Graphic Arts Coalition

Representing the Graphic Communications Industries

March 23, 2007

Ms. Kim Teal

Mail Code XXX

US Environmental Protection Agency

Research Triangle Park, NC 27711

Re: 	Comments on Scope and Applicability of the Paper, Film, Foil
Coating Control Techniques Guideline 

Dear Ms. Teal:

This letter is in response to the discussions that occurred during the
initial meeting held on Feb. 12, 2007 focusing on the development of the
Paper, Film, Foil Coating Control Techniques Guideline (PFFC CTG). 
During the meeting, feedback on the scope of the PFFC CTG was requested.


There are two significant matters that EPA needs to address with respect
to the scope of the PFFC CTG: exclusion of non-coating operations,
including certain printing operations, and a clear definition of
coating.  Both of these issues are critical to avoid duplicative and
unnecessary regulation.  If not addressed, these topics will cause
considerable confusion by both the regulated community and state/local
air pollution control authorities.  Each area is discussed below in more
detail.  

Background on Printing and Packaging Operations

The printing, publishing, packaging and allied industries comprise one
of the largest and most diverse industries in the United States.  The
businesses involved in these industries are divided by both the printing
process utilized and the products produced.  These industries cut across
several North American Industrial Classification System (NAICS)
categories and represent a significant portion of the economy. 

There are six main printing processes that comprise these industry
segments: offset lithographic, flexographic, rotogravure, screen,
letterpress and digital printing.  In terms of market share, lithography
is the largest followed by rotogravure, flexography, screen, digital and
letterpress.  While the ultimate goal of each printing process is to
reproduce and transfer images and text on any number of substrates, they
differ dramatically in how this is accomplished.

These industries produce a variety printed products, packages, and
services, including, but not limited to, books, periodicals, newspapers,
business forms, greeting cards, textiles, wallpaper, billboards, signs,
labels, and general commercial printing, which can include annual
reports, direct mail, advertising, newspaper inserts, directories, and
catalogs. 

The packaging industry segment includes products such as folding
cartons, corrugated boxes and other products, flexible packaging,
labels, and cans.  Flexible packages can be made of metal, plastic or
resins, or a combination of both.

These industry segments represent one of the most viable and vital
industries in the United States.  These segments have posted impressive
growth rates with future predictions of continued economic growth.   

Definition of Coating and Coating Application Operations

One of the most critical aspects of this CTG will be the definition of
coating and coating application units and how they relate to printing
and printing operations.  Historically, the differences between printing
and coating operations have been a subject of controversy and source of
confusion.  However, it is clear from the development of previous
coating- and printing-related CTGs and MACT standards, that the scope of
a coating rule should exclude printing operations. The development of
this CTG provides an opportunity to provide definitive clarification of
this issue. 

Because of this long-standing confusion, printers are frequently
required to demonstrate that the limits established for paper coating
operations are not applicable to printing operations.  This is a
particularly confusing area for those operations where coatings are
applied over the printed substrate.  This coating application can either
occur in-line (during printing) or off-line (with a stand alone coater)
at printing facilities.  

Including ink and adhesives in the definition of coating materials
without qualifying them relative to the process in which they are being
applied will lead to further confusion regarding applicability and
intent.  This concern is based on the common, mistaken classification of
printers as surface coating sources, resulting in the air pollution
control authority incorrectly applying the nonapplicable surface coating
requirements to graphic arts sources.  It is our recommendation that
inks, adhesives, and other overprint coatings applied at printing
operations either be eliminated from the definition or be qualified with
respect to application in the PFFC CTG so that this confusion is
removed. 

During the development of the Printing and Publishing (40 CFR Part 63,
Subpart KK) and Paper and Other Web Coating (40 CFR Part 63, Subpart
JJJJ) MACT standards, the definition of printing, coating, and coating
application units was discussed and, even though progress was made, the
lack of a definitive distinction between printing and coating still
remains.  In looking at the options for the PFFC CTG, there appear to be
two approaches to address the issue. The first is to revise the
definition of coating so that it clearly identifies which coating
operations are addressed in the CTG.  The second is to define the scope
of covered operations from an application perspective.

The preferred approach would be to include definitions that clarify the
PFFC CTG’s applicability.  Traditionally, functional based definitions
have been used to describe applicability and exclusions for CTG and NSPS
rules and, more recently, MACT standards. However, the use of a
functional definition to eliminate inks, adhesives, and other materials
from the definition of coatings may not accomplish the goal of
eliminating confusion and potential misapplication of this CTG. 

