"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Forsythe also notes that the terminology of the California rules is littered with outdated terms, such as “cold cleaning,” which in this case means “below the boiling point.”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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