Specialty Graphic Imaging Association 

1001 5 Main Street, Fairfax, Virginia 22031-3489 USA 

703.385.1335 ·703.273.0456 (fax) 

SG IA.org • sgia@sg ia org 

January 21, 2010 

Ms. Deborah Rabin 

Regulations Coordinator 

Air and Radiation Management Administration 

Department of the Environment 

1800 Washington Boulevard 

Suite 730 

Baltimore, MD 21230-1720 

Dear Ms. Rabin, 

The Specialty Graphic Imaging Association (SGIA), representing the interests of 

facilities engaged in the use of screen printing and wide format digital imaging and their 

associated supplier base, submits the following comments to the draft revisions to 

COMAR 26.11.19.09-01, Control ofVOC Emission from Industrial Solvent Cleaning 

Operations other than Cold and Vapor Degreasing. 

We support the Department's decision to exempt industrial categories with specific 

requirements for cleaning solvents from this rulemaking. However, SGIA opposes the 

implementation of the limit of 50 grams VOC per liter to digital printing operations. We 

believe that the provisions contained in 26.11 .19.18 (F) includes the use of cleaning 

solvents by digital printing operations, therefore, digital operations should be exempted 

from this proposed regulation. 

While the current regulatory language does not specifically reference cleaning materials, 

the language clearly states: 

"General Requirements for Digital Imaging. A person who owns or operates digital 

imaging that is subject to this regulation may not cause the discharge of VOC emissions 

into the atmosphere in excess of 100 pounds on any day from all digital printing at the 

premises." 

Digital printing activities does include cleaning of the equipment, therefore, cleaning 

solvents are already regulated by the State. 

Due to the low applicability threshold proposed, this rule will impact more than the 19 

facilities as depicted in Appendix D, Number of non attainment facilities organized by 

State, that are estimated to meet the applicability criteria recommended in the CTG. 

There are over 200 facilities operating in the state of Maryland with digital capabilities 

Leading a New Generation of Imaging Professionals 
are small 

When for Industrial Solvents was drafted, the 

did not sectors. 

And, when finally industry 

and 

as 

information currently available to 

to a upon the 

50 grams limit was proposed by on a 

cleaning operations: spray gun cleaning, spray booth cleaning, 

components, parts _~'U",..." equipment 

cleaning, and manufactured components 

a study in 1994. Since 

must review the as they 

2006, and the 

developing the 2006 

Bay Air Quality 

solvent only 

to environmental controls. promulgation 

regulatory should allow an industry sector to use the are 
technologically compatible with their manufacturing process. The comments we offer 

seek to explore alternative means to promulgate this regulation that will result in 

environmental benefit without sacrificing an entire industrial sector. 

SGlA proposes that Section (A)(6)(b) be expanded to include digital printing operations. 

Digital printing was not recognized by the US EPA as a source category for 

implementation of this CTG. 

Conclusion 

The intent of the US EPA's Control Technique Guideline for Industrial Cleaning 

Solvents was to provide States with guidance on how to develop effective regulations for 

a variety of industrial sectors using cleaning solvents. It was not a document that 

mandated that only one VOC limit be established. 

SGlA believes that the Maryland Department of the Environment does indeed have the 

authority and flexibility to craft a regulation that will not only reduce air emissions, but 

allow industrial sectors to use cleaning solvents that are technologically feasible. Before 

moving forward to finalize this rule, the Agency needs to craft a regulation that does not 

economically cripple an entire industry sector. 

Thank you for the opportunity to comment on this important rulemaking. If you have any 

questions regarding these comments or if you would like to further discuss, please do not 

hesitate to contact me directly. 

Sincerely, 

Vice President-Government & Business Information