(via sce) products less or equal than 1 liter ... agencies are regulating paint thinners and paint...

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AIM rules (except clear wood finishes in SCAQMD), exempt (via SCE) products less or equal than 1 liter

Flats, Nonflats – Effective 1/1/2019 - 8 ounces and touch-up only

Industrial Maintenance – Effective 1/1/2019, 1 liter, touch-up only and not for “display for sale” at retail outlet

Rust Preventatives – Effective 1/1/2020 (unless in 2019 Board extends effective date)- 8 ounces and touch-up only

2 year sell through

Effective February 5, 2016, the following were eliminated from SCE:◦ Concrete-Curing Compounds For Roadways and Bridges;

◦ Magnesite Cement Coatings;

◦ Multi-Color Coatings;

◦ Pre-Treatment Wash Primers;

◦ Roof Primers, Bituminous;

◦ Stone Consolidants;

◦ Repair and Other Swimming Pool Coatings;

◦ Wood Preservatives

Effective January 1, 2018, eliminate from SCE◦ Tub and Tile Coatings;

◦ Clear and Pigmented Shellacs;

◦ Reactive Penetrating Sealers

2 year sell through

Building Envelope Coatings – 50 g/l (1/1/2019)

Recycled Coatings – 150 g/l (1/1/2019)

Colorants would need VOC content and date code by 1/1/2017

Form Release (100) and Bond Breaker (350) coatings to be moved to a “Release Agent” rule later in 2016 – likely 50 g/l limit

SCE Antibundling – kits are now ok (multiple containers of different coating categories)

EPA Method 24 is the current test method to determine VOC content of coatings

Below 150 g/l – Method 24 can be problematic

SCAQMD added Method 313 and ASTM D6886 to the AIM Rule 1113

Method 313 Problem - semivolatile compounds that would not be VOCs under Method 24 could be VOCs under Method 313

SCAQMD developing “an exclusion pathway”, compounds would be “excluded” if less volatile than methyl palmitate (VOC marker) – pentaethylene glycol would be excluded

SCAQMD to conduct a roundrobin and further look into non-film forming oils – conference call on April 20

CARB is a CA agency that coordinates AIM regulatory activities for 35 CA Air Districts

Periodically develops Suggested Control Measure (SCM) – 1977, 1985, 1989, 2000, and 2007

Local Air Districts have jurisdiction over and regulate the VOC content of AIM coatings via local rulemakings

CARB working on AIM Survey

ACA has requested CARB develop a new SCM – since more reasonable than SCAQMD Rule 1113

San Joaquin developing control measures in December, advocate against SCAQMD Rule 1113

CARB adopted revised AIM Suggested Control Measure in October 2007

13 CA Air Districts have adopted 2007 SCM:◦ Bay Area ◦ Ventura◦ San Joaquin ◦ Imperial ◦ Kern ◦ Placer ◦ Mojave Desert ◦ Monterey ◦ Antelope Valley ◦ Santa Barbara ◦ Feather River ◦ San Diego (adopted June 24, 2015, effective date 1/1/2016)◦ Sacramento (adopted September 24, 2015, effective date March 24, 2016)

El Dorado, and Yolo Solano in 2016 Helpful website -

http://www.arb.ca.gov/coatings/arch/meetings/schedule2007.htm

CT, DE, DC, ME, MD, MA, NH, NJ, NY, PA, RI, VT, and VA

OTC adopted the “Phase II” Model Rule (based on 2007 SCM) on June 3, 2010 - individual OTC states must adopt this “model” rule

Maryland – Notice of Proposed Action (NPA) in MD Register on 1/22/16. Public workshop on 2/22/16. Regulation to become effective 4/25/16, compliance date 1/1/2017

Possible other OTC State adoptions: DE and NY late 2016

Includes WI, IL, IN, MI & OH

Ohio has adopted OTC Phase I (compliance date 1/1/2009). Ohio made minor revisions (anti-bundling language, faux finish labeling) – effective 10/18/2013

Illinois adopted OTC Phase I (compliance date 7/1/2009)

Indiana adopted OTC Phase I on 10/1/2010, with a compliance date of 10/1/2011

Wisconsin and Michigan waiting for National AIM Rule Amendments

Rule is based on the OTC Phase II Model Rule

Rule applies only to 7 counties in Utah (Box Elder, Cache, Davis, Salt Lake, Tooele, Utah, and Weber)

Adopted on 9/11/2013

January 1, 2015 compliance date

EPA has been receiving letters from OTC, various states to amend the National AIM rule

EPA needs to finish several court ordered deadline projects before starting work on the AIM rule

EPA would like to include:◦ SCAQMD Rule 1113 colorant VOC limits◦ Increase the exceedance fee◦ Include both OTC Phase I and Phase II Rule VOC limits

EPA project person has been assigned, may start amendment process in near future

Agencies are regulating paint thinners and paint cleanup products – only exempt compounds can be used

SCAQMD Rule 1143, 25 g/l limit effective 1/1/2011

CARB Consumer Product Rule, 3% VOC by weight limit effective December 31, 2013.

NH adopted the 2012 Consumer Product OTC Model Rule on 2/21/2014, 3% limit, effective January 1, 2017

Utah adopted OTC Model rule on 9/11/2013, 3% limit, effective 1/1/2015 (Multi-purpose solvents) and 1/1/2016 (Paint Thinners)

Delaware – 3% limit for Paint Thinners; adopted on 2/1/2016, compliance date of 1/1/17

Maryland - Consumer Products Stakeholder Meeting 4/5/2016, likely proposed compliance date 1/1/2017

The Clean Air Act requires the Environmental Protection Agency (EPA) to review the National Ozone Standard every five years to protect public health

In 2008 EPA lowered the standard to 0.075 parts per

million (ppm) On October 1, 2015, EPA lowered the standard to

0.070 ppm

Lower Volatile Organic Compound (VOC) regulations

More stringent coating application facility permits

◦ permit conditions

◦ lower factory applied (OEM) VOC standards

◦ add-on controls

◦ more efficient spray guns

VOC standards – new limit will cause another round of lower

limits and States will look to California VOC rules (including

SCAQMD)

EPA Identify Nonattainment Areas (marginal, moderate, severe)

Implementation

2017

Moderate and Severe develop plans

Marginal (new States)

Moderate, Severe and Extreme attainment

By 2021

By 2020

By 2037

AIM VOC Updates – nearly weekly updates to over 300 industry representatives –

AIM Regulatory Reference – ACA website that has general overview of AIM regulations, links, and tools -

Tools – VOC limit table, sell through table, reporting requirement table, monthly update slides

AIM VOC Webinars - regulatory webinar updates to individual member companies (if your interested, please send me an email)

ACA Sustainability Workgroup (includes Green Building issues)