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Regulatory News

By Doreen M. Monteleone, Ph.D., director of sustainability & EHS initiatives

RadTech International North America

Attainment Designations Issued, Nonattainment on Hold

The US Environmental Protection Agency (EPA) issued “Round 1” of final area designations under the 2015 ozone standard. The designations became effective January 16, 2018, and include only those counties, tribal areas and territories that EPA has designated “attainment/unclassifiable” – totaling 2,646 counties. The agency also designated three counties in the state of Washington as “unclassifiable.” EPA did not designate any nonattainment areas as part of the final rule, but simply noted that it is “not yet prepared to issue designations” for the remaining areas of the United States. Learn more at www.epa.gov/ozone-designations.

US EPA Releases List of Chemical Substances Reported Under TSCA

On November 22, 2017, the US Environmental Protection Agency (EPA) announced it was releasing a preliminary list of chemical substances reported under the Toxic Substances Control Act (TSCA) Inventory Notification (Active-Inactive) rule that includes substances reported through November 10, 2017, and that it will be updated approximately once per month. EPA is making this list available in a downloadable, searchable spreadsheet to help keep the stakeholder community informed of the reporting status under the TSCA Inventory Notification (Active-Inactive) rule. The list includes a total of 10,730 chemicals. The new list is not an update to the list of interim active substances or to the list of substances exempt from Form A reporting. It is only a list of substances reported via Form A notices of activity through the specified date. Learn more at www.epa.gov/chemicals-under-tsca.

Final Determination Made on Standards for TSCA Reporting and Recordkeeping

On November 30, 2017, the US Environmental Protection Agency (EPA) published a notice in the Federal Register describing the final determination that a revision is warranted to the current size standards for small manufacturers and processes, which are used in connection with reporting regulations under TSCA Section 8(a). See https://www.federalregister.gov/documents/2017/11/30/2017-25822/tsca-reporting-and-recordkeeping-requirements-standards-for-small-manufacturers-and-processors-final for details.

EuPIA Issues Guidance on Ink Migration

The European Printing Ink Association (EuPIA) has issued “Guidance on Migration Test Methods for the Evaluation of Substances in Printing Inks” and “Varnishes for Food Contact Materials” to be used in conjunction with food packaging regulations. The guide helps select appropriate testing methods for the evaluation of the migration of packaging ink components applied to the nonfood contact surface of food packaging materials and articles intended to come into contact with food. Testing methods for the evaluation of direct food contact applications will be dealt with in a separate document. This document should be read in conjunction with other EuPIA documents on printing inks for food packaging, for instance the “Good Manufacturing Practice (GMP)” and “Guidance on the Risk Assessment of NIAS and Non-Listed Substances.” Learn more at www.eupia.org.

US EPA Compliance Assistance Centers

For many businesses, environmental regulations are confusing, as it’s difficult to determine which rules apply and exactly how to be compliant. The US EPA’s Compliance Assistance Centers help many businesses in various sectors remove the mystery from federal and state environmental regulations by providing plain language overviews of the rules, tips on how to comply, best practice solutions that can help the environment while saving money and links to real world contacts and other useful resources. Learn more at http://www.complianceassistance.net/.

Winning in the Marketplace and the Workplace

In its ongoing exploration of the correlation between corporate sustainability programs and employee job satisfaction, the National Environmental Education Foundation (NEEF) convened corporate thought leaders to share best practices and measure the top drivers of sustainability engagement. Among the findings, nearly 90 percent of employees engaged in their company’s sustainability work say that it enhances their job satisfaction and overall feelings about the company. Learn more at www.neefusa.org/.

Going Green = More Green

The National Association of State Procurement Officials (NASPO) provides an online map of all 50 states and indicates which ones have green procurement practices. Click on any state on the Green Map at www.naspo.org/GreenMap to get details of its green procurement program, with contact information provided.




News From the West Coast

By Rita Loof, director of regional environmental affairs

RadTech International North America

Funding for UV/EB Projects

The South Coast Air Quality Management District (SCAQMD) announced plans to solicit proposals for emission reduction projects within its geographic boundaries. Bidders do not have to be headquartered in the SCAQMD. The original proposal was heavily focused on mobile source (vehicles, trucks) projects. RadTech was successful in asking for the inclusion of stationary sources and especially of UV/EB/LED projects. The new language in the Request of Proposals follows: “Formulation or use of applications with lower VOC content (e.g., water-based products, energy-cured materials that do not require afterburners …)”

The RFP also highlighted the environmental benefits of UV/EB/LED operations, stating: “New businesses can be incentivized to install and operate zero-emission equipment, control equipment, technology and processes beyond the current BACT requirements. One example is the use of energy-curing technologies, including ultraviolet light (UV), electron beam (EB), heat and light emitting diode (LED) cured coatings.” Proposals are due April 11, 2018. Contact rita@radtech.org for additional information.

Stricter Requirements for Hexavalent Chromium

Complaints from residents of Paramount, California, regarding potential exposure to hexavalent chromium brought about an investigation by the SCAQMD which, in addition to conducting air monitoring, “dispatched a large team of inspectors” to conduct a business-by-business search for potential sources of chromium emissions, focusing on a variety of metal-processing industries in the area where high levels were monitored.

Based on its findings, the agency has proposed to amend Rule 1469 – Hexavalent Chromium Emissions from Chromium Electroplating and Chromic Acid Anodizing. Proposed Amended Rule (PAR) 1469 offers new requirements for hexavalent chromium-containing tanks, such as dichromate seal tanks, that currently are not regulated. The rule proposal establishes emission limits for hard and decorative electroplating and chromic acid anodizing based on throughputs and proximity to sensitive receptors; requires ongoing monitoring; and adds initial performance testing of add-on control devices, housekeeping, reporting and record-keeping requirements.

SCAQMD staff has identified 117 facilities that either conduct decorative or hard chromium electroplating or chromic acid anodizing operations within SCAQMD’s jurisdiction. Automotive, computer/electronics, machinery/industrial equipment and defense/government are the four largest segments of industry served by all electroplaters and anodizers. In addition, fasteners are a large industry segment for job shops.

Proposed requirements include triggered provisions for permanent total enclosures vented to air pollution controls based on noncompliance, with specific source testing or monitoring requirements. PAR 1469 also revises existing requirements to reduce surface tension limits and prohibit the use of chemical fume suppressants that contain perfluorooctane sulfonic acid. At the most recent public workshop, staff announced the intent to prohibit fume suppressants altogether. Industry representatives expressed concern that the proposal will be a financial hardship and that the district has not provided sufficient data to show that actual emissions will occur.

Facilities that plan to reformulate their processes to eliminate chrome from their operations emissions will not be required to install an add-on air pollution control device. In order to qualify for this exemption, facilities must submit a plan that includes the method by which the hexavalent chromium concentration will be eliminated or reduced and expected completion date; a list of milestones necessary to occur, including their projected dates; and a list of all control measures that will be implemented until the concentration is eliminated or reduced. Facilities also must submit a monthly progress report and any revisions to the original plan. Implementation of the plan must be completed within two years of approval of the Hexavalent Chromium Phase-Out Plan.

RadTech submitted formal written comments urging the district to provide incentives to companies that choose to reformulate their processes and eliminate emissions of hexavalent chromium. PAR 1469 was originally scheduled to be adopted at a Public Hearing before the SCAQMD Governing Board on February 2, 2018. The agency recently announced postponement of the adoption hearing until April 2018.