SACRAMENTO METROPOLITAN 

AIR QUALITY MANAGEMENT DISTRICT

STAFF REPORT 

Rule 466 – Solvent Cleaning 

August 19, 2010 

Prepared by: Joseph Carle 

Associate Air Quality Engineer

Reviewed by: Kevin J. Williams, Ph.D. 

 Program Coordinator 

 Aleta Kennard 

Program Supervisor

Approved by: Brigette Tollstrup 

Division Manager
Staff Report 

Rule 466, Solvent Cleaning 

August 19, 2010 

Page 2 

BACKGROUND

Ground level ozone is a secondary pollutant formed from photochemical reactions of nitrogen oxides 

(NOx) and volatile organic compounds (VOCs) in the presence of sunlight. Ozone is a strong irritant 

that adversely affects human health and damages crops and other environmental resources. As 

documented by the U.S. Environmental Protection Agency (EPA) in the most recent Criteria 

Document for ozone (U.S. EPA 2006), both short-term and long-term exposure to ozone can irritate 

and damage the human respiratory system, resulting in: 

• decreased lung function; 

• development and aggravation of asthma; 

• increased risk of cardiovascular problems such as heart attacks and strokes; 

• increased hospitalizations and emergency room visits; and 

• premature deaths. 

The District is currently designated as a nonattainment area for both the state and federal ozone 

standards. Because VOC is a precursor to ozone, one of the strategies to control ozone pollution is 

to reduce VOC emissions from existing stationary sources. 

Rule 466 reduces the emissions of VOC from solvent cleaning operations and activities by limiting 

the VOC content of cleaning solvents. VOC emissions are further reduced by work practice 

requirements for the storage and disposal of new and spent cleaning solvents. The rule was first 

adopted on May 23, 2002 and was last amended on September 25, 2008. 

The September 25, 2008 amendments to Rule 466 reduced the allowable VOC content for several 

types of solvent cleaning operations. One of them set a new VOC content limit of 200 grams per liter 

(g/l) for solvent cleaners used in the sterilization of food manufacturing and processing equipment. 

The new VOC limits into effect on September 25, 2009. 

Blue Diamond Growers informed Staff in February 2009 that they would not be able to meet this limit 

without the possibility of causing a food health hazard for their dry food products because they found 

the compliant solvents didn’t meet their sterilization requirements. 

After thorough research and discussions with Blue Diamond Growers and other health experts, Staff 

is proposing an exemption from the VOC content limit for sanitizing products that are labeled and 

applied to food contact surfaces used to process dry and low moisture foods and that are not rinsed 

prior to contact with food. Staff has determined that the previously adopted VOC content limit of 200 

g/L is not feasible for dry food processers. 

LEGAL MANDATES 

Federal Mandates: 

The District is designated as a severe nonattainment area for the federal 8-hour ozone standard. In 

February 2009, the districts of the Sacramento Federal Nonattainment Area adopted an attainment 

plan to achieve the federal 8-hour ozone standard by 2018. The attainment plan includes a 

commitment for the District to achieve 0.593 tons per day of VOC emissions reductions from solvent 

cleaning operations by 2018. 
Staff Report 

Rule 466, Solvent Cleaning 

August 19, 2010 

Page 3 

In September and October of 2008, the District amended nine rules containing requirements for 

solvent cleaning operations: 

• Rule 450 – Graphic Arts Operations 

• Rule 451 – Surface Coating of Miscellaneous Metal Parts and Products 

• Rule 452 – Can Coating 

• Rule 454 – Degreasing Operations 

• Rule 456 – Aerospace Assembly and Component Coating Operations 

• Rule 463 – Wood Products Coatings 

• Rule 464 – Organic Chemical Manufacturing Operations 

• Rule 465 – Polyester Resin Operations 

• Rule 466 – Solvent Cleaning 

The amendments to these rules were estimated to achieve a total of 0.536 tons per day of VOC 

emissions reductions (SMAQMD 2008). Planned amendments to Rule 459 – Automotive, Truck and 

Heavy Equipment Refining Operations, are expected to achieve another 0.18 tons per day of VOC 

emissions reductions from solvent cleaning activities, which will bring the total emissions reductions 

to 0.716 tons per day, exceeding the plan commitment. The 0.005 tons per day of VOC emissions 

reductions that will be lost due the proposed amendments will not cause the total emissions 

reductions from all rule amendments to fall below the plan commitment. 

