Tertiary Butyl Acetate Regulations
Q. Has the TCEQ (Texas Commission on Environmental Quality) approved TBAC (tertiary butyl acetate) as a VOC-exempt solvent? I am considering using it in formulas for paint thinner, in parts washing and for paint equipment cleanup at a large coating applicator job shop.—E.M.
A. The military has done a significant amount of work to qualify TBAC as a viable alternative in hand-wipe cleaning applications for the removal of dirt, grease, soot and paint debris from various parts used in military maintenance applications. The U.S. Environmental Protection Agency also has found TBAC to be a viable solvent alternative. It is both considered to be free of hazardous air pollutants (HAPs) and is listed as a VOC-exempt solvent in the Nov. 29, 2004 Code of Federal Regulations §51.100(s).
I cannot find specific evidence that the Texas environmental authority has ruled against the EPA ruling or instituted other restrictions. Generally, states are required to adopt the Federal environmental regulations as their own unless they choose to make their regulations restrictive. The best reference I could find related to this rule is a TCEQ publication that essentially appears to adopt the EPA regulations without amendment as part of its State Implementation Plan (see short.pfonline.com/TXcomm).
In summary, it appears that the EPA has ruled that the TBAC is considered exempt from VOC regulation, however, you should still contact a local Texas attorney familiar with environmental regulations for a more definitive recommendation.