VENTURA COUNTY APCD 

STAFF REPORT 

REVISIONS TO RULE 74.19, GRAPHIC ARTS 

June 2011 

EXECUTIVE SUMMARY 

Staff is proposing to revise Rule 74.19, Graphic Arts, 

to reduce the reactive organic compound (ROC) 

emissions from graphic arts operations. This rule 

development will implement an All Feasible Measure 

as required by the California Clean Air Act (H&SC 

Section 40914). Ventura County APCD’s 2007 Air 

Quality Management Plan relies on adopting All 

Feasible Measures as a strategy to attain the ozone

ambient air quality standard. In addition, the 

Environmental Protection Agency (EPA) has issued a 

revised control technique guideline (CTG) in 

September of 2006 on the “Control of Volatile 

Organic Compound Emissions from Offset 

Lithographic and Letterhead Printing.” This 

document establishes the federal reasonably available 

control technology (RACT) guidelines for 

nonattainment areas such as Ventura County. 

Staff is proposing to reduce ROC emissions from 

graphic arts operations in Ventura County by: 

• Reducing the ROC content of cleaning solvents 

used for printing operations. 

• Lowering the ROC content of fountain solutions 

used by lithographic printing operations. 

The proposed revisions to Rule 74.19 will affect 

approximately 32 graphic arts operations. The 

permitted or potential ROC emissions from these 

graphic arts operations are approximately 125 tons 

per year. The estimated control effectiveness of the 

proposed revisions is about 40 percent or 51 tons of 

ROC per year. Almost all of the emission reductions 

are based on the use of low-ROC cleaners. Examples

of low-ROC cleaners include vegetable/soy-based 

cleaners, water-based emulsions, and exempt organic

compound cleaners (acetone or PCBTF). The 

existing rule allows printers to use low vapor pressure 

cleaners instead of low-ROC cleaners, and ROC 

emissions will be reduced when printers switch to 

low-ROC cleaners. The proposed revisions to the 

cleaner requirements are based on four existing air

district regulations: South Coast AQMD Rules 1130 

and 1171, Bay Area AQMD Regulation 8, Rule 20, 

San Joaquin Valley APCD Rule 4607, and 

Sacramento Metro AQMD Rule 450. 

The other proposed change to Rule 74.19 establishes

new ROC standards for fountain solutions used by 

lithographic printing operations. These standards are 

based on the recommendations published in the 2006 

Control Techniques Guidelines for Offset 

Lithographic Printing and Letterpress Printing by 

EPA’s Office of Air Quality Planning and Standards. 

These new proposed ROC standards for fountain 

solutions are estimated to reduce ROC emissions by 

only about 3 tons per year since existing standards

have been quite effective. 

The estimated cost analysis for replacing existing 

cleaning products with low-ROC versions was based

on work performed by the Bay Area AQMD (October 

2008 Staff Report). The estimated price changes for 

the new products ranged from an increase of 7 

percent to a decrease of 25 percent. The costeffectiveness for these cleaner replacements ranged

from a cost of $0.17 per pound of ROC reduced to a 

cost savings. This indicates that the proposal is very 

cost-effective especially relative to new sources, 

which may be required under New Source Review to 

spend $9 per pound of ROC reduced to install best 

available control technologies (BACT). 

EPA evaluated the costs of lowering or eliminating 

the use of alcohol concentration of fountain solutions 

in their 1993 control technique guideline. Also, costs 

of using blanket wash cleaners having a high-ROC 

content were compared to the use of low-ROC 

cleaners in the guidelines. According to EPA, the 

proposed fountain solution requirement produces a 

cost saving ranging from $700 to $1,500 per year for 

each printing operation. The cost-effectiveness of

low-ROC content cleaner was about $0.31 per pound 

of ROC reduced according to the EPA control 

technique guideline. 

This report contains five additional sections: (1)

Background, (2) Proposed Rule Requirements, (3) 

Comparison of Proposed Rule Requirements with 

Other Air Pollution Control Requirements, (4) Impact 

of the Proposed Rule, and (5) Environmental Impacts

of Methods of Compliance. The first section 

provides background information including 

regulatory history, latest air pollution control 

technology, and source description. The second 

section explains the key features of the proposed 

revisions to Rule 74.19. The third section compares 

the proposed requirements with existing federal 

requirements and Best Available Control Technology 

(BACT). The fourth section is an analysis of the 

proposed amendment's effect on ROC emissions and 

socioeconomic impacts. The last section examines 

the environmental impacts of compliance methods 

and the mitigations of those impacts. 
 Rule 74.19 Staff Report Page 2

BACKGROUND 

Introduction 

Ventura County APCD Rule 74.19, Graphic Arts, 

was first adopted on August 11, 1992. The analysis

of the source emissions, rule requirements, and 

control technologies were summarized in the staff 

report associated with that rule adoption. The initial 

rule adoption was based on a July 18, 1991, 

RACT/BARCT guidelines developed by the Air 

Resources Board and a statewide committee of local 

air district representatives in 1991. 

