SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

Final Staff Report for 

Proposed Amended Rule 1171 - Solvent Cleaning Operations 

Deputy Executive Officer 

Planning, Rule Development, & Area Sources 

Elaine Chang, DrPH 

Assistant Deputy Executive Officer 

Planning, Rule Development, & Area Sources 

Laki Tisopulos, Ph.D., P.E. 

Director 

Area Sources 

Lee Lockie, M.S. 

February 2008 

____________________________________________________________________________ 

Author: Rizaldy Calungcagin, Air Quality Specialist 

Reviewed By: Louis Yuhas, Program Supervisor 

 William Wong, Sr. Deputy District Counsel 

Technical Assistance: David De Boer, Sr. Staff Specialist 

 Heather Farr, Air Quality Specialist 

 Michael Morris, Air Quality Specialist
i 

SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

GOVERNING BOARD 

Chairman: DR. WILLIAM A. BURKE

Speaker of the Assembly Appointee 

Vice Chairman: S. ROY WILSON, Ed.D. 

 Supervisor, Fourth District 

 County of Riverside 

MEMBERS:

MICHAEL D. ANTONOVICH Supervisor, Fifth District 

County of Los Angeles 

 BILL CAMPBELL 

 Supervisor, Third District 

 County of Orange 

JANE W. CARNEY 

Senate Rules Appointee 

RONALD O. LOVERIDGE

Mayor, Riverside 

Cities of Riverside County 

 JOSEPH K. LYOU, Ph.D. 

 Governor’s Appointee 

 GARY C. OVITT 

Supervisor, Fourth District 

 County of San Bernardino 

 JAN PERRY 

 Councilmember, 9th District 

 City of Los Angeles Representative 

MIGUEL A. PULIDO 

Mayor, Santa Ana 

Cities of Orange County 

 TONIA REYES URANGA 

 Councilmember, City of Long Beach 

 Cities of Los Angeles County/Western Region 

 DENNIS YATES 

 Mayor, Chino 

 Cities of San Bernardino County 

 VACANT 

 Cities of Los Angeles County/Eastern Region 

EXECUTIVE OFFICER:

 BARRY R. WALLERSTEIN, D.Env. 
ii 

_______________________________________________________________ 

TABLE OF CONTENTS 

 page 

Executive Summary 1 

Background 2 

Legislative Authority 5 

Rule Proposal 5 

Emissions Inventory and Reductions 8 

Cost 10 

Socioeconomic Impacts 10 

California Environmental Quality Act 11 

Comparative Analysis 11 

Findings 12 

Public Comments 12 
Proposed Amended Rule 1171 Final Staff Report 

1 

EXECUTIVE SUMMARY 

Proposed Amended Rule (PAR) 1171 – Solvent Cleaning Operations will delay by one year the 

implementation of the 100 gram per liter VOC limit scheduled to take effect on January 1, 2008 

for the cleaning of ultraviolet or electron beam (UV/EB) inks from lithographic printing ink 

application equipment. Staff’s proposal supports the printing industry’s position that additional 

time is needed to fully develop compliant cleaning materials for certain cleaning applications. 

The Printing Industry Association (PIA) has indicated that the users need to conduct further 

tests in order to have enough actual production experience in the use of these products. For the 

same reason, staff is also proposing to extend by one year the limited exemption for the 

cleaning of metering rollers, dampening rollers and printing plates in lithographic UV/EB ink 

application equipment, including cleaning of UV/EB lamps and reflectors. The emission 

impact of this proposal will result in delayed emission reduction of about 0.11 tons per day. 

For clean up of rollers and blankets in lithographic ink application equipment using 

conventional inks, and the clean up of screen printing equipment, the VOC limit of 100 grams 

per liter will be implemented on January 1, 2008 as currently required in Rule 1171. The 

expected VOC emission reduction from implementing the 100 gram per liter VOC limit for 

lithographic ink application equipment using conventional inks is 1.83 tons per day beginning 

year 2008. 

However, staff is proposing to add a limited exemption for on-press cleaning of screens in 

screen printing equipment, and for automatic cleaning equipment used in screen reclamation. 

Such limited exemptions will allow screen printers to continue using solvents that comply with 

the current VOC limit of 500 grams per liter for an additional one year and at the same time 

continue testing low VOC solvent formulations. Clean up solvents used in other screen 

reclamation activities must comply with the 100 grams per liter VOC limit beginning January 

1, 2008. The expected VOC emission reduction from manual screen reclamation is 0.47 tons 

per day. 

The delayed VOC emission reduction as a result of the limited exemption for on-press screen 

cleaning and automatic cleaning equipment for screen reclamation is estimated at 0.10 tons per 

day. Including the impact of delaying the VOC limit for UV/EB ink application equipment, the 

total delayed emission reduction resulting from PAR 1171 would be 0.21 tons per day. 

Other proposed amendments to Rule 1171 include: 

• expanding the rule applicability to include solvent suppliers who supply, sell or 

offer for sale solvent cleaning materials; 

• adding clarifying language for solvent supplier, full service solvent provider, onpress screen cleaning, screen reclamation, and removable press component; 

• addition of recordkeeping requirements for solvent suppliers; 

• requiring operators to maintain, and for solvent suppliers to provide, correct written 

instructions if dilution is necessary to meet the applicable VOC limits; 

• adding labeling requirements for solvent cleaning materials pursuant to Rule 443.1 

– Labeling of Materials Containing Organic Solvents; 

• adding rule language prohibiting full service solvent providers from aiding, abetting 

or assisting a solvent cleaning operation to use a supplied solvent in a noncompliant manner; and 
Proposed Amended Rule 1171 Final Staff Report 

2 

• removal of outdated rule provisions pertaining to technology assessments and the 

limited exemption for UV/EB adhesive application equipment. 

BACKGROUND 

Rule 1171 – Solvent Cleaning Operations, a key component of South Coast Air Quality 

Management District’s (AQMD) ozone reduction strategy, was adopted on August 2, 1991 to 

reduce VOC emissions from the use of solvents and solvent wastes generated during the 

production, repair, maintenance, or servicing of products, tools, machinery, and general work 

areas. Subsequent rule amendments expanded the scope of the rule to cover all solvent 

cleaning activities at all facilities. 

