An Overview of the Impacts of VOC Regulations on Manufacturing

Gases are formed when chemicals vaporize and a substance is converted to a volatile organic compound (VOC). Smog is the result of these gases. Compounds such as these may adversely affect humans, but they are also very toxic to the environment. Due to this fact, all manufacturers must comply with EPA regulations regulating VOCs and hazardous air pollutants (HAPs).

Further, manufacturer-specific guidelines exist for various types of products, such as those used on automobiles, buildings, and aerosols. Thus, owners of facilities may be subject to varying limits, both within the production process and for emissions generated within the facility.

Statutes and Regulations

All stationary and mobile sources are subject to emission limits under the Clean Air Act (1970). As per the Clean Air Act, the EPA’s National Volatile Organic Compound Emission Standards notify industries about VOC limits and production protocols. VOC emissions are expected to be reduced by 90,000 tons per year with these regulations.

For applicable industries, EPA sets VOC-to-product ratios to achieve these goals. In coatings for automobiles, for example, primers for pretreatment wash must not contain more than 780 VOCs per liter. In addition to those required during and after manufacturing, the EPA VOC outlines all industry-specific regulatory limits.

Additionally, the EPA’s National Emission Standards for Hazardous Air Pollutants (NESHAP) program monitors compliance with production process restrictions. There is a need for monitoring of large stationary sources that emit polluting substances that can cause severe health problems and birth defects.

The standards for performance testing must be followed during production, and monitoring devices may be required on-site. They are evaluated every two years for “major sources” that are subject to these tests.

The Regulations At The State Level

Local authorities are required by the Clean Air Act to maintain a certain level of air quality and to develop state implementation plans (SIP) to assist them in meeting those standards. In order to reach the standards prescribed for that state, SIPs generally set stricter emission limits than federal regulations. Your plant’s location will therefore affect the emission limits.

By reducing the use of VOCs in production processes or installing units designed to destroy harmful emissions, manufacturers can comply with emissions standards. To meet federal requirements, you may have to use both methods, depending on the state’s limits. In its implementation plans, the EPA provides a detailed breakdown of industry limits in every state.

Technology Available in a Reasonable Amount of Time (RACT)

EPA and governing bodies understand that when setting limits, it is important to take into consideration the technology available as well as the reduction in VOCs and HAPs. RACT, therefore, is used to evaluate compliance efforts.

The current technologies are assessed as new limitations are introduced, and regulations are accordingly adjusted. In order to ensure compliance with the regulations associated with this rule, your plant must review and renew any active emission control systems. Older units can also be upgraded at a reduced cost and emit less pollution.

Changes in Recent Regulations

Regulations and SIPs are updated regularly by the federal government. New and existing industries in Maryland and Connecticut have recently lowered their emission limits to comply with the Clean Air Act. The California SIP included an update in 2017 that required big-box retailers to provide additional reporting information. EPA and state governments make these updates after studying emerging technologies and monitoring the impacts of new manufacturing processes.

The limits and regulations for emissions are constantly being reviewed. In order to keep up with the continuous rise in regulatory requirements, it’s important not only to comply with government requirements but also to adopt the newest emission control technology.