Mojave Desert 

Air Quality Management District 

Final 

Staff Report 

Amendments to 

Rule 1117 – Graphic Arts and Paper, 

Film, Foil and Fabric Coatings 

Adopted on 

September 28, 2009 

14306 PARK AVE, VICTORVILLE, CA 92392-2310 

PHONE: (760) 245-1661 

FAX: (760) 245-2699 
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MDAQMD Rule 1117 – Graphic Arts TC-1 

Final Staff Report, 01/21/10

FINAL STAFF REPORT 

TABLE OF CONTENTS

Rule 1117 – Graphic Arts and Paper, Film, Foil and Fabric Coatings

I. PURPOSE OF STAFF REPORT ............................................................................................ 1 

II. EXECUTIVE SUMMARY..................................................................................................... 1 

III. STAFF RECOMMENDATION ............................................................................................. 2 

IV. LEGAL REQUIREMENTS CHECKLIST ............................................................................ 3 

V. DISCUSSION OF LEGAL REQUIREMENTS..................................................................... 4 

A. REQUIRED ELEMENTS/FINDINGS............................................................................... 4 

1. State Findings Required for Adoption of Rules & Regulations ..................................... 4 

a. Necessity..................................................................................................................... 4 

b. Authority..................................................................................................................... 4 

c. Clarity ......................................................................................................................... 4 

d. Consistency................................................................................................................. 4 

e. Non-duplication .......................................................................................................... 5 

f. Reference .................................................................................................................... 5 

g. Public Notice & Comment, Public Hearing................................................................ 5 

2. Federal Elements (SIP Submittals, Other Federal Submittals)....................................... 6

a. Satisfaction of Underlying Federal Requirements...................................................... 6 

b. Public Notice and Comment ....................................................................................... 6 

c. Availability of Document ........................................................................................... 6 

d. Notice to Specified Entities ........................................................................................ 7 

e. Public Hearing ............................................................................................................ 7 

f. Legal Authority to Adopt and Implement................................................................... 7 

g. Applicable State Laws and Regulations Were Followed............................................ 7 

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS ............................................ 7 

C. ECONOMIC ANALYSIS .................................................................................................. 9 

1. General............................................................................................................................ 9 

2. Cost Effectiveness........................................................................................................... 9 

D. ENVIRONMENTAL ANALYSIS (CEQA)....................................................................... 9 

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS ................................................... 10 

1. Potential Environmental Impacts.................................................................................. 10 

2. Mitigation of Impacts.................................................................................................... 10 

3. Alternative Methods of Compliance............................................................................. 10 

F. PUBLIC REVIEW............................................................................................................ 10 

VI. TECHNICAL DISCUSSION .............................................................................................. 10 

A. SOURCE DESCRIPTION................................................................................................ 10 

B. EMISSIONS ..................................................................................................................... 12 

C. CONTROL REQUIREMENTS........................................................................................ 12 

D. PROPOSED RULE SUMMARY..................................................................................... 13 

E. SIP HISTORY .................................................................................................................. 14 

1. SIP History................................................................................................................... 14 

a. SIP in the San Bernardino County Portion of MDAQMD ....................................... 14 

b. SIP in the Riverside County Portion of the MDAQMD........................................... 14 
TC-2 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10

2. SIP Analysis.................................................................................................................. 15 

Appendix A - Iterated Version.................................................................................................... A-1 

Appendix B - Public Notice Documents..................................................................................... B-1 

Appendix C - Public Comments and Responses......................................................................... C-1 

Appendix D - California Environmental Quality Act Documentation ....................................... D-1 

Appendix E - Bibliography..........................................................................................................E-1 
MDAQMD Rule 1117 – Graphic Arts 1 

Final Staff Report, 01/21/10 

FINAL STAFF REPORT 

Rule 1117 – Graphic Arts and Paper, Film, Foil and Fabric Coatings 

I. PURPOSE OF STAFF REPORT 

A staff report serves several discrete purposes. Its primary purpose is to provide a summary and 

background material to the members of the Governing Board. This allows the members of the 

Governing Board to be fully informed before making any required decision. It also provides the 

documentation necessary for the Governing Board to make any findings, which are required by 

law to be made prior to the approval or adoption of a document. In addition, a staff report 

ensures that the correct procedures and proper documentation for approval or adoption of a 

document have been performed. Finally, the staff report provides evidence for defense against 

legal challenges regarding the propriety of the approval or adoption of the document. 

II. EXECUTIVE SUMMARY 

The Mojave Desert Air Quality Management District (MDAQMD) has the authority pursuant to 

California Health and Safety Code (H&S Code) §40702 to adopt, amend or repeal rules and 

regulations. The MDAQMD is proposing to amend Rule 1117 – Graphic Arts and Paper, Film, 

Foil and Fabric Coatings for inclusion in the current rulebook. 

H&S Code §39614(d) requires the MDAQMD to adopt the most readily available, feasible and 

cost-effective local control measures for Particulate Matter (PM) as contained on a list developed 

by the California Air Resources Board (CARB). CARB has identified on its list of local control 

measures several items related to graphic arts as potentially feasible. In the “List and 

Implementation Schedule for District Measures to Reduce PM Pursuant to Health & Safety Code 

§39614(d)” the District identified one of these measures as requiring further evaluation. The 

District has evaluated the availability, feasibility and cost-effectiveness of applying this PM 

control measure related to graphic arts within the MDAQMD. The proposed Reasonably 

Available Control Measures (RACT) limits were found to have a maximum Volatile Organic 

Compounds (VOC) cost effectiveness limit of no more than $576 per ton of VOC (2008 dollars). 

The District finds this to be feasible and cost effective as required by H&S Code §3961(d). 

Additionally, the Federal Clean Air Act (FCAA) requires areas designated non-attainment and 

classified moderate and above to implement RACT for sources subject to Control Technology 

Guidelines (CTG) documents issued by United States Environmental Protection Agency 

(USEPA) for “major sources” of VOCs and oxides of nitrogen (NOX) which are ozone 

precursors. The District adopted the 8-Hour Reasonably Available Control Technology – State 

Implementation Plan Analysis (RACT SIP Analysis) August, 2006 which committed to amending 

current RACT for graphic arts operations. The MDAQMD has a graphic arts RACT rule which 

was approved into the SIP in 1996 (61 FR 18962), but this rule does not cover all possible paper 

surface coating CTG source categories, such as offset lithographic printing. A RACT rule is 

technically required for all portions of this CTG source category. The District also reviewed 

three CTGs that were in draft form at the time of adoption of the RACT SIP Analysis. The 
2 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10

MDAQMD is now proposing to update Rule 1117 - Graphic Arts to reflect current paper, film, 

foil, and fabric surface coating RACT. 

The proposed amendments to Rule 1117 address both the PM Analysis and RACT SIP Analysis

commitments. The proposed amendments expand the applicability of the rule; updates 

definitions; updates VOC content limits for different graphic arts product categories; updates 

VOC emission control system limits; updates solvent cleaning operation limits; and, updates 

exemptions, recordkeeping and test methods. 

III. STAFF RECOMMENDATION 

Staff and the Technical Advisory Committee recommend that the Governing Board of the 

Mojave Desert Air Quality Management District (District) adopt the proposed amendments to 

Rule 1117 – Graphic Arts and Paper, Film, Foil and Fabric Coatings and approve the 

appropriate CEQA documentation. This action is necessary to address the commitments made 

by the District in the List and Implementation Schedule for District Measures to Reduce PM 

Pursuant to Health & Safety Code §39614(d) and the RACT SIP Analysis. 

The Governing Board of the Mojave Desert Air Quality Management District amended Rule 

1117 – Graphic Arts and Paper, Film, Foil and Fabric Coatings on September 28, 2009.
MDAQMD Rule 1117 – Graphic Arts 3 

Final Staff Report, 01/21/10 

IV. LEGAL REQUIREMENTS CHECKLIST 

The findings and analysis as indicated below are required for the procedurally correct 

amendments to Rule 1117 – Graphic Arts and Paper, Film, Foil and Fabric Coatings. Each 

item is discussed, if applicable, in Section V. Copies of related documents are included in the 

appropriate appendices. 

FINDINGS REQUIRED FOR 

RULES & REGULATIONS:

 X Necessity 

 X Authority 

 X Clarity 

 X Consistency 

 X Non-duplication 

 X Reference 

 X Public Notice & Comment 

 X Public Hearing 

REQUIREMENTS FOR STATE 

IMPLEMENTATION PLAN 

SUBMISSION (SIP): 

 X Public Notice & Comment 

 X Availability of Document 

 X Notice to Specified Entities (State, Air 

Districts, USEPA, Other States) 

 X Public Hearing 

 X Legal Authority to adopt and implement the 

document. 

 X Applicable State laws and regulations were 

followed. 

ELEMENTS OF A FEDERAL 

SUBMISSION:

 X Elements as set forth in applicable Federal 

law or regulations. 

CALIFORNIA ENVIRONMENTAL QUALITY 

ACT REQUIREMENTS (CEQA):

N/A Ministerial Action 

 X Exemption 

N/A Negative Declaration 

N/A Environmental Impact Report 

 X Appropriate findings, if necessary. 

 X Public Notice & Comment 

SUPPLEMENTAL ENVIRONMENTAL 

ANALYSIS (RULES & REGULATIONS ONLY):

 X Environmental impacts of compliance. 

N/A Mitigation of impacts. 

N/A Alternative methods of compliance. 

OTHER: 

 X Written analysis of existing air pollution 

control requirements 

 X Economic Analysis 

 X Public Review 
4 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10 

V. DISCUSSION OF LEGAL REQUIREMENTS 

A. REQUIRED ELEMENTS/FINDINGS 

This section discusses the State of California statutory requirements that apply to the 

amendments to Rule 1117. These are actions that need to be performed and/or 

information that must be provided in order to amend the rule in a procedurally correct 

manner. 

1. State Findings Required for Adoption of Rules & Regulations: 

Before adopting, amending, or repealing a rule or regulation, the District 

Governing Board is required to make findings of necessity, authority, clarity, 

consistency, non-duplication, and reference based upon relevant information 

presented at the hearing. The information below is provided to assist the 

Governing Board in making these findings. 

a. Necessity: 

The amendments to Rule 1117 are necessary to address the 

commitments made by the District in the List and Implementation 

Schedule for District Measures to Reduce PM Pursuant to Health 

& Safety Code §39614(d) and the RACT SIP Analysis. 

b. Authority: 

The District has the authority pursuant to California Health and 

Safety Code (H&S Code) §40702 to adopt, amend or repeal rules 

and regulations. 

c. Clarity: 

The amendments to Rule 1117 are clear in that they are written so 

that the persons subject to the rule can easily understand the 

meaning. 

d. Consistency: 

The amendments to Rule 1117 are in harmony with, and not in 

conflict with or contradictory to any State law or regulation, 

Federal law or regulation, or court decisions. USEPA has issued 

five CTGs which have an impact on Rule 1117: CTG for Flexible 

Package Printing (EPA 453/R-06-003, 2006/09); CTG for Offset 

Lithographic Printing and Letterpress Printing (EPA 453/R-06-02, 

2006/09); CTG for Paper, Film, and Foil Coatings (EPA 453/R-07-

003, 2007/09); CTG for Control of VOCs from Existing Stationary 

Sources – Volume II; Surface Coating of Cans, Coils, Paper, 

Fabrics, Automobiles and Light-Duty Trucks (EPA 450/2-77-008, 
MDAQMD Rule 1117 – Graphic Arts 5 

Final Staff Report, 01/21/10 

1977/05); and, CTG for Control of VOCs from Existing Stationary 

Sources – Volume III: Graphic Arts-Rotogravure and Flexography 

(EPA 450/2-78-033, 1978/12). The CTGs establish requirements 

and emission limits for VOCs but do not directly implement them. 

Most of these emission limits have been previously included in 

Rule 1117 and the few which were not originally included are 

being added by the amendments, therefore the amendments are not 

in conflict or inconsistent with the CTGs. 

There are two Federal New Source Performance Standards (NSPS) 

that apply to Rule 1117: 40 CFR 60 Subpart QQ (Standards of 

Performance for the Graphic Arts Industry: Publication 

Rotogravure Printing; and 40 CFR 60 Subpart RR (Standards of 

Performance for Pressure Sensitive Tape and Label Surface 

Coating Operations. The amendments are not in conflict with 

either NSPS. 

There are three Maximum Achievable Performance Standards 

(MACTs) that apply to graphic arts; Subpart KK (National 

Emission Standards for the Printing and Publishing Industry); 

Subpart OOOO (Fabric Printing, Coating and Dyeing); and, 

Subpart JJJJ (National Emissions Standards for Hazardous Air 

Pollutants: Paper and other Web Coating). The amendments are 

not in conflict with the MACT standards. 

e. Non-duplication: 

The amendments to Rule 1117 do not impose the same 

requirements as any existing state or federal law or regulation 

because the District is adopting this rule in response to H&S Code 

§39614(d) and federal VOC RACT requirements. 

f. Reference: 

The District has the authority pursuant to H&S Code §40702 to 

adopt, amend or repeal rules and regulations. The District is required 

to adopt readily available, feasible and cost-effective control 

measures for particulate matter from a list of potential local control 

measures promulgated by CARB pursuant to H&S Code 

§39614(d). 

g. Public Notice & Comment, Public Hearing: 

Notice for the public hearing for the proposed amendments to Rule 

1117 was published 08/26/2009. See Appendix “B” for a copy of 

the public notice. See Appendix “C” for copies of comments, if any, 

and District responses. 
6 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10 

2. Federal Elements (SIP Submittals, Other Federal Submittals). 

Submittals to USEPA are required to include various elements depending upon 

the type of document submitted and the underlying federal law that requires the 

submittal. The information below indicates which elements are required for the 

amendments to Rule 1117 and how they were satisfied. 

a. Satisfaction of Underlying Federal Requirements: 

The FCAA requires areas designated non-attainment and classified 

moderate and above to implement RACT for sources subject to 

CTG documents issued by EPA for “major sources” of VOCs and 

NOX that are ozone precursors. The District adopted the RACT 

SIP Analysis August, 2006 which committed to amending current 

RACT for graphic arts operations. The MDAQMD has a graphic 

arts RACT rule which was approved into the SIP in 1996 (61 FR 

18962), but this rule does not cover all possible paper surface 

coating CTG source categories, such as offset lithographic 

printing, letterpress printing, and screen printing. A RACT rule is 

technically required for all portions of this CTG source category. 