On October 8, 1999, Rule 1171 established low-VOC limits for all solvent cleaning activities 

identified in the rule. Achievement of the target VOC limits was expected through greater use 

of aqueous cleaning technologies and VOC-exempt solvents, and through the development of 

new low-VOC cleaning materials. Most of the VOC limits established in 1999 for Rule 1171 

have now been implemented except for certain solvent cleaning activities involving ink 

application equipment. Facilities engaged in lithographic and screen printing are directly 

affected by this pending VOC limit of 100 grams per liter set to take effect on January 1, 2008. 

Since establishing the 100 gram per liter VOC limit in 1999 for the clean up of ink application 

equipment, the compliance date for the use of low-VOC solvents for such application has been 

delayed twice due to infeasibility of the VOC limits at that time. The original compliance date 

was July 1, 2005. Furthermore, unforeseen delays in the completion of the AQMD-sponsored 

technology assessment for lithographic ink application equipment provided additional 

justification for delaying the implementation of the low-VOC limits. 

In May 2006, the technology assessment to support the target VOC limits for lithographic ink 

application equipment was completed. The results of the study indicated that low-VOC 

alternative cleaning materials such as water-based cleaners, blends of VOC-exempt solvents, 

and methyl esters can be used to clean press rollers and blankets. The final report titled 

“Assessment, Development and Demonstration of Low-VOC Materials for Cleaning 

Lithographic Printing Ink Application Equipment” dated May 2006 is available to the public at 

http://www.aqmd.gov/rules/support.html. 

The last amendment to Rule 1171 in July 2006 provided an 18-month extension in the 

compliance date for the use of 100 gram per liter formulations for clean up of ink application 

equipment used in lithographic and screen printing. The delay in compliance date allowed the 

printing industry and solvent formulators additional time to evaluate the results of the 

technology assessment, develop and further test new formulations, and transition to the new 

cleaning materials. The industry has been largely successful in this effort. 

During the past 18 months, the printing industry, solvent formulators, and the AQMD have 

been working together in developing and testing solvent formulations that meet the 100 gram 

per liter VOC limit for cleaning press rollers and blankets. Compliant products were tested in 

actual production environments at various printing facilities. Test results indicated significant 

success in the performance of low-VOC cleaning materials for removing conventional inks 

from rollers and blankets in lithographic ink application equipment. This success was achieved 

for both manual (hand wipe) and automatic cleaning of rollers and blankets. 
Proposed Amended Rule 1171 Final Staff Report 

3 

AQMD staff visited several printing facilities involved in the test program (Taylor Graphics, 

The Castle Press, The Foster Printing, Huhtamaki) and verified the positive performance results 

of the low-VOC cleaners. Taylor Graphics successfully tested both an ester-based product and 

a water-miscible cleaner. The Castle Press and The Foster Printing tested ester-based cleaners 

from different solvent formulators. Huhtamaki tested an ester-based cleaner for removing EB 

inks and reported positive results. However, the company continues to test other compliant 

formulations. 

Staff has also visited other facilities using compliant materials for cleaning rollers and blankets. 

LA Graphico has been successful in using an ester-based product (34 g/l VOC) in automatic 

roller and blanket wash system for cleaning conventional inks. This product is currently 

available in the market. 

Based on the results of the test program, the printing industry believes that there is enough 

evidence indicating that low-VOC products can meet the performance requirements of the 

printers for cleaning ink application equipment using conventional inks. In addition, solvent 

formulators have indicated to AQMD staff that more compliant formulations are now available 

for clean up of conventional inks, and that the printing industry has met the 100 gram per liter 

VOC limit which took effect on January 1, 2008. 

A similar, but more limited, test program has been taking place for the clean up of UV/EB inks. 

However, industry’s resources in testing compliant products were focused more on the clean up 

of conventional inks rather than on UV/EB inks because most of the VOC clean up emissions 

in lithographic printing come from conventional inks. Staff estimates that the clean up of 

conventional inks accounts for 96% of the total lithographic clean up solvent emissions. As a 

result, very few additional compliant formulations have been developed by solvent formulators 

for UV/EB ink clean up and made available for testing. Industry believes that a research 

approach similar to the one used for conventional inks can be used for UV/EB inks in finding 

acceptable compliant formulations. 

Although considerable progress has been made in finding low-VOC alternative cleaners for 

UV/EB inks, the printing industry has requested a one year extension to the compliance date 

for the use of 100 gram per liter formulations for clean up of UV/EB inks only. Since earlier 

research efforts were focused in finding alternative cleaning materials for conventional inks, 

industry believes that additional time is needed to develop more new formulations for UV/EB 

ink clean up and to test these solvents in actual production environment. 

It is worthwhile to note that staff has visited a few facilities that are already in compliance with 

the 100 gram per VOC limit for clean up of UV/EB inks. House of Packaging uses ester-based 

products for removing UV inks from rollers and blankets. Another facility, Money Mailer, is 

already in compliance with the 100 gram per liter VOC limit for roller and blanket wash. 

While the presence of a limited number of low-VOC cleaning solvent formulations that work 

well for certain applications is highly encouraging, more time is needed for the development 

and testing of additional formulations that perform well for the entire spectrum of UV/EB 

applications and substrates over extended time frames. 

Based on the information presented by the printing industry, as well as field data gathered, staff 

believes that an extension of the compliance date for the 100 gram per liter VOC limit is 

justifiable and reasonable. Staff has also reconsidered its earlier proposal and is now proposing 

a one year extension in the compliance date to allow industry additional time in developing and 
Proposed Amended Rule 1171 Final Staff Report 

4 

testing compliant formulations. The industry has committed to provide regular progress reports 

to staff on its test program during this time period. 

Another cleaning application where the 100 gram per liter VOC limit will take effect beginning 

2008 is in the clean up of screen printing equipment. Screens used in the printing process are 

cleaned periodically with solvents during press runs to remove excess inks and/or 

contaminants. This process is called on-press screen cleaning. Another process where solvents 

are used to remove inks is in reclamation where screens are completely cleaned for recycling or 

reuse of the screens for other production runs. 

The Specialty Graphic Imaging Association (SGIA), an association of screen printers, 

coordinated a test program to find low-VOC alternative cleaners that meet the 100 gram per 

liter VOC limit in Rule 1171 for clean up of screen printing equipment. The SGIA worked 

with various vendors/formulators of screen chemicals and several screen printers to develop 

and test low-VOC cleaning materials for cleaning of screens on-press and during screen 

reclamation. SGIA’s test program, however, was focused on finding compliant formulations 

for screen reclamation since this cleaning activity accounts for about ninety (90) percent of the 

total solvent clean up emissions in screen printing operation. Graphics screen printing facilities 

that use UV and solventborne inks, and textile screen printers using plastisol inks, participated 

in the test program. 

