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Forest Products Industry Newsletter – June 2025

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Emerging Regulatory and Technical Topics

  • Congress has voted to use the Congressional Review Act (CRA) to nullify the 2024 revisions to the Major MACT to Area (MM2A) rule. The rule modified the 40 CFR Part 63 General Provisions to specify the procedures for sources that wish to reclassify from major to area source status for hazardous air pollutant (HAP) emissions. The 2024 changes were summarized in an ALL4 blog and included a list of standards with which sources reclassifying to area source status would still have to comply. Litigation on the 2020 rule that eliminated the “Once In, Always In” policy is likely to restart.

  • Although Environmental Justice (EJ) is not currently a priority at the federal level, be sure to check if your state or local agency has an EJ policy or rule before you start your next project. You may need to add some time to the application development or review process to address EJ-related issues. Joe Sabato tracks EJ activity across states, including which states have their own EJ mapping tools.

  • Our last newsletter mentioned that Congressional Repeals had been proposed for the Lead and Copper Rule Improvements (LCRI). Due to grassroots efforts and public pressure, the repeal missed a critical deadline. Litigation is still pending around the requirement for replacement of lead service lines (LSLs) by 2037.

  • Since our last newsletter, we have heard more specifically from U.S. EPA on implementation delays for the Clean Water Act (CWA) Hazardous Substances Facility Response Plan (FRP) Rule. According to an American Public Power Association article published in early June, U.S. EPA plans to issue a notice, possibly as an interim final rule (IFR), that would extend the compliance dates of the rule by up to five years (up to June 1, 2032 to submit a FRP from the current June 1, 2027). IFRs are effective upon publication in the Federal Register unless adverse comments are received. U.S. EPA also plans to issue an advance notice of proposed rulemaking seeking input on changes to be made to the final rule, including: changes to definitions, increasing the threshold quantity to the 10,000x reportable quantity (RQ) from the 2022 proposed rule rather than the 1,000x reportable quantity (RQ) from the final rule, modifying substantial harm requirements, removing mention of environmental justice or climate change, and modifying exemptions to include anything covered by 40 CFR Part 112. We will continue to monitor for updates on proposals from U.S. EPA regarding this rule and will keep our readers up to date.

Industry News

  • June 11, 2025 | AF&PA Vice President Paul Noe testifies before the House Committee on Energy and Commerce, Subcommittee on Environment in their hearing titled “Short-Circuiting Progress: How the Clean Air Act Impacts Building Necessary Infrastructure and Onshoring American Innovation.” Read more

  • June 6, 2025 | International Paper to Explore Building a New State-of-the-Art Sustainable Packaging Facility in Salt Lake City, Utah Read more

  • May 30, 2025 | Georgia-Pacific, Greif, Silgan detail layoff plans in May Read more

  • May 29, 2025 | Industry Publishes Updated Voluntary Standard for Recycling Cardboard Read more

  • May 16, 2025 | AF&PA Details U.S. Paper Production and Capacity Trends Read more

  • May 9, 2025 | International Paper Announces Facility Consolidation Plans in Southern Texas Read more

  • May 5, 2025 | International Paper Breaks Ground for Its New Box Plant in Waterloo, Iowa Read more

  • May 2, 2025 | Greif to Close Paperboard Mill in Los Angeles, California Read more

  • May 1, 2025 | Kimberly-Clark to build $800 million facility in Ohio, create 491 jobs Read more

  • April 30, 2025 | Smurfit Westrock shutdowns to affect 650 employees at 4 facilities Read more

  • April 25, 2025 | Georgia-Pacific Opens More Opportunities for Paper Cup Recycling Read more

  • April 18, 2025 | Pixelle Specialty Solutions to Delay the Closure of Chillicothe Paper Mill in Ohio Read more

  • April 15, 2025 | CO280 Signs 3.69 Million Tonne Agreement with Microsoft to Scale-up Carbon Dioxide Removal in the US Pulp and Paper Industry Read more

