Company… Has undergone a Third Party Certification Audit Works with customers on options for products Is in compliance with all relevant health, safety and environmental regulations Developed and implemented a Sustainability Management System (SMS) Conform to Best Management Practices Supply Chain, Production Operations, Facility-wide, and Employment Annual continuous improvement project Tracking key sustainability metrics Submit an annual report Sustainable Green Printing Partnership Webcrafters Experience With SGP Certification Why Webcrafters became certified Value and benefits to customers, operations, and employees Certification process How it was accomplished internally How much time and effort did it take What was the cost Book Industry Environmental Council(BIEC) Founded: 2008, by: o Green Press Initiative (GPI) o Book Industry Study Group (BISG) Mission: o Identify, foster, and communicate best practices to reduce the environmental footprint and increase the sustainability of books, both printed and electronic. o Reaffirmed in 2012 member survey BIEC Initiatives 1. Publisher Environmental Certification Program • Abandoned 2011 • Picked up by GPI • List of certified publishers not yet available on GPI site 2. Track trends of book industry environmental practices 3. Set goals for reducing greenhouse gas emissions • 20% reduction from 2007 to 2020 • 80% reduction from 2007 to 2050 4. Reduce returns and keep books out of landfills BIEC Member Survey Keep pursuing initiatives 2, 3, 4 Don’t recalculate industry carbon footprint in ‘13 o 17% wanted to, 25% didn’t, others neutral Want more actionable plans Provide member education via speakers/webinars o Environmental regulations o Industry best practices Hold meetings onsite at member companies to see first hand o Global dynamics of recycled fiber Develop data on impact of e publishing 2012 Tracking Report Report drafted May not be released due to member concerns o Data could be skewed depending on which companies participated in survey o Some information was speculative “this could be due to…” Publication uncertain at this time BIEC Administration GPI serving as paid administrator of BIEC 6 month trial Canopy Green Printer Initiative Initiated a search in July 2012 to find North America’s Greenest Printers Created11 page survey covering variety of topics Paper procurement and management (extensive) Sustainability policy and reporting Certifications Process questions – soy inks, energy conservation, pollution reduction, renewable energy, waterless, etc. Final report or listing not published Green America Better Paper Project Program started in 1982 focusing on Magazine Publishers Purpose to help magazine publishers choose sustainable papers (recycled and certified) Refers to Canopy List of “Green Printers” July 2012 “Green In All Grades” White Paper Debunks recent myths and proves that recycled paper is always the best environmental choice, especially when used in magazines. Paper Calculator Managed by EPN 2011 Environmental Defense Fund transferred Paper Calculator to the Environmental Paper Network Revised in August 2012 (Version 3.2) More completely capturing the life cycle water use of both recycled and virgin fiber Updated national average data on mill performance Calculates the environmental savings of both postconsumer and pre-consumer recycled content Updated decomposition rates for each of the paper grades based on new data http://calculator.environmentalpaper.org/resources_a nd_tools Toshiba No Print Day In early June, Toshiba announced National No Print Day on October 23, 2012 Urged offices to not print or copy To raise awareness “of the impact printing has on our planet” and of "the role of paper in the workplace After pushback from industry, Toshiba cancelled National No Print Day The Value of Print http://value.printing.org/ FSC Update Chain of Custody - effective October 1, 2011 New declarations for social, health, and safety requirements New declarations for illegal forest products and other harmful forest practices Declaration requirement has triggered negative response from printing and paper companies Response being organized to approach FSC to exclude North American companies from new requirements PIA “uninvited” from standards review committee FTC Green Guidelines New Guidelines announced October 1, 2012 Last updated in 1998 Includes revisions on existing guides and new sections Revised Claims General Environment Benefit Compostable and Degradable Recyclable and Recycled content Ozone safe or ozone friendly New Sections Carbon offsets “Green” Certifications and Seals Renewable Energy and Renewable Materials Claims Free of and Non-toxic Topics not covered Use of the terms Sustainable, Natural, and Organic FTC Green Guidelines Revised Claims General Environmental Claims Claims should include clear and prominent qualifying language, not general environmental claims such as “eco-friendly” that cannot be substantiated. Compostable Need competent and reliable scientific evidence that all materials will breakdown into or become part of usable compost safely and timely. Should qualify compostable claims that cannot be composted at home safely or