Rule 74.19 was updated in 2001 and was based on the

September 1993 Control Techniques Guideline for 

Offset Lithographic Printers and a June 1994 

Alternative Control Techniques document on offset 

lithographic printers. Also, a more recent 

RACT/BARCT guidance document dated May 28, 

1992, was also used for this revision. The 2001 

revision reduced the ROC content or vapor pressure 

of cleaning solvents and lowered the ROC content of

fountain solutions, adhesives, and flexographic inks 

used on porous substrates. Another significant 

change was aligning the rule requirement threshold 

with the permitting requirement for graphic arts 

operations. 

 

This staff report will focus only on those areas that 

will be most impacted by the proposed revisions, 

which include fountain solutions at lithographic 

printing operations and solvent cleaning at all printing 

operations. The proposed fountain solution standards 

are based on the 2006 federal CTG guidelines as 

adopted by the Sacramento Metro AQMD Rule 450 

in 2008, while the proposed changes for cleaning 

solvents is based on a RACT analysis that reviewed 

the rules from four air districts: South Coast, Bay 

Area, San Joaquin, and Sacramento. 

Graphic Arts Operations 

The ROC emissions at graphic arts operations are 

based on organic solvent evaporation from the use of 

inks, coatings, adhesives, and solvent cleaners. With 

the use of waterborne or low-ROC coatings, 

adhesives and inks required by Rule 74.19, the 

cleaning of printing press rollers and blankets has

become the largest source of ROC emissions. 

Fountain solutions, especially those containing 

alcohol, are another significant source of ROC 

emissions. 

Graphic arts operations consist primarily of six types 

of printing: inkjet, gravure, screen printing, 

letterpress, flexography, and lithographic printing. 

Graphic arts operations currently in the county 

include all of the above except gravure printing. 

ROC emissions from screen printing are regulated by

a different rule, Rule 74.19.1, Screen Printing 

Operations, which was adopted on June 11, 1996. 

Permitted printing operations in the county are 

predominantly lithography with some inkjet, 

flexography, and letterpress. 

The current exemption in the rule for inkjet printing 

operations is being retained based on the fact that

there is only one relatively large permitted source

(about 5 tons per year) that is using solvent-based

inks. Although water-based ink may be used in most

inkjet printing operations, the performance properties 

of solvent-based inks are still superior for the more 

demanding applications such as outdoor billboards 

and signs. 

Letterpress, the oldest type of printing, involves 

printing from a raised ink surface directly onto the 

paper. Flexography is similar to letterpress printing 

since both have a raised ink surface. The difference 

is that flexography uses a rubber image carrier on a 

steel mat mounted on a cylinder. Flexography can be 

used for a variety of substrates including toilet tissue, 

corrugated board, foil, cellophane, polyethylene, and 

other plastic films. Inkjet printing is where liquid ink 

is transferred at high velocity through small diameter 

opening(s) to any solid substrate, including vinyl,

paper, plastic, or metal. 

Lithography, the newest type of printing, dominates

periodical and newspaper printing. The image and 

the nonimage areas are on the same plane. Using the 

principle that oil and water do not mix, the image area 

is receptive to oil-based ink and water repellent. The 

nonimage area is receptive to water and repels the 

ink. 

The process known as offset lithography is when the

ink is transferred from the plate to a rubber blanket 

and then to the substrate. Lithography uses a water 

system supplied by the fountain solution, which is 

used to continually wet the nonimage areas. 

Emission Inventory 

The graphic arts operations currently permitted by the 

District are shown in Table 1. This table provides the 

permitted or potential emissions from each source 

with the total of 125 tons of ROC per year. The 

actual emissions depend on the production level and

type of inks, fountain solution, and cleaners used. 
 Rule 74.19 Staff Report Page 3

Table 1. Permitted Graphic Arts Operations in Ventura County1

Facility Name Permitted ROC 

Emissions 

(tons/year) 

