On March 19, The American Coatings Association, or ACA, submitted comments to the California’s Air Resources Board (CARB) on the agency’s proposed amendments to the Multipurpose Solvent and Paint Thinner regulations discussed at its Feb. 26 Aerosol Coatings and Consumer Products Regulations Public Workshop. The proposed standards include the 3% volatile organic compound limit for paint thinners and multipurpose solvents.
Of note, California’s South Coast Air Quality Management District, or SCAQMD—the only California air district with its own Paint Thinner and Multipurpose Solvent Limit rule that deviates from the CARB proposal—has recommended that CARB complete an “LVP Study” to determine the impact of certain low vapor pressure solvents (LVPs) on ozone formation. However, CARB is moving forward with major changes to the use of LVPs with regard to the Paint Thinner and Multi-purpose Solvents regulations before it even conducts the study. In its comments, ACA urged CARB to complete the proposed research before it amends the LVP exemption for any consumer products.
CARB is currently completing its 2012 Technology Review in order to determine if the 3% limit is commercially and technologically feasible. ACA is awaiting a detailed summary from CARB, but the initial data suggests that products that would comply with a 3% limit would either be acetone, methyl acetate, or parachlorobenzotrifluoride(PCBTF). ACA has emphasized to CARB that acetone and methyl acetate have approximately the same flashpoint and both are extremely flammable, and that PCBTF is considerably more expensive than the other two solvents.
At the public hearing, several stakeholders, including a representative from the Los Angeles Painters Union, expressed concerns over possible fire threats associated with certain paint thinners, and, along with ACA, urged CARB to gather more technical assessment data. This is especially important since CARB staff mentioned that most manufacturers did not rely on LVP-VOC usage to comply with the limit, but four out of five of the products sold were LVPs. ACA stressed that it is critical that CARB release the compliant market share and breakdown of solvent sales — how much acetone and methyl acetate is being sold versus PCBTF — so that the industry can better understand what is actually happening in the marketplace. ACA maintains that CARB must also analyze what will happen in the market as a result of the proposed amendments, especially whether the amendments will increase the use of acetone versus methyl acetate and PCBTF.
The coatings industry is very concerned that if the LVP exemption is removed, painters and consumers will move from mineral spirit-based paint thinners and multipurpose solvents to acetone and methyl acetate, which may lead to increased fires, injuries and deaths. Robert Smith, a representative from the Los Angeles Painters Union, attested that five painters died several years ago due to a fire that resulted from cleaning a spray gun with acetone/methyl acetate. In addition, ACA cited that flammable lacquer sealers are banned from sale in Massachusetts given numerous fires — 25 fires in the Boston area alone since 1995 — and the deaths of three contractors and three others severely injured in two fires where proper work practices were not followed.
The proposed regulation applies to paint thinners and multipurpose solvents that are purchased by consumers. ACA argued that if consumers do not read and follow the label instructions when using acetone, there is little room for error, and this presents a significant hazard to users. And some commentators have noted that consumers, contractors, and workers do not read Material Safety Data Sheets or product labels. If this is the case, fires, destruction of property, injury, and deaths may result from the 3% limit.View the complete press release online.
