SGIA responded to the request from the NY State Department of Environmental Conservation (DEC) for comments on their proposed cleaning solvent rule. The rule would set VOC and/or vapor pressure limits on a variety of cleaning solvents used by business and industry that are not otherwise regulated. The DEC has established cleaning solvent VOC and vapor pressure limits for all other printing processes in its regulation found at Part 234, Graphic Arts.
Since Part 234 does specifically include or exempt digital printing technology, it would be subject to the limits established under the proposed regulation. SGIA’s comments specifically requested that cleaning solvents used on digital output devices be excluded from the requirements. The primary reason for requesting the exemption is because the EPA guidance that the rule is based on did not study the technical or economic feasibly of the recommendations on digital technologies. The limits, if imposed, would make it impossible to clean digital output devices.
The proposed rule also addressed small parts washing units as well. SGIA’s comments also requested that the rule be revised so that these units only need to meet work practice requirements (e.g., as keeping the unit always closed when not being used) and not VOC or vapor pressure limits. These units can be used to clean some digital application equipment’s parts the proposed VOC or vapor pressure limits would prevent them from being used in this manner.
Since Part 234 does specifically include or exempt digital printing technology, it would be subject to the limits established under the proposed regulation. SGIA’s comments specifically requested that cleaning solvents used on digital output devices be excluded from the requirements. The primary reason for requesting the exemption is because the EPA guidance that the rule is based on did not study the technical or economic feasibly of the recommendations on digital technologies. The limits, if imposed, would make it impossible to clean digital output devices.
The proposed rule also addressed small parts washing units as well. SGIA’s comments also requested that the rule be revised so that these units only need to meet work practice requirements (e.g., as keeping the unit always closed when not being used) and not VOC or vapor pressure limits. These units can be used to clean some digital application equipment’s parts the proposed VOC or vapor pressure limits would prevent them from being used in this manner.