Australia

Codes of Practice : Canada : United States : Australia  

Australian Photographic Industry Code of Practice

Table of Contents

top of page

Introduction

Photographic chemicals are used by a broad section of the community to develop film and paper.

• Hospitals, x -ray clinics, vets, dentists, chiropractors and industrial testing laboratories develop x-ray film. 
• One hour minilabs, wholesale photofinishing laboratories, professional laboratories,advertising agencies, schools and technical colleges and most governmentdepartments develop photographic film.
• Newspapers, plate makers, and printers of all kinds develop graphic arts film. 

Clearly, the process of developing a film impacts on the lives of every person in the community many times each year.

The chemicals used to develop film are supplied in small quantities by a handful of suppliers with household names such as Agfa, Fuji and Kodak.

These suppliers have been active over a number of years in developing technology which reduces the environmental impact of their products. Today it requires only 10% of the chemicals used 20 years ago to develop a film. In addition, the types of chemicals have changed to include predominantly inorganic compounds such as ammonia and sulphates, which are common in our environment. In a recent breakthrough, chemicals have been developed for photographic films which are potentially fully recyclable on-site although it will be a few years before equipment manufacturers place products on the market which can take advantage of this development. Longer term, electronic imaging has the potential to replace the film process as we know it, with corresponding elimination of chemicals altogether.

Nevertheless, the photographic industry acknowledges it can do more.

The Photographic Industry Code of Practice has been developed with the sole aim of minimizing the impact of photographic effluent on the environment.

It has been created through co-operation between the photographic industry and sewerage authorities around Australia and signifies a landmark step in showing how industry and government authorities can work together to create policies which place the environment as the number one priority while still allowing industry to prosper.

Companies, associations and sewerage authorities which have either contributed to developing the Photographic Industry Code of Practice or have indicated their acceptance are listed in attachment number 1. Other sewerage authorities are in the process of evaluating their situation. 

top of page

Background

Up until now, the majority of photographic effluent in Australia has been discharged to sewer with little effort by dischargers to reduce waste, and little understanding by sewerage authorities of the impact on their sewerage system, or whether even this is the best method of disposal.

In May 1989 representatives of major suppliers in the photographic industry met to discuss the industry's environmental responsibilities. This led to meetings with major Water Boards and then to the establishment of a working party, which included representatives from the photographic industry, sewerage authorities and the NSW State Pollution Control Commission.

The working party considered two separate approaches for treatment and disposal. One was to pretreat the waste at each individual site, adopting the best available treatment technology and then discharge the residual to sewer. The other was to collect and cart the waste to approved liquid waste disposal and/or treatment sites.

Trials were carried out at selected locations to assess the options and information was collected from groups overseas who had carried out similar studies. Copies of the trial results can be made available on request from PURE. Following detailed assessment, the working party unanimously recommended pretreatment and discharge to sewer as the preferred approach. One of the principle reasons for this recommendation was that the photographic industry is developing technology which will ultimately enable spent photographic solutions to be regenerated and recycled on-site. These solutions cannot be recycled off-site due to oxidation and sulphurisation and the high risk of contamination. The recommendation was further supported by the conclusion that there has been no reported evidence of any environmental problems in sewerage systems, sewage byproducts and receiving waters attributable to the discharge of photographic effluent to sewer.

Cartage, on the other hand, was found to have numerous problems. First, there are occupational safety and health risks associated with employees in the photographic industry, particularly female staff, lifting and moving heavy containers. Storage space is also usually confined and it is generally impractical to set up bunding to contain spillages. Cartage requires movement of wastes through shopping mall type crowds or through hospitals, using 25 litre drums which are relatively fragile. In addition, it is difficult to account for wastes once removed from site. Finally, and probably most importantly, there are no known acceptable disposal options to treat the waste in a more environmentally sound manner at this time.

The Photographic Industry Code of Practice imposes responsibility on both photochemical suppliers and consumers to adopt the best economically available technology to minimize the quantity of waste discharged to sewer. Complete implementation of the Code of Practice across Australia may reduce waste by about 40%. Future revisions of the Code of Practice will reduce waste further, until it is feasible long term goals of zero discharge could be realised.

