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Section 3:
ENVIRONMENTAL, OCCUPATIONAL, AND SAFETY ISSUES
3.1
Introduction. Environmental and health concerns have
led to increased restrictions on coating operations. Material
composition, surface preparation procedures, and application
techniques have been affected. This chapter summarizes these
restrictions and concerns. Detailed information on specific
regulations related to these issues can be obtained from
installation offices responsible for environmental, occupational,
and safety issues.
3.2
3.2.1
VOC Restrictions. VOCs make up the solvent portion of
coatings. When emitted into the atmosphere, they may combine
with oxides of nitrogen to form ozone, a major component of smog.
The Clean Air Act of 1970 (amended in 1977 and 1990) requires
states to develop and implement plans to ensure that the
Environmental Protection Agency's (EPA) National Ozone Standard
(less than 0.12 parts ozone/million parts air (ppm), by volume)
is met (National Ambient Air Quality Standard, 40 Code of Federal
Regulations (CFR) 50). To help meet this requirement, some states
and regions have placed limits on the VOC content of paints and
coatings.
3.2.1.1
Definition of VOC. For paints and coatings, VOC is
defined as the amount of volatile organic material measured in a
specific test procedure. The test procedure used in most regions
is EPA Method 24 (40 CFR 60, Appendix A). The VOC content that
is measured following such a procedure may be different from that
calculated based upon the coating formulation. For field applied
coatings, the VOC is determined on the coating as it is applied.
That is, if the coating was thinned for application, the thinner
contributes to the VOC level.
3.2.1.2
Types of Regulations. VOC regulations may place a
limit on the VOC content of liquid coatings or the amount of VOC
that a coating shop can release into the atmosphere, or may
require a minimum transfer efficiency, depending upon the local
regulations. VOC-content regulations vary from region to region
within states and between states, depending upon the ability of a
region or state to maintain compliance with the National Ambient
Air Quality Standard for ozone. VOC-content regulations may
apply to either or both shop-applied coatings and field-applied
coatings (architectural). Many regions of the country have
restrictions on shop-applied coatings, but only a few have
restrictions on architectural coatings. (However, a national
rule for architectural coatings is expected to become effective
in 1996.) For military facilities, rules affecting shop-applied
coatings (e.g., the miscellaneous metal parts rule) are of
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