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Forest Products Industry Newsletter – September 2025

Home / Forest Products Industry Newsletter – September 2025

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Emerging Regulatory and Technical Topics

  • The 2024 revisions to the Major MACT to Area provisions in 40 CFR Part 63 were eliminated using the Congressional Review Act. The provisions added in 2024 would have limited the types of facilities that would be allowed to recategorize from a major source of hazardous air pollutants to an area source.
  • U.S. EPA has proposed to rescind the 2009 endangerment finding that is the basis for its greenhouse gas (GHG) regulations. It plans to repeal the GHG vehicle standards, repeal or significantly revise the Part 60 standards for electric generating units, reconsider the oil and gas GHG standards, and rescind most of the 40 CFR Part 98 GHG monitoring rule. The days of pulp and paper mills submitting GHG reports in eGGRT may be coming to a close.
  • On January 1, 2026, facilities with refrigeration appliances, including air conditioners, refrigerators, chillers, and freezers, with a full charge of 15 pounds or more of refrigerant may be subject to new leak repair requirements under 40 CFR Part 84, Subpart C (Management of Regulated Substances). Limitations on types of refrigerants that may be used in new installations, existing system rebuild restrictions, and new labeling requirements will be rolling out in the coming years under 40 CFR Part 84, Subpart B (Restrictions on the Use of Hydrofluorocarbons). Additionally, fire suppression equipment containing refrigerants will be subject to new regulations. Please let us know if you would like to review the upcoming Part 84 requirements or discuss ways ALL4 can support your refrigerant management program.
  • The Spring 2025 regulatory agenda included a brief update on the Clean Water Act (CWA) Hazardous Substances Facility Response Plan (FRP) rule, confirming that U.S. EPA plans to propose an extension for the compliance date and make “administrative changes.”  The proposed delay and changes are tied to Section 3 of the January 20, 2025 Executive Order 14154 Unleashing American Energy, which “requires immediate review of agency actions to identify those that may impose an undue burden on identification, development, or use of domestic energy resources.” The timeline given estimated a Notice of Proposed Rulemaking in July 2025 (which has come and gone) and final action by end of 2025, so stay tuned for more! In the meantime, check out our latest blog.
  • U.S. EPA has signaled it is ready to move forward in defending itself in the litigation against the Lead and Copper Rule Improvements (LCRI) brought by the American Water Works Association (AWWA). More details will be coming in the next several months as the case unfolds, but U.S. EPA plans to provide “practical implementation flexibilities and regulatory clarity,” including regarding the lead service line replacement.
  • U.S. EPA recently made a court filing that indicated they plan to issue a proposal to roll back the recently tightened PM2.5 annual NAAQS this fall and finalize it early next year. Could 2026 be a good year to permit that capital project you’ve been considering?

Industry News

  • September 12, 2025 | EPA Releases Proposal to End the Burdensome, Costly Greenhouse Gas Reporting Program, Saving up to $2.4 Billion Read more

  • September 10, 2025 | Georgia-Pacific Announces $800 Million Capital Investment in Alabama River Cellulose Mil Read more

  • September 9, 2025 | Georgia-Pacific to acquire Anchor Packaging Read more

  • September 8, 2025 | Sofidel Successfully Starts-Up Third Tissue Machine at Circleville Mill in Ohio Read more

  • September 8, 2025 | Sonoco to sell ThermoSafe for up to $725M Read more

  • September 4, 2025 | IP, Novolex, Smurfit Westrock among companies with August layoff announcements Read more

  • August 21, 2025 | International Paper to Sell Global Cellulose Fibers Business for $1.5 Billion; Close Savannah Containerboard Mill Read more

  • August 20, 2025 | Domtar to Indefinitely Idle Its Newsprint Mill in Grenada, Mississippi Read more

  • August 13, 2025 | Chillicothe Paper Mill Now Officially Closed…But Offers to Buy Being Considered Read more

  • August 12, 2025 | Paper Industry Announces 2024 U.S. Paper Recycling Rates Read more

  • August 6, 2025 | Suzano to Reduce Production of Market Pulp by 3.5% Over the Next 12 Months Read more

  • July 30, 2025 | American Forest & Paper Association Applauds Initial US-EU Trade Deal Read more

  • July 23, 2025 | Hood Container Announces $118.9 Million Modernization Project at St. Francisville Paper Mill Read more

  • July 8, 2025 | Cascades to Permanently Close Its Corrugated Medium Plant in Niagara Falls, New York Read more

