Report from the TRFA
VOC Task Force
Charles M. Bartish
Charles Zarnitz
Tom Geriak
Derek Kincaid
Air Products
CVC
Garland Floors
Huntsman
September 11, 2006
Montreal, Canada
TRFA and VOC’s: Background
 New US regulations are sharply reducing levels
of VOC’s 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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VOC’s 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
VOC limit, gram/liter
Coating
Category
US EPA
today
CARB /
OTC
Flat
250
100
100
100
Non-flat
380
150
150
50
Primer
350
200
200
100
Floor
400
250
100
50
Wood
600
250
250
100
Concrete
600
400
400
100
Indus. Maint.
450
250 / 340
250
100
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SCAQMD SCAQMD
Previous July 06
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
Benzyl alcohol vapor pressure
 Current method EPA 24
– 0.3 g sample; thin sample
dissolved in 3 ml solvent
– Hard to include fillers and
other additives
– Cure at 110°C 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
VOC, g/l (benzyl alcohol)
Bake Temperature, deg C
System
50
75
100
A
-1
26
66
82
183
B
0
25
86
92
193
C
47
71
95
153
140
control
-1
-5
-1
-4
0
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110 Actual
ASTM task group D01.21.24B proposed
changes to ASTM 2369
 ASTM task group leading efforts to change methods
– Addressing high (>90%) 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
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