SGIA has yet to submit the final test results but data gathered by AQMD staff from various 

sources indicate that compliant formulations performed well in removing UV and solventborne 

inks during screen reclamation. In one instance, the user indicated to AQMD staff that the test 

product performed better than the current high-VOC cleaner. In addition, several solvent 

formulators/suppliers informed AQMD that compliant products are also available for clean up 

of plastisol inks in screen reclamation, and that such cleaning application should not be a 

problem in meeting the 100 gram per liter VOC limit. These solvent formulators also indicated 

that additional compliant cleaning materials will be available for removing UV and 

solventborne ink during screen reclamation in time for the January 1, 2008 compliance date. 

Similar to lithographic printing, an AQMD-sponsored technology assessment to support the 

low-VOC limits for screen printing ink application equipment was completed last year. The 

study indicated that low-VOC alternative cleaning materials such as water-based cleaners, 

blends of VOC-exempt solvents and methyl esters can be used for removing inks from screens. 

Details of the study can be found in the final report titled “Low VOC, Low Toxicity Clean up 

Solvents for Screen Printing: Safer Alternatives” dated May 2006. This report is available to 

the public at http://www.aqmd.gov/rules/support.html. 

For on-press cleaning of screens, the screen printing industry stated that they have not been 

successful in finding acceptable alternative cleaners due to the lack of sufficient testing of 

compliant formulations. The industry focused their research efforts on manual screen 

reclamation, and it was only during the last few months that solvent formulators have started 

looking at potential raw materials that can be used to formulate compliant products for on-press 

screen cleaning. This was confirmed during AQMD staff’s recent conversations with solvent 

formulators. However, the SGIA continues to work with solvent manufacturers and 

formulators to develop commercially viable cleaning materials that meet the 100 gram per liter 

VOC limit. 

Even though progress has been made in demonstrating the effectiveness of compliant 
Proposed Amended Rule 1171 Final Staff Report 

5 

formulations for certain screen printing clean up applications, the SGIA recently submitted a 

letter to the AQMD requesting a one year delay in the compliance date for the 100 grams per 

liter VOC limit for both on-press screen cleaning and screen reclamation. Based on available 

information, staff believes that the 100 grams per liter VOC limit for clean up of screen 

printing equipment can be implemented beginning January 1, 2008, and that additional 

compliant clean up solvents for manual screen reclamation will be available by the start of 

2008. For on-press cleaning of screens, staff supports delaying the implementation of the 100 

gram per liter VOC limit for one year in order for the screen printing industry to develop and 

test compliant formulations for on-press cleaning of screens. Staff also supports delaying the 

compliance date for automatic cleaning equipment used in screen reclamation. 

LEGISLATIVE AUTHORITY 

The California Legislature created the South Coast Air Quality Management District (AQMD) 

in 1977 (The Lewis-Presley Air Quality Management Act, Health and Safety Code Section 

40400 et seq.) as the agency responsible for developing and enforcing air pollution control 

rules and regulations in the South Coast Air Basin (Basin). By statute, the AQMD is required 

to adopt an Air Quality Management Plan (AQMP) demonstrating compliance with all state 

and federal ambient air quality standards for the Basin [California Health and Safety Code 

Section 40460(a)]. Furthermore, the AQMD must adopt rules and regulations that carry out the 

AQMP [California Health and Safety Code Section 40440(a)]. 

RULE PROPOSAL 

Staff is proposing to amend Rule 1171 as follows: 

1. Amend the rule’s applicability, subdivision (a) 

Staff is proposing to expand the rule’s applicability to include all solvent suppliers who 

supply, sell, or offer for sale solvent cleaning materials for use in solvent cleaning 

operations. 

2. Add definition language 

Staff’s proposal will add clarifying language for the following terms used in the rule: 

• Full service solvent provider, paragraph (b)(16); 

• On-press screen cleaning, paragraph (b)(37); 

• Removable press component; paragraph (b)(45); 

• Screen reclamation; paragraph (b)(51); and 

• Solvent supplier, paragraph (b)(55). 

For the definition of removable press components, staff is proposing to add ink trays to the 

list of press parts that are not considered removable press components. Similar to the 

cleaning of rollers and blankets, the current industry practice is to clean ink trays while the 

trays are still physically attached to the press. Occasionally, ink trays are removed from the 

press for subsequent cleaning. The VOC limit for cleaning on-press components shall 

apply for such cleaning application. 

For solvent supplier definition, home improvement retailers or hardware stores such as 
Proposed Amended Rule 1171 Final Staff Report 

6 

Home Depot, Lowe’s, Ace Hardware, TrueValue, Orchard Supply Hardware, etc. would 

fall under the definition if such retailer sells and delivers or arranges to deliver solvent 

cleaning materials to a solvent cleaning operations. 

3. Add a recordkeeping requirement for solvent suppliers, paragraph (c)(7) 

Staff is proposing to add rule language that requires a solvent supplier to keep records, for 

up to 3 years, of solvent cleaning materials sold to solvent cleaning operations. This 

requirement takes effect July 1, 2008. 

Under California Health & Safety Code section 42303.2, AQMD has the authority to 

request information from suppliers of volatile organic compounds and chemical substances 

the use of which results in air contaminants subject to regulations by AQMD. The 

proposed recordkeeping requirement simply codifies specific information that the AQMD 

may request from solvent suppliers as allowed under the California Health & Safety Code. 

The type of information requested includes the following: product name of the supplied 

solvent cleaning material; name and address of the solvent cleaning operation the product 

was supplied to; dates and quantities in which the product was supplied during the time 

period specified by the Executive Officer; and the VOC content of the product as supplied. 

4. Require operators to maintain, and for solvent suppliers to provide, correct written 

dilution instructions, paragraph (c)(8) 

The intent of this proposal is to assist end users of solvent cleaning materials in complying 

with the VOC requirements in the rule. The proposed rule language would require the user 

or operator of a solvent cleaning operation to maintain at all times the correct written 

dilution instructions for solvent cleaning products requiring dilution to meet the VOC 

requirements, and make these dilution instructions available to the Executive Officer upon 

request. These dilution instructions should be specific for each solvent cleaning product, 

and should be obtained from the solvent supplier. Staff believes that the ultimate 

responsibility for maintaining dilution instructions and operating at the appropriate dilution 

ratio rests on the user or operator. 