The Code of Practice is to be fully implemented by a date to be decided at the next meeting of the working party, scheduled for July 1993.

top of page

1. DATA SHEETS

Photographic waste generators will compile and keep updated a data sheet which includes all the technical information required by a Water Board or Council to grant trade waste discharge approval. The data sheet is shown in attachment number 2. 

2. TRADE WASTE DISCHARGE APPROVAL

All photographic waste generators are required to make a trade waste discharge application to the local sewerage authority or to ensure that one has been made on their behalf. The data sheet is to be sent in with the application and is intended to either eliminate the need for applicants to fill out the technical sections of the trade waste application form or, in the case of the Sydney Water Board, assist them to do so. The other sections relating to administrative information will always need to be completed.

Where a trade waste agreement is already held by the generator, an updated data sheet is to be sent in to the local authority with reference to the existing agreement. Where the generator's waste is covered under a trade waste agreement which covers more than one business, an updated data sheet is to be sent to the manager or owner of the property who is responsible for holding the agreement. Where no trade waste policy exists in a particular locality, a letter should be sent to the local sewerage authority, with the data sheet enclosed, requesting permission to discharge and asking for approval in writing.

Waste generators should be aware that trade waste approval is required even if chemical effluent is being removed from site, in order to cover rinse waters and/or sink waste.

Whenever a waste generator changes his processing equipment or types of chemicals, he must submit an updated data sheet with reference to the existing agreement.

3. TYPES OF DISCHARGES

The photographic industry has been divided into six types of discharges, where the effluent is generated from automatic film or paper processors.

1. Waterless minilabs.
2. Water-wash minilabs.
3. Other photographic laboratories, including professional labs and wholesale photofinishing labs.
4. X-ray.
5. Graphic arts.
6. Secondary schools.

Some waste is also generated when films are developed in trays of chemicals, but the volume involved is generally small and is dealt with separately.

The Code of Practice does not necessarily apply to home hobbyists, but, if they choose to do so, should comply with the requirements in Section 5.

Each category will have its own individual waste minimisation and pretreatment requirements, prior to discharging to sewer. The requirements are set out in the following sections. 

top of page

4. REQUIREMENT FOR DISCHARGERS

4.1 Waterless Minilabs

• All silver-bearing wastes, which at the very least include bleach-fix and superstabiliser from paper processors and fixer and superstabiliser from film processors, are to be treated in a silver recovery system. 
• In some localities, the effluent from the silver recovery system must be recombined with all other photographic wastes in a balancing tank/pit with minimum capacity 50 litres, prior to discharge to sewer. The tank/pit can be sited at any suitable location on the property, but must be in a position which is accessible to sewerage authority personnel during business hours. The tank/pit can include any dilution tank, holding tank, or other pit already on the property provided it is downstream of the discharge point and meets the capacity requirement. A list of localities requiring balancing tanks can be obtained from PURE.
• Overflow from the film bleach tank is to be collected for on-site recycling, by the addition of appropriate regeneration chemicals supplied by the chemical manufacturer. Alternatively, a low flow film bleach can be used if it can be demonstrated to yield similar effluent characteristics to the regeneration approach.
• Bleach-fix and film fixer baths are to be tested with approved test strips for pH and silver content at least once per week to identify cases of over replenishment.Chemical supply companies will provide a list of recommended silver contents for comparison. Approved test strips are listed in attachment number 3.
• The lab must convert from bromide-based colour negative photographic paper to chloride-based colour negative photographic paper.

4.2 Water-Wash Minilabs

This category includes any site where at least one processor is water-wash. 

