PAINT AND INK INDUSTRY TOXIC POLLUTANT CONTROL
James R. Berlow, Project Officer
U.S. Environmental Protection Agency
Washington, D.C. 20460
Howard D. Feiler, Project Manager
Paul J. Storch, Project Manager
Burns and Roe Industrial Service Corp.
Paramus, New Jersey 07652
INTRODUCTION
On January 3, 1980, the EPA proposed regulations prohibiting the discharge of process
wastewater pollutants from all paint and ink manufacturing facilities to either receiving
waters or publicly owned treatment works (POTW). After considering comments, the EPA
will issue final regulations.
EPA is proposing this regulation under authority of the Clean Water Act (the Federal
Water Pollution Control Act Amendments of 1972, as amended by the Clean Water Act of
1977, Pub. L. 95-217). These regulations are also proposed in response to the Settlement
Agreement in Natural Resources Defense Council, Inc. v. Train.
PRIOR EPA REGULATIONS
On July 28, 1975, regulations (40 CFR 446) were promulgated setting forth no discharge
of process wastewater pollutants for best practicable control technology currently available
(BPT), best available technology economically achievable (BAT), new source performance
standards (NSPS), and pretreatment standards for new sources (PSNS) for the oil-base
solvent-wash subcategories of the paint and ink industries. These regulations were not
challenged, and are currently in effect. No regulations for any other subcategories have been
previously promulgated. For the purpose of clarifying the coverage of these subcategories,
EPA is retitling these subcategories the solvent wash subcategories.
OVERVIEW OF THE INDUSTRY
The paint industry consists of approximately 1500 manufacturing sites operated by 1150
to 1300 companies. The ink industry consists of approximately 500 sites.
The major products of the paint industry (SIC 2851) are: (a) trade sales paints, also called
architectural coatings, which are primarily off-the-shelf exterior and interior paints for
buildings and other structures; and (b) industrial sales paints, also called chemical coatings,
sold to manufacturers for factory application to such products as automobiles, aircraft,
furniture, machinery, etc.
In addition to paints, the industry produces varnishes and lacquers, which consist of film-
forming binders (resins or drying oils) dissolved in volatile solvents or dispersed in water. The
industry also produces such allied products as putty, caulking compounds, sealants, paint
and varnish removers, and thinners. These items are part of the "Allied Products" segment of
SIC 2851.
The major products of the ink industry (SIC 2893) consist of letterpress inks, lithographic inks, flexographic inks and gravure inks. The industry also produces a variety of
specialty products. Most ink is manufactured for consumption by the printing industry.
According to an EPA survey of all manufacturing sites, approximately 40% of both paint
and ink facilities have less than 10 employees, but account for only a small percentage of the
total industry sales. Paint and ink are generally classified as either water base or solvent (or
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