The proposed regulations call for the use of maximum achievable control technology (MACT). FPA believes a MACT standard would impose costly new requirements on the packaging and printing industry that often are unproductive. FPA's arguments are in line with those of regulatory reformers on Capitol Hill who say regulations should be aimed at real risks when benefits outweigh costs. The MACT standards might well fail the mandatory risk analysis and cost/benefit analysis required in regulatory reform bills now pending in Congress. FPA's suggested modifications include: * Using data supplied by large ink manufacturers to determine the level of hazardous air pollutants for all coatings inks lacquers and other such materials used by packaging manufacturers rather than requiring manufacturers to determine the levels using a testing method that could cost up to $1 per sample; * Take into account controls hours of operation and other restrictions that might limit hazardous air pollution emissions when regulating companies on their potential to emit; * Allow manufacturers to compare beginning and ending inventories of solvents purchased rather than require them to trace and measure each solvent used on the job to demonstrate compliance for each individual press; * Determine compliance to the standard on a plant-wide basis rather than by individual press lines. FPA said this change alone could reduce yearly reporting and recordkeeping costs per plant from $20 to $250. * Require performance tests of control devices only when they are installed or a major modification to a press is made that would affect the efficiency of capturing emissions and * Eliminate or put a moratorium on state air toxins programs until all MACT standards have been adopted. "If EPA accepts our final recommendations the proposed standard will achieve the goals of the Clean Air Act without gutting industry's ability to meet business objectives" said FPA President Glenn Braswell. The final rule must be signed by March 1 1996.