One of the most common questions posed by small printers regarding the Health and Safety in Employment (referred to in this article as OSH) and Hazardous Substances and New Organisms (HASNO) Acts is “do they really apply to me?”
After all, if you are only a small operation, is it really necessary to undergo the strict safety laws that are more applicable to a bigger plant?
The response to this question is always the same, and it is "Yes, OSH and HASNO regulations do apply to the small printer”.
The degree to which the regulations apply is somewhat dependent upon size and application, but because printing is classified as manufacturing, compliance with regulations is not an option.
The purpose of this article therefore is to review some of the more common misconceptions that small printers have regarding compliance with OSH and HASNO regulations.
The first step is to determine which regulations apply and what needs to be done to meet them. Understanding this fact and taking appropriate steps to achieve and maintain compliance will ensure that the safety of employees will be maximised; the environment protected, and enforcement actions can be avoided.
While this article can’t cover all possible compliance requirements, it will highlight key areas where small printers should understand their obligations.
Here are a few of more the common misconceptions that many small printers have:
"Since I have less than ten employees, OSH regulations do not apply to my business.”
This is simply not true. OSH has regulations that cover all business operations and printers must comply with all applicable "general industry" standards including hazard communication, machine guarding, lockout or tagout of equipment undergoing maintenance, fire safety, personal protective equipment, hearing preservation, injury and near-miss recordkeeping, and emergency plans.
"My old equipment does not need machine guards because it is grandfathered."
Again, this statement is not true. According to OSH regulations and interpretations, there is no grandfathering of any existing equipment, which means that old equipment is not exempt from machine guarding standards.
It is the printer’s responsibility to ensure that equipment is properly guarded where possible.
"I don’t have to have a hazard identification programme because we’ve never had an accident."
This statement is not true. The need to conduct a formal and documented job hazard analysis is not dependent upon accident history, but on the hazards present in a particular workplace.
Under OSH laws, every workplace must identify each hazard by job category, decide whether to eliminate, isolate or minimise the hazards, and identify any appropriate personal protective equipment that is required. Once identified, employees must be made aware of all hazards, and know how to use and maintain the protective equipment.
"Lockout/tagout does not apply to me because I have cord and plug equipment and maintenance contracts."
This statement is partially true in that cord and plug equipment is not subject to lockout/tagout requirements as long as it is unplugged during servicing and maintenance, and the plug remains in clear view of the employee performing the service.
For all non-cord and plug equipment, a hazard analysis must be performed and specific lockout/tagout procedures need to be developed and implemented for any servicing and maintenance procedures.
There may be an ability for 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. – but it is wise to get advice if you have any areas of doubt.
“I have collected Material Safety Data Sheets (MSDSs) for my products, so I am in compliance."
By collecting your MSDSs, you are only part of the way to full compliance. Under HASNO regulations, simply collecting MSDSs is not sufficient to demonstrate compliance. Obtaining and maintaining MSDSs is only one of the basic requirements that have to be met. Other requirements include having an inventory of all hazardous chemicals, ensuring that all chemical containers are labelled with the appropriate hazard warnings, obtaining appropriate certification where required and conducting employee training in the safe handling and use of chemicals.
"I don’t have to worry about HASNO because they only regulate the big printers."
Not so. All print facilities are covered by HASNO regulations in New Zealand. The degree to which the regulations apply depends upon the thresholds set under each regulation—and it is important you are aware of those thresholds.
All printers in New Zealand should also be aware of common standards that must be met under general environmental laws, such as restraints on disposing of hazardous liquids.
An alarming trend for the small printer is the amount of automatic blanket wash waste being generated per month. Since many new presses are being equipped with automatic blanket washes and the waste blanket wash is usually a hazardous waste, the amount being generated per month is causing printers a headache
As a result, the printer must plan prudently for its disposal.
While most small printers may not store or use enough chemicals to trigger reporting under these regulations, it is wise to know what the thresholds are in case you inadvertently breach the law.
"I don’t have to provide mechanical ventilation because we are so small.”
Again; the requirement to install appropriate ventilation depends upon two important factors -- location and the amount of air emissions that can be generated from individual pieces of equipment or the facility as a whole.
It is important to meet OSH standards. There are minimum recommended exposure levels for all chemicals which can be obtained from your MSDSs.
"Digital equipment is ‘green’ and does not cause air pollution."
Many printers and suppliers are working under the assumption that digital technologies are "green." This is not true. Digital technologies are not necessarily "green"; they are just different from conventional ones.
If the digital technology is a direct-to-plate imaging system, then it either has a very high pH-developing effluent or is silver-halide based. In either case, the high pH must be neutralised and for the silver halide system, the effluent must both be neutralised and the silver recovered.
Some digital output devices, namely large-format inkjet systems, can literally generate tons of VOC and hazardous emissions which may mean constructing appropriate ventilation systems.
“I can throw away my used rags or cleaning pads."
The most common hazardous waste generated by small printers is waste-cleaning solvents. Since the solvent is typically used with rags, cotton pad, or press cleanup mat, these wastes can also be classified as hazardous.
For disposable towels, the presence of the solvent prevents them from simply being thrown away as trash, and they must be collected and handled as a hazardous waste.
"I can dump my waste fountain solution down the drain because no one ever told me I could not or my salesman told me it was biodegradable."
It is important to remember that the printer is responsible for all of the wastes generated, even waste-water discharges. If the printer discharges waste-water to the drain, the local authority must be contacted to determine if the waste is acceptable and permission needs to be obtained in writing before discharging. The local authority will determine what is not acceptable.
Most local authorities have a "discharge code" that sets the limits regarding types and concentrations of pollutants that they will accept for treatment.
Under no circumstances can any industrial waste be discharged to a septic system. Septic systems are designed to treat sanitary wastes only and not industrial wastes.
Please Note: PrintNZ can help members understand their compliance obligations under both the OSH and HASNO regulations.
This article is based on the work of American authority Gary Jones, who has been a manager of Environmental, Health and Safety Affairs for over 17 years. Gary gave his permission to PrintNZ to modify his comments to a New Zealand perspective, for the benefit of our printers.
Members who wish to take advantage of the general advice of Printing Industries New Zealand can inquire by calling 0800-654-455.
