The American Coatings Association says that many states have established, or are in the process of adopting, industrial solvent cleaning regulations that could impact coatings. The trade group says these rules could impact the type of solvents that are used to clean process equipment, tanks, lines, etc.
"Cleaning solvents would need to meet a volatile organic compound (VOC) limit of 50 g/l, which means that current cleaning solvents would need to be disposed of and exempt solvents (acetone for example) be used their place," the ACA says.
These rules regulate the solvents that used to clean process equipment for manufacturing operations. In general, these rules apply in ozone nonattainment areas to facilities that have at least 15 lb./day of solvent cleaning VOC emissions (uncontrolled). Several states have either adopted or are very close to adopting rules, including Ohio, Indiana, Illinois, Maryland, Connecticut, Wisconsin, New Hampshire, the District of Columbia, Delaware, Texas, Missouri, and North Carolina.
ACA has been actively engaged with approximately 20 states advocating that they adopt more reasonable solvent cleaning standards that would allow continued use of the higher VOC solvents currently used in the industry, with great success. Instead of a 50 g/l limit on cleaning solvents, the revised rules generally allow facilities to use either higher VOC cleaning solvents and work practices among other options.
In addition, while ACA has been able to minimize the burden of most of these rules, these rules do include recordkeeping requirements that require the following information be documented: 1) name, identification, and volume of each VOC-containing cleaning solution; 2) the volume of each fresh cleaning solvent used for cleaning; and 3) volume of cleaning solvent recovered for either offsite or onsite reuse or recycling for further cleaning use.
ACA has developed a state matrix of the industrial solvent cleaning rules and has made it available to its members.
The U.S. Environmental Protection Agency’s Industrial Solvent Cleaning Control Technique Guideline (CTG) that provides additional background on this issue may be accessed HERE.