Introduction

Volatile  ‘Orc’anic Compounds! Yeah, you read it right.

These are potently harmful chemicals that are commonly found in products such as paints, automotive cleaning and detailing products, general purpose adhesives and more. Some of these VOCs are acetone, benzene, butanol etc.

Several research studies have identified that the unmitigated use of VOCs cause smog related pollution, acid rain etc(*).

Context 

Statutory bodies have identified that VOCs pose a real threat to our health and environment. They have imposed stringent regulations to monitor VOC usage.

Millions of dollars have been levied as fines on companies that supply and distribute these products and have violated the VOC regulations(**).

How are VOCs Measured?

They are measured in grams/liter or percentage and this information is available on Safety Data Sheets provided by the manufacturers.

 

VOC Regulations in USA

USA has very stringent, complex, multi-tier regulation on the use of VOCs. Regulations are applied at different levels

  • Federal, monitored by the EPA
  • State
  • District
  • County etc.

California has one of the strictest regulations for VOCs. The regulator for California state is CARB.  The state is divided into 35 separate regions referred to as Air Districts. An air district would constitute several counties.  Each air district implements its own regulations while air-districts without any separate regulation would follow state guidelines.

For example, an engine degreaser (aerosol) containing concentrations of VOC above 10% would be violating California’s code of regulations and is hence, non-saleable. Similarly, an underbody coating with a VOC level exceeding 430 gram/litre would be restricted for sale in the air district of Antelope Valley in California.

Impact on the automotive supply chain

The fundamental rule is that you cannot sell your product in a region where the product violates VOCs limits. Companies have a difficult time complying with VOCs regulations due to many reasons

#1 Multi-tier regulation with different regulatory bodies applying different thresholds for VOC limits in the products

For example, the VOC limit for a product of Penetrant is 25% for the state of California and 50% for the state of Maryland.

#2 Each regulator has a distinct, non-uniform way of categorizing and labelling the VOC carrying products. Product categories include Adhesive & Sealants, Consumer Products, Metal parts & coatings etc.

For instance, the product category “Touch-up and repair coating” is used in many states of USA and “Repair coating” is used in other states. These two categories apply to the same array of end-products as per the definition on this product category for these states.

Companies need to identify which category their products fall into and which regulation applies to them.

#3 Regulations apply to all – manufacturer, distributor and retailers

Retailers are also impacted by these laws. They are mandated to know if the products they sell are compliant with the regulations of the area / zip code in which they sell. The air districts in USA are divided on a geographical basis and due to this, a state might   have two set of rules. For example, people living in western Kern would have to follow San Joaquin valley air pollution control district’s rule whereas people to the east follow Eastern Kern APCD’s rule.

Summary

Sustainable living, recycling and environment protection are increasingly driving decision-making in corporate board rooms. Global regulations continues to evolve rapidly and companies need to keep a strict watch on these regulations continuously and adapt to them in order to survive and succeed.

The authors Balaji T.P and R Krishna Rao are domain experts in global regulations and statutory compliance of automotive products. APA Engineering offers solutions for VOCs compliance management and reporting. To know more, email compliance@apaengineering.com or visit https://compliance.apaengineering.com

(*) –  www.foobot.io/guides/how-does-volatile-organic-compounds-affect-the-environment.php

(**) – ww2.arb.ca.gov/our-work/programs/enforcement-policy-reports/enforcement-case-settlements

If this regulation is applicable to you and you are interested in knowing more about this topic and available solutions, then schedule a free consult with our experts.