OSHA and EPA Inspections and Penalties are on the Rise

And Printers Are a Target

The Best Action Is to Be Prepared

OSHA has developed a new penalty calculation structure, which has caused a dramatic increase in penalties imposed on printing companies across the country.

Here are some quick facts:

• The printing industry is considered a “high hazard” industry for amputations, meaning the high rate inspections of printing facilities will continue.
• OSHA’s penalty calculation system has been revised, and as a result many violations are now considered “serious.” The average serious penalty has been tripled and now ranges from $3,000 to $5,000.
• Many “serious” violations are now considered high gravity and can receive a base penalty of $7,000.
• OSHA has stiffened its penalty reduction policy. Penalty reductions of 50% which were previously common will be much harder to negotiate.  

The bottom line is that all of these changes have resulted in five and six figure penalties for printing companies. You can save tens of thousands, if not hundreds of thousands of dollars if you are proactive and prepared.

Printing Industries of America Can Help!
Regardless of the compliance issue, Printing Industries of America’s EHS Affairs team can provide the necessary expertise and knowledge to help solve a problem, prevent violations, or respond to an enforcement action or citation. A simple phone call or email could literally save you thousands of dollars in consulting fees, wasted time, and fines.

Assistance from our EHS staff can range from answering questions and approving program templates to onsite consultations and training. In addition to working directly with individual printing companies, our staff also works in conjunction with other consultants, attorneys, and, if necessary, individual regulatory agencies on behalf of your company.

In representing printing companies directly or providing specific guidance, the EHS Affairs team has been able to successfully challenge citations and greatly reduce or completely eliminate penalties. If you have any questions, do not hesitate to contact Rick Hartwig at 800-910-4283, ext. 792 or rhartwig@printing.org.

The EHS Regulatory Areas Affecting the Printing Industry Include:

• The Environmental Protection Agency (EPA)
  EPA’s main responsibility is the protection of human health and the environment from pollution. One of EPA’s responsibilities is to develop, implement, and enforce regulations that include air pollution, waste management and disposal, waste water discharges, storm water discharges, reporting the release of toxic chemical use and disposition, hazardous chemical storage, oil spill prevention, controlling the manufacturing and importation of toxic chemicals, accidental spill release reporting, and response and cleanup of contaminated property. 
  
  In addition to the federal requirements, there are state and local requirements as well. EPA sets the minimum standards that need to be met, and the state and local government agencies can and sometimes do impose stricter requirements.
  
  
• The Occupational Safety and Health Administration (OSHA)
  OSHA’s sole responsibility is employee safety and health protection within a facility or at the workplace. OSHA is responsible for development, implementation, and enforcement of safety and health standards and regulations. This includes machine guarding, Lockout/Tagout, Hazard Communication, Personal Protection Equipment, etc. OSHA works with employers and employees to foster effective safety and health programs which reduce workplace hazards.
  
  
• The Department of Transportation (DOT)
  The DOT area that covers the printing industry is the Pipeline and Hazardous Materials Safety Administration (PHMSA). PHMSA establishes regulations that ensure the safe and secure movement of hazardous materials by all transportation modes, including the nation’s pipelines. Since printers can be “shippers” of hazardous materials, they need to understand the registration and meet the training requirements for employees involved in the management of hazardous materials.
  
  The Department of Homeland Security (DHS)
  The responsibility of DHS is to protect the American people and country from many different threats. The one area where DHS affects printers and their operations is the Chemical Facility Anti-Terrorism Standard, which is a risk-based performance standard aimed at facilities that store certain chemicals above specific thresholds.
  
  The Consumer Product Safety Comission (CPSC)
  The CPSC oversees consumer product safety issues and is the agency responsible for implementing the Consumer Product Safety Improvement Act of 2008 (CPSIA). This act limits the amount of lead and phthalates allowed in children’s products and requires printers to test and certify the lead and phthalate content of such products.  

If you have any questions, do not hesitate to contact Rick Hartwig at 800-910-4283, ext. 792 or rhartwig@printing.org.