Gary Jones, Director, Environmental, Health, and Safety Affairs for PRINTING United Alliance was only one of nine small business representatives appointed to participate in a small business panel on Expanded Air Emissions Reporting created by the U.S. Environmental Protection Agency (EPA). The business panel is required under Small Business Regulatory Enforcement Fairness Act, or SBREFA. SBREFA panels are required anytime an agency seeks to issue a new regulation that impacts small business. Participation on the panel provides the opportunity to provide feedback and suggested revisions to the proposed regulation prior to it being released for public review and comment.
The panel was asked to provide feedback on EPA’s development of proposed revisions to the existing Air Emissions Reporting Requirements (AERR) rule that was last revised in February 2015. The Agency’s proposal covers an expansion of the existing reporting requirements and may add reporting requirements to gather data about hazardous air pollutants, emissions rate test results from facilities, emissions from facilities in Indian Country that are not currently reporting emissions data, and emissions from small electricity generating units, primarily backup generators, used intermittently, such as to meet demand on high electricity usage days.
Following the initial meeting held on June 14, 2022, PRINTING United Alliance submitted written comments at the end of June raising concerns regarding the impact the reporting rule would have on small printing operations, many of which are not required to submit emission data to their state or local air pollution control authority. The proposed reporting requirements were very extensive and would require most printing operations to either learn how to conduct extensive emission calculations or hire an outside consultant to perform them. The EPA proposed a reporting threshold of 4.4 pounds per year for many of the Hazardous Air Pollutants found in the printing industry. PRINTING United Alliance's comments objected to these proposed reporting thresholds. It was suggested that an alternative approach based on material consumption amounts tied to emissions be used to simplify the process for small businesses.
As a next step, the EPA will review the comments submitted, consider them, and hold a second meeting of the panel. EPA will present their current thinking to the panel and ask for additional feedback in a second meeting of the panel which will occur when EPA convenes it.
PRINTING United Alliance seeks to keep the printing industry updated on workplace requirements related to environmental compliance. For more information, or if you have questions on this or any other state regulatory program, please contact Marci Kinter, mkinter@printing.org or Gary Jones, gjones@printing.org.