ATTACHMENT B

SOCIOECONOMIC IMPACT ASSESSMENT

PROPOSED AMENDED RULE 67.16 -GRAPHIC ARTS OPERATIONS

July 2011

Prepared by

San Diego County Air Pollution Control District

10124 Old Grove Road

San Diego, CA 92131
SIA for SDAPCD Rule 67.16 B - 2

SOCIOECONOMIC IMPACT ASSESSMENT

PROPOSED AMENDED RULE 67.16 –

GRAPHIC ARTS OPERATIONS

TABLE OF CONTENTS

PAGE

EXECUTIVE SUMMARY 3

I. INTRODUCTION 4

II. NECESSITY OF AMENDMENTS TO RULE 67.16 4

III. SUMMARY OF PROPOSED AMENDMENTS 5

IV. TYPE OF INDUSTRIES AFFECTED BY AMENDED RULE 67.16 5

V. ESTIMATED EMISSIONS IN FROM GRAPHIC ARTS OPERATIONS IN SAN DIEGO COUNTY 6

VI. EMISSION REDUCTION POTENTIAL AND COST-EFFECTIVENESS OF THE PROPOSED AMENDMENTS 7

VII. RANGE OF PROBABLE COSTS TO INDUSTRY INCLUDING SMALL BUSINESS 9

VIII. CONCLUSION 10

REFERENCES
SIA for SDAPCD Rule 67.16 B - 3

EXECUTIVE SUMMARY

This report represents the results of a socioeconomic impact assessment (SIA) of the San Diego 

County Air Pollution Control District’s (District) proposed amended Rule 67.16 - Graphic Arts 

Operations. The proposed rule will comply with the latest federal Control Techniques

Guidelines (CTGs) for lithographic, letterpress and flexible packaging printing industries. 

Proposed amended Rule 67.16 contains volatile organic compound (VOC) emission limits for 

inks, adhesives, coatings, fountain solutions and cleaning materials used in conventional (analog) 

printing processes. These limits are at least as stringent as those established by the federal 

CTGs. The rule provides new exemptions for cleaning of UV lamps and reflectors, electronic 

beam processors and stripping of cured inks, coatings and adhesives. The amended rule also 

includes new and revised definitions and updated test methods for determining compliance.

In addition, the rule contains an exemption for digital printing operations (comparatively new 

technology) provided that specified records are kept for large scale digital printing operations,

as defined. This will allow the District to estimate the magnitude of VOC emissions from digital 

printing and provide an answer as to whether it is necessary to control them.

It is not anticipated that the proposed amendments will have a significant socioeconomic impact 

on affected industries. SIA demonstrates that proposed emission limits in the rule are feasible 

and that complying materials are available in the market place. Many printing facilities in San 

Diego County are already using fountain solutions, cleaning and adhesive materials that comply 

with the proposed lower VOC content limits. The estimated cost-effectiveness of proposed 

amendments to Rule 67.16 is well within the District threshold for the rules regulating VOC 

emissions that reflect Reasonably Available Control Technology.

 
SIA for SDAPCD Rule 67.16 B - 4

I. INTRODUCTION

California law requires air pollution control districts (excluding those with populations of less 

than 500,000 people) to perform a socioeconomic impact assessment (SIA) when adopting, 

amending, or repealing rules and regulations that will significantly affect air quality and emission 

limitations.

The Health and Safety (H&S) Code Section 40728.5, subdivision (b) specifies the following 

elements to be included in the socioeconomic impact assessment:

1. The type of industries or business, including small business, affected by the rule or 

regulation.

2. The impact of the rule or regulation on employment and the economy of the region affected 

by the adoption of the rule or regulation.

3. The range of probable costs, including costs to industry or business, including small business, 

of the rule or regulation.

4. The availability and cost-effectiveness of alternatives of the rule or regulation.

5. The emission reduction potential of the rule or regulation.

6. The necessity of adopting, amending, or repealing the rule or regulation in order to attain 

state and federal ambient air quality standards.

The H&S Code Section 40728.5, subdivision (e) states that “upon the approval by a majority 

vote of the district board, a county district is not required to include the analysis specified in 

paragraphs (2) and (4) above in any assessment of economic impacts of any rule or regulation 

that only has a requirement that is substantially similar to, or is required by, state, or federal 

statute, regulation or applicable formal guidance document”.

