SOCMA: Society of Chemical Manufacturers and Affiliates

Research Triangle Park, NC -- The Synthetic Organic Chemical Manufacturers Association (SOCMA) testified today at a public hearing of the Environmental Protection Agency (EPA), telling the Agency that its recent rule on national emissions standards for hazardous air pollutants (HAPs) was overly burdensome for small and specialty batch chemical manufacturing facilities.

In its testimony, SOCMA states its primary objections to the rule. First, the proposal would exceed its intended scope by not limiting the rule’s requirements to the 15 urban HAPs it identifies. Instead of focusing the rule on the reduction of the HAPs that pose the greatest risk to public health, the rule engrosses every HAP from every process unit of a facility that emits any amount of urban HAPs, even if the urban HAPs are limited to only a few process units. Additionally, the rule inappropriately requires compliance in accordance with the rule for potentially tens of different substances, even though the technology used to control the 15 listed urban HAPs may not be appropriate for other emitted substances.

Second, even if the rule is refocused to cover only the 15 listed HAPs, the levels of expected control are really maximum achievable control technology (MACT) standards, not generally available control technology (GACT). MACT standards are intended for major source emissions, and are inappropriate and damaging to this sector of the chemicals industry. Small companies with small sites and few staff will be disproportionately affected by seemingly minor changes in the rule’s compliance requirements, both in terms of cost and work-hours lost.

“We don’t think this is the right rule to reduce emissions of urban HAPs,” said SOCMA President Joe Acker. “It is overly broad and the compliance burden is damaging to smaller businesses, especially for a rule aimed at small sources of emissions. This proposal can be made more workable for the small sources that characterize the specialty batch chemical industry and still meet the goals Congress has set for area source standards.”

SOCMA believes EPA should establish a de minimis threshold so that sources are only subject to the standard if it processes some minimum quantity of the 15 listed HAPs. This approach has been used by EPA before and substantially moderated the financial impact of the Benzene National Emission Standard for Hazardous Air Pollutants (NESHAP). SOCMA suggested a threshold of 10,000 lbs/year of any urban HAP would greatly reduce the compliance burden of the rule for small businesses.

The full testimony is available online at SOCMA’s website.

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SOCMA is the leading trade association, serving the specialty-batch and custom chemical industry since 1921. SOCMA’s nearly 300 members employ more than 100,000 workers across the country and produce 50,000 products valued at $60 billion annually. For more information please visit www.socma.com.

ChemStewards® is SOCMA’s flagship environmental, health, safety and security (EHS&S) continuous performance improvement program.  ChemStewards was created from industry’s commitment to reducing the environmental footprint left by member’s facilities.  Industry created ChemStewards to meet the unique needs of the batch, custom, and specialty chemical industry. As a mandatory requirement for SOCMA members engaged in the manufacturing or handling of synthetic and organic chemicals, ChemStewards is helping participants reach for superior EHS&S performance.  To learn more visit www.chemstewards.com.