MAKRAUER'S LIVING ON THE AIR IN CINCINNATI: CALIFORNIA LAWS MORE
RESTRICTIVE
LOUIS CHERTKOW
May 08, 1995
This letter is in response to George A. Makrauer's
Perspective
column in the April 17 edition [Page 13]. I serve as
president of the California Film Extruders & Converters Association.
CFECA recently formed a Printers Committee to help its printer members
deal with regulatory restrictions in Southern California, which are
the most stringent in the nation and threatening to become worse.
It is easy for Mr. Makrauer to sit in Cincinnati
and write about how water-based ink technology has allowed him to
meet his customers' needs and comply with air pollution regulations.
That, however, is not what we in Southern California are concerned
with.
Under new regulations being proposed by the South Coast Air Quality
Management District, even companies that have been using water-based
inks for many years will be forced to significantly cut production
or install tremendously expensive add-on controls, just for the
privilege of continuing to operate in the Los Angeles Basin.
This certainly is not the ``level playing field'' Mr. Makrauer admits we are justified in seeking.
Our main objection to Mr. Makrauer's
column is that he apparently never contacted anyone here to get
the facts before he wrote his column. He states: ``Daily, we print
low density and high density polyethylenes, polyester and nylon
substrates [using water-based inks] and satisfy a growing clientele
in a total range of flexible packaging applications, including food
packaging.'' Mr. Makrauer, so do CFECA members in the Los Angeles Basin.
However, there are narrowly limited applications in which water-based
inks do not meet customer demands. We certainly understand that
the idea of technology-forcing rules is to force technology, but
if adequate technology is not developed, what should one do? Close
the doors and lay off the work force?
What is most interesting about Mr. Makrauer's column is that while the first portion takes
CFECA to task for trying to keep its members from being driven out
of Southern California by new laws that would drastically curtail
production, the rest of his column describes exactly the actions
CFECA is taking to respond to increased regulatory pressure in Southern
California.
CFECA is not opposed to air quality regulatory efforts. Its Air
Quality Policy:
Supports the efforts of regulatory bodies, industry and private
citizens to clean our air.
Urges compliance with all current air quality regulations.
Encourages practices within the framework of current air quality
regulations which minimize the emission of volatile organic compounds
and other pollutants.
Seeks to provide a public forum whereby current, compliant printing
technology is shared in order that operations comply with current
rules and regulations, reducing volatile organic compound emissions
as prescribed by law.
Encourages its members' involvement with the regulatory process,
interaction with various governing (air pollution control) districts
and the Air Resources Board so districts are made aware of the problems
facing CFECA members and with the Environmental Protection Agency
to ensure that uniform, realistic compliance standards are enforced
nationwide.
Urges its members and the districts to jointly seek approved methodology
whereby VOC levels are reduced even as levels of product quality
and productivity are maximized.
What CFECA does oppose are arbitrary and unreasonable pro-duction
restraints that are limited to film printing operations conducted
in the South Coast Air Quality Management District and that impair
the ability of its members there to complete ``on a level playing
field'' with other printers nationwide.
Mr. Makrauer finally moves onto solid
ground when he discusses the problems printers have in getting ink
manufacturers to provide suitable formulations with good performance
characteristics. His experiences reflect ours, and we agree that
industry solidarity is necessary to force the development of better
products.
As Mr. Makrauer should know, however,
it was not printers who demanded inks formulated with 1,1,1 trichloroethane.
Rather, it was air quality regulatory agencies and ink manufacturers
that pushed printers into using that technology when water-based
inks did not perform adequately.
Contrary to Mr. Makrauer's inference,
Southern California film printers are not complaining that ``it
can't be done.'' Rather, they are banding together to work with
the ink companies to ``do it here.'' Until the ink companies come
up with the breakthroughs described by Mr. Mak-rauer, however, those
firms must assure that new air quality rules (with which Mr. Makrauer
does not have to deal) do not force them out of business.
CFECA agrees that leadership by solution will help everyone. But
CFECA's Southern California printer members must survive long enough
for the solution to help them. CFECA welcomes Mr. Makrauer's assistance in bringing about a solution
to our mutual problems. However, as a fellow film printer, Mr. Makrauer should remember the ancient Chinese proverb:
``Do not use a hatchet to remove a fly from a friend's forehead.''
Chertkow is president of CFECA in Corona del Mar, Calif.