We see positive progress with a developing Model Rule for Solvent Degreasing, from the Ozone Transport Commission (OTC). The goal is to carry out EPA mandates to improve air quality by reducing Volatile Organic Compounds (VOCs). The rule is significant because it may impact manufacturing in the Northeast/mid Atlantic area. The rule is NOT restricted to cleaning metal or to vapor degreasers. It encompasses a range of manufacturing processes that include such diverse applications as cold cleaning in automotive repair, electronics assembly, and vapor degreasing. We are concerned and active because an early draft of this rule, closely adapted from the stringent requirements of SCAQMD in Southern California, included provisions that we consider detrimental to productive manufacturing. We gave you a heads-up in the March 2011 issue of Clean Source. Even more important, we put our comments and suggestions in writing and sent them to the people developing the rule.
The big take-home lessons here are: communication helps and rational discussion helps (i.e. practical science as opposed to lobbying). The rule developers have been responsive. We are seeing the development of a sensible, practical model rule. A more recent draft of the rule provides guidance, inspiration, and approaches to regulatory agencies that are in turn putting together the regulations that will impact how you manufacture product.
While Southern California regulations may influence environmental rules in the Northeast/Mid Atlantic states, we see significant, positive changes in the Model Rule that could result in both improved air quality and productive manufacturing.
Input – industry experts
We provided three sets of comments to the Ozone Transport Commission (OTC) and participated in several conference calls. Other experts commented as well. The Model Rule is still being finalized, so the exact wording should be considered a bit fluid. It appears to be developing into a sensible, practical approach that reflects the current needs of the manufacturing community. While the original 2010 draft (1) reflects the SCAQMD approach used in Southern California, a more current version (2) shows significant modifications. For vapor degreasing, the latest version follows the 2001 Model Rule and provides for the use of open-top systems with appropriate containment and controls.
It also appears that for electronics assembly applications the allowable VOC limit will be 150 g/L, not 25 g/L. This is important, because defluxing (cleaning) of electronics assemblies is typically conducted in in-line aqueous cleaning systems. In-line systems don’t resemble vapor degreasers; but they are included in the model rule. In our experience, cleaning formulations with less than 25 g/L VOC are often not effective in removing flux residue, particularly with densely-populated assemblies.
We provided two sets of comments to the OTC in September. We suggested that the 150 g/L become an option for other high-value applications. We reiterated our suggestion for modification of the definitions of airless an airtight systems; this would allow more options for development of containment technology.
VOC reduction – not a cure for the common cold
OTC is chartered to develop a Model Rule specifically covering VOCs. This means that the rule does not address air toxics, worker safety, other forms of pollution, or waste generation. For example, as requested during one of the OTC-related teleconferences, we provided our observations of the impact of VOC restrictions in automotive repair applications (The short answer: abundant use of aerosol cleaners). In our comments of September 26, we also included a wish list of regulatory approaches that, while beyond the scope of the OTC charter, would provide greater clarity and consistency. One issue that is well beyond the scope of the OTC charter is to provide good approaches to determining VOC level in cleaning agents. EPA Method 24 is designed for coating materials, not for cleaning agents; and it is subject to, among other things, variability of ovens. There are also technical limitations to SCAQMD Method 313 (Gas Chromatograph/Mass Spectroscopy); and it does not appear to be reproducible. Some related aspects of analysis have been covered in two of our “Controlled Environments” columns (3).
Read our September 2011 comments to the OTC
Comments of September 21, 2011
Comments of September 26, 2011
For the first Clean Source article about the OTC
“OTC Model Rule and Critical Cleaning”
to download our initial comments from March, 2011
References
1. OTC_Solvent_Degreaser_Model_Rule_for_2011_082310AGMP, Version of Feb., 2011,
2. Draft Model Rule for Solvent Degreasing, Version of Aug., 2011, http://otcair.org/upload/Documents/Meeting%20Materials/OTC%20Solvent%20Degreaser%20Draft%20Model%20Rule%20for%202011%2011081711.doc
3. B. Kanegsberg and E. Kanegsberg, “Finding the Optimal Analytical Test: Parts 1 and 2,” Controlled Environments Magazine, November and December, 2010.
