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This topic comprises 2 pages: 1 2
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Author
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Topic: EPA & Film Storage Question
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Frank Angel
Film God
Posts: 5305
From: Brooklyn NY USA
Registered: Dec 1999
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posted 02-11-2005 04:08 AM
We just got told by the college that the EPA is coming to make an on-site visit to inspect all areas of the campus, including the Performing Arts Complex and my booth in particular. The college has agreed that inspectors will have access to all areas -- evidently every nook & cranny is going to be opened and inspected for violations. They are specifically looking for chemicals and other hazardous waste that are not properly identified and segregated. Old air conditioners and obsolete computers, even spent flourscent bulbs (and obviously xenons) if they are lying around, they are considered improperly disposed of because the assumption is that eventually they will be disposed of improperly (?). quote:
Areas such as offices, classrooms, storerooms, art studios, laboratories, shops, mechanical rooms, will all be thoroughly checked for proper storage and disposal of hazardous chemicals, used fluorescent bulbs and non-alkaline batteries, old computers and obsolete electronic equipment. In addition to their proper disposal/recycling, above items found to be no longer in use and improperly stored/abandoned, will be considered to be unmanaged hazardous waste. The inference is that these unmanaged items will eventually be improperly disposed.
Problem is, they don't tell you specifically, only in general, what would be considered hazardous and if the find a violation, evidently they hit you with huge fines. quote:
violations incurred from audit citations can amount to tens of thousands of dollars, with daily penalties for such citations amounting to twenty-seven thousand dollars per day, per violation, until the cited condition is corrected. Clearly, violations of environmental policy could have dire financial consequences to our institution.
This is from the president himself.
Needless to say, I am quite worried about all the film I have in a storage room off the projection booth. Has anyone had such an audit? To my knowledge safety film is not considered in any way hazardous, is it? It would be nice if someone could tell me BEFORE the audit. Does it need to be handled in any particular way? I mean, I just have it stitting on metal shelves. Would the volume of film be in some way be restricted (say more than x amount of footage and it's a violation like they used to have for nitrate?). I certainly don't want to incur fines for the college -- this would be serious stuff. Things could get pretty dicey if anything in my area were a violation. Film is the bastard child here to begin with and any misstep could have dire consequences for me personally, especially if it comes down to something silly like having the wrong cap on the adhesive remover bottle or because I don't have my "sharps" (razor blades in EPA-speak) in plastic, puncture proof containers (I have them stuck under the name plate of the Newmade 35SS splicer like me and every other film tech guy has done for eons. So now all of a sudden it could cost me thousands of dollars if an inspector sees my blades? This REALLY sucks.
If they would go around and tell you what things would incur a violation so that you could correct it, that would be one thing; but it seems they think ordinary workers are going to know ever regulation that the EPA has generated and will be able to correct them before the audit. Anyone know if there even an EPA book of regs that one could study? It's a compliance audit, but they don't tell you what you are supposed to comply with until they get there and tell you you're knee deep in it.
Anyway, if there is anyone out there who has had an EPA Compliance Audit and knows what to expect, I sure would be grateful for any info you could give me as a heads up here.
Thanks in advance.
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Mitchell Dvoskin
Phenomenal Film Handler
Posts: 1869
From: West Milford, NJ, USA
Registered: Jan 2001
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posted 02-11-2005 08:04 AM
I wouldn't worry about safety film laying around.
The EPA is not the Occupational Health Safety Agency, electrical or fire inspectors, etc. The EPA is concerned with hazardous substances. I would REMOVE any liquids (film cleaners, film cement, etc), so that no question comes up about container labeling, and make sure there are no trace of any oil leaks from the projectors. Oil is a hazardous substance (according to the EPA), so having any pans or tins under the projector to catch oil, or even worse, dark spots on the floor, would open the can of worms of how is it being stored, disposed of, etc.
Also make sure you don't have any exposed asbestos anywhere! Lamphouse, holes in the walls, rectifiers, exaust vents, etc...
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Pete Lawrence
Expert Film Handler
Posts: 192
From: Middleburg, PA
Registered: Aug 1999
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posted 02-11-2005 10:04 AM
I haven't had any direct experience with the EPA but I think your getting to worked up about this.