In addition, the proposed rule language would require solvent suppliers providing solvent 

cleaning material for use in solvent cleaning operations to provide, upon the operator’s or 

user’s request, the correct written dilution instructions for each supplied solvent cleaning 

material. If the solvent cleaning material provided already meets the applicable VOC limit, 

then dilution information would not be necessary. For multi-purpose solvents, dilution 

instructions may have to be provided for all applicable solvent cleaning applications. 

Dilution instructions may be printed on product data sheets, formulation data sheets, 

Material Safety Data Sheets, product labels, or on any other written form, including making 

the dilution instructions available on the solvent supplier’s website. 

5. Add language pertaining to labeling of solvent cleaning materials, paragraph (c)(9) 

Staff is adding language for solvent suppliers to label solvent cleaning materials, as they are 

already required to do, in accordance with the provisions of Rule 443.1 – Labeling of 

Materials Containing Organic Solvents. 

6. Prohibit full service solvent providers from assisting solvent cleaning operations in 
Proposed Amended Rule 1171 Final Staff Report 

7 

using solvents in a non-compliant manner, paragraph (d)(5)

Staff is proposing rule language that would prohibit a full service solvent provider from 

aiding, abetting or assisting a solvent cleaning operation in the non-compliant use of 

solvent cleaning materials. By definition, a full service solvent provider is any person that 

provides both solvents and services to a solvent cleaning operation. Such services may 

include, but are not limited to, one or more of the following: filling or refilling solvent 

cleaning equipment with solvent, collection or pick up of customer’s solvent-related waste 

stream, equipment sales or rental, or maintenance of solvent cleaning equipment. 

A full service solvent provider typically has direct contact with its customers and knows 

more about their customers’ operations, such as cleaning activities and solvent products 

used, than any other type of solvent supplier. Many of its customers, particularly small 

businesses, rely on the full service solvent provider to supply them with solvent cleaning 

materials that comply with Rule 1171 requirements. However, field data indicates that 

some of these full service solvent providers actively assist their customers in their use of 

solvent materials in a non-compliant manner. 

The intent of this proposal is to place some responsibility on the full service solvent 

provider to keep its customers in compliance when the provider is aware or should be aware 

that its customers are using the supplied solvents in a non-compliant manner. Thus, the 

proposed rule will place liability on the full service solvent provider for aiding, abetting or 

assisting a solvent cleaning operation to use a supplied solvent in a non-compliant manner. 

For example, a full service solvent provider that fills or refills solvent cleaning equipment 

with concentrated non-compliant solvent cleaning material should take affirmative steps to 

ensure that the solvent will be properly diluted to meet the applicable VOC limits in the 

rule. One such step would be to actually dilute the concentrated solvent for the customer. 

At a minimum, a full service solvent provider should educate its customers on how to dilute 

the concentrated solvent to meet the applicable limits. On the other hand, a full service 

solvent provider that fills or refills a solvent cleaning reservoir with a pre-mixed product, 

intended to be used for cleaning without dilution, would be liable if the pre-mixed solution 

does not meet the applicable VOC limits in the rule. 

Another situation that may be considered aiding, abetting or assisting a solvent cleaning 

operation to use a supplied solvent in a non-compliant manner is when a full service solvent 

provider represents to its customer that a non-compliant product is actually compliant. 

7. Delay the 100 gram per liter VOC limit compliance date for clean up of UV/EB ink 

application equipment, clause (c)(1)(D)(vi)

The printing industry has requested a one year extension in the compliance date for the use 

of 100 gram per liter formulations to allow additional time to develop more new 

formulations for UV/EB ink clean up and test these solvents in actual production 

environment. Industry believes that similar test approach used in conventional inks can be 

applied in UV/EB inks to find acceptable compliant formulations. Previously, staff 

supported a shorter test period (six months) but has reconsidered its initial proposal. 

Staff is now proposing a one year delay in the implementation of the 100 gram per liter 

VOC limit for solvents used in the clean up of UV/EB ink application equipment in 

lithographic/letterpress printing. Currently, the VOC limit for this cleaning application is 
Proposed Amended Rule 1171 Final Staff Report 

8 

650 grams per liter until the end of 2007. The proposed new compliance date for the 100 

grams per liter VOC limit is January 1, 2009. 

8. Extend the exemption for the cleaning of UV/EB lamps and reflectors, subparagraph 

(g)(3)(H)

Staff’s proposal will extend until January 1, 2009 the exemption for the cleaning of UV/EB 

lamps and reflectors, consistent with the one year extension in compliance date provided to 

UV/EB ink application equipment. This proposal is in response to public comments 

received during the Public Workshop for PAR 1171. 

9. Add a limited exemption for on-press cleaning of screens and automatic cleaning 

equipment for screen reclamation, paragraph (g)(9) 

Until January 1, 2009, staff is proposing to exempt from the 100 gram per liter VOC limit 

the on-press cleaning of screens in screen printing equipment, including automatic cleaning 

equipment used in screen reclamation. These limited exemptions allow industry to 

continue using solvents with VOC content of no more than 500 grams per liter, for an 

additional one year, and at the same time test 100 gram per liter formulations that would 

meet their performance requirements. The addition of the limited exemption for automatic 

cleaning equipment is in response to public comments received during the Public 

Workshop for PAR 1171.

10. Extend the exemption for the cleaning of metering rollers, dampening rollers and 

printing plates in UV/EB ink application equipment, paragraph (g)(10) 

Staff is proposing to extend by one year the limited exemption for cleaning of metering 

rollers, dampening rollers and printing plates in UV/EB ink application equipment, 

provided the clean up solvent used for such cleaning contains no more than 800 grams of 

VOC per liter.

11. Remove outdated rule requirements 

Staff’s proposal will remove outdated rule language as follows: 

a. Technology assessment provision in paragraph (d); and 

b. Limited exemption for cleaning of UV/EB adhesive application equipment, 

subparagraph (g)(5)(D). 

EMISSIONS INVENTORY AND REDUCTIONS 

The VOC emissions inventory data presented in the June 2006 Final Staff Report for PAR 1171 

(July 2006 amendment) were used in determining emissions impacts of the proposed 

amendments to Rule 1171. Staff did not include annual growth factors to the emissions data, 

which were based on year 2004 currency. 

