...
Emissions of volatile organic compounds or VOCs to the outdoors are generally regulated by the Environmental Protection Agency (EPA) to prevent the formation of ozone, a constituent of photochemical smog. Many VOCs form ground-level ozone by “reacting” with sources of oxygen molecules in the atmosphere in the presence of sunlight.
Scope
Volatile organic compounds have a high vapor pressure and low water solubility. The European Union goes on to say that a VOC is any organic compound having an initial boiling point less than or equal to 250°C measured at a standard atmospheric pressure of 101.3 kPa. Many VOCs are human-made chemicals. Sources of VOCs include:
- Paints, paint strippers and other solvents;
- Wood preservatives;
- Aerosol sprays;
- Cleansers and disinfectants;
- Moth repellents and air fresheners;
- Stored fuels and automotive products;
- Hobby supplies;
- Dry-cleaned clothing;
- Pesticides;
- Building materials and furnishings;
- Office equipment such as copiers and printers, correction fluids, and carbonless copy paper; and
- Graphics and craft materials including glues and adhesives, permanent markers, and photographic solutions.
VOC controls for products are usually based on the application of products like:
- Automobile Refinish Coatings (40 CFR 59 Subpart B)
- Consumer Products (40 CFR 59 Subpart C)
- Architectural Coatings (40 CFR 59 Subpart D)
- Aerosol Coatings (40 CFR 59 Subpart E)
Anyone who works with these four categories may be impacted by VOC regulations.
Regulatory citations
- 40 CFR 59 — National Volatile Organic Compound Emission Standards for Consumer and Commercial Products
Key definitions
- Aerosol coating product: A pressurized coating product containing pigments or resins that is dispensed by a propellant and is packaged in a disposable can for hand-held application, or for use in specialized equipment for ground traffic/marking applications.
- Architectural coating: A coating recommended for field application to stationary structures and their appurtenances, to portable buildings, to pavements, or to curbs.
- Automobile refinish coating component: Any portion of a coating, such as a reducer or thinner, hardener, additive, etc., recommended to distributors or end-users for automobile refinishing. The raw materials used to produce the components that are mixed by the end-user to prepare a coating for application are not considered automobile refinish coating components. Any reference to automobile refinishing made by a manufacturer or importer on a container or in product literature constitutes a recommendation for automobile refinishing.
- Consumer product: Any household or institutional product (including paints, coatings, and solvents), or substance, or article (including any container or packaging) held by any person, the use, consumption, storage, disposal, destruction, or decomposition of which may result in the release of VOC.
- Thinner: Any solvent used to reduce the viscosity or solids content of a coating.
- Volatile organic compound: Organic chemical compounds whose composition makes it possible for them to evaporate under normal indoor atmospheric conditions of temperature and pressure.
Summary of requirements
The following are some of the labeling and reporting VOC requirements:
Automobile Refinish Coatings (40 CFR 59 Subpart B)
- Each regulated entity subject to this subpart must clearly display on each automobile refinish coating or coating component container or package, the day, month, and year on which the product was manufactured, or a code indicating such date.
- Each regulated entity must submit an initial report within 180 days of the date that the regulated entity first manufactures, or imports automobile refinish coatings or coating components, whichever is later.
Consumer Products (40 CFR 59 Subpart C)
- The container or package of each consumer product that is subject to this subpart shall clearly display the day, month, and year on which the product was manufactured, or a code indicating such date.
- These requirements do not apply to products that are offered to consumers free of charge for the purposes of sampling the product.
- The distributor that is named on the product label, or if no distributor is named on the label, the manufacturer or importer, shall submit by the applicable compliance date, or within 30 days after becoming a regulated entity, a one-time Initial Notification Report.
Architectural Coatings (40 CFR 59 Subpart D)
- Each applicable manufacturer and importer of any architectural coating shall provide the following information on the coating container in which the coating is sold or distributed:
- Date the coating was manufactured, or a date code representing the date shall be indicated on the label, lid, or bottom of the container;
- Statement of the manufacturer’s recommendation regarding thinning of the coating shall be indicated on the label or lid of the container; and
- VOC content of the coating shall be indicated on the label or lid of the container.
- Each regulated entity must submit reports and exceedance fees specified in this section to the appropriate address.
Aerosol Coatings (40 CFR 59 Subpart E)
- The labels of all aerosol products manufactured on and after the applicable compliance date must contain the following information:
- Aerosol coating category code for the coating;
- Applicable product-weighted reactivity (PWR) limit for the product;
- Day, month, and year on which the product was manufactured, or a code indicating such date; and
- Name and a contact address for the manufacturer, distributor, or importer that is the regulated entity.
- Each regulated entity must submit an initial notification on or before the date that you first manufacture, distribute, or import aerosol coatings, whichever is later.