Volatile organic compounds, or VOCs, are chemicals that have been found to cause health and environmental risks when they reach certain concentrations in the atmosphere. VOCs are emitted from all types of materials, from household cleaning supplies to bug sprays and other types of aerosols.

VOCs have for decades been known to contribute to the problem of ground-level ozone. A reaction between oxides of nitrogen and sunlight, ground-level ozone is responsible for numerous respiratory and other health complications in humans. Photos of Beijing’s appalling air quality are stark reminders of what can happen if ground-level ozone is allowed to reach runaway levels.


The EPA regulates VOCs on the national level, but recently there have been pushes by some states and counties to impose even stricter VOC limits. Los Angeles County, for instance, has some of the strictest VOC limits on the books, perhaps due to the smog problems that city endured in the 1950s and 1960s. Because VOCs emitted indoors have a tendency to become more concentrated, the EPA plays especially close attention to VOC limits in indoor manufacturing facilities.

The EPA asks that states comply with what is known as Reasonably Available Control Technology (RACT). This is defined as the “lowest level of emissions that can be achieved taking into account technical and economic considerations.” What this means for our customers is that, depending on the state in which their project is being undertaken, VOC limits may dictate the sort of product that’s called for in the project’s specifications.

Painting and VOC limits

In our line of work, VOCs are most often emitted after a coating has been applied, during the drying phase. If you remember our four elements of a protective coating, the element most closely involved with the emission of VOCs is the solvent portion. Used to keep coatings a liquid for ease of application before the product is applied, solvents are meant to evaporate upon exposure to the air. Unfortunately, solvents are often made from chemicals that can have unintended consequences for air quality and the atmosphere.

The Architectural Coating Rule for Volatile Organic Compounds is the EPA rule that now governs the use of most products in industrial painting. It applies to any coating applied to a stationary structure for the purpose of protecting it from corrosion. For our purposes, this can mean anything from an aboveground water tank to a bridge to penstock. Since many states take their regulations even further than the federal government, it’s important to know a state’s VOC limits when drawing up specifications for the project.

OSHA’s redesigned format for Safety Data Sheets (formerly known as Material Safety Data Sheets) includes a few sections that contain information relevant to VOCs. Section 3 contains information on the chemical makeup of the product, Section 6 details measures to be taken in the case of accidental release, and Section 15 explains other regulatory information that may apply to the product. These sections can be useful to consult when considering how well a product will comply with VOC limits.

Thankfully, products now exist which either use exempt solvent formulations, or little to no solvent at all, in order to keep projects under the VOC limits mandated by the state. In our next post, we’ll discuss some low or VOC-free options for staying below VOC limits and avoiding fines.

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