Type of Printing SIC Code 

AA Printing 1.36 Offset Printing 2750 

Amp Graphics 1.05 Lithography 2752 

Arms Printing 1.05 Lithography 2759 

Bestforms 4.99 Litho/Flexo/Letterpress 2752 

Captured Image 0.62 Lithography 2754 

Clarks Printing 4.22 Lithography 2759 

Coast Index 3.45 Lithography/Screen 2752 

Crockett Graphics 9.00 Lithography 2653 

Crockett Graphics 4.99 Flexography 2653 

Custom Printing 4.99 Lithography 2752 

Fausset Printing 1.05 Lithography 2752 

Flyer Web Printing 1.05 Lithography 2752 

Herald Printing 3.80 Lithography 2759 

Indigo Ink 4.99 Inkjet 2759 

International Paper - Santa Paula 9.11 Flexography 2653 

International Paper - Camarillo 4.85 Flexography 2653 

Jano Graphics 4.75 Lithography 2752 

John Devine Printing 1.05 Lithography 2759 

Ojai Printing 1.05 Lithography 2752 

Packaging Corp of America 4.58 Flexography 2653 

Pepsi Bottling Company 0.25 Inkjet 2086 

Pharmaceutic Litho & Label Company 3.68 Lithography/Flexography 2754 

Precision Tag 1.05 Flexography 2752 

Print N Image 1.05 Lithography 2752 

Procter & Gamble 2.6 Inkjet 2676 

Quickprint Plus 1.05 Lithography 2759 

Signature Graphics 1.05 Lithography 2752 

Sir Speedy -Camarillo 0.83 Lithography 2752 

Taylor Printing 4.17 Lithography 2754 

Technicolor Home Entertainment 10.00 Lithography/Screen 3652 

TFP Data 3.6 Lithography 2752 

The Printing Press 0.37 Lithography 2752 

Ticket Factory 1.05 Letterpress 2752 

Tod Road Jail 1.05 Lithography 9223 

Vanguard Printing 2.94 Lithography 2752 

Ventura County Star – Camarillo 10.41 Lithography 2752 

Ventura Printing 7.60 Lithography 2759 

TOTAL PERMITTED EMISSIONS 124.75 

 

1

 Screen printing operations are not included in this list and are regulated by a different rule (74.19.1). 
 Rule 74.19 Staff Report Page 4

PROPOSED RULE REQUIREMENTS 

The proposed rule revisions will reduce ROC 

emissions by: 

1. Lowering the ROC content of cleaning solvents. 

2. Lowering the ROC content of fountain solutions 

at lithographic printing operations. 

The proposed effective date for these new 

requirements is January 1, 2012. Bay Area AQMD 

Regulation 8, Rule 20, Graphic Art Printing and 

Coating Operation, was last amended on November 

19, 2008. The effective dates for most of the 

cleaning requirements in Bay Area are July 1, 2010,

with one exception for a specialty flexographic 

cleaning requirement, which becomes effective on 

July 1, 2011. The cleaning requirement in South 

Coast AQMD Rule 1171 for graphic arts operations 

have been in effect for several years, with the 

exception of the cleaning requirement for 

ultraviolet/electron beam cured ink applicators, which 

became effective January 1, 2010. 

Section B.2: Fountain Solution Requirements 

The existing limits on the applied ROC content of 

fountain solutions used at lithographic printing 

operations is 80 g/l (100 g/l if refrigerated to 55oF or 

lower at the supply tank). The new proposed limits

are based on federal guidelines and are currently in 

effect in Sacramento Metro AQMD Rule 450. The 

fountain solution limit depends upon the type of 

printing operation, and are summarized in Table 2. 

Table 2 

Proposed Fountain Solution Requirements 

FOUNTAIN SOLUTION LIMITS 

BY PRINTING METHOD 

LIMITS 

ROC CONTENT 

Percent by 

weight - applied 

a. HEATSET WEB-FEB OFFSET LITHOGRAPHIC PRINTING 

 1) If no refrigeration and contains alcohol: 1.6 

 2) If refrigerated below 55oF and contains alcohol 3.0 

 3) If no alcohol in fountain solution 5.0 

b. NON-HEATSET WEB-FED OFFSET LITHOGRAPHIC 

 PRINTING (This fountain solution may not contain alcohol.) 

5.0 

c. SHEET-FED LITHOGRAPHIC PRINTING with maximum 

 sheet size greater than 11X17 inches or total solution 

 reservoir greater than one gallon 

 1) If no refrigeration and contains alcohol 5.0 

 2) If refrigerated below 55oF and contains alcohol 8.5 

 3) If no alcohol in fountain solution 5.0 

d. ALL OTHER PRESSES NOT LISTED ABOVE 

 1) If no refrigeration 8.0 

 2) If refrigerated below 55oF 10.0 

Another new federal requirement in this proposal 

states that any fountain solution at a Non-Heatset 

web-fed offset lithographic printing operation shall 

not contain any alcohol. 

Alcohol is defined as a monohydric alcohol 

containing one hydroxyl group. Examples included 

methanol, ethanol, and iso-propyl alcohol. South 

Coast AQMD Test Method 313-91, “Determination 

of VOCs by Gas Chromatography/Mass Spectrometry 

(GC/MS) is referenced in the rule for alcohol content 

compliance determinations. 

In Ventura County, most of the lithographic printing 

operations are using fountain solutions without any

alcohol. Moreover, a few are using fountain solutions 

with zero ROC content. The most common practice 

is to use an alcohol substitute as a dampening aid to 

enhance the spreadability of the fountain solution 

across the lithographic plate. These alcohol 

replacements are made up of glycols, such as ethylene 
 Rule 74.19 Staff Report Page 5

glycol, glycol ethers, or cellosolve ethers, which are 

chemically similar to alcohol, but not defined as 

alcohols in the rule. They have the same surface 

tension reducing ability but have more complex 

structures and higher boiling points than alcohol. The 

ability to maintain the proper balance of ink and 

fountain solution depends on many factors, including 

the press, dampening system, rollers, ink, paper, 

water quality, and operator skill and training. 

Although alcohol substitutes range from 0 to 100 

percent ROC, only small quantities are used with 

large quantities of water with the ratio of 2 to 4 

ounces per gallon of water. These mixtures result in a 

final solution with less than 3 percent ROC, by 

weight. 

One available fountain solution from Amerikal 

Products is a one-step buffered fountain solution for 

UV/EB and cold set newsprint inks. The applied 

VOC for this product is about 0.11 percent by weight. 