  • April 4, 2025 | Pixelle Announces Agreement to Sell Stevens Point Paper Mill to Ahlstrom Read more

  • April 2, 2025 | Jansen Combustion & Boiler Technologies has Acquired Washington-based Lundberg Read more

  • April 1, 2025 | Novolex and Pactiv Evergreen Inc. Complete Combination, Creating a Leading Manufacturer in Food, Beverage and Specialty Packaging Read more

  • April 1, 2025 | Graphic Packaging to Close its Middletown, Ohio, Coated Recycled Paperboard Mill Read more

  • March 17, 2025 | UFP Packaging Increases Corrugated Capabilities with New Facility in Jeffersonville, Indiana Read more

  • March 12, 2025 | AF&PA Applauds Overdue U.S. EPA Regulatory Reconsiderations Read more

Safety Corner

On April 8, 2025, the Occupational Safety and Health Administration (OSHA) released directive CPL 02-01-067, updating its site-specific targeting (SST) program. The SST is the agency’s primary initiative for targeting non-construction workplaces with 20 or more employees for inspections based on reported injury and illness data. It aims to identify and inspect establishments with higher-than-average rates of incidents—or those that have failed to report required data altogether.

With the newest version of the SST program now in effect, OSHA is using injury and illness data from Calendar Years 2021 through 2023 to determine which workplaces should be inspected. OSHA will focus inspections on establishments with:

  • Days Away, Restricted, or Transferred (DART) rates that are trending upward from 2021–2023

  • Higher DART rates in CY2023

  • Failure to submit Form 300A data for 2023

  • Unusually low DART rates, to verify data integrity

To create its inspection list, OSHA utilizes NAICS codes, applying one DART rate threshold for manufacturing establishments (NAICS codes 31-33) and a different rate for non-manufacturing establishments (all other NAICS codes excluding construction). This approach typically results in an even split between manufacturing and non-manufacturing sites. Manufacturing codes include all manufacturing industries (e.g., forest products); non-manufacturing codes include but are not limited to other industries such as healthcare, warehousing, and utilities.

Between April 7, 2023, and December 12, 2024, the SST program led to 652 OSHA inspections. Data from this period shows that SST-selected sites had a higher number of violations per inspection and a greater rate of non-compliance.

Does your facility meet the criteria for an increased likelihood of an OSHA inspection? If your facility were to be inspected by OSHA, how would this inspection go? In addition to determining the likelihood of inspection, it is crucial to be proactive with safety and evaluate compliance status with health and safety regulations.

Please reach out to Victoria Sparks, CSP for assistance!

Recent Relevant Webinars

Upcoming Events

Conferences

Training

  • WATER101 provides a foundational knowledge of various water-related regulatory programs with an emphasis on the Clean Water Act (CWA). The program covers the history of water-related regulations, water quality protections, and an overview of regulatory programs that impact industrial operations (wastewater permitting and discharge, stormwater permitting and discharge, contingency and response plans, and drinking water and water resources). The topics covered by WATER101 will be those encountered by environmental personnel in their real-world projects.

  • 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.

  • 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. Recent updates were covered in an ALL4 blog.

  • The current Tennessee Multi-Sector General Permit (MSGP) for Industrial Stormwater expires June 30, 2025. A draft MSGP has been issued and public comment has ended; a hearing was held on May 21, 2025. The renewed permit may be finalized concurrent with the current permit expiring, and sites with coverage under the current permit will need to submit a Notice of Intent (NOI). See our 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.

  • Wisconsin’s Tier 1 and Tier 2 Industrial Storm Water General Permits expired on June 2, 2025 and will be administratively continued until they are renewed.

  • Certain state emissions inventories are due June 30.

  • Toxics Release Inventory (TRI) submittals are due July 1 – see below for some helpful reporting reminders.

  • The Texas Waste Reduction Policy Act (WRPA) Pollution Prevention (P2) Plan report is due July 1.

