After several meetings and exchanges of correspondence, the New York State Department of Environmental Conservation (NYSDEC) issued a letter to PRINTING United Alliance on July 6, 2021, providing much needed guidance on how stand-alone press cleaning machines will be regulated under the NYSDEC code. The discussions and request for clarification were prompted by the final volatile organic compound (VOC) limits for cold cleaning degreasing (e.g., parts washers) that take effect in December 2021.
The equipment in question is commonly found in screen, flexographic, and rotogravure operations and used to clean screens, flexographic plates, flexographic plates mounted to cylinders, anilox rolls, ink, and press components such as coating application components, ink, and coating trays, etc. When PRINTING United opened discussions with the NYSDEC, their initial impression was that the VOC limits for cold cleaning degreasing units would apply to this equipment. The problem with the limit for the cold cleaning degreasing units is the VOC content limit could not be met, thus making all this equipment that provides production efficiency obsolete.
PRINTING United’s goal was to demonstrate to the NYSDEC that the cleaning equipment was subject to the requirements as specific in their regulation covering printing operations (Rule 234) and not the cold cleaning degreasing regulation. Information was presented to the NYSDEC that clearly indicated the equipment under discussion is integral to the production process and was not used in the same manner as a cold cleaner degreaser.
The letter by the NYSDEC clearly states that the cleaning equipment discussed is covered by the regulation limiting VOC emissions from printing operations (Rule 234). This is significant as it means covered printing operations can still use this vital cleaning equipment and maintain their elevated levels of productivity.
PRINTING United Alliance has prepared a fact sheet that has more details about the letter and the regulatory requirements.