EPA-453/R-06-002 

September 2006 

Control Techniques Guidelines for Offset 

Lithographic Printing and Letterpress Printing 

 
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EPA 453/R-06-002 

September 2006 

Control Techniques Guidelines for 

Offset Lithographic Printing and 

Letterpress Printing 

Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

RTP, NC
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TABLE OF CONTENTS 

I. Introduction..................................................................................Page 1 

 II. Background and Overview ..........................................................Page 2 

III. Applicability ................................................................................Page 3 

IV. Process Description and Sources of VOC Emissions..................Page 6 

 A. Offset Lithography 

1. Inks 

2. Fountain Solution 

3. Cleaning Materials 

 B. Letterpress Printing 

1. Inks 

2. Cleaning Materials 

V. Available Control Options ...........................................................Page 9 

A. Inks 

B. Fountain Solution 

C. Cleaning Materials 

D. Existing State and Local Regulations 

VI. Recommended Control Options...................................................Page 13 

A. Heatset Web Offset Lithographic and Heatset Letterpress Inks and 

Dryers 

B. Fountain Solution 

C. Cleaning Materials 

VII. Cost Effectiveness of Recommended Control Options ...............Page 17 

VIII. Factors to Consider in Determining VOC Emissions from Offset 

Lithographic Printing and Letterpress Printing ...........................Page 18 

A. Ink Oil Retention 

B. Retention of Low VOC Composite Vapor Pressure Cleaning 

Materials in Shop Towels 

C. Carryover of VOC from Automatic Blanket Wash and Fountain 

Solution to Offset Lithographic Heatset Dryers 

D. Capture of Petroleum Ink Oil in Heatset Dryers 

E. Methods 25 and 25A 

IX. References....................................................................................Page 21 
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TABLE OF CONTENTS (continued)

Appendix A 

 Access to 1993 draft CTG, 1994 ACT, and 2005 TSD ..............Page 22 

 

 

Appendix B 

 State and Local Regulations for Offset Lithographic Printing ....Page 24 

 Agency, Rule Number and Applicability 

 Fountain Solution Limits 

Appendix C 

State and Local Regulations for Letterpress Printing .................Page 36 

Appendix D 

Estimated Costs Associated with the Recommendations Contained in the 

Control Techniques Guideline for Offset Lithographic Printing and 

Letterpress Printing......................................................................Page 38 
I. Introduction

 Clean Air Act (CAA) section 172(c)(1) provides that state implementation plans 

(SIPs) for nonattainment areas must include “reasonably available control measures” 

(RACM), including “reasonably available control technology” (RACT), for sources of 

emissions. Section 182(b)(2) provides that for certain nonattainment areas, States must 

revise their SIPs to include RACT for sources of VOC emissions covered by a control 

techniques guidelines (CTG) document issued after November 15, 1990 and prior to the 

area’s date of attainment. 

 The United States Environmental Protection Agency (EPA) defines RACT as “the 

lowest emission limitation that a particular source is capable of meeting by the 

application of control technology that is reasonably available considering technological 

and economic feasibility.” 44 FR 53761 (Sept. 17, 1979). In subsequent Federal 

Register notices, EPA has addressed how states can meet the RACT requirements of the 

Act. 

 CAA section 183(e) directs EPA to list for regulation those categories of products 

that account for at least 80 percent of the VOC emissions, on a reactivity-adjusted basis, 

from consumer and commercial products in areas that violate the NAAQS for ozone (i.e., 

ozone nonattainment areas). EPA issued the list on March 23, 1995, and has revised the 

list periodically. See 60 FR 15264 (March 23, 1995); see also 71 FR 28320 (May 16, 

2006), 70 FR 69759 (Nov. 17, 2005); 64 FR 13422 (Mar. 18, 1999). Offset lithographic 

printing and letterpress printing are included on the current section 183(e) list. 

 This CTG addresses both the offset lithographic printing industry and the 

letterpress printing industry. Although offset lithographic printing and letterpress 

printing are two distinct product categories on the section 183(e) list, they have many 

similarities in the types of inks and cleaning materials used, the sources of VOC 

emissions, and the controls available to address those emissions. We therefore address 

both categories in this CTG. 

 The CTG is intended to provide state and local air pollution control authorities 

information that should assist them in determining RACT for volatile organic compounds 

(VOCs) for offset lithographic printing and letterpress printing. In developing this CTG, 

EPA, among other things, evaluated the sources of VOC emissions from these printing 

industries and the available control approaches for addressing these emissions, including 

the costs of such approaches. Based on available information and data, EPA provides 

recommendations for RACT for offset lithographic printing and letterpress printing. 

 States can use the recommendations in this CTG to inform their own 

determination as to what constitutes RACT for VOCs for offset lithographic printing and 

letterpress printing in their particular nonattainment areas. The information contained in 

this document is provided only as guidance. This guidance does not change, or substitute 

for, applicable sections of the CAA or EPA’s regulations; nor is it a regulation itself. 

This document does not impose any legally binding requirements on any entity. It 
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provides only recommendations for state and local air pollution control agencies to 

consider in determining RACT. State and local pollution control agencies are free to 

implement other technically-sound approaches that are consistent with the CAA and 

EPA’s implementing regulations. 

 The recommendations contained in this CTG are based on data and information 

currently available to EPA. These general recommendations may not apply to a 

particular situation based upon the circumstances of a specific source. Regardless of 

whether a State chooses to implement the recommendations contained herein through 

State rules, or to issue State rules that adopt different approaches for RACT for VOCs for 

offset lithographic printing and letterpress printing, States must submit their RACT rules 

to EPA for review and approval as part of the SIP process. EPA will evaluate the rules 

and determine, through notice and comment rulemaking in the SIP process, whether they 

meet the RACT requirements of the Act and EPA’s regulations. To the extent a State 

adopts any of the recommendations in this guidance into its State RACT rules, interested 

parties can raise questions and objections about the substance of this guidance and the 

appropriateness of the application of this guidance to a particular situation during the 

development of the State rules and EPA’s SIP approval process. 

 CAA section 182(b)(2) provides that a CTG issued after November 15, 1990 and 

before the date of attainment must include the date by which States must submit SIP 

revisions in response to the CTG. States subject to section 182(b) should submit their 

SIP revisions within one year of the date of issuance of this final CTG. States subject to 

CAA section 172(c)(1) may take action in response to this guidance, as necessary to 

attain. 

II. Background and Overview

 On November 8, 1993, EPA published a draft CTG for offset lithographic 

printing. (58 FR 59261). After reviewing comments on the draft CTG and soliciting 

additional information to help clarify those comments, EPA published an alternative 

control techniques (ACT) document in June 1994 that provided supplemental information 

for States to use in developing rules based on RACT for offset lithographic printing. See 

References 1 and 2 in the reference section for the full citation to these documents. 

 The 1993 draft CTG and 1994 ACT (see Appendix A) provide a thorough 

discussion of the offset lithographic printing industry, the nature of VOC emissions from 

that industry, available control technologies for addressing such emissions, the costs of 

available control options, and other items. In large part, the recommended approaches for 

RACT in this document are similar to those proposed in 1993. EPA developed the 

recommended approaches contained in this document after reviewing existing state and 

local VOC emission reduction approaches, reviewing the 1993 draft CTG and 1994 ACT, 

and considering information obtained since issuance of the ACT. 

 As noted above, letterpress printing and offset lithographic printing have several 

important similarities, including similar sources of VOC emissions and similar available 
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VOC control approaches. In light of these similarities, EPA relied heavily on the 

substantial data and information included in the 1993 draft CTG and 1994 ACT for offset 

lithographic printing in formulating the recommendations for RACT in this document for 

the letterpress printing industry. 

 The remainder of this document is divided into seven sections. Section III 

describes the scope of sources to which this CTG applies. Section IV provides a 

summary of the processes associated with the offset lithographic printing and letterpress 

printing industries and identifies the sources of VOC emissions from those processes. 

Section V describes the available control approaches for addressing VOC emissions from 

this source category and summarizes state and local regulatory approaches for addressing 

such emissions. Section VI provides our recommendations for RACT for offset 

lithographic printing and letterpress printing. Section VII discusses the cost-effectiveness 

of the recommended control approaches. Section VIII presents factors to consider in 

assessing VOC emissions from offset lithographic printing and letterpress printing. 

References are provided in Section IX. 

III. Applicability

This CTG provides control recommendations for reducing VOC emissions 

stemming from the use of fountain solutions, cleaning materials and inks in offset 

lithographic printing and cleaning materials and inks in letterpress printing. This section 

addresses EPA’s recommendations as to the scope of entities to which the RACT 

recommendations in this CTG should apply. As explained above, this document is 

guidance and provides information for States to consider in determining RACT. When 

State and local pollution control agencies develop RACT rules, they may elect to adopt 

control approaches that differ from those described in this document and/or promulgate 

applicability criteria that differ from those recommended here. 

In terms of applicability, we recommend that the control recommendations 

discussed in this CTG for cleaning materials and fountain solutions apply to any offset 

lithographic printing operation where the emissions associated with all aspects of that 

operation equal or exceed 6.8 kg/day (15 lb/day) actual emissions of VOC, or an 

equivalent level, before consideration of controls.1

 As noted below, the cleaning control 

approaches recommended in this CTG include limitations on the VOC composite vapor 

pressure of cleaning materials and limits on the VOC content of cleaning materials, with 

an exclusion of 110 gallons per year of cleaning materials which meet neither the low 

VOC composite vapor pressure recommendation nor the lower VOC content 

recommendation, and work practices. We further recommend that the recommendations 

concerning fountain solution, which are described in detail below, not be applied to 

sheet-fed presses with maximum sheet size 11x17 inches or smaller, or to any press with 

 

1

 “Lithographic printing” means a printing process where the image and non-image areas are chemically 

differentiated; the image area is oil receptive and the non-image area is water receptive. This method differs 

from other printing methods, where the image is a raised or recessed surface. “Offset lithographic printing” 

means a printing process that transfers the ink film from the lithographic plate to an intermediary surface 

(blanket), which, in turn, transfers the ink film to the substrate. 
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total fountain solution reservoir of less than 1 gallon because for these presses. EPA 

recommends these exclusions because the recommended VOC (alcohol or alcohol 

substitute) content levels associated with such presses would yield a small emission 

reduction relative to the cost of achieving that reduction (e.g., changing and maintaining 

rollers). 

Similarly, we recommend that the control approaches for cleaning materials 

discussed in this CTG apply to any letterpress printing operation where the emissions 

associated with all aspects of that operation equal or exceed 6.8 kg/day (15 lb/day) actual 

emissions of VOC, or an equivalent level, before consideration of controls.2 As noted 

below, these control recommendations include limitations on the VOC composite vapor 

pressure of cleaning materials and limits on the VOC content of cleaning materials, with 

an exclusion of 110 gallons per year of cleaning materials which meet neither the low 

VOC composite vapor pressure recommendation nor the lower VOC content 

recommendation, and work practices. 

In developing their RACT rules, State and local agencies should consider 

carefully the facts and circumstances of the affected sources in their States. As noted 

above, States can adopt the above recommended 15 lb/day actual emissions of VOC 

applicability criterion before consideration of controls, or an equivalent applicability 

level expressed on a monthly basis (e.g., 450 lb/month) or 12-month rolling basis (e.g., 3 

tons per 12-month rolling period), or they can develop other applicability criteria that 

they determine are appropriate considering the facts and circumstances of the sources in 

their particular nonattainment areas. EPA will review the State RACT rules in the 

context of the SIP revision process. 