Staff’s proposal to delay implementation of the 100 gram per liter VOC limit for lithographic 

UV/EB ink application equipment would result in a one year delay in achieving VOC emission 

reductions of about 0.11 tons per day. However, such reductions will occur beginning January 

1, 2009. 

For lithographic printing using conventional inks, the 100 grams per liter VOC limit will be 
Proposed Amended Rule 1171 Final Staff Report 

9 

implemented as scheduled on January 1, 2008. Implementing this VOC limit for this cleaning 

application will result in VOC emission reduction of 1.83 tons per day. 

In the area of screen printing, extending the compliance date to January 1, 2009 the 100 grams 

per liter VOC limit for on-press screen cleaning and screen reclamation using automatic 

cleaning equipment will delay the expected VOC emission reduction of about 0.10 tons per day 

from these cleaning applications. For manual screen reclamation, the VOC limit of 100 grams 

per liter will be implemented beginning January 1, 2008, and will result in VOC emission 

reduction of 0.47 tons per day. 

The total VOC emission reduction as a result of implementing the 100 grams per liter VOC 

limit starting January 1, 2008 is as follows: 

VOC Emission Reduction from Lithographic-Conventional Inks = 1.83 tons per day 

VOC Emission Reduction from Manual Screen Reclamation = 0.47 tons per day 

Total VOC Emission Reduction beginning 2008 = 1.83 tons per day + 0.47 tons per day 

 = 2.30 tons per day 

The total VOC emission reduction delayed to 2009 as result of staff’s proposals to extend the 

compliance date for the use of cleaning materials with 100 grams per liter or less VOC in 

certain cleaning applications is: 

Delayed VOC Emission Reduction from UV/EB inks = 0.11 tons per day 

Delayed VOC Emission Reduction from Screen Printing = 0.10 tons per day 

Total VOC Emissions Delayed = 0.11 tons/day + 0.10 tons/day 

 = 0.21 tons per day 

Table 1 shows the VOC emissions inventory and reductions for cleaning applications affected 

by the proposed amendments. (Source: Final Staff Report for PAR 1171, June 2006) 
Proposed Amended Rule 1171 Final Staff Report 

10 

Table 1 – VOC Emission Inventory and Reductions for PAR 1171 

Ink Application 

Equipment 

2007 VOC 

Emissions 

Inventory 

(tons/day) 

1/1/08 VOC 

Emission 

Reductions 

(tons/day) 

Delayed 

VOC 

Emission 

Reductions 

(tons/day) 

Final VOC 

Emissions 

Inventory 

(tons/day) 

Lithographic – 

Conventional Inks 2.27 1.83 0 0.44 

Lithographic – 

UV/EB Inks 0.13 0 0.11 0.02 

Screen Printing 

a) Reclamation(1)

• Manual Cleaning 

• Automatic Cleaning(2)

 b) On-Press Cleaning 

Total Screen Printing 

0.64 

0.59 

0.05 

0.07 

0.71 

0.47 

0.47 

 0 

 0 

0.47 

0.04 

 0

0.04 

0.06 

0.10 

0.13 

0.12 

0.01 

0.01 

0.14 

Total 3.11 2.30 0.21 0.60 

Notes: 

(1) VOC emissions from screen reclamation are about 90% of total screen printing clean up solvent emissions. 

(2) The VOC emissions from screen reclamation using automatic cleaning equipment are calculated based on 

data provided by industry. 

COST 

Staff’s proposal to delay the implementation of the 100 gram per liter VOC limit for cleaning 

of lithographic UV/EB ink application equipment, on-press screen cleaning from screen 

printing equipment, and screen reclamation using automatic cleaning equipment is a relaxation 

of an existing requirement in Rule 1171 and, therefore, does not impose additional cost to the 

affected industry. The staff report for the 1999 amendment of Rule 1171 provides a detailed 

cost-effectiveness analysis, including an incremental cost analysis, for the 100 gram per liter 

VOC limit for these cleaning applications. 

SOCIOECONOMIC IMPACTS 

The proposed amendments to Rule 1171 (PAR 1171) would delay by one year (until January 1, 

2009) the compliance date for solvents with VOC content of 100 grams per liter or less used in 

lithographic printing using UV/EB inks, on-press screen cleaning, and screen reclamation using 

automatic cleaning equipment. The cost associated with using the low-VOC solvent would 

thus be delayed by one year. 

PAR 1171 would also extend an existing exemption for the cleaning of metering rollers, 

dampening rollers, printing plates, and UV/EB lamps and reflectors in UV/EB ink application 

equipment. There is no additional cost resulting from this extension. Instead, the provision 

allows flexibility to the affected printing operations as they gain experience in using products 

with lower VOC content. 
Proposed Amended Rule 1171 Final Staff Report 

11 

PAR 1171 would require solvent suppliers to provide correct written dilution instructions to the 

end user if dilution is necessary to meet the applicable VOC limits in the rule. Staff believes 

that there is no additional cost associated with this proposal because most solvent suppliers of 

cleaning materials sold in the AQMD already provide dilution instructions if needed to meet 

the VOC limits in the rule. 

In addition, PAR 1171 would also require solvent suppliers to keep records of solvent cleaning 

materials sold for up to three years, and such records be made available to AQMD in an 

approved format upon request. Under California Health & Safety Code section 42303.2, 

AQMD has the authority to request information from suppliers of volatile organic compounds 

and chemical substances the use of which results in air contaminants subject to regulations by 

AQMD. PAR 1171 recordkeeping requirement codifies specific information that the AQMD 

may request from solvent suppliers. Furthermore, keeping records of business transactions for 

at least five years for tax purposes is already part of current business practice. Based on the 

above information, staff has concluded that this proposal will not result in additional cost to the 

solvent suppliers. 

In conclusion, PAR 1171 does not have any cost impact and would thus have no adverse 

socioeconomic impacts. 

