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California Print Shop Solvent Ink Rules: AQMD Compliance for Small Shops

California print shop solvent ink rules come from CARB and local districts; South Coast AQMD Rules 1130 and 1171 set ink, fountain and cleaner limits.

What to take away

  • California regulates solvent ink emissions through the California Air Resources Board and 35 local air districts; the South Coast AQMD covers Los Angeles, Orange, Riverside and San Bernardino counties.
  • The federal EPA sets no VOC content limit on lithographic or flexographic printing inks; California districts do, and they are stricter.
  • Compliance means an accurate solvent inventory, VOC content records for every ink and cleaner, and equipment that meets the district rule for your press type.
  • A district can issue a notice of violation, assess civil penalties per day per violation, and in repeat cases shut down the offending press until it is brought into compliance.
  • If you print with solvent inks in California, your first stop is your district's rules page, not the federal register.

Who has jurisdiction

Three layers of authority apply to a California shop using solvent based inks. The federal EPA sets national air quality standards under the Clean Air Act, but leaves VOC content limits on printing inks to states.

CARB, the California Air Resources Board, writes the statewide plan and the suggested control measure for solvent cleaning and printing operations. Local air districts then adopt rules at least as strict, and often stricter.

California Solvent Ink Authority

  1. EPA sets national air quality standards
  2. CARB writes statewide plan and control measure
  3. Local air district adopts stricter rules
  4. South Coast AQMD permits and enforces
  5. Bay Area and San Joaquin districts enforce

In Los Angeles County, Orange County, Riverside or San Bernardino County, the South Coast AQMD is the permitting and enforcement authority. Bay Area shops answer to the Bay Area Air Quality Management District, whose printing rule is Regulation 8, Rule 20, Graphic Arts Printing and Coating Operations.

San Joaquin Valley shops answer to the San Joaquin Valley Air Pollution Control District. Rule numbers differ, but the shape is the same.

South Coast AQMD maintains its own rulebook. For inks, coatings and fountain solutions the rule is Rule 1130, Graphic Arts, and for press washes and cleaners it is Rule 1171, Solvent Cleaning Operations. Read the rule that names your printing process before you buy ink.

What the limits cover

California districts regulate three things on a solvent press: the VOC content of the ink as applied, the VOC content of cleaning solvents, and the total emissions from the facility. A shop that stays under the district's small source thresholds may avoid a permit, but it still has to keep records that prove the threshold is not exceeded.

In the South Coast AQMD those thresholds are in Rule 219, the permit exemption rule. Graphic arts printing, coating and laminating equipment is exempt from a written permit if, among other conditions, its uncontrolled VOC emissions, including clean-up, are three pounds per day or less or 66 pounds per calendar month or less. For conventional inks, coatings and adhesives, fountain solutions (excluding water) and the associated VOC-containing solvents including clean-up, the usage ceiling is two gallons per day or less or 44 gallons per calendar month or less. Plastisol materials and non-solvent UV/EB/LED materials have a higher ceiling of six gallons per day or 132 gallons per calendar month. A small solvent shop that uses more than two gallons of ink, fountain solution and wash on a busy day is outside the usage exemption, which is why the usage log matters.

VOC Content by Material

Water based ink

Typical VOC level
near zero
Regulated by district
yes
Proof source
SDS

Solvent flexographic ink

Typical VOC level
several lb/gal
Regulated by district
yes
Proof source
SDS

Wash solvent

Typical VOC level
higher
Regulated by district
yes
Proof source
SDS

VOC content is measured in pounds per gallon of applied material, or grams per liter. A water based ink may sit near zero. A typical solvent based flexographic ink can run several pounds per gallon, and a wash solvent can run higher.

Those figures are illustrative. The legal ceiling is set by the district. In the South Coast AQMD, Rule 1130's Table of Standards I limits graphic arts materials, in grams of VOC per liter less water and less exempt compounds, to 300 g/L for offset lithographic, letterpress and gravure inks, 300 g/L for flexographic ink on non-porous substrates, 225 g/L for flexographic ink on porous substrates, 300 g/L for coatings and 150 g/L for adhesives.

