‘rule 1122’ back on the front burner

1
tuckers take W ord on the street is that the South Coast Air Quality Management District (SCAQMD) is considering opening “Rule 1122— Solvent Degreasers.” The primary drivers—my sources tell me—are requests from manufacturers of flu- orinated solvents and the impend- ing production phaseout of HCFC- 225ca/cb 1 in 2015. In short, Rule 1122 covers vapor degreasing and cold cleaning, It per- mits the use of cleaning agents con- taining no more than 25g/L VOC— and that applies to both aqueous and solvent-based cleaners. Conversely, if operators are using cleaning agents exceeding those lim- its, then other methods (namely “air- less” cleaning systems) are required. For finishing shops and captive facilities operating inside and out- side the state of California, discus- sions to open the rule are equally rel- evant. Obviously, if you manufac- ture within the impacted district and have been using the agents and processes outlined Rule 1122, the mandate is clear. But those operat- ing outside of California also stand to be impacted. As we have seen with other regulatory initiatives, environ- mental policies in place in California could be adopted in other parts of the country. Experts in the field of cleaning processes and chemistries view this as a valuable opportunity to get involved. “We highly recommend that [finishers] provide comments now so that SCAQMD can come up with a rule that protects air quality and allows manufacturers to produce quality product for new and future designs,” said Barbara Kanegsberg, principal of Los Angeles-based BFK Solutions, LLC. (see the “On the Surface” column in this issue.) “Are you successfully cleaning with low- VOC, non-HAP options? Let SCAQMD know. Does Rule 1122 stop you from doing manufacturing projects? Tell them.” One vocal critic of Rule 1122 rec- ommends a radical re-thinking. John Durkee, Metal Finishing’s “Cleaning Times” columnist and an independent authority on the sub- ject, suggests that SCAQMD adopt the “European Approach,” (in Europe, all halogenated solvents, except n-propyl bromide, are permit- ted where storage, use, and recovery of solvents is facilitated via automat- ed, fully enclosed machines). “Clearly, it is in the interests of SCAQMD to sponsor with some positive (not punitive) incentives” to make the changeover, Durkee said. At the same time, it is also in the interests of “local operators to use the time between 2012 and 2019 to revise specifications from a require- ment to use HCFC-225ca/cb to another option not threatened by future phaseout.” Both Kanegsberg and Durkee encourage operators to submit their comments directly to SCAQMD by e-mailing Rizaldy Calungcagin ([email protected]) or Mike Morris ([email protected].) REFERENCES 1. HCFC-225ca/cb is a Class II ozone-depleting compound with exception performance attrib- utes. It has been required by spec- ification for use in aerospace, military, and other applications due to its performance. ‘Rule 1122’ Back on the Front Burner July/August 2012 Volume 110 - Number 6 Publisher David Hopwood Editor Reginald Tucker [email protected] Art Director - Production Manager Susan Canalizo-Baruch [email protected] Advertising Sales Manager Arnie Hoffman Ph: (847) 559-0909 E-mail: [email protected] Advertising Sales Reps Donald Moeller 512-585-2391 E-mail: [email protected] Lynne Arons 847-853-7001 E-mail: [email protected] Annabelle Jacobson 847-256-6850 E-mail: [email protected] Gabe Jacobson E-mail: [email protected] Tel: 847-256-6818 Sales Operations Coordinator Eileen McNulty [email protected] Marketing/Circulation Manager Caroline Champney [email protected] Metal Finishing 360 Park Avenue South New York, NY 10010-1710 (212) 633-3100 FAX: (212) 462-1915 Metal Finishing (ISSN 0026-0576) is published 10 times per year in January/February, March, April/May, June, July/August, September, October, November, November/December, and December by Elsevier Inc., 360 Park Avenue South, New York, NY 10010. POSTMASTER: Send all address changes to Metal Finishing P.O. Box 141, Congress, NY 10920-0141. Metal Finishing is free to qualified metal finishers in North America. For others related to the field the subscription rate per year, including a copy of the Metal Finishing Guidebook and Directory Issue” and the Organic Finishing Guidebook and Directory Issue” is: 1-year subs for 2011 USA $123.00 Canada/Mexico $173.00 Europe & Japan $252.00 Rest of World $284.00 Metal Finishing Customer Service, P.O. Box 141, Congers, N.Y. 10920-0141. Toll free (U.S. only): (800) 765-7514. Outside the U.S. call (845) 267-3490, fax (845) 267-3478. E-mail: [email protected]. Periodicals postage paid at New York, N.Y. and at additional mailing offices. Change of Address: Postmaster—send address changes to Metal Finishing, P.O. Box 141, Congers, N.Y. 10920-0141. Toll-free (for U.S. customers) (800) 765-7514. Outside of the U.S. call (845) 267-3490, fax: (845) 267-3478. E-mail: [email protected], 45 days advance notice required. Please include both new and old address. Copyright by Elsevier, Inc. Permission for reprinting selected portions will usually be granted on written application to the publisher. metal finishing www.metalfinishing.com July/August 2012 I metalfinishing I 3

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Page 1: ‘Rule 1122’ Back on the Front Burner

tuckerstakeWord on the street is that the

South Coast Air QualityManagement District (SCAQMD) isconsidering opening “Rule 1122—Solvent Degreasers.” The primarydrivers—my sources tell me—arerequests from manufacturers of flu-orinated solvents and the impend-ing production phaseout of HCFC-225ca/cb1 in 2015.