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) ANALYSIS 

AQMD staff has reviewed Proposed Amended Rule 1171 pursuant to state CEQA Guidelines 

§15002 (k)(3) and the AQMD’s Certified Regulatory Program (Rule 110). A Draft Subsequent 

Environmental Assessment (EA) was prepared, pursuant to CEQA Guidelines §15162 and 

§15252 because the proposed project constitutes a modification of a previously approved 

project that was analyzed in a Final EA that was certified by the AQMD Governing Board in 

October 1999. The Draft Subsequent EA was circulated for a 45-day public review and 

comment period from November 21, 2007 to January 4, 2008. The project will result in a delay 

of VOC emission reductions that will exceed the SCAQMD’s daily significance operational 

threshold and, thus, adverse air quality impacts have been determined to be significant. No 

other environmental topic area is considered to have an adverse impact as a result of the 

proposed project. One public comment letter was received on the Draft Subsequent EA, and 

responses to the comment letter can be found in the Final Subsequent EA. Minor modifications 

were made to the Draft Subsequent EA so it is now a Final Subsequent EA. Changes to the 

project description are minor and do not change the conclusions made in the Draft Subsequent 

EA or increase the environmental impact analyzed in the Draft Subsequent EA. Pursuant to 

CEQA Guidelines §15073.5(c)(2), recirculation is not necessary since the information provided 

does not result in new avoidable significant effects. 

COMPARATIVE ANALYSIS 

The only federal requirement applicable to similar sources is the National Emission Standards 

for Hazardous Air Pollutants (NESHAP) requirement for handwipe cleaning in the aerospace 

industry. The requirements of Rule 1171, however, do not apply to handwipe cleaning in the 

aerospace industry; therefore, Rule 1171 is not in conflict with any federal requirement. 

Additionally, AQMD Rule 1401 - New Source Review of Toxic Air Contaminants and Rule 

1402 - Control of Toxic Air Contaminants from Existing Sources, control the emissions of 
Proposed Amended Rule 1171 Final Staff Report 

12 

solvent containing toxic or hazardous air pollutants. Rule 1401 limits emissions from new and 

modified permitted sources exceeding certain thresholds, and Rule 1402 limits emissions from 

existing sources. 

FINDINGS UNDER THE CALIFORNIA HEALTH AND SAFETY CODE 

Before adopting, amending, or repealing a rule, the California Health and Safety Code requires 

the AQMD to adopt written findings of necessity, authority, clarity, consistency, nonduplication, and reference, as defined in Section 40727. The draft findings are as follows: 

Necessity – The AQMD Governing Board has determined that a need exists to amend Rule 

1171 – Solvent Cleaning Operations, in order to delay the compliance date of VOC limits that 

are infeasible at this time for certain cleaning applications. 

Authority – The AQMD Governing Board obtains its authority to adopt, amend, or repeal 

rules and regulations from the California Health and Safety Code sections 39002, 40000, 

40001, 40440, 40441, 40702, 41508, and 41700. 

Clarity – The AQMD Governing Board has determined that the proposed amendment to Rule 

1171 is written or displayed so that its meaning can be easily understood by persons directly 

affected by it. 

Consistency – The AQMD Governing Board has determined that Proposed Amended Rule 

1171 is in harmony with, and not in conflict with or contradictory to, existing statutes, court 

decisions, federal or state regulations. 

Non-Duplication – The AQMD Governing Board has determined that the proposed 

amendment to Rule 1171 does not impose the same requirements as any existing state or 

federal regulations, and the proposed amended rule is necessary and proper to execute the 

powers and duties granted to, and imposed upon, the AQMD. 

Reference – In adopting this regulation, the AQMD Governing Board references the following 

statutes which the AQMD hereby implements, interprets or makes specific: California Health 

and Safety Code sections 40001, 40440, and 40702. 

PUBLIC COMMENTS AND RESPONSES 

This section summarizes the comments received as result of the Public Workshops conducted 

on November 7, 2007 and December 4, 2007. 

COMMENT: Reformulated cleaners meeting the 100 g/l VOC requirement for screen 

reclamation have not been available in quantities that allow for testing in 

automatic cleaning machines. We are asking AQMD to consider 

delaying implementation of the 100 g/l VOC limit for this cleaning 

application to allow adequate time to test lower VOC products and 

evaluate any effects the products may have on the equipment. 

RESPONSE: Staff agrees that low-VOC cleaners developed for screen reclamation 

have not been extensively tested in automatic cleaning equipment. 

Staff’s latest proposal now includes a limited exemption for screen 
Proposed Amended Rule 1171 Final Staff Report 

13 

reclamation using automatic cleaning equipment until January 1, 2009 to 

allow industry additional time to develop and test more compliant 

formulations for use in the cleaning equipment. Furthermore, the 

extension in compliance date allows solvent manufacturers more time to 

produce compliant formulations in larger quantities to support the needs 

of the screen printing industry. 

COMMENT: Low VOC cleaning solvents require the use of haze removers to clean 

screens during final reclamation which means the use of additional 

chemicals to comply with Rule 1171. 

RESPONSE: Staff disagrees. Screen printers already use haze removers even when 

using high-VOC cleaning solvents. Some of the cleaning materials 

successfully tested that meet the 100 g/l VOC limit were effective in 

removing both inks and ghost images (haze) during screen reclamation; 

thus, potentially eliminating the need for haze removers during screen 

reclamation.

COMMENT: It is not clear what staff means by on-press screen cleaning and screen 

reclamation. 

RESPONSE: The preliminary draft staff report differentiates on-press screen cleaning 

from screen reclamation. Staff has now added definitions to the rule for 

both terms to clarify rule intent. 

COMMENT: Solvent manufacturers have indicated that low VOC products are 

expected to cost close to twice as much as the cleaning products 

currently being used. Furthermore, it is possible that larger quantities of 

low VOC products may be necessary to achieve the same results as those 

products with higher VOC content. 

RESPONSE: Staff disagrees. Data obtained during field visits indicate that low VOC 

products may cost just slightly higher than cleaners currently being used. 

The cost effectiveness analysis presented in Final Staff Report for the 

1999 Rule 1171 amendment concluded that lowering the VOC limit to 

100 g/l to achieve emission reduction is cost effective in spite of higher 

solvent replacement cost. Staff does not expect a significant increase in 

the cost of low VOC solvents as more compliant solvents become 

available in the market. 

As far as solvent usage is concerned, staff believes that facilities may 

end up using less volume of the low VOC solvents for the same cleaning 

application because most of the compliant formulations available do not 

readily evaporate as compared to high VOC solvents. Staff noted in 
Proposed Amended Rule 1171 Final Staff Report 

14 

visits to several printing facilities testing low VOC cleaners that solvent 

usage remained the same, or was even lower in certain applications; thus 

making the transition to the 100 g/l formulation even more cost effective. 

