The Santa Barbara County Air Pollution Control District held a public workshop earlier this month to discuss a possible revision of the established Rule 321, which addresses solvent use for degreasing and cleaning within industrial settings. 

“The revision primarily addresses cleaning processes from which we know water-based solvents are much lower-polluting,” said Tom Murphy, manager of the Technology and Environmental Assessment Division at the APCD. 

The scoping meeting was held to hear public comment, which Murphy says will be taken into account in proposing an eventual draft rule to the APCD board of directors. 

One issue that stood out was the possible restriction of isopropyl alcohol to clean equipment, or as Tom Banigan, board vice chairman of the Santa Barbara Technology and Industry Association, called it, “criminalizing the use of rubbing alcohol.” 

Banigan, who also serves on the APCD Community Advisory Council, says Rule 321 doesn’t need more restriction within its existing compliant businesses, but rather needs to include certain businesses that are exempt from it.

“They aren’t saying you can only use 55 gallons per year, or dispose of it in this way,” he said. “They are saying categorically you can’t use (IPA).”

Murphy said that while the IPA issue is a big subset of the rule, no decisions have been made as to how its use will be affected.

“At the workshop, it was clear to me that the SBTIA is concerned about future regulation of IPA,” Murphy said. “They are concerned that they have limits on their use of IPA while hospitals are exempt. But there has not been a final decision.”

The APCD works on achieving air quality standards, primarily focusing on ozone, or smog. Ozone is formed when oxide and nitrogen react with organic compounds in the presence of sunlight.

Santa Barbara County, Murphy said, has been out of compliance with state standards on ozone level for many years.

“The end result,” he said, “is that the solvents being used by businesses will be less reactive, meaning they will have less reactive compound.”

Rule 321 already controls solvent use, including limitations on IPA; however, it leaves certain industries excused from compliance, including many medical facilities.

“The use of IPA specifically in hospitals is just needed for sterilization,” Murphy said. “We at the district generally regulate emitting devices and processes, but we don’t see hospitals to fall into those categories,” said Murphy. .”

To Banigan, who works as vice president of regulatory compliance at Nusil Silcone Technology, avoiding regulation of hospitals and other medical facilities is an issue of political charge.

“It’s the third rail,” he said. “(APCD is saying) we’re regulating you guys because we can while giving the public the impression that business is the main source (of solvent use). It’s my opinion that these other (exempt) sources are the greater sources, and they aren’t even mentioned.”

In response to the idea that exempt solvent users are responsible for the most actual use, Murphy said that the APCD is still investigating emission sources. “This rule was not intended to limit IPA. It was intended to limit other reactive compounds that are used in other solvents,” he said.

Another platform brought focus to commercial oil rigs, which often use quickly vaporizing solvents such as IPA for cleaning purposes to reduce water runoff into the ocean. It was suggested that using a more water-based solvent could result in breaching water discharge limits. 

Murphy said he asked that the concern be put in writing and that it will be considered.

The input from the public, he said, was exactly what the APCD was expecting and hoping for during the workshop. “We are going to take the input we got and do our best to satisfy our mission and understand other people’s positions,” he said.

“We have heard Tom (Banigan’s) comments and will definitely be working on a draft.”

Once the public draft is released, the APCD plans to either conduct another public workshop or a joint workshop-advisory council meeting.

Noozhawk intern Mollie Helmuth can be reached at