2006 FPA Environmental Summit and Safety Conference: A Great Success!

The Flexible Packaging Association’s Environmental Summit and Safety Conference, known for great content and high caliber presenters, was once again a great success. Held on January 18-20, 2006, the events provided significant information with “take-home” value. “The Environmental Summit and Safety Conference are, as always, the highlights of the year,” commented Steve Rach of MEGTEC Systems. “The sessions provided information of a true value.”

The FPA Environmental Summit

The FPA Environmental Summit, held from January 19-20 engaged attendees in interactive presentations that focused on environmental topics critical to the flexible packaging industry, its manufacturing plants and facilities. “This conference keeps me proactive and abreast of pertinent environmental issues,” commented Oliver Stanley of Sonoco Flexible Packaging. Following are highlights of the summit presentations.

Deputy Director of the U.S. EPA Office of Solid Waste, Maria Parisi Vickers discussed the efforts of the U.S. EPA to conserve natural resources. Deputy Director Vickers explained that the agency has accomplished the task of creating a safe system for waste disposal and is now focusing its efforts on source reduction, reuse and recycling. In 2002, the U.S. EPA initiated The Resource Conservation Challenge to encourage recycling, reduction of toxics in products and resulting waste, and the conservation of natural resources and energy.

One key priority under the Resource Conservation Challenge is to increase the recycling of municipal solid waste. “The U.S. EPA has selected packaging as an area of focus because of its increasing prominence in the solid waste stream,” said Deputy Director Vickers. Her presentation noted that in 2003, packaging represented approximately one-third of the U.S. municipal solid waste stream, and only 30 percent of generated packaging waste was recycled. As packaging waste increases worldwide, 28 countries have implemented laws, which encourage reduced packaging material and the recycling of packaging discards. Of those countries, many require manufacturers to take back packaging waste or pay for recycling.

“The U.S. EPA recognizes the importance of source reduction in resource management and will collaborate with the industry to educate state, local and tribal governments about better solid waste management,” said Deputy Director Vickers. She outlined several U.S. EPA sponsored programs and initiatives including the EPA Cradle-to-Cradle Design Award, Design for End-of-Life, the Sustainable Packaging Coalition, the Recyclable Transfer Packaging Roundtable and WasteWise, which focus on reducing packaging waste and increasing recycling.

“The U.S. does not have federal packaging mandates. However, state and local government concerns about packaging waste continues to grow,” noted Deputy Director Vickers. She stressed that the U.S. EPA does not have a regulatory agenda on packaging, but is very interested in working with the packaging industry to decrease waste through source reduction and recycling. Deputy Director Vickers pledged that the U.S. EPA is committed to working with “…the flexible packaging industry to educate the public on the benefits of source reduction in packaging...”

“The Flexible Packaging Association will be proactive in efforts to increase awareness and education throughout the public about source reduction,” commented FPA president Marla Donahue. “FPA has a very positive story to tell about source reduction, and we embrace the opportunity to work with EPA on this initiative. The association, more specifically the FPA Environmental Committee, has a history and tradition of working successfully with the U.S. EPA to simultaneously benefit the environment and the industry.”

Sarah Dauk of the U.S. EPA reviewed reforms for managing ozone-depleting substances and noted that the U.S. EPA has increased enforcement activities in this area. Ms. Dauk provided attendees with a typical EPA inspection “checklist” that detailed what an inspector is looking for during a compliance inspection.

Storm Water Permitting and SPCC Plans

Michael Mitchell of the U.S. EPA discussed the benefits and the steps that should be taken in developing an effective storm water pollution prevention plan and reviewed the applicable requirements. Ted Walden of the U.S. EPA highlighted the essential elements of a spill prevention control and countermeasure plan including certification, approval, review and inspections.

Gary Rust of U.S. EPA discussed the Technical Support Document for Printing and Flexible Packaging and other VOC emitters that were developed in conjunction with FPA. The document provides practical approaches to Title V Permitting and monitoring. Mr. Rust discussed the Monitoring Knowledge Base system and noted that using the Monitoring Knowledge Base system provides a comprehensive understanding of emissions sources, control devices and monitoring techniques.

Tom Driscoll of the U.S. EPA provided an update of the agency’s activities concerning the Title V Permitting task force, PTE rulemaking, Once In Always In rulemaking and umbrella monitoring. Bob Iwanchuk of ENSR International provided an overview of Title V permitting including the regulatory review process that follows the submission of a complete operating permit application.

“The Hazardous Organic NESHAP rules require the development and use of start-up, shutdown and malfunction plans during SS&M periods,” noted Norman Morrow of Fresh Air Consulting. Mr. Morrow explained that the requirement applies to Printing NESHAP (Subpart KK) and Paper and Other Web Coating NESHAP (Subpart JJJJ) sources that use control devices for emission control.

“Businesses should include security considerations in all of their operations to effectively manage the potential security risks associated with the transportation of hazardous materials,” said Tay Rucker of the U.S. Department of Transportation. Mr. Rucker noted that the agency has mandated businesses to implement security plans and, proactively educate and train employees to handle potential security problems that may arise during the transport of hazardous materials.

