Regulations, Violations, Permits, VOC, HAP and Such

SPECIFYING NON-COMPLIANT COATINGS IN A NON-ATTAINMENT AREA

Q: I’m a state inspector in Ohio. Typically, companies will tell us that the auto industry mandates the use of specific non-compliant coatings. How can we work through this?

A: In most (if not all) states the company that performs the painting operations is responsible for insuring that only compliant coatings are used.  Strictly speaking, if the company cannot purchase a compliant coating that meets his customer’s requirements nor can add an abatement device to the facility, he is obligated to turn down the work.  Well, that’s probably easier said than done especially in a state such as Ohio where many companies are contractors to the automotive OEMs.

California dealt with this already in the mid-1980s when job shops (custom coaters) were being required to use non-compliant coatings on military projects.  The Bay Area Air Quality Management District (BAAQMD), and later most of the other California districts, included a clause in their respective regulations mandating that all coatings specified for use within the state of CA were to be compliant, regardless of the state in which the specifier resided!  Remember, this was the “Star Wars” era.   The contracting companies were generally not fined for non-compliance provided that they were willing to supply the names, addresses and phone numbers of their military customers to the BAAQMD!  Armed with this information, the Agency took several high ranking military officers to court, and warned them that unless new compliant coatings were soon specified, the Agency would shut down the contractors’ painting operations.  Needless to say, within a short period, and with lots of research efforts on behalf of the army and air force coatings laboratories, complaint coatings soon became available.

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