USEPA directed the District to evaluate San Joaquin Valley Air 

Pollution Control District (SJVAPCD) Rule 4607 – Graphic Arts 

and Paper, Film, Foil, and Fabric Operations (12/18/08), Bay 

Area Air Quality Management District (BAAQMD) Rule 8-20 – 

Graphic Arts Printing and Coating Operations (11/19/08), and 

Sacramento Metropolitan Air Quality Management District 

(SMAQMD) Rule 450 Graphic Arts Operations (10/23/08) as 

RACT rules. SJVAPCD Rule 4607 was used as a basis for the 

amendments to Rule 1117 – Graphic Arts and Paper, Film, Foil, 

and Fabric Operations.

b. Public Notice and Comment: 

Notice for the public hearing for the proposed amendments to Rule 

1117 was published 08/26/2009. See Appendix “B” for a copy of 

the public notice. See Appendix “C” for copies of comments, if 

any, and District responses. 

c. Availability of Document: 

Copies of the proposed amendments to Rule 1117 and the 

accompanying draft staff report were made available to the public 

on 08/18/09. The proposed amendments were reviewed by the 

Technical Advisory Committee (TAC), a committee consisting of 

a variety of regulated industry and local governmental entities, on 

09/14/09. 
MDAQMD Rule 1117 – Graphic Arts 7 

Final Staff Report, 01/21/10 

d. Notice to Specified Entities: 

Copies of the preliminary draft Rule 1117 were sent for initial 

industry review on 05/26/2009. Copies of the proposed 

amendments to Rule 1117 and the accompanying draft staff report 

were sent to all affected agencies. The proposed amendments were 

sent to CARB and USEPA on 08/20/09. 

e. Public Hearing: 

A public hearing to consider the proposed amendments to Rule 

1117 was held on 09/28/2009. 

f. Legal Authority to Adopt and Implement: 

The District has the authority pursuant to H&S Code §40702 to 

adopt, amend, or repeal rules and regulations, and to do such acts 

as may be necessary or proper to execute the duties imposed upon 

the District. 

g. Applicable State Laws and Regulations Were Followed: 

Public notice and hearing procedures pursuant to H&S Code 

§§40725-40728 have been followed. See Section (V)(A)(1) above 

for compliance with state findings required pursuant to H&S Code 

§40727. See Section (V)(B) below for compliance with the 

required analysis of existing requirements pursuant to H&S Code 

§40727.2. See Section (V)(C) for compliance with economic 

analysis requirements pursuant to H&S Code §40920.6. See 

Section (V)(D) below for compliance with provisions of the 

California Environmental Quality Act (CEQA). 

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS 

H&S Code §40727.2 requires air districts to prepare a written analysis of all existing 

federal air pollution control requirements that apply to the same equipment or source type 

as the rule modified by the district. 

The USEPA has issued several recent CTGs which have an impact on Rule 1117. These 

CTGs were issued after the adoption of the RACT SIP Analysis. The CTG for Flexible 

Package Printing (EPA 453/R-06-003, September 2006) provides recommendations for 

reducing VOC emissions from inks, coatings, adhesives and cleaning materials used in 

flexible packaging printing. The CTG for Offset Lithographic Printing and Letterpress 

Printing (EPA 453/R-06-02, September 2006) provides control recommendations for 

reducing VOC emissions stemming from the use of fountain solutions, cleaning materials 

and inks in offset lithographic printing and cleaning materials and inks in letterpress 

printing. The CTG for Paper, Film, and Foil Coatings (EPA 453/R-07-003, September 

2007) provides control recommendations for reducing VOC emissions stemming from 
8 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10 

the use of coatings in paper, film and foil surface coating operations. Coating performed 

on, or in-line with, any offset lithographic, screen, letterpress, flexographic, rotogravure, 

or digital printing press is part of a printing process and is not part of the paper, film, and 

foil coating category. 

Four CTGs were addressed in the RACT SIP Analysis. The Control of VOCs from 

Existing Stationary Sources – Volume I; Control Methods for Surface-Coating 

Operations (EPA 450/2-76-028, November 1976), although often listed with the CTGs 

for historical reasons, this document does not define RACT for any source. It is a 

compilation of control techniques (pursuant to USEPA comment). The Control of VOCs 

from Existing Stationary Sources – Volume II; Surface Coating of Cans, Coils, Paper, 

Fabrics, Automobiles and Light-Duty Trucks (EPA 450/2-77-008, May 1977) provides 

levels of VOC for all coatings put on paper, pressure sensitive tapes regardless of 

substrate (including paper, fabric or plastic film) and related web coating processes on 

plastic film such as typewriter ribbons, photographic film, and magnetic tape. The 

Control of VOCs from Existing Stationary Sources – Volume III: Graphic ArtsRotogravure and Flexography (EPA 450/2-78-033, 1978/12) deals with VOC emission 

from the graphic arts operations which utilize inks containing VOCs (does not apply to 

offset lithography or letterpress printing). The Control of VOC Emissions from Ink and 

Paint Manufacturing Processes (EPA-450/3-92-013, April 1992) deals with emission 

control techniques and cleaning practices throughout the manufacturing process of inks. 

The CTGs establish requirements and emission limits for VOCs but do not directly 

implement them. Therefore, rule adoption at the local level and submission as a SIP 

revision is necessary to implement these requirements. In addition, most of these 

emission limits have been previously included in Rule 1117 and the remainder are 

proposed for inclusion by the amendments, therefore the amendments are not in conflict 

or inconsistent with the CTGs. 

There are two Federal New Source Performance Standards (NSPS) that apply to Rule 

1117: 40 CFR 60 Subpart QQ (Standards of Performance for the Graphic Arts Industry: 

Publication Rotogravure Printing; and 40 CFR 60 Subpart RR (Standards of 

Performance for Pressure Sensitive Tape and Label Surface Coating Operations). The 

amendments are not in conflict with either NSPS. NSPS standards are generally adopted 

by reference within the MDAQMD (see Rule 900) and apply only to newer stationary 

sources as specified in the NSPS. The amendments apply RACT level control to all 

existing stationary sources which in most cases is the same level as that imposed by the 

NSPS standard. Please note that a new major stationary source in this source category 

would require Best Available Control Technology (BACT) pursuant to the provisions of 

New Source Review (Regulation XIII) and thus would be subject to potentially more 

stringent requirements than those contained in either of the NSPSs or amended Rule 

1117. 

There are three Maximum Achievable Performance Standards (MACTs) that apply to 

graphic arts; Subpart KK (National Emission Standards for the Printing and Publishing 

Industry); Subpart OOOO (Fabric Printing, Coating and Dyeing); and, Subpart JJJJ 

(National Emissions Standards for Hazardous Air Pollutants: Paper and other Web 

Coating). The amendments are not in conflict with the MACT standards. MACT 
MDAQMD Rule 1117 – Graphic Arts 9 

Final Staff Report, 01/21/10 

standards are imposed upon existing sources pursuant to the provisions of Rule 1520 – 

Control of Toxic Air Contaminants from Existing Sources. Thus, many of the existing 

sources are already subject to the same level of control for certain chemicals as that 

specified in amended 1117. Please note that any new or modified stationary source in 

this category would require a Toxic New Source Review analysis as part of its permitting 

process (see Rule 1320) and would thus acquire the same level of control as that provided 

for by amended 1117. 

C. ECONOMIC ANALYSIS 

1. General 

Rule 1117 is equivalent to San Joaquin Valley Unified Air Pollution Control 

District Rule 4607 – Graphic Arts and Paper, Film, Foil and Fabric Coatings that 

was determined by USEPA to be RACT (67 FR 4299), therefore cost 

effectiveness is not required. However, these amendments have been analyzed 

for VOC cost effectiveness in response to state requirements (see below). 

2. Cost Effectiveness 

Bay Area Air Quality Management District (BAAQMD) established a cost 

effectiveness of $576 per ton VOC reduced1. In their staff report, SJVUAPCD 

determined that their cost assumptions paralleled those of BAAQMD. The 

District finds that the BAAQMD analysis is applicable to this amendment action 

and presents this value as the cost effectiveness of the rule. This value is deemed 

feasible for VOC by the District.

D. ENVIRONMENTAL ANALYSIS (CEQA) 

Through the process described below the appropriate CEQA process for the amendments 

to Rule 1117 was determined. 

1. The amendments to Rule 1117 meet the CEQA definition of “project”. 

They are not “ministerial” actions. 

2. The amendment of Rule 1117 is exempt from CEQA review because it 

will not create any adverse impacts on the environment. The requirements in the 

amendments to Rule 1117 are more stringent than the currently existing 

requirements (see more detailed discussion in Rule Summary §(D)) in that: rule 

applicability is expanded to include current CTG source categories; definitions are 

updated to make the rule more comprehensive, reflect the current applicability of 

the rule, and provide additional clarity; VOC limits for various categories of 

coatings and solvent coating operations have been included; work practice 

requirements have been added; and, the monitoring and recordkeeping, and test 

method sections have been strengthened. In addition, ink and coatings satisfying 

 

1

 BAAQMD Staff Report “Proposed Amendments to BAAQMD Regulation 8, Rule 20: Graphic Arts Printing and 

Coating Operations (October 2008) pg 15. 
10 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10 

the limits contained in the rule are readily available in commerce and have been 

shown not to cause either additional usage of the coatings themselves or of 

cleaning solvents. Other air districts have adopted similar rules and neither they 

nor USEPA has identified increased usage of inks, coatings or solvents as an issue 

in supporting documentation. 

Therefore, no adverse environmental effects are foreseen from the amendments. 

Copies of the documents relating to CEQA can be found in Appendix “D”. 

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS 

1. Potential Environmental Impacts 

There are no potential adverse environmental impacts of compliance with the 

adoption of Rule 1117. Rule 1117 will expand the applicability of the rule to 

include all CTG categories for paper, film, foil and fabric; will impose additional 

controls on VOC emissions from inks, coatings, adhesives, fountain solutions, and 

solvent cleaning; and will increase the overall capture and control efficiency of 

emission control systems. Inks and coatings complying with the rule limits are 

readily available in commerce and should not cause additional usage of the 

coatings themselves or of cleaning solvents. No existing facility in this source 

category within the MDAQMD currently has an emission control system and the 

MDAQMD does not expect the installation of such directly as the result of the 

amendments to the rule primarily due to the high availability of compliant inks 

and coatings. In fact, the MDAQAMD suspects that a high percentage of the 

facilities in this source category are already using compliant inks and coatings due 

to the availability and the fact that most such inks and coatings are purchased 

within the South Coast Air Quality Management District.

2. Mitigation of Impacts 

N/A 

3. Alternative Methods of Compliance 

N/A 

F. PUBLIC REVIEW 

See Staff Report Section (V)(A)(1)(g) and (2)(b), as well as Appendix “B” 

VI. TECHNICAL DISCUSSION 

A. SOURCE DESCRIPTION 

Rule 1117 will be amended to include all CTG categories for paper, film, foil and fabric 

coating operations. The rule will be applicable to all graphic arts printing operations; 
MDAQMD Rule 1117 – Graphic Arts 11 

Final Staff Report, 01/21/10 

paper, film, foil and fabric printing operations; as well as, the use, storage and disposal of 

solvents associated with these operations. 

Graphic arts printing operations include lithographic printing, letterpress printing, digital 

printing, screen printing, and flexible packaging printing (rotogravure and flexographic). 

Lithography refers to a plane-o-graphic method of printing in which the image areas 

attract ink and the non-image areas repel ink. Most lithography is offset which means the 

image is transferred from the plate to a rubber blanket, and then printed (offset) from the 

blanket onto the paper. 

Letterpress Printing is a method where the image area is raised relative to the non-image 

area of the printing plate. The plate is inked and pressed onto the substrate allowing the 

ink to be transferred to the substrate directly from the image surface. 

Digital printing encompasses a variety of technologies all of which are based on the same 

distinguishing characteristics. Digital printing technologies do not require a physical 

master, stencils, screens or plates, but instead utilize digital data to control the deposition 

of ink, toner, or dye to create images. Digital printing is a print on demand technology, 

which includes, but is not limited to, various forms of inkjet, thermography, 

electrophotography, ionography, and magnetography. 

Screen Printing is a method in which a printing medium, such as ink, is forced through a 

web or fabric that has a stenciled image area that allows the ink to pass through the mesh 

to create the image. The stencil openings determine the form and dimension of the 

imprint. 

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 materials2

. 

Gravure Printing, also known as rotogravure, is an intaglio printing operation in which 

the ink is transferred from minute etched wells on a cylinder to the substrate, which is 

supported by an impression roller with excess ink removed from the cylinder by a doctor 

blade. 

