There are regulations in the U.S. and other countries that are designed to limit exposures to specific heavy metals due to environmental, health and/or safety concerns. Managers of coatings operations have the responsibility to be familiar with these regulations and assess how they may affect their employees and their business. Before using a coatings product, the entire product label and Safety Data Sheets (SDS) should be reviewed. It is essential that facilities understand what they are working with and how to safely handle products.
Rules & Regulations
Globally Harmonized System of Classification and Labeling of Chemicals (GHS)
The United States Occupational and Health Administration (OSHA), on March 26, 2012, published the final rule on the Hazard Communication Standard (HAZCOM 2012) that will adopt the Globally Harmonized System of Classification and Labeling for Chemicals (GHS). The legislation becomes effective 60 days after publication and provides several transition dates for employee training and revised safety data sheets and labels. In addition to the hazards defined in the GHS, OSHA has included requirements for disclosing additional hazards known about chemicals under a "hazards not otherwise classified" section. OSHA's new standard will classify chemicals according to their health and physical hazards and establish consistent labels and safety data sheets for all chemicals made in the United States and imported from abroad. During the transition period chemical manufacturers, importers, distributors and employers may comply with either the existing standard, the final standard (HAZCOM 2012), or both.
PPG is a global leader in the manufacture and distribution of coatings, resins, chemicals, glass and fiber glass products. Starting in early 2013, PPG will begin the process of converting our existing product compliance documents to the new HAZCOM 2012 regulation, and we expect that our transition will be completed well in advance of the June 1, 2015 deadline for chemical manufacturers and the December 1, 2015 deadline for distributors. As products are converted to the new SDS and label format, PPG representatives will be informing our customers of the changeover.
Please note that during the transition period of converting our SDS to the new OSHA compliant standard, customers may receive two styles of product compliance documents for different products. These will be the most current documents for each product. We would also like to point out those changes in SDS and labels as a result of the new regulation are not related to any changes in the actual product formulations unless you are notified to the contrary by PPG.
Heavy Metals Regulation
The link below is a general guide to some of the rules and regulations that affect the use of certain heavy metals contained in PPG Refinish coatings products. This document is not intended to be all-inclusive.
Area Source Rule Summary
The EPA recently enacted an Area Source Rule that affects coatings facilities that spray apply coatings on metal and plastic substrates. This rule was designed to cover smaller facilities not targeted by the major source NESHAP, already in place. Refinish facilities in particular are regulated under this new federal rule, known formally as 40 CFR Part 63, National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources, Subpart HHHHHH. This document is a brief summary, not intended to be all-inclusive.
Area Source Rule Text
What follows is a link to the text of the final rule, 40 CFR Part 63, National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources, Subpart HHHHHH, as promulgated by the U.S. EPA on January 9, 2008. It is the responsibility of the facility owner/operator to understand the specific requirements of the rule, including any amendments to the rule that may have been proposed and/or promulgated after January 9, 2008. PPG makes this document available for convenience only and makes no representation or warranty that it is current and/or has not been amended or modified by the U.S. EPA since January 9, 2008.
EPA Small Business Resources
A wide range of resources are available including training, checklists, compliance guides, mentoring programs and other activities to help small businesses learn about environmental compliance and take advantage of the Small Business Compliance Policy.
Area Source Rule Exemption Application
Under 40 CFR Part 63, Subpart HHHHHH, the National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coatings Operations at Area Sources, an application for an exemption from the requirements of the rule is possible for U.S. facilities using selected coatings products that do not contain the listed heavy metal HAPs. This document assures PPG customers that an application for an exemption can be filed if using selected PPG Refinish products, particularly if waterborne basecoat is used, also if listed solvent-borne basecoats and single-stage systems are chosen. Numerous clearcoats and primers allowed under an exemption are also listed.
Area Source Rule Exemption Qualifying Product Lists
Several PPG Refinish product lines may be used within an exemption from 40 CFR Part 63, Subpart HHHHHH, National Emission Standard for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coatings Operations at Area Sources. The reference documents supplied list products that may be used—and also the few products to be avoided—from each product line if a customer wishes to maintain an exemption from the Area Source Rule.
Substrate Cleaner Guidance Under Auto Refinish Regulations in North America
Parts of North America have auto refinish regulations that carry the lowest VOC standards for products used - based on the California Air Resources Board Suggested Control Measure (CARB SCM) model rule. These auto refinish regulations are found in California, Maryland, Delaware, Washington DC and Canada. Typically, they call for cleaners with a VOC content at 0.21 lbs./gal., with a few exceptions. VOC limits for all coatings categories and products compliant with those regulations are well documented.
Outside of those jurisdictions, the remainder of the US generally follows national rule VOC limits for coatings categories. However, a few parts of the country have unique substrate cleaner VOC limits that local shops should be aware. PPG Refinish offers a variety of products, compliant with local regulations. The document below lists those regions, their regulations and recommended PPG OneChoice® cleaners.