When the Clean Air Act Amendments of 1990 were implemented, they greatly increased both the number and scope of businesses whose air pollution emissions were regulated. Prior to these amendments, federal regulations had primarily sought to limit air pollution from large sources such as major industrial and manufacturing facilities and electric power plants. With the 1990 Amendments, however, the government recognized the tremendous aggregate effects that hundreds of thousands of small sources of air pollution—such as printers, small furniture manufacturers, dry cleaners, and repair shops—were having on the nation's air quality. Limiting air pollution from these sources was considered to be just as important as the prior effort to limit pollution from large emitters.

Fortunately, as they crafted the 1990 Amendments, the federal government also recognized that unlike their larger counterparts, the small businesses that would be affected by these new laws would not have environmental specialists and attorneys on staff for help and guidance. Bringing about compliance would require outreach, education, and technical assistance. The 1990 Amendments, therefore, require every state to create a Small Business Technical and Compliance Assistance Program to provide this outreach. Each state's program would have three components: an Ombudsman, to conduct outreach and offer assistance resolving regulatory difficulties; a Small Business Assistance Program, also to conduct outreach and to provide technical assistance; and a Compliance Advisory Panel, a group of appointed individuals to offer guidance to the other two components of the state's program.

In New York State, the Ombudsman function is performed by Empire State Development's Small Business Environmental Ombudsman (SBEO) unit and the Small Business Assistance Program (SBAP) is provided by the New York State Environmental Facilities Corporation (a nonregulatory, state public benefit corporation) under contract to the NYSDEC. Together, these partners have brought thousands of small businesses into compliance. Services to small businesses from the SBAP and SBEO are free and confidential. Frequently, the SBAP offers P2 suggestions to small businesses to help them comply with pollution limits. Although P2 measures will not always ensure compliance with emission limits, they can significantly reduce a business' air emissions and frequently save money. In some cases, implementing P2 measures such as material substitutions can exempt a facility from permitting and other regulations.

The SBAP's P2 tips focus on reducing emissions of volatile organic compounds (VOCs). These air pollutants are heavily regulated because they contribute to ground-level ozone, or "smog." Many VOCs are also classified as hazardous air pollutants (HAPs), another category of heavily regulated pollutants. Reducing VOC emissions, therefore, also reduces total HAP emissions.

To reduce VOC emissions, the SBAP suggests that small businesses use these general guidelines:
      - Identify and evaluate sources of air pollution. Objectively walk through your operations and note where and how wastes are generated and in what quantities. Assess if and how these wastes might be prevented. Often your own staff can suggest ways to reduce VOCs.
      - Reduce wastes; recycle materials where possible.
      - Implement simple, no-cost measures such as good housekeeping practices to prevent pollution. Maintain equipment to prevent failures and downtime; label and date containers of supplies and materials to help identify the contents and shelf life; keep the shop clean to prevent contamination of raw materials. These are easy ways to reduce waste.
      - Examine your short-term and long-term options for P2. Keep in mind that the usefulness of any prevention option depends on your assessment of several factors: the cost of any changes required and your ability to finance these improvements; the degree of environmental hazard the pollution poses; and your potential liability for managing the pollution.
      - Calculate your current costs for controlling and managing pollutants and compare these costs with the estimated costs of preventing the pollution. By linking prevention costs to the source of pollution, rather than treating these costs as overhead, you can identify which prevention measure will make the most economic sense to implement.
      - Implement the P2 plan that yields the greatest environmental and economic benefits. This means you should implement practices that eliminate the most hazardous pollutants, reduce the overall amount of pollutants, or reduce or eliminate the pollutants that are the most expensive to manage.

Contact the SBAP's hotline (800-780-7227) for help in assessing air pollutants and identifying ways to reduce emissions. Remember, SBAP staff can provide free confidential assistance to help you assess your operations.

Two of the largest industries that benefit from VOC-reducing P2 tips are the graphic arts (printing) and surface coating industries. These industries are among the most-frequent callers to the SBAP's technical assistance hotline and, as a result, the SBAP has compiled some comprehensive air P2 tips for these sectors.

Pollution prevention for printers

Air pollution emissions from printers in New York State primarily are regulated by Part 234, Graphic Arts. The specific requirements that apply to a particular printer depend on the facility's location in the state. Contact the SBAP if you're not sure about Part 234's requirements for your printing operation.

One element of Part 234 is a limit on the VOC content of fountain solutions used on offset lithographic printing equipment. Thus, the SBAP's P2 tips for this industry focus on reducing the VOCs in fountain solutions and limiting VOC emissions from other sources, such as cleanup solvents.

Storing and handling VOCs

Do not use open containers to store and handle VOCs. Open containers enable the VOCs to evaporate or volatilize, thereby increasing emissions. Never use open containers to store cloths or papers that contain VOCs or that have been used for pressroom cleanup. Use only closed containers to store or dispose of inks or surface coatings.