The above recommended 15 lb/day threshold is consistent with the applicability 

threshold contained in many previous CTGs.3

 It is also consistent with the purpose of the 

section 183(e) program. In section 183(e), Congress directed EPA to assist States in 

achieving VOC emission reductions from consumer and commercial products. These 

products individually may result in relatively small amounts of VOC emissions, but, in 

the aggregate, they contribute significantly to ozone formation in nonattainment areas. 

Given the nature of the products and sources at issue here, we believe that the 15 lb/day 

actual VOC emissions before consideration of controls applicability threshold or 

equivalent is appropriate for offset lithographic printing and letterpress printing materials. 

For purposes of determining whether the recommended 15 lb/day actual VOC 

emissions applicability threshold or an equivalent threshold is met at a given facility, we 

recommend that an offset lithographic printer consider emissions from all offset 

 

2

 “Letterpress printing” means a printing process in which the image area is raised relative to the nonimage area and the paste ink is transferred to the substrate directly from the image surface. 

3

 - See. e.g., Model Volatile Organic Compound Rules for Reasonably Available Control Technology: 

Planning for Ozone Nonattainment Pursuant to Title I of the Clean Air Act, dated June 1992 (establishing 

the 15 lb of VOC per day applicability threshold for coating applications for eleven industries, including, 

automobile and light duty truck coating operations and coating of cans, coil, paper, fabric, vinyl, metal 

furniture, large appliances, magnet wire, miscellaneous metal parts, and flat wood paneling). 
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lithographic printing operations, including related cleaning activities at the facility prior 

to controls. Similarly, we recommend that a letterpress printer should consider emissions 

from all letterpress printing operations, including related cleaning operations at the 

facility prior to controls, in evaluating whether the 15 lb/day actual emissions 

applicability threshold or an equivalent threshold has been met. 

We recommend a different applicability threshold for the RACT 

recommendations in this CTG relating to heatset web offset lithographic printing and 

letterpress printing operations. Specifically, we recommend applying the add-on control 

recommendations for heatset web offset lithographic printing operations and heatset web 

letterpress printing operations only to those presses with potential to emit from the dryer, 

prior to controls, of at least 25 tpy of VOC (petroleum ink oil) from heatset inks. We 

recommend providing printers with the option of using an enforceable limitation on 

potential emissions to keep an individual press below this 25 tpy potential to emit 

threshold. Guidance on limiting potential to emit from printing operations is provided in 

the Technical Support Document (TSD) for Title V Permitting of Printing Facilities (see 

Appendix A). We believe add-on control for heatset presses with potential to emit below 

25 tpy is too costly for the emission reduction that would be achieved. 

 We also recommend excluding heatset presses used for book printing and 

excluding heatset presses with maximum web width of 22 inches or less from the add-on 

control recommendations. We believe add-on control for such heatset presses is too 

costly for the emission reduction that would be achieved. 

 We estimate that there are approximately 6,700 offset lithographic printing 

facilities in current ozone nonattainment areas that meet the 15 lb/day actual VOC 

emissions (before controls) applicability threshold described above. We derived this 

number based on available information concerning the offset lithographic printing 

industry. Specifically, in the 1993 draft CTG, we estimated that, as of the early 1990s, 

there were approximately 34,500 offset lithographic printing facilities in ozone 

nonattainment areas. We have information concerning the percentage of the U.S. 

population residing in nonattainment areas in the 1990 and 2000 Census. We believe it is 

reasonable to use these population figures to estimate the number of offset lithographic 

printing facilities in current nonattainment areas (i.e., areas based on the April 2004 

designations). Specifically, given the percentage of U.S. population in ozone 

nonattainment areas in 1993, and the percentage of U.S. population in ozone 

nonattainment areas today, we estimate that 30,500 offset lithographic printing facilities 

are located in current ozone nonattainment areas. In the 1993 draft CTG, 78 percent of 

the model facilities emitted less than 15 lb/day before controls. Applying this percentage 

to the number of offset lithographic printing facilities in current ozone nonattainment 

areas, about 6,700 facilities emit 15 lb VOC per day or more. Based on a similar 

assessment, we estimate that less than 700 heatset web offset lithographic printing 

facilities in current ozone nonattainment areas have individual presses that are potentially 

affected by the 25 tpy potential to emit threshold described above. 
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We have limited information on the number of letterpress printing facilities in 

ozone nonattainment areas. In 1992, however, EPA’s Office of Pollution Prevention and 

Toxics issued a report3 which estimates that there are 21,000 facilities nationwide that are 

engaged in letterpress printing operations. Based on the percentage of the U.S. 

population in ozone nonattainment areas in 1990 and the percentage of U.S. population in 

ozone nonattainment areas in 2000), we estimate that approximately 11,000 of these 

facilities are located in current ozone nonattainment areas (based on April 2006 

designations). In light of the similarities between letterpress and offset lithographic 

printing and the lack of specific data relevant to letterpress printers, we assume that 

approximately 80 percent of the letterpress facilities in current ozone nonattainment areas 

emit less than 15 lb of VOC per day and would therefore not be affected by this CTG. 

Applying this percentage to the number of letterpress printing facilities in current ozone 

nonattainment areas, about 2,200 facilities emit 15 lb/day actual VOC emissions (before 

controls) or more. There are very few heatset letterpress facilities anywhere in the U.S. 

IV. Process Description and Sources of VOC Emissions

 

A. Offset Lithography

Offset lithography is a planographic method of printing. The term 

“planographic” denotes that the printing and non-printing areas are in the same 

plane on the surface of a thin metal lithographic plate. To maintain the distinction 

between the areas on the lithographic plate, the image area is rendered oil 

receptive, and the non-image area is rendered water receptive. 

Offset lithography is an indirect printing method; that is, ink is not 

transferred directly to a substrate. Rather, ink is transferred from the lithographic 

plate to a rubber-covered, intermediate “blanket” cylinder and then transferred 

from the blanket cylinder to the substrate. The offset lithographic process is used 

for a broad range of printing applications, including books, magazines, 

periodicals, labels and wrappers, catalogs and directories, financial and legal 

documents, business forms, advertising brochures, newspapers, newspaper inserts, 

charts and maps, calendars, tickets and coupons, greeting cards, and stamps. 

There are two types of offset lithography characterized by the method in 

which the substrate is fed to the press. In sheet-fed printing, individual sheets of 

paper or other substrate are fed to the press. In web printing, continuous rolls of 

substrate material are fed to the press and rewound or cut to size after printing. 

VOC emissions from offset lithographic printing result from the evaporation of 

components of the inks, fountain solutions, cleaning materials and other 

miscellaneous materials such as varnishes, coatings and glues. For a more 

complete description of these industry processes, refer to the 1993 draft CTG. 
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1. Inks 

Offset lithographic printing inks are composed of pigments, vehicles, 

binders, and other additives. Offset lithographic inks are paste inks. Pigments 

provide the desired color and contain organic and inorganic materials. The 

vehicle is a solvent that carries pigment and binders, and is usually composed of 

petroleum oils and vegetable oils. Binders fix the pigment to the substrate and are 

composed of organic resins and polymers or oils and resins. Additives include 

waxes, lubricants, and driers. 

 

Heatset web inks require heat to set the ink. Coldset web (also called nonheatset web) and sheet-fed inks dry by absorption into the substrate or by 

oxidation. 

Heatset web inks may contain up to 45 percent VOCs (ink oils). In heatset 

web lithographic printing, 20 percent of the petroleum ink oils and essentially all 

of the vegetable ink oils are retained in the substrate and dry ink film. The 

remaining 80 percent of the petroleum ink oil is volatilized in and then exhausted 

from the dryer. Since the vegetable ink oil does not volatilize in the dryer, the 

amount of vegetable ink oil that can be used in heatset web offset lithographic 

inks is very limited. If there is too much vegetable oil in a heatset web offset 

lithographic ink, the ink will not dry properly. 

The petroleum ink oils in sheet-fed and coldset web inks have higher 

boiling points than the ink oils in heatset inks. Coldset web inks usually contain 

below 35 percent VOC. Most sheet-fed inks contain below 25 percent VOC. In 

sheet-fed and coldset web offset lithographic printing, 95 percent of the petroleum 

ink oils and essentially all of the vegetable oils are retained in the substrate and 

dry ink film. The remaining 5 percent of petroleum ink oils is volatilized and 

emitted. Because of the high level of ink oil retention, emissions from sheet-fed 

and coldset web offset lithographic inks are inherently very low. 

Some radiation (ultra-violet light or electron beam) cured materials are 

also used. Some printers use these materials in lieu of the heatset web printing 

process and others use them in conjunction with heatset web, coldset web or 

sheet-fed printing processes. Radiation cured materials generate minimal VOC 

emissions. Ultra-violet lamps or electron beam generators are used to dry and 

cure these materials. 

Varnishes are unpigmented offset lithographic inks. They are applied on 

offset lithographic presses in the same manner (i.e., using a lithographic printing 

plate, fountain solution and blanket cylinder) as offset lithographic ink. Heatset 

varnishes are unpigmented heatset inks. The emissions generated by heatset 

varnishes are similar in nature to the emissions generated by heatset inks and they 

can be controlled in the same manner. Sheet-fed and coldset web varnishes are 

unpigmented sheet-fed and coldset web inks. Sheet-fed and coldset web 
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varnishes exhibit the same high level of ink oil retention and generate the same 

inherently low emissions as sheet-fed and coldset web inks. The coatings used on 

offset lithographic presses are predominantly waterbased or radiation (ultra-violet 

or electron beam) cured materials which generate minimal VOC emissions. We 

recommend that varnishes and coatings used on offset lithographic printing 

presses be considered part of the offset lithographic printing process and that the 

recommendations described below in section VI for heatset web offset 

lithographic inks and dryers apply equally to varnishes. We recommend that 

varnishes and coatings used on offset lithographic printing presses not be 

considered as a separate process (e.g., paper coating). 

2. Fountain Solution 

Fountain solution is applied to the lithographic plate to render the nonimage areas unreceptive to ink. Since offset lithographic printing inks are oilbased, the fountain solution is water-based. The fountain solution contains small 

amounts of gum Arabic or synthetic resins, acids, and buffer salts to maintain the 

pH of the solution, and a wetting agent or “dampening aid” to enhance the 

spreadability of the fountain solution across the plate. The dampening aid reduces 

the surface tension of water as well as increases viscosity. 

Isopropyl alcohol traditionally has been used as a dampening aid. Other 

alcohols such as ethanol and n-propyl alcohol may also be used. Before the 

1980’s, the concentration of alcohol in the fountain solution was sometimes as 

high as 35 percent, with the concentration in most presses falling between 15 and 

20 percent. Over the last 20 years, printers have greatly reduced the alcohol 

content of fountain solution. Also in the last 20 years, non-alcohol dampening 

aids have been developed. These alcohol substitutes are typically glycol ethers or 

ethylene glycol, and achieve the same purpose as alcohol. 

3. Cleaning Materials 

Cleaning materials are used to remove excess printing inks, oils, and 

residual paper from press equipment. These materials are typically mixtures of 

organic (often petroleum-based) solvents. The cleaning material may be a solvent 

such as kerosene (which contains numerous organics), or a specific mixture of 

individual solvents. Cleaning materials are used to wash the blankets, rollers, and 

outside of presses, and to remove residues of excess ink between color changes. 

Cleaning may be done manually, for example using shop towels, or using an 

automatic blanket wash systems. 
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 B. Letterpress Printing

1. Inks 

Letterpress inks are similar to offset lithographic inks. They are paste inks 

containing petroleum oils or vegetable oils. Both sheet-fed and web presses are 

used for letterpress printing. 