Flexographic Printing is the application of an image to a substrate by means of a roll 

printing technique in which the pattern is applied to an image carrier made of rubber or 

other elastomeric materials. The image to be printed is raised above the carrier surface. 

Offset lithographic printing and letterpress printing are two distinct product categories 

under section 183(e) of the CAA, but have many similarities in the types of inks and 

cleaning materials used, and controls available to control emissions. The offset 

lithographic process is used in many printing applications, including books, magazines, 

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

 

2

 Control Techniques Guidelines for Flexible Packaging Printing, EPA 453/R-06-003, September 2006, pg.5. 
12 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10 

business forms, advertising brochures, newspapers and inserts, charts and maps, 

calendars, tickets and coupons, greeting cards, and stamps. The paper, film and foil 

coatings product category listed under section 183(e) of the CAA includes coatings that 

are applied to paper, film, or foil surfaces in the manufacturing of several major product 

types for the following industry sectors: pressure sensitive tape and labels (including 

fabric coated for use in pressure sensitive tapes and labels); photographic film; industrial 

and decorative laminates; abrasive products (including fabric coated for use in abrasive 

products); and flexible packaging (including coating of non-woven polymer substrates for 

use in flexible packaging). This category also includes coatings applied during 

miscellaneous coatings operations for several products including: corrugated and solid 

fiber boxes; die-cut paper paperboard, and cardboard; converted paper and paperboard 

not elsewhere classified; folding paperboard boxes, including sanitary boxes; manifold 

business forms and related products; plastic aseptic packaging; and carbon paper and 

inked ribbons3. 

MDAQMD Rule 1117 currently applies to any packaging rotogravure; publication 

rotogravure, or flexographic printing operation; and, to the manufactures of any ink, 

coating, or adhesive containing VOC which is sold, offered for sale, or supplied for use in 

graphic arts operations in the MDAQMD. The applicability of Rule 1117 is for 

amendment to include all CTG categories for paper, film, foil and fabric coating 

operations as well as the manufacture of any ink, coating, or adhesive containing VOC 

which is sold, offered for sale, or supplied for use in Graphic Arts and Paper, Film, Foil 

and Fabric Coating Operations in the District. 

Several facilities in the MDAQMD have operations potentially affected by the change in 

applicability of the rule. The Daily Press operates an offset lithographic printing press 

that was previously exempted from the requirements of Rule 1117. There are 

approximately 50 screen printing operations that are potentially subject to the amended 

rule which were also previously exempted. There is a potential future facility which may 

manufacture and print packaging materials for a future beverage bottling plant which may 

also be subject to the rule. 

B. EMISSIONS 

The amendments to Rule 1117 – Graphic Arts and Paper, Film, Foil and Fabric 

Coatings do not cause the release of additional air contaminants, or create any adverse 

environmental impacts because the amended rule proposes a more stringent applicability, 

as well as, more stringent VOC limits for all categories, including solvent cleaning 

operations, than the existing rule. 

C. CONTROL REQUIREMENTS 

Please see section (C)(1) through (C)(12) of the rule (see Appendix “A”) for control 

requirements. Control requirements are in the form of VOC limits for the various inks, 

coatings, adhesives, fountain solutions, and solvents for various graphic arts operations 

 

3

 Control Techniques Guidelines for Paper, Film and Foil Coatings, EPA 453/R-07-003, September 2007, pg. 5. 
MDAQMD Rule 1117 – Graphic Arts 13 

Final Staff Report, 01/21/10 

and paper, film, foil and fabric operations. Approved VOC emission control system 

limits, approved coating application equipment, and work practices are also specified.

D. PROPOSED RULE SUMMARY 

This section gives a brief overview of the amendments to Rule 1117. The iterated rule 

version is contained in Appendix “A” of this staff report. 

Proposed amendments to Rule 1117 were designed to enable the District to comply with 

the provisions of H&S Code §39614(d) that requires the adoption of the most readily 

available, feasible and cost-effective control measures for PM as set forth on a list 

developed by CARB.4 This list was developed based on rules, regulations, and programs 

existing in California as of 01/01/04. There is one South Coast Air Quality Management 

District (SCAQMD) Rule listed as potential local control measures contained in the 

CARB document. Specifically, Appendix B of the CARB document Proposed List of 

Measures to Reduce Particulate Matter, Strategy I – Coating Measures (Measures reduce 

VOC) 70, refers to this SCAQMD rule amendment of 10/08/99: Rule 1130 – Graphic 

Arts. The District has analyzed this SCAQMD Rule to determine if the measures they 

contained were readily available, feasible and cost-effective for implementation within 

the MDAQMD. The VOC limits contained in the SCAQMD rule were determined to be 

cost effective and have been incorporated in the amendments to Rule 1117. 

Section (A) has been amended to include all CTG categories for paper, film, foil and 

fabric coating operations, and digital printing operations. 

Section (B) definitions are updated. Definitions have been included to make the rule 

more comprehensive, reflect the current applicability of the rule, and provide additional 

clarity. 

Section (C) requirements have been modified to include specific VOC limits: inks, 

coatings and adhesives (Table 1); fountain solutions (Table 2); flexographic specialty ink 

(Table 3); screen printing inks, coatings, and adhesives (Table 4); paper, film, foil, fabric 

coating and wash primer (Table 5); emission control system overall capture and control 

efficiency (Table 6); and, solvent cleaning (Table 7). Coating application equipment is 

specified in section (C)(7), and work practices are specified in (C)(12). 

Section (D) has been updated to be more comprehensive and to reflect the applicability of 

the rule. The section has also been reorganized for clarity. 

Section (E) has been updated to reflect the applicability. Recordkeeping requirements 

have been strengthened and clarified. Digital printing recordkeeping requirements have 

been added, but this category is otherwise exempted from the requirements of the 

amendments. 

 

4

 A copy of the CARB “Proposed List of Measures to Reduce Particulate Matter – PM10 and PM2.5 

(Implementation of Senate Bill 656, Sher 2003) and attendant staff report may be found at: 

http://www.arb.ca.gov/pm/pmmeasures/pmmeasures.htm . 
14 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10 

Section (F) has been updated to reflect the applicability. 

Various format changes were made for consistency with current MDAQMD rule format, 

as well as correction of typographical errors and several grammatical changes. 

E. SIP HISTORY 

1. SIP History 

a. SIP in the San Bernardino County Portion of MDAQMD 

On July 1, 1993 the MDAQMD was formed pursuant to statute. 

Pursuant to statute it also retained all the rules and regulations of 

the SBCAPCD until such time as the Governing Board of the 

MDAQMD wished to adopt, amend or rescind such rules. The 

MDAQMD Governing Board, at its very first meeting, reaffirmed 

all the rules and regulations of the SBCAPCD. Rule 1117 was a 

new rule adopted by the MDAQMD on 06/22/1994 in response to 

a SIP-Call made by USEPA. This version of the rule was 

submitted for inclusion in the SIP on 07/13/1994 and was approved 

into the SIP on 04/30/96 (61 FR 18962). This version of the rule is 

the current version in the SIP. 

b. SIP in the Riverside County (Blythe/Palo Verde Valley) Portion of 

the MDAQMD 

One of the provisions of the legislations which created the 

MDAQMD allowed areas contiguous to the MDAQMD 

boundaries and within the same air basin to leave their current air 

district and become a part of the MDAQMD. On July 1, 1994 the 

area commonly known as the Palo Verde Valley in Riverside 

County, including the City of Blythe, left SCAQMD and joined the 

MDAQMD. Since USEPA adopts SIP revisions in California as 

effective within the jurisdictional boundaries of local air districts, 

when the local boundaries change the SIP as approved by USEPA 

for that area up to the date of the change remains as the SIP in that 

particular area. Upon annexation of the Blythe/Palo Verde Valley 

the MDAQMD acquired the SIP prior to July 1, 1994 that was 

effective in the Blythe/Palo Verde Valley. Therefore, the SIP 

history for the Blythe/Palo Verde Valley Portion of the MDAQMD 

is based upon the rules adopted and approved for that portion of 

Riverside County by SCAQMD. SCAQMD adopted Rule 1130 – 

Graphic Arts on 10/03/1980 and subsequently amended the rule on

02/01/1985, 05/05/1989, 02/02/1990, 03/02/1990, 04/06/1990, 

06/01/1990, 11/02/1990, 12/07/1990, 08/02/1991, 03/06/1992, 

07/09/1993, and on subsequent dates to the annexation of the 

Blythe/Palo Verde Valley. The 03/06/1992 is the version of Rule 
MDAQMD Rule 1117 – Graphic Arts 15 

Final Staff Report, 01/21/10 

1130 that was given limited approval and limited disapproval in 

the SIP on 04/14/1994 (59 FR 17697). This version of Rule 1130 

should have been effective in the SIP for the Blythe/Palo Verde 

Valley portion of SCAQMD upon annexation into the MDAQMD. 

It is presumed that the current version of Rule 1117 in the 

MDAQMD Rule Book is not applicable to the Blythe/Palo Verde 

Valley area of Riverside County as this rule was adopted on 

06/22/1994, just prior to the annexation of this area. 

SCAQMD adopted Rule 1130.1 – Screen Printing Operations on 

08/02/1991 and subsequently amended the rule on 07/09/1993 and 

12/13/1996. This rule was submitted for inclusion in the SIP but it 

is presumed there was no action taken and the submission was 

withdrawn effective 08/27/1996 (61 FR 43976). Therefore, Rule 

1130.1 is not in the SIP for the Blythe/Palo Verde Valley portion 

of the MDAQMD. 

2. SIP Analysis. 

The District will request that CARB submit the amendments of Rule 1117 to 

replace the SIP versions in effect in the San Bernardino County portion of the 

MDAB and the Blythe/Palo Verde Valley portion of Riverside County. This 

submission is necessary because there are two different SIP versions currently in 

effect within the MDAQMD. 

Since there are previously existing SIP rules for this category the District will 

request that they be superseded. In order to replace existing SIP rules the District 

is required to show that the amendments are not less stringent than the provisions 

currently in the SIP. The rule is more stringent than the prior rules because it has 

been amended to include all CTG categories for paper, film, foil and fabric 

coating operations. The VOC limits for inks, adhesives, coatings, fountain 

solutions, solvents and emission control systems are more stringent than previous 

rule versions (MDAQMD Rule 1117 and SCAQMD Rule 1130). 
16 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10 

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MDAQMD Rule 1117 – Graphic Arts A-1 

Final Staff Report, 01/21/10 

Appendix “A”

Rule 1117 – Graphic Arts and Paper, Film, Foil and Fabric Coatings 

Iterated Version 

The iterated version is provided so that the changes to an existing rule may be easily found. The 

manner of differentiating text is as follows: 

1. Underlined text identifies new or revised language. 

2. Lined out text identifies language which is being deleted. 

3. Normal text identifies the current language of the rule which will remain unchanged by 

the adoption of the proposed amendments. 

4. [Bracketed italicized text] is explanatory material that is not part of the proposed 

language. It is removed once the proposed amendments are adopted. 
A-2 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10 

This page intentionally left blank. 
(Adopted: 06/22/94; Amended: mm/dd/yy)

MDAQMD Rule 1117 1117-1

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RULE 1117 

Graphic Arts and Paper, Film, Foil And Fabric Coatings

(A) General

(1) Purpose: To reduce emissions of volatile organic compounds (VOC) from 

packaging rotogravure, publication rotogravure, and flexographic printing 

operations.

(a) To reduce emissions of Volatile Organic Compounds (VOC) from 

Graphic Arts Printing Operations, Digital Printing Operations, and Paper, Film, 

Foil or Fabric Coating Operations. [Derived from SJVUAPCD Rule 4607 §1.0]

(2) Applicability. The provisions of this rule apply to: [Restated in each 

subsection for clarity]

(a) Any packaging rotogravure, publication rotogravure, or flexographic 

printing operation.

(a) This rule is applicable to any Graphic Arts Printing Operations, Digital 

Printing Operations, and Paper, Film, Foil or Fabric Coating Operation 

and to the Solvent cleaning materials and processes associated with such 

Operations. [Derived from SJVUAPCD Rule 4607 §2.0]

(b) AnyThis rule is applicable to any person who manufactures any ink, 

coating, or adhesiveInk, Coating, or Adhesive containing VOC which is sold, 

offered for sale, or supplied for use in packaging rotogravure, publication 

rotogravure, or flexographic printing operationsGraphic Arts and Paper, Film, 

Foil and Fabric Coating Operations in the District. [Restated for clarity]

(B) Definitions 

For the purposes of this rule, the following definitions shall apply: [New rule definitions 

are derived from SJVUAPCD Rule 4607 unless otherwise indicated]

(1) "Coating": A thin layer of material applied to a substrate in a relatively unbroken 

film.

(2) "Exempt Compounds": Any of the following compounds:

methane,
1117-2 MDAQMD Rule 1117

Graphic Arts d2, 09/01/09 

carbon monoxide,

carbon dioxide,

carbonic acid,

metallic carbides or carbonates,

ammonium carbonate,

1,1,1-trichloroethane,

methylene chloride,

trichlorofluoromethane (CFC-11),

dichlorodifluoromethane (CFC-12),

chlorodifluoromethane (HCFC-22),

trifluoromethane (HFC-23),

1,1,1-trichloro-2,2,2-trifluoroethane (CFC-113),

1-chloro-1,1-difluoro-2-chloro-2,2-difluoroethane (CFC-114),

chloropentafluoroethane (CFC-115),

2,2-dichloro-1,1,1-trifluoroethane (HCFC-123),

2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124),

pentafluoroethane (HFC-125),

1,1,2,2-tetrafluoroethane (HFC-134),

1,1,1,2-tetrafluoroethane (HFC-134a),

1,1-dichloro-1-fluoroethane (HCFC-141b),

1-chloro-1,1-difluoroethane (HCFC-142b),

1,1,1-trifluoroethane (HFC-143a),

1,1-difluoroethane (HFC-152a),

and the following four classes of perfluorocarbon (PFC) compounds:

(i) cyclic, branched, or linear, completely fluorinated alkanes,

(ii) cyclic, branched, or linear, completely fluorinated ethers with no 

unsaturations,

(iii) cyclic, branched, or linear, completely fluorinated tertiary amines 

with no unsaturations, and

(iv) saturated perfluorocarbons containing sulfur with sulfur bonds 

only to carbon and fluorine.

