Regulatory News

Biorenewable Materials in UV and EB Inks, Coatings and Adhesives for Sustainability Programs

Bio-renewable content of inks, coatings and adhesive materials is an integral part of manufacturer sustainability programs. Sustainability material manufacturing is meant to create and maintain an “environmentally friendly” balance with human activity and nature. Concerning inks, coatings and adhesives, the terms used to describe the raw materials, intermediates and final products include eco-friendly, biorenewable and biodegradable. These manufactured materials are required to be non-toxic in air, water and soil. They are designed to have trace levels (below the environmental regulatory limits) of toxic chemicals such as heavy metals, hazardous air pollutants (HAPS), volatile organic compounds (VOC) and persistent bio-accumulative toxic (PBT) chemicals.

Biorenewable content (BRC) of inks, coatings and adhesive can be determined by the raw material compositions containing bio-based chemicals. BRC has been used successfully by printing ink manufacturers to market solvent- and water-based liquid flexographic inks and oil-based lithographic paste inks using the BRC percentage in the final product.

The National Association of Printing Ink Manufacturers (NAPIM) has a Biorenewable Content (BRC) Labeling Program for printing inks and coatings, which was launched in 2009, as part of the movement to lower the environmental impact of printing inks. It now is used by companies as part of their overall sustainability programs. NAPIM’s BRC program assesses the bio-based component amount in the ink formulation composition in accordance with a list of BRC chemicals. Upon approval, a BRC label certification is issued. The NAPIM BRC listing includes energy-curable materials based on vegetable- and plant-derived compounds.

UV/EB material suppliers are encouraged to update their buyers guide products to include a sustainability statement, bio-based content of materials, the test method used to determine the bio-based content, composability or biodegradability. Contact RadTech for further specific information.

Gregory V. Pace, Ph.D., M.S.,
Consultant, Regulatory & Product Stewardship




RadTech Partners with IMDPA

RadTech supported the International Metal Decorators Professional Association (IMDPA) event, recently held in Itasca, Illinois. The association was an exhibitor and presented during the general sessions. Rita Loof, director of Environmental Affairs, gave a presentation on RadTech’s accomplishments and the great work of the Environmental Health and Safety Committee to ensure a place at the regulatory table for UV/EB/LED technology. The IMDPA includes more than 600 individual members from more than 200 companies located around the world promoting the interests of metal decorators, can makers, designers and trade suppliers involved in metal decorating and packaging. Many RadTech member companies (Heraeus, Miltec, AMS Spectral UV, INX International and Allied Photochemical, to name a few) also are members of IMDPA. The current IMDPA president is John Clark of Heraeus. Bob Blandford of Miltec was honored at the event with an award for his volunteerism.

The general session included presentations from beverage leader Monster Energy, Henry Crown /CC Industries. The need for greater sustainability efforts in the industry was front and center. The RadTech presentation outlined some of the benefits of UV/EB/LED technology, such as reduced emissions, energy efficiency, less floor space requirements and reduced carbon footprint. Information also was shared about a pollution prevention project between the US Department of Energy, US Environmental Protection Agency and Colorado Office of Energy Conservation where UV curing inks were used for an exterior aluminum can application. The operation involved one billion cans per year and, according to regulatory documents, resulted in the elimination of 1,740 tons of Volatile Organic Compounds (VOCs).

Semiconductors in Maricopa County

According to news reports, the semiconductor industry is one of the fastest-growing industries in Arizona. Forbes magazine has named Arizona the United States’ “Semiconductor Central.” Last year, the US Environmental Protection Agency (EPA) reclassified portions of Maricopa County as a moderate nonattainment area with respect to the 2015 eight-hour ozone National Ambient Air Quality Standard. The Clean Air Act (CAA) requires jurisdictions that are classified as “moderate” or higher nonattainment to implement reasonably available control technology (RACT) for all sources subject to an EPA Control Techniques Guideline (CTG), as well as for all non-CTG major sources of volatile organic compounds (VOCs) or nitrogen oxides (NOx). The federal action prompted the Maricopa County Air Quality Department (MCAQD) to revise its Semiconductor rule (Rule 338) to review the volatile organic compound (VOC) controls in the rule and “ensure the controls continue to implement RACT.” MCAQD also is looking into emissions of NOx generated during the semiconductor manufacturing process. MCAQD believes that controls already are incorporated in most air quality permits for semiconductor manufacturing facilities in Maricopa County.

RadTech recently submitted formal written comments on Rule 338, pointing out that the rule does not include definitions for UV/EB/LED technology, which is a basic first step to the allowance of a technology by a regulatory agency. According to the staff report, the last revision to the rule occurred in 2013; thus, the most current information about UV/EB/LED technology is not reflected in the rule. In its current form, Rule 338 seems to focus on Emission Control Systems (ECS) as the only means of compliance. The approach excludes pollution prevention technologies such as UV/EB/LED and puts businesses at disadvantage as compared to systems using conventional solvents with ECS. RadTech asserted that its materials typically are well below 50 grams/liter in VOC content, which is minimal compared to the proposed limits and requested that UV/EB/LED materials be exempted from the rule requirements and for the RadTech test method for thin films (ASTM D7767-11) to be included in the rules, among other things. The rule is in the beginning stages of a multi-month regulatory process.

Recently, the semiconductor industry has been urging President Biden to include substantial funding for semiconductor manufacturing and research in the administration’s economic recovery and infrastructure plan. Industry representatives would like the administration to prioritize semiconductor investment to “reassert U.S. technological leadership.” The Maricopa Community Colleges and Intel Corporation have embarked on a program to provide students with an expedited pathway to meet the growing demand of the semiconductor manufacturing industry in the region.

EPA Revises PM Standards

In late August, the EPA announced a new review of the Ozone National Ambient Air Quality Standards (NAAQS) to “ensure the standards reflect the most current, relevant science, and protect people’s health from the harmful pollutants.” EPA established the current standards at a level of 70 parts per billion in 2015 and retained them in 2020, after concluding that there was little new information to suggest the need for revision. The EPA’s advisory body (CASAC) identified studies published more recently and also recommended that EPA conduct additional risk analyses that might support more stringent standards. EPA has determined that incorporating the ongoing reconsideration into a new review will best ensure full consideration of this new information and advice. EPA plans to issue a call for information in the Federal Register and convene a public science and policy workshop in Spring 2024 to gather input from the scientific community and the public. In Summer 2024, EPA will summarize the proceedings of the workshop to consider how the information gathered can be used to inform the next review, including specific areas of science that warrant particular focus and analytic enhancements. A plan will be released sometime in Fall 2024.

The agency also is proposing revisions of the primary (health-based) annual PM2.5 standard from its current level of 12.0 µg/m3 to within the range of 9.0 to 10.0 µg/m3. EPA also proposed not to change the current:

  • secondary (welfare-based) annual PM2.5 standard,
  • primary and secondary 24-hour PM2.5 standards, and
  • primary and secondary PM10 standards.

In addition, EPA proposed revisions to other key aspects related to the PM NAAQS, including revisions to the Air Quality Index (AQI) and monitoring requirements.

Rita LoofRita Loof, director of regional environmental affairs, RadTech International
North America