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Panel: Steve Risotto
Media: Bryan Goodman

HAP regulations typically apply nationwide to facilities that have the “potential to emit” 10 tons or more per year of one HAP or 25 tons or more per year of all HAPs. VOC regulations, on the other hand, generally apply only to emitters in nonattainment areas. Most emitters located outside those areas will not be subject to VOC regulations unless they build a major new facility or make a major change at an existing facility.

HAP regulations under the Clean Air Act are set by the EPA, although many states also operate their own air toxics programs pursuant to state environmental statutes. Most VOC regulations are set by state or local regulatory agencies-- often based on guidance from the EPA, although as noted above, EPA has set national standards for VOC content of architectural coatings and a few other product categories.

Options for Complying with VOC and HAP Regulation

While specific options will depend on the language of the regulations themselves, solvent users generally have three choices for complying with VOC and HAP regulations: (1) switch to an alternative technology; (2) try to reformulate; or (3) install control or recovery technology. Some of the advantages and disadvantages of each approach, particularly as they apply to coatings, are summarized in Cutting Through the Maze.

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