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
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TRFA and VOCs Background

• New US regulations are sharply reducing levels of
  VOCs 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

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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

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VOCs 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

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Ozone 8-hr non-attainment areas
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Impact Regulations are driving down allowable
VOC content in coatings
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TRFA 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

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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
• NPCA, ASTM, CARB, SCAQMD, EPA

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Insights into new method development

• Current method EPA 24
• 0.3 g sample thin sample dissolved in 3 ml
  solvent
• Hard to include fillers and other additives
• Cure at 110C for 1 hr in forced draft oven
• Benzyl alcohol has a low vapor pressure, but EPA
  method will encourage volatilization
• Methods should reflect real world use
• TRFA proposed experiments to characterize impact
  of temperature on VOC measurement

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TRFA 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

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Reduced bake temperature in EPA 24 gives more
realistic VOC results
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ASTM task group D01.21.24B proposed changes to
ASTM 2369

• ASTM task group leading efforts to change methods
  
• Addressing high (gt90) 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

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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

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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

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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)

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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