COMPLIANCE SECTION

Printing and Publishing Industry:
HAP and VOC Emission Rules Around the Corner

The U.S. EPA has proposed and/or promulgated several rules that impact the printing and publishing industry. These rules center around the control and/or reduction of volatile organic compound (VOC) and hazardous air pollutant (HAP) emissions. Ensuring compliance with these rules may require facilities to adjust current work practices, coordinate with suppliers, and/or install control equipment.

OVERVIEW
There are three major emission rules, one promulgated, two proposed, which impact the printing and publishing industry. These rules would be added to any standard requirements that apply to all facilities regardless of activity, such as Title V, FESOP, and minor source permitting concerns. The three rules are:

1. Printing and Publishing NESHAP Rule--Promulgated 5/31/96 - The Printing and Publishing NESHAP Rule was promulgated as a final rule in May 1996 and is found in 40 CFR Part 63 Subpart KK. The rule impacts major sources within the wide-web flexographic and rotogravure industries. The rules require a reduction in HAP emissions through use of substitute products, capture and control methods, or a combination of these methods. The U.S. EPA Office of Air and Radiation Emissions Standards Division made a decision before the rule was proposed to not specifically include lithography in this rule. However, there are some facilities in which a piece of equipment may have both lithographic and wide web flexographic functions. In this case, the rule would be applicable. The U.S. EPA is working to better define the applicability of this rule to industries that closely resemble flexography, such as using a foam roller for adhesive application in making envelopes. The compliance date for this rule was May 1999.
   
   
2. Paper and Other Web Coating NESHAP rule--Not Yet Proposed - According to Mr. Dan Brown of the U.S. EPA, this rule will regulate HAP emissions from web coating lines. The proposed rule is scheduled to be published in June 2000. The rule would require facilities that use solvent-based coatings to achieve a 95% control efficiency. If pollution prevention type coatings are used, the limit would be 0.2 kg HAPs per kg of solids applied or 0.04% HAPs by weight. Based on the proposed rule publication date, the rule will probably go final in June 2001. The U.S. EPA plans to give the industry three years to comply.
   
   
3. Offset Lithographic Printing National VOC Rule--Final Action Scheduled for March 2001 - This rule will deal with lithographic printing materials, specifically with VOCs (not HAPs) as per Section 183 (e). The rule is expected to affect suppliers of materials as opposed to the users. According to Mr. David Salman of the U.S. EPA, the deadline for a final action is March 2001. The U.S. EPA may approach this rule in one of two ways. The Agency may produce a national VOC rule, or a guidance document. If the U.S. EPA decides to promulgate a rule, as opposed to producing another guidance document (two already exist), the rules will focus on suppliers such as manufacturers of inks, blanket wash, etc. Some possible items that may be included in the rule or guidance document are a recommendation/requirement to use alcohol substitutes and low vapor pressure cleaning solvents. Many states, such as Tennessee, have already developed VOC rules for lithography in nonattainment areas.
   

SUMMARY
The U.S. EPA has proposed and/or promulgated several rules relating to HAPs and VOCs that affect the printing industry. Ensuring that management has the equipment, manpower, and information to address these rules after promulgation is essential to uninterrupted operations and continued compliance. If you are unsure of the rules that may, or do, apply to your facility, or would like more information, or desire assistance in developing compliance strategies, please contact Emily Covert or Tony Domanico at 513-489-2255 or toll free at 800-229-1443, or via e-mail at eac@paynefirm.com or aid@paynefirm.com.