(3) "(1) “Adhesive” – A material that is applied for the primary purpose of 

bonding two surfaces together by surface attachment. Adhesives may be used to 

facilitate the attachment of two surfaces or substances in varying degrees of 

permanence. [Derived from BAAQMD Rule 8-20 §8-20-237]

(2) “Aerosol Product” – A hand-held, non-refillable container that expels a 

pressurized Solvent-containing product by means of a Propellant induced force.

(3) “Application Equipment” – A device, including, but not limited to, a spray gun, 

brush, roller, and a printing press, used to apply Adhesives, coatings, or Inks.
MDAQMD Rule 1117 1117-3

Graphic Arts d2, 09/01/09 

(4) “Bench Scale Project” – A project (other than at a Research and Development 

facility) that is operated on a small scale, such as one capable of being located on 

a laboratory bench top.

(5) “Blanket” – A synthetic rubber mat used to transfer or ”offset” an image from a 

printing plate to paper or other substrate, commonly used in Offset Lithography.

(6) “Blanket Repair Material” – The material used in Offset Lithographic Printing to 

correct low spots in the press Blanket. [Changed for consistency]

(7) “Blanket Wash” – A Solvent used to remove Ink from the Blanket of a press.

(8) “California Air Resources Board (CARB)” – The California State Air Resources 

Board the powers and duties of which are described in Part 2 of Division 26 of the 

California Health & Safety Code (commencing with section 39500). [Derived 

from MDAQMD Rule 1133]

(9) “Capture Efficiency (CE)” – In percent, is the ratio of the weight of the VOC in 

the effluent stream entering the Control Device to the weight of VOC emitted 

from the Operation, both measured simultaneously, and can be calculated by the 

following equation: 

×100 







=

e

c

W

W Capture Efficiency

Where: 

Wc = weight of VOC entering Control Device 

We = weight of VOC emitted from the Operation

(10) “Coating” – The application of a uniform layer of material across the entire width 

of a substrate. Those machines which have both Coating and printing units 

should be considered as performing a printing Operation. Coating applications 

that are not performed in association with a printing Operation are considered 

Coating Operations and are not Graphic Arts Printing Operations.

(11) “Coating Line” –A series of Coating applicators, flash-off areas, and any 

associated curing/drying equipment between one or more unwind/feed stations 

and one or more rewind/cutting stations.

(12) “Control Device” – Equipment such as an incinerator or adsorber, or 

cooler/condenser filtration used to prevent air pollutants from being emitted into 

the atmosphere.

(13) “Control Device Efficiency” – In percent, is the ratio of the weight of the VOC

removed by the Control Device from the effluent stream entering the Control 

Device to the weight of the VOC in the effluent stream entering the Control 
1117-4 MDAQMD Rule 1117

Graphic Arts d2, 09/01/09 

Device, both measured simultaneously, and can be calculated by the following 

equation: 

( )

×100 





 −

=

c

c d

W

W W Control Device Efficiency

Where: 

Wc = Weight of VOC entering Control Device 

Wd = Weight of VOC discharged from the Control Device

(14) “Conventional Printing Operations” – Those printing Operations that utilize 

physical masters, stencils, screens or plates during the printing process. 

Conventional Printing Operations use technologies including but not limited to 

Offset Lithographic, Flexographic, Gravure, Letterpress, and Screen Printing": .

(15) “Cured Adhesive, Cured Coating, or Cured Ink” – An Adhesive, Coating, or Ink 

that is dry to the touch.

(16) “Die Coater (or Slit Coater)” – A type of Application Equipment that coats an 

object by flowing Coatings through a slit directly onto the object moving past the 

slit.

(17) “Digital Printer” – A printing device that uses a computer-driven machine to 

transfer an electronic image to a substrate through the use of Inks, toners, or other 

graphic materials. Digital printing technologies include, but are not limited to, 

various forms of Ink Jet, Thermography, Electrophotography, Ionography, and 

Magnetography.

(18) “Digital Printing Operations” – Those Operations that do not use a physical 

master, stencils, or plates but use digital data to control the deposition of Ink, 

toner, or dye to create images.

(19) “Dip Coater” – A type of Application Equipment that coats an object by 

submerging the object in a vat of Coating, and subsequently withdrawing the 

object and draining off the excess Coating.

(20) “Doctor Blade” – A steel blade used to scrape excess Ink from a printing plate or 

Inking cylinder.

(21) “Dryer” – A hot air, high velocity system used to dry Inks on printed or coated 

substrate.

(22) “Dye Sublimation” – An imaging process that vaporizes colorant with heat and 

pressure, and deposits it onto a substrate in order to simulate a continuous tone 

image. Dye Sublimation is a digital printing technology.
MDAQMD Rule 1117 1117-5

Graphic Arts d2, 09/01/09 

(23) “Electron Beam Ink” – Ink that, when exposed to electron energy, crosslinks or 

solidifies in milliseconds.

(24) “Electron Charge Deposition Printing” – See Ionography [Clarification provided 

for ease of use]

(25) “Electrophotograpy” – A digital printing technology that works by recording an 

image on a drum in the form of an electrostatic charge, which is then transferred 

to the substrate. Electrophotography includes such technologies as laser printers, 

xerography, and Liquid Electrophotography.

(26) “Electrostatic Application” – A method of applying Coating whereby atomized 

paint droplets are charged and subsequently deposited on the substrate by 

electrostatic attraction.

(27) “Exempt Compound” – Those compounds listed in 40 Code of 

Federal Regulations (CFR) 51.100(s)(1). [Derived from 

MDAQMD Rule 1162, correction of typographical error]

(28) “Extreme Performance Ink/Coating” – An Ink or Coating used in Screen Printing 

on a Non-Porous Substrate that is designed to resist or withstand any of the 

following: 

(a) More than two years of outdoor exposure; or 

(b) Exposure to industrial-grade chemicals, Solvents, acids, detergents, oil 

products, cosmetics, temperatures exceeding 170oF, vacuum-forming, 

embossing or molding. [Removed unnecessary word]

(29) “Fabric Coating” – Any decorative or protective Coating or reinforcing material 

applied or impregnated into textile fabric, vinyl coated textile fabric, or vinyl 

sheets.

(30) “Film Coating” – A Coating applied in a Web Coating process on any film 

substrate other than paper or fabric, including but not limited to typewriter 

ribbons, photographic film, magnetic tape, and metal foil gift wrap, but excluding 

Coatings applied to packaging used exclusively for food and health care products 

for human or animal consumption.

(31) “Fine Arts Painting” – Any unique visual representation, consisting of paint, Ink, 

or other media, hand applied to a substrate of canvas, wood, paper, metal, or other 

material.

(32) “Flexible Packaging” – Any package or part of a package the shape of which can 

readily be 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.
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(33) “Flexographic Printing” – The application of words, designs, or pictures to 

a substrate by means of a roll printing technique in which the pattern to be 

is applied is raised above the printing roll and the to an image carrier is 

made of rubber or other elastomeric material. The image to be printed is 

raised above the carrier surface, while the non-image area is not raised.

(4) "(34) “Flow Coater” – A Coating application system with no air supplied to the 

nozzle and where paint flows over the part and the excess Coating drains back 

into the collection system.

(35) “Foam Coater” – A Coating application system that coats an object by flowing 

foam through holes or a slit directly onto the object moving underneath it.

(36) “Foil Coating” – A Coating applied in a Web Coating process on any foil 

substrate other than paper or fabric, including but not limited to typewriter 

ribbons, photographic film, magnetic tape, and metal foil gift wrap, but excluding 

Coatings applied to packaging used exclusively for food and health care products 

for human and animal consumption.

(37) “Fountain Solution” – Solution composed mainly of water and contains at least 

one of the following materials: etchants such as mineral salts; hydrophilic gums; 

or other additives, which is applied to the image plate to maintain the hydrophilic 

properties of the non-image areas.

(38) “Fugitive Emissions": ” – Uncollected emissions of VOC from any 

portion of the printing, coat or laminating operation.Coating or 

Laminating Operation other than from the Dryer. [Correction of 

typographical error]

(5) "(39) “Grams of VOC per Liter of Ink, Coating (or Ink or, Adhesive), 

Excluding, or Wash Primer Less Water and Less Exempt Compounds"

(VOC Content): ) ” – The weight of VOCs emitted during use, 

coatingCoating, curing or drying per combined volume of VOC and 

coating (or ink or adhesive)of Ink, Coating, Adhesive, or Wash Primer

solids and can be calculated by the following equation: 

Grams VOC (less water & exempt compounds) = Ws - Ww - Wes

Liter of Coating Vm - Vw - Ves

( ) ( )

( )







− −

− −

=

m w es

s w es

less water and exempt compounds

V V V

W W W

Liter of Coating

Grams VOC
MDAQMD Rule 1117 1117-7

Graphic Arts d2, 09/01/09 

Where: Ws = weight of volatile compounds, in grams 

Ww = weight of water, in grams 

Wes = weight of exempt compoundsExempt Compounds, in 

grams 

Vm = volume of material, in liters 

Vw = volume of water, in liters 

Ves = volume of exempt compoundsExempt Compounds, in 

liters

(6) "Gravure Printing": An intaglio printing operation in which 

the ink

(40) Grams of VOC Per Liter of Material” – The weight of VOC per volume of 

material and to be calculated by the following equation: [Clarification]

( )







 − −

=

m

s w es

V

W W W Grams of VOC per Liter of Material

Where: Ws = weight of volatile compounds, in grams 

Ww = weight of water, in grams 

Wes = weight of Exempt Compounds, in grams 

 Vm = volume of materials, in liters

(41) “Graphic Arts Coating” – The application of a uniform layer of material across 

the entire width of a substrate. Those machines which perform both Coating and 

printing should be considered as performing a printing Operation. For purposes 

of this rule, digital printing is not considered a Graphic Arts Coating Operation.

[Correction of typographical errors]

(42) “Graphic Arts Printing Operations” – Those Operations employing Conventional 

Printing Operations, or any Coating or Laminating process associated with 

Conventional Printing Operations to produce published products and packages. 

Solvent cleaning Operations performed in order to produce published products 

and packages are considered to be part of Graphic Arts Printing Operations.

(43) “Gravure Printing” – An Intaglio Printing Operation in which the Ink is 

transferred from minute etched wells on a platecylinder to the substrate, which is 

supported by an impression roller, with excess inkInk removed from the cylinder 

by a doctor bladeDoctor Blade. 

(7) "Ink Additive": That solvent which is added to printing inks to reduce viscosity.

(8) "(44) “Hand Application Method” – A method of applying a Coating to a 

substrate using manually held, non-mechanically operated equipment. Such 
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equipment includes paintbrushes, hand rollers, caulking guns, trowels, spatulas, 

syringe daubers, rags, and sponges.

(45) “Heatset Ink” – A quick-drying Ink in which the Solvents are vaporized by 

passing the printed surface through a heater or Oven.

(46) “High-Volume, Low-Pressure (HVLP) Spray Equipment” – Equipment used to 

apply materials by means of a spray gun which is designed and intended to be 

operated, and which is operated, between 0.1 and 10.0 psig of air atomizing 

pressure, measured dynamically at the center of the air cap and the air 

horns.Transfer efficiency specified in section (C)(7)(h). Using same definition as 

SJVUAPCD rule]

 

(47) “Ink” – A pigmented and/or dyed liquid or paste used in a graphic arts operation 

typically for printing, impressing, or transferring an image onto a substrate. 

[Derived from BAAQMD Rule 8-20 § 8-20-239]

(48) “Ink Jet” – A digital printing technology in which Ink is ejected through 

printheads onto a substrate to create an image.

(49) “Intaglio Printing” – Printing done from a plate or cylinder in which the image is 

sunk below (etched or engraved into) the surface.

(50) “Ion Deposition Printing” – See Ionography [Clarification provided for ease of 

use]

(51) “Ionography” – A digital printing technology that utilizes a directed array of ions 

to create a charge on a nonconductive surface to create an image. Ionography can 

also be known as ion deposition or electron charge deposition printing.

(52) “Key System Operating Parameters” – Those parameters necessary to ensure 

compliance with (C)(6), including, but not limited to, temperature, pressure drop, 

and air flow rate.

(53) “Lamination": ” – A process of bonding two or more layers of material to form a 

single, multiple -layer sheet by using an adhesiveAdhesive. 

(9) "(54) “Letterpress printing": Printing” – A printing method where the image 

area is raised relative to the non-image area and the inkInk is transferred to the 

paper directly from the image surface. 

(10) "(55) “Line” – The minimum equipment which is required for the application, 

drying, and/or curing of Inks, Ultraviolet Inks, and/or Coatings on a substrate, 
MDAQMD Rule 1117 1117-9

Graphic Arts d2, 09/01/09 

including the Ink and/or Coating applicators and drying systems, and associated 

Ink and Coating agitation and delivery systems.

(56) “Liquid Leak” – A visible Solvent leak from a container at a rate of more than 

three drops per minute, or a visible liquid mist.