Terry Lam, of the T&T Group emphasized the importance of recycling and encouraged plastic manufacturers and converters, and recyclers to work together to increase recycling. Mr. Lam noted that a recycler must place emphasis on R&D and invest in machines and equipment with advanced technology that include sorting, grinding, washing and drying, and extruder processing.

Victor Bell of Environmental Packaging International discussed environmental labeling and sustainable packaging. Mr. Bell reviewed international requirements for material coding, what is required to be put on packaging, the proper use of the SPI code and legal requirements for making environmental claims about packaging. Mr. Bell outlined the growing movement towards sustainable packaging and the roles and activities of the Sustainable Packaging Coalition.

Wendy Pratt of NewPoint Group Management Consultants provided an overview of environmental issues related to plastics, plastic film and plastic bags. Ms. Pratt noted that plastic bags have been getting considerable attention by regulators. Internationally, plastic bags have been banned, taxed, studied and the subject of voluntary initiatives. In the United States there have been several tax proposals for plastic bags, ranging from two cents to 15 cents per bag. “Responsible environmental management of plastic bags is here to stay,” said Ms. Pratt. “Today is an ideal time for the plastic film industry to step forward and address the environmental issues of their products.”

Test Methods (846, 24, 25/25A, 204)

Dave Ellison of Alcan Packaging discussed U.S. EPA Test Methods SW 846 for evaluating solid waste, Method 24 and 24A for measurement of VOCs in paint, varnish, lacquer and coatings, and challenged the audience concerning applicability of Methods 25 versus 25A. Mr. Ellison provided the pros and cons of using these specific Test Methods and conducted a very thought provoking session.

“The Summit agenda, developed by industry peers, focused on critical and timely issues. Every year the program agenda gets stronger and the selection of the speakers more relevant to our industry,” said Jim Hillstrom, chairperson, FPA Environmental Committee.

The FPA Safety Conference, held on Wednesday, January 18, 2006 welcomed speakers familiar with key safety topics important to the flexible packaging industry. Following are highlights of the conference presentations.

Graham Tyers of Newson Gale, Inc., discussed static electricity and explained that an electrostatic charge is an unfortunate by-product of many processes and is a constant hazard in production facilities and maintenance areas. Mr. Tyers detailed the serious consequences of static spark in a hazardous atmosphere, how to reliably and safely avoid the occurrence of an uncontrolled static discharge with proper design, the use of grounding and bonding techniques, new developments in ground verification systems and static control technical standards and guidelines.

William Bradshaw of Process Industries ABSG Consulting explained the requirements of the PSM program and how it can be applied in the flexible packaging industry. Mr. Bradshaw’s presentation provided guidance on designing an ink room and solvent dispensing facility.

Jim Washam of the Occupational Safety and Health Administration (OSHA) discussed machine hazards related to flexo printing and extruder equipment. Mr. Washam emphasized that the best way to determine proper safeguarding methods is to perform a task based risk assessment, such as the ANSI Standard TR3-Risk Assessment and Reduction, 2000. Mr. Washam also gave an overview of OSHA’s Lockout/Tagout Standard and covered the scope and purpose of the Standard.

“LFL monitoring is gaining attention by printers in the flexible packaging industry,” said Steve Rach of MEGTEC Systems. “Printers in the flexible packaging industry have used this technology to provide an added level of protection against explosion when running VOC based inks and coatings.” Mr. Rach explained that NFPA 86 requires enough dilution air to always maintain less than 25 percent of LFL for systems without monitors, and up to 50 percent of LFL for systems with monitors. In the past, these monitors have traditionally been flame type units. Mr. Rach discussed the increased availability and application of infrared LFL monitoring in North America, and the differences between traditional flame and infrared systems.

Teresa McGuckin of Rohm and Haas Company discussed industrial hygiene considerations, reviewed the essential elements of a successful product stewardship program including leadership commitment, risk assessment/risk management and outreach to commercial partners. With its foundation in the American Chemistry Council’s Responsible Care Ô program, Ms. McGuckin explained “product stewardship is an important tool, and promotes the safe handling and use of chemicals at all stages in the products life cycle, so neither people, nor the environment, are harmed.” Ms. McGuckin also stressed the importance of understanding the hazards of products produced and managing the hazards at an acceptable level of risk.

Ted Sommer of Town & Country Electric provided an in-depth review of the recently adopted NFPA 70E safe electrical work practices Standard and discussed plant specific applicability of the Standard as it relates to troubleshooting or working with live electrical circuits. Mr. Sommer also discussed the issue of shared responsibility and the relationship between owner and contractor as they relate to the Standard.

“The Environmental Summit and Safety Conference once again saw positive interaction among attendees and presenters,” commented Ram Singhal, director of regulatory and government relations. “Both conferences served to impart information that will help in dealing with very complex regulatory issues.”