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Clean Chat: Ozone - Regional Rule, National Impact
Air currents migrate, so poor air quality in one state inevitably impacts the air in another state—which is why Congress established the Ozone Transport Commission (OTC).
The OTC is an advisory/regulatory consortium that covers Northeast and Mid-Atlantic states. The commission is tasked with addressing the problem of ground-level ozone. The manufacturing community is tasked with producing high quality product in a cost-effective manner while minimizing hazards to workers, to communities, and to the global environment. While some product can be manufactured with little or no cleaning, critical cleaning requirements have, in general, increased over the past decade.
The EPA has tightened national air standards; more areas do not meet the requirements for Volatile Organic Compounds (VOCs). In response, the OTC is developing a Model Rule to reduce VOC emissions from vapor degreasing and cold cleaning. In its current draft form, the Model Rule draws heavily from two Southern California regulations. The draft model rule includes requirements to use cleaning agents that are below 25 g/L VOC or, alternatively, conduct the process in well-contained airless systems. If individual states adopt the rule, many critical and industrial cleaning processes, both aqueous and solvent, would have to change, and both chemical and process options would be restricted.
Based on our experience, including observations of cleaning processes in Southern California, such restrictions are likely to have a negative impact on product quality and performance, manufacturing costs and customer satisfaction.
The OTC has asked for industry input. As of late May 2011, the commission had posted almost 30 thoughtful written comments. Some were from manufacturers of cleaning agents and cleaning equipment or from related advocacy groups. Many were concerned about assuring that their product or technology would continue to be available to you, the manufacturer. There were comments from aerospace, medical device manufacture, those involved in maintenance and repair and consultants (including us).
We participated in an April 26 teleconference that included 15 OTC participants and 12 stakeholders. In the regulatory world, “stakeholder” means people or groups who would be affected by new regulations or regulatory policy, including those who actually manufacture product. Some voiced concern about potential impact on manufacturing options and about the negative economic impact of a very similar regulation on California manufacturing. While it would be outside the scope of the Congressional mandate to the OTC, several people urged additional wording in the rule making mention of the toxicity of some VOC-exempt chemicals in order to avoid potential unintended consequences.
It appears to us that OTC members might benefit from even more information, particularly from people who are cleaning and manufacturing product. “Cold cleaning” encompasses not only sink-on-a-drum processes used in automotive repair facilities, but also critical, precision processes. One example is defluxing (cleaning) of electronics assemblies. Many electronics assemblies use no-clean (low residue) or water soluble fluxes, so cleaning has not been an issue.
However, within the last few years, the development of densely populated boards with high-performance requirements means that more and more manufacturers are needing to deflux. This includes use of products, both aqueous and solvent, that may have significantly higher than 25 g/L VOCs, using in-line cleaning systems. Therefore, during the call, we gave a brief introduction to in-line cleaning and the challenges of adapting large-scale defluxing systems to airless or airtight requirements.
Many critical cleaning applications, possibly including those you use, would be restricted if the model rule were to be adopted. If you are not certain about the VOC content of your cleaning agent, consider this an opportunity to ask your chemical supplier.
The current model rule provides for certain exemptions and these exemptions are largely drawn from Southern California regulations. Many reflect requirements of the manufacturing mix of the late 1990s, not the performance requirements and product mix of the current decade. Telling regulators that nothing can replace the currently used high-VOC chemicals and processes or that civilization will cease if the process is changed may not be effective. A rational, data-based explanation of requirements is more likely to result in relevant exemptions.
Cleaning chemicals and processes represent a fragmented market. There are many technical variables in critical cleaning such as materials of construction, process flow and end-use requirements. Even two similar products may require different sorts of cleaning. Therefore, looking at one cleaning process is like looking at a close-up of a few tiles in a mosaic; it is necessary to understand the scope and arrangement of many tiles to gain a clear, complete image. In order for the OTC to develop an optimal model rule, one that will be protective of air quality and allow productive manufacturing, they need to understand the complex mosaic that constitutes cleaning and manufacturing. People in the manufacturing community are in a good position to help them.