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The VOC in Coatings / Epoxy
Restriction Page
Laws are being passed throughout the United States that restrict the sale/use of coatings that contain solvents, known as VOCs (volatile organic compounds). These laws are passed on the state or even the county level.
VOC in Epoxy Resin Coatings - Restrictions Page
Epoxy resin coating VOC issues - Links to Low Voc No Voc sellers
Your Host and Tour Guide:
Paul Oman, MS, MBA - Progressive Epoxy Polymers, Inc. - (floor epoxies, marine epoxies, underwater epoxies, repair epoxies)
Member: NACE (National Assoc. of Corrosion Engineers), SSPC (Soc. of Protective Coatings)
"Professionals helping Professionals"
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NOTES:
Southern California region - called SCADMD - includes LA County, Orange County, Riverside County, San Bernadino County
OTC STATES: Maine, Massachusetts, New Hampshire, Rhode Island, Vermont (under consideration 2007), Connecticut, New York, Pennsylvania, New Jersey, Delaware, DC, Maryland, Virginia (several northern counties). Also OH and IL.
Coating users and consumers may not add solvents to any coating if such additions result in exceeding the VOC limits as stated in the table below.
Solvent free epoxies (0% VOC) may actually contain 0-5 g/l solvent bound up into the chemical structure.
Some products may contain excempt solvents which may or may not be subtracted from the listed VOC listed,
1 pound/gallon VOC equals 120 grams/liter.
Coating manufactures are struggling to keep abreast of these new laws and restrictions, which are constantly changing
in addition to new states/counties adding this laws to their books. There are lots of 'exemptions' to the rules
which make it even more difficult to stay on top of. For example, many coatings/paints etc. list VOC levels well
above stated limits but claim these products are 'California Compliant' or 'can be sold in California.' Assuming
honesty and correctness, the only explanation is that they are using exempt solvents - although I have yet to find
any coating manufacture explicitly state that.
California has some of the toughest VOC restrictive rules and several counties in Southern California have even
tougher restrictions than the overall state restrictions. They practically outlaw anything with more than about
10% solvents which is almost everything. Coating vendors have to decide to if they wish to treat California as
a 'No Sell' region (due to the tough Southern Calif laws) or as two regions - formulating/selling products that
meet the California standards in the northern part of the state but not those in the southern part of the state.
The other 'block' of restrictive states is along the East Coast, basically from Maine to Virginia. The all have
almost the same set of restrictions (Virginia, like California, has some county based restrictions). These are
generally referred to as the OTC (Ozone Transport Commission) states. Again, most vendors match the most restrictive
of these states. In Jan. 2009, Ohio and Illinois joined the OTC states.
Thus the United States is basically divided into four sections, California, Southern California, the OTC states,
and the rest of the country (regulated by national EPA restrictions). Mostly, California has the toughest restrictions,
followed by the OTC states and then the rest of the county. Southern California standards are so tough they practically
exclude all coatings.
VOC regulations measure the solvent levels in grams per liter (g/l). Without getting into the specific regulations,
the acceptable level of solvents in coatings in these restricted areas is about 10% by volume in Southern California,
25% by volume in the rest of California and about 33% in the OTC states. EPA (rest of the country) restrictions
are at about 45% by volume. Many solvent based coatings have/had upwards of 60% solvent in them which is means
these products can no longer be sold/used in these restricted states. The amount of allowed VOC varies with how
the product is classified (i.e. floor coating, mastic, primer, metallic, waterproofing, etc.)
Aerosol cans of paint are exempt (with some VOC retrictions in California only), as are quart units of paints except
in California. Certain solvents are exempt for the rulings to. This offers the possible option for coating manufactures
to maybe reformulate their product(s) to comply with the regulations.
Except in California - products packaged in quart units are exempt from the regulations. Thus you can purchase
a quart of high solvent varnish in New Hampshire, but not a gallon can of it.
Solvents themselves are also not included in these regulations, I guess because they are not coatings but rather
only an ingredient in many coatings. However, if a coatings user adds the solvents to a coating he is using and
as a result exceeds the VOC limits of the regulations (easy to do!) he is technically in violation of the rules.
As I said, all very confusing.
