EPA ditches spray requirement for two key metal fabrication sectors

The Environmental Protection Agency’s (EPA) final rule on air contaminant limits for two metal manufacturing sectors involved in surface coating applications was notable for provisions the agency did not include.

The good news for those in the metal furniture and large-appliance manufacturing segments is that the agency, in the end, stepped back from some mandates it had been thinking of requiring. One mandated the use of high-efficiency application equipment for spray coatings. In its proposed rule, the EPA made a critical assumption that the four high-efficiency spray equipment technologies rulemaking (which covered high-volume, low-pressure; electrostatic application; airless; and air-assisted, airless spray equipment) would achieve at least 65 percent transfer efficiency when used in painting metal furniture and large appliances.

Those two fabricating sectors are under separate National Emission Standards for Hazardous Air Pollutants (NESHAP). The EPA is supposed to conduct a residual risk and technology review (RTR) every eight years after a NESHAP goes into effect. The idea is to see whether air contaminant limits in the NESHAP are still appropriate. But the agency said in the final RTR rule that new information led it to conclude that the transfer efficiency of the proposed high-efficiency spray application technologies may be less than 65 percent, as it is dependent on parameters such as part size, part shape, distance of the spray gun from the parts, atomizing air pressure, fluid pressure, painting technique, type of coating, viscosity of the coating, and other factors.

The EPA, after getting pushback from the American Coatings Association, admitted it did not have enough good data to make a new requirement stick. Besides that, the agency said a number of states already require high-efficiency spraying, and that companies already lean toward using it, required or not, because it reduces coatings consumption and lowers waste disposal costs.

As a result of this joint RTR, the EPA did not tighten air emission limits for either metal furniture or large-appliance manufacturers. However, the EPA did finalize a new requirement that companies in the two categories must submit electronic copies of certain required performance test reports through the agency’s Central Data Exchange website.

EPA also is requiring manufacturers to conduct control device performance testing in certain situations.

Manufacturing Bills Introduced

Two different manufacturing bills have been launched recently, one targeting manufacturing technology and the other manufacturing worker training. Both have bipartisan support, which is a critical requirement for passage in this Congress.

The first is the Smart Manufacturing Leadership Act of 2019 (S. 715 / H.R. 1633) introduced by Sens. Jeanne Shaheen, D-N.H., and Lamar Alexander, R-Tenn., and Reps. Peter Welch, D-Vt., and Tom Reed, R-N.Y. It focuses on expanding the use of energy efficiency technologies on factory floors. The bill was introduced in the last Congress but did not move forward.

The second bill is called the Retain Innovation and Manufacturing Excellence Act of 2019 (S. 856). This legislation would allow the National Institute of Standards and Technology’s Manufacturing Extension Partnership program to establish a pilot program where businesses could retain retiring employees long enough to train replacement workers. Sens. Jim Inhofe, R-Okla., and Sheldon Whitehouse, D-R.I., introduced that bill in December 2018, too late for it to get any consideration in the last Congress.