(57) “Liquid Electrophotography (LEP)” – A digital printing technology that records a 

latent electrostatic image on a photoconductive surface, such as a drum or belt. 

The image created by applying toner to the charged areas of the photoconductor is 

electrically transferred to an intermediate surface. In a second transfer process, 

the image is released from the Blanket surface to the final substrate, cooling 

rapidly as the substrate passes between the Blanket and an impression drum, 

causing the image to “peel off” the Blanket and be affixed to the substrate. This 

Operation repeats itself on the one printing station for every color separation in 

the image.

(58) “Lithographic printing": Printing” – Printing by a planographic method in which 

the image and non-image areas are on the same plane. 

(11) "(59) “Magnetography” – A digital printing technology whereby an image is 

printed using a magnetic toner, electromagnetic write heads, and magnetic fields 

on an imaging drum.

(60) “Maintenance Cleaning” – A Solvent cleaning Operation or activity carried out to 

keep tools, machinery, equipment (excluding Ink, Coating, or Adhesive 

Application Equipment) or general work areas in clean and good operational 

condition.

(61) “Manufacturing Process” – The process of making goods or articles by hand or by 

machine.

(62) “Matte Finish Ink” – A Specialty Ink which is applied on Non-Porous Substrates 

in Flexographic Printing Operations and contains at least five percent by weight 

silicon dioxide flattening agent. [Clarification and consistency with definition of 

Specialty Ink]

(63) “Metallic Finish Ink” – A Ink which is applied on Non-Porous Substrates in 

Flexographic Printing Operations and contains at least 28 percent by weight 

elemental metal particles.

(64) “Metallic Ink” – A Specialty Ink containing at least 50 grams of elemental metal 

particles per liter of Ink (0.4 lb/gal) as applied and which is not used in the 

manufacture of an electronic circuit. [Clarification and consistency with definition 

of Specialty Ink]

(65) “Non-Absorbent Container” – A container made of non-porous material that does 

not allow the migration of Solvents through it.
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(66) “Non-Atomized Solvent Flow” – Solvents in the form of a liquid stream without 

the introduction of any Propellant.

(67) “Non-Heatset Ink” – An Ink which dries by oxidation and/or absorption into the 

substrate without use of heat from Dryers or Ovens.

(68) “Non-Leaking Container” – A container without Liquid Leak.

(69) “Non-Porous” – Any substrate whose surface prevents penetration by water, 

including but not limited to foil, polyethylene, polypropylene, cellophane, 

metalized polyester, nylon, and polyethylene terephthalate (mylar), paper or 

paperboard coated with non-porous surface. Clay coated printing paper as 

defined by the American Paper Institute Classification System, and paperboard 

coated with clay to prevent water penetration, shall be considered Non-Porous.

(70) “Offset Lithographic Printing": ” – A planographic method in which the image 

and non-image areas are on the same plane and where the inkInk is transferred 

from an image plate on one cylinder to an image blanketBlanket on a different 

cylinder. The inkInk is finally transferred from the image blanketBlanket to the 

surface to be printed. 

(12) "Oven": (71) “On-Press Component” – A part, component, or accessory of a 

press that is cleaned while still being physically attached to the press.

(72) “Operation” – Any physical action resulting in a change in the location, form, or 

physical properties of a material, or any chemical action resulting in a change in 

the chemical composition or the chemical or physical properties of a material.

(73) “Operator” – Includes but is not limited to any person who owns, leases, 

supervises, or operates a facility and/or equipment.

(74) “Oven” – A heating chamber which uses heat, ultraviolet (UV) radiation, or 

electron beam (EB) radiation to bake, cure, polymerize, or dry a surface 

coatingCoating. 

(13) "(75) “Packaging Gravure": Gravure printing ” – Gravure Printing on paper, 

paperboard, foil, film or other substrates which are to be used to produce 

containers or packages. 

(14) "(76) “Pantone Color": A printing inkInk” – An Ink created for color matching 

by combination of process inksProcess Inks. 

(15) "Printing Ink": Any fluid or viscous composition used in printing, impressing, or 

transferring an image onto a substrate.
MDAQMD Rule 1117 1117-11

Graphic Arts d2, 09/01/09 

(16) "(77) “Paper Coating” – Any Coating applied on or impregnated into paper, 

including, but not limited to, Adhesive tapes and labels, book covers, post cards, 

office copier paper, drafting paper, and pressure sensitive tapes.

(78) “Plastisizer” – A material used to keep plastic material soft and viscous.

(79) “Plastisol” – A Coating that is a liquid dispersion of small particles of resins and 

Plastisizers that are fused to become a plastic.

 

(80) “Porous” – A substrate whose surface does not prevent penetration by water, 

including but not limited to, paper, paperboard, and any paper product coated with 

a porous material.

(81) “Process Ink": ” – The hues yellow, magenta, and cyan, plus black used in 

the four-color print process. 

(17) "(82) “Proof Press” – A press used only for printing a sample copy of a graphic 

art product to check the quality of print, color reproduction and editorial content.

(83) “Propellant” – Any gas, including air, in a pressure container for expelling the 

contents when the pressure is released.

(84) “Publication rotogravure": Gravure printing on paperGravure” – Gravure Printing 

on a substrate which is subsequently formed into books, magazines, catalogues, 

brochures, directories, newspaper supplements or other types of printed material. 

(18) "(85) “Removable Press Component” – A part, component, or accessory of a 

press that is physically attached to the press but is disassembled and removed 

from the press prior to being cleaned. Rollers, Blankets, metering rollers, 

fountains, impression cylinders and plates shall not be considered as Removable 

Press Components.

(86) “Repair Process” – The process of returning a damaged object or an object not 

operating properly to good condition.

(87) “Research and Development” – A facility or portion thereof used to further the 

development of useful materials, devices, systems, or methods, including, but not 

limited to, design, development, and improvement of prototypes and processes. 

Research and Development does not include the Manufacturing Process itself.

(88) “Resists” – Inks that are Screen Printed to form the required patterns, alphabets, 

numerals, designs, or symbols on the surface of the substrate; protect the Screen 

Printed or covered surface from the subsequent application of etching or plating 
1117-12 MDAQMD Rule 1117

Graphic Arts d2, 09/01/09 

solution; and are later removed from the substrate by a resist stripper. Resist 

applications include, but are not limited to, etched electronic circuits, display 

screens, chemical milling of parts, nameplates and signage.

(89) “Roll Coater” – A type of Application Equipment in which a series of mechanical 

rollers form a thin Coating film on the surface of a roller, which is subsequently 

applied to a substrate by moving the substrate underneath the roller.

(90) “Roller Wash” – A Solvent used to remove Ink from the rollers of a press.

(91) “Screen Printing": ” – A process where the printing inkInk passes through a 

webWeb or a fabric to which a refined form of stencil has been applied. The 

stencil openings determine the form and dimensions of the imprint. 

(19) "Volatile Organic Compounds (VOCs)": Any compound containing at least one 

atom of carbon, except exempt organic compounds.

(92) “Screen Printing Metallic Ink” – An Ink used in Screen Printing that contains 

greater than 50 grams of elemental metal per liter (0.4 lb/gal) of Ink as applied.

(93) “Sign Ink/Coating” – An Ink or Coating used in Screen Printing indoor and 

outdoor signs (excluding structural components) and murals, including lettering 

enamels, poster colors, copy blockers, and bulletin enamels.

(94) “Slit Coater” – See Die Coater [Added for clarification and ease of use]

(95) “Solvent” – Any liquid containing a volatile organic compound or combination of 

volatile organic compounds, which is used as a diluent, thinner, dissolver, 

viscosity reducer, cleaning agent, or for other similar uses. [Derived from 

SJVUAPCD Rule 4663 §3.36]

(96) “Solvent Flushing” – The use of a Solvent to remove uncured Adhesives, uncured 

Inks, uncured Coatings, or contaminants from the internal surfaces and passages 

of equipment by flushing Solvent, by a Non-Atomized Solvent Flow, through the 

equipment.

(97) “Specialty Flexographic Printing” – A Flexographic Printing on polyethylene or 

polypropylene food packaging, fertilizer bags, or liquid-tight food containers.

(98) “Specialty Gravure Printing” – Printing that uses the gravure process for 

production of wall and floor covering, decorated household paper products such 

as towels and tissues, cigarette filter tips, vinyl upholstery, woodgrains, and a 

wide variety of other products.
MDAQMD Rule 1117 1117-13

Graphic Arts d2, 09/01/09 

(99) “Specialty Ink” – An Ink that is applied only on Non-Porous Substrates in 

Flexographic Printing Operations, and is either:

(a) A Metallic Ink that contains at least 28 percent elemental metallic powder, 

by weight; or

(b) A matte finish Ink containing at least 5 percent silicon dioxide flattening 

agent, by weight.

(100) “Stripping” – The use of Solvent to remove material such as Cured Adhesives, 

Cured Inks, cured or dried paint, cured or dried paint residue or temporary 

protective Coating.

(101) “Substrate Retention Factor” – A fraction, expressed in percent, of VOCs in 

lithographic Inks which is retained in the substrate when the Inks dry by 

adsorption or absorption.

(102) “Surface Preparation” – The removal of contaminants from a surface prior to the 

application of Coatings, Inks, or Adhesives or before proceeding to the next step 

of a Manufacturing Process.

(103) “Thermography” – A digital printing technology that creates an image via a 

chemical reaction that occurs when portions of a thermal-coated substrate are 

subjected to heat. Thermographic technologies include but are not limited to 

thermal wax transfer, multi-bit thermal wax transfer, and Dye Sublimation.

(104) “Thin Film UV Ink” – An Ultraviolet Ink for which <0.2 g will cover an area of 

≥225 cm2 (35 in2), using the following formula: [Derived from EPA Method 24]

C = F × A× Dc

Where: A = area of substrate in cm2 (or in2)

 C = amount of Ink added to the substrate in g

 Dc = density of Ink in g/cm3 (or g/in3)

 F = manufacturer’s recommended film thickness in cm 

 (or in)

(105) “Thinner” – A Solvent that is used to dilute Coatings or Inks to reduce viscosity, 

color strength, and/or solids, or to modify drying conditions. [Clarification]

(106) “Ultraviolet (UV) Ink” – An Ink which dries by polymerization reaction by 

ultraviolet or electron beam radiation.

(107) “USEPA” – The United States Environmental Protection Agency, the 

Administrator of the USEPA and his or her authorized representative. [Derived 

from MDAQMD Rule 1165]
1117-14 MDAQMD Rule 1117

Graphic Arts d2, 09/01/09 

(108) Volatile Organic Compound (VOC) – Any compound of carbon, excluding 

carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, 

and ammonium carbonate, which participates in atmospheric photochemical 

reactions and those compounds listed in 40 CFR 51.100(s)(1). [Derived from 

MDAQMD Rule 1162] 

(109) “Wash Primer” – A material used to clean and/or to activate surfaces of paper or 

fabric that contains no more than 5 percent, by weight, solid materials.

(110) “Waste Solvent Material” – Any Solvent which may contain dirt, oil, metal 

particles, sludge, and/or waste products, or wiping material containing VOCs 

including, but not limited to, paper, cloth, sponge, rag, or cotton swab used in 

Solvent cleaning.

(111) “Water Slide Decal” – A decal that is Screen Printed onto treated paper stock and 

is removable from the stock by the dissolution of an underlying water- soluble 

Adhesive or similar carrier.

(112) “Web” – A continuous sheet of substrate.

(113) “Web Feed” – An automatic system which supplies substrate from a Web.

(114) “Web Splicing Adhesive” – An Adhesive used to join two continuous rolls of 

substrate materials.

(115) “Wipe Cleaning” – A Solvent cleaning activity performed by hand rubbing an 

absorbent material such as a rag, paper, sponge, brush, or cotton swab containing 

Solvent.

(C) Requirements 

(1) No packaging rotogravure, publication rotogravure, or flexographic printing 

operation shall use any inks, coatings, or adhesives unless the grams of VOC per 

liter of coating (or ink or adhesive), excluding water and exempt Compounds, as 

applied, is less than 300 grams per liter (2.5 lbs/gallon).

(2(1) Graphic Arts Printing Operation [Derived from SJVUAPCD Rule 4607 §5.1]

(a) An Operator performing a Graphic Arts Operation, not subject to (C)(2), 

(C)(3), (C)(4), and (C)(5), shall not use graphic arts materials containing 

VOC in excess of the limits in Table 1 and Table 2, in accordance with the 

effective date. 

 Table 1
MDAQMD Rule 1117 1117-15

Graphic Arts d2, 09/01/09 

VOC Content Limits for Inks, Coatings and Adhesives

Material

Grams of VOC per liter 

(lb/gal), less water and less 

exempt compounds, as 

applied, effective through 

July 31, 2010

Grams of VOC per liter 

(lb/gal), less water and 

less Exempt Compounds, 

as applied, effective on 

and after August 1, 2010

Flexographic Ink 

on Porous 

Substrates

300 (2.5) 225 (1.88)

All other Inks 300 (2.5) 300 (2.5)

Coatings 300 (2.5) 300 (2.5)

Adhesives 300 (2.5) 150 (1.25)

Web Splicing 

Adhesives 300 (2.5) 150 (1.25)

 Table 2

VOC Content Limits for Fountain Solutions

Fountain Solution Percent VOC by volume, effective on 

and after August 1, 2010

Heatset Web Offset Lithographic 1.6

Coldset Web Offset 

Lithographic 5.0

Sheet-fed Offset Lithographic 

with maximum sheet size greater

than 11 x 17 inches

5.0

All other presses 8.0

(2) Flexographic Specialty Ink [Derived from SJVUAPCD Rule 4607 §5.2]

(a) An Operator using a Flexographic Printing Operation shall not use a 

Specialty Ink in excess of the VOC limit in Table 3, and shall not use 

more than two (2) gallons of Specialty Inks in a calendar day and 120 

gallons of Specialty Inks in a calendar year.
1117-16 MDAQMD Rule 1117

Graphic Arts d2, 09/01/09 

 Table 3

VOC Content Limits for Flexographic Specialty Ink

Material

Grams of VOC per liter (lb/gal), less 

water and less exempt compounds, as 

applied, effective on and after August 1, 

2010

Metallic Ink 460 (3.8)

Matte Finish Ink 535 (4.5)

Metallic Ink and Matte Finish 

Ink on Flexible Package Printing 383 (3.2)

(b) On and after August 1, 2010, facilities with the potential to emit or with 

actual emissions of at least 10 tons VOC in any calendar year shall not use 

Specialty Inks with VOC content greater than 300 grams VOC per liter, 

less water and Exempt Compounds, as applied.

