VOC Regulations from US EPA, OTC, CARB, SCAQMD and Environment Canada

These regulations lower the amount of Volatile Organic Content (VOC) emitted from architectural and industrial maintenance (AIM) coatings. All states are affected, with greatest changes taking place in Canada, California, the Northeast, and Mid-Atlantic regions. By January 1, 2009, most of these areas and states will have already been affected. Canada will be affected in April, 2010

These regional VOC regulations (OTC, CARB, SCAQMD, etc.) differ from U.S. Environmental Protection Agency (USEPA) national VOC standards. In general, the new regulations are more restrictive in lowering the maximum amount of VOCs allowed in these areas. USEPA regulations also permit manufacturers to pay an "exceedance fee" in order to supply non-compliant specialty products. That is not allowed in the areas adopting the new regulations.

Although the regulations affect what products distributors in these areas can buy from Vexcon after effective dates, "sell-through" provisions let distributors sell inventory of affected coatings manufactured on or before the effective dates. The new regulations affect the following product categories sold by Vexcon:

Waterproofing Concrete/Masonry Coatings
Epoxy Coatings
Cure & Seal Coatings
Penetrating Sealers
Water & Stain Repellents
Form Treatments
Paver Treatments

All Vexcon materials comply presently with these VOC rules. With some small exceptions regions and states vary significantly, and the tables below include example limits on a range of product categories. This information has been obtained from sources believed to be accurate. The most current information can be obtained by consulting each agency. Consult your local, state, regional or federal authorities for more information on rules applicable to your area. Contact Vexcon Technical Service or your Vexcon representative at (215) 332-7709 or (888) 839-2661 for more information on how our materials comply with various rules.

Category Examples under Various State and Regional Standards

National AIM rule (regulated by EPA) = US EPA AIM = Federal AIM VOC 40 CFR Part 59 Subpart D under authority of Section 183(e) of the Clean Air Act

Bond Breakers	600 g/L
Concrete Curing Compounds	350 g/L
Concrete Curing and Sealing Compounds	700 g/L
Concrete Surface Retarders	780 g/L
Form Release Compounds	450 g/L
Industrial Maintenance	450 g/L
http://www.epa.gov/ttn/atw/183e/aim/aimpg.html http://www.epa.gov/EPA-AIR/1998/September/Day-11/a22659.htm New Rule expected 2007, implementation 2009 Expected to follow OTC Phase I Model Rule

Canada EPA and Environment Canada: CEPA categories, effective April 2010

Follows OTC AIM Phase 1 Categories and Limits
Any other Industrial Maintenance Coating	340 g/L
Bond Breakers	350 g/L
Concrete Curing Compounds	350 g/L
Concrete Surface Retarders	789 g/L
Floor Coatings	250 g/L
Form Release Compounds	250 g/L
Mastic Texture Coatings	300 g/L
Specialty Primers, Sealers, Under Coaters	350 g/L
Stain	250 g/L
Waterproofing Sealer, Concrete/Masonry	400 g/L
Waterproofing Sealer, other Film Forming	250 g/L

California except South Coast: CARB SCM (Suggested Control Measure) categories, Nov 2006

Bond Breakers	350 g/L
Concrete Curing Compounds	350 g/L
Industrial Maintenance	250 g/L
Primer	200 g/L
Stain	250 g/L
Waterproofing Concrete / Masonry Sealers	400 g/L
http://www.arb.ca.gov/coatings/arch/VOCLimits.htm * New rule adapted, implementation January, 2010

California South Coast: SCAQMD Rule 1113, July 1 2007 (plus Antelope Valley/Mojave Desert)

Bond Breakers	350 g/L
Concrete-Curing Compounds	100 g/L (350 g/l if labeled For Roads & Bridges Only)
Floor Coatings	50 g/L
Industrial Maintenance Coatings	100 g/L
Primer	100 g/L
Stain (interior)	100 g/L
Waterproofing Concrete/Masonry Sealers	100 g/L
http://www.aqmd.gov/rules/download.html Rule 1113

Northeast and Mid-Atlantic: OTC Phase I Model Rule, January 1 2005

Industrial Maintenance	340 g/L (Model Rule is 250 g/L; states select 340 g/L)
Primer	200 g/L
Stain	250 g/L
Waterproofing Concrete/Masonry Sealers	400 g/L
http://www.otcair.org *OTC Phase II Revision expected for early 2009

Massachusetts Final Rule 310 CMR 7.25 (11), effective January 1, 2009 (follows OTC)

Bond Breakers	350 g/L
Concrete Curing Compounds	350 g/L
Concrete Surface Retarders	780 g/L
Floor Coatings	250 g/L
Form-Release Compounds	250 g/L
Industrial Maintenance Coatings	340 g/L
Non-Flat Coatings	150 g/L
Non-Flat High Gloss Coatings	250 g/L
Primers, Sealers, and Under Coaters	200 g/L
Waterproofing Concrete/Masonry Sealers	400 g/L
http://www.mass.gov/dep/air/laws/aimcpfr.pdf

Ohio effective rule: Ohio Administrative Code (OAC) 3745-113 Effective January 1, 2009:

Bond Breakers	350 g/L
Concrete Curing Compounds	350 g/L
Floor Coatings	250 g/L
Form-Release compounds	250 g/L
Industrial Maintenance Coatings	340 g/L
Waterproofing Concrete/Masonry Sealers	400 g/L
http://www.epa.state.oh.us/dapc/regs/3745-113/3745-113-03f.pdf

Key to Acronyms

AIM: Architectural, Industrial, Maintenance
CARB: California Air Resource Board = Cal/EPA ARB
CEPA/EC: Canada Environmental Protection Agency/Environment Canada
EPA: Environmental Protection Agency
LADCO: Lake Michigan Air Directors Consortium (Illinois, Indiana, Mich., Wisc.)
MRPO: Midwest Regional Planning Organization (IL, IN, Mich., Ohio, Wisc.)
OTC: Ozone Transport Commission (CT, DC, DE, MA, MD, ME, NH, NJ, NY, PA, RI, VT, VA)
SCAQMD: South Coast Air Quality Management District (California, Los Angeles area)
VOC: Volatile Organic Compound

Information contained herein is for informational purposes only and is based solely on information available to Vexcon and the general public as of the date of this document. Vexcon does not guarantee the accuracy of this information nor makes any assumptions or predications what so ever.