State Mandates: 

Serious Nonattainment Plan Requirements: The District is designated as a serious nonattainment 

area for the state ozone standard. The California Clean Air Act requires areas with this designation 

to adopt control measures required in sections 40913, 40914, and 40919 of the California Health and 

Safety Code (HSC): 

• HSC Section 40913 requires districts to develop a plan to achieve California’s 

ambient air quality standards by the earliest practicable date. 

• HSC Section 40914(b)(2) requires every nonattainment district that cannot achieve a 

reduction of 5% or more per year in district wide emissions to adopt “every feasible 

measure” to reduce the emission of nonattainment pollutants and their precursors. 

• HSC Section 40919(a)(3) requires districts with serious nonattainment for ozone to 

adopt BARCT for all existing permitted sources. 

The September 25, 2008 amendments to Rule 466, together with the eight other previously 

mentioned rules amended in September and October of 2008, met the commitment of 0.37 tons per 

day of VOC emissions reductions from solvent cleaning operation in the District’s 2003 Triennial 

Report and Plan Revision, and the associated feasible measure and BARCT requirements. The 

VOC emissions reductions achieved by the amendments to these rules were estimated to be 0.536 

tons per day. The 0.005 tons per day of VOC emissions reductions that will be lost due the proposed 

amendments will not cause the total emissions reductions to fall below the plan commitment. Staff 

has determined that it is not feasible to require sanitizers to meet the current VOC limit in dry food 

processing applications where the food contact surface is not rinsed prior to contact with food. 

Therefore, the rule will still meet the state mandates and plan commitment after the proposed 

amendment. 
Staff Report 

Rule 466, Solvent Cleaning 

August 19, 2010 

Page 4 

Transport Mitigation Emission Control Requirements: Districts within the areas of origin of 

transported air pollutants, as identified in HSC Section 70500(c), shall include sufficient emission 

control measures in their attainment plans for ozone adopted pursuant to Part 3, Chapter 10 

(commencing with Section 40910) of Division 26 of the Health and Safety Code, to mitigate the 

impact of pollution sources within their jurisdictions on ozone concentrations in downwind areas 

commensurate with the level of contribution. An upwind district shall comply with the transport 

mitigation planning and implementation requirements set forth in this section regardless of its 

attainment status. 

The September 2008 amendments to Rule 466 met the transport mitigation emission control 

requirements. After the proposed amendment, the rule will still meet these requirements. 

DISCUSSION

Staff has identified an almond producer (Blue Diamond Growers) and an organic spices producer 

operating in Sacramento County where the use of aqueous-based low VOC sanitizers would have 

been required by the 2008 amendment to Rule 466. There have been a number of salmonella 

outbreaks related to dry foods (chocolate, cereal, nuts, and spices) including outbreaks in 2000 

through 2001 and in 2003 through 2004 from raw almonds occurring in the United States and 

Canada (GMA 2009). Another salmonella outbreak occurred in 2009 that was associated with white 

and black pepper produced by a Bay Area facility. As a result of the almond outbreaks, the United 

States Department of Agriculture (USDA) created mandatory quality control requirements to reduce 

the potential for salmonella bacteria in almonds in 2007. The program requires, “handlers must 

subject their almonds to a treatment process or processes that achieve in total a minimum 4-log 

reduction of salmonella bacteria.” A 4-log reduction decreases bacteria by a factor of 10,000. Due to 

the potential of dust and debris from the raw materials being transferred throughout the facility to 

contaminate the product, it is necessary sanitize the processing equipment to maintain a 4-log 

reduction in bacteria. 

Typically, sanitizers for food-contact surfaces are aqueous based. After application to the food 

processing equipment, the sanitizer is rinsed from the surface with water. The rinse water is not 

dried in between cleanings. For many foods, contact with water is not an issue except for dry and 

low- moisture foods, which because of their nature must avoid water contact. Additionally, water that 

collects in the equipment promotes pathogen growth and can damage the equipment. In order for 

dry food manufacturers or processers to use an aqueous based sanitizer, the equipment would need 

to be thoroughly dried before contact with the food. Part 21 of the Code of Federal Regulations, Part 

110, Current Good Manufacturing Practice in Manufacturing, Packing, or Holding Human Food, 

Section 110.35(d)(1) states 

“Food-contact surfaces used for manufacturing or holding low-moisture food shall be 

in a dry, sanitary condition at the time of use. When the surfaces are wet-cleaned, 

they shall, when necessary, be sanitized and thoroughly dried before subsequent 

use.” 

