BACT Update Marks Milestone for UV Lithographic Printing as RadTech Pursues Inclusion of EB

A newly proposed Best Available Control Technology (BACT) listing recognizes UV lithographic printing. The proposed addition of Non-Heatset, Sheet-fed UV Lithographic Printing to the South Coast Air Quality Management District’s (SCAQMD) BACT Guidelines reflects the growing recognition of UV curing technology as a commercially available, low-emission printing process that has been “achieved in practice.” Once adopted, guidelines would acknowledge UV lithographic printing as a BACT option for applicable new or modified printing operations within the SCAQMD jurisdiction (see Slide 23, https://tinyurl.com/4x2u9mmb). For UV lithographic process specifics, see pages 17-20 at https://tinyurl.com/5fj2s5ab.

During the May 2026 meeting of the BACT Scientific Review Committee, RadTech sought clarification regarding the types of curing mechanisms. The proposed listing specifies a sheet-fed lithographic printing press, a 170 kW-rated ultraviolet (UV) dryer and a 175 kW-rated infrared dryer. The RadTech representative pointed out that energy-curable materials can be cured with Electron Beam (EB) and Light Emitting Diode (LED) technologies. It is important for our industry to be certain that EB or LED processes would be equivalent for purposes of the proposed BACT listing. In conversations, staff indicated that the listings are intended to be technology-neutral and thus, whether the curing happens via exposure to UV light, EB or LED, the process would be considered equivalent to the proposed listing for the Lithographic Printing, Non-Heatset, Sheet-fed category. The district was urged to provide clarity on this matter.

SCAQMD staff plan to present their recommendations for inclusion of UV Lithographic printing to the Governing Board later this year. Once adopted by the Board, the listing will become official.

Wood Coatings Rule Revisions Strengthened Through Industry Engagement

The outstanding advocacy and engagement of RadTech members led to significant improvements in the proposed revisions to South Coast Air Quality Management District Rule 1136 (Wood Coatings). While the final proposal did not incorporate all of the Association’s recommendations, it represents a significant improvement over the original draft.

Ideally, the district would have exempted UV/EB/LED materials outright or provided a mass-based exemption (one pound per day) rather than a one-gallon-per-day usage exemption. This would have allowed users of energy-curable materials to increase their production without a stringent cap. Several SCAQMD board members supported RadTech’s position; however, staff cited a hypothetical UV coating scenario that described a UV coating allegedly containing a VOC content of 541 grams per liter and including toxic constituents. Despite various public records requests, staff never produced any evidence of such a coating. 

The rule came back to the Board in May, but – in an extremely unusual move – staff postponed the rule. Letters from RadTech members were pouring in, several members were making public comment, and three environmental groups had taken positions to support RadTech’s requests. At that point, staff likely knew there were not enough votes to get the rule over the finish line. 

The rule went back to the Board, for a third time, in June. While waiting to testify, the Rule Manager informed RadTech that the agency had agreed to revise the rule resolution language to incorporate some of the provisions proposed by the Association. This revision effectively committed the agency to consider some of the options proposed by RadTech, such as exemptions based on actual emissions and exemptions for low-VOC materials. This represents a meaningful step forward, particularly given that the initial staff position had rejected nearly all elements of the proposal.

Basically, staff committed to conducting a technical assessment and bringing back the rule by January 1, 2029, in order to consider the Association’s proposal for a one pound per day exemption. Additionally, staff attempted to address concerns raised regarding the definition of “reactive diluent.” Although RadTech’s recommended language was not adopted, substantial clarifying text was added to the staff report, which is beneficial in that it provides additional visibility for UV/EB/LED technologies.

For additional details, view the webcast at https://tinyurl.com/5f9z6t9r.  

SCAQMD Proposes Changes to Marine Coatings Rule

The South Coast Air Quality Management District is proposing amendments to Rule 1106 – Marine Coatings. RadTech previously obtained an exemption for UV/EB/LED coatings as the rule does not apply to Marine Coatings or Pleasure Craft Coatings that have a VOC content of 50 g/L or less. The rule is scheduled for final adoption in October of this year, with the proposed amended rule available at https://tinyurl.com/4c4ndb33. The Association will monitor the rulemaking process. 

Rita Loof
director of regional environmental affairs, RadTech International North America
rita@radtech.org