  • July 2, 2025 | Pixelle, IP, Hood, Pratt disclosed layoff updates in June Read more

  • July 1, 2025 | Packaging Corporation of America Announces Agreement to Purchase Greif Containerboard Business Read more

  • June 18, 2025 | Danone, DuPont, Green Bay Packaging, Sonoco detail facility expansions Read more

Safety Corner

The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) announced on June 26, 2025, in a National News Release, the renewal of its Amputations in Manufacturing Industries National Emphasis Program (NEP) aimed at mitigating the risk of amputations in manufacturing environments. This initiative continues OSHA’s long-standing effort to reduce serious workplace injuries associated with mechanical equipment, particularly those that involve improper machine guarding and uncontrolled hazardous energy.

The renewed NEP focuses on proactively identifying and addressing conditions in manufacturing facilities that present a heightened risk for amputations. OSHA will carry out programmed inspections of establishments in selected manufacturing sectors to evaluate compliance with relevant safety standards. The renewed NEP on Amputations in Manufacturing applies to:

1. Manufacturing Establishments 

Specifically, those classified under certain updated NAICS (North American Industry Classification System) codes identified by OSHA as high-risk for amputation hazards. These codes cover a range of manufacturing sectors such as:

  • Automobile manufacturing

  • Metal fabrication

  • Food processing

  • Wood product manufacturing

  • Plastics and rubber products

  • Ship building and repairing

  • And others where mechanical equipment is commonly used.

2. Facilities Using Hazardous Machinery 

Any manufacturing facility that is subject to Machine Guarding (29 CFR §1910.212) requirements that operates machinery with exposed moving parts, cutting tools, presses, or conveyors that could cause amputation injuries during operation, servicing, and maintenance.

3. Facilities Using Lockout/Tagout (LOTO) 

Any manufacturing workplaces with equipment that requires energy control procedures under 29 CFR §1910.147, Control of Hazardous Energy (Lockout/Tagout).

The inspections will assess procedures during the operation, servicing, and maintenance of equipment, particularly where workers may be exposed to moving machine parts or stored energy. The renewed NEP is set to take effect immediately upon the expiration of the current program on June 27, 2025. The updated directive will remain active for five years from the effective date, unless extended or modified.

Recent Relevant Webinars

Upcoming Events

Conferences

Training

  • WASTE 101 provides a foundational knowledge of various waste-related regulatory programs, with an emphasis on the Resource Conservation and Recovery Act (RCRA). The program covers the history of waste-related regulations and an overview of regulatory programs that impact industrial operations in various sectors, including forest products. Our Fall 2025 program begins September 11.
  • Air Quality 101 (AQ101) Training provides a comprehensive and foundational knowledge of the Clean Air Act (CAA) and its various regulatory programs. The program covers the history of the CAA, NAAQS, and an overview of regulatory programs that impact industrial operations (e.g., New Source Performance Standards, Prevention of Significant Deterioration, air quality modeling, etc.). The program also covers more focused topics that are encountered day to day by facility environmental personnel such as the basics of emissions testing and continuous emissions monitoring. Our Fall 2025 program begins October 14.
  • Do you have budget left on a general assistance project with ALL4? You can use it to register for training – reach out to your project manager for information and a client discount code.
  • ALL4 can develop customized EHS training programs for your staff – reach out to Lindsey Kroos for information!

Click here for a list of ALL4 conferences, webinars, trainings, and other events.

Upcoming Regulatory Deadlines

Do you have electronic reports due soon? Be sure to check the U.S. EPA Compliance and Emissions Data Reporting Interface (CEDRI) and the Electronic Reporting Tool (ERT) websites for updates. The ERT was last updated on September 2, 2025.

  • The Tennessee Multi-Sector General Permit (TMSP) for Industrial Stormwater renewed on July 1, 2025. Facilities with coverage under the previous permit who wish to retain coverage under the renewed permit are required to update their Stormwater Pollution Prevention Plan (SWPPP) and submit a Notice of Intent (NOI) by September 30, 2025. See our latest blog for more information.

  • The Minnesota Industrial Stormwater MSGP was renewed effective June 1, 2025. The e-Services application for the 2025 permit is not yet available.

  • Mississippi’s Industrial Stormwater General Permit (ISGP) expires on November 30, 2025. MDEQ Is working to reissue the permit and will provide a Letter of Instruction to active coverage holders outlining the process for obtaining recoverage under the ISGP. Permittees should not submit renewal forms or requests until instructed to do so. If the ISGP is not reissued prior to the expiration date, it will be administratively continued until reissued.

