The VOC factor, Part 1: resins and paints.

A midst ongoing industry consolidation, increasing raw material and energy costs, and competition from large discount retailers, the paint and coatings industry must wrestle with ever more strict regulations on volatile organic compounds (VOCs) and hazardous air pollutants (HAPS). While all participants within the industry agree that protection of the environment is a primary concern, some question whether or not the historical methods of determining limits on VOCs and HAPS actually result in effective reduction of emissions. Companies have and are continuing to make significant investments in R & D efforts to develop new technologies and alternative products that will provide the performance expected by customers at a reasonable cost while meeting the limits on VOCs and HAPS. Others are also working at developing an understanding of the science behind the environmentally harmful aspects of VOCs and HAPS in order to design more appropriate regulations for the future.

Regulation of VOCs in paints and coatings began in the late 1970s when it was recognized that VOC emissions (largely solvents) in these products may accelerate the process by which sunlight and nitrogen oxides (NOx) generate ozone, which is a ground level air pollutant and major component of smog. The first regulation concerned VOC content in architectural coatings and was adopted in California in 1977. The rest of the U.S., especially the Northeast's Ozone Transport Commission (OTC), has generally followed California's lead, often implementing very similar regulations to those developed by the California Air Resources Board (CARB) and South Coast Air Quality Management District (SCAQMD). Even the European Emissions Directive has taken some cues from the California VOC regulations for paints and coatings.

CHALLENGES TO THE COATINGS INDUSTRY

In the U.S., regulations controlling the VOC content in paints and coatings have been introduced on the federal, state, and local levels. Resin manufacturers and paint formulators must contend with a complex matrix of global, national and regional rules for different paint applications. Architectural and industrial maintenance paints have been most heavily regulated. Allowable levels of VOCs also differ depending on the type of paint as well (high gloss, medium gloss, semi-gloss, flat/satin, solvent-based, waterborne, etc.) Emissions must be controlled both within the manufacturing facility (point sources) and when the product is applied. For shop or factory coating applications, alternative emission controls such as carbon adsorption and vapor incineration may be available. The only compliance option available for field-applied architectural and industrial maintenance coatings, however, is product formulation or substitution.

At the federal level, the Environmental Protection Agency (EPA) has the authority through the Clean Air Act Amendments (CAAA) to regulate emissions of VOCs and hazardous air pollutants (HAPS). For a number of categories of industrial surface coating operations, the Coatings and Consumer Products Group (CCPG) of the EPA has developed national emission standards for HAPS (NESHAPS) under Section 112 of the CAA (commonly called MACT rules) and national VOC rules or control technique guidelines (CTG) under section 183e of the CAA. Compliance dates for most of these regulations fall in the 2005-2007 time frame.

According to Michael D. Brown, vice president of The ChemQuest Group, a management consulting firm located in Cincinnati, OH, the regulation of HAPS as part of the MACT standard is the most significant challenge on the horizon. "Many of the solvents used in coatings are considered to be HAPs, and therefore will be limited in their use in a coatings formula," notes Mr. Brown. "As a result, formulators must go through another round of reformulation to eliminate or reduce these materials in the formula."

On a regional basis, regulations requiring additional reductions in VOCs will take effect in both the Northeast and Southern California over the next few years. The OTC is in the process of implementing VOC limits that were scheduled to take effect January 1 of 2005. The SCAQMD has additional VOC reduction requirements scheduled for July of 2006 and in 2008 as well. Other regions of the U.S. are also expected to adopt these limits. As a result, paint manufacturers are formulating their products to meet the most stringent regulations.

"The SCAQMD's set of extremely low VOC content limits scheduled to take effect on July 1, 2006 are the darkest cloud on the horizon," says Robert Wendoll, director of environmental affairs for Dunn-Edwards. "The new limits will affect all the major architectural coatings categories: flats; non-flats; primers, sealers, and undercoaters; and industrial maintenance coatings. These categories make up at least 75% of the total volume of architectural coatings, and the limits would ban approximately 80 to 90% of the product formulations currently in use," he explains. Anthony M. Ciepiel, president and COO of The Flood Company, adds that "these changes are expected to dramatically impact flow and leveling in normal conditions and an even greater impact when the temperature and humidity varies beyond the rather limited 'sweet spot' that most paints are formulated to perform within."

The European Union has regulations set to take effect in 2007 and 2010. The implementation of the European Emission Directive will take effect in 2007. For tangent industries to collision repair, the Miscellaneous Plastic Parts and Miscellaneous Metal Parts HAPS limitations, and the possibilities for HAPS limits beyond the collision repair industry will be factors, according to Bradley M. Richards, manager of refinish coatings R & D for BASF Corporation in North America. "For most companies, the implementation in Europe requires finalizing the exchange of technologies and training for the remaining customers. The expected lower HAPS mandates of the future may still require reformulation of some products in their solvent makeup," he notes.

Staying abreast of the many regulations is but one of the difficulties faced by the paint and coatings industry. Developing cost-effective technologies and alternative formulations that meet the regulatory requirements while still providing the level of performance expected by customers is the main challenge for resin and paint manufacturers. The pace of new product development necessary for meeting continually reduced VOC levels has been a hurdle for some companies as well.