(3) Coldset Web Offset Lithographic Fountain Solution [Derived from SJVUAPCD 

Rule 4607 §5.3]

(a) On and after August 1, 2010, an Operator performing coldset Web Offset 

Lithographic Printing shall use Fountain Solution that is five percent 

alcohol substitute or less, by weight, and shall have no alcohol in the 

Fountain Solution.

(4) Screen Printing Operation [Derived from SJVUAPCD Rule 4607 §5.4]

(a) An Operator using a Screen Printing Operation shall not use graphic arts 

materials in excess of the VOC content limits, as applied, in Table 4.

 Table 4

VOC Content Limits for Screen Printing Inks, Coatings, and Adhesives

Material

Grams of VOC per liter (lb/gal), less 

water and less Exempt Compounds on 

and after August 1, 2010

Inks and Coatings, including 

Extreme Performance, 

Metallic and Sign/Ink

400 (3.3)

Adhesives 150 (1.25)

Resists 600 (5.0)

(5) Paper, Film, Foil, or Fabric Coating Operations [Derived from SJVUAPCD Rule 

4607 §5.5]

(a) An Operator using a Paper, Film, Foil, or Fabric Coating Operation shall 

not use any Coating or Wash Primer in excess of the VOC content limits, 

as applied, in Table 5.
MDAQMD Rule 1117 1117-17

Graphic Arts d2, 09/01/09 

 Table 5

VOC Content Limits of Paper, Film, Foil, or Fabric Coating and Wash Primer

Material

VOC Content Limit, 

effective through July 31, 

2010

VOC Content Limit, 

effective on and after 

August 1, 2010

Coating

300 gm/liter (2.5 lb/gal) 

of Coating, less water 

and less Exempt 

Compounds

265 gm/liter (2.2 lb/gal) 

of Coating, less water 

and less Exempt 

Compounds

Wash Primer

300 gm/liter (2.5 lb/gal) 

of Coating, less water 

and less Exempt 

Compounds

265 gm/liter (2.2 lb/gal) 

of Coating, less water 

and less Exempt 

Compounds

Plastisols __ 20 gm/liter (0.16 lb/gal)

(b) On and after August 1, 2010, an Operator performing pressure sensitive 

tape and label surface Coating Operations shall not use any VOC content 

materials or combinations of materials that exceed a VOC content of 

either 0.20 kg of VOC/kg of solids (0.20 lb VOC/lb of solids), as applied, 

or an additional limit of 0.067 kg VOC/kg of Coating (0.067 lb of VOC/lb 

of Coating), as applied.

(6) Approved VOC Emission Control System [Derived from SJVUAPCD Rule 4607 

§5.6]

(a) Heatset Web Offset Lithographic or Letterpress

On or after August 1, 2010, an Operator performing Heatset Web Offset 

Lithographic or Letterpress Printing that has greater than 25 tpy potential 

to emit prior to controls shall use an add-on Control Device on the Dryers, 

as follows: [Correction of typographical error]

(i) Heatset Web offset lithographic or letterpress printer Control 

Device installed on or prior to July 31, 2010 shall have an overall 

capture and control efficiency of 90 percent. [Typographical 

correction and format change for consistency]

(ii) Heatset Web offset lithographic or letterpress printer Control 

Device installed on or after August 1, 2010 shall have an overall 

capture and control efficiency of 95 percent. [Format consistency]

(b) In lieu of the requirements of Subsection (C)(1), (C)(2), (C)(3), (C)(4) and 

(C)(5), emissions of VOC may be controlled by an emission capture and control 

system, which reduces VOC emissions to the atmosphere, provided that: 
1117-18 MDAQMD Rule 1117

Graphic Arts d2, 09/01/09 

(a) Averaged over any period of continuous operation not to exceed 24 hours, 

the control device reduces the VOC emissions delivered from the capture 

system to the control device by at least 90 percent, by weight; and,

(b) Averaged over any period of continuous operation not to exceed 24 hours, 

the combined effects of the capture and control system shall provide an 

overall emission reduction efficiency of at least:

(i) 75 percent, by weight, for publication rotogravure, or

(ii) 65 percent, by weight, for packaging rotogravure, or

(iii) 60 percent, by weight, for flexographic printing operations; and,

(i) The VOC emission control system is approved, in writing, by the 

Air Pollution Control Officer (APCO). [Typographical correction]

(ii) During continuous operation, not to exceed 24 hours, the VOC 

emission control system shall have a minimum overall VOC 

capture and control efficiency as specified in Table 6, in 

accordance with the corresponding effective date;

Table 6

VOC Emission Control System Overall Capture and Control Efficiency

Process

Overall VOC capture 

and control efficiency 

%, by weight, 

effective through July 

31, 2010

Overall VOC capture 

and control efficiency 

%, by weight, 

effective on and after 

August 1, 2010

Flexible Package Printing 

(All Technologies) 65% 80%

Publication Gravure 75% 85%

Flexographic Printing 

Operations 60% n/a 

Other Printing 

Operations

n/a 75%

Paper, Film, Foil, or 

Fabric Coating 

Operations

n/a 90%

(c) The collection system shall vent all drying ovenOven exhaust to the 

control deviceControl Device and shall have one or more inlets for collection of 

fugitive emissionsFugitive Emissions; and, 
MDAQMD Rule 1117 1117-19

Graphic Arts d2, 09/01/09 

(d) During any period of operation of a thermal incinerator, combustion 

temperature shall be continuously monitored; and, 

(e) During any period of operation of a catalytic incinerator, exhaust gas 

temperature shall be continuously monitored; and, 

(f) Appropriate permit(s) for the emission capture and control system are 

obtained pursuant to District regulations. 

(3) Materials containing VOCs shall be stored in nonabsorbent, nonleaking 

containers, which shall be kept closed except when adding or removing material 

or during cleaning operations.

(4)(g) The VOC emission control system shall reduce VOC emissions, at all 

times, to a level that is not greater than the emissions which would have 

been achieved through the use of compliant materials, compliant 

equipment or compliant work practices in Sections (C)(1), (C)(2), (C)(3), 

(C)(4), (C)(5), and (C)(8).

(7) Coating Application Equipment [Derived from SJVUAPCD Rule 4607 §5.7]

 No Operator shall apply Coatings unless Coatings are applied with equipment 

operated according to manufacturer’s specifications, and only by the use of one of 

the following types of Coating Application Equipment:

(a) Flow Coater;

(b) Roll Coater;

(c) Dip Coater:

(d) Foam Coater;

(e) Die Coater;

(f) Hand Application Methods; or

(g) High-volume, low-pressure (HVLP) spray for air dried Coatings.

(i) For HVLP spray guns manufactured prior to January 1, 1996, the 

end user shall demonstrate that the gun meets HVLP spray 

equipment standards. Satisfactory proof will be either in the form 

of manufacturer's published technical material or by a 

demonstration using a certified air pressure tip gauge, measuring 

the air atomizing pressure dynamically at the center of the air cap 

and at the air horns.
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Graphic Arts d2, 09/01/09 

(ii) A person shall not sell or offer for sale for use within the District 

any HVLP spray gun without a permanent marking denoting the 

maximum inlet air pressure in psig at which the gun will operate 

within the parameters specified in (B)(46).

(h) Other Coating application methods which are demonstrated to the APCO 

to be capable of achieving at least 65 percent transfer efficiency as 

determined in accordance with Section (F). Prior written approval from 

the APCO shall be obtained for each alternative method used.

(i) In lieu of complying with Section (C)(7)(a) through (C)(7)(h), an Operator

may control emissions from the Coating Application Equipment with a 

VOC emission control system that meets the requirements of Section 

(C)(6).

(8) Solvent Cleaning [Derived from SJVUAPCD Rule 4607 §5.8]

(a) An Operator shall not use Solvents for cleaning Operations that exceed the 

VOC content limits specified in Table 7 in accordance with the 

corresponding effective date.
MDAQMD Rule 1117 1117-21

Graphic Arts d2, 09/01/09 

 Table 7

VOC Content Limits for Solvent Cleaning

Type of Solvent Cleaning Operation 

VOC Content Limit grams 

of VOC/liter of material 

(Lb/gal), effective on and 

after July 1, 2011 [Date 

changed for consistency 

with BAAQMD 

requirement at request of 

commenter]

A. Product Cleaning During Manufacturing 

Process; or Surface Preparation for Coating, 

Ink, or Adhesive Application

25 (0.21)

B. Repair and Maintenance Cleaning 25 (0.21)

C. Cleaning of Coating or Adhesive 

Application Equipment 25 (0.21)

D. Cleaning of Ink Application Equipment

 1. General 25 (0.21)

 2. Flexographic Printing 25 (0.21)

 3. Specialty Flexographic Printing 100 (0.83)

 4. Gravure Printing

 a. Publication 100 (0.83)

 b. Packaging 25 (0.21)

 5. Lithographic (Offset) or Letterpress 

Printing

 a. Roller Wash - Step 1 100 (0.83)

 b. Roller Wash - Step 2; Roller Wash -

not specified; Blanket Wash, and On-Press 

Components

100 (0.83)

 c. Removable Press Components 25 (0.21)

 6. Screen Printing 100 (0.83)

 7. Ultraviolet Ink/Electron Beam Ink 

Application Equipment (except Screen 

Printing)

100 (0.83)

(b) 

(b) The following cleaning Operations may be performed outside of an 

APCO-approved VOC emission control system and using Solvent with 

VOC content greater than 25 g/L:

(i) Wipe Cleaning;

(ii) Application of Solvent from hand-held spray bottles from which 

Solvents are dispensed without a Propellant induced force; 
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Graphic Arts d2, 09/01/09 

(iii) Non-Atomized Solvent Flow method in which the cleaning Solvent

is collected in a container or a collection system which is closed 

except for Solvent collection openings and, if necessary, openings 

to avoid excessive pressure build-up inside the container; or

(iv) Solvent Flushing method in which the cleaning Solvent is 

discharged into a container that is closed except for Solvent

collection openings and, if necessary, openings to avoid excessive 

pressure build-up inside the container. The discharged Solvent

from the equipment must be collected into containers without 

atomizing into the open air. The Solvent may be flushed through 

the system by air or hydraulic pressure, or by pumping.

(c) Solvent shall not be atomized into the open air unless it is vented to a 

VOC emission control system that complies with Section (C)(6). This 

provision shall not apply to printing Operations where the roller or 

Blanket Wash is applied automatically and the cleaning of nozzle tips of 

automated spray equipment systems, except for robotic systems, and 

cleaning with spray bottles or containers described in Section (C)(8)(b)(ii).

[Correction of typographical error]

(d) An Operator shall not use VOC-containing materials to clean spray 

equipment used for the application of Coatings, Adhesives, or Ink, unless 

an enclosed system or equipment that is proven to be equally effective at 

controlling emissions is used for cleaning. If an enclosed system is used, it 

must totally enclose spray guns, cups, nozzles, bowls, and other parts 

during washing, rinsing and draining procedures, and it must be used 

according to the manufacturer’s recommendations and must be closed 

when not in use.

(e) In lieu of complying with the provisions of Sections (C)(8)(a) through 

(C)(8)(d), an Operator may control emissions from cleaning Operations 

with an APCO-approved VOC emission control system that meets the 

requirements of Section (C)(6).

(9) An Operator shall store or dispose of fresh or spent Solvents, Waste Solvent 

Materials, Coatings, Adhesives, catalysts, Thinners, and Ink in Non-Absorbent, 

Non-Leaking Containers, which shall be kept closed except when adding or 

removing material, during cleaning Operations, or when the container is empty.

(10) VOC material wastes (including but not limited to liquid wastes, rags, and 

packaging) shall be disposed of in a manner consistent with Federal, State, 

and local hazardous waste regulations. 

(5)(11) The manufacturer of any ink, coating, or adhesiveInk, Coating, or 

Adhesive, except Thin Film UV Ink, which is sold, offered for sale, or 

supplied for use in packaging rotogravure, publication rotogravure, or 
MDAQMD Rule 1117 1117-23

Graphic Arts d2, 09/01/09 

flexographic printing operationsPackaging Gravure, Publication Gravure, 

or Flexographic Printing Operations in the District shall include the 

following information on the product container or a data sheetMaterial 

Safety Data Sheet (MSDS) supplied with the product: [Thin Film UV Inks 

are exempted because there is no method for determining VOC content. 

ASTM D 5403-93, Standard Test Methods for Volatile Content of 

Radiation Curable Materials, is not applicable]

(a) Material name, manufacturer identification, specific mixing instructions, 

density, and VOC content, as applied. 