Alcohol-free fountain solutions reduce VOC emissions

Printers often use fountain solutions that are free of alcohol as a substitute to reduce their VOC emissions. When mixed properly, these substitutes will result in fountain solutions with a VOC content of 3% to 5% by weight, which complies with NYSDEC's Part 234 requirements. Care should be taken if any alcohol is added to the dampening system, however, because it will increase the overall VOC content of the fountain solution.

Choosing a different cleanup solvent

Up to 95% of the VOC emissions from offset lithographic printing facilities are from cleanup solvents. Using a low- or non-VOC cleanup solvent can thus greatly reduce a facility's VOC emissions. Choosing the right solvent for your applications requires a little research, but all the information you need should be at your disposal.

First, identify all cleaning operations in the facility and gather the Material Safety Data Sheets (MSDSs) for the cleaners you presently use. Second, request that vendors for each potential substitute supply the MSDS for that cleanup solvent. Third, compare the potential of all solvents to emit air pollution. The two characteristics of the cleanup solvent that determine its potential to emit air pollutants are its VOC content and how quickly it evaporates (listed as the "vapor pressure" on the MSDS). Then, armed with this information both for the solvents you presently use and for the substitutes you are considering, you can reduce your VOC emissions. Use the following tips each time you choose a cleaner for a particular application:

Use solvents with the lowest VOC content possible for the job at hand.
Use solvents with lower vapor pressures to minimize evaporation. (This will save money in the long run, since the solvent you've paid for isn't evaporating as quickly.)
Use the mildest effective cleaner for each task.
Use aggressive, quick-evaporating solvents only for tasks that truly require their use.

Once you've chosen a few solvents that work for your particular cleaning applications, standardize the types of cleaners and cleaning procedures at your facility so all your operators are using the same solvent for the same cleaning task. To help you track usage rates for different operators, dispense solvents from a central location.

Finally, talk to your ink vendor about your solvent substitution efforts, since your ink formulation will affect your cleanup solvent options. Wherever possible, choose inks that clean up easily with environment-friendly solvents.

Reduce solvent consumption and facility air emissions

Now that you've chosen some cleanup solvents with low or no VOC content, reduce your emissions even further with these techniques:

Reduce the need to clean.: Limit your need to clean ink fountains by consecutively running jobs that require the same ink color, whenever possible.
Use a standard ink sequence.: Use a standard ink sequence to reduce the number of ink rotations you must perform and consequently the amount of waste ink and cleaning solution.
Use non-soaked cleaning rags.: Use a plunger can or a squeeze bottle filled with cleaning solvent to moisten cleanup rags, instead of soaking them. Also, set up equipment or procedures to remove solvent for reuse. For instance, use a hand-operated wringer or a centrifuge to wring solvent from the rags.

Remember, these tips not only reduce solvent consumption and air emissions, they may save you money, too.

Recycle waste inks

Most waste inks can be recycled. One recycling technique blends waste inks of different colors together to make "black" ink. You may need to add small amounts of certain inks or black toner to the blend to obtain an acceptable color; test the results of this blending to be sure it meets your customer's approval. With this technique, not only do you save the purchase price of an equivalent volume of new black ink, you also eliminate the costs associated with disposing of your waste inks.

Pollution prevention for surface coaters

Air pollution emissions from surface coaters in New York State are regulated by Part 228, Surface Coating Processes. Whether Part 228 applies to a particular facility depends on the facility's location in the state. One important element of Part 228 is the limit it places on the VOC content of coatings, depending on the material being coated. Although not all surface coaters are subject to these limits, all can benefit from the SBAP's P2 tips which focus on:

Limiting VOC emissions from sources such as cleanup solvents
Reducing VOC emissions from coatings through changes to coating techniques and technologies
Removing heavy metals from pigments.

Materials handling

Cover any containers used to store or dispense materials such as solvents, coatings, or any cloths or papers soaked in solvents or coatings. This reduces the amount of VOCs emitted into the air.

If you are subject to Part 228's limits on VOC content, the regulation also mandates that you use spray gun cleaning equipment that is designed to recover cleaning solvents. Even if you are not subject to Part 228, this solvent recycling equipment

Reduce solvent emissions

The following techniques not only reduce solvent consumption and air emissions, they may save you money, too:

Use lower VOC-content coatings.: Even if your facility is not currently subject to Part 228, you should investigate switching to low-VOC-content surface coating materials. This will reduce your facility's VOC emissions and reduce your workers' exposure to hazardous air pollutants.
Reduce the need to clean.: Limit your need to clean your equipment by consecutively running jobs that require the same coating color.
Use non-soaked cleaning rags.: Use a plunger can or a squeeze bottle filled with cleaning solvent to moisten cleanup rags instead of soaking them. Also, set up equipment or procedures to remove solvent for reuse. For instance, use a hand-operated wringer or a centrifuge to wring solvent from the rags.
Improve your transfer efficiency: You can reduce your total VOC emissions by improving the transfer efficiency of your paint application system. Transfer efficiency is the ratio of the amount of paint solids deposited on the product to the total amount of paint solids leaving the spray gun. A higher transfer efficiency means more of the paint that you pay for is ending up on the object you're coating, thus saving you money. Improving transfer efficiency will reduce both paint consumption and VOC emissions.

