See the latest EHS federal and state regulatory updates due to COVID-19

Many of the rules that South Coast Air Quality Management District (SCAQMD) proposed to pass or update are being pushed out to 2021. For the remainder of this year, the regulatory forecast includes the following key rules that will be adopted and amended:

November 2020

  • Rule 218/218.1 - Continuous Emission Monitoring and Performance Specifications
  • Rule 218.2/218.3 - Enhanced Requirements for Continuous Emission Monitoring Systems and Performance Specifications
  • Rule 1407.1 - Control of Toxic Air Contaminant Emissions from Chromium Alloy Melting Operations

December 2020

  • Rule 442.1 - Usage of Solvent
  • Rule 1107 - Coating of Metal Parts and Products
  • Rule 1124 - Aerospace Assembly and Component Manufacturing Operations
  • Rule 1136 - Wood Products Coatings
  • Rule 1145 - Plastic, Rubber, Leather, and Glass Coatings
  • Rule 1147 - NOx Reductions from Miscellaneous Sources
  • Rule 1171 - Solvent Cleaning Operations

Of those listed, one of the most interesting rules will be Rule 442.1. The existing Rule 442 is a “catch-all” rule that regulates emissions from any material not subject to Regulation XI. Rule 442.1 will change the types of coatings and solvents that facilities can purchase and use by completely prohibiting the sale, distribution, and use of any materials that do not meet Regulation XI volatile organic compound (VOC) limits. Regulation XI rules may also include circumvention provisions to prevent these materials from being used.

What does this mean? If your facility uses VOC-containing materials, review your inventory and assess which materials are compliant with Regulation XI, and which are above respective VOC limits. If you are using high-VOC materials because of exemptions based on usage limits, compliance date implementation, or other criteria, be aware that Rule 442.1 may impact your facility.

At the time of this article, SCAQMD staff has not initiated rulemaking efforts. Rule 442.1 was scheduled to be adopted in summer 2020, but adoption is being moved to December 2020 per recent communications with SCAQMD.

The amendments to Rule 1147, which affect many combustion sources such as oxidizers and ovens, have also been pushed back to December 2020. For more info on these changes and the potential capital projects they will likely bring, please see our article published last month.

For questions about any of the rule changes, please email Marcos Moral or call 949.567.9880.