• A wash water limiter or control system is to be used on any water wash processor,so that water is only used when film or paper is being processed and also so that water usage is reduced to the minimum levels sufficient for adequate washing.
• All silver-bearing wastes, which include the bleach-fix from paper processors and the fixer from film processors, are to be treated in a silver recovery system.
• In some localities the effluent from the silver recovery system must be recombined with other photographic wastes in a balancing tank/pit with a minimum capacity of 100 litres prior to discharge to sewer. The tank/pit can be sited at any suitable location on the property, but must be in a position which is accessible to sewerage authority personnel during business hours. The tank/pit can include any dilution tank, or other pit already on the property provided it is downstream of the discharge point and meets the capacity requirements. A list of localities requiring balancing tanks can be obtained from PURE.
• Overflow from the film bleach tank is to be collected for on-site recycling by the addition of appropriate regeneration chemicals supplied by the chemical manufacturer. Alternatively a low flow film bleach can be used if it can be demonstrated to yield similar effluent characteristics to the regeneration approach.
• Bleach-fix and film fixer baths are to be tested with approved test strips for pH and silver content at least once per week to identify cases of over replenishment. Chemical supply companies will provide a list of recommended silver contents for comparison. Approved test strips are listed in attachment number 3.
• The lab must convert from bromide-based colour negative photographic paper to chloride-based colour negative photographic paper.

top of page

4.3 Other Photographic Laboratories

• A wash water limiter or control system is to be used on any water wash processor, so that water is only used when film or paper is being processed and also so that water usage is reduced to the minimum levels sufficient for adequate washing. 
• All silver-bearing wastes, which at the very least include bleach-fix and superstabiliser from paper processors and fixer and superstabiliser from film processors, are to be treated in a silver recovery system.
• In some localities the effluent from the silver recovery system must be recombined with other photographic wastes in a balancing tank/pit which provides one hour detention time for the total waste and with a minimum capacity of 200 litres prior to discharge to sewer. The tank/pit can be sited at any suitable location on the property, but must be in a position which is accessible to sewerage authority personnel during business hours. The tank/pit can include any dilution tank, or other pit already on the property provided it is downstream of the discharge point and meets the capacity requirements. A list of localities requiring balancing tanks can be obtained from PURE.
• Overflow from the film bleach tank is to be collected for recycling by the addition of appropriate regeneration chemicals supplied by the chemical manufacturer.Alternatively a low flow film bleach can be used if it can be demonstrated to yield similar effluent characteristics to the regeneration approach.
• Bleach-fix and film fixer baths are to be tested with approved test strips for pH and silver content at least once per week to identify cases of over replenishment.Chemical supply companies will provide a list of recommended silver contents for comparison. Approved test strips are listed in attachment number 3.
• The lab must convert from bromide-based colour negative photographic paper to chloride-based colour negative photographic paper.

4.4 X-ray

• Fixers should be treated in a silver recovery system. 
• In some localities all effluent must be directed to a balancing tank/pit which provides a minimum 1 hour retention, but with a minimum size of 200 litres for hospitals and specialist x-ray practices, 100 litres for medical centres which include an x-ray service amongst other medical services and 50 litres for dental,veterinarian or other small practices. The tank/pit can include any dilution tank, or other pit already on the property, provided it is downstream of the discharge point and meets the capacity requirement. A list of localities requiring balancing tanks can be obtained from PURE.
• Each fixer bath is to be tested with approved test strips for pH and silver content at least once per week to identify cases of over replenishment. Chemical supply companies will provide a list of recommended silver contents for comparison. Approved test strips are listed in attachment number 3.
• A wash water limiter or control system is to be used on any water wash processor, so that water is only used when film is being processed and also so that water usage is reduced to the minimum levels sufficient for adequate washing.

top of page

4.5 Graphic Arts

• Fixers should be treated in silver recovery system. 
• In some localities all effluent must be directed to a balancing tank/pit which provides a minimum 1 hour detention, but with a minimum size of 200 litres, prior to discharge to sewer. The tank/pit can include any dilution tank, or other pit already on the property, provided it is downstream of the discharge point and meets the capacity requirements. A list of localities requiring balancing tanks can be obtained from PURE. 
• Each fixer bath is to be tested with approved test strips for pH and silver content at least once per week to identify cases of over replenishment. Chemical supply companies will provide a list of recommended silver contents for comparison.Approved test strips are listed in attachment number 3. 
• A wash water limiter or control system is to be used on any water wash processor,so that water is only used when film is being processed and also so that water usage is reduced to the minimum levels sufficient for adequate washing.

