From: ACTSNYC**At_Symbol_Here**CS.COM
Subject: Re: [DCHAS-L] Overspray from screen print cleaning
Date: February 2, 2012 7:05:42 PM EST
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: <30da.3355ae.3c5c7ed6**At_Symbol_Here**>

Bruce,  I suggest you reread my post.  You seem to think I was saying some of the colorants in the ink should or could be batch-appoved FDA colorants.  I can assure you, NONE of them are.  They are too expensive and they are not archival (color fast).

You must be irked to demand I prove ~200 ink pigments are toxic.  That's the same argument that industry uses.  And industry demands this proof knowing full well they have never studied their chemicals to provide this data.

That's why the EU Dye Directive is so precedent-setting.  No testing is necessary  other than knowing that at least one of 22 carcinogenic metabolites can be released.  And usually, this can be determined by looking at the structure of the azo dyes or pigments (those -N=N- bonds are the first to go).

So, I refer you to the EU Dye Directives list and the Colour Index constitution number which can be used to look up the structure of those dyes. You don't need a "crystal ball" as you said, just a good MSDS.   Or you can look at the pigment and dye chart in one of my books. I list about 230 colorants used in art materials by C.I. name/number and some of what is known and/or can reasonably be expected in regard to their toxicity.

You end by saying:  "How would you dispose of what you proposed in accordance with current law?  Anxiously awaiting your responses."   I would dispose of them exactly as EPA requires and as you are doing.  My only issue with you was your prior statement that "If the water spray and particulates are non-hazardous and there is no potential for occupational exposure, have you considered educating the shop manager to alleviate his/her concerns? "

Instead, I would tell the shop manager that those pigments are not innocuous despite EPA's regs, and to follow the Precautionary Principle whenever exposed to untested substances that are in known hazardous chemical classes.

A Prius and a big V-8 Chevy truck!  You must be doing very well.


In a message dated 2/2/2012 4:14:41 PM Eastern Standard Time, brucev**At_Symbol_Here**BRIGHT..NET writes:


I apologize if my original post was unclear.  I did NOT mean to imply that lacking an EPA waste code means the compounds are non-hazardous.  In no way, shape or form did I think my post could be interpreted as unregulated by EPA WW could be interpreted as non-hazardous to personnel.  We don't have knowledge of the inks/emulsion(s) generated from the cleaning of screens from the dyes questioned within the original post to properly address FDA food grade dyes/metabolites.  I was simply trying to respond to both aspects of the original post, stating that the compounds "don't contain any hazardous materials" and the second dealing with the environmental issues/concerns raised.  I didn=E2=80™t perform the initial classification, identify the potential routes of exposure nor quantify the exposures to the chemicals, let alone attempt to identify their respective metabolites.  So, I didn't think it ethical to address, but you did.  BUT YOU CAN'T EITHER if you are responding to the information provided within the original post (which is conveniently deleted from your response). 

All we can do is provide input/advice/recommendations, which is what I thought I had done. 

Do we really want to start discussing the metabolites of chemicals when most chemicals themselves have not been evaluated regarding toxicity?

Please specify the metabolites, BEIs, =BD life(s), etc. of the specific "possible contaminates" provided from the original post.

I apologize, I don't have a crystal ball to tell me what dyes/pigments were used, let alone if the inks, strippers, emulsions, etc. are FDA batch-approved food dyes and pigments.  I am curious where you obtained that information from the original post?  You can't.  Maybe we should focus upon providing scientifically justified and defensible responses to the list when possible.  All we can do is to respond to the information provided to the best of our abilities,  knowledge and experience.

If this response offends you, I apologize.  I was simply trying to respond to the issues raised in the original post with no harmful intentions.  Who was considered the Father of Toxicology?  Paracel what?  Maybe we should recommend taking a step back, evaluating the exposures/dose before offering criticism or making assumptions.  Please refer to the original post, maybe you have read more into the information provided than I did.  I'm always open to suggestions. 

Now, if there is a car you would like to discuss, would you like to discuss my Prius or my big V-8 Chevy truck?  If so, may I suggest we do that offline? 

How would you dispose of what you proposed in accordance with current law?  Anxiously awaiting your responses.



From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of ACTSNYC**At_Symbol_Here**CS.COM
Sent: Wednesday, February 01, 2012 5:14 PM
Subject: Re: [DCHAS-L] Overspray from screen print cleaning

Unregulated by EPA in waste water DOES NOT EQUAL non-hazardous to people. 

Those are not FDA batch-apparoved food dyes and pigments.  If you really think those art pigments are non-hazardous after looking at their structures some of which are azos which can be anticipated to metabolize to release aniline, toluidine, benzidine, chlorinated benzenes, etc., then there is a car I want to talk to you about. 

Monona Rossol

In a message dated 2/1/2012 11:42:21 AM Eastern Standard Time, brucev**At_Symbol_Here**BRIGHT.NET writes:

Debbie - If the water spray and particulates are non-hazardous and there is no potential for occupational exposure, have you considered educating the shop manager to alleviate his/her concerns?  A famous quote is "the dose makes the poison" and it just seems to me that we should be educating people to be concerned about the hazards that are indeed hazardous and satisfy them with those issues that are not, maybe a little training could go a long way.

Ron - Waste has to be profiled to meet EPA discharge regulations or disposal regulations.  Debbie was speaking of an occupational exposure governed by OSHA, not EPA.  Different standards/criteria, an apples to oranges comparison.  You stated that your discharge is a non-hazardous waste.  How was the information presented to the city?  Was the waste stream properly characterized for disposal?  Characterization is required to be performed by a lab that is probably outside of your company, but certified by your state/Fed EPA.  Homeowners or retail consumers have always been and always will be exempt from EPA compliance requirements, while we are not.  Your city was/is right in that they have the final say in what they will accept into their wastewater treatment facility and if not sufficiently defended with analytical results.  Your city does  not want to treat a hazardous waste or be classified as a Treatment, Storage or Disposal Facility (TSDF)?  You can make this a win-win situation.  Do you have a permit, maybe even an industrial wastewater discharge permit from your city? 

If not I would recommend that you investigate the requirements and obtain one.  Either way you will need the lab analytical results to present to them.  Yes, this will require initial laboratory analytical confirmation, continued on a recurrent basis, for them to continue to accept the wastewater discharge into their sewer system and that is the point, that=E2=80™s compliance and yes, violations can/will lead to expensive fines/penalties in California or anywhere else. 

The location is irrelevant they are implementing the federal law!   


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