Beside being low-VOC, this product has no regulated

toxics and performs without alcohol. Other benefits 

include sharper dot, improved drying, and better ink 

mileage. Second-step chemicals containing ethylene

glycol are not necessary for this one-step product.

Section B.2: Solvent Cleaning 

The vapor pressure requirements related to cleaning

solvents in graphic operations are proposed to be 

eliminated and replaced with new lower ROC content 

standards. Although lower vapor pressure cleaners 

will evaporate more slowly, the use of low-ROC 

cleaners are much more effective in reducing 

emissions. The ROC content of low vapor pressure 

cleaners may contain up to 6.6 pounds of ROC per 

gallon, while new low-ROC cleaners contain less than 

0.83 pounds of ROC per gallon. This is the basis for 

the significant emission reductions anticipated by this 

rule proposal. The proposal summarized in Table 3 is 

based on identical requirements already adopted by 

the South Coast AQMD, Bay Area AQMD, San 

Joaquin Valley APCD, and the Sacramento Metro 

AQMD. 

The graphics arts industry uses a variety of cleaning 

products to remove excess printing inks, oils, grease, 

coatings, and adhesives, and to remove unwanted 

dust, debris, and other pressroom contaminants. 

Cleaning solvents are defined in Rule 74.19 as the 

removal of uncured inks, coatings, and adhesives. 

Table 3 

Proposed Solvent Cleaning Requirements 

SOLVENT CLEANING ACTIVITY LIMITS - ROC Content

g/l (lb/gal) 

a. Surface Preparation 25 (0.21) 

b. Repair and Maintenance Cleaning 25 (0.21) 

c. Other Press Parts 25 (0.21) 

d. Cleaning of Coatings or Adhesives Application Equipment 25 (0.21) 

e. Cleaning of Ink Application Equipment 

 1) General, unless listed below 25 (0.21) 

 2) Flexographic Printing 

 a)Specialty Flexographic 100 (0.83) 

 b)Other Flexographic 25 (0.21) 

 3) Gravure Printing 

 a)Publication 100 (0.83) 

 b)Packaging 25 (0.21) 

 4) Lithographic or Letter Press Printing 

 a)Roller Wash 100 (0.83) 

 b)Blanket Wash 100 (0.83) 

 c)Metering Roller Cleaner 100 (0.83) 

 d)Plate Cleaner 100 (0.83) 

 e)Removable Press Components 25 (0.21) 

 5) Radiation Curing Ink Removal 100 (0.83) 
 Rule 74.19 Staff Report Page 6

Many graphic arts operators use ROC-containing 

cleaning products to clean external parts of the 

printing press manually and to clean internal areas of 

the press manually and mechanically. Press operators 

apply small amounts of cleaning solvent to a cloth 

and hand wipe blankets, rollers, cylinders, drums, ink 

tools, ink trays, ink cans, ink rails, pipe rollers, and 

spray bars. Used cloths, if contaminated by toxic 

solvents, are disposed as hazardous waste. 

Automated systems using specially formulated 

cleaners are used to clean internal parts of the press 

such as automatic blanket washes on lithographic 

presses. One of the advantages of the automatic press 

cleaning feature is that operators may clean a press 

while simultaneously printing a job. 

 

Another source of ROC emissions relates to the 

cleaning of press parts that are not directly involved 

in the creation or application of images or that do not 

usually come into contact with inks, otherwise known 

as “other press parts.” Other press parts may be 

cleaned with solvents and include non-image areas of 

printing plates, catwalks, motors, belts, die cutters, 

side frames, gripper bars, delivery units, ink pumps, 

dryer boxes, drip pans, and ink trays. 

 

The proposed solvent cleaning categories are almost

identical to those in the existing rule. Based on the 

Bay Area rule, staff is proposing to define two new

categories: Other Press Parts and Removable Press 

Components. Other Press Parts are defined as any 

press parts that do not come into contact with inks, 

adhesives, or coatings. Examples include pressure 

rollers, motors, and belts. The new category, 

Removable Press Components, is similar but only 

applies to lithographic printing operations. It applies 

to any part, component, or accessory of a press that is 

physically attached to the press but does not come 

into contact with ink, and which is removed from the 

press prior to being cleaned. The following are not

considered to be removable press components or 

other press components: rollers, blankets, metering 

rollers, fountains, impression cylinders, and plates. 

The proposed ROC content limit for each new 

category is identical at 25 grams per liter. 

Several graphic arts suppliers including Amerikal 

Products, SoyGold, Prisco, Gans Ink & Supply, 

Pitman, and Day International Chemical Products are

currently manufacturing pressroom cleaners in 

compliance with the proposed standards for rollers,

blankets, and impression cylinders. Mention of 

company names or products are to demonstrate 

availability, and no endorsement by the District 

should be implied. 

