PM2.5 State Implementation Plan (SIP)
Historically, primary emissions reduction strategies have been directed at industrial emissions. But with PM2.5, industry currently contributes about eleven percent of the pollution. This leaves reductions in mobile and area sources as the critical focus areas for reducing the emissions that form PM2.5.
As part of its pollution reduction planning for the PM2.5 State Implementation Plan (SIP), DAQ proposed and Air Quality Board adopted rules to reduce emissions from area sources. Because the chemical reactions forming the majority of fine particulate pollution are complex and the emissions come from a wide variety of sources, finding solutions to the problem of high PM2.5 levels in Utah’s airsheds has proven complicated. It will take a concerted effort on the part of the public and small business to find ways to collectively reduce these emissions. A combination of small, individual reductions will be needed to achieve the large-scale reductions necessary to address Utah’s PM2.5 challenge.
Rulemaking to Reduce VOC Emissions in Utah
Concern about the air quality impacts of VOCs in consumer products is not new. The Environmental Protection Agency (EPA) promulgated a rule in 1998 to reduce VOCs in consumer products nationwide after the agency determined that VOCs emissions from the use of certain products could cause or contribute to high ozone levels.For some ozone nonattainment areas (areas that don’t meet EPA standards), the rules did not go far enough to improve air quality. Eastern states that are members of the Ozone Transport Commission (OTC) and the California Air Resources Board (CARB) updated their state rules to achieve VOC reductions in consumer products beyond those required by the federal rule. These groups have worked with manufacturers to reconfigure their products to meet lower VOC requirements. States wishing to reduce VOC emissions from consumer products are now considering updated requirements contained in the OTC 2014 Model Rule for Consumer Products, which is part of a regional effort to reduce ozone levels in the Northeast.DAQ is following suit, proposing rules to reduce VOCs in the manufacturing and sales of consumer products. The rules establish VOC limits, which will require the reformulation of some of products that fall into the four categories:
- Personal care products
- Household products
- Auto aftermarket products
- Consumer use coatings
Lower VOCs in these products would provide a reduction of approximately 4,000 tons per year for the counties in nonattainment for PM2.5. When preparing the rule, the DAQ consulted and collaborated with national stakeholders who would be affected. These stakeholders included:
- The Consumer Product Specialty Association (CSPA), the trade association for companies that engage in the manufacture, formulation, distribution and sale of familiar consumer products. Their membership accounts for 75 percent of the products manufactured that would be regulated by this rule,
- The Personal Care Products Council (PCPC), the leading national trade association for the cosmetic and personal care products industry
- The American Coatings Association, Inc. (ACA), representing manufacturers of paints and coatings.
Generally speaking, the CSPA, PCPC, and ACA support the OTC model rule because it offers regulatory uniformity that allows manufacturers to produce formulations that can be distributed nationally. The rules would not ban products. Products currently on the shelves and in warehouses could still be sold. Products subject to the rules will be required to clearly display the product manufacture date no later than a year before the rules are in effect for that particular product to be sold. Once the rules go into effect, manufacturers and suppliers would be required to provide only low-VOC product formulations for sale and distribution in nonattainment counties.
More information can be found through the Utah Department of Environmental Quality Factsheet about Consumer Products and PM2.5.