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.