Operators should choose carefully when selecting a 

solvent to clean rubber blankets and rollers. The 

strongest solvents such as acetone and MEK will 

remove the plasticizer from the rubber and harden the 

rollers. The roller will then become unusable for 

printing and their lifetime will be shortened. Blanket 

and roller washes must offer the printer strong 

cleaning. Fortunately vegetable-based cleaners are

now available that provide strong cleaning without 

the use of petroleum-based products. For example, 

LA Graphico, a printer located in Burbank in the 

South Coast AQMD, has been successfully using a 

Amerikal Products vegetable-based cleaner (Brigl 

Wash) since 2004. This cleaner does not contain any 

acetone, water, petroleum products, or hazardous air 

pollutants, and has an ROC content under 50 grams 

per liter. 

Other contributing factors to roller degradation 

include solvent-containing inks, alcohol from 

fountain solutions, high temperatures, and strong 

acids or alkalis. Proper maintenance and careful 

monitoring of process parameters will help preserve

the life of rubber rollers and blankets. 

Section B.6: Add-On Emissions Controls 

Staff is proposing to raise the combined capture and 

control efficiency for optional add-on emission 

control equipment from 75 to 80 percent for graphic

arts operations other than publication rotogravure. 

This is based on a recommendation from the federal 

Control Technique Guidelines for Flexographic 

Printing. Moreover, the control efficiency of catalytic 

oxidizers is typically greater than 95 percent if inlet 

temperatures are maintained above 475 degrees F. 

No printers operating in the county are using add-on 

control equipment to comply with the requirements of 

Rule 74.19. Based on the availability of low-ROC 

cleaners that comply with the proposed amendments, 

staff anticipates that none of the printers in the county 

will need to install add-on controls. 
 Rule 74.19 Staff Report Page 7

COMPARISON OF PROPOSED RULE REQUIREMENTS 

 WITH OTHER AIR POLLUTION CONTROL REQUIREMENTS 

Health and Safety Code Section 40727.2 requires 

Districts to compare the requirements of a proposed

revised rule with other air pollution control 

requirements. These other air pollution control 

requirements include federal New Source 

Performance Standards (NSPS), federal National 

Emissions Standards for Hazardous Air Pollutants 

(NESHAPS), Best Available Control Technology 

(BACT) and any other District rule that applies to the 

same equipment. 

Comparison with Federal NSPS and NESHAPS 

The only federal NSPS that may impact graphic arts 

operations is found in Title 40, Part 60, Subpart QQ, 

Graphic Arts Industry: Publication Rotogravure 

Printing. The federal NESHAPS that will impact 

graphic arts operations may be found in Title 40, Part 

63, Subpart KK, NESHAP for the Printing and 

Publishing Industry. The elements of the NSPS and 

NESHAPS were compared to proposed amendments 

to VCAPCD Rule 74.19. None of the proposed 

amendments to Rule 74.19 affect the: 

• Units used for emission standards 

• Monitoring Frequency 

• Test Methods 

• Recordkeeping Requirements 

No emission averaging provisions or reporting 

requirements are contained in Rule 74.19. In 

summary, there are no conflicting requirements with

the federal NSPS or NESHAPS. 

It is worth noting that VCAPCD Rule 76, Federally 

Enforceable Limits on Potential to Emit, contains 

requirements for recordkeeping and reporting of 

Hazardous Air Pollutants that may impact some 

existing graphic arts operations. For example, 

sources that are larger than De Minimis levels and 

smaller than major source levels must keep records of 

hazardous air pollutant emissions. 

Comparison with BACT Requirements 

Health and Safety Code Section 40727.2 (a) requires

that the proposed amendments to Rule 74.19 be 

compared with Best Available Control Technology. 

The CAPCOA Engineering Manager Rule 

Development Subcommittee developed guidance on 

this matter. Under this guidance, it was 

recommended that BACT be interpreted as a 

District’s BACT determination. 

BACT for the graphic arts industry was determined 

by surveying the BACT determinations from the 

South Coast AQMD and the Air Resources Board 

BACT Clearinghouse. The SCAQMD BACT 

guideline is published on their website for permitting 

purposes in Appendix B. The BACT Clearinghouse 

is published on the Air Resources Board website and

is a compilation of permit applications submitted by 

air districts in California that show BACT 

requirements imposed on new sources. BACT 

determinations were found for the following types of 

printing: 

• Lithographic Offset Printing – Non-Heatset 

• Lithographic Offset Printing – Heatset 

• Flexographic Printing Line 

• Rotogravure Printing – Publication and 

Packaging 

The proposed Rule 74.19 ROC emissions controls for 

printing processes are comparable to BACT 

requirements. The lowest ROC content limits for 

inks for all printing processes and for fountain 

solution for lithographic offset printing processes are 

equivalent or more stringent. 

The results indicate that BACT limits (5% to 8% by 

wt.) for inks are equal or more stringent than the ink 

ROC content limit of 300 grams per liter in existing 

Rule 74.19. A similar result is found when 

comparing the fountain solution ROC content limits. 

The ROC limit of fountain solutions proposed for 

Rule 74.19 are based on CTG limits and the existing

requirements in Sacramento Metro AQMD Rule 450. 

