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EPA Proposes Reactivity-Based National Rule for Aerosol Coatings; NPCA Submits Comments

Published on 2007-09-11. Author : SpecialChem

In August, NPCA submitted comments to U.S. EPA on its July-proposed rule for National Volatile Organic Compound (VOC) Emission Standards for Aerosol Coatings. NPCA had urged EPA to develop its rule to conform to the California Air Resources Board's (ARB) Regulation for Reducing the Ozone Formed from Aerosol Coating Product Emissions, and it seems the proposed rule establishing national reactivity standards is consistent with the ARB rule. With a national rule in sight, NPCA and its Spray Paint Manufacturers Committee are hopeful that the remaining regions in the country that have VOC command and control regulations for spray paint (California's Bay Area Air Quality Management District, Portland, Ore., and Seattle, Wash.) will voluntarily repeal these regulations or, in the alternative, recognize that compliance with the reactivity standard constitutes compliance with the regional regulation.

The definitions of product categories and the Table of Standards in the EPA proposal mirror the California reactivity regulation. The EPA proposal is different in that EPA has chosen not to specifically exempt products that could be confused as aerosol coatings and consequently, EPA does not define these products (belt dressing, cleaner, dye, electrical coating, ink, layout fluid, leather preservative/cleaner, lubricant, maskant, mold release, rust converter). EPA does not address use of ingredients that are hazardous air pollutants such as methylene chloride or ozone depleting substances so there is no ban on use or accompanying reporting requirements. Additionally, the labeling requirements are similar to ARB's requirements, with the exception of the EPA proposed requirement for the name and contact address of the regulated entity.

The effective date of the rule is Jan. 1, 2009, with an extension to Jan. 1, 2011 for those who have never manufactured, distributed or imported aerosol coatings in the state of California. The EPA proposal allows for indefinite "sell-through" so long as products are date-coded and compliant when manufactured.

NPCA's comments addressed specifics EPA sought from industry on its estimate of the products that are not compliant with these limits specifically, and its evaluation of the potential VOC emission reductions generally. One point NPCA stressed is that the proposed U.S. EPA and California ARB rules' recordkeeping and reporting requirements are vastly different, which appears problematic. EPA's proposal requires specific recordkeeping for the manufacture of each product category and each batch of each product category.

The EPA proposal would also require an Initial Notification of Compliance report along with a requirement to provide certain information within 60 days if requested in writing.

EPA's methodology for determining compliance with the reactivity standards is the same as that required by the ARB, although EPA has chosen to use different terms to identify these calculations. The fundamental principles of reactivity are consistent in this EPA proposal in that there are no exempt VOCs. Other elements of the ARB regulation are included in this EPA proposal such as the "most restrictive limit" and application of most stringent limit.

Source: National Paint & Coatings Association


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