Environmental Compliance with Digital Plates
Fujifilm is strongly committed to Environmental Compliance and Sustainability. We commissioned an independant third party review of plate development chemistry effluent to measure our and our competitors plates compliance with sewer disposal bylaws across Canada. The review was conducted by Envision Compliance Inc.
The report below highlights the results of the review. For a full copy of the laboratory results please contact Tony Karg (tkarg@fujifilm.ca).
Sewer Use Bylaws and Plate Processing Chemistry
Recently we have had an increase in inquiries from both printers and City Inspectors concerning the use of the drain for the disposal of prepress and pressroom chemicals. As we all are aware, the major source of wastewater going into the sanitary sewer from a printing plant is from used fountain solutions and the prepress department. However the answers that we were able to get tended to be confusing.
Under the sponsorship of Fujifilm Canada Inc., we took on the task of trying to bring some straight talk to the prepress effluent concerns. To get our investigation underway we focused on chemistry from the major suppliers. Envision Compliance obtained samples of Fujifilm Ecomaxx-V process chemistry, LH-PJ process chemistry used with a Fujifilm EcoPro Neutralizer Unit, Heidelberg Chem Free and Agfa :Azura TS processing chemistry. Another plate product, Fujifilm’s Ecomaxx-T plate, is a processless plate that is developed on press, therefore it does not utilize any processing chemistry but is included here as a reference.
Independent of this investigation we already had samples of Kodak chemicals analyzed at the request of some of our clients. All of these process chemistries had been used to process plates, in a typical prepress operation following manufacturer’s recommendations. The samples were intended to demonstrate what would go to the drain following use.
Should testing be done before use?
In most cases, process chemistry before it is used does not have contaminants in it, other than perhaps a pH issue or depending on concentrations a high BOD (Biological Oxygen Demand). Both of these contaminants would likely need to be corrected before it goes to the drain. But we use the chemistry to process the plates. Throwing away process chemistry before it is used doesn’t make sense. Therefore getting information on chemistry before it is used is not helpful to stopping the confusion when it comes to disposal. What our callers must know is can it go to the drain after it has processed printing plates. The City inspector checks the waste water after it is used in your plant, not prior to use.
Armed with samples of used chemistry provided to us from a variety of prepress operations across Canada we analyzed the chemistry against typical limits in sewer use bylaws in Canada. At some of the plants, the staff volunteered that they had been advised to just put the used chemicals from the processor down the drain. However, our analysis showed that the answer isn’t that simple. In many situations, once the chemistry had been used to process plates, it contained contaminants that came off of the plate as the imaged developed. It is only logical that when the image comes up on the plates, the material that is removed has to go somewhere. We all know that it goes into the process chemistry.
Some of the contaminants from processing that end up in the chemistry were found to be above the bylaw limits. To ensure representative results, all analytical testing was done using process chemistry that had developed plates following the manufacturer’s recommendations.
The following is a selection of some of the results from the test.
- BOD (Biological Oxygen Demand) found as high as 67,000 mg/L, typical bylaw limits are 300 mg/L
- Total Suspended Solids found as high as 1200 mg/L, typical bylaw limits are 350 mg/L
- pH (processes without neutralizers) found in ranges as low as 5.0 or as high as 13.5, typical bylaw limits are between 6.0 to 11
- Copper found as high as 5 mg/L, typical bylaw limits are 2.0 mg/L
- Phosphorus found as high as 5500 mg/L, typical bylaw limits are 10 mg/L
- Total Kjeldahl Nitrogen (TKN) found as high as 4,100 mg/L, typical bylaw limits are 100 mg/L
We found examples of chemistry and plate combinations that used a neutralizer recommended by the plate manufacturer. When the neutralizers followed recommendations it had the ability to remove specified contaminants in the process chemistry. We found, only Fujifilm’s LH-PJ plate used with an Eco-Pro neutralizer conformed with our selection of Canadian city sewer effluent bylaws. The Fujifilm Ecomaxx-T plate, which is processless, also conformed since it generated no waste effluent in the prepress department. All other products, Fujifilm Ecomaxx-V, Heidelberg Chem Free and Agfa: Azura TS failed to conform with typical bylaw limits therefore cannot be disposed in the sanitary drain.
What is the penalty for non-conformance?
Most municipalities have backed up their by law with significant penalties for non-compliance. This ranges from the inspector having the power to immediately issue a ticket when he or she sees a section of the bylaw being broken, to a severe monetary fine. The following is an excerpt from the City of Toronto bylaw and details what they can do to a company that is not complying.
- B. Every corporation which contravenes any provision § 681-2, 681-3 or 681-4 of this article (Discharge of process water that is not complainant with the requirements of the bylaw) is guilty of an offence and on conviction is liable, for every day or part thereof upon which such offence occurs or continues, to a fine of not more than $50,000 for a first offence and $100,000 for any subsequent conviction.
- C. Notwithstanding Subsections A, every person who contravenes any provisionof any other section of this article is guilty of an offence and on conviction is liable, for every day or part thereof upon which such offence occurs or continues, to a fine of not more than $5,000.
The reality of this story is, you must satisfy yourself that if you are using the drain you must be compliant with the bylaw. There is only one way to be absolutely sure. Have the processing effluent sampled and analyzed following use. Only under very specific conditions can used chemistry go to the drain following pre-treatment. With the samples we tested, the contaminants that came off of the plates during processing resulted in the effluent non-compliant with the bylaw limits, unless the chemistry had been taken from a process combination specifically designed to use a pre-treatment system such as an EcoPro neutralizer, or an equivalent device. Just diluting the processing chemistry with extra water is not an acceptable method to reach compliance. Purposely diluting a chemical with non-process water is an offense in most bylaws in North America.
To start your facility down the road to compliance:
Step 1: Ask your supplier what you need to do to make the used chemistry acceptable with the bylaw limits.
then
Step 2: Have the effluent from the process analyzed or request analytical proof from your supplier that if you are going to use the drain the effluent from your specific installation is compliance with the bylaw.
It is our opinion, that these two simple steps will help to get you on the road to preventing your Print Facility from receiving a Notice of Violation from your municipal or provincial inspector. It’s your business! Remember as the operator or owner, you are responsible for what goes in the drain, not your plate vendor.
Envision Compliance Ltd.