VOC regulations and coatings
Of the many considerations to make when preparing for a coatings project, from the surface preparation to corrosion control, volatile organic compound (VOC) regulations on coatings are important to keep in mind. Following federal and state regulations of VOC emissions not only eliminates unnecessary fines but helps contribute to maintaining air quality.
The following defines VOCs and why the Environmental Protection Agency (EPA) regulates them; explains the regulations that apply to industrial and marine coatings; and clarifies regulation differences across states.
What VOCs are and why they are regulated
A volatile organic compound (VOC) is any chemical that becomes a gas at room temperature and has the potential to react with the surrounding atmosphere. VOCs are dangerous to air quality because when they react with nitrogen oxide under UV radiation, ground-level ozone is formed.
Ground-level ozone causes negative health effects, such as reduced lung function, respiratory symptoms, and aggravation of lung diseases. In terms of the environmental effects, ground-level ozone can damage vegetation, decrease crop yields, reduce biodiversity, and decrease plant uptake of CO2. Ozone is also a greenhouse gas that contributes to the warming of the atmosphere.
Under the Clean Air Act (CAA) of 1970, which led to the EPA’s establishment of the National Ambient Air Quality Standards (NAAQS), ground-level ozone is one of the six common air pollutants the EPA is most concerned with reducing. Because VOCs are what lead to ground-level ozone formation, they are the substance that’s regulated by the EPA.
In relation to coatings projects, almost all the organic solvents in coatings are classified as VOCs, meaning they are subject to EPA regulation.
VOC regulations for coatings
When preparing for a coatings project, project managers need to be familiar with VOC regulations and the methods for control. VOC emissions from coatings can be controlled in several ways. The most common method widely employed by state agencies is limiting the amount or proportion of VOCs in a coating formula.
The CAA sets the limit for the amount of VOC in a coating formula based on the use of each coating. For VOC limits on industrial and shipbuilding coatings, two sections apply.
- VOC Emissions Standards for Architectural Coatings: This rule establishes a number of categories for the max VOC level for field-applied coatings to stationary structures, pavements or curbs. For example, the VOC limit for industrial maintenance coatings is 450 grams per liter. (See the full section here and the limits for all categories here.)
- Emission Standards for Shipbuilding and Ship Repair (Surface Coating): For surface coatings on ships, most of the VOC paint solvents used in shipyards are also categorized as hazardous air pollutants (HAPs). This means they are toxic and are known or are suspected to cause cancer or other serious health effects. For these coatings there is a single regulation for VOC and HAP limits since they are one and the same in these scenarios. For example, the VOHAP limit for antifoulant coating is 400 grams per liter. (See the full section here and the limits for all categories here.)
The second method for controlling VOC emissions is limiting the total quantity of VOCs emitted from a facility for a unit of time. If a facility emits more than 100 tons per year of one of the six major regulated pollutants (which includes VOCs), the facility will need to obtain a Title V permit from the state. This requires a manager at the facility to keep records of the solvents emitting VOCs used and the amounts in which the solvents were used.
If the VOC limit is exceeded, fines must be paid to the EPA. The fee is calculated using the amount of VOC emissions that are over the limit: $0.0028 per gram, $1.27 per pound and $2,500 per ton.
Fee rate X Excess VOC content X Annual volume of the coating
How VOC regulations differ across states
The EPA’s VOC reduction goals at the federal level have made strides in reducing air pollution and improving air quality: Since 1990, when the Clean Air Act Amendments were enacted and put forth an ambitious program from reducing air pollution, the national average of the ozone 8-hour concentration has dropped from 0.088 parts per million (ppm) to 0.068 ppm, in line with the most recent national standard. But some states who were already seeing dangerous effects from air pollution took the regulations even further.
The first state to push for more stringent regulations was California, which now has its own Air Resources Board (CARB). For example, the VOC limit on industrial maintenance coatings of 450 grams per liter is lowered to 250 grams per liter in most regions of the state. It is as low as 100 grams per liter in the South Coast region, where L.A. is working hard to reduce its ozone and smog problem.
Other states have followed California’s example and have formed regional air quality groups that work to improve air quality for the region. The groups are CARB, the Lake Michigan Air Directors Consortium (LADCO) and the Ozone Transport Committee (OTC). The following states abide by stricter regulations than those set at the federal level, and project managers working on projects in these states should familiarize themselves with the stricter regulations for their next coatings project.
- California (CARB)
- Illinois (LADCO)
- Indiana (LADCO)
- Ohio (LADCO)
- Michigan (LADCO)
- Minnesota (LADCO)
- Wisconsin (LADCO)
- Pennsylvania (OTC)
- Maryland (OTC)
- Delaware (OTC)
- New Jersey (OTC)
- New York (OTC)
- Connecticut (OTC)
- Rhode Island (OTC)
- Massachusetts (OTC)
- New Hampshire (OTC)
- Maine (OTC)
- District of Columbia (OTC)
Air quality issues don’t abide by state lines, so doing your part to limit VOC emissions with your coating project will help improve and maintain air quality. To make sure you’re choosing the right coating for your state’s VOC emissions regulations and abiding by all environmental regulations, read Painting Manual Vol.1: Good Painting Practice, available at the AMPP Store.