EPA proposes “residual risk review” for US boatbuilders

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The U.S. Environmental Protection Agency recently proposed Residual Risk amendments to the 2001 National Emission Standards for Hazardous Air Pollutants (NESHAP) for Boat Manufacturing. On April 18, the EPA proposed “minor amendments” to enhance the effectiveness of existing rules by improving compliance and implementation, according to the EPA document. EPA has determined that current MACT rules provide “ample margins of environmental safety.”

The Boat Manufacturing NESHAP covers the production of fiberglass and aluminum boat hulls or decks, mold building to manufacture hulls or decks, and boat assembly from premanufactured parts. Regulated processes within the standards include fiberglass resin and gel coat operations, carpet and fabric adhesive operations, and painting operations.

The National Marine Manufacturers Association said in today’s Currents e-newsletter that it had dedicated “significant resources” to provide EPA with critical data on risk assessment and the technology review.

The EPA has determined that risks from boat manufacturing to be acceptable. “The current rules provide an ample margin of safety to protect public health,” said the EPA document. “While the proposed rules would not result in further emission reductions, this action would improve monitoring, compliance and implementation at no cost to industry.”

The Clean Air Act also requires EPA to assess, review and revise air toxics standards, as necessary, considering developments in practices, processes and control technologies. “The technology reviews of the standards for Boat Manufacturing facilities did not identify any developments that would further reduce hazardous air pollutant emissions beyond the original NESHAPs which are current practices at boat plants,” said the Currents story.

“This proposal has yet to be published in the Federal Register, so it is fresh off the press, but on first review, EPA has asked questions in the proposal that NMMA will respond to with formal written comments,” said the Currents story.

The association said it will also provide boatbuilders with guidance so they can “submit comments addressing the industry position regarding the EPA questions and supporting the EPA risk and technology review determinations.” 


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