Due to requirements imposed by the Clean Air Act, the Rhode Island Department of Environmental Management (RIDEM) has proposed revisions to its air pollution control regulations for printing operations. The proposed changes include new emission limitations for offset lithographic, letterpress and flexible package printing and cleaning operations, recordkeeping requirements and work practice standards for offset lithographic, letterpress and flexible package printing facilities with emissions greater than three (3) tons in any twelve (12) month period.
The proposal impacts many small printing companies as there were no specific limits for offset lithographic, letterpress and flexible package printing operations. While the three (3) ton applicability threshold and some of the limitations are required by EPA, other conditions are at the discretion of the RIDEM. In representing its members, SGIA submitted extensive comments requesting many changes to the proposed regulations. One of the more significant requests was for the RIDEM to clearly state that the limits for flexible packaging are for flexographic and rotogravure presses only. This is important as the limits are based on a product and not a printing process. The limits cannot be met by digital printing devices and with the digital printing of packaging becoming more popular, the rule’s applicability needs to be crystal clear. Other requested changes would eliminate confusing requirements, reduce the administrative and compliance demonstration burden, and allow for additional exemptions from the regulatory requirements.
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