Lack of raw material supplies for production of inkjet inks and UV LED inks are leading to product delivery delays. Currently, the shortage involves photo initiators TPO and TPO-L. Only a small handful of companies produce the precursor needed for TPO and TPO-L, and one of the major producers has been shut down by the Chinese government.
The European Printing Ink Association (EuPIA), in a statement issued on May 4th, indicated that there is a “potential shortage of photo initiators.” EuPIA added that the two main causes are governmental activities and REACH-related issues.
“Over the last few years the global geo-political situation has undergone a number of changes, including a shift from attempts to reduce trade barriers to ideas about increasing trade barriers. In China, where the majority of photo initiators and their precursors are manufactured, governmental initiatives for environmental protection have prompted many suppliers to either cease or reduce production for limited periods of time. Holistically, these initiatives are to be welcomed, but they undeniably influence the availability of materials, oftentimes resulting in price increases.
“The supply of photo initiators has been further impacted by major incidents; a factory fire, unforeseeable events (force majeure) at chemical plants, low stocks, unplanned maintenance and production outages – all recent examples.
“As the deadline for registration under the REACH regulation approaches, some raw material suppliers have chosen either not to register some raw materials or to register them only for low volume usage. This has the potential to narrow the choice that ink manufacturers have when substituting photo initiators for materials that can also suffer short term supply issues or limited applicability due to re-classification under the CLP regulation (classification, labelling and packaging), in accordance with the EuPIA Exclusion Policy.”
Attention all Digital and Screen Printing Facilities! Following a review of its 2016 final rule to Improve Tracking of Workplace Injuries and Illnesses, also known as the electronic recordkeeping rule, OSHA has corrected an implementation error that affects the compliance obligations of employers in state-plan states. In its review, OSHA determined that Section 18(c)(7) of the Occupational Safety and Health Act, and relevant OSHA regulations pertaining to State Plans, require all affected employers to submit injury and illness data in OSHA’s Injury Tracking Application (ITA) online portal, even if the employer is covered by a State Plan that has not completed adoption of its own state rule.
Before the recent correction, several states had not yet completed implementation of the electronic recordkeeping rule. Employers in those states were not required to submit their injury and illness data electronically until the state adopted the rule. The recent correction means that all employers in all states that are covered under the electronic recordkeeping requirements, regardless of whether they are under federal or state OSHA jurisdiction, must electronically submit injury and illness data for calendar year 2017 by July 1, 2018.
An employer covered by a State Plan that has not completed adoption of a state rule must provide Form 300A data for Calendar Year 2017. Employers are required to submit their data by July 1, 2018. There is no retroactive requirement for employers covered by State Plans that have not adopted a state rule to submit data for Calendar Year 2016.
The following employers are required to submit Form 300A data to OSHA electronically:
•Establishments with 250 or more employees that are required to keep OSHA injury and illness records
•Establishments with 20-249 employees in designated high-hazard industries - this includes all digital and screen printing facilities.
SGIA wil continue to follow the implementation of this important regulatory issue. Sign up to recieve the most up-to-date regulatory and legislative information about specialty imaging
California’s Department of Industrial Relations sought comments on its Jan. draft proposal to amend the state’s Injury and Illness Prevention Program to include requirements for businesses to develop and implement a workplace violence prevention program. SGIA does not oppose the development of such programs, however, any program proposed needs to consider the impacts on the small business community. Complex programs that require extensive tracking, reporting and paperwork increase the regulatory burden on the small business community.
In it’s comments to the Department, SGIA indicated that the current discussion draft does not address the impact on small business. Significant requirements have been proposed that that will need to be met by covered businesses. SGIA indicated that given the limited resources of small businesses, the regulation needs to be structured in such a manner to accommodate these limitations. Further, within the state’s Injury and Illness Prevention Program regulations, there is recognition of small businesses, specifically those with less than 10 employees. There is also recognition within the Injury and Illness Program of high hazard and low hazard industry sectors. SGIA continues to have questions as to how this will be carried through to the development of Workplace Violence Prevention Program regulations.
While the state has yet to propose a formal regulatory package, SGIA continues to monitor this regulatory initiative. Sign up to recieve the most up-to-date regulatory and legislative information about specialty imaging
The Environmental Protection Agency (EPA or the Agency) has issued a proposal to add hazardous waste aerosol cans to the universal waste program under the federal Resource Conservation and Recovery Act (RCRA) regulations. This proposed change, once finalized, would benefit the wide variety of establishments generating and managing hazardous waste aerosol cans. This includes not only the screen print sector, but also the retail sector by providing a clear, protective system for managing discarded aerosol cans. The streamlined universal waste regulations are expected to ease regulatory burdens on those establishments that discard hazardous waste aerosol cans; promote the collection and recycling of these cans; and encourage the development of municipal and commercial programs to reduce the quantity of these wastes going to municipal solid waste landfills or combustors.
Comments on this proposal are due by May 15th. SGIA is working to develop comments to submit to the Agency. Sign up to recieve the most up-to-date regulatory and legislative information about specialty imaging.
The U.S. Environmental Protection Agency has indicated its intent to issue a proposed rule that is intended to simplify the regulation of hazardous waste aerosol cans by adding them to the list of materials that can be managed under the Universal Waste management system. Some states, including California, Colorado, Minnesota, New Mexico, Texas, and Utah have already added aerosol cans to their Universal Waste lists. Adding aerosol cans to the list of Universal Wastes would ease the RCRA burden on generators in the two top economic sectors with the largest percentage of potentially affected entities, the retail trade industry and manufacturing.
Currently the U.S. EPA regulates nonempty aerosol cans as RCRA hazardous wastes in the same manner as other hazardous wastes; that is, hazardous waste aerosol cans are basically subject to the same requirements as drums of hazardous waste, including limitations on accumulation time and volume, manifesting, disposal requirements, employee training, and response to releases. That is, aerosol cans are regulated as hazardous waste when discarded. Aerosol cans can be excluded from the definition of hazardous waste, but only if they meet certain strict requirements.
Hazardous waste batteries, certain hazardous waste pesticides, mercury-containing equipment, and hazardous waste mercury lamps are already regulated as Universal Wastes. In general, materials managed as universal waste can be stored for 1 year or longer, and do not require a manifest when shipped, provided they are properly labeled, packaged and stored. Universal wastes also do not need to be counted toward a hazardous waste generator’s inventory for determining whether the generator is classified as a very small quantity generator, small quantity generator, or large quantity generator.
SGIA will continue to monitor and follow this important regulatory initiative. Sign up to recieve the most up-to-date regulatory and legislative information about specialty imaging.