4.6 Secondary Schools

• In some localities, all waste must be discharged to sewer via a balancing tank/pit of minimum size 50 litres. The tank/pit can include any dilution tank, or other pit already on the property, provided it is downstream of the discharge point and meets the capacity requirement.

A list of localities requiring balancing tanks can be obtained from PURE.

5. TRAY OR MANUAL DEVELOPING

Where film or paper processing is carried out in trays of chemicals, the silver-bearing chemicals must be passed through a silver recovery system, unless the total quantity of silver averages less than 2 grams per day over a full week. Other chemical wastes can be discharged to sewer either through a balancing tank/pit with minimum size 50 litres or direct to sewer if approved by the local authority. If a tank/pit is to be used, it can include any dilution tank, pit, or other vessel already on the property provided it is downstream of the discharge point and meets the capacity requirement.

top of page

6. OTHER SITUATIONS

Considering the complexity of photographic activities, there will undoubtedly be situations which cannot be adequately covered by any of the categories listed above. In these cases, the waste generator should negotiate directly with his local sewerage authority, seeking the assistance of PURE if necessary. In any such negotiations, the principles used to establish the Code of Practice should be followed - namely that sewerage authorities recognise the need for industry to remain viable, while industry recognises its responsibility to adopt the best known systems for treating its wastes.

7. BALANCING TANK/PIT

The principle purpose of the balancing tank/pit is to provide dilution for spent solutions when there is no dilution from other sources. With this aim in mind, it is clear the balancing tank/pit can be any vessel with sufficient capacity, sited downstream of the discharge, but prior to the sewer connection point. The balancing tank/pit must allow suitable access for sampling.

8. SINK WASTE AND TANK CLEANING

At all existing sites sink waste generated by cleaning activities such as washing racks can continue to be discharged to sewer through the existing plumbing system. However, in any new installations, the sink waste must be connected to the balancing tank/pit, in localities where a balancing tank is required by the local authority.

When processor tanks are dumped for cleaning, silver-bearing chemicals must be passed through the silver recovery system. Non-silver bearing chemicals, as well as all tank washings, must be passed through the balancing tank/pit, where a balancing tank is required by the local authority. Acid cleaners must be neutralised by addition of a suitable neutraliser supplied with the cleaner, prior to discharge from the processor. These conditions apply to existing installations as well as new ones.

top of page

9. SILVER RECOVERY SYSTEM

The silver recovery system must reduce the silver concentration in the effluent from the silver recovery system to a maximum of 50 mg/L. If a steel wool ion exchange system is incorporated into the system, then an iron removal system must also be used so that the iron concentration does not increase above the levels existing in the untreated effluent by more than 25 mg/L of iron. Manufacturers and/or distributors of silver recovery systems must provide a warranty that the effluent quality out of their systems meets the limit of 50 mg/L of silver and must specify the operating conditions under which the warranty will apply.

PURE will compile a list of systems for which the manufacturers and/or distributors have provided a warranty. PURE will in turn provide updated copies of these lists to the groups listed in attachment number 1 and any other sewerage authorities who acknowledge the Code of Practice in their territory.

For existing silver recovery systems which are not warranted by the manufacturer and/or distributor, the waste discharger must submit an effluent sample from his system to a NATA registered laboratory for analysis of silver. A copy of the analysis certificate must be attached to the data sheet and submitted with any trade waste discharge applications. Approval for discharge to sewer will only be given if the silver content is less than 50 mg/L.

All silver recovery systems are to be tested every three months by the discharger by collecting and submitting an effluent sample to a NATA registered laboratory for analysis of silver. The sample should be collected from the outlet pipe immediately after the silver recovery system and the sample should be analysed for silver according to specified sewerage authority procedures. Any system which is discharging more than 50 mg/L of silver must be upgraded or replaced.

