Testing Techniques

EPA METHOD 24 AND MSDS

Q:  Does an MSDS have to state the laboratory test method used for determining VOCs? How does the user know?

A:  To the best of my knowledge, there is no federal regulation that mandates a company to state the test method by which the VOC content has been calculated. It is possible that some states require such information, but I'm not aware of this. I'm not sure that I've seen many (if any) MSDS that specifically tell the customer how the data was derived.

I would hope that the VOC information provided on all modern MSDS are based on EPA Method 24. Again, if you are not sure, and if the VOC content of a coating is at the regulatory limits, such as 3.5 (lbs/gal, less water, less exempt compounds), you should confirm the test method with your vendor.

If you still have some old MSDS that were prepared in the 1980's or perhaps even in the early 90s, you might not want to take any chances. Call you vendor and ask for an updated MSDS.

Remember, an inspector can only cite you if the VOC or HAP content, as determined by EPA Method 24, exceeds the regulatory limit.

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