Regulatory Response to VOC Emissions

To combat these adverse impacts, the U.S. Environmental Protection Agency (EPA) has mandated maximum allowable VOC content for thousands of products including, paints, coatings, inks, adhesives, thinners, diluents, etc. Individual U.S. states are required to adopt companion regulations, and many state regulations are more restrictive than EPA regulations. Because of the smog problems in the Los Angeles basin, the South Coast Air Quality Management District (SCAQMD (vi)) and the California Air Resources Board (CARB), have adopted the most stringent regulations on VOC product content and emissions. Many state regulators simply adopt the California standards. >  The EPA and state and local regulators continue to strengthen the regulations on VOC emissions. For example:

  • On March 1, 2013, the Texas Commission on Environmental Quality introduced stricter limits on VOC emissions for storage of VOCs and certain solvent-using processes.
  • CARB has issued new tighter VOC emission restrictions and lower MIR restrictions for aerosol manufacturers which come into effect from 2015 – 2017.  To accommodate the new CARB regulations, many companies are reformulating products now to be compliant ahead of schedule.

>  There is a distinction among regulators over designating solvents as “VOC exempt”, “Zero VOC” and “Ultralow VOC”.  Background information on this terminology and its application to TBF green solvents can be found on the    VOC Content and VOC Exemption Rules page. >  VOC content limits are not the only means to regulate the emission of harmful VOCs to the atmosphere.  In the last decade, the EPA and CARB have been working together to develop and implement the concept of Maximum Incremental Reactivity or MIR.  MIR values have been determined for thousands of chemicals in order to determine which have the greatest propensity to create smog.  Regulatory efforts will be focused on the high-MIR compounds. Please link to the CARB page for further information. >  The U.S. Department of Labor and its Occupational Safety and Health Administration (OSHA) regulate VOC exposure in the workplace (viii). This guide does not address the OSHA regulations. >  Environment Canada publishes a National Pollutant Release Inventory (ix) (NPRI) which requires owners and operators of manufacturing facilities above a certain size to publish a comprehensive list of all of their emissions of pollutants. All VOCs above the allowable limits are included in the list of reportable pollutants. Clearly, there is a comprehensive regulatory effort to reduce the emission of VOCs which is driving users to find environmentally-friendly substitutes for the conventional toxic solvents. All regulators are continuously reviewing the regulations and lowering the limits with the intent of eventually reducing them to insignificance. Companies must be prepared to continuously update their knowledge of the regulations and pending updates. ____________________________________