Sheet-fed letterpress presses use coldset inks. Most web letterpress 

equipment use coldset inks. These letterpress inks are similar in composition and 

behavior to sheet-fed and coldset web lithographic inks. In sheet-fed and coldset 

web letterpress printing, 95 percent of the petroleum ink oils and essentially all of 

the vegetable oils are retained in the substrate and dry ink film. The remaining 5 

percent of petroleum ink oils is volatilized and emitted. Because of the high level 

of ink oil retention, emissions from sheet-fed and coldset web letterpress inks are 

inherently very low. 

There are also some heatset web letterpress printers. Heatset letterpress 

ink is similar to heatset lithographic ink with 20 percent of the petroleum ink oils 

and essentially all of the vegetable ink oils retained in the substrate and dry ink 

film. The remaining 80 percent ink oil is volatilized in and then exhausted from 

the dryer. Since the vegetable ink oil does not volatilize in the dryer, the amount 

of vegetable ink oil that can be used in heatset letterpress inks is very limited. If 

there is too much vegetable oil in a heatset letterpress ink, the ink will not dry 

properly. 

2. Cleaning Materials 

Cleaning materials are used to remove excess printing inks, oils, and 

residual paper from press equipment. The cleaning materials used for letterpress 

printing are similar to those used in offset lithographic printing. These materials 

are typically mixtures of organic (often petroleum-based) solvents. 

V. Available Control Options 

There are three main sources of VOC emissions from offset lithographic printing: 

(1) evaporation of VOC (petroleum ink oils) from the inks; (2) evaporation of VOC from 

the fountain solution; and (3) evaporation of VOC from the cleaning materials. There 

are two main sources of VOC emissions from letterpress printing: (1) evaporation of 

VOC (petroleum ink oils) from the inks and (2) evaporation of VOC from the cleaning 

materials. 
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The three mechanisms to reduce VOC emissions from offset lithographic printing 

and letterpress printing are as follows: 

• Add-on controls, 

• Process modifications or work practices, and 

• Material reformulation or substitution. 

A. Inks

Inks are a significant source of VOC emissions from heatset web offset 

lithographic printing and heatset letterpress printing. In these processes, heat is 

applied in a dryer to set the inks. As a result of the heating process, about 80 

percent of the petroleum ink oil (VOC) is volatilized in the dryer. The remaining 

20 percent of petroleum ink oil and all of the vegetable ink oil is retained in the 

substrate and dry ink film. 

Most heatset web offset lithographic printing dryers are equipped with 

control devices such as a thermal oxidizer, catalytic oxidizer, or chiller condenser 

(condenser filter). These same control devices can also be used on heatset 

letterpress dryers. These control devices significantly reduce VOC emissions 

from heatset web printing. Oxidizers are more widely used than condenser filters, 

with catalytic oxidizers being slightly more popular than thermal oxidizers. At 

the time the 1993 draft CTG was being developed, new oxidizers generally were 

capable of achieving 95 percent or greater destruction efficiency, but chiller 

condensers were only capable of achieving 90 percent. 

Oxidizers and condenser filters may not be able to achieve the above 

stated destruction or recovery efficiencies when the VOC concentration of the 

stream entering the control device is too low. Oxidizers tend to have a rather 

constant outlet concentration around 20 ppmv as compound. As a result, an 

oxidizer that achieves 90 percent destruction efficiency at inlet concentrations 

above 200 ppmv as compound may not be able to achieve this level of destruction 

efficiency at inlet concentrations below 200 ppmv as compound. Similarly, an 

oxidizer that achieves 95 percent destruction efficiency at inlet concentrations 

above 400 ppmv as compound may not be able to achieve this level of destruction 

efficiency at inlet concentrations below 400 ppmv as compound. Print jobs (e.g., 

book printing) with light coverage will yield low inlet concentrations. In addition, 

there are several instances, such as sources utilizing combined dryers and control 

devices that do not have an identifiable measurable inlet where the only option 

available is to measure the outlet concentration to demonstrate compliance. 

Some printers use radiation (ultra-violet light or electron beam) cured 

materials in lieu of the heatset web printing process. These radiation cured 

materials generate minimal VOC emissions. 
11

Some reduction in VOC emissions from heatset web offset lithographic 

inks and heatset letterpress inks could be achieved by increasing the use of 

vegetable oil and decreasing the use of petroleum oil. Since only very limited 

amounts of vegetable oil can be used in heatset inks, only a small emission 

reduction could be achieved and we do not believe this reduction would be costeffective. 

The VOC emissions from sheet-fed and coldset web lithographic inks and 

sheet-fed and coldset web letterpress inks are inherently very low. First, these 

inks are lower VOC-content inks than heatset web inks. Second, 95 percent of the 

petroleum ink oil and essentially all of the vegetable ink oil in sheet-fed and 

coldset web inks do not evaporate and are retained in the substrate and dry ink 

film. Because only a small percentage of the sheet-fed and coldset web ink oils 

evaporate, VOC emissions associated with these inks are small. 

Some reduction in VOC emissions from sheet-fed and coldset web inks 

could be achieved by increasing the use of vegetable oil and decreasing the use of 

petroleum oil. Since 95 percent of the petroleum oil is retained, only a small 

emission reduction could be achieved and we do not believe this reduction would 

be cost-effective. 

The limited VOC emissions that occur from sheet-fed and coldset web 

offset lithographic inks are diffuse and spread over a large area. These emissions 

are not amenable to add-on control. This is in contrast to the emissions associated 

with heatset offset web lithographic inks and heatset web letterpress inks, as the 

petroleum oils in those inks volatilize in a dryer and are more amenable to add-on 

control because they are emitted in a more concentrated form from a discrete 

source. 

B. Fountain Solution

Fountain solutions can be the source of a significant portion of the VOC 

emitted by offset lithographic printing operations. Historically, alcohols such as 

isopropyl alcohol, n-propyl alcohol and ethanol were used as the dampening aid. 

Before the 1980’s, the concentration of alcohol in the fountain solution 

was sometimes as high as 35 percent, with the concentration in most presses 

falling between 15 and 20 percent. Over the last 20 years, printers have greatly 

reduced the alcohol content of fountain solution. 

Cooling a fountain solution that contains isopropyl alcohol is a process 

modification that reduces VOC emissions by reducing the evaporation of the 

alcohol. Refrigerated circulators are available that can cool the fountain solution 

to a pre-set temperature of 55 to 60 oF. Refrigeration also gives operators better 

control of ink emulsification and hot weather scumming, and stabilizes the 

ink/water balance by minimizing alcohol evaporation. Refrigeration of fountain 
12

solution trays has been shown to reduce alcohol consumption by as much as 44 

percent. 

In addition, many printers have reduced VOC emissions by switching to 

alcohol substitutes, most commonly certain glycol ethers. These additives have 

higher boiling points and lower volatilities than traditional dampening aids. The 

additives are incorporated in small quantities (from 2 to 4 ounces in 1 gallon of 

water) to produce a final, mixed fountain solution that is usually less than 3 

weight percent VOC. 

C. Cleaning Materials

Cleaning materials can be the source of a significant portion of the VOC 

emitted by offset lithographic printing and letterpress printing operations. The 

keys to reducing VOC emissions from offset lithographic printing and letterpress 

printing cleaning materials are reducing the composite vapor pressure or VOC 

content of the material used, and work practices. 

 

Cleaning materials with VOC composite vapor pressure less than 10 

millimeters of mercury (mm Hg) at 20 oC have been used successfully by many 

printers for blanket washing and other cleaning activities. Low VOC composite 

vapor pressure materials generate less VOC emissions than higher vapor pressure 

cleaning materials. As noted in the ACT document, cleaning materials with VOC 

composite vapor pressure less than 10 millimeters of mercury (mm Hg) at 20 oC 

when used in conjunction with good work practices achieve a comparable 

emission reduction to cleaning materials containing 30 weight percent VOC. For 

certain cleaning activities, such as metering roller cleaning or removing dried ink, 

higher vapor pressure cleaning materials may be required. 

The VOC composite vapor pressure of a cleaning material is a weighted 

average of the vapor pressures of the VOC components of that cleaning material. 

The vapor pressure of each VOC component is weighted by the mole fraction of 

that VOC component in the whole cleaning material including non-VOC 

components such as water or exempt compounds. Water and exempt compounds 

thereby reduce the VOC composite vapor pressure of cleaning materials in which 

they are present. 

 

Water-miscible cleaning materials with less than 30 weight percent VOC 

were developed and tested for offset lithographic printing in the early 1990’s. 

These materials were recommended as RACT in the 1993 draft CTG. These 

materials did not provide adequate performance and therefore they are not being 

used by the offset lithographic printing industry today. 

There are some water-miscible or exempt solvent containing cleaning 

materials that contain 70 weight percent VOC or less in use today. These lower 

VOC content materials are capable of performing many of the tasks, such as 
13

metering roller cleaning, which cannot be performed with low VOC composite 

vapor pressure cleaning materials. A small number of cleaning tasks cannot be 

carried out with low VOC composite vapor pressure cleaning materials or reduced 

VOC content cleaning materials. 

Work practices such as keeping solvent containers closed except when 

filling, draining or conducting cleaning operations, and keeping used shop towels 

in closed containers also reduce VOC emissions. Typically, 50 percent of a 

cleaning material with composite vapor pressure less than 10 mm Hg at 20 oC will 

remain in used shop towels if the used towels are kept in closed containers. 

D. Existing State and Local Regulations

In researching available control approaches for addressing VOC emissions 

associated with offset lithographic printing and letterpress printing, EPA reviewed 

existing state and local regulatory approaches. Seventeen states or local areas 

have VOC emission regulations for offset lithographic printing operations. Five 

states or local areas have regulations for letterpress printing operations. These 

rules generally limit the alcohol or alcohol substitute content of fountain solutions 

(for offset lithographic printers only) and the composite vapor pressure or VOC 

content of cleaning materials, and require control of heatset dryer exhaust. The 

tables in Appendices B and C list and describe the regulations that EPA reviewed. 

VI. Recommended Control Options 

Recommendations for controlling VOC emissions from heatset inks, fountain 

solution, and cleaning materials used in offset lithographic printing operatons, and for 

controlling VOC emissions from heatset inks and cleaning materials used in letterpress 

printing operations are as follows: 

A. Heatset web offset lithographic and heatset letterpress inks and dryers

 The recommended level of control for VOC emissions from heatset dryers 

is tied to the first installation date of the control device. The first installation date 

for a control device does not change if it is later moved to a new location. For 

example, a brand new control device first installed in 1992 is moved to a new 

location in 1998 – the first installation date for this control device is still 1992. 

The first installation date for a control device does not change if it is later used to 

control a new press. For example, a brand new heatset press is installed in 2009 

and emissions from this press are controlled by a control device that was first 

installed in 2002 - the first installation date for this control device is still 2002. 

The recommended level of control for VOC emissions from heatset dryers 

is 90 percent control efficiency for a control device whose first installation date 

was prior to the effective date of a State RACT rule issued after the date of this 

CTG. The recommended level of control for VOC emissions from heatset dryers 
14

is 95 percent control efficiency for a control device whose first installation date 

was on or after the effective date of a State RACT rule issued after the date of this 

CTG. 

