EPA Publishes Reactivity Rule for Aerosol Coatings

Tag : organic compound

The EPA's new final rule for National Volatile Organic Compound(VOC) Emission Standards for Aerosol Coatings pares down the Tableof Reactivity Factors from over 800 compounds to approximately 40compounds. It defines product categories and the Table of Standardsin a manner that mirrors the current California reactivityregulation. The EPA rule differs from California in that the agencyhas chosen not to specifically exempt products that could beconfused as aerosol coatings. Belt dressing, cleaner, dye,electrical coating, ink, layout fluid, leatherpreservative/cleaner, lubricant, maskant, mold release, and rustconverters are not defined.
The EPA rule does not ban ingredients that are hazardous airpollutants (HAPS), such as methylene chloride or ozone-depletingsubstances. The labeling requirements are similar to the Californiarequirements, with the exception of the EPA proposed requirementfor the name and contact address of the regulated entity. EPA'sproposal requires specific recordkeeping for the manufacture ofeach product category and each batch of each product category.
The effective date of this rule is Jan. 1, 2009, with an extensionto Jan. 1, 2011 for those who have never manufactured, distributed,or imported aerosol coatings in the state of California. Companiessubject to this rule must provide information about the amounts ofeach VOC in their products every three years, beginning with datafor calendar year 2010. The EPA rule allows for indefinite"sell-through" so long as products are date-coded andcompliant when manufactured.
Source: SSPC