The proposed amendments to Rule 74.19 cleaning 

requirements are based on existing in South Coast 

AQMD, Bay Area AQMD, San Joaquin Valley 

APCD, and Sacramento AQMD, and are considered 

to be BACT. 
 Rule 74.19 Staff Report Page 8

IMPACT OF THE PROPOSED RULE 

Table 4. Baseline ROC Emissions Factors for 

Graphic Arts Operations Sources 

ROC Emission Source Baseline Emission 

Factor (lb/gal) 

Inks 0.25 

Fountain Solution 0.9 

Cleaners 6.6 

Coatings/Adhesives 1.25 

ROC Emissions Impacts 

As shown earlier in Table 1, the permitted emissions 

(ROC) from graphic arts operations are about 125 

tons per year. The relative ROC emissions were 

estimated using data from permitted sources in the 

county that are currently subject to Rule 74.19. The 

average factors in Table 4 above were used to 

compute the relative contribution of each graphic arts 

emission source. 

Figure 1. Percentage of ROC Emissions 

by Graphic Arts Category 

The results of this analysis in Figure 1 clearly shows 

that the largest source of ROC emissions in graphic

arts operations are from the use of cleaning solvents. 

The next largest ROC emission source at 18 percent 

is from inks is based on an emission factor of 0.25

pounds per gallon. This factor was derived from the 

current standard of 2.5 pounds per gallon times a 

correction factor of 10 percent. This correction factor 

is based on the assumption that nonheatset ink 

solvents are retained in substrate. This solvent 

retention occurs because these inks dry by oxidation 

or absorption and not by evaporation of the ink oils. 

The derivation of the projected potential ROC 

emission reductions of 51 tons per year from the 

proposed amendments to Rule 74.19 are shown in 

Table 5. The more wide spread use of lower ROC 

cleaning solvents will contribute to over 95 percent of 

the total reductions. The much smaller projected 

emission reductions resulting from the new standards 

for fountain solutions are based on the fact that most 

if not all printers are already in compliance with these 

new proposed standards. 

Staff also analyzed actual emission reductions that

would have occurred based on recent production 

levels. These results indicate much lower emission

reductions at about 20 tons per year, which reflect the 

slowdown in recent economic activity. Presumably,

the potential emission reductions will increase once 

more normal production rates are reached. 

The projected emission reductions from this proposed 

rule change at 51 tons per year is a more conservative 

projection than the one determined for the recently

adopted amendments to Bay Area AQMD Regulation 

8, Rule 20. Bay Area AQMD staff projected an 

emission reduction of 1.65 tons per day, which is 

equivalent to about 66 tons per year in Ventura 

County based on population differences. 

The ROC emission reductions from this source 

category are significant, and all emission reductions 

are needed to reach the federal and state ambient 

ozone air quality standards. The availability, 

feasibility, and cost-effectiveness of the proposed

replacement fountain solutions and cleaning solvents 

make this proposal worthwhile. 

Table 5. Projected ROC Emission Reductions 

Source 

Category 

Baseline 

ROC 

Emissions 

Estimated 

Control 

Efficiency 

Projected 

ROC 

Emission 

Reductions 

Cleaners 60 tons/yr 80 % 48 tons/y 

Fountain 

Solution 

13 tons/yr 23 % 3 tons/yr 

TOTAL 51 tons/yr 

Cost-Effectiveness 

The estimated cost analysis for replacing existing 

cleaning products with low-ROC versions was based 

on work performed by the Bay Area AQMD (October 

2008 Staff Report). The estimated price changes for 

the new products ranged from an increase of 7 

percent to a decrease of 25 percent. The costeffectiveness for these cleaner replacements ranged

Cleaners

62%

Fountain 

Solution

13%

Coatings 

Adhesive

6%

Inks

18%
 Rule 74.19 Staff Report Page 9

from a $0.17 per pound of ROC reduced to a cost 

savings. In addition, staff contacted LA Graphico,

the Burbank printer currently using the low-ROC 

vegetable-based cleaners. According to the plant 

manager, the cost of the new cleaners is equivalent to 

the high-ROC cleaners previously used. 

Based on cost data from the EPA control technique 

guideline for offset Lithographic printing (September 

1993), the proposed ROC standard for fountain 

solutions will save businesses from $779 to $1,494 

per year for small sheetfed printers where alcohol use 

is reduced. Larger facilities that reduce alcohol use 

will save more. This cost savings is based on reduced 

alcohol raw material costs. 

Similar cost savings will result if alcohol is 

completely eliminated. If alcohol substitutes are 

used, the cost saving is the difference between the

savings from reduced alcohol usage and the cost of 

the alcohol replacement. EPA estimates the cost 

savings with the use of alcohol substitutes from $732 

to $1,403 per year for the same types of sheetfed 

printing operations. Although the cost of the alcohol 

substitute at $1.55 per pound is much higher than 

isopropyl alcohol at $0.46 per pound, approximately

90 percent less alcohol substitute is needed in the

fountain solution. 

When operators are trained in the use of substitute

cleaners, they often use much less than was needed 

with a regular blanket wash. In Europe, a program 

called SUBSPRINT was developed to eliminate the 

use of organic solvents in the printing industry. Two 

of the companies in this program showed that with 

training, blanket wash consumption can be cut by as

much as 80 percent compared to the regular blanket 

wash. This type of performance will actually result in 

a cost saving when using low-emission cleaners. 