We recommended a 90 percent control efficiency in the 1993 draft CTG 

and this efficiency is currently required by most state and local regulations for 

heatset web offset lithography. At the time the 1993 draft CTG was being 

developed, new oxidizers generally were capable of achieving 95 percent or 

greater destruction efficiency, but chiller condensers were only capable of 

achieving 90 percent. For a variety of reasons, including the 90 percent control 

efficiency recommendation in the 1993 draft CTG and the 90 percent control 

efficiency requirement in most existing state and local regulations, some oxidizers 

first installed between 1993 and the publication of this CTG may not be achieving 

95 percent control device efficiency. We do not recommend retroactively 

requiring these oxidizers to achieve 95 percent control device efficiency. 

To accommodate situations where the inlet VOC concentration is so low 

that a 90 or 95 percent efficiency may not be achievable, we recommend 

providing an outlet concentration alternative. Specifically we recommend 

providing an option to reduce the control device outlet concentration to 20 ppmv 

as hexane on a dry basis to accommodate situations where the inlet VOC 

concentration is low, or there is no identifiable measurable inlet. 

As explained above in section III, we recommend applying the above 

recommended levels of control to individual heatset web offset lithographic 

printing presses with potential to emit from the dryer, prior to controls, of at least 

25 tpy of VOC (petroleum ink oil). We also recommend applying the above 

recommended levels of control to individual heatset web letterpress printing 

presses with potential to emit from the dryer, prior to controls, of at least 25 tpy of 

VOC (petroleum ink oil). We recommend providing printers with the option of 

using an enforceable limitation on potential emissions to keep an individual 

heatset press below this 25 tpy potential to emit threshold. This equates to using 

inks and coatings which contain less than 31.25 tpy VOC (petroleum ink oil) 

because of the 20 percent ink oil retention. We also recommend excluding heatset 

presses used for book printing and excluding heatset presses with maximum web 

width of 22 inches or less from the add-on control recommendations. 

We believe that control of a press that is above the 25 tpy threshold will 

generally be cost effective. Control of a press that is below the 25 tpy threshold, 

presses used for book printing, and presses with maximum web width of 22 

inches or less will generally not be cost effective. 

We are not recommending control of VOC emissions from sheet-fed or 

coldset web inks, sheet-fed or coldset web varnishes, waterborne coatings or 

radiation (ultra-violet light or electron beam) cured materials used on offset 
15

lithographic presses or letterpress presses. The VOC emissions from these 

materials are already low and they are not amenable to add-on control. 

 B. Fountain Solution 

We recommend the following approaches for controlling VOC emissions 

from fountain solution. These recommended levels of control were recommended 

in the 1993 draft CTG and are required by certain existing state and local 

regulations. 

• Heatset Web Offset Lithographic Printing

The recommended level of control for VOC emissions from on-press 

(as-applied) fountain solution for heatset web offset lithographic 

printing is 1.6 percent alcohol (by weight) in the fountain or 

equivalent. There are at least three different approaches for achieving 

this level of control. The first approach involves reducing the on-press 

(as-applied) alcohol content to 1.6 percent alcohol or less (by weight). 

The second approach involves using 3 percent alcohol or less (by 

weight) on-press (as-applied) in the fountain solution if the fountain 

solution is refrigerated to below 60oF (15.5oC). The third approach 

involves using 5 percent alcohol substitute or less (by weight) on-press 

(as-applied) and no alcohol in the fountain solution. 

• Sheet-fed Offset Lithographic Printing

The recommended level of control for VOC emissions from on-press 

(as-applied) fountain solution for sheet-fed printing is equivalent to 5 

percent alcohol (by weight) in the fountain or equivalent. There are at 

least three different approaches for achieving this recommended level 

of control. The first approach involves reducing the on-press (asapplied) alcohol content to 5.0 percent alcohol or less (by weight). 

The second approach involves using 8.5 percent alcohol or less (by 

weight) on-press (as-applied) in the fountain solution provided the 

fountain solution is refrigerated to below 60oF (15.5 oC). The third 

approach involves using 5 percent alcohol substitute or less (by 

weight) on-press (as-applied) and no alcohol in the fountain solution. 

This recommendation does not apply to sheet-fed presses with sheet 

size of 11 inches by 17 inches or smaller, and does not apply to any 

press with total fountain solution reservoir of less than 1 gallon. 

• Coldset Web Offset Lithographic Printing

The recommended level of control for VOC emissions from fountain 

solution for coldset web is 5 percent alcohol substitute or less (by 

weight) on-press (as-applied) and no alcohol in the fountain solution. 
16

As explained more fully in Section III above, we recommend applying the 

control recommendations for offset lithographic printing fountain solution to any 

offset lithographic printing operation where the emissions associated with all 

aspects of that operation equal or exceed 6.8 kg/day (15 lb/day) actual emissions 

of VOC, or an equivalent level, before consideration of controls. State and local 

agencies may adopt different applicability criteria in their regulations. States 

should craft their applicability criteria in their State RACT rules based on 

consideration of the facts and circumstances of the facilities in their particular 

nonattainment areas. 

We recommend that these control recommendations for fountain solution 

not be applied to sheet-fed presses with maximum sheet size 11x17 inches or 

smaller, or to any press with total fountain solution reservoir of less than 1 gallon. 

For these presses, the recommended VOC (alcohol or alcohol substitute) content 

levels would yield a small emission reduction relative to the cost of achieving that 

reduction (e.g., changing and maintaining rollers). 

C. Cleaning Materials

The following recommendations apply to blanket washing, roller washing, 

plate cleaners, metering roller cleaners, impression cylinder cleaners, rubber 

rejuvenators, and other cleaners used for cleaning a press, press parts, or to 

remove dried ink from areas around a press. EPA recommends that when States 

develop RACT rules in response to the Industrial Cleaning Solvents CTG, see 

EPA 453/R-06-001 (Sept. 2006), they consider excluding from those rules the 

activities noted in the prior sentence, which are covered by this CTG. See 71 FR 

44540. In addition, the recommendations for cleaning materials provided below 

do not apply to cleaners used on electronic components of a press, pre-press 

cleaning operations (e.g., platemaking), post-press cleaning operations (e.g., 

binding), cleaning supplies (e.g., detergents) used to clean the floor (other than 

dried ink) in the area around a press, or cleaning performed in parts washers or 

cold cleaners. 

We recommend using cleaning materials with a VOC composite vapor 

pressure less than 10 mm Hg at 20 oC or cleaning materials containing less than 

70 weight percent VOC. We believe this combination of material 

recommendations will reduce VOC emissions and allow for use of a mix of 

materials capable of achieving all of the covered cleaning tasks. Cleaning 

materials with low VOC composite vapor pressure have been used successfully 

by many printers for blanket washing and other cleaning activities. Many of the 

cleaning tasks that cannot be carried out with low VOC composite vapor pressure 

cleaning materials can be carried out with reduced VOC content cleaning 

materials. We also recommend excluding 110 gallons per year of cleaning 

materials which meet neither the low VOC composite vapor pressure 

recommendation nor the lower VOC content recommendation because a small 
17

number of cleaning tasks cannot be carried out with low VOC composite vapor 

pressure cleaning materials or reduced VOC content cleaning materials. 

We also recommend that the following work practices be employed: 

keeping cleaning materials and used shop towels in closed containers. In the 

ACT document, EPA noted that using cleaning materials with a VOC composite 

partial vapor pressure less than 10 mm Hg at 20 oC in conjunction with good 

work practices would result in an emission reduction that is comparable to using 

cleaning materials that contain less than 30 weight percent VOC. 

As explained more fully in Section III above, we recommend applying the 

above control recommendations for offset lithographic printing cleaning 

materials to any offset lithographic printing operation where the emissions 

associated with all aspects of that operation equal or exceed 6.8 kg/day (15 

lb/day) actual emissions of VOC, or an equivalent level, before consideration of 

controls. Similarly, we recommend applying the above control recommendations 

for letterpress printing cleaning materials to any letterpress printing operation 

where the emissions associated with all aspects of that operation equal or exceed 

6.8 kg/day (15 lb/day) actual emissions of VOC, or an equivalent level, before 

consideration of controls. State and local agencies may adopt different 

applicability criteria in their regulations. States should craft their applicability 

criteria in their State RACT rules based on consideration of the facts and 

circumstances of the facilities in their particular nonattainment areas. 

VII. Cost Effectiveness of Recommended Control Options

In the 1993 draft CTG, EPA estimated baseline emissions from the offset 

lithographic printing industry in ozone nonattainment areas, based on 1990 data, to be 

820,000 tons per year (with 62,000 tpy coming from ink, 631,000 tpy from fountain 

solution and 126,000 tpy from cleaning). In the 1993 draft CTG, EPA also conducted a 

model plant analysis, in which it evaluated VOC emissions associated with different 

kinds of printing processes, the VOC emission reduction capabilities of various control 

options, and the costs of such controls. The model plants were developed to represent a 

range of sizes and emissions. See Appendix A (describing model plant analysis and 

EPA’s VOC emission reduction and cost estimates). 

Commenters on the 1993 draft CTG asserted that the alcohol content (17 percent) 

used to generate this estimate was too high and that the assumed ratio of fountain solution 

usage to ink usage was also too high. Baseline VOC emissions from fountain solution 

may have been overestimated in 1993 by a factor of 2 to 3, which would mean that 

industrywide baseline emissions in 1990 ranged from approximately 400,000 to 500,000 

tpy. As for letterpress printers, we have limited emissions information for this industry. 

Based on available information, we estimate that VOC emissions from the letterpress 

printing industry as of 1990 were about 28,000 tons per year. 
18

We believe that the model plant analysis in the 1993 draft CTG is representative 

of current operations in the offset lithographic printing industry and current control 

options. The significant control approaches addressed in the 1993 draft CTG are the 

same approaches that are available today, and those approaches continue to represent the 

most effective means of controlling VOC emissions from offset lithographic printers. 

We also believe that the model plant analysis accurately presents the costs associated 

with the control approaches identified in the 1993 document. We recognize, however, 

that the costs in that draft document are presented in first quarter 1990 dollars and must 

be adjusted to represent current costs. Accordingly, for purposes of estimating the costeffectiveness of the recommended control approaches in this document, we escalated the 

1990 costs in the 1993 draft CTG, to 2005 costs using a cost index.4 The escalated costs 

are presented in Table 1 below. (See Appendix D for additional cost information.) 

Table 1. Cost Effectiveness Values for Recommended Control Approaches 

for Offset Lithographic Printing 

Control Technique $ Per Ton VOC Removeda

Control of VOC from heatset inks 2,010 

Control of VOC from fountain solutions estimated savingsb

Control of VOC from cleaning materials 855 

a

 Costs from 1990 are escalated to 2005 costs by use of a Marshall and Swift Equipment Cost 

Index (Chemical Engineering Magazine). 

b Reduction in alcohol use or conversion to alcohol substitutes results in a cost savings. 

Because of the similarities between offset lithographic printing and letterpress printing in 

terms of the nature of the processes at issue, the sources of VOC emissions and available 

control approaches, it is reasonable to assume that the cost-effectiveness estimates in 

Table 1 for control of VOC from heatset inks and control of VOC from cleaning 

materials apply equally to the letterpress printing industry. 

VIII. Factors to Consider in Determining VOC Emissions from Offset 

Lithographic Printing and Letterpress Printing

 This section provides a summary of some of the recommendations EPA has 

previously made to States concerning factors that may be considered in determining 

VOC emissions from offset lithographic printing and letterpress printing operations. 

These factors are important for a number of reasons including determining whether a 

facility or a press exceeds the applicability thresholds recommended in this CTG or other 

applicability thresholds that a state may consider including in its regulations. The factors 

described below and other relevant factors are discussed in the 1993 draft CTG, the 1994 

ACT and the 2005 Printing TSD. 

