February 19, 2001
Metal stamping companies are required to comply with a number of regulations relating to the collection, transport, treatment, and disposal of the wastes they generate. As a result, each company must learn which materials are classfied as hazardous and how to comply with detailed regulations.
Possessing an in-depth knowledge of the latest metal stamping techniques, methods, tooling, and machinery is obviously a desirable trait for any professional in the metal manufacturing and fabricating industry. Unfortunately, the same value is not always placed on being knowledgeable in another key area of metal stamping operations—how to properly handle waste generated in the pressroom.
Since the 1984 Resource Conservation and Recovery Act (RCRA) was enacted, businesses in every industry have become legally responsible for the hazardous and nonhazardous wastes they generate. If a company generates any hazardous waste in a month, it is considered a generator and legally is responsible for that waste.
Metal stamping companies are required to comply with a number of local, state, and federal environmental regulations relating to the collection, transport, treatment, and disposal of the hazardous and nonhazardous wastes they generate. As a result, each stamping company must learn which materials are classified as hazardous and how to comply with detailed regulations.
Employing one or more professionals who have a sound understanding of these environmental requirements is a definite advantage. However, putting that knowledge to use is a time-intensive process. To be successful in achieving and maintaining compliance, a metal stamping company should implement a facilitywide program that motivates, educates, and trains all employees in proper waste handling procedures.
One of the first steps in implementing a compliance program is teaching employees to identify the different types of waste generated at their facility. A waste is any solid, liquid, or contained gaseous material that is discarded through disposal, burning or incineration, or recycling. Waste can be the by-product of a manufacturing process or simply a commercial product that is used and discarded. Even materials that are recyclable or can be reused in some way, such as burning used oil as fuel, may be considered to be waste.
Waste generated at a metal stamping operation can range from hydraulic fluids, lubricants, and machine oils to used parts-cleaning solutions and absorbents. However, some types of waste are not always easily identifiable.
For example, most people know that PCBs are harmful to the environment, but what about rags and wipes? Although it is not a hazardous waste by itself, a rag used to wipe up a fluid spill becomes a waste that is governed by the same regulations that apply to the fluid absorbed into the rag.
Another step in implementing a compliance program is to evaluate existing waste management procedures at a company. The U.S. Occupational Safety and Health Administration (OSHA) has set specific guidelines that every facility must meet, including having written plans in place for emergencies and facilitating employee right-to-know information. Managing waste is not a part-time activity; rather, it is a full-time commitment that each business owner must make to stay in business.
Determining how much waste an operation generates also is important in developing a compliance program. A metal stamping company should, for example, consider whether specific quantities of oils and fluids are used over a period of time or if the amounts vary as business changes. The U.S. Environmental Protection Agency (EPA) defines three categories of hazardous-waste generators based on the quantity of hazardous waste generated per month:
1. Conditionally exempt small-quantity generators (CESQGs), which create less than 220 pounds (100 kilograms) per month
2. Small-quantity generators (SQGs), which produce from 220 pounds (100 kilograms) to 2,200 pounds (1,000 kilograms) per month
3. Large-quantity generators (LQGs), which produce more than 2,200 pounds per month
Companies must comply with the hazardous-waste rules set up for the category in which they fit. For example, CESQGs are exempt from nearly all of the U.S. government's generator requirements in the 40 CFR 262, as well as the Land Disposal Restriction regulations in 40 CFR 268. SQGs, on the other hand, are required to follow these regulations.
In addition to U.S. government requirements, many states have their own hazardous-waste regulations that are based on federal regulations. While some states' requirements mirror the federal rules, other states may have more stringent requirements.
It also is helpful to know how much waste a company has on hand to establish an immediate need versus an anticipated one. For instance, if a pressroom worker disposes of rags by tossing them in the trash, the company may have "zero" rags on hand but will need to determine usage to institute a compliant waste management plan.
If rags have been collected in a drum, the immediate need is known, but the question of long-term usage still must be answered. In both cases, knowing how much waste is on hand provides a starting point for measuring usage factors.