Incremental Cost-Effectiveness Analysis 

Health and Safety Code Section 40920.6(a) requires 

districts to identify one or more potential control

options, assess the cost-effectiveness of those options, 

and calculate the incremental cost-effectiveness. 

Health and Safety Code Section 40920.6 also requires 

an assessment of the incremental cost-effectiveness

for proposed regulations relative to ozone, carbon 

monoxide (CO), sulfur oxides (SOx), nitrogen oxides

(NOx), and their precursors. 

Incremental cost-effectiveness is defined as the 

difference in control costs divided by the difference 

in emission reductions between two potential control 

options achieving the same emission reduction goal 

of a regulation. The proposed amendments to Rule 

74.19 will require the most stringent viable ROC 

limits and no other viable control option can achieve 

the same amount of emission reductions. Therefore,

the incremental cost-effectiveness analysis does not 

apply to this rulemaking. 

Socioeconomic Analysis 

Assembly Bill 2061 (Polanco), which became 

effective January 1, 1992, requires that the District 

Board consider the socioeconomic impacts of any 

new rule. The Board must evaluate the following 

socioeconomic information on proposed amendments 

to Rule 74.19. 

(1) The type of industries or businesses, including

small business, affected by the rule or 

regulation. 

 The adoption of amendments to Rule 74.19 will 

directly affect thirty-two permitted graphic art 

operations in the county (see Table 1). The 

inkjet printers listed in Table 1 will not be 

impacted because the proposed rule 

amendments do not change the current exempt 

status for this type of printing. 

(2) The impact of the rule amendments on 

employment and the economy of the region. 

 Revisions to Rule 74.19 are not expected to 

have a negative impact on either employment or 

the economy of Ventura County. According to 

the cost analysis of the proposed revisions to 

Rule 74.19, some segments of the graphic arts 

industry may benefit from reduced material 

costs, which should help economic growth. 

(3) The range of probable costs, including costs to

industry or business, including small business, 

of the rule or regulation. 

 Probable savings will range from $732 to 

$1,403 per each facility that reduces the use of 

alcohol in their fountain solutions. Costs of 

switching to low-emission cleaners will range 

from a cost savings to a cost of $0.17 per pound 

of ROC reduced. 

(4) The availability and cost-effectiveness of 

alternatives to the rule or regulation being 

proposed or amended. 

 Since the proposed rule amendments are the 

most cost-effective control option, no other 

alternatives were analyzed. 
 Rule 74.19 Staff Report Page 10

 (5) The emission reduction potential of the rule or 

regulation. 

 The anticipated emission reduction potential of 

the proposed rule is about 51 tons per year of 

ROC emissions. These emission reductions 

result from the use of low-ROC cleaners and 

low-ROC fountain solutions. 

(6) The necessity of adopting, amending, or 

repealing the rule or regulation in order to attain

state and federal ambient air standards pursuant 

to Chapter 10 (commencing with Section 

40910). 

 Ventura County is classified as a serious 

nonattainment area for the federal Ambient Air 

Quality Standards for ozone. These proposed 

rule amendments will reduce ROC emissions 

that are precursors to the formation of ozone. 

According to the 2007 AQMP, these emission 

reductions will help the District in its effort to 

attain the standards. California Health and 

Safety Code Section 40914(b)(2) requires that 

the District adopt every feasible measure to 

reduce ozone precursors. 

ENVIRONMENTAL IMPACTS OF METHODS OF COMPLIANCE 

California Public Resources Code Section 21159 requires the District to perform an environmental analysis of the 

reasonably foreseeable methods of compliance. The analysis must include the following information on proposed 

revisions to Rule 74.19: 

(1) An analysis of the reasonably foreseeable environmental impacts of the methods of compliance. 

(2) An analysis of the reasonably foreseeable mitigation measures. 

(3) An analysis of the reasonably foreseeable alternative means of compliance with the rule or regulation. 

Table 6 lists all reasonably foreseeable compliance methods, the environmental impacts of those methods, and 

measures that could be used to mitigate the environmental impacts. 

Table 6 

Environmental Impacts and Mitigations of Methods of Compliance 

Compliance Methods (including all 

reasonably foreseeable alternative 

means of compliance) 

Reasonably Foreseeable 

Environmental Impacts 

Reasonably Foreseeable 

Mitigation Measures 

Reformulation of fountain solutions 

and cleaning solvents 

Air Quality Impacts: Reformulation 

may result in the use of toxic 

materials. 

Operators may use reformulated 

products with less or no toxic 

materials. 

 Water Impacts: Improper disposal of 

fountain solution and cleaning 

solvents may cause water impacts 

Compliance with wastewater 

discharge standards and waste 

disposal requirements will 

mitigate these impacts. 

 Human Health Impacts: Fountain 

solutions and cleaning solvents may 

be replaced with products containing 

more toxic compounds. 

Compliance with OSHA safety 

guidelines (e.g., personal 

protective equipment, prevention 

and response, emergency first aid 

procedures) reduces these 

impacts. 

Installation of Catalytic Oxidation 

Add-On Controls 

Solid Waste Disposal Impacts: May 

cause increase quantities of solid 

waste (catalyst material). 

Catalyst materials are valuable 

and are typically reclaimed and 

recycled. 