It appears that the only practical method to clarify the cope of the
PFFC CTG is to provide applicability and exclusion provisions based on
process type.  A process based approach would clearly delineate which
coating application processes are subject to this CTG and those that are
excluded. For those coating operations that will be subject to the CTG,
a process based approach can also include those input materials that
would be subject to rules based on the CTG’s recommendations.   

In the revisions to the Printing and Publishing NESHAP, promulgated on
May 6, 2006 (71 FR 29792), EPA provided clarification with respect to
the differences between printing and coating operations.  However, the
definitions do not go far enough to clearly address the application of
coating that occurs either inline or offline at printing operations.  

Coating means material applied onto or impregnated into a substrate for
decorative, protective, or functional purposes. Such materials include,
but are not limited to, solvent-borne coatings, waterborne coatings, wax
coatings, wax laminations, extrusion coatings, extrusion laminations,
100 percent solid adhesives, ultra-violet cured coatings, electron beam
cured coatings, hot melt coatings, and cold seal coatings. Materials
used to form unsupported substrates such as calendaring of vinyl, blown
film, cast film, extruded film, and coextruded film are not considered
coatings. 

Printing operation means the formation of words, designs, or pictures on
a substrate other than wood furniture components as defined in the Wood
Furniture Manufacturing Operations NESHAP (40 CFR part 63, subpart JJ),
wood building products as defined in the Surface Coating of Wood
Building Products NESHAP (40 CFR part 63, subpart QQQQ), and fabric or
other textiles as defined in the Printing, Coating, and Dyeing of Fabric
and Other Textiles NESHAP (40 CFR part 63, subpart OOOO), except for
fabric or other textiles for use in flexible packaging. 

In the development of the Paper and Other Web Coating NESHAP, EPA
provided a clearer statement regarding the applicability of the coating
rule with respect to printing operations. In the Final Rule (67 FR
72342), EPA specifically excluded printing operations in Section
63.3300:

…Web coating lines specified in paragraphs (a) through (g) of this
section are not part of the affected source of this subpart.

Any web coating line that is stand-alone coating equipment under subpart
KK of this part (national emission standards for the printing and
publishing industry) which the owner or operator includes in the
affected source under subpart KK.

Any web coating line that is a product and packaging rotogravure or
wide-web flexographic press under subpart KK of this part (national
emission standards for the printing and publishing industry) which is
included in the affected source under subpart KK.

Web coating in lithography, screenprinting, letterpress, and narrow-web
flexographic printing processes.

Any web coating line subject to subpart EE of this part (national
emission standards for magnetic tape manufacturing operations).

Any web coating line that will be subject to the national emission
standards for hazardous air pollutants (NESHAP) for surface coating of
metal coil currently under development.

Any web coating line that will be subject to the NESHAP for the
printing, coating, and dyeing of fabric and other textiles currently
under development. This would include any web coating line that coats
both a paper or other web substrate and a fabric or other textile
substrate, except for a fabric substrate used for pressure sensitive
tape and abrasive materials.

Any web coating line that is defined as research or laboratory equipment
in §63.3310.

The combined printing and coating operation and its classification was
addressed in Section 1.2.4 of the Control Techniques Guidelines for
Graphic Arts-Rotogravure and Flexography (EPA-450/2-78-033). This
document contains a provision specifying that a combination of printing
and coating would all be considered printing and subject to the graphic
arts regulations.

This classification was also included in the recently issued CTG for
Flexible Packaging (EPA-450/2-78-033) in the definition a flexible
package and the definition of a flexographic and rotogravure press. The
definitions are as follows:  

Definition of Flexible Packaging 

Printing, coating, and laminating may all be performed on or in-line
with a flexible package printing press and these activities are included
in the source category. One portion of the flexible packaging industry
provides fully printed packaging materials (designated "preformed
specialty bags") to contract packagers. Another portion provides
combination or laminated materials (designated converted wrap) for
printing and/or final packing by captive packaging operations. Applying
coatings is a major capability of flexible packaging converters, so the
same facilities may be used to manufacture non-packaging materials such
as gift wraps and hot stamp foils. 

Definition of Press 

Rotogravure press means an unwind or feed section, which may include
more than one unwind or feed station (such as on a laminator), a series
of individual work stations, one or more of which is a rotogravure print
station, any dryers associated with the work stations, and a rewind,
stack, or collection section. Inboard and outboard work stations,
including those employing any other technology, such as flexography, are
included if they are capable of printing or coating on the same
substrate. 

Flexographic press means an unwind or feed section, which may include
more than one unwind or feed station (such as on a laminator), a series
of individual work stations, one or more of which is a flexographic
print station, any dryers (including interstage dryers and overhead
tunnel dryers) associated with the work stations, and a rewind, stack,
or collection section. The work stations may be oriented vertically,
horizontally, or around the circumference of a single large impression
cylinder. Inboard and outboard work stations, including those employing
any other technology, such as rotogravure, are included if they are
capable of printing or coating on the same substrate. 

