Industry News_April 2004

Effective January 1, 2004, the Bay Area Air Quality Management District (BAAQMD) has significantly reduced the allowable amounts of volatile organic compounds (VOCs) allowed to be emitted from industrial coatings. VOCs are known to react with oxides of nitrogen under certain conditions to form ozone, a pollutant that is regulated under the U.S. Federal Clean Air Act. Ozone is a regional air pollution problem because in high concentrations it can constrict the airways as well as aggravate existing respiratory problems such as asthma, bronchitis, and emphysema. The classification “industrial coating,” for purposes of the regulation, comprises floor coatings, primers, sealers, undercoats, intermediate coats, and topcoats formulated for application to substrates that will be subject to:

Immersion in water, wastewater, or chemical solutions (aqueous or nonaqueous solutions) or chronic exposure of interior surfaces to moisture condensation;
Acute or chronic exposure to corrosive, caustic or acidic agents, or to chemicals, chemical fumes or chemical mixtures or solutions;
Repeated exposure to temperatures above 121˚C (250˚F);
Repeated heavy abrasion, including mechanical wear and repeated scrubbing with industrial solvents, cleansers or scouring agents; and/or
Exterior exposure of metal structures and structural components.

Under Regulation 8, Rule 3, Standard 301 for organic architectural coatings, no person shall:

manufacture, blend, or repackage for sale within the District,
supply, sell, or offer for sale within the District, or
solicit for application or apply within the District

any architectural coating with a VOC content in excess of the new limit of 250 grams/liter as of January 1, 2004 . The previous limit had been 420 grams/liter and was instituted on January 1, 2003 . When fully effective, the BAAQMD expects the new requirements to reduce daily emissions of VOCs. Similarly, the Southern Coast Air Quality Management District (SCAQMD) in 1997 adopted Rule 1113, which aimed at reducing the amount of VOCs emitted by 50 percent by the year 2010.^{^[1]}

All VOC limits are based on the concept of reformulating existing coatings, either with water, exempt solvents, and/or currently available innovative resin technology.

The Coating Industry Responds
Representatives from coating industry associations believe that the new regulations threaten to have severe financial and coating performance impacts. It is too early to determine how the reduction in VOCs will affect organic architectural coatings, but many believe that there will be a high rate of failures. The failures will most likely be due to poor UV resistance, chemical resistance, and inferior application characteristics. Additionally, it is believed that low-VOC coatings are thicker and thus require more thinning, priming, topcoats, touch-ups, frequent recoating, substitution, and reactivity with harsh environments.

On the other hand, proponents of the new rule suggest that new low and zero-VOC coatings have equal, or in some cases superior, coverage area and scrubbing resistance.

In Southern California , the National Paint and Coatings Association filed a petition with the Orange County Superior Court claiming that the SCAQMD rushed to adopt new VOC requirements while under pressure by environmentalists. The District was accused of not evaluating the feasibility of the new regulation on the industrial coating manufacturing industry.

In June 1999 the California Painters Association (CPA) filed a suit against the SCAQMD, claiming the District had not studied the economic and environmental impacts associated with the rule as required under California environmental law. The CPA claimed that the cost of producing low- and zero-VOC coatings would most likely double the final cost from $6/gal to $12/gal. In addition, the CPA claimed that the new regulations will ban more than 7,000 products, or 90% of the market, currently available to consumers.^{^[2]}

Regulations in the Bay Area
Locally, BAAQMD has adopted Control Measure SS-11, which is aimed at controlling VOC content in architectural coatings used on stationary structures, appurtenances, and pavements. Control Measure SS-11 was based on SCAQMD’s Rule 1113 revisions adopted in 1996, 1998, and 1999. In the water and wastewater treatment industry, this means that coatings used for storage tanks, metallic piping, concrete structures, and floors will have new VOC limits. Some examples of these products include the following:

Product Name	Type and Application	VOC g/L
Carboline Bitumastic 50	Coal tar mastic used to protect steel and concrete substrates	360
Carboline Plasite 4110	Vinyl ester resin used for high chemical abrasion-resistant tank lining. NSF 61 approved	60
Tnemec Pota-Pox Series N140	Polyamidoamine epoxy used for the coating of potable water storage tanks, valves, and pipes. NSF 61 approved	284
Devoe AS-150	Epoxy Polyamide used for non-slip floor and deck coating	74
Sherwin-Williams ArmorSeal 300	Catalyzed epoxy floor coating used for chemical resistance in heavy duty non-skid areas	340

As the table shows, there is a large variation in the amount of VOCs contained in coatings with similar applications. Bitumastic 50, which is one of the most commonly used coal tar mastics for coating or repairing buried pipelines, has a VOC concentration of 360 g/L and would therefore be banned under the new regulations. Similarly, Plasite 4110 and Pota-Pox Series 20 are both NSF-approved, but the difference in their VOC content would make Plasite 4110 more favorable under the new BAAQMD regulations. By the same logic, Devoe AS-150 would be favored over ArmorSeal 300.

Product Selection
It is important to note, however, that VOC concentration is only one of the factors that should be considered when choosing the best coating. Many other factors should also be considered, incuding:

application in harsh environments;
application while in service;
substrate material—i.e., concrete, steel, or “other.”

V&A Consulting Engineers has extensive experience with all commonly used coating formulations and their application and performance. Please feel free to contact Mike Oriol, V&A’s Coatings Division Manager, for assistance with the selection of coating materials.

Additional information about South Coast Air Quality Management District Rule 1113 is available online at http://www.aqmd.gov/aqmp/Final_Amendment.pdf.

Information about Bay Area Air Quality Management District Control Measure SS-11 may be found at http://www.baaqmd.gov/dst/regulations/rg0803.pdf.

[1] “ California Regulation Stirs Up Paint Industry.” Materials Performance, Vol. 38, No. 10, October 1999, p. 18.

[2] Ibid, p. 21.