There are also shipping/mailing restrictions on solvent based and non-solvent based coatings. These are separate from the local VOC restrictions and are primarily U.S. Department of Transportation rules - primarily known as Hazmat or ORM-D restrictions. It is especially difficult (not impossible if proper training and documents are handled) to ship such goods by air and some countries will not accept them no matter how they are shipped. Even if shippable, they seem to spend an excessive amount of time trapped in Customs. CLICK HERE for more info on shipping restrictions.
Acetone is a solvent exempt from the VOC regulations, however, because of its properties it usually fails the criteria needed to allow for easy ORM-D shipping. In such cases, you can sell acetone based coatings but not inexpensively ship it (i.e. simple ORM-D shipping, vs. the much more strict, costly, and controlled "hazmat" shipping). Other exempt solvents: Parachlorobenzotrifluoride (PCBTF) and Tertiary Butyl Acetate (TBCa).
When considering the purchase of a solvent based coating you (and your vendor) should/must know if the product(s)
can be sold/used in your state.
VOC RESTRICTIVE STATES
1) California
2) Southern California - SCAQMD District - LA County, Riverside County, San Bernardino County, Orange County.
2) OTC STATES: Maine, Massachusetts, New Hampshire, Rhode Island, Vermont (under consideration 2007), Connecticut,
New York, Pennsylvania, New Jersey, Delaware, DC, Maryland, Virginia (several northern counties).
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This current page is all about:
VOC in Epoxy Resin Coatings - Restrictions Page
Epoxy resin coating VOC issues - Links to Low Voc No Voc sellers
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Note that almost all of our epoxies are solvent free and not subject to these VOC restrictions. However some, but not all, of the epoxies are subject to certain shipping restrictions and cannot be sent by air, etc.
VOC - LIMITS CHART (GRAMS/LITER)
CALIFORNIA |
SOUTHERN CAL |
OTC STATES |
REST OF USA |
COMMENTS |
|
INDUST/MAIN COATINGS (AIM) |
250 |
100 |
340 |
450 |
|
MOBILE EQUIP COATINGS (*) |
420 |
340 |
600 |
600 |
|
METALLIC COATINGS |
500 |
500 |
500 |
500 |
|
MASTIC COATINGS |
300 |
300 |
300 |
300 |
|
FLOOR COATINGS |
250 |
50 |
250 |
400 |
|
WATERPROOFING SEALER |
250 |
100 |
250 |
600 |
|
ONE QUART UNITS |
NOT EXEMPT |
NOT EXEMPT |
EXEMPT |
EXEMPT |
|
VARNISH |
350 |
350 |
350 |
350 |
|
PRIMER |
200 |
100 |
200 |
350 |
|
AEROSOL ** |
METALLIC COATINGS - VOC UNDER 80% |
SEE CALIFORNIA |
EXEMPT |
EXEMPT |
NOTES:
VOC RESTRICTIVE STATES
1) California
2) Southern California - SCAQMD District - LA County, Riverside County, San Bernardino County, Orange County.
2) OTC STATES: Maine, Massachusetts, New Hampshire, Rhode Island, Vermont (under consideration 2007), Connecticut, New York, Pennsylvania, New Jersey, Delaware, DC, Maryland, Virginia (several northern counties).
MASTIC - "coating labeled and forumulated to cover
holes and minor cracks, and to conceal surface irregularities, and applied in a single coat of at least 10 mils."
VOC information on Progressive Epoxy Polymer products can be found at www.epoxyproducts.com/datamsds.html Some
products may also contain exempt solvents such as naphtha which would be subtracted out of the listed/posted VOC
value for a 'regulated' VOC value.
* ........"Coatings applied in shop applications or to non-stationary structures such as airplanes, ships,
boats, railcars, and automobiles, and adhesives are not considered architectural coatings for the purpose of this
rule." (reg 8 rule 3 #206)
** .......Only California (CARB) as put VOC restrictions on aerosol coatings. OTC and others expected to follow the CARB example. Currently aerosol paints in disposable, single use containers are considered exempt.
Disclaimer: The above information is correct as best as Progressive Epoxy Polymers, Inc. can determine.
VOC information on Pregressive Epoxy Polymer products are found on the same page as our data sheets and MSDS - CLICK HERE
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VOC in Epoxy Resin Coatings - Restrictions Page
Epoxy resin coating VOC issues - Links to Low Voc No Voc sellers