COMMENT: It seems that the AQMD and its contractor IRTA believe that soy is the 

answer to lowering VOCs in cleaning materials. Soy bean derived 

cleaning materials do not work well in removing UV and conventional 

inks from screens especially in automated cleaning systems. 

Furthermore, automatic cleaning machines were designed for the use of 

conventional solvent cleaners. Existing cleaning machines may need to 

be retrofitted or re-designed to make them compatible with low VOC 

products. 

RESPONSE: AQMD does not specify the use of any product or raw material to 

achieve the VOC limits in the rule. The technology assessment 

conducted by IRTA found successful use of certain soy-based 

formulations for cleaning screens. However, the findings from this 

technology assessment did not indicate soy as the only solution to 

lowering the VOC content of cleaning materials. 

Staff is aware of other ester-based formulations (non-soy) that were 

successfully tested at different printing facilities for manual screen 

reclamation. The limited exemption added to the initial rule proposal 

would allow solvent formulators and screen printing facilities additional 

time to develop and test other low VOC products for screen reclamation 

using automatic cleaning equipment. 

COMMENT: The existing exemption for the clean up of UV/EB lamps and reflectors 

in Rule 1171 (g)(3)(H) will expire at the end of this year. We are 

requesting a one year extension of the exemption similar to UV/EB ink 

application equipment because industry has not yet begun to test 

alternative cleaners for such application. 

RESPONSE: Staff agrees. Rule language has been modified to allow a one year 

extension of the exemption for cleaning UV/EB lamps and reflectors. 

The additional time will allow the printing industry to work with UV/EB 

equipment manufacturers and solvent formulators in developing and 

testing alternative cleaners for cleaning UV/EB lamps and reflectors. 

Staff is recommending this extension with the commitment from the 

industry to provide regular progress reports to the Stationary Source 

Committee on the test program. 

COMMENT: A representative from Huhtamaki clarified that the company has not 

converted to an ester-based cleaner as implied in the Preliminary Draft 
Proposed Amended Rule 1171 Final Staff Report 

15 

Staff Report. However, the company continues to test other low-VOC 

cleaners.

RESPONSE: Staff has modified language in the Draft Staff Report to clarify that the 

company tested an ester-based cleaner with positive results but continues 

to test other compliant formulations. In a telephone conversation with 

Huhtamaki, a company representative indicated that more products will 

be tested in order to find the best performing cleaner for their 

application. 

COMMENT: The AQMD should provide a list of compliant formulations so that 

industry can be aware of potential low-VOC alternatives. 

RESPONSE: Staff is currently working with the printing industry and solvent 

formulators in developing a list of low-VOC cleaners that have been 

successfully tested for various lithographic printing cleaning 

applications. The PIA will establish a database on their website of these 

compliant formulations and there will be a link to PIA also available on 

the AQMD website. Information to be presented includes product name, 

solvent manufacturer or supplier, VOC content, contact person, cleaning 

application, etc. The list will be updated as more compliant products 

become available. 

COMMENT: Heatset presses utilize dryers to set the ink. The use of highly volatile, 

low flashpoint exempt solvents such as acetone increases the risk of 

explosion or fires in the dryers, presenting an unacceptable safety risk. 

RESPONSE: The AQMD is not requiring the use of acetone to comply with the VOC 

limit for cleaning lithographic printing ink application equipment. 

Acetone is a good cleaner but may not be a suitable alternative cleaner 

for certain applications, e.g., heatset presses. Other compliant solvent 

formulations with lower flashpoint and volatility have been developed 

and tested with acceptable results for lithographic printing applications. 

COMMENT: The testing by PIA and IRTA did not demonstrate success of 100 g/l 

cleaners for web-fed, high-speed lithographic presses. Sheet fed, coldset 

presses that were used during the tests allowed for extensive hand 

washing because the presses were frequently down during cleaning. 

Web-fed, high-speed lithographic presses are cleaned with the press 

running and cannot be stopped for manual cleaning without significant 

loss in productivity. Furthermore, build up of solvent residue causes 

solvent to drip onto the printed products thus creating quality problems. 

RESPONSE: The PIA selected printers with sheet fed presses as test sites from a 
Proposed Amended Rule 1171 Final Staff Report 

16 

segment of the industry that accounts for a significant fraction of the 

total amount of solvent consumed by all lithographic printers. Rollers 

and blankets from sheet fed presses are washed more often than in web 

presses because of shorter printing runs and frequent color changes in 

sheet fed presses; therefore, any productivity loss as a result of using low 

VOC cleaning materials will be greatly felt by printers with sheet fed 

presses. The feedback obtained from the PIA indicated that the 

compliant formulations tested performed well enough with no significant 

loss in productivity. In addition, staff is aware of a facility that has been 

using low VOC cleaning material in its web-fed, heatset presses for 

about three (3) years now without quality or productivity problems. 

It is important to reiterate that low VOC cleaners are not drop-in 

replacements for high VOC washes for rollers and blankets. Printers 

need to spend time to test and learn how to use these low VOC cleaners 

to make them work. This may require a few changes in their cleaning 

process. 

The commenter has indicated that his company has identified a 

compliant product and is ready to transition to the 100 g/l formulation 

when the new VOC limit takes effect on January 1, 2008. AQMD staff 

suggests that the company continue testing other 100 g/l formulations if 

it is not completely satisfied with the performance of their cleaner. 

COMMENT: There is no way for solvent suppliers to keep track of day to day use of 

their products to ensure that the products are being used in a compliant 

manner. If the AQMD intends to regulate a specific type of solvent 

supplier, then the proposed language in (d)(5) should reflect that 

explicitly rather than categorize all solvent suppliers under one general 

category. 

RESPONSE: The intent of the proposed language is to hold certain solvent suppliers 

liable in the event they are assisting its customers in the non-compliant 

use of solvent cleaning materials or misrepresenting VOC content to 

their customers. Recently, AQMD’s compliance staff has inspected and 

found solvent cleaning activities where certain solvent suppliers appear 

to have knowingly provided non-compliant cleaning materials to its 

customers or may have misrepresented non-compliant solvents provided 

to its customers as being compliant with the VOC requirements in Rule 

1171. These solvent suppliers, commonly known in the industry as full 

service solvent providers, supply both solvents and other services to their 

customers such as cleaning equipment sales or rentals, filling or refilling 

of cleaning equipment with solvent, pick up or collection of customer’s 

solvent-related waste stream, etc.; thus, the term “full service.” Because 

of their direct contact with users, these full service solvent providers 

know what products their customers are using, what cleaning 

applications these products are used for, and how these products are 
Proposed Amended Rule 1171 Final Staff Report 

17 

being used relative to Rule 1171 requirements. These solvent suppliers 

are in the best position, and often a position of trust, to recommend and 

provide to their customers products that comply with rule requirements. 

