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Volatile Organic Compounds - VOCs

 

What are "VOCs"?

The acronym VOC stands for “Volatile Organic Compound”. In general, VOCs are chemicals that contain carbon and evaporate at room temperature and pressure. The term includes all sorts of common solvents as well as gases (e.g. mineral spirits, xylene, propane).

Why are we concerned about VOCs?

VOCs evaporate and chemically react with car emissions and other pollutants to form ground-level ozone (i.e. smog). Ozone is a reactive molecule that attacks the lungs. Therefore, smog contributes to respiratory problems such as asthma, pneumonia and bronchitis.

How are VOCs regulated?

VOCs can be regulated by various levels of the government: federal, state and local. The U.S. Environmental Protection Agency (EPA) has established ‘safe’ levels of ground-level ozone and developed air quality standardsto ensure compliance. In order to meet EPA’s standards, several states adopted regulations that limit the amount of VOCs in consumer products by product type and category. These regulations are generally referred to as the Consumer Product Regulations.

California was the first state to adopt these regulations. Since then, other states have followed their lead. The Ozone Transport Commission (OTC) has developed Model Rules for Consumer Products that memberstates can use a guide to promulgate their own Consumer Product Regulations. The Lake Michigan Air Directors Consortium (LADCO) consists of states that border Lake Michigan and is another group that uses the OTC Model Rules. Over the years, the Consumer Product Regulations have been updated to include more product categories and reduce the VOC limits imposed on existing product categories. These updates, since they take place at the state not federal level, have resulted in a patchwork quilt of regulations. Each state’s rules are similar but not identical. States that have adopted Consumer Product Regulations include:California, Connecticut, District of Columbia, Delaware, Indiana, Illinois, Maine, Maryland, Massachusetts, Michigan, New Hampshire, New Jersey, New York, Ohio, Pennsylvania, Rhode Island, Utah and Virginia. It isworth mentioning that a federal Consumer Products Regulation does exist. However, it has been virtually obsoleted by the more stringent state regulations.

The air quality in some areas of the country, most notably southern California, is so poor that local governments decided there was a need to further limit VOCs. The main difference between these local regulationsand the state-level Consumer Product Regulations is the approach they take. The Consumer Product Regulations restrict the SALE OF certain products while local rules generally restrict the USE OF productsin certain applications. Also, the Consumer Product Regulations do not regulate industrial products (those used in the manufacturing process) while local rules typically cover any product if it is used in a particular application. This requires the end-user to make informed decisions about which products are compliant for their particular use. Local regulations, especially those in California’s South Coast Air Quality Management District (SCAQMD), can be very confusing. Since the type of discussion that would be required to explain these rules is beyond the scope of this guide, we recommend partnering with product manufacturers and distributors/retailers to determine the exact impact of these regulations on your business.

What is a Consumer Product?

The Consumer Products Regulations define a consumer product to be a chemically formulated product used by household and institutional consumers. Basically, unless the product is used in a manufacturing process, it is a consumer product and must meet the VOC limits specified in the Consumer Products Regulations in order to be sold.

What does "Not for retail sale - For use in the manufacturing process only" mean?

Consumer Products Regulations allow the sale of high-VOC lubricants and general purpose degreasers if these products are sold exclusively to establishments that manufacture or construct goods or commodities and are labeled as follows:

• In states adopting OTC Model Rule: “not for retail sale”

• In California: for “use in the manufacturing process only”

What does "chlorinated solvent restriction" mean?

Certain states are restricting the use of methylene chloride, perchloroethylene, and trichloroethylene in select product categories. LPS products are not affected by this restriction.

What is the Distributor's responsibility? 

When the sale of a product is regulated, the distributor is responsible for selling VOC compliant products in affected states and ensuring that products labeled “Not for retail sale – for use in the manufacturing process only” are sold exclusively to manufacturing establishments. Enforcement action, including fines, could be taken against a distributor that fails to comply with sales restrictions.

What does LPS offer as a solution? 

LPS provides a wide variety of 50 State Compliant products and continuously monitors developments affecting consumer products to ensure its customers have the latest information available. We offer the LPS VOC Guide  to assist our customers in determining the compliance status of regulated products as well as a complete listing of our 50 State Compliant items.

Dowloads:

LPS VOC Guide

VOC Guide

 

LPS 50 State VOC Compliant Products Flyer

LPS VOC compliant 50 states