Proposed Amendments to Air Toxics Standards for Leather Finishing
Operations: Fact Sheet

ACTION

•	On February 28, 2018, the U.S. Environmental Protection Agency (EPA) proposed to
amend the 2002 Leather Finishing Operations National Emission Standards for
Hazardous Air Pollutants (NESHAP).

•	EPA is proposing these minor amendments to enhance the effectiveness of the rule by
improving compliance with existing requirements and by increasing the efficiency of
data submissions.

•	Hazardous air pollutants, also known as air toxics, are known to cause serious health
and environmental effects. The Clean Air Act (CAA) directs EPA to regulate emissions of
187 listed air toxics.

•	This action includes emission units covered under the NESHAP, including all coating
operations; coatings conveyors and transfer equipment; and storage, mixing and waste
containers.

•	On February 27, 2002, the EPA issued the final Leather Finishing Operations NESHAP and
followed with some minor amendments on February 28, 2005. The rule applies to
facilities that produce a variety of products such as automotive leather, furniture
leather, clothing and apparel, and footwear.

•	Following a residual risk and technology review conducted under the Clean Air Act
(CAA), the EPA is proposing to:

o Revise the startup, shutdown and malfunction language to be consistent with the

most recent court decisions,
o Require facilities to submit electronic copies of compliance reports, including
performance tests.

•	EPA will accept comment on the proposed amendments for 45 days after publication in
the Federal Register.

RESIDUAL RISK ASSESSMENT

•	The CAA requires the EPA to assess the risk remaining after application of the final air
toxics emission standards. This is known as a residual risk assessment.

•	Based on the completed risk assessment, available health information and associated
uncertainties, the EPA determined risks from the leather finishing sector to be
acceptable and provide an ample margin of safety to protect public health.

•	The maximum individual cancer risk for inhalation for the source category is estimated
to be less than 1-in-l million.

1


-------
TECHNOLOGY REVIEW

•	The CAA requires the EPA to assess, review and revise air toxics standards as necessary,
taking into account developments in practices, processes and control technologies since
the standards were first issued.

•	The technology assessment for leather finishing did not identify any technological
developments to reduce emissions of hazardous air pollutants.

BACKGROUND

•	The CAA requires the EPA to regulate hazardous air pollutants from categories of
industrial facilities in two phases.

•	The first phase is "technology-based," where the EPA develops standards for controlling
the emissions of air toxics from sources in an industry group (or "source category").
These NESHAP establish maximum achievable control technology (MACT) standards
which are based on emissions levels that are already being achieved by the best-
controlled and lower-emitting sources in an industry group.

•	Within 8 years of setting MACT standards, the CAA directs the EPA to assess the
remaining health risks from each source category to determine whether the MACT
standards protect public health with an ample margin of safety and protect against
adverse environmental effects. This second phase is a "risk-based" approach called
residual risk. Here, the EPA must determine whether more health-protective standards
are necessary.

•	Also, every 8 years after setting MACT standards, the CAA requires that the EPA review
and revise the standards, if necessary, to account for improvements in air pollution
controls and/or prevention.

FOR MORE INFORMATION

•	To download a copy of the proposed rule notice, go to EPA's website at
https://www.epa.gov/stationary-sources-air-pollution/leather-finishing-operations-
national-emission-standards-hazardous. Today's action notice and other background
information are also available either electronically at http://www.regulations.gov. EPA's
electronic public docket and comment system, or in hardcopy at the EPA Docket
Center's Public Reading Room.

o The Public Reading Room is located at EPA Headquarters library, room number
3334 in the EPA WJC West Building, 1301 Constitution Avenue, NW, Washington,
DC. Hours of operation are 8:30 a.m. to 4:30 p.m. eastern standard time,

Monday through Friday, excluding Federal holidays,
o Visitors are required to show photographic identification, pass through a metal
detector and sign the EPA visitor log. All visitor materials will be processed
through an X-ray machine as well. Visitors will be provided a badge that must be
visible at all times.

2


-------
o Materials for this proposed action can be accessed using Docket ID No. EPA-HQ-
2003-0194.

• For further technical information about the rule contact William Schrock, at the EPA's
Office of Air Quality Planning and Standards, at (919) 541-5032 or schrock.bill@epa.gov.

3


-------