Results are to be kept on-site, and need only be submitted to sewerage authorities if requested.

10. SILVER AND pH LIMITS

For waterless minilabs, the quantity of silver discharged after silver recovery must be less than 2g/day. For all other types of dischargers, the silver concentration either in the balancing tank/pit prior to dilution with domestic waste, or at the property boundary where a balancing tank is not required, must be less than 5 mg/L.

For all dischargers, the pH at the same point must be in the range 7 to 9.

top of page

11. CHROMIUM-BASED SYSTEMS CLEANERS

Chemical suppliers will stop supplying chromium-based systems cleaners and provide a replacement. If the replacement is acidic, the supplier should also provide an appropriate neutraliser together with suitable instructions for the user. The neutralised mix must pass through the balancing tank/pit, in localities where a balancing tank is required.

12. COPPER PIPES

Discharge to copper drainage pipes is discouraged but permitted, provided the owner of the property acknowledges in writing prior to installation that he is aware of the risks to the drainage system and accepts them. A copy of this letter must be attached to the trade waste application.

Chemical suppliers should provide sufficient information to the owner so that the risks can be assessed.

13. SAMPLING

Each year the working party mentioned in section 2 will randomly select one site in each discharge category for each principle brand of chemicals on the market. For example, if there are five principle chemical suppliers and five discharge categories, then 25 sites will be selected. Sites will be mainly confined to major capital cities.

A one litre grab sample will be collected from the balancing tank/pit at each selected site and submitted within 24 hours to a NATA registered laboratory for analysis of pH, silver, COD, ammonia, thiosulphate, sulphite and sulphate according to specified sewerage authority testing procedure. The results for pH and silver must meet the limits indicated in point 9. The other tests are intended to establish data and to form the basis for possible quality charges. Analysis results will be provided to all major sewerage authorities. The suppliers of the chemicals involved will pay for the cost of analysis.

Random samples may also be collected by sewerage authorities at any time for their own analysis at their cost.

14. LOG BOOK

Each waste generator will be required to keep a log book, which is available for inspection by sewerage authority personnel. At the very least, the log book must include the following information:

1. Method of disposal of wastes, i.e. discharge to sewer, or if wastes are being removed from site, the name and EPA license number of the carter and name and location of the disposal site.
2. Quantity of waste generated.
3. Weekly pH and silver test strip readings on fixer and/or bleach-fix baths.
4. Sample results from testing of silver recovery systems.

In addition, the data sheet referred to in section 1 should be stapled to the front of the log book.

top of page

15. IMPLEMENTATION TIME

The requirements stated above will apply to all new installations. Existing installations will need to meet the requirements by a date decided at the next meeting of the working party scheduled for July 1993, unless the particular discharger can provide good reason acceptable to the local sewerage authority why he is unable to meet the deadline.

16. CARTAGE

Where a discharger is unable to meet the requirements, or chooses not to install the necessary pretreatment facilities, the waste photographic chemicals are to be carted off site by a licensed transporter to a fully licensed and approved liquid waste disposal depot. Both the transporter and the disposal site must be approved by all relevant local authorities. The discharger is to be provided with documentation by the transporter which is appropriate to the local regulatory authority and which shows that the wastes have been disposed of at a licensed depot. In some cases, the local sewerage authority may require copies of documentation to be forwarded to them.

The waste chemicals must also be stored on-site in accordance with the requirements of the local regulatory authority.

17. RESPONSIBILITIES OF PHOTOGRAPHIC CHEMICAL AND EQUIPMENT SUPPLY COMPANIES

Photographic chemical supply companies have the principle obligation for ensuring the photographic industry disposes of its wastes in the most environmentally sound manner. Their role is important in ensuring the Code of Practice is universally adopted for the benefit of the environment. Where they are supplying chemicals to an intermediary stockist or distributor, the chemical supplier must obtain written acknowledgment from the stockist or distributor that they accept the responsibilities outlined below.

