Many states defer to the South Coast Air Quality Management District (SCAQMD) of California (the air pollution regulator for the Los Angeles basin) for VOC content limits. However, SCAQMD Rule 102 includes VOC-exempt products which may or may not be listed as VOC-exempt by the EPA. This confuses the categorization of chemical compounds and blends as “VOC-exempt”, and the VOC contents of products.

EPA will not declare a solvent blend VOC-exempt, only pure compounds. Therefore none of TBF’s products are or will be VOC-exempt under the EPA or under Rule 102 by SCAQMD.

ZemaSol™ is a blend of VOC-exempt materials. The VOC content of ZemaSol is zero in most jurisdictions as all of the ingredients are VOC-exempt according to the EPA.  SCAQMD has certified ZemaSol as a Clean Air Solvent as it meets the clean air qualifications (<25 g/litre) under SCAQMD Rules 1122 and 1171. However, ZemaSol is not considered VOC-exempt as, similarly to the EPA, SCAQMD does not certify blends as VOC-exempt.

The VOC content of ZemaSol is zero (0) in 49 states and most of California. However, under Rule 102 in SCAQMD, ZemaSol is considered to contribute 1.59 g/litre when used in a manufacturing process, or in cleaning or as a diluent. ZemaSol’s VOC content (1.59 g/litre) must be added to the VOC content calculation of any product manufactured and/or sold in SCAQMD. (1.59 g/litre is considered an ultra-low VOC value, and can almost be considered to be zero for practical purposes, given that the accepted VOC-exempt limit is 25 g/litre or less.)

The VOC content of EkaSol 1™ is zero (0) in 49 states and most of California when used in cleaning and formulation. However, in SCAQMD, EkaSol 1 contributes 2.66 g/litre of VOC when used in either manufacturing of a product, or in cleaning or as a diluent.  (2.66 g/litre is considered an ultra-low VOC value, and can almost be considered to be zero for practical purposes, given that the accepted standard as VOC-exempt limit is 25 g/litre or less.)

The VOC content of TergoSol™ is zero (0) in 49 states and most of California when used in cleaning and formulation. However, in SCAQMD, TergoSol contributes 2.82 g/litre of VOC when used in either manufacturing of a product, or in cleaning or as a diluent.  (2.82 g/litre is considered an ultra-low VOC value, and can almost be considered to be zero for practical purposes, given that the accepted standard as VOC-exempt limit is 25 g/litre or less.)

In Canada, Environment Canada, similar to the EPA, will not classify a solvent blend as VOC-exempt. ZemaSol is considered “zero VOC” because all of its ingredients are exempt under the National Pollution Release Inventory (NPRI). EkaSol 1 is considered 69% exempt and TergoSol is 72% exempt under NPRI.

Generally, in order to be reportable under NPRI, a facility must use in excess of 10,000 kg of a NPRI listed product. Thus a facility using EkaSol or TergoSol would allow be able to use up to 3.2 or 3.6 times more material, respectively, before they would have to report.