The proposed amendments to Rule 67.16 comply with the emission standards of two federal

guidance documents: Control Technique Guidelines (CTGs) for Offset Lithographic Printing 

and Letterpress Printing (1) and for Flexible Package Printing (2). Therefore, the following report 

does not include the analysis required by paragraphs (2) and (4) 

II. NECESSITY OF AMENDING RULE 67.16

San Diego County Air Basin does not attain the National and State Ambient Air Quality 

Standards for ozone. Both federal and state laws require the District to implement rules that 

control emissions of ozone precursors -- volatile organic compounds (VOC) and oxides of 

nitrogen. Current Rule 67.16 – Graphic Arts Operations regulates VOC emissions from printing 

and related operations. In addition, in 2006 the Environmental Protection Agency (EPA) issued 

two Control Techniques Guidelines (CTGs) for printing industry: the CTG for Lithographic and 
SIA for SDAPCD Rule 67.16 B - 5

Letterpress Printing1and the CTG for Flexible Package Printing2that established more stringent 

emission limits for cleaning solvents and fountain solutions than those in existing Rule 67.16. 

The proposed amended Rule 67.16 follows the federal guidelines. In addition, the rule requires 

updating because it was last amended in 1996. 

III. SUMMARY OF PROPOSED AMENDMENTS TO RULE 67.16

The amended rule will:

Reduce the VOC content limit for non-refrigerated fountain solutions to 5% VOC by 

volume, and to 8.5% for refrigerated fountain solutions;

For cleaning materials, establish the new, lower emissions limits: VOC content less than 

100 g/liter, or VOC vapor pressure 5 mm Hg at 20oC or less;

Establish a new VOC content limit for adhesives at 150 g/liter, less water and less exempt 

compounds;

Include new or revised definitions including definitions for digital printing operations;

Exempt digital printing operations from Rule 67.16, provided that specified records are 

maintained for large operations with a print capacity as defined in the rule; 

Provide new exemptions for stripping of cured inks, coatings and adhesives, cleaning of 

UV lamps and reflectors and electronic beam processors; and,

Update the test methods for determining VOC content of graphic arts and cleaning 

materials and VOC vapor pressure of cleaning materials and the overall control efficiency 

of emission control systems.

IV. TYPE OF INDUSTRIES AFFECTED BY AMENDED RULE 67.16

Proposed amended Rule 67.16 will affect owners and operators of companies conducting graphic 

arts operations, such as lithographic, letterpress and flexographic printing (NAICS Code 32311). 

Presently, there are 16 companies with permits to operate in San Diego County subject to 

Rule 67.16. The majority of them (13) conduct lithographic printing. 

Lithography is a printing technique where the image and non-image areas are on the same plane 

on a printing plate. The image area of the plate is hydrophobic (repels water) and the non-image 

area is hydrophilic (attracts water). A water system continually supplies a fountain solution 

wetting the non-image area. Often lithographic processes are offset, i.e., the ink is transferred 

from the plate to a rubber blanket and then to a paper substrate. Lithography is used mostly in 

newspaper and book printing. Three companies in the county conduct flexographic printing 

where the image carrier is made of elastomeric material and the image is raised above the non-
SIA for SDAPCD Rule 67.16 B - 6

image area. The substrates in flexographic printing include plastic films, foil, paper boards and 

envelopes, textiles, etc. One company uses letterpress printing, the oldest printing technology 

where raised inked metal type is applied directly onto the substrate, in this case onto paper plates.

The newest printing technique that became quite popular in the last decade is digital printing. 

Unlike traditional printing it does not use real metal or rubber plates to create images. The 

images are generated electronically in a computer that uses digital files such as PDFs (portable 

document formats) and sends the images to a printer (inkjet or laser). 

V. ESTIMATED VOC EMISSIONS FROM GRAPHIC ARTS OPERATIONS

IN SAN DIEGO COUNTY 

VOC emissions from traditional analog printing processes occur as a result of using VOC-based 

inks, cleaning solvents, and fountain solutions. The magnitude of VOC emissions from these 

processes is very well established, including emission factors for cleaning materials and inks, 

i.e., their VOC content, and retention factors for VOC- and water-based inks applied to porous 

surfaces such as paper. 

Table 1 on the following page contains a list of facilities subject to proposed amended Rule 

67.16 and their VOC emissions. This list does not include operations, each emitting less than an 

average 15 lbs VOC per day of operation, calculated on monthly basis, that are exempt from the 

rule emission limits. These operations are also exempt from District permit requirements by 

current Rule 11 (Exemptions from Rule 10 Permit Requirements). In addition, Table 1 does not 

include facilities conducting digital printing operations because their VOC emissions are not yet 

quantified. It is assumed in this report that such emissions are below the permit requirement 

threshold (average of 15 lbs per day calculated on monthly basis from all operations at a 

stationary source) as specified in Rule 11.

Table 1 also contains the number of employees at each facility obtained from the data published 

by the California Employment Development Department3and from the information provided by 

the affected companies.