timely, and if it can be composted in a municipal or institutional facility if they are not available to a majority of consumers. FTC Green Guidelines Revised Guides Degradable Can make an unqualified claim only if it can be proven that the entire product or package will break down and return to nature within one year after customary disposal Items destined for landfills, incinerators, or recycling facilities will not degrade within a year, and cannot be claimed as biodegradable. Recyclable Must qualify recyclable claims when recycling facilities are not available to at least 60% of consumers or communities. FTC Green Guidelines Revised Guides Recycled Content Make recycled claims only for materials recovered or diverted from waste during manufacturing process or after consumer use Qualify claims for products or packages made partly from recycled material Qualify products containing used, reconditioned, or remanufactured components to avoid deception Ozone friendly or safe Claims cannot misrepresent a product as ozone- friendly or safe for ozone layer FTC Green Guidelines New Sections Carbon Offsets Unqualified carbon offset claims should refer to emission reductions that have occurred or will in the immediate future Any claim that will not occur for two years or longer should be explicitly qualified Claims are not permissible for reductions or activities resulting in reductions required by law “Green” Certifications and Seals Unqualified certifications or seals of approval should clearly state they apply to specific benefits Use of a third party certifier’s name, logo, or seal of approval must comply with FTC’s Endorsement Guides FTC Green Guidelines New Sections Renewable Energy Claims Unqualified claims cannot be used where power derived from fossil fuel is used to manufacture any part of the product or service Claims are not permissible where manufacturer generates renewable energy but sells renewable energy certificates for all of that electricity Renewable Materials Claims Where necessary, claims should be qualified by specifying the material used, how the material is sourced, and why the material is renewable FTC Green Guidelines New Sections Free-of and Non-toxic Claims Product cannot contain more than trace amounts or background levels of a substance Amount of substance present does not cause harm that is associated with the substance Substance was not intentionally added to product Product cannot use substance that poses same or similar environmental concerns as removed substance Removed substance is not one associated with the product category FTC Green Guidelines First FTC Enforcement Action October 26, 2012 settlement with Sherwin Williams and PPG for charges on misleading “Zero VOC” claims on paint can labels and promotional material Claimed “Zero VOC” paints Mixing bases contain no or trace VOCs Colorants used to tint added enough VOCs negating claim Sherwin Williams included a disclaimer on their product FTC ruled not sufficient due to VOC added by colorant Must stop current advertising and must have material available for review by FTC FTC Green Guides Avoiding An FTC Enforcement Action Be clear and specific about environmental-benefit claims Marketing message should be clear and prominent, and whether the claims apply to the product, packaging, or component Must not overstate or use general environmental claims Be careful about using environmental certifications and seals of approval in advertising Certifications and seals considered endorsements Must be truthful and substantiated FTC Green Guides Avoiding An FTC Enforcement Action Keep marketing and compliance departments on the same page Substantiation for a claim must be on hand before the claim is made Marketers and compliance officers should work together and have a sharp focus on corporate compliance Check the Green Guides carefully before using any green term http://business.ftc.gov/advertising-and- marketing/environmental-marketing The Lacey Act The Food, Conservation and Energy Act of 2008 Passed May 22, 2008 (effective immediately) The Lacey Act makes it unlawful to import, export, transport, sell, receive, acquire, or purchase in interstate or foreign commerce any plant, with some limited exceptions, taken or traded in violation of the laws of the U.S., a U.S. State, or most relevant foreign laws Can be a “knowingly” or “unknowingly” participant Examples of relevant underlying foreign law violations Theft of timber, including from parks and protected areas Harvesting without permission Failure to comply with harvesting regulations Failure to pay royalties, taxes or fees The Lacey Act Exercise “Due Care” when purchasing paper “Due care means that degree of care which a reasonably prudent person would exercise under the same or similar circumstances.” Due care applied differently based on expectations Useful tools to demonstrate due care Asking questions Compliance plans Industry standards Records of efforts Changes in above in response to practical experiences Lacey Act In 2008 and 2009 wood from Gibson guitar was seized and company investigated for violating Lacey Act Illegally purchasing and important ebony wood from Madagascar and