A. Ink Oil Retention 

 Heatset Inks – We recommend using a 20 percent VOC retention factor 

for petroleum ink oils and a 100 percent retention factor for vegetable ink oils in 

heatset inks. The VOC emissions, before consideration of any control, from a 
19

heatset ink would therefore be 80 percent of the petroleum ink oil content. The 

petroleum ink oil content of a heastet ink can be determined from formulation 

data (e.g., technical data sheet or material safety data sheet). We believe that a 

Method 24 test of a heatset ink will volatilize the petroleum ink oils and will not 

volatilize the vegetable ink oils. 

 Sheet-fed and coldset web inks - We recommend using a 95 percent VOC 

retention factor for petroleum ink oils and a 100 percent retention factor for 

vegetable ink oils in sheet-fed and coldset web inks. The VOC emissions from a 

sheet-fed or coldset web ink would therefore be 5 percent of the petroleum ink oil 

content. The petroleum ink oil content of a sheet-fed or coldset web ink can be 

determined from formulation data (e.g., technical data sheet or material safety 

data sheet). We believe that an EPA Method 24 test of a sheet-fed or coldset web 

ink will volatilize the petroleum ink oils and will not volatilize the vegetable ink 

oils. The ASTM method D6419 (Standard Test Method for Volatile Content of 

Sheet-Fed and Coldset Web Offset Printing Inks) is a more precise method for 

determining the volatile (petroleum ink oil) content of sheet-fed and coldset web 

inks than ASTM D2369 which is referenced in EPA Method 24. 

B. Retention of Low VOC Composite Vapor Pressure Cleaning Materials in 

Shop Towels

 We recommend using a 50 percent VOC retention factor for low VOC 

composite vapor pressure cleaning materials in shop towels where (1) VOC 

composite vapor pressure of the cleaning material is less than 10 mm Hg at 20 oC, 

and (2) cleaning materials and used shop towels are kept in closed containers. 

C. Carryover of VOC from Automatic Blanket Wash and Fountain Solution 

to Offset Lithographic Heatset Dryers 

 We recommend using a 40 percent VOC carryover (capture) factor for 

automatic blanket washing when the VOC composite vapor pressure of the 

cleaning material is less than 10mm Hg at 20°C. 

 We recommend using a 70 percent VOC carryover (capture) factor for 

alcohol substitutes in fountain solution. 

D. Capture of Petroleum Ink Oil in Heatset Dryers

For heatset web offset lithographic presses and heatset web letterpress 

presses, we believe capture efficiency for VOC (petroleum ink oils) from oilbased paste inks and oil-based paste varnishes (coatings) can be demonstrated by 

showing that the dryer is operating at negative pressure relative to the surrounding 
20

pressroom. We recommend that as long as the dryer is operated at negative 

pressure, the capture efficiency for VOC from the heatset lithographic inks and 

varnishes (coatings) formulated with low volatility ink oils can be assumed to be 

100 percent of the VOC (ink oils) volatilized in the dryer. We do not recommend 

conducting a capture efficiency test in this situation. 

Conventional heatset lithographic inks and varnishes are paste-type 

materials. The VOC in these materials are oils with high boiling points, which 

volatilize only within the dryer. Some ink oils, nominally 20 percent, are not 

volatilized and remain in the substrate. If other types (e.g., fluid type) of coating 

materials are used on a heatset lithographic press or a heatset letterpress press, we 

recommend that capture efficiency testing be conducted for the VOC from these 

other materials if the printer wants to take into account the effect that the dryer 

controls have on VOC emissions from these other types of coatings. The most 

common other types of coatings materials used on heatset presses are waterbased 

or radiation (ultra-violet light or electron beam) cured materials which generate 

minimal VOC emissions. 

E. Methods 25 and 25A

We recommend using EPA Method 25A in lieu of EPA Method 25 for 

determining the destruction efficiency of an oxidizer (inlet and outlet 

concentrations) when: 

• An exhaust concentration of 50 or less parts per million volume 

(ppmv) as carbon (C1) is required to comply with the applicable 

standard; 

• The inlet concentration and the required level of control results in 

an exhaust concentration of 50 or less ppmv as C1; or 

• The high efficiency of the control device alone results in an 

exhaust concentration of 50 or less ppmv as C1. 

In situations where M25 is not viable, such as those described in section 1.1 of 

M25, we recommend the use of M25A on both the inlet and outlet. 
21

IX. References

1. Guideline Series: Control of Volatile Organic Compound Emissions from Offset 

Lithographic Printing. Draft. U.S. Environmental Protection Agency. Research 

Triangle Park, NC. September 1993. 

2. Alternative Control Techniques Document: Offset Lithographic Printing. EPA 

453/R-94-054. U.S. Environmental Protection Agency. Research Triangle Park, 

NC. June 1994. 

3. Use Cluster Analysis of the Printing Industry. Office of Pollution Prevention and 

Toxics. Office of Pollution Prevention and Toxics. May 1992. 

4. Marshall and Swift Equipment Cost Index. Chemical Engineering Magazine. 

McGraw-Hill. (www.che.com) 

5. Model Volatile Organic Compound Rules for Reasonably Available Control 

Technology: Planning for Ozone Nonattainment Pursuant to Title I of the Clean 

Air Act. U.S. Environmental Protection Agency. Research Triangle Park, NC. 

June 1992. 

6. Technical Support Document (TSD) for Title V Permitting of Printing Facilities, 

Office of Air Quality Planning and Standards, U.S. Environmental Protection 

Agency, Research Triangle Park, NC 27711, January 2005. 
22

Appendix A 

Access to 1993 draft CTG, 1994 ACT, and 2005 TSD

Guideline Series: Control of Volatile Organic Compound Emissions from Offset 

Lithographic Printing. Draft. U.S. Environmental Protection Agency. Research 

Triangle Park, NC. September 1993. 

Available as a separate item in docket EPA-HQ-OAR-2006-0536 and on the internet 

at http://www.epa.gov/ttn/atw/print/draftlithoctg.pdf . 

Alternative Control Techniques Document: Offset Lithographic Printing. 

EPA 453/R-94-054. U.S. Environmental Protection Agency. Research Triangle 

Park, NC. June 1994. 

Available as a separate item in docket EPA-HQ-OAR-2006-0536 and on the internet 

at http://www.epa.gov/ttn/atw/print/lact.pdf . 

Technical Support Document (TSD) for Title V Permitting of Printing Facilities, 

Office of Air Quality Planning and Standards, U.S. Environmental Protection 

Agency, Research Triangle Park, NC 27711, January 2005. 

Available as a separate item in docket EPA-HQ-OAR-2006-0536 and on the internet 

at http://www.epa.gov/ttn/oarpg/t5/memoranda/tsd.pdf . 
23

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24

Appendix B 

State and Local Regulations for Offset Lithographic Printing 

Agency, Rule Number and Applicability 

State or Local 

Agency 

Offset 

Lithography 

Applicability 

Bay Area Air 

Quality 

Management 

District 

Regulation 8 

Rule 20 

http://www.baaqmd.gov/dst/regulations/rg0820.pdf

8-20-110 

175 lb VOC per month 

San Joaquin 

Valley 

Unified Air 

Pollution 

Control 

District 

Rule 4607 – 

Graphic Arts 

No cutoff 

http://www.valleyair.org/rules/currntrules/r4607.pdf

2.0 Applicability 

This rule is applicable to any graphic arts printing operation, to any 

paper or fabric coating operation, to the organic solvent cleaning, and to 

the storage and disposal of solvents and waste solvent materials 

associated with such operations as defined in Section 3.0 of this rule. 

San Diego 

County Air 

Pollution 

Control 

District 

Rule 67.16 – 

Graphic Arts 

Operations 

http://www.sdapcd.org/rules/rules/Reg4pdf/R67-16.pdf

(1) The provisions of Sections (d) and (e) of this rule shall not apply to 

stationary sources which emit less than an average of 15 lbs (6.8 kg) of 

volatile organic compounds (VOCs) from all graphic arts operations per 

day of operation for each calendar month. 

South Coast 

Air Quality 

Management 

District 

Rule 1130 – 

Graphic Arts, 

Rule 1171 – 

Solvent 

Cleaning 

Operations 

http://www.aqmd.gov/rules/reg/reg11/r1130.pdf

no cutoff 

Delaware CAP 24.47 – 

Offset 

Lithographic 

Printing 

http://www.dnrec.state.de.us/air/aqm_page/docs/pdf/reg_24.pdf

15 lb/day 

2. This Section does not apply to any offset lithographic printing facility 

whose total actual volatile organic compound (VOC) emissions from all 

lithographic printing operations (including emissions from cleaning 

solutions used on lithographic printing presses) are less than 6.8 

kilograms (kg) (15 pounds [lb]) VOCs per day before the application of 

capture systems and control devices. 

or maintains a maximum dryer exhaust outlet concentration of 20 parts 

per million by volume (ppmv) as methane (as C1), whichever is less 

stringent when the press is in operation. 
25

Georgia 391-3-1-02 

Provisions. 

Amended, 

(2)(ddd) - 

VOC 

Emissions 

from Offset 

Lithography 

25 tpy 

100 tpy 

3. The requirements of this subsection shall apply to facilities with VOC 

emissions exceeding 25 tons per year and located in the counties of 

Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, 

Fulton, Gwinnett, Henry, Paulding and Rockdale and to facilities with 

potential VOC emissions exceeding 100 tons per year and located in the 

counties of Bartow, Carroll, Hall, Newton, Spalding, and Walton. 

Illinois 35.215.408 – 

(Heatset 

Web), 

35.218.407 – 

Lines on and 

after March 

15, 1996, and 

35.219.407 – 

Lines on and 

after March 

15, 1996 

Old rule? 

http://www.ipcb.state.il.us/documents/dsweb/Get/Document-11924/ 

Section 215.408 Heatset Web Offset Lithographic Printing 

a) No owner or operator of a heatset web offset lithographic printing 

facility, located in Cook, DuPage, Kane, Lake, Macoupin, Madison, 

McHenry, Monroe, St. Clair or Will County, emitting over 100 tons/year 

of organic material, in the absence of pollution control equipment, may 

cause or allow the operation of a heatset web offset press unless: 

1) An incinerator system is installed and operated that oxidizes at least 

90 percent of the organic materials (measured as total combustible 

carbon) in the dryer exhaust airstream to carbon dioxide and water; or 

2) The fountain solution contains no more than eight (8) percent, by 

weight, of volatile organic material and a condensation recovery system 

is installed and operated that removes at least 75 percent of the nonisopropyl alcohol organic materials from the dryer exhaust airstream. 

b) No owner or operator of a heatset web offset lithographic printing 

facility, located in a county other than Cook, DuPage, Kane, Lake, 

Macoupin, Madison, McHenry, Monroe, St. Clair or Will County, 

emitting over 100 tons/year of organic material, in the absence of 

pollution control equipment, may cause or allow the operation of a 

heatset web offset press unless the fountain solution contains no more 

than eight (8) percent, by weight, of volatile organic material. 

(Source: Added at 11 Ill. Reg. 16706, effective September 30, 1987) 

Kansas 28-19-76 – 

Lithography 

Printing 

Operations 

http://www.kdheks.gov/bar/download/AIRREGS2005new.pdf

28-19-76. Lithography printing operations. (a) 

The provisions of this regulation shall apply to all offset lithography 

printing facilities with a potential contaminant emission rate of volatile 

organic compounds (VOC) equal to or more than 100 tons per year. The 

potential contaminant emission rate calculations may include federally 

enforceable permit conditions. 

