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 multi state 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. Notably OTC Phase II was approved in 2014, and was adopted by Maryland, taking effect January 1, 2107. Seven counties in Utah also adopted OTC Phase II guidelines January 1, 2015. See the chart below for details.

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 resources:

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

Federal CARB LADCO OTC* Utah** MD OTC Phase II 1/1/17 SCAQMD Canada
Concrete Curing Compounds 350 350 350 350 100 100 100 350
Concrete Curing and Sealing Compounds 700 100 350 350 100 100 100 350
Concrete Protective Coatings 400 100 n/a n/a n/a n/a n/a 400
Concrete Surface Retarders 780 n/a n/a n/a n/a n/a n/a 780
Concrete Form Release 450 250 250 250 250 250 250 250
Primers, Sealers, and Undercoats 350 100 350 350 100 100 100 350
Stains, clear 550 250 250 250 250 250 100 250
Stains, opaque 350 250 250 250 250 250 100 250
Waterproofing Sealers and Treatments 600 400 400 400 n/a n/a 100 400
Waterproofing Membranes n/a n/a n/a n/a n/a 100 n/a n/a
Concrete / Masonry Sealers n/a n/a n/a n/a n/a 100 n/a n/a
Driveways Sealers n/a n/a n/a n/a n/a 50 n/a n/a
Reactive Penetrating Sealers n/a n/a n/a n/a n/a 350 n/a n/a

*The state of Maryland adopted OTC Phase II in 2010, it became effective 4/25/16 with a compliance date of 1/1/2017. OTC Phase II utilizes the same VOC minimums as SCAQMD.

**Seven counties in the state of Utah (Box Elder, Cache, Davis, Salt Lake, Tooele, Utah, and Weber) adopted OTC Phase II on 9/2013, with a compliance date of 1/1/2015.

As of late 2016, the states of NY and DE are considering adoption of OTC Phase II.

The stricter limit applies for products that fall under multiple categories.

Q&A: Does Your Concrete Sealer Meet VOC Content Regulations?

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Author Chris Sullivan, technical expert and vice president of sales and marketing for ChemSystems Inc.

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