Blue Diamond Growers stated that drying equipment to this level would require an equipment 

teardown and reassembly, which would require a minimum of 8 hours but in many cases would take 

longer to complete. Additionally, wet and dry areas are separated in the facility to avoid potential 

health risks. Teardown, transferring and proper cleaning usually takes up to 1 to 2 days. Because 
Staff Report 

Rule 466, Solvent Cleaning 

August 19, 2010 

Page 5 

most equipment in the facility is sanitized on a daily basis, this method of sanitation would be 

infeasible. 

Most commonly, manufacturers will use a solution with an isopropyl alcohol (IPA) because it 

evaporates quickly and is highly effective in reducing bacteria. A recent study from the University of 

California Davis (Du et al. 2010) compared the effectiveness of sanitizers on dust gathered from an 

almond hulling and shelling facility. The study compared non-aqueous based sanitizer effectiveness 

by comparing quaternary ammonia (AQuat) based sanitizers to a sanitizer that is IPA based with 

small amounts of quaternary ammonium (IPAQuat). The study showed, 

“The introduction of water or AQuat should be restricted in [hulling and shelling] 

facilities where dust cannot be strictly controlled. To avoid the multiplication of 

Salmonella in [hulling and shelling] facilities, AQuats are only appropriate when 

equipment is accessible, complete removal of dust is possible with cleaning, and 

adequate time is available for thorough drying of the equipment...IPAQuat reduced 

Salmonella densities as much as 7 log [colony forming units (CFU) per gram] in 

[hulling and shelling] dust...IPAQuat or other alcohol-based sanitizers may be 

appropriate for in-season (hulling and shelling) facility sanitation programs.” 

The report also shows that concentrations of IPA in the sanitizing solution should be at minimum 

greater than 50% in order to have immediate results for Salmonella reductions greater than 4 log 

CFU/g. If IPA concentrations are less than 50% the sanitizer will not achieve the required bacteria 

reduction. Additionally, the report specifies, “The information should be applicable and useful to the 

nut industry and to other low-moisture foods.” 

According to the information above, the minimum effective sanitizer would consist of 50% isopropyl 

alcohol and 50% water. The VOC content of this solution would be 393 g/L which would violate the 

200 g/L limit for the sterilization of food manufacturing and processing equipment currently in effect 

for Rule 466. 

In 2006, the California Air Resources Board (CARB) proposed a 1% VOC content limit for nonaerosol sanitizers in their consumer products regulation. CARB staff received comments from the 

California Department of Health and Safety, which recommended that CARB staff should exempt 

food surface sanitizers from the VOC limit. As a result, CARB staff agreed with the Department of 

Health and Safety and included an exemption for products which are labeled to be applied to foodcontact surfaces and are not required to be rinsed prior to contact with food. 

District Staff contacted the California Department of Public Health (formerly the Department of Health 

and Safety) for their recommendation on food surface sanitizers. They responded as follows: 

“The Food and Drug Branch [of the California Department of Public Health] would 

recommend similarly to your agency as it did the State Air Resources Board that airdrying sanitizers used by food processers should be exempt from your regulation. 

Numerous dry and low water activity food products are susceptible to contamination 

with salmonella, listeria and other species of pathogenic bacteria. Use of waterbased sanitizers or rinsing with water after sanitation can provide the ideal growing 

environment for these organisms, and once established in a processing facility, can 

lead to adulteration of the feed and eventually an illness outbreak. Use of isopropyl 

alcohol or other sanitizers that air dry are important tools for combating food-borne 
Staff Report 

Rule 466, Solvent Cleaning 

August 19, 2010 

Page 6 

illness.” (Kennelly 2009) 

Based on the information gathered, Staff has determined that subjecting food surface sanitizers that 

air dry to the current VOC limit in Rule 466 and forcing dry food manufacturers and processers to use 

currently available low-VOC sanitizers is infeasible and could create food health risks. 