Here are a few techniques for improving transfer efficiency:

Rack small parts rather than trying to coat each

individually. Make sure the parts are racked in such a way that the coating won't puddle on the part. The ability to successfully coat racked parts depends on the configuration or shape of the parts being coated. Try various configurations until you find one that suits the job at hand.

Ground your electrostatic spray equipment for safety

purposes and ground all parts to be sprayed with electrostatic equipment so that the coating is applied uniformly.

Cut the air pressure on conventional spray guns to

approximately 40 lb to reduce overspray.

Use as narrow a fan pattern as possible when

spraying. This also will help to avoid or reduce overspray.

Avoid excessive air flow in the spray booth. Keep it

to approximately 100 ft/min to avoid or reduce overspray.

Heated spray systems reduce make-up solvent usage

Using heated spray systems can eliminate the need for you to add solvents to paints to reduce their viscosity. Heated systems usually use paint in the 100-150(F range. The paint has a higher solids content (due to less make-up solvent), which will provide greater coverage for each spray gun pass. Be sure to alert your coating operators to this change, and train them to revise their application method accordingly. The vendor of your heated spray system is an excellent resource for this training, which often is included in the purchase price of such a system.

Eliminate heavy metals in paint pigments

Many coatings contain metals such as lead, chrome, and cadmium. The quantity and type of metals are specified on the MSDS for each coating. Workers who apply the coatings are exposed to these toxic substances. When these emissions are exhausted from the spray booth, residents near the facility are also exposed. In many cases, you can eliminate these chemicals from the coating by requesting nonmetal-based paints from your coating supplier. As an added benefit, using nonmetal-based paints means your used paint filters are classified as a nonhazardous waste, thereby eliminating the cost of disposing of them through a hazardous waste hauler.

Solvent substitution works for all industries

Many industries, including printing and surface coating, use cleaning solvents as a part of their normal operations and can reduce their air pollution emissions by using low- or non-VOC solvents. Improvements are continuously being made to make solvents less hazardous. If you have not tried or have tried but failed to find a useful aqueous (water-based) solvent, it is time to take another look. Vendors are constantly introducing new solvents and improving existing offerings. One of these newcomers may suit your needs to a T. As an added incentive, some organic solvents on the market are not considered hazardous wastes after you are through using them.

Costs of material substitutions to achieve P2

Many of the SBAP's P2 tips involve substituting a new material for more-hazardous one that is currently being used. Substituting an environment-friendly material for your current material can appear to be more costly on the surface: many alternatives cost more per unit, or the new machinery appears to be more costly than current equipment. When evaluating the costs of a substitution, however, remember the hidden costs of your present material, equipment, or process. In short, look at the entire environmental cost of the material you are currently using, not just its cost per unit from the vendor. Add up the following possible costs of your present material, then compare this total to the total cost of a substitute:

1. Actual costs of material

2. Disposal costs and liability for hazardous wastes. Using a nonhazardous substitute can reduce or eliminate the costs and liability associated with disposing of hazardous wastes.

3. Costs of increased usage due to the evaporation of solvents with a high VOC content. This cost is critical for surface coating, printing, and solvent cleaning operations, because they use a high volume of solvents.

4. Permitting fees. Some substitutions—such as powder coating, UV-cured coating, and aqueous cleaning operations—may make your process exempt from permitting.

5. Required reporting. If the material you are using makes you subject to a particular regulation that requires self-monitoring and recordkeeping, such as federally regulated halogenated solvents or perc dry-cleaning, labor costs for monitoring and recordkeeping can really add up.

6. Enforcement fines from noncompliance.

You may find that a substitute that initially appeared to be more expensive when evaluated strictly on a per-unitis is actually less expensive when all the costs of your current material are considered.

More help available If you'd like more advice or information about pollution prevention to help your facility comply with state or federal air pollution control requirements, contact the SBAP's toll-free hotline (800-780-7227). All calls are confidential.

Click here to visit the SBAP web site, sponsored by the EFC.

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Amy Fowler is the Technical Information Specialist for the SBAP at the NYSEFC SBAP. Project Managers Harry Ching, James Coyle, Steve Mohr, and Virginia Rest provided valuable information for this article, as did SBAP Program Manager Marian Mudar.

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