New Colorant VOC Limits Set for 2014
The United States’ first VOC regulation on colorants for architectural and industrial maintenance coatings is poised to take effect New Year’s Day.
The changes have been pending since June 2011, when the South Coast Air Quality Management District (SCAQMD) approved a number of amendments to the district’s Rule 1113 on architectural and industrial maintenance coatings.
The changes include a provision lowering Volatile Organic Compounds content limits on a number of specialty coatings.
Also approved were labeling requirements for coatings sold in one-liter or smaller containers under the small-container exemption.
All of those changes will go in effect Jan. 1, 2014.
The district also approved the elimination of the rule’s VOC “averaging” provision, which gives coatings manufacturers a flexibility option in meeting the rule’s stringent VOC-content provisions. The averaging provision will be eliminated on Jan. 1, 2015, according to officials.
The Rule 1113 changes approved by the district do not include lower VOC limits on primers, sealers and undercoaters. Those reductions had been among the rule amendments originally proposed by the district’s staff, but strongly opposed by coatings-industry representatives. The VOC content limit for those products remains at 100 grams per liter.
The influential South Coast agency has long imposed the nation’s toughest VOC rules on field-applied paints and coatings. The rules are designed to help reduce air-pollution levels in the smog-plagued Los Angeles air basin.
South Coast's actions are closely watched nationwide as a potential bellwether for future regulatory changes elsewhere.
VOC Limits on Colorants
The new VOC limits are 50 grams per liter for architectural coatings (excluding industrial maintenance coatings), 50 g/L for water-borne industrial maintenance coatings, and 600 g/L for solvent-borne industrial maintenance coatings.
The VOC limits are only for colorants used to tint coating at the point of sale (POS), including retail outlets that add colorant to a coating container to obtain a specific color.
Colorant added at the factory or at the worksite is not subject to the VOC limit, according to the district. Containers of colorant sold at the POS for use in the field or on a job site are also not subject to the limit.
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The South Coast agency has long imposed the nation’s toughest VOC rules on field-applied paints and coatings. The rules are designed to help reduce air-pollution levels in the smog-plagued Los Angeles air basin.
There is no “sell-through provision” for this change, district officials note. Therefore, all colorants used to tint coatings at the POS after Jan. 1 must meet the new VOC limits.
The addition of VOC-containing colorants or tints at the point of sale increases the VOC content of coatings as applied. Thus, coatings products marketed as low- or even zero-VOC may actually contain significant amounts of VOCs after tinting with VOC-containing colorants.
The amount of VOC content after tinting can vary, depending in part on the color. Light or pastel colors require lower levels of colorant to achieve the target color, while greater amounts are needed for medium, deep or accent colors.
Colorants containing near-zero VOCs have been developed by a number of companies.
New Limits on Several Product Types
The amendments to Rule 1113 also include lower VOC limits on several categories of specialty coatings. Those categories and VOC limits, also effective Jan. 1, are as follows.
The amendments of June 2011 also revised subparagraph (f)(1), referred to as “the small container exemption.” They require, as of Jan. 1, 2014, that coatings sold in one-liter or smaller containers to comply with all provisions of the rule, except the VOC limits.
Hence, all other rule requirements, including labeling mandates, would apply to coatings sold in all container sizes.
In 2013, coating manufacturers expressed concern with labeling very small containers, such as sample sizes of two fluid ounces or less and stains sold in the shape of a pen containing about 1/3 of a fluid ounce of product, according to district officials.
Therefore, the rule was amended on Sept. 6, 2013, to exempt coatings sold in two fluid ounces or smaller containers from the labeling provisions.
The officials also note there is no sell-through provision for this change. Therefore, coatings sold in containers larger than two fluid ounces must comply with all of the Rule 1113 labeling requirements, including VOC content and date of manufacture or a code indicating the date of manufacture.
Also effective Jan. 1, 2014, the VOC content must be displayed as follows: