Law & Order

EPA Expands List of VOCs Subject To Aerosol Paint Rule

The U.S. Environmental Protection Agency (EPA) has added 128 substances to the list of chemicals sometimes found in aerosol paints that emit volatile organic compounds (VOCs). The primary substances include formaldehyde, ethanol, benzene, propane and vinyl chloride. VOCs react with nitrogen oxides in the presence of sunlight to form ground-level ozone, which has been linked to respiratory ailments. 

Spray paint manufacturers must now determine whether their products contain the newly-added substances and still comply with aerosol coating emissions limits.  

Starting in January 2009, the EPA began limiting VOC emissions from aerosols such as spray paints, primers and clear coatings. The EPA rule, issued in 2007, is similar to a California standard and applies to manufacturers and distributors of aerosol products which are used for both industrial applications and by “do-it-yourselfers.”

The rule focuses on encouraging manufacturers to use less reactive VOC ingredients in their product formulas since certain chemicals are less likely to produce ozone. Toluene and xylene were specific targets of the rule.  

According to the EPA, nearly 85% of the spray paints used in the United States in 2007 were produced by three companies, and the aerosol coatings already complied with the California regulations. Companies subject to the rule must inform the EPA every three years regarding the amount of VOCs in their products.

Manufacturers that make limited quantities of aerosol spray paints containing VOCs (less than 7,500 kilograms/8.3 tons) on an annual basis are exempt from the regulation. Companies that have not previously manufactured or distributed aerosol paints in California have until January 2011 to comply with the EPA rule.  

For details, contact Stuart Gosswein.