Southern California - OEHHA Inspired Air Toxics Rules
Barbara Kanegsberg BFK Solutions LLC
The South Coast Air Quality Management District (SCAQMD) is looking revise key air regulations (1). The changes are a rapid response to the health risk assessment guidelines manual from the Office of Environmental Health Hazard Assessment (OEHHA) that was adopted on March 6, 2015. The new guidelines seem likely to impact manufacturing throughout California (2). And, it is not unknown for regulators throughout the U.S. to adapt or adopt the approach of California agencies.
Impact on you
Will the regulations impact your manufacturing facility? It depends. Because the situation is complex, we suggest that your safety/environmental professionals look at your current manufacturing processes, review anticipated changes, and consider the geographical environment and regulatory microclimate. Manufacturing processes with superlative engineering and emissions controls taking place in a facility that is located in an industrial park is probably less likely to be affected than one located in a mixed-use neighborhood. Facilities that are designated "Air Toxics Hot Spots" are likely to see more complexities. You can find additional information on the SCAQMD website.
Even if your facility is not in SCAQMD, it would be reasonable to check with your local regulatory groups, because OEHHA guidelines were developed for use throughout California.
An SCAQMD Board Meeting is scheduled for June 5, 2015, at which point the Board could either adopt the new rules or take some other action. The proposed updates will be discussed briefly at an SCAQMD Stationary Source Committee Meeting, on April 17, 2015. Written comments to SCAQMD are due on May 1, 2015.
1 - SCAQMD Rules 1401, 1401.1, 1402, and 212.
2 - Campopiano, M. and M. Friedman, "California's Strict New Health Risk Assessment Guidelines May Increase Regulatory Burden on Industrial Uses and Development Projects," Latham & Watkins Clean Energy Law Report, March 18, 2015.
Knowledge Is Power
"Some Like it Hotter"
We have a new column, "Kanegsbergs on Cleaning," in Process Finishing Magazine. Read about the effects of temperature on cleaning, both positive and negative, in the March issue.
"Success to Failure"
In "Success to Failure", in the current issue of Controlled Environments Magazine, Ed and Barb Kanegsberg discuss how incorrect or incomplete information can be found even in peer-reviewed articles. Negative results may not ever be published. We show you how to look at papers and presentations in a productive, critical manner.
Avoid Cleaning Catastrophes; come to Parts Cleaning Expo (PCx), 2015
Hear Barbara Kanegsberg present "Cleaning Catastrophes and How You Can Avoid Them." The informative and entertaining talk is part of Parts Cleaning Expo (PCx) which takes place April 21 - 23, 2015 in Columbus OH.
Learn about cleaning and enjoy the scenery
Barbara and Ed will present "Critical cleaning and surface quality of what gets shipped out the door of the cleanroom" at the Upstate NY chapter of the IEST, Spring 2015 technical seminar. The seminar is Thursday, June 4 at the Canandaigua Inn on The Lake, Canandaigua, NY. The snow will have melted by then.
The Kanegsbergs return to SUR/FIN June 8-10, Rosemont, IL. They will present two talks, "Cleaning Extreme Surfaces," and "New Studies - Improve Your Ultrasonic Cleaning Process."
About BFK Solutions
Does your cleaning process work sometimes (but not well)? Are you waiting for the results of "one more cleaning test"? Are you afraid of regulators - or consultants? Stop putting up with semi-beautiful cleaning processes and contact us to learn more. Our "Actually Do Something (A.D.S.) Action Program" may be just the gentle nudge you need.
We're independent. We don't sell chemicals or cleaning equipment; and we don't take commissions. Instead, we work for you. This saves you cold hard cash. We use our 30 years of experience to help you make good decisions about your cleaning processes, your manufacturing processes, your business. Check our website; send us an email; give us a call. We always like to hear from you.