Clark County, NV Targets Printing Operations for Air Regulation

Clark County Nevada, which includes Las Vegas, and the surrounding areas, has failed to achieve compliance with the health-based pollution standards set by the U.S. Environmental Protection Agency (EPA). These standards, called National Ambient Air Quality Standards (NAAQS), set acceptable ozone concentrations allowed in the air. Because Clark County has not met the ozone NAAQS, it is required to develop and impose new regulations designed to reduce the precursors of ozone, which are Volatile Organic Compounds (VOC) and Nitrogen Oxides (NOx).

Clark County is experiencing growing ozone pollution after nearly a decade of declines, according to data from the county. Therefore, the Clark County Division of Air Quality (DAQ) must adopt regulations that, at a minimum, use the appropriate EPA guideline on a variety of industries that emit VOCs. One of the affected industries is the printing industry, with several different printing applications subject to the regulations.

The regulations under development that will impact printing operations include:

• Consumer Products (impacts adhesive use in screen printing)
• Cold cleaners (e.g., parts washers)
• Industrial solvent cleaning
• Graphic arts lines (i.e., flexographic and rotogravure)
• Flexible packaging
• Offset lithographic and letterpress printing

Printing United Alliance was invited to participate in several workgroups formed by Clark County to provide feedback on the structure and form for the new rules. The workgroup is composed of industry representatives, associations, and consultants who provide feedback on the structure and requirements of the new rules.

During the first set of workgroup meetings, the DAQ presented a series of options and portions of other state or local rules they are considering using to develop their own regulations. Some of the rules had similar limits, but some rules under consideration included ones currently in place in Southern California, which are among the most stringent in the country. For the printing industry rules, the DAQ was relying on the current rule in Maricopa County (Phoenix area), Arizona.

The Alliance submitted extensive comments on all applicable concept drafts. In comments on the industrial solvent cleaning, paper, film, foil coating, and miscellaneous industrial adhesives drafts, the Alliance requested that printing operations be included in the list of exempt operations.

Comments on the flexible packaging, offset lithographic and letterpress printing rules focused on providing clarity to the Maricopa County rule. The Alliance offered revisions that would streamline the applicability provisions, limits, and the requirements needed to demonstrate compliance.

A comment on the consumer product rule, as provided, had language clarifying that the limits only apply to materials available via retail locations and not products sold directly to businesses. Direct-to-business products will be covered by a separate rule The comments also stressed that current regulations in Southern California should not be adopted as they are too restrictive and do not provide printing operations with any operational flexibility.

The DAQ is behind on meeting EPA’s deadline for passing the new rules, so it has accelerated the development timeline to be formally proposed and finalized by July 4, 2023.