(b) The provisions of this regulation do not apply to: 

(1) printing on fabric, metal or plastic; 

(2) sheet fed lithographic presses with cylinder widths of 26 inches or 

less; or 

(3) web lithographic presses with cylinder widths of 18 inches or less. 

(c) Any owner or operator of an offset lithographic printing press subject 

to this regulation 

Maryland 26.11.19.11 – 

Lithographic 

Printing 

http://www.dsd.state.md.us/comar/26/26.11.19.11.htm

no cutoff for some items, 100 lb/day from web presses for heatset dryer 

control, 18 inch width for sheet fed ftn soln limits 
26

Massachusetts 310 CMR 

7.26 – (24) 

Non-Heatset 

Operations, 

(27) Printers 

with Heatset 

Presses or 

Nonconforming 

Operations 

Complex, but less than major 

http://www.mass.gov/dep/service/regulations/310cmr07.pdf

Missouri 10 CSR 10-

2.340 and 10 

CSR 10-

5.442, Control 

of Emissions 

from 

Lithographic 

Printing 

2.340 Kansas City 

http://www.sos.mo.gov/adrules/csr/current/10csr/10c10-2.pdf

(B) This regulation shall apply to installations that have calculated actual 

volatile organic compound (VOC) emissions for a known number of 

crewed hours, increased by the amount by weight of VOCs whose 

emission into the atmosphere is prevented by the use of air pollution 

control devices and extrapolated to eight thousand seven hundred 

sixty (8,760) hours per year equal to or greater than one hundred (100) 

tons per year from offset lithographic printing presses after 

December 9, 1991. The following factors shall be taken into 

consideration unless an alternative 

5.442 St. Louis 

http://www.sos.mo.gov/adrules/csr/current/10csr/10c10-5.pdf

(B) This rule shall apply only to installations described in subsection 

(2)(A) which have ever had the potential to emit VOCs equal to or 

greater than one hundred (100) tons per year. Once the installation 

exceeds the applicability level of this rule, it shall remain subject to this 

rule even if its potential emissions drop below the applicability 

level. 

(C) This rule shall not apply to printing on fabric, metal or plastic.

New 

Hampshire 

Env-A 

1204.37 – 

Applicability 

Criteria and 

Compliance 

Standards 

http://www.des.state.nh.us/Rules/pdf/env-a1200.pdf

(a) A source whose offset lithographic printing operations have 

combined TPEs during any consecutive 12-month period after December 

31, 1989 which equal or exceed 50 tons of VOCs shall be subject to the 

provisions of this section. 

(cy) "Theoretical potential VOC emissions" (TPEs) means the emissions 

of VOCs that would have occurred prior to the application of add-on 

controls required by a federally enforceable rule or document issued 

prior to January 1, 1990, based on one of the following: 

(1) Continuous operation of 8760 hours per year under 

maximum production capacity, which for coating and 

graphic arts sources includes coatings and inks with the 

highest VOC content used in practice by the source during 

1993 and 1994 or the 2-year period most representative of 

normal production rates; or 

(2) Hours of operation, process conditions, or both that are 

limited by federally enforceable permit conditions;
27

New York 6 Part 234 – 

Graphic Arts 

http://www.dec.state.ny.us/website/regs/part234.html

NYC metro 

(b) Any packaging rotogravure, publication rotogravure, flexographic, 

offset lithographic printing process or screen printing process at any 

facility located in the New York City metropolitan area, regardless of its 

annual potential to emit volatile organic compounds, must comply with 

this Part according to the following schedule. 

(3) . . . Any offset lithographic printing process which was constructed 

on or before September 1, 1988 regardless of annual potential to emit 

must have demonstrated compliance with this Part by May 15, 1991. 

(4) Any owner or operator of a packaging rotogravure, publication 

rotogravure, flexographic or offset lithographic printing process which 

was constructed after September 1, 1988 must have demonstrated 

compliance with this Part upon start-up. 

Lower Orange County metro 

(c) Any owner or operator of a packaging rotogravure, publication 

rotogravure, flexographic or offset lithographic printing process or 

screen printing process at any facility located in the Lower Orange 

County metropolitan area must comply with this Part according to the 

following schedule: 

 (3) Any owner or operator of a packaging rotogravure, publication 

rotogravure, flexographic, offset lithographic printing process or screen 

printing process at any facility for which the annual potential to emit 

volatile organic compounds from all sources regardless of process type, 

but excluding combustion installations, at the facility equal or exceed 25 

tons must: 

Rest of state 

 (d) Any owner or operator of a packaging rotogravure, publication 

rotogravure, f1exographic, offset 1ithographic printing process, or 

screen printing process at any facility located outside the New York City 

metropolitan area and Lower Orange county metropolitan area must 

comply with this Part according to the following schedule: 

(3) Any owner or operator of a packaging rotogravure, publication 

rotogravure, flexographic, offset lithographic printing process, or screen 

printing process at any facility for which the annual potential to emit 

volatile organic compounds from all sources regardless of process type, 

but excluding combustion installations, at the facility equal or exceed 50 

tons must: 

North 

Carolina 

15A NCAC 

02Q.0803 – 

Coating, 

Solvent 

Cleaning, 

Graphic Arts 

Operations 

This is a title V exclusionary rule, not a RACT rule 

http://daq.state.nc.us/rules/rules/Q0800.pdf

Mecklenburg County VOC rules (nothing on litho) 

http://tinyurl.com/peemj
28

Tennessee 1200-3-18.43 

– Offset 

Lithographic 

Printing 

Operations 

http://www.state.tn.us/sos/rules/1200/1200-03/1200-03-18.pdf

1200-3-18-.43 OFFSET LITHOGRAPHIC PRINTING 

OPERATIONS. 

(1) Applicability of this rule is as follows: 

(a) This rule applies to offset lithographic printing operations in 

Davidson, Rutherford, Shelby, Sumner, Williamson, and Wilson 

Counties. 

(b) The emission limits of this rule do not apply to offset lithographic 

printing operations within any facility whose potential VOC emissions 

from all offset lithographic printing operations within the facility are less 

than 100 tons of volatile organic compounds (VOC’s) per year. 

Texas 30 Section 

115.442 – 

Control 

Requirements 

http://www.tceq.state.tx.us/assets/public/legal/rules/rules/pdflib/115e.pdf

starts at 115.440 

§115.449. Counties and Compliance Schedules. 

(a) In El Paso County, all offset lithographic printing presses shall be in 

compliance with §§115.442, 115.443, 115.445, and 115.446 of this title 

(relating to Control Requirements; Alternate Control Requirements; 

Testing Requirements; and Monitoring and Recordkeeping 

Requirements) as soon as practicable, but no later than November 15, 

1996. 

(b) In Collin, Dallas, Denton, and Tarrant Counties, all offset 

lithographic printing presses on a property which, when uncontrolled, 

emit a combined weight of volatile organic compound (VOC) 

equal to or greater than 50 tons per calendar year, shall be in compliance 

with §§115.442, 115.443, 115.445, and 115.446 of this title as soon as 

practicable, but no later than December 31, 2000. 

(c) In Collin, Dallas, Denton, and Tarrant Counties, all offset 

lithographic printing presses on a property which, when uncontrolled, 

emit a combined weight of VOC less than 50 tons per calendar 

year, shall be in compliance with §§115.442, 115.443, 115.445, and 

115.446 of this title as soon as practicable, but no later than one year, 

after the commission publishes notification in the Texas Register 

of its determination that this contingency rule is necessary as a result of 

failure to attain the national ambient air quality standard (NAAQS) for 

ozone by the attainment deadline or failure to demonstrate 

reasonable further progress as set forth in the 1990 Amendments to the 

Federal Clean Air Act (FCAA), §172(c)(9). 

(d) In Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, 

Montgomery, and Waller Counties, all offset lithographic printing 

presses on a property which, when uncontrolled, emit a combined 

weight of VOC equal to or greater than 25 tons per calendar year, shall 

be in compliance with §§115.442, 115.443, 115.445, and 115.446 of this 

title as soon as practicable, but no later than December 31, 2002. 

(e) In Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, 

Montgomery, and Waller Counties, all offset lithographic printing 

presses on a property which, when uncontrolled, emit a combined 

weight of VOC less than 25 tons per calendar year, shall be in 

compliance with §§115.442, 115.443, 115.445, and 115.446 of this title 

as soon as practicable, but no later than one year, after the 

commission publishes notification in the Texas Register of its 

determination that this contingency rule is necessary as a result of failure 

to attain the NAAQS for ozone by the attainment deadline 
29

Virginia 9 VAC 5-40-

7820 – 

Standard for 

Volatile 

Organic 

Compounds 

http://www.deq.virginia.gov/air/regulations/air40.html

see article 53 

9VAC5-40-7800. Applicability and designation of affected facility. 

A. Except as provided in subsections C, D, and E of this section, the 

affected facility to which the provisions of this article apply is each 

lithographic printing process which uses a substrate other than a textile. 

B. The provisions of this article apply only to sources of volatile organic 

compounds in the Northern Virginia or Richmond Volatile Organic 

Compound Emissions Control Area designated in 9VAC5-20-206. 

C. Exempted from the provisions of this article are facilities in the 

Northern Virginia Volatile Organic Compound Emissions Control Area 

whose potential to emit is less than 10 tons per year of volatile organic 

compounds, provided the emission rates are determined in a manner 

acceptable to the board. All volatile organic compound emissions from 

printing inks, coatings, cleaning solutions, and fountain solutions shall 

be considered in applying the exemption levels specified in this 

subsection. 

D. Exempted from the provisions of this article are facilities in the 

Richmond Volatile Organic Compound Emissions Control Area whose 

potential to emit is less than 100 tons per year of volatile organic 

compounds, provided the emission rates are determined in a manner 

acceptable to the board. All volatile organic compound emissions from 

printing inks, coatings, cleaning solutions, and fountain solutions shall 

be considered in applying the exemption levels specified in this 

subsection. 

E. The provisions of this article do not apply to the following: 

1. Printing processes used exclusively for determination of product 

quality and commercial acceptance provided: 

a. The operation is not an integral part of the production process; 

b. The emissions from all product quality printing processes do not 

exceed 400 pounds in any 30 day period; and 

c. The exemption is approved by the board. 

2. Photoprocessing, typesetting, or imagesetting equipment using waterbased chemistry to develop silver halide images. 

3. Platemaking equipment using water-based chemistry to remove 

unhardened image-producing material from an exposed plate. 

4. Equipment used to make blueprints. 

5. Any sheet-fed offset lithographic press with a cylinder width of 26 

inches or less. 

Wisconsin NR 422.142 – 

Lithographic 

Printing, NR 

423.035 – 

Industrial 

Cleaning 

Operations 

http://www.legis.state.wi.us/rsb/code/nr/nr422.pdf

NR 422.142 Lithographic printing. (1) APPLICABILITY. 

(a) This section applies to all lithographic printing presses at any facility 

which is located in the county of Kenosha, Kewaunee, Manitowoc, 

Milwaukee, Ozaukee, Racine, Sheboygan, Washington or Waukesha and 

which has maximum theoretical emissions of VOCs from all 

lithographic printing presses at the facility greater than or equal to 755.7 

kilograms (1666 pounds) in any month. 