  • Quarterly and semi-annual compliance reports are due July 30.

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

Tips & Tricks

Every year July 1st brings the due date for the TRI report. Thousands of companies report on hundreds of chemicals but U.S. EPA throws in changes every year. To prepare for your final review before submittal, we thought we would highlight the changes for 2024 and some tips and watch outs.

Changes for RY2024

  • Diisononyl phthalate (DINP) category (N125) has been added.

  • 7 additional per- and polyfluoroalkyl (PFAS) are reportable.

  • There is no longer a de minimis exemption for PFAS compounds.

  • The de minimis levels have been lowered from 1.0% to 0.1% for these compounds:

    • Some cobalt compounds (N096): soluble cobalt(II) salts, cobalt(II) oxide.

    • Some antimony compounds (N010): trivalent antimony.

Tips and Watchouts  

  • 2024 was a leap year so be sure to use 8784 hours in your calculations instead of 8760.

  • Check for consistency between TRI and other required air, water, and waste reports.

  • Make sure staff responsible for new chemical approvals or receiving updated supplier notifications are on the lookout for new SDS with indication of PFAS or other new constituents.

  • Fill out the comment box to document valid differences from one year to the next to avoid getting a call or email from U.S. EPA!

  • Ensure the certifying official has an active Central Data Exchange (CDX)/TRI-ME web account prior to the submittal deadline. Remember that beginning last Fall, CDX login goes through Login.gov.

  • Please reach out to Scott Kirkpatrick for assistance!

Solutions Spotlight

In addition to the regulation of forest products and biomass feedstocks (NFPA 1, Chapter 31) the fire code (including the International Fire Code) establishes a far-reaching set of requirements, standards, and guidelines applicable to various processes and operations conducted at pulp and paper mills, timber and lumber processing plants, and various other processing and manufacturing plants within the forest products industry. These requirements cover operations as fundamental as welding and cutting (Hot Work) associated with facility and equipment maintenance operations, to the more involved and complex issues related to the management of combustible dust. One of the more basic areas that tends to be overlooked is the management of hazardous materials.

The fire code defines a hazardous material as “a chemical or substance that is classified as a physical hazard material or a health hazard material, whether the chemical or substance is in usable or waste condition.”1 This definition is broad and covers a multitude of materials. Common materials that you may find at a forest products site may include chlorine, calcium hydroxide, diesel fuel, hydrochloric acid, hydrogen peroxide, hydrogen sulfide, methanol, oxygen, and sulfuric acid just to name a few.

The fire code establishes specific requirements applicable to the storage, handling and use of these materials depending on the corresponding physical and health hazards that each present. Physical and health hazard categories include flammable and combustible liquids (various classes), flammable solids, organic peroxides, toxics, oxidizers, unstable-reactive, water-reactive, corrosives, and others. The quantity of materials in use and storage within each hazard class is limited by the Maximum Allowable Quantity (MAQ) values established in the code. When the MAQ is exceeded, the occupancy classification of the area in which the material is used or stored changes, triggering additional building construction requirements.

Due to the risks associated with the storage, handling, and use of hazardous materials, fire departments and related Authorities Having Jurisdiction are increasing inspection efforts and enforcement of the code requirements, even in locations that believe that they have been “grandfathered” under current versions of the code. Additionally, property loss insurers are looking at ways to ensure customers are complying with applicable code requirements. ALL4 has seen instances where property loss claims have been denied because the facility was determined to be out of compliance with the applicable code requirements.

ALL4 helps facilities by evaluating chemical inventories and preparing a chemical classification under the fire and building codes. Using this report and working with ALL4, facilities are able to identify potential code compliance issues before they become problems. Once the potential issues are identified, strategies are developed to enhance or achieve compliance. These efforts can result in the avoidance of enforcement and penalties and ultimately reduce the potential for negative impacts to employees and the environment. For more information, please contact Eli Waddell or Bruce Armbruster.

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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