SUMMARY OF PROPOSED AMENDMENTS 

The proposed amendments to Rule 466 exempt sanitizing products which are labeled and applied to 

food-contact surfaces that are used to process dry and low-moisture food products and are not rinsed 

prior to contact with food from the rule requirements except for the recordkeeping required by Section 

501. Staff has defined a low-moisture food as having a water activity less than 0.85 or other 

applicable standards approved by the Air Pollution Control Officer, California Air Resources Board, 

and U.S. Environmental Protection Agency. The U.S. Food and Drug Administration have not 

formally defined what a low-moisture food is so the industry standard is used as reported by the 

Grocery Manufacturers Association (GMA 2009). The proposed amendments also include a 

definition and test method for water activity. 

 

EMISSIONS IMPACT 

The proposed exemption for Rule 466 will result in loss of 0.005 tons per day of VOC emissions 

reductions that were expected to be achieved when Rule 466, along with eight other rules with 

solvent cleaning requirements, were amended in September and October of 2008. The amendments 

to these rules were estimated to achieve a total of 0.536 tons per day of VOC emissions reductions, 

and due to the proposed exemption to Rule 466, will decrease to 0.531 tons per day. Together with 

VOC emissions reductions that are expected to be achieved by planned amendments to solvent 

requirements in Rule 459 – Automotive, Truck and Heavy Equipment Refining Operations (0.18 tons 

per day), the total VOC emissions reductions from solvent cleaning operations in the District will be 

0.711 tons per day, which will exceed the federal (0.593 tons per day) and state (0.37 tons per day) 

plan commitments. 

COST AND COST EFFECTIVENESS 

The proposed amendments to Rule 466 will not result in any additional costs to owners/operators or 

to the District. 

SOCIOECONOMIC IMPACT ANALYSIS 

California HSC Section 40728.5 requires a district to perform an assessment of the socioeconomic 

impacts before adopting, amending, or repealing a rule that will significantly affect air quality or 

emission limitations. Staff has determined that the proposed amendments to Rule 466 will not 

significantly affect air quality or emission limitations; therefore, a socioeconomic impact analysis is 

not required. 
Staff Report 

Rule 466, Solvent Cleaning 

August 19, 2010 

Page 7 

PUBLIC COMMENTS 

Staff will post a 30-day for the public hearing and will take public comments during that period. The 

public will also have an opportunity to address the SMAQMD Board of Directors during the hearing. 

ENVIRONMENTAL REVIEW AND COMPLIANCE 

Staff finds that the approval of the proposed action is exempt from CEQA under Section 15061(b)(3) 

of the State CEQA Guidelines because it can be seen with certainty that there is no possibility that 

the activity in question may have a significant adverse effect on the environment. Because the lower 

VOC limit was infeasible for dry food manufacturers and processors, the limit was never enforced and 

therefore there will be no environmental impact. 

TABLE OF FINDINGS 

Six required findings: According to Section 40727(a) of the California Health and Safety Code, prior 

to adopting or amending a rule or regulation, an air district’s board must make findings of necessity, 

authority, clarity, consistency, non-duplication, and reference. The findings must be based on the 

following: 

1. Information presented in the District’s written analysis, prepared pursuant to Health and 

Safety Code Section 40727.2; 

2. Information contained in the rulemaking records pursuant to Section 40728 of the California 

Health and Safety Code; and 

3. Relevant information presented at the Board’s hearing for the rule. 

The table below sets the finding and the basis for making the finding. 

FINDING FINDING DETERMINATION 

Authority: The District must find that a provision of 

law or of a state or federal regulation permits or 

requires the District to adopt, amend, or repeal the 

rule. 

The District is authorized to adopt rules and regulations 

by California Health and Safety Code, Sections 40001, 

40702, 40716, and 41010. [Health and Safety Code 

Section 40727(b)(2)]. 

Necessity: The District must find that the 

rulemaking demonstrates a need exists for the rule, 

or for its amendment or repeal. 

It is necessary for the District to amend Rule 466 to exempt 

sanitizers used in dry food processing applications. [HSC 

Section 40727(b)(1)]. 

Clarity: The District must find that the rule is written 

or displayed so that its meaning can be easily 

understood by the persons directly affected by it. 

The District has reviewed the proposed rule and 

determined that it can be understood by the affected 

parties. In addition, the record contains no evidence that 

people directly affected by the rule cannot understand the 

rule. [HSC Section 40727(b)(3)]. 

Consistency: The rule is in harmony with, and not 

in conflict with or contradictory to, existing statutes, 

court decisions, or state or federal regulations. 