(b) To determine VOC emissions under par. (a), the VOC content of a 

lithographic ink shall be multiplied by 0.8 for a heatset ink, or multiplied 

by 0.05 for a non−heatset ink, to account for VOC retention on the 

substrate. 
30

 

Fountain Solution Limits 

1) San Joaquin Valley Unified Air Pollution Control District

Effective 9/17/2000 – 8 percent VOC by volume as applied 

2) San Diego County Air Pollution Control District

15 percent by volume VOC as applied 

3) South Coast Air Quality Management District

Effective January 1, 2000 – 80 grams per liter VOC as applied or 100 

grams per liter as applied if a refrigerated chiller is used 

4) Bay Area AQMD

 8 percent VOC by volume 

5) Delaware

For heatset web presses: 1.6 percent or less by volume or 3 percent or 

less by volume if the fountain solution is refrigerated to less than 15.6 oC (60 oF) 

For non-heatset web presses: alcohol content in the fountain solution 

shall be eliminated; non-alcohol additives or alcohol substitutes may be used to 

accomplish the total elimination of alcohol use 

For sheet-fed presses: 5 percent or less by volume or 8.5 percent or less 

by volume if the fountain solution is refrigerated to below 15.6 oC (60 oF) 

Any type of offset lithographic printing press is in compliance if the 

only VOC’s in the fountain solution are in non-alcohol additives or alcohol 

substitutes so that the concentration of VOCs’ in the fountain solution is 3 percent 

or less by weight. (The fountain solution shall not contain any alcohol.) 

6) Georgia

8 percent or less by volume VOC 

7) Illinois

 8 percent or less VOC by weight 

8) Kansas

Continuously contain 10 percent or less by weight of alcohol (alcohol is 

defined as isopropanol or isopropyl alcohol) or fountain solution is refrigerated to 

a temperature of 55 oF or less for alcohol-based solutions 
31

9) Maryland

8.5 percent isopropyl alcohol by weight; fountain solution is refrigerated 

to maintain a temperature of less than 55 oF if isopropyl alcohol is used 

10) Massachusetts

For facilities that will not have a usage rate of all VOC-containing 

compounds exceeding 670 gallons per calendar month or a facility-wide 

emission rate of VOC exceeding 2.5 tons per calendar month: 

Non-heatset: for web presses installed on or after May 1, 1998, the 

fountain solution shall not contain any alcohol. 

Sheet-fed presses with cylinder widths greater than 21 inches: 

3 percent alcohol by volume, or 5 percent alcohol by volume and 

fountain solution refrigerated to a temperature of less than 60 oF. 

Sheet-fed presses with cylinder widths less than or equal to 21 

inches: 5 percent alcohol by volume 

Newspaper printing – 0 percent alcohol 

Any VOC-containing additive other than alcohol shall be limited 

to a mix ratio that will result in a VOC concentration in the 

fountain solution, excluding alcohol, equal to or less than 2.5 

percent volume by alcohol. 

For facilities with the potential to emit, before the application of air 

pollution control equipment, equal to or greater than 50 tons per year of 

VOC (310 CMR 7.18(25)(a):

Sheet-fed offset lithographic press using propanol in fountain 

solution: 5 percent VOC by volume as applied or 8 percent VOC 

by volume as applied with fountain solution refrigerated to a 

temperature below 60 oF 

Web fed offset lithographic press using propanol in fountain 

solution: 1.6 percent VOC by volume as applied or 3 percent VOC 

by volume as applied with fountain solution refrigerated to a 

temperature below 60 oF 

Non-heatset web-fed offset lithographic press: 0 percent 

propanol and maintain a total VOC concentration of 2.5 percent or 

less by weight 
32

Propanol Substitute Requirements: Any person subject to 310 

CMR 7.18(25)(a), who owns, leases, operates, or controls an offset 

lithographic press with fountain solution with propanol substitutes, 

containing a concentration of VOC in the fountain solution at 3.0 

percent by volume or less, shall be considered in compliance with 

the VOC emission limitations for fountain solutions contained in 

310 CMR 7.18(25). 

For large printers1 and midsize printers2: 

The following standards apply to midsize and large 

printers, except that they do not apply to the fountain 

solution in a press with a fountain solution reservoir that 

holds less than or equal to one gallon. 

Web-fed Presses: fountain solution shall not contain any alcohol. 

Sheet-fed Presses: 

a. unrefrigerated fountain solution containing alcohol shall 

contain no more than 5 percent VOC by weight, including 

but not limited to alcohol, and; 

b. refrigerated fountain solution containing alcohol shall 

contain no more than 8 percent VOC by weight, including 

but not limited to alcohol, and shall be refrigerated to a 

temperature of less than 60° F.

 

1 Large printer - a printer that uses a total of more than 3,000 

gallons of cleanup solution and inks/coatings/adhesives with a 

VOC content greater than 10 percent by weight as applied, per 

rolling12 month period, where incidental material, ink used in nonheatset offset lithographic printing, waterbased 

ink/coating/adhesive, plastisol and ultraviolet ink are excluded 

from this calculation 

2

 Midsize printer - a printer that uses a total of more than 275 and 

no more than 3000 gallons of cleanup solution and 

inks/coatings/adhesives with a VOC content greater than 10 

percent by weight as applied, per rolling 12 month period, or that 

uses a total of more than 55 gallons of alcohol per rolling 12 month 

period and a total of no more than 3000 gallons of cleanup 

solution, and inks/coatings/adhesives with a VOC content greater 

than 10 percent by weight as applied, per rolling 12 month period, 

where incidental material, ink used in non-heatset offset 

lithographic printing, water-based ink/coating/adhesive, plastisol 

and ultraviolet ink are excluded from this calculation

11) Missouri

(Kansas City) 10 percent or less alcohol by weight and fountain solution 

refrigerated to 55 oF or less for alcohol based solutions 
33

(St. Louis) heat set web: 1.6 percent or less by volume of alcohol, or 3 

percent or less by volume of alcohol and fountain solution is refrigerated to a 

temperature of 60 oF or less, or 5 percent or less by volume of alcohol substitutes 

(St. Louis) sheet-fed: 5 percent or less by volume of alcohol, or 8.5 

percent or less by volume of alcohol and fountain solution is refrigerated to a 

temperature of 60 oF or less, or 5 percent or less by volume of alcohol substitutes 

or combination of alcohol and alcohol substitutes 

(St. Louis) non-heatset web: 5 percent or less by volume of alcohol 

substitutes, or 5 percent or less by volume of a combination of alcohol and 

alcohol substitutes 

12) New Hampshire

Heatset web: 1.6 percent or less by weight, or 3 percent or less by weight 

if the fountain is refrigerated to a temperature below 60 oF, or 5 percent or less by 

weight if the fountain solution contains no alcohol

Sheet-fed: 5 percent VOC or less by weight, or VOC content of 8.5 

percent or less by weight if the fountain solution is refrigerated to a temperature 

below 60 oF 

Fountain solution used in a non-heatset web-fed offset lithographic 

printing process, including both newspaper and non-newspaper facilities,

shall contain no alcohol and the concentration of total VOC’s shall not exceed 5 

percent by weight in the final solution. 

13) New York

10 percent or less by weight of VOC 

14) North Carolina

 None found 

15) Tennessee

Heatset web: 1.6 percent VOC by volume as applied, or 3 percent VOC 

by volume as applied if the fountain solution is refrigerated to less than 60 oF, or 

4.6 percent VOC by volume as applied and use no alcohol in the fountain 

solution, or 6 percent VOC by volume as applied if the fountain solution is 

refrigerated to less than 60 oF and use no alcohol in the fountain solution 

Non-heatset web: No owner or operator of a non-heatset web offset 

printing press subject to this rule shall apply any fountain solution that contains 

alcohol, nor shall any fountain solution be applied unless the VOC content is 

equal to or less than 5 percent by weight of the fountain solution as applied. 
34

Sheet-fed: 5 percent VOC by volume as applied, or 8.5 percent by volume 

as applied is the fountain solution is refrigerated to less than 60 oF 

16) Texas

Heatset web: Any person who owns or operates a heatset web offset 

lithographic printing press that uses alcohol in the fountain solution shall maintain 

total fountain solution alcohol to 5.0 percent or less by volume. Alternatively, a 

standard of 10.0 percent or less by volume alcohol may be used if the fountain 

solution containing alcohol is refrigerated to less than 60 degrees Fahrenheit. 

Nonheatset web newspaper: Eliminate the use of alcohol in the fountain 

solution. Non-alcohol additives or alcohol substitutes can be used to accomplish 

the total elimination of alcohol use. 

Nonheatset web non-newspaper: 5.0 percent or less by volume or 10.0 

percent or less by volume alcohol may be used if the fountain solution is 

refrigerated to less than 60 oF. 

Sheet fed: 10.0 percent or less by volume or 12.0% or less by volume 

alcohol may be used if the fountain solution is refrigerated to less than 60 oF. 

Any person who owns or operates any type of offset lithographic printing 

press shall be considered in compliance with the fountain solution limitations of 

this paragraph if the only VOCs in the fountain solution are in nonalcohol 

additives or alcohol substitutes, so that the concentration of VOCs in the fountain 

solution is 3.0 percent or less by weight. The fountain solution shall not contain 

any isopropyl alcohol. 

17) Virginia

Heatset web: 

 a. When the fountain solution contains alcohol: 

(1) The fountain solution shall contain no more than a daily 

average of 1.6 percent volatile organic compounds by weight; or 

(2) The temperature of the fountain solution shall be maintained at 

or below 60 oF and the fountain solution shall contain no more than 

a daily average of 3.0 percent volatile organic compounds by 

weight; or 

b. When the fountain solution contains no alcohol, the fountain solution 

shall contain no more than a daily average of 5.0 percent volatile organic 

compounds by weight. 

Non-heatset web presses and each newspaper presses: the fountain 

solution shall contain no alcohol and shall contain no more than a daily 

average of 5.0 percent volatile organic compounds by weight. 
35

Sheet-fed press: 

a. The fountain solution shall contain no more than a daily average of 5.0 

percent volatile organic compounds by weight; or 

b. The temperature of the fountain solution shall be maintained at or below 

60 oF and the fountain solution shall contain no more than a daily average 

of 8.5 percent volatile organic compounds by weight. 

18) Wisconsin

Heatset web presses: any person who owns or operates a heatset web 

lithographic printing press shall, when printing on a substrate other than metal, 

metal-foil or plastic, use a fountain solution which has a VOC content as applied 

of no more than one of the following: 

a. 1.6 percent by weight if the fountain solution contains any restricted 

alcohol and is not refrigerated to 60 oF or less. 

b. 3.0 percent by weight if the fountain solution contains any restricted 

alcohol and is refrigerated to 60°F or less. 

c. 5.0 percent by weight if the fountain solution contains no restricted 

alcohol. 

Non-heatset web presses: any person who owns or operates a non-heatset 

web lithographic printing press shall, when printing on a substrate other than 

metal, metal-foil or plastic, use a fountain solution which has a VOC content as 

applied of no more than 5.0 percent by weight and which contains no restricted 

alcohol. 

Sheet-fed presses: any person who owns or operates a sheet-fed 

lithographic printing press shall, when printing on a substrate other than metal, 

metal-foil or plastic, use a fountain solution which has a VOC content as applied 

of no more than one of the following: 

a. 5.0 percent by weight. 

b. 8.5 percent by weight if the fountain solution is refrigerated to 60 oF or 

less. 

