WASHINGTON -- A proposed rule regulating the volume of ozone that can be released in the Northeast US could force considerable changes to the way cleaning chemistries are used, industry experts say.

The Ozone Transport Commission, an organization of 12 northeastern states and the District of Columbia, is rewriting a decades-old California rule for air pollution that crosses state boundaries. The proposed rule, say industry experts, is practically identical to the California rule, which sets a rigorous limit for ozone emissions.

The OTC was created under the Clean Air Act and is responsible for advising the US EPA on transport issues and for developing and implementing regional solutions to the ground-level ozone problem in the Northeast and Mid-Atlantic regions. Above certain quantities (measured in parts per billion), ground-level ozone is considered harmful to human health. Among the hazards include increased incidences of asthma and heart- and lung-related problems.

The OTC says the proposed rule limits the degree to which plants can engage in interstate trading of emissions. By restricting interstate trading, each state will be required to reduce its share of transported pollution, as required by a federal court decision.

Critics claim the proposed rule uses arcane language and sets emission standards that are not supported by solid science.

The proposed rule caps volatile organic compound emissions at 25 grams/liter. EPA estimates the new rule would save $120 billion to $290 billion in health-related costs per year, while costing the industry $2.8 billion to implement. The proposed rule would go into effect January 2014.

The rule could have serious repercussions for electronics manufacturing companies. Flux used in soldering printed circuit boards contain organic compounds, and cannot be effectively cleaned without organic chemistry. The area covered by the proposed rule is home to almost all the nation's largest defense contractors, including Raytheon, Lockheed-Martin, Textron, Northrup Grumman, L-3 and General Dynamics. (Zestron counted some 475 companies that would be affected by the rule.) These companies all make extensive use of solvent- and aqueous-based cleaners. Today, the average VOC content in aqueous-based cleaning agents for removing common soils is in the range of 100-200 grams/liter, depending on the flux technology being employed.

"We're not sure where the [25 g/l] number came from, but the fact remains, at that time companies were cleaning RMA fluxes and water-soluble pastes and could get the job done," Kyzen vice president Tom Forsythe told CIRCUITS ASSEMBLY. "Cleaning no-clean lead-free [solder] isn’t going to happen at 25 g/l."

Forsythe says the EPA appears to have good intentions and is trying to encourage stakeholder input. But he points out that the proposed rule could be damaging to the affected business environment. "The EPA seems to be thinking that they aren’t exactly breaking new ground. But they took the California rules verbatim. And the California rules haven’t helped the area retain high volume electronics production over the past 20 years."

Zestron USA technical marketing manager Sal Sparacino is even more direct: "EPA is modeling off the toughest rules in the country. And the cleaning industry has left California."

The potential effects of the proposed rule extend from cleaning to coatings and any other product containing VOCs. But they fail to take into account advances in cleaning technology that might obviate air pollution.

"Perhaps 15 years ago there wasn’t effective technology for scrubbing – maybe," says Forsythe. "There is no provision for being able to capture emissions. The rule measures emissions by counting the number of drums you haul in and the number of drums you haul out. When the rules were written, vapor degreasers were the common equipment. But in aqueous cleaning, plenty of stuff goes down the drain, either to water works or to closed-loop systems."

Forsythe also notes that the terminology of the California rules is littered with outdated terms, such as “cold cleaning,” which in this case means “below the boiling point.” "No one knows what the terms mean."

The committee will next meet Sept. 7-8, near BWI Airport in Linthicum Heights, MD. Stakeholders are urged to attend and comment on the proposed rule.

The proposed rule does not appear to be a fait accompli, say industry watchers. "EPA seems to be receptive to some data and we have lots of it," Forsythe said. "They seemed quite upset they had gotten very little input."

A new revised draft from OTC is due out next week. (The current draft is here.) According to some persons contacted by CIRCUITS ASSEMBLY, the revised draft could reflect a more moderate limit of perhaps 150 g/l.

For more on the proposed rule and its estimated effects, click here.

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