Temporary relief doesn’t change long-term expectations. Here’s how Montrose is helping clients turn regulatory shifts into strategic advantage.
In July 2025, the EPA under a presidential exemption granted delayed enforcement of several major air toxics regulations under National Emissions Standards for Hazardous Air Pollutants (NESHAP), including rules targeting ethylene oxide (EtO), chloroprene, mercury, and fugitive hazardous air pollutants (HAPs). While some see this as a pause, many see it for what it is: a chance to lead.
These regulatory changes—while offering breathing room on paper—do not eliminate compliance obligations, reputational risk, or community pressure. Facilities that use this time to get ahead will gain far more than compliance. They’ll gain trust, efficiency, and operational readiness.
At Montrose, we’re already there.
What Changed and What It Means
1. Ethylene Oxide (EtO) NESHAP – Commercial Sterilization Facilities
What changed: A two-year exemption on enforcement of the 2024 final rule requiring 95% emissions reduction and operating permanent total enclosures.
Why it still matters: EtO is a known carcinogen under heavy public scrutiny. While enforcement is paused, expectations from communities, media, and stakeholders are not. Past precedent of EtO emissions liability still burdens the facilities.
How Montrose helps: We’re actively deploying real-time indoor air monitoring (FIFRA), state of the art real-time stack monitoring CEMS (NESHAP), implementing fenceline monitoring strategies, and designing compliance-ready control systems for major sterilization clients. Delaying action now will only increase the cost later.
2. HON Rule – Hazardous Organic NESHAP for Chemical Manufacturing
What changed: Temporary delay on stricter LDAR thresholds, emissions reporting, and control requirements targeting HAPs like benzene and chloroprene.
Why it still matters: These pollutants carry major health risks and visibility, and some state agencies are proceeding with more aggressive enforcement regardless of the delay. The rule has not changed, and facilities will still have to comply, just at a later date.
How Montrose helps: Our teams are already upgrading client programs to meet future standards. We’re enhancing leak detection methods, refining reporting systems, and reducing fugitive emissions risk ahead of the curve. Many facilities are still starting pilot programs to better understand their fenceline concentrations and address any potential emissions prior to the compliance deadline.
3. Integrated Iron and Steel NESHAP
What changed: EPA delayed compliance deadlines for key provisions—like opacity limits, work practices for fugitive emissions, and fenceline monitoring for chromium—until April 3, 2027, due to technical challenges and ongoing reconsideration.
Why it still matters: Communities surrounding these facilities remain concerned about heavy metals and particulate emissions. Even without immediate enforcement, legal exposure and reputational risk remain high for non-compliant operations.
How Montrose helps: We guide clients through evolving work practice standards, deploy fenceline monitoring programs for chromium, and ensure data management systems are audit-ready when compliance dates kick in.
4. Coke Ovens NESHAP
What changed: The EPA extended compliance deadlines to July 5, 2027, for new fenceline benzene monitoring, updated leak standards for doors/lids/offtakes, and MACT limits for pollutants like mercury, HCN, PAHs, and acid gases.
Why it still matters: Fenceline monitoring is already shaping public perception and driving litigation risk. And once these rules go live, facilities must hit ambitious targets backed by limited industry precedent.
How Montrose helps: We support coke producers with feasibility assessments, benzene monitoring program management, and root cause analysis—helping clients stay ahead of action levels and public scrutiny.
Why Waiting Is the Riskier Move
While these exemptions may feel like a reprieve, they don’t eliminate long-term responsibility. Enforcement will return. State regulations are moving independently. Public pressure is continuously increasing. And many clients are realizing that delaying investments in monitoring, capture systems, or control technologies now simply means more expense, more risk, and more operational disruption later.
Montrose Is Already Delivering
At Montrose, we don’t just monitor compliance—we help shape it. Our integrated air services help clients stay ahead through:
- Real-Time Air Monitoring: Deploying fenceline and mobile lab solutions tailored to EtO, benzene, and other HON compounds.
- Stack Testing & Air Permitting: Keeping clients aligned with shifting federal and state requirements
- LDAR & Fugitive Emissions Programs: Advanced leak detection, monitoring, and compliance tracking
- Strategic Consulting & Readiness Planning: Translating complex rules into actionable roadmaps
We’re not reacting to the rule changes—we’re guiding clients through them with confidence and clarity.
Final Thought: The Leaders Are Already Moving
This regulatory reset is a chance to lead—not pause. Facilities that move now will be better prepared, more transparent, and more trusted when enforcement returns.
If your operation is affected by the 2025 NESHAP changes, now is the time to act. Let’s build a compliance strategy that’s proactive, not reactive.
Contact us today to schedule a compliance readiness consultation.
About the Authors
Sean Wheeler
SMS Operations Manager
Sean specializes in complex VOC and HAP measurements, with deep expertise in FTIR spectroscopy. He has a strong focus on ultra-low Ethylene Oxide detection in challenging gas matrices and a thorough understanding of source testing regulations and CEMS.
Jenna Granstra
Gulf Coast Operations Manager
Jenna has over a decade of experience managing large-scale air monitoring programs. She specializes in fenceline and community air monitoring, data analysis, and quality assurance.
Austin Heitmann
VP Operations – Real Time Air Monitoring
Austin has 9 years of experience managing air monitoring programs and developing emerging technologies.
Need help managing your emissions?
Ready to see the platform or have a question for our experts? Use the form below.