The aerosol coatings rule, which was last updated in 2008, establishes nationwide VOC reactivity-based emissions standards to address VOC emissions from the aerosol spray paints category.
The proposed amendments to the rule include:
- Update coating category product-weighted reactivity limits for aerosol coatings categories.
- Add new compounds and reactivity factors (RFs).
- Update existing reactivity values.
- Revise the default RF.
- Amend the thresholds for regulated compounds.
- Add electronic reporting provisions.
These changes are in response to industry trade associations’ requests for the EPA to revise the national VOC standards so they are consistent with state standards such as California’s.
Comments received when the rule was proposed indicated support from industry trade associations such as the American Coatings Association (ACA), Household & Commercial Products Association (HCPA), and the National Aerosol Association (NAA) and manufacturer Seymore of Sycamore.
In comments submitted when the amendments were proposed, the ACA requested “a compliance date of two years after publication in the Federal Register for the updated coatings category limits” to “ensure that industry has sufficient time to reformulate their products and adapt their distribution methods to effectively and efficiently implement the amended rule’s requirements.”
Additional comments from the ACA seek to have the revised rule:
- Further align with California’s default value of 11.97 g O3/g VOC.
- Not include a sell-through provision for any products manufactured before the new reactivity limits become effective.
- Update definitions, and add several new definitions.
- Allow regulated entities to petition the EPA to change the reactivity value of existing compounds, and provide the ability to add new compounds.
- Eliminate triennial reporting requirements for aerosol coatings manufacturers, or, alternatively, amend the reporting requirement to every 5 or 10 years.
- Establish a clear process with a set timeline for review and approval of petitions to add new compounds to Tables 2A, 2B, and 2C.
- Clarify the requirements for providing notification to the EPA of new aerosol coating formulations.
- Remove the requirement to report the trade name and solvent mixture manufacturer for hydrocarbon solvents.
- Allow industry to start converting labels before the new compliance deadline.
Both the HCPA and the NAA support the ACA’s suggested revisions to the proposed rule.