After pressroom wastes have been identified, current practices assessed, and the amount of waste that is generated determined, a company must decide what method(s) will be used to treat its waste. It also must determine if its compliance program will be managed internally or whether it should turn to an outside provider for assistance. These important decisions should be based on a number of factors, including the types of waste generated and the extent of a company's on-site resources.
Metal stamping companies that generate nonhazardous waste either can recycle it into useful products or, if recycling is not practical, recover energy from the waste to use in making new products. Waste paint, for example, can be blended into an industrial fuel. Certain types of waste, such as oil, can be treated using a variety of methods, including re-refining or processing and burning for energy recovery.
Metal stamping companies can treat and recycle certain types of waste continuously on-site. Recycling units can be used on the pressroom floor to treat water-based fluids such as mop water.
According to the EPA, types of used oil that can be recycled include synthetic oil, engine oil, transmission fluid, refrigeration oil, compressor oils, metalworking fluids and oils, laminating oils, industrial hydraulic fluid, copper and aluminum wire drawing solutions, electrical insulating oil, industrial process oils, and oils used as buoyants.
Other types of waste can be treated and recycled continuously on-site. For example, the amount of wastewater that a metal stamping company generates can be reduced dramatically through the use of filtration technology and aqueous fluid recycling equipment. A recycling unit can be used on the pressroom floor to treat water-based fluids such as aqueous cleaner baths, mass finishing fluids, press water, mop water, and synthetic coolants (see Figure 1). Soils that reduce the useful life of the fluids can be filtered and collected to improve the cleaning capability of the equipment and the efficiency of the vibratory media or coolant.
Using on-site recycling processes can reduce waste generation by as much as 90 percent. In addition, because the process retains and concentrates larger oil and dirt particles in the tank, the unconsumed active ingredients in the chemistry can be reused many times, reducing chemical usage by as much as 85 percent.
The cost and time involved in understanding different waste treatment methods, environmental requirements, and actually handling the waste quickly can become a burden for small and medium-size businesses. Each company must determine whether it has enough personnel to oversee the operation and maintenance of the recycling equipment or the collection and transport of waste to processing facilities.
A metal stamping company that chooses to implement its own environmental compliance program should be able to designate at least one full-time employee as its environmental manager. This person should be able to interpret government regulations relating to hazardous and nonhazardous wastes, supervise waste management practices, and handle all related paperwork.
If staffing one or more full-time environmental managers is not an option, an alternative is to hire an environmental service provider. Many of these waste management companies can help prepare manifest paperwork, conduct laboratory analyses, determine appropriate pickup schedules, and recommend different waste minimization opportunities.
If a company decides to seek outside assistance, knowing how to choose a qualified provider can affect the success of its compliance program.
Some service providers are transporters and limit their business to picking up and hauling waste, while transfer and storage firms (also known as waste brokers) collect waste from many generators and combine it to make shipments large enough to take to disposal facilities. Full-service providers take responsibility for the waste from pickup to processing and reclamation.
Here are some questions to consider when evaluating an environmental service provider:
1. What services can the company provide? Can the company handle all waste materials, or will several firms be needed to get the entire job done?
2. Does the company have the proper federal and state environmental permits, and does it comply with all federal and state environmental regulations?
3. Does the company keep operating records, including inspection and training records?
4. Are the facilities processing the waste fully and regularly audited?
5. Does the company have sufficient assets to protect its customers in the event of an accident, cleanup operation, or legal proceedings stemming from the handling, treatment, or disposal of waste?
6. Have the company's service representatives received documented training on environmental regulations and United Nations/Department of Transportation (UN/DOT) requirements, and do they have access to specialists who can be consulted if necessary?
A company that is considering outsourcing its waste management compliance program should remember to examine the credentials, employees, facilities, and business practices of environmental service providers thoroughly. Service representatives who are knowledgeable about their company's waste handling procedures and can recommend various environmental alternatives are a valuable resource.
Whether a metal stamping company decides to handle its waste internally or use an outside service provider, it pays to do the research and be prepared. Thoroughly investigating environmental service providers, having a solid understanding of environmental regulations, and evaluating a company's resources are critical to the success of a compliance program.