In addition, when EPA finalized the Control Techniques Guideline for
Offset Lithographic Printing and Letterpress Printing (EPA 453/R-06-002)
in September 2006, the issue of coating application was also addressed.
On page 7, it states:

Varnishes are unpigmented offset lithographic inks. They are applied on
offset lithographic presses in the same manner (i.e., using a
lithographic printing plate, fountain solution and blanket cylinder) as
offset lithographic ink. Heatset varnishes are unpigmented heatset inks.
The emissions generated by heatset varnishes are similar in nature to
the emissions generated by heatset inks and they can be controlled in
the same manner. Sheet-fed and coldset web varnishes are unpigmented
sheet-fed and coldset web inks. Sheet-fed and coldset web varnishes
exhibit the same high level of ink oil retention and generate the same
inherently low emissions as sheet-fed and coldset web inks. The coatings
used on offset lithographic presses are predominantly waterbased or
radiation (ultra-violet or electron beam) cured materials which generate
minimal VOC emissions. We recommend that varnishes and coatings used on
offset lithographic printing presses be considered part of the offset
lithographic printing process and that the recommendations described
below in section VI for heatset web offset lithographic inks and dryers
apply equally to varnishes. We recommend that varnishes and coatings
used on offset lithographic printing presses not be considered as a
separate process (e.g., paper coating).

It is clear from the intent of the development of previous CTGs and MACT
standards, that the scope of a coating rule should exclude printing
operations. Therefore, to ensure that printing operations are not
inadvertently included in the CTG, the following exclusionary provision
is offered for inclusion in the rule:

For purposes of this CTG, any offset lithographic, screen, letterpress,
flexographic, rotogravure, or digital printing and packaging line
including any in-line and auxiliary coating, laminating, and adhesive
application is not subject to the recommendations in this CTG. Inks,
adhesives, and other coating materials used in these operations are also
not subject to the recommended limits of this CTG. 

Sources Addressed by Other CTGs

To avoid confusion and duplication of regulation, those sources and
processes that have been addressed by previously issued CTGs or will be
evaluated in future CTGs should be specifically excluded from this CTG. 
This request is consistent with the recent development of the CTG for
Industrial Cleaning Solvents (EPA 453/R-06-001), in which EPA was
requested to provide an exclusion for any industrial sources with
current limits for cleaning activities in source-specific state
regulations.  The final version of the Industrial Cleaning Solvent CTG
does in fact provide clear language excluding these sources from the
recommendations found in the document. .  EPA provided the requested
exclusion by including a recommendation that states consider excluding
those source categories that would have limits for cleaning included in
their respective state regulations.  On page 5, of the Industrial
Solvent Cleaning CTG, the following statement appears:

Some industries with solvent cleaning operations are presently covered
by an existing CTG (e.g., aerospace). Other industries with solvent
cleaning operations may be the subject of a CTG that is presently being
developed (e.g., printing) or may be the subject of a future CTG (e.g.,
automobiles and light trucks coatings). CTGs often recommend control
approaches for a particular industry, like printing, and those
approaches achieve important VOC emission reductions. We recommend that
States consider excluding from the applicability of their State rules
promulgated in response to this CTG, those industries relevant to the
product categories listed for regulation under CAA section 183(e). See
71 FR 44540. We list below the section 183(e) industries that the States
may wish to consider excluding from the applicability of their State
rules.

On page 15 of the Industrial Solvent Cleaning CTG, the list of other
industries that have cleaning solvent limits as referenced in the
paragraph on page 5 is provided. The list is as follows:

 

We recommend that the States exclude from applicability those cleaning

operations in the following categories listed for regulation under CAA
section 183(e):

1.  Aerospace coatings;

2.  Wood furniture coatings;

3.  Shipbuilding and repair coatings;

4.  Flexible packaging printing materials;

5.  Lithographic printing materials;

6.  Letterpress printing materials;

7.  Flat wood paneling coatings;

8.  Large appliance coatings;

9.  Metal furniture coatings;

10.  Paper film and foil coating;

11.  Plastic parts coatings;

12.  Miscellaneous metals parts coatings;

13.  Fiberglass boat manufacturing materials;

14.  Miscellaneous industrial adhesives; and

15.  Auto and light-duty truck assembly coatings.

We request that USEPA include a  similar exemption provision in this CTG
for industries that have or will have limits imposed on their coatings
or coating application process in their respective source-specific CTGs,
or for those processes where EPA has determined that separate
limitations on coatings are not warranted.  An example is the
above-referenced Control Techniques Guideline for Offset Lithographic
Printing and Letterpress Printing, where EPA concluded that coatings
applied in the printing process are adequately addressed in this CTG and
determined that these coatings be considered part of the printing
operation and should not be considered a separate (i.e., coating)
process.  The PFFC CTG should be consistent with such previous EPA
determinations in its scope.