Small offset presses get a specific allowance for fountain solution. The rule's fountain-solution limits do not apply to sheet-fed offset presses with a sheet size no larger than 11 by 17 inches, or to any offset press with a total solution reservoir of one gallon or less, provided the fountain solution contains no more than 80 grams of VOC per liter as applied, or 100 grams per liter with a refrigerated chiller.

Compare those limits with the number on the manufacturer's safety data sheet for the product you bought.

The OSHA Hazard Communication Standard requires you to keep those safety data sheets on hand and to train employees who handle the chemicals, which is the same paperwork a district inspector will ask to see. The federal rule is at OSHA Hazard Communication.

Records a compliant shop keeps

  • A current solvent inventory listing every ink, wash, fountain solution and cleaner by product name and manufacturer.
  • Safety data sheets for each item, accessible to employees on every shift.
  • VOC content documentation for each product, taken from the SDS or a manufacturer certificate.
  • Monthly or per-batch usage records showing how much of each solvent was consumed.
  • Equipment maintenance logs for any add-on control device or enclosed cleaning unit required by your district rule.

In the South Coast AQMD, Rule 1171 sets the retention period for the cleaning side: anyone who performs solvent cleaning keeps records for five years for all solvent cleaning materials used, including the product name of each cleaner, the dates and quantities used, and its VOC content as used. On the ink side, Rule 1130's recordkeeping section states that records shall be maintained pursuant to Rule 109, the district's general recordkeeping rule for VOC emissions, so the same binder serves both rules.

What happens if you skip it

A district inspector can arrive on a complaint or routine sweep. If the shop cannot produce VOC records or uses a solvent over the district limit, the inspector issues a notice of violation.

South Coast AQMD penalties are assessed per day and per violation, and the district publishes its enforcement actions. Repeat violations can escalate to a shutdown order on the specific press, stopping production on that equipment until the shop demonstrates compliance.

A shutdown order on a press costs more than a fine. Jobs scheduled on that machine must be rerouted, reprinted or refunded, and a shop that loses a week to a compliance hold also loses the customer relationship tied to that turnaround.

The paperwork that prevents this is boring and cheap next to the alternative.

Example: a four-color solvent press in Orange County

A small shop runs a four-color sheetfed press with a solvent wash. After reading the district rule, the owner switches to a lower VOC wash, updates the SDS binder, and logs wash usage by the gallon each week.

At the next inspection, the records match the purchase invoices, and the inspector closes the visit without a violation. With no records, the same shop could not show its emissions stayed under the threshold.

Where this fits with the rest of the shop

Solvent rules do not stand alone. A shop also must manage machine guarding under OSHA general requirements for machines. Those rules apply to cutting and creasing equipment, and one inspection visit often covers both.

If the shop already keeps maintenance logs for its cutters, it can add solvent records to the same binder. The guide to cutting and creasing machine maintenance schedule shows how those logs are structured.

For a broader view of how federal and state environmental rules overlap for a small shop, the plain language walkthrough at OSHA and EPA compliance for small US print shops covers the parts that are not California specific.

Common questions

Does the EPA limit VOC content in printing inks?
No. The EPA sets national ambient air quality standards and regulates some categories of printing under the Clean Air Act, but VOC content limits on inks are set by states and local districts. In California, CARB and the districts do the limiting.
Which district covers my shop?
It depends on the county. South Coast AQMD covers Los Angeles, Orange, Riverside and San Bernardino. Bay Area shops answer to the Bay Area Air Quality Management District. Check your district's rules page for the rule number that names your printing process.
Do water based inks avoid all of this?
No. Water based inks usually have much lower VOC content, but cleaning solvents and fountain solutions still count, and the district still expects records. The rule follows the material, not the marketing label.
What is the first document an inspector asks for?
The solvent inventory and the safety data sheets for the products on it. If those two documents are current, the rest of the inspection is a matter of matching usage records to purchases.

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