Solvent Cleaners and Degreasers
Volatile Organic Compound (VOC) Content Limits
Introduction
This document summarizes the regulations in several states affecting the content limits of Volatile Organic Compounds (VOCs) for Solvent Cleaners and Degreasers. For a quick introduction on how to most easily interpret these pages, link to How to Use the VOC and MIR Rules.
Skip to regulations:
- South Coast Air Quality Management District (SCAQMD)
- California Air Resources Board (CARB)
- Massachusetts
- Texas
- Ozone Transport Commission (OTC) (NY, NJ)
- Lake Michigan Air Directors Consortium (LADCO) (MI, OH, IL, IN)
Note: ISSA, the leading trade association for the cleaning industry worldwide publishes a comprehensive list of VOC content limts by state and application: Summary of State and Federal VOC Limitations for Institutional and Consumer Products.
South Coast Air Quality Management District (SCAQMD)
SCAQMD has published 2 sets of rules: Rule 1122 Solvent Degreasers: As noted on the SCAQMD page, the VOC content limits for solvents used in solvent degreasing was reduced to 25 grams/litre in 2009. The 25 g/litre regulation is found throughout the text of Rule 1122 applied to several degreasing applications. Rule 1171 Solvent Cleaning Operations: The VOC content limit for solvents used in many solvent cleaning applications is 25 grams of VOC per liter, however, certain applications are afforded a higher limit, as shown in the following table:
Solvent Cleaning Activity effective 1/1/2010 | VOC Content Limit (g/litre) |
(A) Product Cleaning During Manufacturing Process Or Surface Preparation For Coating, Adhesive, Or Ink Application | |
(i) General | 25 |
(ii) Electrical Apparatus Components & Electronic Components | 100 |
(iii) Medical Devices & Pharmaceuticals | 800 |
(B) Repair and Maintenance Cleaning | |
(i) General | 25 |
(ii) Electrical Apparatus Components & Electronic Components | 100 |
(iii) Medical Devices & Pharmaceuticals | |
(A) Tools, Equipment, & Machinery | 800 |
(B) General Work Surfaces | 600 |
(C) Cleaning of Coatings or Adhesives Application Equipment | 25 |
(D) Cleaning of Ink Application Equipment | |
(i) General | 25 |
(ii) Flexographic Printing | 25 |
(iii) Gravure Printing | |
(A) Publication 100 | 100 |
(B) Packaging 25 | 25 |
(iv) Lithographic (Offset) or Letter Press Printing | |
(A) Roller Wash, Blanket Wash, & On-Press Components | 100 |
(B) Removable Press Components | 25 |
(v) Screen Printing | 100 |
(vi) Ultraviolet Ink/ Electron Beam Ink Application Equipment (except screen printing) | 100 |
(vii) Specialty Flexographic Printing | 100 |
(E) Cleaning of Polyester Resin Application Equipment | 25 |
As described on the SCAQMD page, solvents which meet the 25 g/litre limit, along with several other requirements, may be eligible for a Clean Air Solvent Certificate. TBF’s ZemaSol™ solvent is the only industrial solvent in the past 20 years to have been certified by SCAQMD as a Clean Air Solvent.
California Air Resources Board (CARB)
CARB does not publish its own regulations for solvent cleaning and degreasing. They do helpfully publish a table showing the VOC content limit rules for many applications including solvent cleaning and degreasing in each of the 35 AQMDs in California. SCAQMD’s Rules 1122 and 1171 are unique. CARB is diligent in enforcing its regulations. See CARB Enforcement.
Massachusetts
Massachusetts has published all of their air pollution regulations in a single, long document. There is a process-based regulation for cleaners and degreasers: 7.18 (8) Solvent Metal Degreasing. Pg 282 (a) Cold Cleaning Degreasing: solvents must have a vapour pressure that does not exceed 1.0 mm Hg measured at 20/C. The enclosure must have a VOC control efficiency of at least 90%.
Texas
Texas has published their air pollution regulations in a multi-tiered document: TITLE 30 ENVIRONMENTAL QUALITYPART 1 TEXAS COMMISSION ON ENVIRONMENTAL QUALITY CHAPTER 115 CONTROL OF AIR POLLUTION FROM VOLATILE ORGANIC COMPOUNDS SUBCHAPTER E SOLVENT-USING PROCESSES In this sub chapter, there are a couple of references to Cleaners and Degreasers: DIVISION 6 INDUSTRIAL CLEANING SOLVENTS RULE §115.463 Control Requirements
- 0.42 pound of VOC per gallon of solution (lb VOC/gal solution)
- partial vapor pressure of the cleaning solution to 8.0 millimeters of mercury at 20 degrees Celsius
DIVISION 1 DEGREASING PROCESSES RULE §115.412 Control Requirements This is a process-facing regulation, and does not specify a content limit or an emission limit.