(b) The VOC content of inks, coatingsInks (except Thin Film UV Ink), 

Coatings, and adhesivesAdhesives expressed as defined in Subsection (B)(539) 

[Correction of typographical error].

(12) Work Practices [Specific work practices added in response to USEPA comments, 

derived from EPA-453/R-06-002, CTG for Offset Lithographic Printing and 

Letterpress Printing (September 2006), EPA 453/R-07-003, CTG for Paper, Film, 

and Foil Coatings (September 2007) and EPA 453/R-06-003, CTG for Flexible 

Packaging Printing (September 2006)]

(a) An Operator shall properly use and properly operate all graphic arts 

printing technologies as directed and/or specified by the manufacturer of 

the printer or graphic arts material.

(b) Solvent containers and mixing tanks must be kept closed or covered 

except when filling, draining, or conducting cleaning operations. 

(c) Used shop towels, rags and wipes shall be kept in closed containers. 

(d) Spray guns shall be cleaned in an enclosed system. [Reworded for 

consistency with prior work practice sections]

(e) Recycled solvents shall be used for cleaning if available and practical. 

[Reworded for consistency with prior work practice sections]

(f) Cleaning materials shall be conveyed from one location to another in 

closed containers or pipes. [Reworded for consistency with prior work 

practice sections]

(D) Exemptions 
1117-24 MDAQMD Rule 1117

Graphic Arts d2, 09/01/09 

(1) The requirements of Subsections (C)(1) and (C)(2) shall not apply to graphic arts 

facilities which emit less than 2500 pounds of VOC in any month from printing, 

coating, and adhesive operations. Once a facility becomes subject to Subsections 

(C)(1) and (C)(2) by exceeding this threshold, it will remain subject to these 

provisions even if its emissions later fall below the applicability threshold.

(2) Screen Printing.

(3) Letterpress Printing.

(4) Lithographic Printing.

(1) The requirements of this rule, except for the recordkeeping requirements of 

section (E)(6), shall not apply to the following Operations except for Paper, Film, 

Foil, or Fabric Coating Operations:

(a) Effective through July 31, 2010, any Graphic Arts Printing Operation 

which emits less than 400 pounds of VOC per calendar month. [Derived 

from SJVUAPCD Rule 4607 §4.1.1, typographical correction]

(b) On or after August 1, 2010, any Graphic Arts Printing Operation that 

emits less than 200 pounds of VOC per 12 rolling consecutive calendar 

months. [Derived from SJVUAPCD Rule 4607 §4.1.2]

 [Relocated to (D)(2)](2) The requirements of this rule shall not apply to: [Derived 

from SJVUAPCD Rule 4607 §4.3]

(a) Proof Presses;

(b) The application of Coatings and use of cleaning Solvents in creating Fine 

Art Paintings;

(c) Stripping of Cured Coatings, Cured Adhesives, and Cured Inks, except the 

Stripping of such materials from spray Application Equipment;

(d) Cleaning Operations in printing pre-press or graphic arts pre-press areas, 

including the cleaning of film processors, color scanners, plate processors, 

films, and plates. [Removed redundant wording]

(e) Blanket Repair Materials used in containers of four (4) fluid ounces or 

less. [Derived from SJVUAPCD Rule 4607 §4.1.3]

(f) Digital Printers and Digital Printing Operations except for recordkeeping 

requirements in section (E)(5) . [Derived from SJVUAPCD Rule 4607 

§4.1.4]
MDAQMD Rule 1117 1117-25

Graphic Arts d2, 09/01/09 

(g) Screen Printing of Waterslide Decals. [Derived from BAAQMD Rule 8-

20, §8-20-118]

(3) The provisions of section (C) shall not apply to the application of Adhesives and 

Coatings via Aerosol Products. [Derived from SJVUAPCD Rule 4607 §4.4]

(4) This rule shall not apply to laboratory tests or analyses, Bench Scale, or Research 

and Development Projects. [Derived from SJVUAPCD Rule 4607 §4.5]

(5) This rule shall not limit the VOC content of Thin Film UV Inks.(6) Cleaning 

materials with a VOC composite vapor pressure less than 8 mm Hg at 20o C are 

exempt from section (C)(8)(a) of this rule. [Derived from EPA-453/R-06-001, 

Control Techniques Guidelines: Industrial Cleaning Solvents (September 2006)] 

.

(E) Monitoring and Records

Unless otherwise noted, all VOC content and density values recorded pursuant to the 

requirements of this rule shall be for the material as applied. Packaging rotogravure, 

publication rotogravure,Graphic Arts and flexographic printing operationsPaper, Film, 

Foil and Fabric Coating Operations subject to this rule shall maintain the following 

records and information: 

(1) For each ink, coating, and adhesiveInk, Coating, and Adhesive, Fountain Solution, 

Wash Primer, and Solvent in use and in storage: 

(a) aA Material Safety Data Sheet (MSDS) or product data sheet or material 

list giving material name, manufacturer identification, specific mixing 

instructions, and density; and 

(b) VOC content as applied. 

(2) Compliant Materials Records [Changes derived from SJVAPCD Rule 4607 

§6.1.2]

If only inks, coatingsInks, Coatings, and adhesivesAdhesives meeting the 

specification found in Subsection (C)(1) are used: 

(a) Records on a daily basis showing the amount of ink Ink used. Ink use 

records shall be maintained using one of the following options: [Monthly changed 
1117-26 MDAQMD Rule 1117

Graphic Arts d2, 09/01/09 

back to daily at suggestion of USEPA. Had been changed to monthly to reflect 

SJVAPCD rule requirements.]

(i) Group the quantity of all inksInks used and noteidentify the 

highestmaximum VOC content figure and use the lowest minimum 

density figure from all the inks.of 1,010 gm/liter (8.44 lb/gal) ; 

(ii) Itemize each inkProcess Inks and pantone colorPantone 

Inks separately and use the specific VOC content and density value

for each.

(b) Records on a daily basis showing the amount of coatings Process 

Ink, and adhesives used. the highest VOC content and the 

maximum density of 1,010 gm/liter (8.44 lb/gal) for Pantone Inks; 

(iii) Report Process Inks and Pantone Inks separately and use 

the maximum VOC content and minimum density value for 

both process and Pantone Inks, or use the density of 1,010 

gm/liter (8.44 lb/gal) for Pantone Inks; or

(iv) Itemize each coating and adhesiveInk and Pantone Ink and 

use the specific VOC content and density value for each. 

(3) If inks, coatings, or adhesives(b) Records on a daily basis showing the 

amount of Coatings,Adhesive, Wash Primer, and Solvent (including 

cleaning Solvent) used. Itemize each Coating, Adhesive, Wash Primer, 

and Solvent and use the specific VOC content and density value for each. 

[Correction of typographical omission]

(c) Record, on a daily basis, the type, amount, and percent VOC by volume of 

Fountain Solution used. [Derived from SJVAPCD Rule 4607 §6.1.2.3]

(3) Non-Compliant Materials Records [Changes derived from SJVAPCD Rule 4607 

§6.1.3]

If Inks, Coatings, Adhesives, Fountain Solutions, Wash Primers, and 

Solvents (including non-compliant cleaning Solvent) which do not meet 

the specifications found in Subsection (C)(1) are used and compliance is 

achieved through the use of add-on emission control equipment pursuant 

to (C)(6): 

(a) Records on a daily basis showing the type and amount of inks, coatings, 

and adhesives used. Such records shall itemize each ink, coating, and 

adhesiveInks, Coatings, Adhesives, Fountain Solutions, Wash Primers, and 
MDAQMD Rule 1117 1117-27

Graphic Arts d2, 09/01/09 

Solvents (including non-compliant cleaning Solvent) usedand itemized using the 

specific VOC content and density value for each. 

(b) Daily records of key system operating and maintenance parametersKey 

System Operating Parameters which will demonstrate continuous 

operationOperation and compliance of the emission control deviceControl Device

during periods of emission producing activities. Key system operating parameters 

Key System Operating Parameters are those necessary to ensure compliance with 

VOC capture and control requirements pursuant to (C)(6) (including but not 

limited to temperatures, pressures, and flow rates). Such records shall be kept in 

the form and manner as prescribed by the APCO. 

(4) Records for Flexographic Specialty Inks [Derived from SJVAPCD Rule 4607 

§6.1.4]

If flexographic Specialty Inks are used pursuant to section (C)(2), record, on a daily 

basis, the type and amount of each Specialty Ink used.(5) Digital Printing 

Records [Derived from SJVAPCD Rule 4607 §6.1.6]

(a) On or after August 1, 2010, Digital Printing Operations shall keep records 

in accordance with (E)(5)(b) for each Digital Printer that: [Clarification]

(i) Uses Solvent-based Inks and has a print capacity of 1,000 ft

2

/hr or 

more; or

(ii) Uses water-based Inks, or UV Inks and has a print capacity of 

10,000 ft

2

/hr or more,

(b) Operators with printers Subject to Section (E)(5)(a) shall keep the 

following records:

(i) A current file of Inks, Coatings, Adhesives, and Solvents in use 

and in storage. The file shall include a MSDS or product data sheet 

showing the material name, manufacturer's name, VOC content as 

applied, specific mixing instructions, and density.

(ii) Monthly records of the type, and amount of each Ink, Coating, 

and/or Adhesive used.

(iii) Monthly records of the type, and amount of Solvent used for 

thinning the Ink, Coating, or Adhesive, and for cleaning.

(6) If the facility is claiming exempt status pursuant to Subsection (D)(1), the 

facility shall maintain adequate records on a monthly basis to demonstrate 

the exempt status. The Operator who becomes subject to the emission 

limits/standards of this rule through loss of exemption in Section (D) shall 

not operate the subject equipment, except as required for obtaining a new 
1117-28 MDAQMD Rule 1117

Graphic Arts d2, 09/01/09 

or modified Permit-to-Operate, until the Operator demonstrates that the 

Operation is in full compliance with the requirements of this rule.

(57) Any record required or produced pursuant to this rule shall be retained on 

site for a minimum of five years and shall be made available to the APCO, 

CARB, or USEPA upon request. 

 [See section (C)(11), duplicative.](8) Determination of VOC Emissions from Inks 

Used in a Lithographic Printing Operation [Derived from SJVAPCD Rule 4607 

§6.3]

For the purposes of determining compliance with emissions limits, and 

determining eligibility for exemption under Section (D)(1) of this rule, the amount 

of VOC emitted from Heatset and Non-Heatset Inks used shall be discounted by 

the following Substrate Retention Factors: 20 percent for Heatset Inks and 95 

percent for Non-Heatset Inks. These Substrate Retention Factors shall not be 

used when determining compliance of Inks with applicable VOC content limits 

specified in this rule, and Heatset and Non-Heatset lithographic Inks shall meet 

the VOC content limits specified in Section (C)(1), Table 1.

(F) Test Methods

(1) Measurement of the VOC content of inks, coatings, and adhesives, except as 

specified in subsection (F)(2), shall be conducted and reported in accordance with 

EPA Reference Method 24 and ARB Method 432 for determination of exempt 

compounds as necessary. Perfluorocarbon compounds shall be assumed to be 

absent from a product or process unless a manufacturer or facility operator 

identifies the specific individual compounds (from the broad classes of 

perfluorocarbon compounds) and the amounts present in the product or process 

and identifies a validated test method which can be used to quantify the specific 

compounds.

(2) Measurement of the VOC content of publication rotogravure inks shall be 

conducted and reported in accordance with EPA Reference Method 24A and ARB 

Method 432 for determination of exempt compounds as necessary.

(3) Emissions of VOC as specified in Subsection (C)(2) shall be measured as 

prescribed by either EPA Reference Method 25 or EPA Reference Method 25A, 

for determining organic emissions, and EPA Reference Method 18, for 

quantifying emissions of exempt compounds.

(4) The capture and control efficiency of air pollution control equipment, as specified 

in Subsection (C)(2), shall be determined using applicable methods in 40 CFR 

52.741.
MDAQMD Rule 1117 1117-29

Graphic Arts d2, 09/01/09 

The VOC content of materials subject to the provisions of this rule and overall capture 

and control efficiency of VOC emission control systems shall be determined by the 

following test methods specified in Sections (F)(1) through (F)(7), or alternative test 

methods approved by the APCO, USEPA, and CARB. [Derived from SJVUAPCD Rule 

4607 §6.4]

(1) Except for UV Inks, the VOC content of Inks, Adhesives, Fountain Solutions, 

Solvents and Coatings shall be determined by using EPA Method 24 or 24A as 

applicable. The VOC content of UV Inks, except for Thin Film UV Inks, shall be 

determined by using American Society of Testing and Materials (ASTM) D5403-

93 (2007) (Test Methods for Volatile Content of Radiation Curable Materials).

(2) Exempt Compound Content: Exempt compound content shall be determined by 

using ARB Method 432, “Determination of Dichloromethane and 1,1,1-

Trichlorethane in Paints and Coatings,” September 12, 1989; ARB Method 422 

“Determination of Volatile Organic Compounds in Emission from Stationary 

Sources,” January 22, 1987; or, South Coast Air Quality Management District 

(SCAQMD) Method 303-91 “Determination of Exempt Compounds,” August 1, 

1996.

(3) The content of silicon dioxide as a flattening agent in a Matte Finish Ink shall be 

determined by using the latest EPA approved revision of ASTM D717-86 

(Standard Test Methods for Analysis of Magnesium Silicate Pigment).

(4) The metal content of Metallic Inks shall be determined by SCAQMD Test 

Method 318, (Determination of Weight Percent Elemental Metal In Coatings by 

X-Ray Diffraction).

