Regulations for Industrial Cleaning Solvents across New England

Environmental Consulting

August 24, 2023

Share it with the world!

Industrial cleaning solvents include a variety of products that are used to remove containments such as adhesives, inks, paint, dirt, oil, and grease.

Each state is free to implement their own air pollution control regulations that are consistent with the Clean Air Act and the EPA’s regulations. Although all six New England states have similar compliance standards for industrial cleaning solvents, the applicability to become subject to compliance may vary across the states. This rule applies to facilities that use industrial cleaning solvents above either a volume threshold or air emission threshold, unless otherwise exempt. The regulations for each state can be found in the following links:

A summary of the applicability for each state is shown in the table below (if the use does not qualify for an exemption):

Table 1.

State	Regulation	Applicability	Effective Date
MA	310 CMR 7.18(31)	≥ 15 lbs/day VOC or ≥ 3 tons VOC per rolling 12-month period[1]	March 9, 2018 (work practice) March 9, 2020 (work practice and emission limits)
NH	Env-A 1221.05	≥ 3 tons VOC per rolling 12-month period[1]	January 1, 2026
RI	250-RICR-120-05-36	≥ 2.7 tons VOC per rolling 12-month period[1]	June 13, 2022
CT	RCSA 22a-174-20(ii)	Purchases for use ≥855 gallons of cleaning solvents per 12-month rolling period	January 1, 2011
VT	5-253.17	Purchases for use ≥855 gallons of cleaning solvents per 12-month rolling period	September 15, 2018
ME	Dep 06. Division 096-166	≥3 tons VOC per 12-month rolling period[1]	Within 120 days of August 22, 2018

_{[1] Note – before control.}

Common exemptions to these regulations include cleaning operations conducted as part of the following:

Quality control and laboratory testing
Research and development programs
Medical device manufacturing
Pharmaceutical manufacturing

For other exemptions that will be state-specific, please see your state’s exemption list within the regulations cited above.

Once applicability to an industrial cleaning solvent regulation is established, all facilities or operators across New England are subject to compliance standards, work practice, and recordkeeping requirements. Any facility subject to the regulation shall limit VOC emissions by complying with one or more of the following:

Use industrial cleaning solvents that have a VOC content no greater than 50 g/L (0.42 lb/gal) or;
Use industrial cleaning solvents that have a VOC composite partial pressure equal to or less than 8 mmHg at 20°C (68°F) or;
Achieve an overall control efficiency of at least 85% by weight using add-on air pollution capture and control equipment.

Cleaners that do not meet the requirements can be used in amounts less than 55 gallons per year. In addition to these compliance requirements, any facility shall minimize VOC emissions of industrial cleaning solvents in accordance with certain work practices and prepare and maintain records that are to be kept on-site for five years. Example work practice standards include:

Cleaning solvents shall be stored in a nonabsorbent, non-leaking container. Such a container shall be kept always closed except when the container is being filled, emptied, or is otherwise actively in use
Cleaning solvent shall be conveyed from one location to another in a closed container or pipe
Maintaining cleaning equipment and solvent containers, including repairing solvent leaks
Properly disposing of used solvents and absorbent applicators

Example recordkeeping requirements include to following:

Name and description of each industrial cleaning solvent
VOC content and/or vapor pressure of each industrial cleaning solvent as supplied or applied.
Material Safety Data sheet for each industrial cleaning solvent

For state-specific work practice and record-keeping requirements, please see the requirements within the state-specific regulations.

If a facility cannot comply with these rules, a case-by-case Reasonably Available Control Technology (RACT) order will be required. This could include the purchase of emission reduction credits.

If you would like to discuss these industrial cleaning solvent regulations and how they may impact your facility, please email Lynne Santos in Trinity’s Boston office.

Trinity has helped me train our staff and navigate the complexities of hazardous waste permitting and compliance with ease and efficiency. They have always delivered high-quality work on time and are very responsive and thorough whenever I’ve had any questions or concerns. I highly recommend Trinity to anyone who needs an advocate for agency interaction and reliable assistance with their hazardous waste management and permitting needs.

Director of Environment & Sustainability /Hazardous Waste Company