By Charles Haney, Pennsylvania SBDC’s Environmental Management Assistance Program (EMAP)

Worker wearing protective wear performing powder coating of metal details in a special industrial cameraThe PA Department of Environmental Protection has published a new regulation that will go into effect beginning January 1, 2017. ‘The Control of VOC emissions from Miscellaneous Metal Parts Surface Coating Processes, Miscellaneous Plastic Parts Surface Coating Processes and Pleasure Craft Surface Coatings’ regulation is focused on ensuring that paint pigments are applied without using excessive volatile organic compounds (VOCs). This regulation is a catchall for surface coating operations, of metal and plastic parts, which are not regulated elsewhere under Chapter 129. So, unless you know you are subject to a different regulation, it’s pretty likely that you will end up covered by this rule.

If you emit less than 2.7 tons per year of VOCs from paint and clean up solvents, there is only a minor recordkeeping requirement. Recordkeeping includes having current MSDS (material safety data sheet) and usage records to demonstrate that you are under the threshold amount.

If you emit more than 2.7 tons per year of VOCs, you already have VOC content limits that apply to your facility which are dependent on one of the 7 categories you fit into. As of January 1st, those categories will be revised and new VOC content limits apply. (By the way, the units have been changed as well.) Depending on which of the new categories your coatings fit into, you may be subject to lower VOC content limits.

For the first time, that I am aware of, facilities that paint plastics now have a VOC content limit. You will need to figure out which category you fall under and see if your coatings meet the limits provided. Work practice requirements involve standard best management practices: use a high efficiency spray gun, store VOC containing coatings and thinners in closed containers, etc. Most of the recordkeeping involves the coating parameters and usage amounts. The regulation provides some compliance options, but if you want to use a “non-compliant coating” you will need an add-on air pollution control device.

Charles Haney, and the team at EMAP, provide statewide, no-cost, confidential environmental compliance assistance. Find information at askemap.org.