 Noise Impacts: Fans and associated 

equipment with add-on controls may 

increase noise levels. 

Sound wall or enclosures may be 

constructed around the control 

equipment. 
 Rule 74.19 Staff Report Page 11

This analysis demonstrates that the adoption of revisions to Rule 74.19 will not have a significant effect on the 

environment due to unusual circumstances. 

REFERENCES 

1. Allied Pressroom Products: Eco Range Blanket 

& Roller Wash. Los Angeles, CA 2010. 

2. Alternative Control Techniques Document: 

Offset Lithographic Printing, EPA OAQPS, 

Document No. 453/R-94-054, Research 

Triangle Park, NC, June 1994. 

3. Amerikai Product Corporation: Genesis Brigl 

Wash, Blanket and Roller Wash for 

Conventional, UV, Co-cure and EB Inks, 

www.amerikal.com, Waukegan, IL, Aug 2006. 

4. Anchor 7747 Digital Plate Cleaner, 

www.fujigraphics.com. 2010. 

5. “Assessment, Development, and Demonstration 

of Low-VOC Materials for Cleaning of 

Lithographic Printing Ink Application 

Equipment,” Institute for Research and 

Technical Assistance. May 2006. 

6. “Assessment, Development, and Demonstration 

of Low-VOC Materials for Cleaning of 

Lithographic Printing Ink Application 

Equipment,” Printing Industries of 

America/Graphic Arts Technical Foundation, 

March 2006. 

7. ATP Graphic Arts Information Network. Hyper 

Corp. Website, www.hyper.com. 

8. Bay Area AQMD Staff Report: Proposed 

Amendments to Regulation 8, Rule 20, Graphic 

Arts Printing & Coating Operations. Oct 2008. 

9. “Compatibility Testing of Low-VOC 

Alternative Cleaning Solvents for Lithographic 

Printing Application,” Univ. of Tennessee 

Center for Clean Products & Clean 

Technologies, April 2006. 

10. Control Techniques Guidelines for Offset 

Lithographic Printing and Letterpress Printing, 

EPA-453/R-06-002, Sept 2006. 

11. Determination of Reasonably Available Control 

Technology and Best Available Retrofit 

Technology for Graphic Arts Operations, Air 

Resources Board, May 28, 1992. 

12. Falmouth Products, Catalytic Oxidizer, 

Falmouth, MA, 2000. 

www.falmouthproducts.com

13. GANS Rule 1171 Compliant Wash for UV Inks, 

GANS Inks Supply Co., Los Angeles, CA Dec 

2009. 

14. Letter to Katy Wolf (IRTA) from Frank Barnet 

(Anderson Lithograph) dated Jan 13, 2004: 

“SCAQMD Alternative Solvent Technology 

Assessment Soya Base Roller & Blanket Wash 

Solvent Formulation Extended Filed Test: 

Sheet-fed Press, UV Ink.” 

15 Personal Communication with Robert Tubbs, 

Manager, LAgraphico, Burbank, CA June 10, 

2010. 

16. “Pollution Prevention Manual for Lithographic 

Printers,” Case Study H: Selecting Alcohol 

Substitutes, Iowa Waste Reduction Center, 

University of North Iowa, 1995. 

17. Prisco Press Washes and Solvents, Printers 

Service, Newark, NJ, March 2009. 

18. Sacramento Metropolitan AQMD Rule 450, 

Graphic Arts Operations, amended Oct 23, 

2008. 

19. Schneider Jr., Robert J., “Printing with Alcohol 

Substitutes,” Graphic Arts Technical 

Foundation, Pittsburgh, PA, 1993. 

20. Soy Gold 2000, water-rinsable industrial 

solvent. www.soygold.com 2010. 

 

21. Stealth Industries, Firecat Thermal/Catalytic 

Oxidizers, Anaheim, CA 2000. 

www.stealthindustries.com/firecat.htm

22. “Substitute Blanket Washes: Making Them 

Work,” Design for The Environment: 

Lithography Project Bulletin 1, EPA, Document 

No. 744-F-96-002, August 1996. 

23. “The Effect of Solvents on Blankets and 

Rollers,” Prisco, 1999. 
 Rule 74.19 Staff Report Page 12

24. “Thinking Green,” LAgraphico, 

www.lagraphico.com June 2010. 

25. Tower MRC 100 g/l Metering Roller Cleaner, 

Tower Products, Easton, PA, Dec 2007. 

26. Varn Microkleen, Ultra Low-VOC Press Wash, 

Day International Chemical Products Division, 

Dayton, OH, Nov 2007. 

27. Ventura County Air Quality Management Plan, 

2007 AQMP, adopted May 13, 2008. 

28. Ventura County Air Pollution Control District 

Staff Report for Rule 74.19, Graphic Arts, April 

10, 2001. 

29. “Vegetable Ester Blanket Washes,” Design for 

the Environment: Lithography Project Bulletin 

3, EPA Document No. 744-F-96-014, 1996. 

DISCLAIMER 

This report contains references to company and product names to illustrate product availability. Mention of these 

names is not to be considered an endorsement by the Ventura County Air Pollution Control District.