Currently, Rule 1171 does not have a provision that would subject such 

solvent suppliers to liability for aiding, abetting or assisting their 

customers in the non-compliant use of solvent cleaning materials. 

Examples of non-compliance activities that may be considered “aiding, 

abetting or assisting” under this prohibition are discussed in the “Rule 

Proposal” section in this Draft Staff Report. 

In order to make the proposed rule language consistent with the original 

intent, the prohibition now applies only to full service solvent providers. 

Staff has added a definition for full service solvent provider to clarify 

rule intent. 

COMMENT: Rule compliance has always been the user’s responsibility and PAR 

1171’s efforts to add responsibility and potential liability to a supplier 

for an operator using non-compliant solvent seems unnecessary. The 

District should not pass on compliance efforts to solvent suppliers in the 

event the District has been ineffective in overseeing solvent cleaning 

operators. 

RESPONSE: Staff agrees that the ultimate responsibility for rule compliance is with 

the user or operator of solvent cleaning operations, and that the District 

has the responsibility for enforcing its rules and regulations. The 

proposed prohibition language in (d)(5) is not intended to have certain 

solvent suppliers police its customers to ensure that compliance with the 

rule is achieved. As mentioned in the response to the previous comment, 

such prohibition language would allow the AQMD to prosecute certain 

solvent suppliers, i.e., full service solvent providers, who know the rule 

requirements and their customers’ needs but continue to provide them 

with non-compliant cleaning materials or assist them in the use of 

solvents in a non-compliant manner. Many of these users of solvent 

cleaning materials assume that they are receiving compliant cleaning 

materials from their full service solvent providers. The prohibition 

language has been modified to limit the liability to full service solvent 

providers to be consistent with staff’s intent. 

COMMENT: PAR 1171 needs to be clear as to what “supplier” means. Our company 

offers solvents to distributors and we have no way of knowing where 

they are selling the solvents and to whom, not to mention the specific 

application. The same is true for solvents suppliers located outside the 

AQMD or California. We suggest that the definition for solvent supplier 

include the language “last point of sale for a solvent cleaning material” 

to clarify that the liability would clearly belong to the company that last 
Proposed Amended Rule 1171 Final Staff Report 

18 

sold the material to the end user. 

RESPONSE: For the purpose of this rule, a solvent supplier is a person who sells and

delivers or arranges to deliver solvent cleaning materials to a solvent 

cleaning operation. Anyone who sells to a distributor is not considered a 

solvent supplier. Retailers and hardware stores such as such as Home 

Depot, Lowe’s, Ace Hardware, TrueValue, Orchard Supply Hardware, 

etc. would fall under the solvent supplier definition if such retailer sells 

and delivers or arranges to deliver solvent cleaning materials to a solvent 

cleaning operation. Likewise, United Parcel Service or similar delivery 

services are not solvent suppliers under this rule. 

Staff has added clarifying language to the solvent supplier definition. 

COMMENT: The AQMD should provide information on what is an approved 

electronic format as stated in the proposed recordkeeping requirements 

in order to evaluate any potential additional cost burden to the solvent 

supplier. It is also difficult for certain solvent suppliers to capture 

information as to how the customer will use the product or the intended 

VOC content of the product as applied. 

RESPONSE: In implementing the recordkeeping provision in the rule, AQMD staff 

will require that the requested data be provided in a simple spreadsheet 

format using computer software commonly used by businesses such as 

Microsoft Excel. Staff does not believe that this would impose an 

additional cost burden to the solvent suppliers given the fact that most 

businesses use computers. 

With regard to information required from solvent suppliers, staff has 

modified the original proposed rule language to exclude data on intended 

use of the product as well as intended VOC of the product as applied. 

Staff’s revised language requires only information on name and VOC 

content of the supplied solvent cleaning material, name and address of 

the solvent cleaning operation that the product was supplied to, and dates 

and quantities in which the product was supplied during the time period 

specified by the Executive Officer.

COMMENT: We suggest that AQMD allows solvent suppliers enough lead time to 

comply with the recordkeeping and dilution provision in the rule. 

RESPONSE: Staff agrees and has added a compliance date of July 1, 2008 for both 

recordkeeping and dilution requirements. 

COMMENT: AQMD needs to hold another Public Workshop to address proposed 

rules changes regarding solvent suppliers. The workshop notice should 
Proposed Amended Rule 1171 Final Staff Report 

19 

clearly identify that rule changes will impact solvent suppliers. 

RESPONSE: Staff disagrees. The two Public Workshops, and the one focused 

conference call on this subject, conducted for PAR 1171 were adequate 

to inform the public and soliciting information from them regarding the 

proposed changes to Rule 1171. AQMD notices for both public 

workshops clearly identify those facilities affected by PAR 1171, 

including solvent suppliers who supply solvent cleaning materials to 

solvent cleaning operations. 

COMMENT: We have not been successful in finding cleaning solution that meets the 

VOC limit for cleaning metering rollers in our electrophotographic 

printing process. Our customers will have to replace the metering rollers 

since AQMD has not proposed extending the exemption for cleaning 

these rollers. 

RESPONSE: Staff has met with the commenter several months ago and suggested to 

the company representative several options to meet the requirements of 

the rule. Such options include: testing other potential cleaning solvents 

with low viscosity to clean the metering rollers in the Binary Image 

Developer (BID) unit of the electrophotographic printing process; the 

use of compressed air; or the use of an emission control system such as 

carbon adsorber. In addition, AQMD also provided a list of solvent 

formulators for the company to contact and work with on alternative 

cleaning materials. 

At that time, the company agreed to continue testing other alternative 

cleaning methods and submit a detailed report to AQMD on the results 

of alternative cleaning materials tested. To date, AQMD has not 

received any report from the company on what products have been tested 

to clean the BID units. The only input received from the commenter 

prior to the workshop pertains to the company’s plan to discard the old 

BID units and replace them with new ones that do not require cleaning. 

Staff believes that the company should pursue all options including those 

suggested by AQMD.