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VOC RegulationsHow They Affect the Products You Use (SEALER SERIES Part 2)
Regulations concerning the manufacture and use of sealers and coatings for concrete have been the source of much discussion and confusion. In an effort to try and simply the matter, the following is a brief summary of how the US Environmental Protection Agency’s 1999 Architectural Coating Rule for Volatile Organic Compounds impacts the manufacture and use of sealers and coatings in the concrete industry in 2014.
The Environmental Protection Agency published the architectural coatings rule on September 11, 1998 (63 FR 48848) under authority of Section 183(e) of the Clean Air Act. This rule took effect in 1999 and limits the amount of volatile organic compounds (VOC) that manufacturers and importers of architectural coatings can put into their products. VOCs are carbon-based compounds released from certain solvents, plastics or rubber that combine with other gases in the atmosphere to form ozone which can adversely impact the environment and atmosphere. The rule also has container labeling requirements for architectural coatings. There are different options for complying with the VOC limits, including exemptions for products that may be hard to reformulate and or small quantity manufacturing and packaging, but the bottom line is most sealers, coatings, cures, water proofers, and cure and seals for concrete fall under these guidelines. The question then remains which guideline and what are the limits for the product I am using?
To answer this question you need to know what category the product you are manufacturing or using falls under and the VOC limits for the that particular product in the area you are working. As an installer, most of that work is taken care of by the manufacturer or distributor, but it is still your responsibility to understand the guidelines and work within them.
In regard to sealers and coatings for concrete, there are federal standards, state and multistate group regulations, and in some cases counties or air quality management districts that have set their own regulations. To complicate matters further there are some 61 sub categories of sealers and coatings, each with its own VOC limit that can vary greatly depending on which state or county you are manufacturing or using the product in. This series of different regulations can complicate matters when determining if a concrete sealer or coating meets the VOC regulations for that area. . So which regulation do you need to follow? State regulations trump federal regulations, and district regulations trump both state and federal regulations. The chart below clarifies the VOC limits for the key concrete coatings categories by area as of 2014.
It is important to note that VOC regulations are not static and changes are always being proposed and implemented. July of 2014 several Northeastern states in the Ozone Transport Commission (OTC) and local California Air Districts have recently proposed amendments, or will likely propose amendments next year, to their regulations governing volatile organic compound (VOC) limits in architectural and industrial maintenance (AIM) coatings. Many of these do not affect coatings and sealers for concrete, but it is important to monitor changes and how they may affect your choice of sealer of coating.
You can find out the VOC content and category for the sealer or coating you are using by looking at the MSDS or specification sheet for that product. For more information on solvents, VOC regulations, and the Architectural Coating Rule for Volatile Organic Compounds (63 FR 48848) check out these two resources:
- Rule and Implementation Information for Architectural Coatings
- Architectural Coating Rule for Volatile Organic Compounds (Detailed Fact Sheet - PDF)
- Increased AIM VOC Regulation Activities Around the States and in California Air Districts
- VOC Regulations from US EPA, OTC, CARB, SCAQMD and Environment Canada
Architectural Industrial and Maintenance (A.I.M.) Coatings VOC Regulatory Regions in 2014
Federal A.I.M. - Any state or region not impacted by a multi-state or air quality district regulation.
CARB - California Air Resources Board. Made up of 20 air management districts in the state of California.
LANDCO - Lake Michigan Air Directors Consortium. Made up of the following states: Ohio, Indiana, Michigan, Illinois, Wisconsin and Minnesota.
OTC - The Ozone Transport Commission. Made up of the following states: Connecticut, Delaware, the District of Columbia, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and Virginia.
SCAQMD - South Coast Air Quality Management District. Made up of the following counties in Southern California: Orange County and the urban portions of Los Angeles, Riverside and San Bernardino counties.
Canada - The entire country of Canada operates under the same VOC limitations.
VOC Limitations for Concrete Coatings by Product for the US and CanadaMeasured in grams per liter
|Concrete Curing Compounds||350||350||350||350||100||350|
|Concrete Curing and Sealing Compounds||700||100||350||350||100||350|
|Concrete Protective Coatings||400||100||n/a||n/a||n/a||400|
|Concrete Surface Retarders||780||n/a||n/a||n/a||n/a||780|
|Concrete Form Release||450||250||250||250||250||250|
|Primers, Sealers, and Undercoats||350||100||350||350||100||350|
|Waterproofing Sealers and Treatments||600||400||400||400||100||400|
Environmentally friendly sealer: Pro-Seal's Ultra Shield II-A
Author Chris Sullivan, ConcreteNetwork.com technical expert and vice president of sales and marketing for ChemSystems Inc.
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