EPA Publishes Reactivity
Rule for Aerosol Coatings
The EPA’s new final rule for National Volatile Organic Compound (VOC) Emission Standards for Aerosol Coatings pares down the Table of Reactivity Factors from over 800 compounds to approximately 40 compounds. It defines product categories and the Table of Standards in a manner that mirrors the current California reactivity regulation. The EPA rule differs from California in that the agency has chosen not to specifically exempt products that could be confused as aerosol coatings. Belt dressing, cleaner, dye, electrical coating, ink, layout fluid, leather preservative/cleaner, lubricant, maskant, mold release and rust converters are not defined.
The EPA rule does not ban ingredients that are hazardous air pollutants (HAPS), such as methylene chloride or ozone-depleting substances. The labeling requirements are similar to the California requirements, with the exception of the EPA proposed requirement for the name and contact address of the regulated entity. EPA’s proposal requires specific recordkeeping for the manufacture of each product category and each batch of each product category.
The effective date of this 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. Companies subject to this rule must provide information about the amounts of each VOC in their products every three years, beginning with data for calendar year 2010.