The impact of Title V regulations on hospitals and health care facilities

The Clean Air Act, enacted in 1970, failed to provide for an enforceable regulatory scheme at any level of government. In late 1990, Congress passed the Clean Air Act Amendments, of which Title V is the focal point. This amendment includes the Operating Permit Program, which states that all "major sources" are required to obtain Title V operating permits on or before November 15, 1995. Under Title V, the burden of demonstrating compliance will now fall directly to the facility itself. This document both summarizes and highlights the requirements of the Operating Permit Program and presents guidelines for preparing to file a Title V Operator Permit application.