report from the trfa voc task force charles m. bartishair products charles zarnitzcvc tom...

Report from the TRFA VOC Task Force

Charles M. Bartish Air ProductsCharles Zarnitz CVCTom Geriak Garland FloorsDerek Kincaid Huntsman

September 11, 2006 Montreal, Canada

2 Bartish Sept. 2006TRFA VOC Montreal

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Good Chemistry at Work

TRFA and VOC’s: Background

New US regulations are sharply reducing levels of VOC’s acceptable in coatings formulations

Significant discussion in Regulatory Affairs session in Ft. Lauderdale re new VOC legislation

Coatings, Civil Engineering, Flooring Committee requested effort to address issue for TRFA

Team formed to address issue, focused on needs of TRFA companies

Purpose of this presentation is to update the membership on accomplishments to date


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Why is there concern about VOCs?

Any volatile compound of carbon is a VOC for regulatory purposes, unless specifically exempted

VOC + NOx + Sunlight O3

– Precursors: motor vehicle exhaust, industrial emissions, gasoline vapors, chemical solvents

– Sunlight, hot weather lead to harmful concentrations– Winds carry O3 and its precursors miles from sources

Ozone is harmful to health and the environment– Triggers health problems even at very low levels– Long-term exposure may cause permanent lung

damage– Damages plants and ecosystems


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VOC’s are regulated federally and locally Federal Clean Air Revisions Act of 1996

– resulted in stricter national VOC regulations. – AIM (Architectural and Industrial Maintenance) regulations

became effective in 1999. – EPA "non-attainment" areas exceeding 8-hr standards

Some state regulations even tougher and impact coatings– California (CARB) and New Jersey strict standards– Southern California (SCAQMD) has the toughest rules

Ozone Transport Commission (OTC) regulations– Areas from Northern Virginia to New England adopted

lower VOC limits January 2005. More regulations coming

– LADCO – Lake Michigan Air Directors Consortium– VISTA – Visibility Improvement State and Tribunal

Association of the Southeast


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Ozone 8-hr non-attainment areas


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Impact: Regulations are driving down allowable VOC content in coatings

VOC limit, gram/liter

Coating Category

US EPA today

CARB / OTC

SCAQMD Previous

SCAQMD July 06

Flat 250 100 100 100

Non-flat 380 150 150 50

Primer 350 200 200 100

Floor 400 250 100 50

Wood 600 250 250 100

Concrete 600 400 400 100

Indus. Maint. 450 250 / 340 250 100


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TRFA formed the VOC Task Force

Industry team members with interest, commitment to address issue

– Charlie Bartish Air Products and Chemicals– Charlie Zarnitz CVC Specialty Chemicals– Tom Geriak Garland Floors– Derek Kincaid Huntsman

Significant participation from TRFA administration– Jeri Church– Kathy Fatz

Benzyl alcohol suppliers asked, but declined to participate


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Task Force approaches outlined

Focus on VOC issues related to benzyl alcohol– Common ingredient in many formulated products– Limited volatilization; formulation dependent – Consider alternate performance-equivalent solvents;

supplier feedback pessimistic based on work to date

Define why benzyl alcohol should not be classified VOC– Existing analytical methods (EPA 24, ASTM 2369)

overstate VOC impact of benzyl alcohol– Develop and get new method approved– Components can be excluded, i.e. reactive diluents– EPA process, although tedious, exists to delist chemicals

from VOC list

Work closely with other organizations with common interests

– NPCA, ASTM, CARB, SCAQMD, EPA


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Insights into new method development

Current method EPA 24– 0.3 g sample; thin sample

dissolved in 3 ml solvent– Hard to include fillers and

other additives– Cure at 110°C for 1 hr in

forced draft oven

Benzyl alcohol has a low vapor pressure, but EPA method will encourage volatilization

Methods should reflect real world use

TRFA proposed experiments to characterize impact of temperature on VOC measurement

Benzyl alcohol vapor pressure


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TRFA experiments to characterize impact of temperature on VOC VOC measurement should be dependent on

temperature of bake oven

TRFA companies provided three hardeners containing benzyl alcohol from 30 – 50%.

Formulated product gave benzyl alcohol in the range of 13 – 18%.

CVC measured VOC content by EPA 24 on the formulated product, but varied temperature of test to measure impact


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Reduced bake temperature in EPA 24 gives more realistic VOC results

VOC, g/l (benzyl alcohol)

Bake Temperature, deg C

System 50 75 100 110 Actual

A -1 26 66 82 183

B 0 25 86 92 193

C 47 71 95 153 140

control -1 -5 -1 -4 0


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ASTM task group D01.21.24B proposed changes to ASTM 2369 ASTM task group leading efforts to change methods

– Addressing high (>90%) solids coatings– Fred Gelfant (Stonhard) chairs task group

Proposed changes include:– Sample size not limited to 0.3 g– Apply at thickness for product intended use– No solvent dilution required in test– Up to 24-hr cure time

These changes could benefit the benzyl alcohol case. – Stonhard data supports conclusion– TRFA will work more closely with ASTM

EPA letter will allow use of changes in certain areas


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EPA exemption letter expected to allow use of revised procedure EPA committed to issue exemption letter

– Timing still unclear

Will allow changes to VOC test procedure for two-component, high solids coatings

Revision of ASTM 2369 will include all changes described earlier


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Next steps and what you can do to help Gain active support from CARB / SCAQMD re

oven temperature change in method

Validate Task Force lower temperature oven test results against proposed ASTM method changes

Volunteer for ASTM analytical round robin test program

Provide supporting data that benzyl alcohol has remained in coatings over time

Join, support ASTM committee D.01 and signal approval of changes to ASTM D2369


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Delisting benzyl alcohol as VOC or finding replacement is a long shot NPCA has experience leading effort to delist

tertiary-butyl acetate as VOC– Nearly a five-year effort – Test data necessary– Three year effort abandoned on benzyl alcohol

Finding alternate, drop-in carrier to benzyl alcohol not likely in near future

– Supplier companies have had programs to identify alternate carriers

– Challenge is to find performance equivalent materials (reactivity, physical properties)


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Conclusions

New VOC regulations require a response from TRFA formulators to meet new requirements

Formulations containing benzyl alcohol need attention to meet new VOC limits

TRFA VOC Task Force is formed and has reviewed several options for solutions

Benzyl alcohol delisting or replacement low probability to meet time needs

Modification of analytical methods EPA 24 / ASTM 2369 offers good potential for success and may be usable in near future

TRFA VOC Task Force will work closely with ASTM to influence industry forward program

report from the trfa voc task force charles m. bartishair products charles zarnitzcvc tom...

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