By Janie Smith
On September 24, 2013, ENV-A 4100 – Volatile Organic Compound (VOC) Limits for Consumer Products, which reduces emissions of volatile organic compounds by establishing caps on the VOC content of various consumer products, was anticipated to expire; therefore, the rules are suggested to be re-adopted. The revisions were proposed in accordance with the revisions to the Ozone Transport Commission (OTC) Model Rules to add definitions, add consumer product categories, change selected existing VOC limits, add new VOC limits for certain products and add specific requirements for paint thinners and multi-purpose solvents. The Clean Air Act created the OTC, an organization that is responsible for advising the United States Environmental Protection Agency (EPA) in regards to Ozone Transport issues and for developing and implementing regional solutions to the ozone issues in the Northeast and Mid-Atlantic regions.
VOC limits for specific products are scheduled to be increased for construction panel, floor covering adhesives and structural waterproof adhesives. There are also specific VOC limits that are suggested to be decreased such as those for general purpose adhesives, carburetor or fuel-injection air intake cleaners, aerosol engine degreasers, floor polishes/waxes (other than wood floor wax), aerosol general purpose cleaners, aerosol general purpose degreasers, and laundry starch/sizing/fabric finish products. A number of particular products are to have VOC limits added which include the following: adhesive removers, dual purpose air freshener/disinfectants (aerosol), anti-static products, automotive windshield cleaner, non-aerosol bathroom and tile cleaner, brake cleaner, disinfectant (aerosol and non-aerosol), electrical cleaner, electronic cleaner, fabric fresheners (aerosol and non-aerosol), footwear or leather care products, graffiti remover (aerosol and non-aerosol), hair styling products, multi-purpose solvent paint thinner, sanitizer (aerosol and non-aerosol), shaving gel, aerosol temporary hair color, toilet/urinal care products (aerosol and non-aerosol) and wood cleaner (aerosol and non-aerosol).
The proposed rule does allow for a sell-through of products manufactured prior to the effective date; this is in order for the existing stock to be sold out. The proposed rules also would forbid the sale of or manufacture of any multi-purpose solvent or paint thinner that encompasses any methylene chloride, perchloroethylene or trichloroethylene, subject to allowances for sell through and for impurities in a combined amount equal to or less than 0.01 percent by weight.