Waste Ink Management - SQF

Hello all,

We are in the early stages of creating a food safety management system, pursuing SQF Certification. We have a flexo printer and we currently manage the waste ourselves. The ink waste passes into a storage tank, then into a treatment tank, then flows out into a dumpster to "set up". At this stage it is exposed. 

Currently, our waste ink system is located inside the processing area, 15 feet from where raw materials (unused ink, master rolls) are stored during the production process. 

My question is, do we need to move this entire process out of the production area? Please share thoughts, experience, and clarifications. 

Justin

You are SQF packaging correct, not food processing?

So sorry, meant to include that bit. Yes, we're working with modules 2 and 13 for food packaging manufacturers.

Is the waste visually distinct from new?  What would happen if the waste ink spilled or was used?

Scampi - Yes, it's visually distinct. After treatment and a couple of hours of being filtered, all that's left is a muddy looking residue that is then hauled to the dumpster. I would say there is no practical way for it to be re-used as it is pumped straight from the printer into the waste tank, which is sealed. 

SQF Consultant - It is exposed to the air on a grated conveyor covered in filter paper. After the excess liquid ink waste drains (filter paper and treatment chemicals render it fit for return to city water system; keep in mind a lot of water ends up in the waste tank as well), it is conveyed into the dumpster. I would say, without deep analysis this waste would most likely be considered a hazard if it came in contact with the food grade packaging materials. However, the likelihood of this occurring is not high.  

Don't change a thing. It sounds like the risks are very low in your facility 

Thanks Justin - I'd follow the suggestion by Scampi as to low risk - however since I am rather anal retentive, I'd still run a documented risk analysis on have that on file in case.

Thanks for all of the help! We will follow these suggestions. 

Ink is not regulated by the FDA.  Thus it is not approved as a food contact material.

I don't know how clean the water is that you are removing from the ink.  It may be clean enough for the city sewer system but this doesn't mean it would be clean enough to touch a food contact surface (packaging and machines).

So my opinion is that the waste ink and the water that is removed would be hazard it it got onto the food contact surface of your packaging products on machine parts that touch the food contact surface of your packaging.

Therefore I suggest that your risk analysis deal with the severity and probability of a spill that would contaminate your machines and/or your products and what control programs you would have in place to clean machines and sort through contaminated product.

A couple of things: (It sounds like a Heidelberg)

• While the city deems the waste water safe to return to the treatment plant, our town plant is small and we learned on the first day that water with a high pigment content after treatment in- house flooded the plant and colored it all blue. We now have a secondary dilution process to reduce that risk.
• How much is the waste exposed after it leaves the print process? If there is very little exposure your risk analysis should state that. If it is in close proximity to the press, maybe consider a screen or moveable, self standing wall partition. That should reduce the risk to almost nothing. I'm all about simple, quick fixes that satisfy the code.

We were fortunate to have all chillers, electronics and water removal on the other side of a wall next to our press.

Hoosiersmoker - 

Thanks for the reply. I've only ever seen a litho Heidelberg; neat to know they make flexos. We're in a pretty big city, and had a couple of bumps in the road about 15 years ago, but have since been approved by the city with our current practices. 

The waste is around 15 feet from the press, and is exposed for a couple of hours while the water runs off it and it becomes the clumpy, muddy material I mentioned previously. I think that's good advice about the partition. I will be suggesting it in our next task team meeting.