Clark County, Nevada, which includes the Las Vegas metropolitan area, has adopted new air pollution control regulations for printing operations in the county. After about a year and half of development, the rule became effective on May 21, 2024.
Clark County was required to implement a series of regulations on business and industry because it failed to meet the ozone standard set by the U.S. Environmental Protection Agency (EPA) and was redesignated by EPA as an area with worse air quality. Clark County is experiencing increasing levels of ozone pollution, which means it must implement regulations that meet the EPA’s requirements for various industries that emit volatile organic compounds (VOCs), including printing operations.
PRINTING United Alliance has been working closely with Clark County to ensure the rules are both compliant with federal requirements and manageable for the printing industry. Over the course of several workshops, meetings, and comment submissions, the Alliance was able to scale back some proposed requirements that would have been onerous for the printing industry.
Two major changes the Alliance helped make to the final rule included the elimination of all regulatory requirements for digital and screen-printing operations. The Alliance also urged Clark County to reject any consideration of adopting California’s VOC limits because the California VOC content limit is one of the most stringent in the country. Instead, the Alliance recommended following the EPA guidelines for printing industry VOC limits.
The new Clark County regulations apply to any printing operation that has a lithographic press, letterpress press, or is engaged in flexible packaging converting with flexographic or rotogravure printing presses. The requirements that need to be met are based on either the amount of material used per year, or the facility's emissions of VOC. There are three thresholds of applicability in the rule.
The first threshold is for facilities that are completely exempt from the regulation. Any printing operation that uses less than 500 gallons (about 1,892.7 L) or less than 5,000 pounds of graphic arts material per year are fully exempt from the regulations.
The second threshold is for any covered facilities that use more than 500 gallons or 5,000 pounds of graphic arts materials. They must meet requirements which include registration, notification, recordkeeping and reporting.
The third threshold is for any covered facility that has projected maximum emissions of VOC equal to or greater than 3.0 tons per calendar year. In addition to the registration, notification, recordkeeping and reporting requirements, they must meet additional requirements, which include:
- For lithographic printing presses, there are limits for cleaning solutions and fountain solutions. Heatset presses wider than 22 inches or emitting more than 25 tons potential VOC must install and operate an oxidizer.
- For flexible packaging operations, they must either meet a low VOC content limit for inks and coatings or install and operate an add-on pollution control device, such as an oxidizer.
- Work practices for using, storing, handling, or disposing of graphic arts materials. This includes keeping containers closed and labeled.
- Compliance obligations include identifying the VOC content of all materials and conducting quarterly inspections of the work practices mentioned above.
The requirements above are not an exhaustive list and more are included in the regulation. The Alliance will release a toolkit to help members understand the regulation and what is needed to meet its requirements.
The County has also published a fact sheet and flow diagram to assist facilities with compliance. Members are encouraged to read the rule in its entirety and contact Sara Osorio (sosorio@printing.org) or Gary Jones (gjones@printing.org) to verify which requirements apply to their facility.
In this article, Sara Osorio, Coordinator, EHS Affairs, PRINTING United Alliance, reviews the recently approved air rules in Clark County, NV. More information about this and other sustainability issues can be found at Business Excellence-EHS Affairs or reach out to Sara directly if you have questions about how these issues may affect your business: sosorio@printing.org.
To become a member of the Alliance and learn more about how our subject matter experts can assist your company with services and resources such as those mentioned in this article, please contact the Alliance membership team: 888-385-3588 / membership@printing.org.