rosewood and ebony from India August 6, 2012 settlement with DOJ Penalty of $300,000, donate $50,000 to the National Fish and Wildlife Foundation, and implement a compliance program Gibson will withdraw its claim to the wood seized with a total invoice of $261,844. State Air Pollution Control Regulations 85 Counties Ozone Nonattainment Areas What is a CTG? Control Techniques Guideline Not a national regulation Guidance containing “recommendations” by EPA to States on how to control VOC emissions Sets Reasonably Available Control Technology limits Applies to printers in ozone nonattainment areas Moderate, Serious, Severe, and Extreme Ozone transport region (Northern VA to Maine) States with ozone nonattainment areas must adopt new regulations or revise existing ones. Who Does The CTGs Apply To? Applicability Printers in moderate or worse ozone nonattainment areas Can be nonattainment area only or statewide 15 lb/day actual VOC emissions before controls Ink, Fountain Solutions, Coatings, Cleaning Solvents EPA said states could use 450 lbs/mo or 3 tpy Unless monthly or annual-then daily recordkeeping States must have any other threshold approved Lithographic/Letterpress CTG Inks, Varnishes, and Coatings Sheetfed and Nonheatset Web No VOC content limits or reformulation required UV/EB cured classified as “nonheatset” 95% VOC retention factor for conventional inks and varnishes Heatset Web No VOC Content Limits or Reformation Required Reduce VOC emissions add-on control device 20% VOC retention factor for conventional inks and 100% capture in dryer Lithographic/Letterpress CTG Inks, Varnishes, and Coatings Considered part of printing process not subject to paper coating regulations Varnishes Unpigmented inks and treated the same as inks Water-based & UV/EB cured Minimal VOC emissions No VOC content limits or reformulation required Lithographic/Letterpress CTG Inks, Varnishes, and Coatings Heatset web add-on controls (oxidizer) Any press with potential ink oil emissions greater than 25 tons per year 31.25 tons per year considering 20% retention Book and presses 22 inches in width or less are exempt Control efficiency 90% for all existing control devices 95% for all new control devices installed after state rule date VOC outlet concentration of 20 ppmv (hexane) or less Lithographic/Letterpress CTG Fountain Solution Sheetfed VOC limit of 5% by weight VOC with no refrigeration or VOC limit of 8.5% by weight if refrigerated below 60o F Limits are on an “as applied” basis (press ready) Nonheatset Web No IPA Alcohol substitute limit of 5% by weight Limits are on an “as applied” basis (press ready) Lithographic/Letterpress CTG Fountain Solution Heatset Web IPA limit of 1.6% by weight with no refrigeration or IPA limit of 3% by weight if refrigerated below 60o F Alcohol substitute limit of 5% by weight Limits are on an “as applied” basis (press ready) Allows 70% carryover of substitutes into HSWO dryers Lithographic/Letterpress CTG Cleaning Solutions Applies to all printing press cleaning activities Blanket wash, roller wash, metering roller, etc. Limits 70% weight VOC content limit, or VOC composite vapor pressure limit of 10 mm Hg at 20oC Requires closed containers for towels and solutions Allows 50% shop towel retention factor for washes meeting low vapor pressure limit Allows 40% carryover for ABW into HSWO dryers States With Existing/Revised Litho Rules Arizona Connecticut District of Columbia Delaware Georgia Illinois Indiana Kansas Louisiana Massachusetts Maryland Maine Missouri North Carolina New Hampshire New Jersey New York Ohio Tennessee Texas Wisconsin California • Bay Area Air Quality Management District • San Joaquin Valley Unified Air Pollution Control District • San Diego County Air Pollution Control District • South Coast Air Quality Management District States Without Final Litho RACT Rules Pennsylvania Proposed rule published 02/2012, reviewing comments Virginia Proposed rule published, 08/2009, currently undergoing secretary review. Vermont No proposed Rule, but plan on adopting CTG. Kentucky No Proposed Rule Florida No Proposed Rule Michigan No Proposed Rule Rhode Island Plan to publish a proposed rule in 2013. Utah Proposed rule published 09/2012 South Carolina No Proposed Rule Industrial Solvent Cleaning CTG Operational Limits Digital operations are exempt Except Utah and Georgia Low VOC content 50 grams/liter (0.42 lbs/gal) Low vapor pressure Less than 8mm Hg at 20oC (68ooF) Industrial Solvent Cleaning CTG Required Work Practices Cover open containers Minimize air circulation around cleaning operations Properly dispose of used solvents and shop towels Implement equipment practices to minimize emissions States With Existing/Revised ISC Rules Maryland Connecticut District of Columbia Delaware Georgia Illinois Indiana Kansas Texas Wisconsin Ohio Georgia Missouri North Carolina New Hampshire States Developing ISCR Rules Pennsylvania Proposed rule 02/2012 Virginia Proposed rule, in executive review New York No rule proposed, but plan on adopting CTG States With No Current Plans for ISC Rules Maine New Jersey Kentucky Michigan West Virginia Arizona Massachusetts Louisiana South Carolina Colorado Nevada Rhode Island