No new emissions limits for metal product manufacturers

Nov 06, 2023

Manufacturers of metal products that were watching to see if the Environmental Protection Agency was going to require more extensive emissions control for companies that paint products or strip painted products can rest easy knowing that the changes aren't likely to happen. Nordroden/iStock/Getty Images Plus

After a just-completed review, the Environmental Protection Agency (EPA) decided to make only minor changes to air emission standards for metal product manufacturers that do surface coating and paint stripping.

The agency did make some changes in the relevant Clean Air Act standards, including adding electronic reporting provisions, simplifying the petition for exemption process, and clarifying requirements for addressing emissions during periods of startup, shutdown, and maintenance (SSM). (With SSM events, the EPA decided not to establish a separate standard for equipment malfunction events.) The final rule went into effect on Nov. 10.

The end result could have been worse for surface coaters of metals because the environmental group Earthjustice and others, such as California Communities Against Toxics, pressed the EPA to expand the hazardous air pollutants (HAPs) it has emission standards for. Both organizations wanted the HAPs standards to cover polycyclic organic matter, which consists of a range of chemical compounds, including polycyclic aromatic hydrocarbons such as naphthalene. Additionally, those groups wanted the EPA to tighten emission standards for metal product companies from the currently used generally available control technologies (GACT), or management practices, which are prescribed for "area sources," emissions equipment typically used by smaller companies with lower emissions, and upgrade them to those for "major sources," called maximum achievable control technology standards. In both instances the EPA declined to do so. The source categories covered by the GACT standards currently include approximately 40,000 facilities.

The current area source emission standards apply to companies manufacturing such items as automobile parts, metal pipes, containers, and bridge components. It also covers job shops, which serves those manufacturing sectors and others that the EPA says are affected. The primary hazardous air pollutant emitted from paint stripping operations is methylene chloride (MeCl), and the GACT standard says that evaporative losses have to be minimized. If those emissions exceed 1 ton/year, the company must develop and implement a written MeCl minimization plan which looks at alternative on-site stripping methods.

The primary HAPs emitted from surface coating operations are compounds of cadmium, chromium, lead, manganese, and nickel from heavy metals contained in coatings. Manufacturers must apply the coatings with a high-volume, low-pressure (HVLP) spray gun, electrostatic spray gun, airless spray gun, air-assisted airless spray gun, or a spray gun demonstrated to be equal in transfer efficiency to an HVLP spray gun. Sources are required to demonstrate that:

The Occupational Safety and Health Administration (OSHA) is considering the paperwork burdens posed by its welding, cutting, and brazing standard.

The standard requires inspection of welding equipment, certification of safety of the equipment, and maintenance of records and training of employees. Those records must be available to employees and OSHA inspectors.

OSHA wants input from the industry before it asks the White House Office of Management and Budget to approve renewal of the standard. This is an opportunity for affected companies to weigh in, if they choose, on such things as whether the welding safety standards are even necessary and, if they are, whether manufacturers subject to the welding standard agree with the quality, utility, and clarity of the information collected.

Comments can be sent directly to the agency via www.regulations.gov. Plug in the docket number—OSHA-2010-0037—and leave your comment.