(5) Determination of emissions of VOC from spray gun cleaning systems shall be 

made using SCAQMD method "General Test Method for Determining Solvent

Losses from Spray Gun Cleaning Systems," October 3, 1989.

(6) The transfer efficiency of alternative Coating application methods shall be 

determined in accordance with the SCAQMD method “Spray Equipment Transfer 

Efficiency Test Procedure for Equipment User,” May 24, 1989.

(7) Determination of Overall Capture and Control Efficiency of VOC Emission 

Control Systems

(a) The Capture Efficiency of a VOC emission control system’s collection 

device(s) shall be determined according to EPA’s “Guidelines for 

Determining Capture Efficiency,” January 9, 1995 and 40 CFR 51, 

Appendix M, Test Methods 204-204F, as applicable.

(b) The control efficiency of a VOC emission control system’s VOC Control 

Device(s) shall be determined using EPA Test Methods 2, 2A, or 2D for 
1117-30 MDAQMD Rule 1117

Graphic Arts d2, 09/01/09 

measuring flow rates and EPA Test Methods 25, 25A, or 25B for 

measuring total gaseous organic concentrations at the inlet and outlet of 

the Control Device(s). EPA Method 18 or ARB Method 422 shall be used 

to determine the emissions of Exempt Compounds.

(c) For VOC emission control systems that consist of a single VOC emission 

collection device connected to a single VOC emission Control Device, the 

overall capture and control efficiency shall be calculated by using the 

following equation: 

[ ]/ 100 CECapture ,Control = CECapture ×CEControl

Where: 

CE

Capture,Control 

= Overall Capture and Control Efficiency, in percent 

CE

Capture 

= Capture Efficiency of the collection device, in percent, as 

determined in Section (F)(7)(a) 

CE

Control 

= Control Efficiency of the Control Device, in percent, as 

determined in Section (F)(7)(b).

(d) The following equation shall be used to determine if the minimum 

required overall capture and control efficiency of an emission control 

system is at an equivalent or greater level of VOC reduction as would be 

achieved using compliant materials, equipment, or work practices, as 

stated in Section (C)(6)(g). 

100

1

1

1

,

,

,

×





























































−













−

= − ×

c

LWC

n Max

LWn Max

LWn Max

LWc

D

VOC

D

VOC

VOC

VOC

CE

Where: 

CE = Minimum Required Overall Capture and Control Efficiency, percent 

VOC

LWc 

= VOC Limit, less water and less Exempt Compounds 

VOC

LWn,Max 

= Maximum VOC content of noncompliant Ink (or Coating or 

Adhesive) used in conjunction with a Control Device, less 

water and less Exempt Compounds 

D

n,Max 

= Density of Solvent, reducer, or Thinner contained in 

the noncompliant Ink (or Coating or Adhesive), containing 
MDAQMD Rule 1117 1117-31

Graphic Arts d2, 09/01/09 

the maximum VOC content of the multi-component Ink (or 

Coating, or Adhesive) printing Line

 Dc = Density of corresponding Solvent, reducer, or 

Thinner used in the compliant Ink (or Coating, or Adhesive) system = 880 

gm/liter. (8) When one or more test method or set of test methods are specified 

for any testing, a violation of any requirement of this rule established by any one 

of the specified test methods or set of test methods shall constitute a violation of 

the rule. [Derived from MDAQMD Rule 1165 and added in response to USEPA 

suggestion as a provision when multiple test methods are provided.]

[SIP: Submitted as amended mm/dd/yy on mm/dd/yy; Approved: 4/30/96, 61 FR 18962, 40 CFR 

52.220(c)(198)(I)(E)(2)] 
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MDAQMD Rule 1117 – Graphic Arts B-1 

Final Staff Report, 01/21/10 

Appendix “B” 

Public Notice Documents 

1. Proof of Publication – Daily Press 08/26/2009 

2. Proof of Publication – Riverside Press Enterprise 08/26/2009 
B-2 MDAQMD Rule 1117 – Graphic Arts

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MDAQMD Rule 1117 – Graphic Arts B-3 

Final Staff Report, 01/21/10 
B-4 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10 
MDAQMD Rule 1117 – Graphic Arts C-1 

Final Staff Report, 01/21/10

Appendix “C” 

Public Comments and Responses 

1. Email from Catherine F. Jacobsen, Ph. D., DABT, 3M Materials, 06/25/2009 

2. Email from USEPA, 06/25/2009 

3. Letter from Marci Kinter, SGIA, 06/26/2009 

4. Email from Harry Pontious, Victorille Daily Press, 06/29/2009 

5. Email from Catherine F. Jacobsen, Ph. D., DABT, 3M Materials, 07/09/2009 

6. Letter from Marci Kinter, SGIA, 07/20/2009 

7. Email from Catherine F. Jacobsen, Ph. D., DABT, 3M Materials, 07/28/2009 

8. CARB comment letter, 09/03/2009 
C-2 MDAQMD Rule 1117 – Graphic Arts

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MDAQMD Rule 1117 – Graphic Arts C-3 

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2 

1 

Comment Letter 1 
C-4 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10

District response to Comment Letter 1 

1. Section (C)(10) appears numbered correctly in the preliminary draft. All numbering will 

be verified in final rule version for accuracy. The requirements of (C)(11) and (C)(11)(b) 

have been modified to exclude thin film inks because there is no approved method to 

determine VOC content, and exemption (D)(5) has been added. 

2. The cross reference in section (C)(11)(b) was incorrect and has been changed to the 

proper reference of (B)(38). 
MDAQMD Rule 1117 – Graphic Arts C-5 

Final Staff Report, 01/21/10

Comment Letter 2 

1 
C-6 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10

3 

4 

2 
MDAQMD Rule 1117 – Graphic Arts C-7 

Final Staff Report, 01/21/10

District response to Comment Letter 2 

1. Section (C)(12) – Work Practices was added with the work practice requirements for 

cleaning operations as described in the CTGs. 

2. Recordkeeping requirements in section (E)(2)(a), (b) and (c) were returned to “daily.” 

3. Section (E)(2)(a)(i) was re-worded to clarify the intended meaning. 

4. Section (F)(8) was added to clarify that a violation determined by any listed test method 

shall constitute a violation of the rule. 
C-8 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10

Comment Letter 3 

1 

2 

3 
MDAQMD Rule 1117 – Graphic Arts C-9 

Final Staff Report, 01/21/10

4 
C-10 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10
MDAQMD Rule 1117 – Graphic Arts C-11 

Final Staff Report, 01/21/10

District response to Comment Letter 3 

1. Subsections (D)(1)(c), (d) and (e) have been moved to section (D)(2) which is more 

appropriate and clear for those reading the rule. The District believes that (D)(1)(a) and 

(b) should remain as placed. 

2. The District believes that the requirement of section (D)(2)(f) (digital printing operations) 

is appropriately located in the exemption section rather than the applicability section to 

remain consistent with typical rule format used in the District. 

3. The effective date of solvent cleaning VOC limits in Table 7 has been changed to July 

2011 for consistency with Bay Area Air Quality Management District rule requirement as 

requested. 

4. The District does not feel that a separate VOC limit is necessary for Screen printing wipe 

cleaning as this method of clean-up is adequately addressed in section (C)(8)(b). 
C-12 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10

Comment Letter 4 

1 
MDAQMD Rule 1117 – Graphic Arts C-13 

Final Staff Report, 01/21/10

District response to Comment Letter 4 

1. Exemption (D)(6) has been added for cleaning materials with a VOC composite vapor 

pressure less than 8 mm Hg at 20 C which is consistent with the Industrial Solvent 

Cleaning CTG. This will allow the operator to comply with all the VOC requirements of 

the rule. 
C-14 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10

Comment Letter 5 

1 
MDAQMD Rule 1117 – Graphic Arts C-15 

Final Staff Report, 01/21/10

District response to Comment Letter 5 

1. Definition (B)(101) – Thin Film UV Ink, has been added pursuant to EPA Method 24, 

11.1.5, 12.1, and 12.2. 
C-16 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10

Comment Letter 6 

1 

2 
MDAQMD Rule 1117 – Graphic Arts C-17 

Final Staff Report, 01/21/10

District response to Comment Letter 6 

1. The District concurs with the clarification requested and these sections were relocated to 

(D)(2). 

2. The District concurs that the exemption can be expanded to include all cleaning solvents 

with a vapor pressure of 8 mm Hg for consistency with the CTG for Industrial Cleaning 

Solvents. 
C-18 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10

Comment Letter 7 

1 
MDAQMD Rule 1117 – Graphic Arts C-19 

Final Staff Report, 01/21/10
C-20 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10

District response to Comment Letter 7 

1. Typographical errors in definition (B)(101) were made as noted. The markup does 

obscure the equal portion of the greater than or equal to symbol. 
MDAQMD Rule 1117 – Graphic Arts C-21 

Final Staff Report, 01/21/10

Comment Letter 8 
C-22 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10

1 
MDAQMD Rule 1117 – Graphic Arts C-23 

Final Staff Report, 01/21/10

District response to Comment Letter 8 

1. The District has no operation that is subject to the 300 g/L limit. Therefore there will be 

no change (or increase) of VOC emissions due to this language. In addition, there is no 

practical difference between “less than 300” and “300 or less.” The proposed language is 

consistent with graphic arts regulation language used statewide and determined to be 

Federal RACT. 
C-24 MDAQMD Rule 1117 – Graphic Arts

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MDAQMD Rule 1117 – Graphic Arts D-1 

Final Staff Report, 01/21/10 

Appendix “D” 

California Environmental Quality Act 

Documentation 

1. Notice of Exemption, San Bernardino County 

2. Notice of Exemption, Riverside County 
D-2 MDAQMD Rule 1117 – Graphic Arts

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MDAQMD Rule 1117 – Graphic Arts D-3 

Final Staff Report, 01/21/10
D-4 MDAQMD Rule 1117 – Graphic Arts

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MDAQMD Rule 1117 – Graphic Arts E-1 

Final Staff Report, 01/21/10

Appendix “E” 

Bibliography

The following documents were consulted in the preparation of this staff report. 

Statutes and Regulations

EPA-450/2-76-028 (1976/11) – Control of Volatile Organic Emissions from Existing Stationary 

Sources – Volume I: Control Methods for Surface Coating Operations 

EPA-450/2-77-008 (1977/05) – Control of Volatile Organic Emissions from Existing Stationary 

Sources – Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and LightDuty Trucks 

EPA-450/2-78-033 (1978/12) – Control of Volatile Organic Emissions from Existing Stationary 

Sources – Volume III: Graphic Arts-Rotogravure and Flexography 

EPA-450/3-92-013 (1992/04) – Control of VOC Emissions from Ink and Paint Manufacturing 

Processes 

EPA 453/R-06-002 2006/09 – Control Techniques Guidelines for Offset Lithographic Printing 

and Letterpress Printing 

EPA 453/R-06-003 – Control Techniques Guidelines for Flexible Packaging Printing 

EPA 453/R-07-003 – Control Techniques Guidelines for Paper, Film, and Foil Coatings 

40 CFR 63 – National Emission Standards for Hazardous Air Pollutants; Paper and other Web 

Coating; Proposed Rule (September 13, 2000) 

40 CFR 63 – National Emission Standards for Hazardous Air Pollutants; Printing, Coating, and 

Dyeing of Fabrics and other Textiles; Final Rule (May 29, 2003) 

40 CFR 63 Subpart KK – National Emissions Standards for the Printing and Publishing Industry 

40 CFR 63 Subpart QQ – Standards of Performance for the Graphic Arts Industry: Publication 

Rotogravure Printing 

40 CFR 63 Subpart RR – Standards of Performance for Pressure Sensitive Tape and Label 

Surface Coating Operations 

Local Air Districts

Regulation 8, Rule 20: Graphic Arts Printing and Coating Operations (Bay Area Air Quality 

Management District, amended November 19, 2008) 
E-2 MDAQMD Rule 1117 – Graphic Arts

Final Staff Report, 01/21/10 

Staff Report for Proposed Amendments to Regulation 8, Rule 20: Graphic Arts Printing and 

Coating Operations (Bay Area Air Quality Management District, October 2008) 

Rule 450 – Graphic Arts Operations (Sacramento Metropolitan Air Quality Management 

District, amended 10/23/2008) 

Rule 4607 – Graphic Arts and Paper, Film, Foil and Fabric Coatings (San Joaquin Valley Air 

Pollution Control District, amended 12/18/2008) 

Attachments for Agenda Item regarding Rule 4607 amendments (San Joaquin Valley Air 

Pollution Control District, 12/18/2008) 

Rule 1130 – Graphic Arts (South Coast Air Quality Management District, March 6, 1992) 

Rule 1130 – Graphic Arts (South Coast Air Quality Management District, October 8, 1999) 

Attachments for Agenda Item Regarding Rule 1130 – Graphic Arts (South Coast Air Quality 

Management District, October 8, 1999) 

SIP Citations

Rule 1130 (South Coast Air Quality Management District, for Blythe/Palo Verde Valley) 

 58 FR 50884, Limited approval/limited disapproval of 03/06/92 version 

 59 FR 17697, Finalizing Limited approval, limited disapproval of 03/06/92 version 

 60 FR 55312/55314/55354, Approval of Rule 1130 

Rule 1130.1 (South Coast Air Quality Management District, for Blythe/Palo Verde Valley) 

 61 FR 43976, Withdrawal 

Rule 1117 (Mojave Desert Air Quality Management District) 

 61 FR 18962 

Miscellaneous

EPA Method 24 – Determination of Volatile Matter Content, Water Content, Density, Volume 

Solids, and Weight Solids of Surface Coatings.