Table 1 shows that the total VOC emissions from sources subject to Rule 67.16 are about 

64 tons/year, with the majority of emissions (66%) coming from the use of cleaning materials.

The printing inks are not a main contributor to the total emissions from graphic arts operations 

due to a significant retention of volatile organic compounds (up to 95% of ink oils) that occurs 

during non-heat lithographic printing on porous substrates such as paper. Therefore, the 

proposed rule amendments almost entirely address control measures to reduce VOC emissions 

from the use of cleaning materials. 
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Table 1. Sources and VOC Emissions Subject to Amended Rule 67.16.

VOC Emissions tpy

Company Number of 

Employees3 Operation Fountain Solutions

Cleaning

Materials

Total, 

including 

inks

1 20-49

Lithographic, single sheet fed

heat set w/ cat. oxidizer; also 

non- heat set, digital

0.01 0.02 2.6

2 App.195 Letterpress, single sheet fed

Paper Plates printing 0 0.01 0.1

3 50-99 Lithographic, single sheet fed 1.34 8.87 10.5

4 50-99 Lithographic web fed 0.06 6.23 7.9

5 20-49

Lithographic, web fed & 

flexographic, single sheet & 

web fed

0.06 0.45 2.0

6 50-99 Lithographic, single sheet fed 0.01 0.65 1.0

7 50-99 Lithographic, single sheet fed 0.01 6.62 7.6

8 App.500 Lithographic, web fed 0.13 2.24 2.8

9 50-99 Lithographic , web fed 0.19 2.57 3.4

10 100-249 Lithographic, web fed 0.21 1.35 1.9

11 100-249 Lithographic, web fed 0.71 5.96 7.0

12 50-99 Flexographic & lithographic,

web fed 0.1 0.71 2.2

13 50-99 Flexographic 0.06 1.29 3.1

14 20-49 Lithographic, web fed 0.01 0.96 1.0

15 100 Lithographic, web fed 0.01 2.75 4.3

16 120 Flexographic, envelopes 0 1.6 6.7

Total 2.9 42.3 64.1

VI. EMISSION REDUCTION POTENTIAL AND COST-EFFECTIVENESS OF THE 

PROPOSED AMENDMENTS

1. Cleaning materials.

As shown in Table 1, the estimated emissions from the use of cleaning materials in graphic arts 

subject to the proposed amendments are approximately 42.3 tons per year. These VOCcontaining materials are used for manual and automatic cleaning of printing presses and their 

parts. The proposed emission limits for cleaning materials in the amended Rule 67.16 are 

100 g VOC per liter or a VOC vapor pressure of 5 mm Hg at 20oC. In the current rule, the VOC 

content limit for cleaning materials is 200 g/l or the VOC vapor pressure 45 mm Hg at 20oC. If 

all facilities choose to use a cleaning material complying with the VOC content limit, the 

estimated emission reduction will be approximately 50%, i.e. proportional to the reduction in the 

VOC content, or approximately 21 tons per year.
SIA for SDAPCD Rule 67.16 B - 8

However, if a facility chooses to comply with the rule by using a cleaning material with a VOC 

vapor pressure not exceeding 5 mm Hg a 20oC, estimating emission reductions will present some

problems. The majority of cleaning materials are mixtures of several organic compounds;

therefore it is very difficult to determine the correlation between the vapor pressure of such 

mixtures and their evaporation rates. In addition, some graphic arts companies in San Diego 

County are already using cleaning materials with a complying VOC composite vapor pressure, 

some are using solvents with a vapor pressure as low as 0.5 mm Hg at 20oC. 

Therefore, to be more realistic and assuming that only half of the estimated emission reductions 

will actually take place, this rule provision is conservatively estimated to reduce VOC emissions 

by 10.5 tons per year.

The current rule requires fountain solutions to contain less than 15vol. % of VOCs. The 

proposed amendments will reduce the VOC concentration to 5vol. % if a fountain solution is not 

refrigerated, or 8.5vol. % if it is refrigerated to at least 60oF. As shown in Table 1, the total 

emissions from fountain solutions are about 3 tons/year. The majority of fountain solutions 

presently used by the graphic arts industry in San Diego County do not contain high volatility 

alcohols such as isopropyl alcohol, very widely used in the past. Instead, they use low volatility 

alcohols, or their esters. In addition, most fountain solutions are normally sold as concentrates 

and are diluted with water, sometimes in proportions as high as 1:10 or 1: 20. Many companies 

are already using fountain solutions that are in compliance with the VOC limits in the proposed 

rule. Therefore, it is not expected that reducing VOC concentration limits for fountain solutions 

will result in measurable emission reductions. 

