The Mojave Desert Air Pollution Control District (MDAPCD) has issued proposed changes to Rule 1117, Graphic Arts and Paper, Foil, Film and Fabric Coating Operations. This rule sets down the regulatory requirements for printing facilities operating in this air district, which includes parts of Los Angeles area. There are specific requirements for lithographic, flexographic, rotogravure, screen printing and digital printing operations. PrUA submitted comments requesting both clarifications and additional exemptions to the rulemaking proposal.
Overall, we supported the District in its use of the U.S. Environmental Protection Agency’s (USEPA) 2006 Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing (hereafter referred to as the CTG for Offset Lithographic Printing) as the basis for developing revising the requirements in Rule 1117. However, as many critical elements contained in the CTG for Offset Lithographic Printing providing guidance on compliance demonstration were not included in the proposed regulation, we made specific recommendations to include these as part of the comments .
Further, the comments also indicated support for the inclusion of requirements from San Joaquin Valley Air Pollution Control District’s Rule 4607, Graphic Arts, Paper, Foil, Film and Fabric Coatings for the requirements impacting screen printing operations. In addition, the comments requested other changes to streamline these requirements as well as address outstanding technical issues.
For a full copy of the comments submitted, or for additional information, please contact PrUA’s Government and Regulatory Affairs Department at govtaffairs@sgia.org.
Overall, we supported the District in its use of the U.S. Environmental Protection Agency’s (USEPA) 2006 Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing (hereafter referred to as the CTG for Offset Lithographic Printing) as the basis for developing revising the requirements in Rule 1117. However, as many critical elements contained in the CTG for Offset Lithographic Printing providing guidance on compliance demonstration were not included in the proposed regulation, we made specific recommendations to include these as part of the comments .
Further, the comments also indicated support for the inclusion of requirements from San Joaquin Valley Air Pollution Control District’s Rule 4607, Graphic Arts, Paper, Foil, Film and Fabric Coatings for the requirements impacting screen printing operations. In addition, the comments requested other changes to streamline these requirements as well as address outstanding technical issues.
For a full copy of the comments submitted, or for additional information, please contact PrUA’s Government and Regulatory Affairs Department at govtaffairs@sgia.org.