Metal, metal-foil or plastic substrates: any person who owns or operates 

any lithographic printing press shall, when printing on a metal, metal-foil or 

plastic substrate, use a fountain solution which has a VOC content as applied of 

no more than one of the following: 

a. 13.5 percent by weight if the fountain solution contains any restricted 

alcohol and is refrigerated to 60 oF or less. 

b. Not more than 1.6 percent by weight if the fountain solution contains 

any restricted alcohol and is not refrigerated to 60 oF or less or 5.0 percent 

by weight if the fountain solution contains no restricted alcohol for 

heatset web; not more than a VOC content as applied of 5.0 percent by 

weight and which contains no restricted alcohol for non-heatset web; and 

not more than a VOC content as applied of 5.0 percent by weight for 

sheet-fed presses. 
36

Appendix C 

State and Local Regulations for Letterpress Printing 

Letterpress State and Local Rules – Ink VOC Content Limits 

State Ink VOC Content Limit (lb/gal as applied, less 

water) 

San Diego 

Rule 67.16 

2.5 

San Joaquin Valley1 

Rule 4607 

2.5 

South Coast1 

Rules 1130 (printing) and 1171 (cleaning) 

2.5 

Massachusetts 

310 CMR 7.26 – (25) 

2.5 

Wisconsin2 

NR 423.035 (cleaning) 

---- 

1. This limit is expressed as lb/gal as applied, less water and less exempt compounds. 

2. Wisconsin only has rules for industrial solvent cleaning operations. 

Letterpress State and Local Rules – Cleaning Solutions 

State Cleaning Solution 

VOC Content 

Limit 

(grams/liter) 

Cleaning Solution VOC 

Composite Partial Vapor 

Pressure, 

millimeters of mercury 

(mm Hg) at 20 oC 

Cleaning Solution 

VOC Content Limit 

(lb/gal) 

San Diego1 200 45 

San Joaquin 

Roller Wash – Step 1 

600 10 5.0 

San Joaquin 

Roller Wash – Step 2, 

Blanket Wash, and Onpress Components 

800 10 6.7 

San Joaquin 

Removable Press 

Components 

50 10 0.42 

South Coast 

Roller Wash – Step 1 

500 4.2 

South Coast 

Roller Wash – Step 2, 

Blanket Wash, and Onpress Components 

500 4.2 

South Coast Removable 

Press Components 

25 0.21 

Massachusetts 25 

Wisconsin On-press 

Components2

 

Wisconsin Removable 

Press Components 

50 0.42 

1. Total vapor pressure 

2. A maximum VOC content of 30% by weight
37

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38

Appendix D 

Estimated Costs Associated with the Recommendations Contained in the 

Control Techniques Guidelines for Offset Lithographic Printing and 

Letterpress Printing 

This appendix presents the estimated costs associated with implementing the 

recommendations in the CTG for controlling volatile organic compounds (VOCs) 

emissions from offset lithographic printing and letterpress printing facilities in ozone 

nonattainment areas. As explained in the CTG, the CTG is guidance for State and local 

pollution control agencies to use in determining “reasonably available control 

technology” (RACT) for VOCs from offset lithographic printing and letterpress printing. 

State and local pollution control agencies are free to adopt the recommendations 

contained in the CTG, or implement other technically-sound approaches for RACT, 

provided those approaches are consistent with the CAA and EPA’s implementing 

regulations. Accordingly, there is necessarily some uncertainty in any prediction of 

costs and emission impacts associated with the recommendations contained in the CTG. 

For purposes of this analysis, we assume that all states will adopt the recommendations in 

the CTG. 

 Costs are presented below for installing and operating control equipment to 

reduce VOC emissions from heatset dryers, and for reducing emissions from cleaning 

through the use of low VOC composite vapor pressure (less than or equal to 10mm Hg at 

20 degrees C) and low VOC content (less than 70 weight percent VOC) cleaning 

materials. 

Estimated nationwide total annual cost of CTG recommendations for offset 

lithographic printing - heatset dryers 

The nationwide total annual cost of the CTG recommendations for offset lithographic 

printing heatset dryers is estimated to be $33 million. 

As shown in Tables 1 through 3, this is based on estimates in the 1993 draft CTG with 

adjustments made for the number of facilities in nonattaiment areas today versus 1993, 

2005 dollars versus first quarter 1990 dollars and the number of facilities already 

achieving the recommendations in this CTG today versus the number of facilities 

achieving the 1993 draft recommendations in 1993. 
39

 Table 1 

Col A Col B Col C Col D Col E 

B*53/60 B*0.4 C*0.2 

heatset 

litho 

model 

plants 

# 

facilities 

in 

nonatt 

areas in 

1993 

draft 

CTG 

# 

facilities 

in 

nonatt 

areas 

today 

# 

facilities 

in 

nonatt 

areas in 

1993 

w/o 

dryer 

controls 

# 

facilities 

in 

nonatt 

areas 

today 

w/o 

dryer 

controls 

A-I 77 68 30 14

A-II 122 108 48 22

A-III 319 282 127 57

A-IV 308 272 123 55

Table 1 Notes 

In 1993, 60 percent of US population was in ozone nonattainment areas. Today, 53 

percent of US population is in ozone nonattainment areas. 

In 1993, 60 percent of heatset dryers were assumed to already be controlled and 40 

percent were assumed to be uncontrolled. Today, 80 percent of heatset dryers are 

assumed to already be controlled and 20 percent are assumed to be uncontrolled. 
40

 Table 2 

Col A Col B Col C Col D Col E 

 B/C D*1.36 

Heatset 

litho 

model 

plants 

total annual 

cost from 

1993 draft 

CTG Table 

E-1 

# of 

facilities 

installing 

controls 

in 1993 

total 

annual 

cost of 

control 

per 

facility 

(1st 

quarter 

1990 

dollars) 

total 

annual 

cost of 

control 

per 

facility 

(2005 

dollars) 

 

A-I $1,513,392 30 $50,446 $68,607

A-II $4,433,742 48 $92,370 $125,623

A-III $20,464,574 127 $161,138 $219,148

A-IV $27,614,987 123 $224,512 $305,336

A cost escalation factor of 1.36 was used to convert first quarter 1990 dollars to 2005 

dollars. 

 Table 3 

Col A Col B Col C Col D 

 B*C 

Heatset 

litho 

model 

plants 

# facilities 

in nonatt 

areas 

today w/o 

dryer 

controls 

total 

annual 

cost of 

control 

per 

facility 

(2005 

dollars) 

total annual 

cost of 

control 

(2005 

dollars) 

 

A-I 14 $68,607 $960,499 

A-II 22 $125,623 $2,763,699 

A-III 57 $219,148 $12,491,447 

A-IV 55 $305,336 $16,793,504 

TOTAL $33,009,150 
41

Estimated nationwide total annual cost of CTG recommendations for offset 

lithographic printing – cleaning 

The nationwide total annual cost of the CTG recommendations for cleaning associated 

with offset lithographic printing is estimated to be $18 million. 

As shown in Tables 4 through 6, this is based on estimates in the 1993 draft CTG with 

adjustments made for the number of facilities in nonattaiment areas today versus 1993, 

2005 dollars versus first quarter 1990 dollars and the number of facilities already 

achieving the recommendations in this CTG today. 
42

 Table 4 

Col A Col B Col C Col D Col E 

 B*53/60 D*0.4 

model 

plants 

# 

facilities 

in 

nonatt 

areas in 

1993 

draft 

CTG 

# 

facilities 

in 

nonatt 

areas 

today 

# 

facilities 

in 

nonatt 

areas 

today 

above 

cutoff 

# facilities in 

nonatt areas 

today above 

cutoff and not 

already meeting 

cleaning 

recommendations 

 

heatset 

A-I 77 68 68 27

A-II 122 108 108 43

A-III 319 282 282 113

A-IV 308 272 272 109

 

coldset 

web 

B-I 158 140 140 56

B-II 535 473 473 189

B-III 1,198 1,058 1,058 423

B-IV 397 351 351 140

 

sheet fed 

C-I 14,362 12,686 0 0

C-II 12,131 10,716 0 0

C-III 2,624 2,318 2,318 927

C-IV 1,733 1,531 1,531 612

 

newspaper 

D-I 419 370 0 0

D-II 93 82 82 33

D-III 42 37 37 15

D-IV 21 19 19 7

D-V 8 7 7 3

D-VI 4 4 4 1
43

Table 4 Notes 

In 1993, 60 percent of US population was in ozone nonattainment areas. Today, 53 

percent of US population is in ozone nonattainment areas. 

The two smallest size sheet-fed model facilities and the smallest size newspaper model 

facility do not exceed the 15 lb/day cutoff. 

In 1993, no facilities were assumed to be meeting the draft recommendations for 

cleaning. Today, at least 60 percent of facilities are assumed to already be meeting the 

recommendations for cleaning because over 60 percent of the nonattainment area 

population is in areas which already have state or local VOC rule for offset lithography. 
44

 Table 5 

Col A Col B Col C Col D Col E 

 B/C D*1.36 

Model 

plants 

total annual 

cost from 

1993 draft 

CTG Table 

E-3 (1st 

quarter 1990 

dollars) 

# facilities in nonatt 

areas in 1993 draft 

CTG 

total annual cost of 

control per facility 

(1st quarter 1990 

dollars) 

total annual cost of 

control per facility 

(2005 dollars) 

 

Heatset 

A-I $84,080 77 $1,092 $1,485

A-II $292,755 122 $2,400 $3,263

A-III $1,529,563 319 $4,795 $6,521

A-IV $2,685,126 308 $8,718 $11,856

 

coldset 

web 

B-I $172,527 158 $1,092 $1,485

B-II $1,283,805 535 $2,400 $3,264

B-III $5,744,251 1,198 $4,795 $6,521

B-IV $3,461,022 397 $8,718 $11,856

 

sheet fed 

C-I $6,323,589 14,362 $440 $599

C-II $10,682,559 12,131 $881 $1,198

C-III $9,242,778 2,624 $3,522 $4,790

C-IV $12,971,678 1,733 $7,485 $10,180

 

newspaper 

D-I $276,729 419 $660 $898

D-II $184,266 93 $1,981 $2,695

D-III $151,639 42 $3,610 $4,910

D-IV $151,639 21 $7,221 $9,820

D-V $119,409 8 $14,926 $20,300

D-VI $96,514 4 $24,129 $32,815

 

Table 5 Notes 

A cost escalation factor of 1.36 was used to convert first quarter 1990 dollars to 2005 

dollars. 
45

 Table 6 

Col A Col B Col C Col D 

 B*C 

Model 

plants 

# facilities in 

nonatt areas 

today above 

cutoff and not 

already meeting 

cleaning 

recommendations 

total 

annual 

cost of 

control 

per 

facility 

(2005 

dollars) 

total annual 

cost of 

control (2005 

dollars) 

 

heatset 

A-I 27 $1,485 $40,403

A-II 43 $3,263 $140,679

A-III 113 $6,521 $735,006

A-IV 109 $11,856 $1,290,293

 

coldset 

web 

B-I 56 $1,485 $82,905

B-II 189 $3,264 $616,911

B-III 423 $6,521 $2,760,304

B-IV 140 $11,856 $1,663,136

 

sheet fed 

C-I 0 $440 $0

C-II 0 $881 $0

C-III 927 $4,790 $4,441,463

C-IV 612 $10,180 $6,233,324

 

newspaper 

D-I 0 $660 $0

D-II 33 $2,695 $88,546

D-III 15 $4,910 $72,868

D-IV 7 $9,820 $72,868

D-V 3 $20,300 $57,380

D-VI 1 $32,815 $46,378

 

TOTAL $18,342,463
United States 

Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Sector Policies and Programs Division 

Research Triangle Park, NC 

Publication N