2. Adhesive materials.

The proposed VOC content limit for adhesives is reduced from 300 g/l to 150 g/l (less water and 

less exempt compounds). While this limit is significantly lower than the previous one, there will 

be no significant emission reductions because adhesives are not used in the majority of graphic 

arts operations in the county. The companies that use adhesives are already in compliance with 

the proposed limit.

3. Cost-effectiveness of the proposed rule.

The emission limits of cleaning products will only affect the companies that are presently using 

solvents with a VOC content close to 200 g/liter as provided by existing Rule 67.16. These 

companies will have to replace them with complying products, having either a VOC content less 

than 100 g/liter, or with a low composite vapor pressure as required by the proposed rule.

It should be noted that many air districts in California, including such large districts as Bay Area 

and South Coast Air Quality Management Districts, have very similar or even more stringent 

rules for graphic arts industry. Therefore low VOC content adhesives, cleaning materials and 

fountain solutions are widely available in the market place at the prices not much different from 

the cleaning products that were previously sold.
SIA for SDAPCD Rule 67.16 B - 9

The District’s information obtained from cleaning products manufacturers and local distributors 

of graphic arts materials shows that there is no significant difference in the cost of cleaning 

materials complying with a proposed VOC composite vapor pressure limit and the ones presently 

used. On the other hand, if a facility chooses to use cleaning products complying with the VOC 

content limit of the amended rule, they will have to buy products that are slightly more expensive 

than the non-complying ones. For example, according to the information from local distributors, 

conventional high VOC content solvents are sold for about $10 per gallon, while low VOC 

content products cost between $10 and $17 per gallon, with the average cost of $13.5 per gallon, 

which is an increase of approximately 35%. Assuming that the solvents complying with the 

proposed rule limits have the same cleaning effectiveness as previously used products, the cost 

effectiveness of the proposed rule will be about $2,265/ton, or $1.1/lb of VOC emissions 

reduced4. This value is significantly lower than the District cost-effectiveness threshold of $6/lb 

of VOC reduced for prohibitory rules reflecting RACT.

In reality, the cost of compliance with proposed amendments to Rule 67.16 may be somewhat 

higher for some facilities because the amount of low VOC content products used to achieve the 

same quality of cleaning maybe higher than the amount of conventional cleaning materials. On 

the other hand, some printing companies in San Diego County may not need to replace cleaning 

materials because they are using products that comply with the VOC vapor pressure limits in the 

proposed rule. Therefore they would not incur any additional expenses.

VII. RANGE OF PROBABLE COSTS TO INDUSTRY INCLUDING SMALL 

BUSINESS

As mentioned above, the majority of facilities subject to the rule will not incur any additional 

costs as a result of amendments of Rule 67.16, because they either use low vapor pressure 

cleaning materials or have add-on emission control equipment. Those facilities that will have to 

replace their high VOC content solvents will find a variety of complying materials at reasonable 

prices. 

In the previous socioeconomic impact assessments for several proposed rules, the District has 

defined a small business as an entity that meets all of the conditions below.

1. The business is independently owned and operated. (California Government Code, Section 

11342.610, Small Business definition)

2. The business is not dominant in its field of operation. (Same)

3. The business has gross annual receipts not more than $500,000. (SCAQMD, Rule 102)

4. The business employs ten persons or less. (SCAQMD Rule 102)

5. The business has total annual VOC emissions less than 10 tons. (H&S Code, Section 42323, 

Small Stationary Source).
SIA for SDAPCD Rule 67.16 B - 10

According to the District’s permit files and information obtained from the California 

Employment Development Department3, none of the businesses subject to the proposed amended 

rule meet all conditions mentioned above. As shown in Table 1, all of them employ more than 

ten people. In addition, some companies are not independently operated but are part of bigger 

corporations. Therefore proposed Rule 67.16 amendments will not affect small businesses.

III. CONCLUSION

Proposed amended Rule 67.16 will not negatively impact affected industry, including small 

business entities. It will provide air quality benefits by reducing emissions of volatile organic 

compounds that are precursors of ground level ozone, a major component of photochemical 

smog.
SIA for SDAPCD Rule 67.16 B - 11

References

1. Control Techniques Guidelines for Offset Lithographic Printing, EPA 453/R-06002, 

September 2006.

2. Control Techniques Guidelines for Flexible Packaging Printing, EPA-453/R-06003, 

September 2006.

3. California Employment Development Department, Labor Market Information, 

http://www.labormarketinfo.edd.ca.gov. 

4. Bay Area Air Quality Management District. Staff Report for the BAAQMD Regulation 8, 

Rule 20 – Graphic Arts Printing and Coating Operations, October 2008.