Regulations, Violations, Permits, VOC, HAP and Such

ARE AEROSOL PAINTS EXEMPT FROM REGULATIONS?

Q: I am currently involved in evaluating permits and coatings in larger facilities in Pennsylvania. I have found no VOC content exemption for aerosol coatings in 25 PADEP 129.52 (surface coating processes) although there is one in 25 PADEP 129.73 (aerospace manufacturing and rework). 129.52 has a touch and repair exclusion but that does not cover all possible aerosol coating usage. 

Are you aware of how PA regulates aerosol coating VOC content? The VOC limits in 129.52 are in lb VOC/gal solid. I think I must be missing something.

A:  I'm not familiar with the PA rules and regs. It is quite possible that, as you have said, there might not be an exemption for aerosols, but on the other had, this is covered by an exemption for touchup and repair. After all, in most cases, one does not expect aerosols to be used for touchup and repair or for painting larger surfaces. 

If you intend to use aerosols for non-touchup operations, but to apply coatings to larger surface areas, then you might need to satisfy the lbs/gal solids limit. I doubt that there are many (if any) aerosols that can meet this tough standard.

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