From a date to be decided at the next Code review, photographic chemical suppliers, stockists and distributors will notify the relevant local authority of any customer (other than a home hobbyist in hobby-type quantities) who is in breach of environmental regulations by not being able to provide either a copy of a trade waste discharge permit or approval to discharge in writing from the local authority and, where some off-site cartage is involved, a licensed transporter approval number appropriate to the local regulatory authority and associated paper documentation proving the carted wastes were disposed of at a licensed disposal site.

Suppliers will provide to the sewerage authorities listed in attachment number 1, a list of names which are their points of contact in each state on environmental issues. The list is to be revised annually.

For any photographic chemicals already in use, chemical suppliers will provide material safety data sheets to the local sewerage authority if these are requested.

Before new photochemicals are introduced into the market place, suppliers will take and analyse samples to establish data on effluent quality. Samples will be analysed for pH, COD, ammonia, thiosulphate, sulphite and sulphate. The results are to be submitted to the sewerage authorities listed in attachment number 1 within 30 days of the chemicals being introduced, along with the material safety data sheets.

Equipment suppliers will prepare a list of processors currently being sold for submission to the authorities listed in attachment number 1.

Each new piece of processing equipment introduced into Australia which generates photographic trade waste must be approved for use either by the Melbourne Board of Works or the Sydney Water Board. In addition, a separate application needs to be submitted to the Joint Committee of the Department of Housing and Local Government in Queensland, with a copy of the test results from the Melbourne or Sydney tests enclosed. The authorities for their part should provide a list of the standards against which approval is assessed. Following assessment, the authorities will advise what steps must be taken for installation of the equipment. Where assessment takes longer than 30 days, the Board doing the testing should consider providing an interim letter of approval.

top of page

18. AREAS OF PRIMARY TREATMENT

The Code of Practice recognises that on-site waste minimisation and discharge to secondary treatment systems results in the least impact on the environment amongst systems available today. It has not been established, however, whether on-site waste minimisation and discharge to a primary treatment system results in less environmental impact than an option which involves collection of spent chemicals and cartage to a secondary treatment plant.

Until such an impact study is carried out, the guidelines set down in the Code of Practice are not necessarily the best option for primary treatment systems. The photographic industry will ensure that such a study is carried out for consideration in the next review of the Code of Practice as outlined in Section 18.

19. CODE OF PRACTICE REVIEW

The Photographic Industry Code of Practice is due to be reviewed on 1 July 1993 and at that time a date will be nominated for the following review.

Each review is intended to assess the success of the Code of Practice, as well as to consider new technology which can be included for the future. As environmental regulations and technology are both changing rapidly, each review may result in substantial changes, although it will always be an accepted policy to give industry adequate lead time for change.

Other events could also lead to a substantial review of policies: if for example, the code of Practice should have minimal impact due to lack of response by the photographic industry, or if the silver content of sludges produced by sewage treatment plants does not meet the limits necessary for disposal or reuse on a plant specific basis. Even at this stage there are a number of changes planned for inclusion in the next Code of Practice.

1. The silver content in the effluent from the silver recovery system may be reduced, for example, to 30 mg/L (or 2g/day for sewerage authorities which have adopted mass limits) from the end of 1993 and to 10 mg/L from the end of 1995.
    
2. Any new models of film and paper processors and/or any new brands of chemicals which permit recycling or regeneration of spent solutions will be required at all new installations from July 1994. 
3. If the study outlined in section 17 concludes that cartage to a secondary treatment site has less environmental impact than sewer discharge to primary treatment systems then the limits will have to be tightened further to reduce the impact of sewer discharge. These would include likely mass limits on silver of 2 g/day,ammonia of 40g/day, thiosulphate 240 g/day, and sulphite 40 g/day. 
4. Chemicals which are introduced which have substantial benefit to the environment, such as the elimination or reduction of ammonia, will almost certainly be given preference from some nominated date in the future (possibly July 1994).

top of page