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Industries in this sector specialize in manufacturing products made by processing plastics materials and raw rubber. Plastics and rubber are combined in the same subsector because plastics are increasingly being used as a substitute for rubber; however the subsector is generally restricted to the production of products made of just one material, either solely plastics or rubber.
Many manufacturing activities use plastics or rubber, such as in the manufacture of footwear or furniture. Typically, the production process of these products involves more than one material. In these cases, technologies that allow disparate materials to be formed and combined are of central importance in describing the manufacturing activity. In classifying industry segments, footwear and furniture manufacturing activities are not classified in the Plastics and Rubber Products Manufacturing subsector because the core technologies for these activities are diverse and involve multiple materials.
The Bureau of Labor Statistics reported that as of July 2008, there were about 14,000 establishments in private industry, employing nearly 800,000 people. And, according to the Society of the Plastics Industry (SPI), the plastics industry is one of the largest manufacturing industries in the U.S., accounting for more than $379 billion dollars in annual shipments.
Plastics play an indispensable role in a wide variety of markets, including:
- Packaging;
- Building and construction;
- Transportation and aerospace industries;
- Consumer and institutional products;
- Furniture and furnishings;
- Electrical and electronic components; and
- Adhesives, inks, and coatings.
Industry hazards
Injuries resulting from inadequate machine guarding are of concern due to their potential severity. Plastics processing machines are complex pieces of equipment that require guards to protect employees from nip points, numerous moving parts, exposure to high voltage, and exposure to high temperature. Serious injuries including fatalities, amputations, avulsions, burns, cuts, and bruises can occur during operation. Such injuries may result from guards that are missing, improperly installed, removed, or bypassed.
OSHA standards most commonly cited for this industry include:
- Lockout/tagout
- General machine guarding
- Electrical
- Powered industrial trucks
- Hazard communication
- Mechanical power-transmission apparatus
- Respiratory protection
- Abrasive wheel machinery
- Guarding floor and wall openings and holes
Environmental concerns
The environmental issues directly addressed for rubber products manufacturing are recycling mandates, air emissions, and hazardous waste disposal. Recycling requirements exist at the state and local level for plastics products. Based on their pollutant outputs, both plastics and rubber products manufacturing processes have the potential to be regulated under the CAA, the CWA, and RCRA.
Air
At rubber and plastics products manufacturing facilities, air emissions from both process and combustion units are regulated under the NAAQS and the State Implementation Plans (SIP) that enforce the standards. States may implement controls to limit emissions of PM, NOx, VOC, and SO2.
Although many limits are implemented at the state level, there are national guidelines that serve as a basis for more specific limits. Sources that are considered "major" under the CAA are subject to prevention of significant deterioration (PSD) or new source review (NSR). Both PSD and NSR are permit programs for facilities that were constructed or modified after a certain date.
In addition to the PSD/NSR preconstruction obligations, there are process-specific operational standards, New Source Performance Standards (NSPS). 40 CFR Part 60 lists these standards, several of which directly regulate the plastics and rubber industry.
- Subparts D, Db, Dc Industrial Boilers
- Subpart GG Gas-Fired Turbines
- Subpart Kb Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels)
- Subpart BBB Rubber and Tire Manufacturing Industry
- Subpart TTT Industrial Surface Coating: Surface Coating of Plastic Parts for Business Machines
- Subpart VVV Polymeric Coating of Supporting Substrates
Air toxics regulations apply to rubber and plastics products manufacturing industries. EPA has developed National Emission Standards for Hazardous Air Pollutants (NESHAPs) expressly for several processes in these industries. The following NESHAPs are particularly relevant to the plastics and rubber industry:
- 40 CFR 61 Subpart M Controlling asbestos emissions from demolition or renovation activities.
- 40 CFR 63 Subpart H Controlling HAP emissions from equipment leaks, "Leak Detection and Repair."
- 40 CFR 63 Subpart Q Controlling chromium emissions from cooling towers.
- 40 CFR 63 Subpart III Controlling HAP emissions from facilities that make flexible polyurethane foam products, targeting methylene chloride in particular.
- 40 CFR 63 Subpart MMMM Controlling HAP emissions from facilities that coat miscellaneous metal parts and products.
- 40 CFR 63 Subpart PPPP Controlling HAP emissions from facilities that coat plastic parts and products.
- 40 CFR 63 Subpart WWWW Controlling HAP emissions from facilities that make reinforced plastic composites products, targeting styrene in particular.
- 40 CFR 63 Subpart XXXX Controlling HAP emissions from all rubber tire manufacturing industry facilities that make rubber tire products.
- 40 CFR 63 Subpart MMMMM Controlling HAP emissions from facilities that cut, glue, and/or laminate pieces of flexible polyurethane foam.
Some NESHAPS, such as 40 CFR 63 Subpart J Polyvinyl Chloride and Copolymers Production and 40 CFR 63 Subpart U Group 1 Polymers and Resins Production, apply to facilities that manufacture the plastic resins used by the plastics and rubber industry. Since these facilities are sometimes co-located with facilities in the plastics and rubber industry, these regulations may also apply.
Many large plastics and rubber manufacturing facilities are subject to risk management requirements and are required to have a Title V air permit.
Facilities operating industrial process refrigeration units, such as chillers for chlorine dioxide plants, utilizing ozone-depleting chemicals, such as CFCs, are required to follow leak repair requirements under ozone protection regulations.
Water
There are two industry-specific components of the CWA requirements: NPDES permitting and pretreatment programs. Other general CWA requirements, such as those for wetlands and stormwater, may also apply to rubber and plastics products manufacturing facilities.
In addition to applicable general CWA requirements, rubber product manufacturers are subject to the specific requirements contained in 40 CFR Part 428, "EPA Effluent Guidelines and Standards for Rubber Manufacturing."
The rubber manufacturing industry is regulated under the storm water permitting requirements because it is covered by SIC code 30.
Plastics products manufacturers are subject to applicable general CWA requirements and to the specific requirements contained in 40 CFR Part 463, "Plastic Molding and Forming Point Source Category Effluent Limitations Guidelines; Pretreatment Standards and New Source Performance Standards."
For facilities that discharge their wastewater to a POTW, pretreatment standards may apply. In addition to general standards established by EPA that address all industries, there are pretreatment standards for new sources and pretreatment standards for existing sources that are specific to the plastics and rubber industry. These standards regulate the biocides trichlorophenol and pentachlorophenol, with limits that are specified for each subcategory of the industry.
EPCRA
Three of the components of EPCRA are directly relevant to the rubber and plastics products manufacturing facilities:
- Emergency Planning. Businesses that produce, use or store "hazardous
substances" must submit:
- MSDSs or the equivalent, and
- Tier I/Tier II annual inventory report forms to the appropriate local emergency planning commission. Those handling "extremely hazardous substances" also are required to submit a one-time notice to the SERC.
- Emergency Notification of Extremely Hazardous Substance Release.
- Release Reporting (Form R reporting).
Hazardous waste
Facilities engaged in rubber product or rubber tire manufacture use RCRA-regulated commercial chemical products which, if spilled or sent for disposal, are considered hazardous waste. These include ethylene thiourea, phenol, guanidines, and some lead, selenium, and cadmium compounds. Because these are all compounding agents that are added to the rubber mixture in their original form, spills are a reasonable possibility and RCRA requirements are likely to apply.
Some waste streams containing solvents such as toluene, MEK, 1 ,1,1-trichloroethane, acetone, methanol, xylene, methyl isobutyl ketone, trichlorofluoromethane, trichloroethylene, and n-butyl alcohol may be hazardous waste if they are D001 ignitable.