  • The Boiler MACT (40 CFR Part 63, Subpart DDDDD) limits that were revised in 2022 apply starting October 6, 2025.

  • Quarterly compliance reports are due October 30.

  • Check your permits for other upcoming site-specific due dates!

Tips & Tricks

We have passed the halfway point of 2025.  In a few months we will be in the rush of annual reporting.  Here are some things to think about now to help make 2025 reporting go smoothly:

  • Did you know that global warming potentials (GWP) were updated in 40 CFR Part 98, Table A-1 effective January 1, 2025?  Now is a good time to update the factors in your greenhouse gas emissions tracking documents.

  • Do you have new equipment that will require emissions reporting for the first time in 2026?  Be sure you have throughput and emissions tracking for this equipment setup now to avoid a crunch at reporting time.

  • Do you have new/updated site-specific data that will be used for calendar year 2025 reporting (e.g., stack testing or fuel sampling results)?  Now is a good time to make sure the emissions factors in your tracking documents are the latest factors.

  • Remember last year when you made a “wish list” of items that you wanted to “clean-up” or improve in your emissions inventory?  Now is a good time to work on that list.

Solutions Spotlight

ALL4 has a team of continuous monitoring system (CMS) experts who can work with your team and assist with all aspects of CMS data management related to 40 CFR Part 60, Part 63 and Part 75 emissions and parameter monitoring requirements. Do you have a requirement to continuously monitor certain pollutant(s) or parameter(s) for the purpose of demonstrating compliance with an emissions limit, operating parameter limit, or emissions trading program, in your Title V Permit, a consent decree, or a state regulation?  Ultimately, if you are required to operate a CMS, it is important to provide the systems, processes, procedures and people to allow your certifying or responsible official to confidently sign and submit the compliance report. In signing and submitting a CMS compliance report, the responsible official is attesting to a certain level of “reasonable inquiry” having been completed as part of report development.  

So, what are some best practices to “reasonably inquire” into the truth, accuracy, and completeness of the information contained in a CMS report? You need to have systems and processes in place that provide reasonable assurance that the data is good. 

1. Proactive Report Development – Completing preliminary checks or data reviews on a weekly or monthly basis improves reasonable inquiry. By reviewing data in manageable intervals, by the time you reach the end of the quarter or semi-annual period, you will have a draft report that’s been (mostly) verified. Additionally, it is easier to capture and record information “in the moment”, when it is fresh, as opposed to going back to emails or conversations from several months ago to determine what occurred.

2. Data Review Tools – Asking someone to pick out an outlier data point from hundreds of lines of CMS data would be nearly impossible. But, if you were to visualize the dataset, you would have no problem identifying the outlier. A simple plot can often reveal outliers in datasets that would otherwise be reported as-is. If you have CMS, you are monitoring continuously, likely 24 hours a day, 7 days a week, and in doing so, equipment breaks or drifts and doesn’t behave as expected. Having a set of visual tools to review data that you must report can reveal data that may be affected by malfunctioning equipment or even by untagged maintenance events that would otherwise go unnoticed and reported.

3. Checklists – Checklists are excellent tools for ensuring repetitive tasks are completed in a timely fashion. When certifying the reports, a responsible official must verify the accuracy, completeness, and correctness of the report and having a checklist makes it easier to verify these aspects.  It also provides an opportunity for the official to ask questions, seek clarifications, and provide feedback on the reporting process, truly fulfilling the “reasonable inquiry” to which the responsible official attests.

4. Dashboards – While checklists focus on completeness, dashboards are powerful tools that provide insights at a quick glance. A dashboard with performance indicators gives the responsible official an overview of the compliance status and allows for comparison between the current reporting period’s data and prior reporting periods to see how the facility performed. 

There are many other practices that can be used to improve your overall CMS program. Those mentioned here are just a snapshot of what can be done to improve the program at your facility! Please reach out to Matt Carideo if you’d like to have a discussion about how our CMS team can help you improve your data management or reporting processes. 

In this time where there is a steady stream of regulatory and deregulatory news, stay tuned for ALL4 updates in our weekly newsletter, 4 The Record. Please reach out if you have any questions or suggestions for our next quarterly Forest Products newsletter.

Thanks,

Amy Marshall, Air Quality Practice Director

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