Concern for the quality of air created by industrial plants has been with us since the late 1970s. Federal, state and some local regulations have been in place for these many years, supported and enforced through the need to have permits to operate. With the start of 2010, at both the federal and state levels efforts are in progress to make these requirements more stringent. While the media has publicized this effort by the U.S. Environmental Protection Agency, steps being taken by state governments are less heralded.
It is essential to have a proper permit or certification for a printing facility to operate. It is even more critical, once permitted, that the facility be in compliance with the emission standards established as acceptable, utilizing the approved safer technologies or add-on control systems. A mandatory requirement for all printers is the need to have adequate documentation of the volume of inks, coating and solvents used with their Volatile Organic Compound (VOC) content. Compliance is based on the percentage or quantity of VOC delivered to the substrate and exhausted, as well as the amount over a 12 month period.
In New York State, of great concern in these efforts is compliance with Parts 201 and 234, the regulations governing printing establishments. Currently under review with comments to be submitted by industry and the public by Feb. 17th is a major revision of Parts 201 and 234 that will lower the threshold of applicability, the standards for acceptable emissions and the inclusion of a broader number of printing processes.
The proposed amendments to part 201 will revise the criteria for a graphic arts process to obtain an exemption. In order to qualify for an exemption, the facility must be located outside of a sever ozone non-attainment area and have facility wide VOC emission of less than three tons per year, on a 12 month rolling basis. The lower threshold of three tons will bring many printing facilities into the regulated arena. Printers who did not need permits or registrations will now come under the umbrella of Parts 201 and 234.
Letterpress operations are currently listed as a trivial activity and exempted from the regulation. This exemption will end. Added to the list of exemptions will be “Proof Press Operations.” In Part 234 there are additional exemptions based on the nature of the process and end product as well as the inks and fountain solutions used. It is imperative that all printers consult the new regulations when published to assure the status of their processes and determine whether they are now subject to compliance with the directives from the state.
Don’t wait for a knock on the door by a state inspector. That could cost you a considerable amount of penalty dollars. Take the bull by the horn and obtain the permit documents on line at the NYSDEC Web site or contact the NYS Environmental Facilities Corp.
Small business will benefit from provisions that lessen the load, although not the need to be more conscious of the environment and health issues in selecting ink systems and cleaning solvents. Facilities with three tons per year or more of annual VOC process emissions will be required to obtain a permit (air registration) and maintain records. Added to the list of permitted operations will be letterpress equipment. More stringent control requirements have been placed on flexographic, offset lithographic and rotogravure printing, as well as the coating, adhesives and cleaning solutions for all processes. There are a number of very specific conditions that provide for exemptions spelled out in the revised regulation.
The small business will also benefit from not needing the services of professionals to comply with the regulations. In many cases, compliant products are available from suppliers to the industry. When assistance is needed in filing for permits and other regulatory assistance, such services can be obtained from the New York State Environmental Facilities Corporation in Albany under the state’s Small Business Assistance Program (800-780-7227). The savings can be quite considerable.
Facilities that emit more than three tons per year must examine their performance to date. Add-on control emission destruction rates will be higher. Use of solvents, fountain solutions and cleaning agents will necessitate the use of chemicals with lower VOC content. Processes that were exempt may no longer be in that category. Records are mandatory. Purchase and use spreadsheets can be most helpful in keeping track of the chemicals and volatiles in the process. Twelve month records will be needed to confirm performance with the regulatory standards.
It is incumbent on the printer to be knowledgeable about the requirement set forth by the regulations for his or her particular operation. Don’t wait for a knock on the door by a state inspector. That could cost you a considerable amount of penalty dollars. Take the bull by the horn and obtain the permit documents on line at the NYSDEC Web site or contact the NYS Environmental Facilities Corp. If you are in other states, contact the Small Business Ombudsman for guidance. Don’t get caught short; it hurts.
Fred Shapiro is president of P-F Consultants, Silver Spring, Md., a technical and environmental management consulting firm to the graphics arts industry. Contact him at (301) 598-7949.