Ozone Transport Commission (OTC)
Connecticut, Delaware, the District of Columbia, Maine, Maryland, (except Massachusetts), New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and Virginia: OTC adopted MODEL RULE 2002- Solvents and Cleaners. It specifies that solvents used in degreasing processes cannot have a vapor pressure of 1.0 millimeters of mercury (mm Hg) or greater, measured at 20 oC (68 oF). Unless not otherwise compliant, manufacturers must ensure that emissions from each solvent cleaning machine are equal to or less than the applicable emission limit presented in Table 6. Source: MODEL RULE 2002- Solvents and Cleaners Table 6 Emission Limits for Batch Vapor and In‑Line Solvent Cleaning Machines with a Solvent/Air Interface Solvent cleaning machine 3‑month rolling average monthly emission limitkg/m2/month lb/ft2/month Batch vapor solvent cleaning machines 150 30.7 Existing in‑line solvent cleaning machines 153 31.3 New in‑line solvent cleaning machines 99 20.2
Lake Michigan Air Directors Consortium (LADCO)
Indiana, Illinois, Michigan, Wisconsin and Ohio, publish their own VOC content limits for solvent cleaning and degreasing. Many use a process-based regulation limiting VOC emissions to so many pounds per day or parts per million.
- Illinois
Under Title 35, Section 215.182 Cold Cleaning specifies that the solvent vapor pressure must be less than 2 kPa (15 mmHg or 0.3 psi) measured at 38 oC (100 oF) under certain conditions and there are other operational requirements. - Michigan
Michigan egulates VOC emissions on a quantity per hour basis. Section 336.1610 Existing coating lines; emission of volatile organic compounds from existing automobile, light-duty truck, and other product and material coating lines includes tables of emissions limits: Table 62 pg 13 Volatile organic compound emission limits for existing automobile and light-duty truck coating lines Coating category
Coating category | Emission limit |
1. Prime-electrodeposition process | 1.21 |
2. Primer surfacer3 | 14.92 |
3. Topcoat3 | 14.92 |
4. Final repair | 4.81 |
- Pounds of volatile organic compounds per gallon of coating, minus water, as applied.
- Pounds of volatile organic compounds per gallon of applied coating solids.
- The primer surfacer or topcoat coating category would include an anti-chip, blackout, or spot primer coating if this coating is applied as part of the primer surfacer or topcoat coating operation.
Table 63 pg 13 Volatile organic compound emission limits for existing coating lines
Coating category | Column A1 | Column B2 |
A. Metallic surfaces | ||
1. Coating of cans | ||
(a) Sheet basecoat exterior and interior) and overvarnish; 2-piece can exterior (basecoat and overvarnish) | 2.8 | |
(b) 2- and 3-piece can interior body spray; 2-piece can interior end (spray or roll coat) | 4.2 | |
(c) 3-piece can side-seam | 5.5 | |
End sealing compound | 3.7 | |
2. Coating of coils | 2.6 | |
3. Coating of large appliances3 | 2.8 | 7.5 |
4. Coating of metal furniture3 | 3.0 | 8.4 |
5. Insulation of magnet wire | 1.7 | |
B. Nonmetallic surfaces | ||
1. Coating of fabric | 2.9 | |
2. Coating of vinyl | 3.8 | |
3. Coating of paper | 2.9 |
1. Pounds of volatile organic compounds emitted per gallon of coating, minus water, as applied.
2. Pounds of volatile organic compounds emitted per gallon of applied coating solids.
The purpose of column B emission limits is to allow credit for transfer efficiencies greater than the baseline transfer efficiency. Note: department approval of the transfer efficiency test method is required. 3. The allowable emission rate does not apply to coatings that are used for the repair of scratches and nicks.
- Ohio
The Ohio Administrative Code (OAC) chapter 3745 includes section 3745-21-23 Control of volatile organic compound emissions from industrial solvent cleaning operations.
Table of standards
Solvent Cleaning Operation | VOC-Content Limitation [in pounds per gallon] |
(A) Product cleaning during manufacturing process or surface preparation for coating, adhesive, or ink application: | |
(1) General | 0.42 |
(2) Electrical apparatus components and electronic components | 0.83 |
(3) Medical devices and pharmaceuticals | 6.7 |
(B) Repair and maintenance cleaning: | |
(1) General | 0.42 |
(2) Electrical apparatus components and electronic components | 0.83 |
(3) Medical devices and pharmaceuticals | |
(a) Tools, equipment and machinery | 6.7 |
(b) General work surfaces | 5.0 |
(C) Cleaning of coating or adhesive application equipment | 0.42 |
(D) Cleaning of ink application equipment: | |
(1) General | 0.42 |
(2) Flexographic printing | 0.42 |
(3) Gravure printing: | |
(a) Publication | 0.83 |
(b) Packaging | 0.42 |
(4) Screen printing | 4.2 |
(5) Ultraviolet ink and electron beam ink application equipment, except screen printing | 5.4 |
(6) Specialty flexographic printing | 0.83 |
(E) Cleaning of polyester resin application equipment not subject to 40 CRF Part 63 Subpart WWWW | 0.42 |
Summary:
The 25 g/litre limit adopted by SCAQMD is the strictest in the country. Manufacturers selling solvents for cleaning and degreasing uses in California must meet this tough limit. Using TBF’s ultralow and zero VOC solvents may be the easiest route. Outside California, there is a patchwork of regulations for solvent cleaning and degreasing. Some states have few or no regulations, while others have comprehensive regulations. Manufacturers typically do not want to maintain different formulations of the same product to satisfy differing state regulations. Using TBF’s zero VOC solvents to meet the highest standards may be the easiest route.