In short, Rule 1122 covers vapordegreasing and cold cleaning, It per-mits the use of cleaning agents con-taining no more than 25g/L VOC—and that applies to both aqueousand solvent-based cleaners.Conversely, if operators are usingcleaning agents exceeding those lim-its, then other methods (namely “air-less” cleaning systems) are required.

For finishing shops and captivefacilities operating inside and out-side the state of California, discus-sions to open the rule are equally rel-evant. Obviously, if you manufac-ture within the impacted districtand have been using the agents andprocesses outlined Rule 1122, themandate is clear. But those operat-ing outside of California also standto be impacted. As we have seen withother regulatory initiatives, environ-mental policies in place in Californiacould be adopted in other parts ofthe country.

Experts in the field of cleaningprocesses and chemistries view this asa valuable opportunity to getinvolved. “We highly recommend that[finishers] provide comments now sothat SCAQMD can come up with arule that protects air quality andallows manufacturers to producequality product for new and futuredesigns,” said Barbara Kanegsberg,principal of Los Angeles-based BFKSolutions, LLC. (see the “On theSurface” column in this issue.) “Are

you successfully cleaning with low-VOC, non-HAP options? LetSCAQMD know. Does Rule 1122stop you from doing manufacturingprojects? Tell them.”

One vocal critic of Rule 1122 rec-ommends a radical re-thinking.John Durkee, Metal Finishing’s“Cleaning Times” columnist and anindependent authority on the sub-ject, suggests that SCAQMD adoptthe “European Approach,” (inEurope, all halogenated solvents,except n-propyl bromide, are permit-ted where storage, use, and recoveryof solvents is facilitated via automat-ed, fully enclosed machines).

“Clearly, it is in the interests ofSCAQMD to sponsor with somepositive (not punitive) incentives” tomake the changeover, Durkee said.At the same time, it is also in theinterests of “local operators to usethe time between 2012 and 2019 torevise specifications from a require-ment to use HCFC-225ca/cb toanother option not threatened byfuture phaseout.”

Both Kanegsberg and Durkeeencourage operators to submit theircomments directly to SCAQMD bye-mailing Rizaldy Calungcagin([email protected]) or MikeMorris ([email protected].)

REFERENCES1. HCFC-225ca/cb is a Class II

ozone-depleting compound withexception performance attrib-utes. It has been required by spec-ification for use in aerospace,military, and other applicationsdue to its performance.

‘Rule 1122’ Back on the Front Burner

July/August 2012Volume 110 - Number 6

Publisher David Hopwood

EditorReginald Tucker

[email protected]

Art Director - Production ManagerSusan [email protected]

Advertising Sales ManagerArnie Hoffman

Ph: (847) 559-0909E-mail: [email protected]

Advertising Sales RepsDonald Moeller512-585-2391

E-mail: [email protected]

Lynne Arons847-853-7001

E-mail: [email protected]

Annabelle Jacobson847-256-6850

E-mail: [email protected]

Gabe JacobsonE-mail: [email protected]

Tel: 847-256-6818

Sales Operations CoordinatorEileen McNulty

[email protected]

Marketing/Circulation ManagerCaroline Champney

[email protected]

Metal Finishing360 Park Avenue South

New York, NY 10010-1710(212) 633-3100

FAX: (212) 462-1915

Metal Finishing (ISSN 0026-0576) is published 10 times peryear in January/February, March, April/May, June,July/August, September, October, November,November/December, and December by Elsevier Inc., 360Park Avenue South, New York, NY 10010. POSTMASTER:Send all address changes to Metal Finishing P.O. Box 141,Congress, NY 10920-0141. Metal Finishing is free to qualifiedmetal finishers in North America. For others related to thefield the subscription rate per year, including a copy of the“Metal Finishing Guidebook and Directory Issue” and the“Organic Finish ing Guidebook and Directory Issue” is:

1-year subs for 2011

USA $123.00

Canada/Mexico $173.00

Europe & Japan $252.00

Rest of World $284.00

Metal Finishing Customer Service, P.O. Box 141, Congers, N.Y.10920-0141. Toll free (U.S. only): (800) 765-7514. Outsidethe U.S. call (845) 267-3490, fax (845) 267-3478. E-mail:[email protected]. Periodicals postage paid at NewYork, N.Y. and at additional mailing offices.

Change of Address: Postmaster—send address changes to Metal Finishing, P.O. Box 141, Congers, N.Y. 10920-0141.Toll-free (for U.S. customers) (800) 765-7514. Outside of theU.S. call (845) 267-3490, fax: (845) 267- 3478. E-mail:[email protected], 45 days advance notice required.Please include both new and old address.

Copyright by Elsevier, Inc. Permission for reprinting selectedportions will usually be granted on written application to thepublisher.

metal finishing

www.metalfinishing.com July/August 2012 I metalfinishing I 3