Over the last 10 years the paint and coatings industry has made great strides in emission reductions. Current and near-term regulations, as well as pollution prevention and waste minimization practices, have rapidly lowered the amount of emissions from the paint and coatings industry and will continue to do so. For example, changes in paint production formulation that were and will continue to be made in order to meet the national architectural industrial maintenance (AIM) rule regulatory levels, have significantly reduced volatile organic compound (VOC) emission levels. Additionally, many industry members have reduced levels further by compliance with many state regulations, such as California and others in ozone non-attainment areas, which have developed even more stringent VOC regulations than the national AIM rule.
Since the end of World War II, manufacturers of paints and other coatings have been producing low-VOC emitting coatings and focusing reformulation and R&D efforts on water-based paints, which give off far less VOC emissions than their oil-based counterparts. The development of waterborne coatings thus predates by decades the clean air laws in the United States and now constitute over 80 percent of the residential and commercial building coatings. The U.S. Environmental Protection Agency’s (EPA) national regulation for AIM coatings also has driven industry to make additional strides in low-VOC emitting, in-demand products.
The national AIM rule specifies national standards for the VOC content of AIM coatings and implements several requirements and programs to further these regulatory controls, including manufacturer registration, labeling and sales literature requirements, alternative compliance provisions, and certain exemptions. ACA and its member companies were instrumental in the development of the rule, and the association continues to promote EPA’s national AIM rule among all states and regional jurisdictions to ensure regulatory uniformity across the country.
Several states, including California, and several northeastern states, have introduced rules regulating VOC emissions from AIM coatings, some of which are more stringent than or differ from the EPA national AIM VOC rule. In the face of this, ACA continues to stress the importance of a single, uniform national rule with one uniform set of limits, labeling and other requirements, maintaining that national uniformity is sensible for both efficiency and focused research and development.
There is a real and urgent need for realistic, scientifically achievable limits in any AIM coatings regulation that will continue to allow industry to manufacture its products as demanded by the market. It is important to understand that manufacturers do not oppose making low-emission paints; their customers demand these products ― and current national and state regulations serve to reinforce this demand. Rather, they oppose regulations that impose a “one size fits all” standard for all coatings. To be effective, limits must be developed following thorough and consensus “exposure” testing of technology. Only this procedure will allow for low VOC coatings adequate in all respects to replace existing higher VOC coatings, without detrimentally affecting necessary performance properties.
Additionally, the industry is governed by EPA regulations that control emissions of Hazardous Air Pollutants (HAPs) from paint manufacturing facilities as well as numerous categories of industrial surface coatings operations. These industrial surface coating operations alone represent nearly 95 percent of original equipment manufacturers surface coatings that the industry supplies. The National Emission Standard for Hazardous Air Pollutants, or NESHAP rules establish national technology-based emissions standards, or maximum achievable control technology (MACT), that require add-on controls that capture HAP emissions at major source paint and coating manufacturing facilities. In addition, the MACT standards for surface coating operations allow these facilities to comply by using low HAP-containing coatings in lieu of installing controls. Thus, manufacturers of coatings have not only controlled HAPs at their own facilities; they have reduced HAPs in industrial coatings formulations to their customers’ demands and comply with all the certification, and testing and data submittal requirements. These reductions, at the facility and product levels, will continue with the near term NESHAP regulations for minor source facilities.