Summary and Conclusion

Experience has shown that it is equally as critical to articulate what
operations are not covered by a rule as it is to define which operations
are subject the rule. This is especially important when the CTG covers
only certain sub-segments of a larger industrial sector.  Since EPA will
be developing a CTG to address Paper, Film, and Foil Coating operations,
an opportunity now presents itself to clarify the applicability of the
guidance document (and any subsequently promulgated regulations) to
printing operations. 

Questions regarding the applicability of printing and coating limits by
permitting authorities have historically triggered intense discussions
and in many instances produced results that have been less than
satisfactory.  Since the intent of the PFFC CTG is to address coating
operations, the scope must be crafted in such a way as to not
inadvertently include sources and operations that have already been
covered by other regulation or those that are not coating operations. 
Therefore, an explicit, clearly defined scope for the PFFC CTG is
paramount in producing a document and a set of recommended control
requirements that is specific and appropriate to the sources being
addressed.  

We look forward to meeting with you to discuss the comments contained in
this letter.  Feel free to contact any of the undersigned for more
information.

Sincerely,

Gary Jones

Director, Environmental, Health and Safety Affairs

Printing Industries of America /Graphic Arts Technical Foundation

412/259-1794

Marcia Y. Kinter

Vice President – Government Affairs and Business Development

Screenprinting and Graphic Imaging Association International

703-359-1313

Doreen Monteleone

Director of Environmental Affairs

Foundation of Flexographic Technical Association

631/737-6020

The following definitions are also offered: 

Lithographic printing is defined as follows: A planographic printing
system where the image and nonimage areas are chemically differentiated;
the image area is oil receptive and nonimage area is water receptive.
Ink film from the lithographic plate is transferred to an intermediary
surface (blanket), which, in turn, transfers the ink film to the
substrate. Fountain solution is applied to maintain the hydrophilic
properties of the nonimage area. Ink drying is divided into heatset and
nonheatset.

Fountain solution is defined as follows:  A mixture of water and other
volatile and non-volatile chemicals and additives that maintains the
quality of the printing plate and reduces the surface tension of the
water so that it spreads easily across the printing plate surface. The
fountain solution wets the nonimage area so that the ink is maintained
within the image areas.  Non-volatile additives include mineral salts
and hydrophilic gums.  Alcohol and alcohol substitutes, including
isopropyl alcohol, glycol ethers, and ethylene glycol, are the most
common VOC additives used to reduce the surface tension of the fountain
solution.

Heatset is defined as follows:  A lithographic web printing process
where heat is used to evaporate ink oils from the printing ink. Heatset
dryers (typically hot air) are used to deliver the heat to the printed
web.

Non-heatset is defined as follows:  A lithographic printing process
where the printing inks are set without the use of heat. Traditional
non-heatset inks set and dry by absorption and/or oxidation of the ink
oils. For the purposes of this rule, ultraviolet-cured and electron
beam-cured inks are considered non-heatset, although radiant energy is
required to cure these inks.

Flexographic printing is defined as follows: A printing system utilizing
a flexible rubber or elastomeric image carrier in which the image area
is raised relative to the nonimage area. The image is transferred to the
substrate through first applying ink to a smooth roller which in turn
transfers the ink onto the raised pattern of the rubber or elastomeric
image carrier fastened around a second roller, which then transfers the
ink onto the substrate.

Rotogravure printing is defined as follows: A printing system utilizing
a chrome plated cylinder where the image area is recessed relative to
the nonimage area. Images are transferred onto a substrate through first
applying ink to a cylinder, which has been etched with small shallow
cells to form a pattern, then wiping the lands between the cells free of
ink with a doctor blade, and finally rolling the cylinder over the
substrate so that the surface of the substrate is pressed into the cells
thus transferring the ink to the substrate.

Screen printing is defined as follows: A printing system where the
printing ink passes through a web or fabric to which a refined form of
stencil has been applied. The stencil openings determine the form and
dimensions of the imprint. 

Digital Printing is defined as follows:  A printing system engaged in
which the image area is created electronically and regenerated for every
single image. The image can either be directly transferred to the
substrate or indirectly transferred through an intermediary system
through digital output devices.

Letterpress printing is defined as follows: A printing system in which
the image area is raised relative to nonimage area and the ink is
transferred to the substrate directly from the image surface.

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