As Mitch said, the EPA isn't OSHA or the fire inspector. They are looking for things that might be disposed of improperly and find their way into the environment. Air conditioners contain Freon, old electronic equipment contains lead, florescents contain mercury, computer CRTs contain a lot of lead in the glass and solder, and so on. Xenons contain Tungsten and possibly something slightly radioactive like thorium which helps ignition. They might get interested in those, but if they are valuable emergency spares, well. Just have a good answer on how you dispose of the bad ones. Recycling the electrodes to a scrap dealer is one way. Ozone free xenons might also be a plus here.
If the film is projected once in a while it's not being disposed of. It's a valuable asset and (I assume) properly cared for.
They will get interested in anything that will eventually evaporate into the atmosphere. Keep any chemicals to a minimum and have the MSDS documents handy. This especially includes anything backstage like opened paints, thinners, cleaners and such. Those are likely to be in larger quantities than anything you have in the booth.
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John Pytlak
Film God
Posts: 9987
From: Rochester, NY 14650-1922
Registered: Jan 2000
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posted 02-11-2005 10:35 AM
Here's a link to MSDS information for any Kodak product containing chemicals (e.g., Kodak Professional Film Cement, processing solutions):
http://www.kodak.com/go/msds
quote:
Material Safety Data Sheets for chemical products and Article Information Sheets, for items such as film, paper, and equipment, contain country specific regulatory information.
Here is a link to the Kodak "People and Planet" site with environmental information:
http://www.kodak.com/US/en/motion/hse/index.jhtml?id=0.1.4.5&lc=en
And Kodak's Health, Safety and Environment Information:
http://www.kodak.com/US/en/corp/environment/index.jhtml?pq-path=2/8/2879/3650
quote:
Health, Safety and Environment
Health, safety and environmental responsibility is fundamental to Kodak Values. As a world-class company and the world leader in imaging, our vision is to make measurable improvements in the health, safety and environmental aspects of our products, services, and operations. . .every day, every month. . every year.
Here is a publication about film flammability:
http://www.kodak.com/global/en/professional/support/techPubs/cis37/cis37.jhtml
And Nitrate Film:
http://www.kodak.com/global/en/corp/environment/kes/pubs/pdfs/H182.pdf
And disposal of film ("Is film a regulated waste?"):
http://www.kodak.com/US/en/motion/hse/waste.jhtml?id=0.1.4.5.18.6&lc=en
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John Pytlak
Film God
Posts: 9987
From: Rochester, NY 14650-1922
Registered: Jan 2000
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posted 02-18-2005 01:28 PM
quote: Frank Angel
How DO you dispose of junk film?
http://fpchollywood.com/fscsalvage.html
quote:
Since the 1950’s, the Film Salvage Company (FSC) has provided anti-piracy support to the motion picture film industry through the secured destruction and environmental disposal of used motion picture film.
Approximately 20 million pounds of film are destroyed and recycled annually, and in March of 2000, FSC was recognized by the Academy of Motion Picture Arts and Sciences for its recycling program.
FSC is a division of FPC, Inc., which happens to be a subsidiary of the Eastman Kodak Motion Picture Group. We are located in Hollywood, California; Mountain City, Tennessee; and Milan, Italy.
http://www.kodak.com/global/en/corp/environment/kes/pubs/pdfs/KES60ENG.pdf
quote:
SCRAP FILM BUYERS
This list has been compiled from various sources. Inclusion on this list does not imply endorsement or recommendation by
Eastman Kodak Company.
http://www.kodak.com/US/en/motion/hse/recycleInCam1-02.jhtml?id=0.1.4.5.18.4&lc=en
quote:
We designed an initiative for independent producers to recycle film prints and other unneeded film stock in the United States...We installed film collection barrels in our Hollywood and New York offices. These barrels provide a straightforward way for independent and student producers to dispose of unneeded film and motion picture accessories (cans, cores, reels, spools, etc.) responsibly. All our customers have to do is bring along any used stock they wish to discard when they come to purchase new film.
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