The District has found that the proposed rule does not 

conflict with, and is not contradictory to, existing statutes, 

court decisions, or state or federal regulations. [HSC 

Section 40727(b)(4)]. 
Staff Report 

Rule 466, Solvent Cleaning 

August 19, 2010 

Page 8 

FINDING FINDING DETERMINATION 

Non-Duplication: The District must find that either: 

1) The rule does not impose the same requirements 

as an existing state or federal regulation; or (2) that 

the duplicative requirements are necessary or proper 

to execute the powers and duties granted to, and 

imposed upon the District. 

The District has found this proposed rule does not 

duplicate any existing state or federal regulations [HSC 

Section 40727(b)(5)]. 

Reference: The District must refer to any statute, 

court decision, or other provision of law that the 

District implements, interprets, or makes specific by 

adopting, amending or repealing the rule. 

California Clean Air Act of 1988 (California Health and 

Safety Code Section 40914); California Health and Safety 

Code Sections 40910, 40913, 40914, 40919(a)(3); Section 

70500(c); Sections 70500, 70600, and 70601 of Title 17 of 

the California Code of Regulations; Sections 182(c), 

182(d), and 182(f) of the Federal Clean Air Act 

Amendments of 1990. 

Additional Informational Requirements: In 

complying with HSC Section 40727.2, the District 

must identify all federal requirements and District 

rules that apply to the same equipment or source 

type as the proposed rule or amendments. 

Sources regulated by Rule 466 are not regulated by federal 

requirements but are subject to District rules 201 and 202. 

[Health and Safety Code Section 40727.2(g)]. 

REFERENCES 

Grocery Manufacturers Association (GMA), “Control of Salmonella in Low-Moisture Foods,” February 4, 

2009. 

Kennelly, Pat, California Department of Public Health. “RE: SMAQMD food surface sanitizer VOC 

limits,” Email to Joseph Carle. June 6, 2009. 

Sacramento Metropolitan Air Quality Management District (SMAQMD), “Staff Report for Amendments 

to Rule 450 – Graphic Arts Operations, Rule 451 – Surface Coating of Miscellaneous Metal Parts and 

Products, Rule 452 – Can Coating, Rule 454 – Degreasing Operations, Rule 456 – Aerospace 

Assembly and Component Coating Operations, Rule 463 – Wood Products Coatings, Rule 464 – 

Organic Chemical Manufacturing Operations, Rule 465 – Polyester Resin Operations, and Rule 466 

– Solvent Cleaning,” August 25, 2008. 

U.S. Department of Agriculture, “Almonds Grown in California; Outgoing Quality Control 

Requirements,” Code of Federal Regulations Title 7 Part 981. 

U.S. Food and Drug Administration, “Current Good Manufacturing Practice In Manufacturing, 

Packing, or Holding Human Food,” Code of Federal Regulations Title 21 Part 110. 

Wen-Xian Du, Michelle D. Danyluk, and Linda J. Harris, “Efficacy of Aqueous and Alcohol-Based 

Quaternary Ammonium Sanitizers for Reducing Salmonella in Dusts Generated in Almond Hulling 

and Shelling Facilities,” Journal of Food Science, Vol. 75, November 1, 2010, Pg. M7 – M13 

Wen-Xian Du, Michelle D. Danyluk, and Linda J. Harris, “Evaluation of Cleaning Treatments for AlmondContact Surfaces in Hulling and Shelling Facilities,” Food Production Trends, September 2007, Pg. 678 – 

683
Staff Report 

Rule 466, Solvent Cleaning 

August 19, 2010 

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APPENDIX A 

SUMMARY OF PROPOSED AMENDMENTS 

NEW 

SECTION 

NUMBER

EXISTING 

SECTION 

NUMBER PROPOSED CHANGES 

110.3.c N/A Added an exemption from VOC content limits for sanitizers which are 

labeled and applied to food-contact surfaces that are used to process 

dry and low-moisture food products and are not rinsed prior to contact 

with food. 

224 N/A Added definition of low-moisture food, consistent with the GMA 2009 

report. 

225-250 224-249 Sections renumbered. 

251 N/A Added definition of water activity consistent with 21 CFR 110.3(r) 

252-253 250-251 Sections renumbered. 

502.6 N/A Added Food and Drug Administration test method for determining water 

activity in food. 

502.7 502.6 Section renumbered.