SGIA submitted comments to the Virginia Department of Environmental Quality on the proposed revisions contained in Article 57, Emission Standards for Industrial Solvent Cleaning Operations in Northern Virginia, Volatile Organic Compound Emissions Control Area, 8 hour Ozone Standard (Rule 4-57). SGIA's intent is to encourage adoption of a regulation that conforms with the industrial solvent cleaning regulations adopted by other states in the same geographic area. Promulgation of any regulatory controls, such as those proposed by the VA DEQ, should allow an industry sector to use the materials that are technologically compatible with their manufacturing process. The comments we offered seek to explore alternative means to promulgate the regulation that will result in environmental benefit without sacrificing an entire industrial sector.
SGIA, as with similar state regulatory proposals, recommended the that State adopt a VOC content limit of 4.2 pounds of VOC per gallon for industrial solvents used by screen printing facilities, and that cleaning operations associated with digital printing be exempt. For more information on this regulatory action, please contact Marci Kinter, Vice President - Government & Business Information at firstname.lastname@example.org.
In response to the request for comments at the March 31st Stakeholder Meeting, SGIA submitted comments to the Department of Environmental Protection on their pre-proposal regulatory package for Industrial Solvent Cleaning Activities. In its comments, SGIA recommended that cleaning activities associated with digital printing be exempt from the rule’s requirements. Further, we recommended adoption of a limit of 4.2 pounds of VOC per gallon for screen printing operations. We also requested a list of exempted activities, such as stripping of cured inks and coatings, be added to the rule.
It is anticipated that the Agency will release a proposed rule by the Summer of 2014. At this time there will be another opportunity to offer comments on the rule’s provisions. For a full copy of SGIA’s comments, please contact Marci Kinter at email@example.com.