TECHNICAL SUPPORT DOCUMENT

Department of the Environment 

Amendment to — COMAR 26.11.19.10 Flexographic 

and Rotogravure Printing and Adoption of New 

Regulations COMAR 26.11.19.10-1 Flexible 

Packaging Printing

Purpose of Action 

The purpose of this action is to adopt the requirements of the Environmental Protection Agency 

(EPA) Control Techniques Guidelines (CTG) for flexible packaging printing. EPA develops 

CTGs as guidance on control requirements for source categories. States can follow the CTGs or 

adopt more restrictive standards. MDE proposes to adopt the CTG standards for flexible 

packaging printing and work practices. 

Background 

EPA developed the CTG after conducting a review of currently existing state and local VOC 

emission reduction approaches for flexible package printing, reviewing the 1978 CTG and the 

1996 NESHAP for the printing and publishing industry (40 CFR Part 60, Subpart KK), which is 

applicable to flexible package printing and taking into account the information that has become 

available since then. 

Flexible packaging refers to any package or part of a package the shape of which can be readily 

changed. Flexible packaging includes, but is not limited to, bags, pouches, liners, and wraps 

utilizing paper, plastic, film, aluminum foil, metalized or coated paper or film, or any 

combination of these materials. Flexible packaging materials start out as rolls of paper or foil, or 

beads of plastic resin, and are converted into a package or roll of packaging material. 

Any printing of shrink-wrap labels or wrappers conducted on or in-line with a flexible package 

printing press is also considered to be included under the flexible packaging source category. 

Printing of self-adhesive labels is not included in flexible packaging. 

Rigid packaging printing operations are often times co-located with flexible package printing 

operations. Folding cartons, some labels and wrappers, gift wraps, wall coverings, vinyl 

products, decorative laminates, floor coverings, tissue products, and miscellaneous specialty 

products are not considered flexible packaging. 

Flexographic and rotogravure presses are used in flexible packaging. There are two main sources 

of VOC emissions from flexible package printing for both flexographic and rotogravure: (1) 

evaporation of VOC from inks, coatings, and adhesives, and (2) evaporation of VOC from 

cleaning materials. 

1 
Sources Affected 

This action will affect sources that use flexographic and rotogravure presses to print flexible 

packaging materials. 

Requirements 

COMAR 26.11.19.10 is amended to state that the requirements for flexible packaging printing 

are in COMAR 26.11.19.10-1 Flexible Packaging Printing. 

Standards for flexible packaging printing lines are: 

1. 0.8 lb VOC/lb or kg VOC/kg solids applied; or 

2. 0.16 lb VOC/lb or kg VOC/kg materials applied; or 

If a control device is used: 

The dryer exhaust is required to be ducted to a control device that is constructed, operated, and 

maintained to achieve various overall control efficiencies based on the installation date of the 

Flexible Packaging line and air pollution control device. 

The work practice standards apply to the usage of all VOC containing materials. 

Basis for Emission Standards 

The CTG standards are: 

• 65 percent overall control for a press that was first installed prior to March 14, 1995 and 

that is controlled by an add-on air pollution control device (APCD) whose first installation date was 

prior to the effective date. 

• 70 percent overall control for a press that was first installed prior to March 14, 1995 and 

that is controlled by an add-on APCD whose first installation date was on or after the effective date 

of the rule. 

• 75 percent overall control for a press that was first installed on or after March 14, 1995 and 

that is controlled by an add-on APCD whose first installation date was prior to the effective date of 

the rule. 

• 80 percent overall control for a press that was first installed on or after March 14, 1995 and 

that is controlled by an add-on APCD whose first installation date was on or after the effective date 

of the rule. 

Equivalent Standards 

The CTG provides two optional standards that can be met with the use of low VOC content 

materials or combinations of materials and controls as follows: (1) 0.8 kg VOC/kg solids applied, 

or (2) 0.16 kg VOC/kg materials applied. 

DRAFT 2 12/15/2009 1:10 PM 
DRAFT 3 12/15/2009 1:10 PM 

Expected Emissions Reductions 

This proposed action sets standards for flexible packaging printing. VOC emissions reductions in 

Maryland would be approximately 0.08 tons/day.

Health Effects and Ground-Level Ozone 

The maximum benefit from these amendments will be provided during the ozone season when 

VOCs readily combine with NOx to form the pollutant ground level ozone.

Economic Impact

The economic impact of implementing CTG requirements has been estimated by EPA on a 

national level. Cost effectiveness is approximately $1,400-2,400/ton of VOC controlled. The 

impact on the Department is going to be minimal as affected sources are already regulated. The 

Department will need to review additional records and ensure new standards are being met.

Revision to Maryland's SIP 

This action will be submitted to the U.S. EPA for approval as a revision to Maryland's State 

Implementation Plan. 

Other State or Federal Requirements 

There are no other state or federal reasonably available control technology standards for this 

category. Multiple facilities are covered under this CTG and each may be subject to additional 

federal requirements.

Comparison to Federal Standards 

There is a corresponding federal standard to this proposed action, but the proposed action is not 

more restrictive or stringent. 

References

Control Techniques Guidelines for Flexible Package Printing (EPA 453/R-06-003 September 

2006)