Report from the TRFA VOC Task Force

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Report from the TRFA VOC Task Force. Charles M. Bartish Air Products Charles Zarnitz CVC Tom Geriak Garland Floors Derek Kincaid Huntsman. September 11, 2006 Montreal, Canada. TRFA and VOC’s: Background.
Report from the TRFA VOC Task Force Charles M. Bartish Air ProductsCharles Zarnitz CVCTom Geriak Garland FloorsDerek Kincaid HuntsmanSeptember 11, 2006 Montreal, CanadaTRFA 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
  • 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
  • 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
  • Ozone 8-hr non-attainment areasImpact: Regulations are driving down allowable VOC content in coatingsTRFA 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
  • 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
  • Current method EPA 240.3 g sample; thin sample dissolved in 3 ml solventHard to include fillers and other additivesCure at 110°C for 1 hr in forced draft ovenBenzyl alcohol has a low vapor pressure, but EPA method will encourage volatilizationMethods should reflect real world useTRFA proposed experiments to characterize impact of temperature on VOC measurementBenzyl alcohol vapor pressureInsights into new method developmentTRFA 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
  • Reduced bake temperature in EPA 24 gives more realistic VOC resultsASTM 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
  • 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
  • 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
  • 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)
  • 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
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