Film-Tech Forum ARCHIVE: EPA & Film Storage Question

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Posted by Frank Angel (Member # 248) on 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.

Posted by Mitchell Dvoskin (Member # 751) on 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...

Posted by Scott Manley (Member # 867) on 02-11-2005, 09:00 AM:

I would suggest that any chemicals that you have to have on hand you should have a MSDS reports for any of the chemicals.

Posted by Pete Lawrence (Member # 130) on 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.

Posted by Marc Hansen (Member # 705) on 02-11-2005, 10:09 AM:

I've been through it many times. There really is no book, the "experts" that come out pretty much base it on their own education and experience. First, remember that nothing is waste until it has no further use. If it has no use get rid of it now.If it's there be prepared to explain why it is still in use.Get MSDS's on everything. Getting one for the film (any brand, they won't unroll it to check) should solve that problem, besides it's not waste, it could still be projected. Get a large dishpan or something similar and keep your chemical bottles sitting in that. They call that secondary containment, if the bottle leeks it still doesn't go anywhere. Also clean house, the cleaner it is the happier they are. Since it is your first visit it is unlikely they will wright anything up unless it is really bad.I've been dealing with them for 20 years as a hazardous waste generator and it really is not that bad.

Posted by John Pytlak (Member # 331) on 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

Posted by Frank Angel (Member # 248) on 02-11-2005, 01:39 PM:

That's quite a relief guys, thanks. It's just that the president sent word down to a vice-pres who sent word down to a provost who sent work down to my boss and my boss read the riot act to me, so naturally it's a major concern to every department. But all the above is great advice and I will methodically go thru the entire area and take care of business. I am assuming things like Film-Guard and VitaFilm, if they have their original, proper labels, would be fine, correct? I believe Brad sent the MSDS with F-G; I'll have to check ECCO 1500. Vitafilm and FilmRenew.

Well, at least I've got till April to get the house in order. Talk about a major spring cleaning!

Thanks guys.

Posted by Brad Miller (Member # 2) on 02-11-2005, 01:48 PM:

If you don't have it, just email me and I'll send you one.

(FilmRenew doesn't have an MSDS available, I've tried to obtain one before.)

Posted by Randy Stankey (Member # 64) on 02-11-2005, 01:55 PM:

When people ask me I just tell them that MODERN film is made out of polyester PLASTIC. The same thing they make plastic Coke bottles out of.

While that statement doesn't tell the whole story, it gets the point across that film isn't the dangerous inflammable substance that it was many years ago.

I stress the words "MODERN" and "PLASTIC". That gets across the point that film isn't what it used to be and that film isn't much different than any other plastic material people deal with every day.

Posted by Pete Lawrence (Member # 130) on 02-11-2005, 02:28 PM:

quote: Brad Miller
FilmRenew doesn't have an MSDS available, I've tried to obtain one before.

Last time I bought some Filmrenew I asked Larry for the MSDS. It was included in the package. That was some two years ago.

Posted by Brad Miller (Member # 2) on 02-11-2005, 03:03 PM:

I guess he finally got around to having one made then. He was quite angry at the idea of providing an MSDS before for fear it would disclose the composition, which MSDS sheets do not do.

Posted by Frank Angel (Member # 248) on 02-18-2005, 05:43 AM:

Since teh film that we run still has quantities of silver in it, I am wondering if the EPA will require that we show we are disposing of it as an environmental hazard, and thus needs special handling and can't be thrown out in what they call, "Universal Refuse" (or some such). Do I need a special trashcan marked Motion Picture Film?

From what I've gathered so far, they are happy if you just mark everything so that hazardous stuff won't be mistaken as regular garbage and throw out into the environment. If you mark old computers as "SPARE -- DO NOT DISCARD" they will be fine with that....but the same computer sitting unmarked in a corner on the floor will get a violation because some cleaner might come by and think it's junk and toss it into regular garbage.

How DO you dispose of junk film?

Posted by Mark Gulbrandsen (Member # 72) on 02-18-2005, 07:28 AM:

quote: Frank Angel
How DO you dispose of junk film?

Just tell em that you send it back to John Pytlak [Wink]

!

Mark

Posted by Mitchell Dvoskin (Member # 751) on 02-18-2005, 08:44 AM:

Film, and silver, is not a hazardous item. The process that at one time was used to reclaim the silver from old motion picture film used many extremely hazardous chemicals, which is where your confusion is coming from. It's a case where recycling caused more environmental harm than just throwing it out, but the value of the silver made it worth doing prior to modern EPA regulations.

Posted by John Pytlak (Member # 331) on 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.

Posted by Dean Kollet (Member # 1789) on 02-18-2005, 06:50 PM:

I wouldn't worry too much Frank, but careful...they shut down the Ghostbusters and all hell broke loose in Manhattan

Posted by Dominic Case (Member # 1830) on 02-21-2005, 08:55 PM:

[QUOTE] Film, and silver, is not a hazardous item. The process that at one time was used to reclaim the silver from old motion picture film used many extremely hazardous chemicals, which is where your confusion is coming from. /QUOTE]
The only silver in colour film is in the soundtrack (of course you won't need to worry about cyan tracks). As long as it remains in the soundtrack and you aren't planning to dump the film, there is no environmental hazard (any more than there is in wearing silver jewellery). But the silver itself is counted as a hazard if it goes down the drain or is dumped as landfill.

Posted by Alexander Smith (Member # 1769) on 02-22-2005, 12:21 PM:

Reference John Pytlak's post about re-cycling junk film:

Are there any organisations in the UK who accept waste
film? From heads/feet of trailers and e.t.c.

Ideally, I'd just like to be able to send them a box of
old film on an irregular basis.

Alex.

Posted by Carl Martin (Member # 1146) on 02-22-2005, 04:41 PM:

the best way to recycle trailer heads/tails is to stick them back on the trailers whence they came when you're done running them. then if you save the trailer it's protected and if you toss the trailer, well, you're back to your original question.

carl

Posted by Alexander Smith (Member # 1769) on 02-25-2005, 03:31 PM:

If there were even the smallest chance a trailer might
be re-used we would. The vast majority of trailers we
show seem to have an indication of when the film being
advertised is released ("Coming March 2005" as an example).

Once America, Canada, the UK and Australia have had the
film released, there are not many English-speaking
territories left where the trailer might be re-used.

Alex.

Posted by Mitchell Dvoskin (Member # 751) on 04-27-2005, 02:39 PM:

Well, what happened. Is your booth a new Superfund Cleanup site?

[Smile]

Posted by Monte L Fullmer (Member # 2797) on 04-28-2005, 03:40 AM:

..yea-send your old trailers back in the cans, especially since most cans have that empty space where a reel should be (unless you hit a can with one of those "reel filler doo-dads" from TECH, even then, plop a few around that "reel"..), and let the depots take care of them.

-Monte

Posted by John Pytlak (Member # 331) on 04-28-2005, 11:07 AM:

Kodak FPC Film Salvage recycles billions of feet of old film annually:

http://www.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/US/en/motion/hse/recycleInCam1-02.jhtml?id=0.1.4.5.18.4&lc=en

quote:
Through our subsidiary, FPC, we also help distributors and major studios manage film waste. FPC recycles 18 million pounds of used film prints worldwide into new materials each year. This is a win-win situation: the environment benefits as materials are diverted from landfills and our industry benefits as the risk of piracy is reduced.

This has been a fabulously successful program, but now we have taken it a step further. We designed an initiative for independent producers to recycle film prints and other unneeded film stock in the United States. This past summer, 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.

Posted by Frank Angel (Member # 248) on 04-29-2005, 05:09 AM:

We passed our EPA inspection with only a single violation that were some old paint in a locked closet that we never use. We were as surprised as the inspectors were. They only gave a minimum nominal fine and warning. They didn't seem to even blink at all the film in our archive room. So I conclude that film is safe. Used flourscent light tubes, on the other hand, gives them a kinipshin fit.

Posted by John Pytlak (Member # 331) on 04-29-2005, 05:39 AM:

Used fluorescent tubes may contain small amounts of mercury, and must be disposed of properly.

Posted by Steve Guttag (Member # 268) on 04-29-2005, 09:49 AM:

Yeah, bury them! Or, if you have a good high-pressure air supply, make a "rocket launcher" and shoot the tubes for fun and excitement. Then again, there is always xenon lamp juggling!