Performance issues have generally been related to field-applied architectural and industrial maintenance coatings. According to Mr. Brown, regulations to reduce VOCs in formulas have made management of the coating viscosity more difficult. "Viscosity has a major impact on application and a minor impact on adhesion. Therefore, the biggest impact has been in those markets where viscosity and application is very important," he says. In original equipment manufacture (OEM) coatings, gloss has been directly impacted by the viscosity issue. For architectural coatings, there is little opportunity to control the cure environment, and therefore the applicator productivity is directly related to the speed at which the coating dries and the next coat can be applied. Solvents evaporate much more quickly than water and therefore are more productive.

FINANCIAL IMPACT

Both direct and indirect costs have been accrued by the paint and coatings industry due to environmental regulations. Direct costs include special capital costs for new production equipment and emissions control devices, plus investment in R & D efforts for new technology and product development. In addition, many of the acceptable raw materials come with much higher costs. "Often it is difficult to pass these costs on to customers, who resist higher product prices," says Carl Sullivan, technical manager of Coating Products with Reichhold. "Therefore, resin manufacturers are seeing margins squeezed." Mr. Ciepiel notes that these cost pressures are "currently being compounded by dramatic raw material cost increases that the industry is experiencing due to higher crude oil and steel costs, further creating pressure for margin compression."

There are numerous indirect costs as well. "Diversion of R & D investment dollars away from products that could have been developed solely in response to the underlying drivers of technology advancement in our industry, specifically the market demand for products that work better, cost less, and have fewer adverse impacts," states Mr. Wendoll. "Forcing R & D efforts into a narrow channel of restricted options, where the overriding concern is reducing VOC content, has cost the paint and coatings industry untold value." Dunn-Edwards believes that without the existing regulatory restrictions, the industry would be "much further along in the development of truly eco-efficient coatings that maximize the efficient utility of raw materials and other resources while minimizing adverse impacts on human health, safety, and the environment in all aspects, not just air quality," Mr. Wendoll adds.

To complicate matters, certain market dynamics are compounding the cost pressures created by the VOC regulations. "Until recently, formulating with solvents was considered to be the lowest cost way to formulate," says Mr. Brown. "Depending on the long-term prospects of oil prices, this situation may no longer be true. In fact, solvent pricing could help to drive formulators away from solventborne technology since it is a 'cost inefficiency' in that it serves no purpose for the end-user once it evaporates," he continues. On the architectural side, the impact of big box retailers like Home Depot is placing additional downward pressure on prices. Consolidation within the industry is an additional factor impacting the industry. "One thing that can be said about the VOC regulations is that they are a point of continuity in an industry experiencing rapid change," says Mike Mulvihill, market development manager for Building Construction Materials with Reichhold.

The continuous introduction of stricter regulations has obviously taken a financial toll on the paint and coatings industry. "The main concern is that each iteration of the regulations causes the formulators to change formulas and switch out their inventory," notes Mr. Brown. "This changeover usually comes at substantial costs in R & D as well as supply chain and marketing costs." Clair Doyle, group market manager, Architectural Coatings North America, with Rohm and Haas Company agrees that one of the biggest concerns is the financial impact of the cost of the multiple reformulations for paint and coatings manufacturers. "Since the limits have kept changing, our customers have had to make multiple changes, all of which have required significant investments," she says. "Rohm and Haas has responded to the situation by providing very high levels of technical support for our customers to assist in their reformulation efforts," she continues.

RECOGNIZING NEW OPPORTUNITIES

While the regulations do pose considerable hardships for resin and paint producers, everyone agrees that protection of the environment should be a primary concern for the industry. "The positive side is the assumption that citizens and industry agree that we can all reduce the impact on the environment. The strategy and mission statement of Surface Specialties UCB is clear on our commitment to this notion," says Terry Scoville, market manager--Liquid Coating Resins for Surface Specialties. The regulatory climate is also a reflection of a broader trend towards "green" construction practices and the use of renewable resources, according to Ms. Doyle. Bruce Johnson, technical director--Resins for Engineered Polymer Solutions/Color Corporation of America (EPS/CCA) agrees that "the lower levels of solvent required in the coatings are providing an opportunity for the coatings industry to position itself as a 'green friendly user of chemistry'." Mr. Richards warns, though, that gaining a beneficial effect to the environment is not automatic. "End-users need education and training on new products and processes. This need for further education is recognized by the end-users. Although it brings added business costs, the training improves the caliber of the end-users and helps strengthen end-user loyalty to the paint company," he explains.

The regulatory situation has also provided opportunities for companies. "We have experienced increased interest from a broad spectrum of customers, even ones that have traditionally aligned with only a few key suppliers," says Nick Mittica, coatings market manager, Emulsions for Air Products Polymers. "Coatings producers are open to evaluating our technologies even if our companies have not had a history of working together on the development of polymer technology. These companies recognize the need to consider all alternatives to solving their reformulation challenges, and have been very receptive to the use of new technology to accomplish their goals," he explains. Lee Miller, North America market manager, Specialty Surfactants with Air Products, adds that the increasing regulatory demands have enabled Air Products to prove that it is not just a product supplier, but a total solutions provider to its customers. "We've been successful in helping our customers maintain their high performance needs, while at the same time helping them achieve compliance with tighter VOC and other regulatory requirements," says Mr. Miller.

Opportunities for differentiation have also been important, but have had a positive and negative side to them. "VOC regulations have made it challenging to develop high performance, cost-competitive products. We have focused on differentiating Reichhold by introducing to the marketplace VOC-compliant products that offer the desired level of performance at a reasonable cost," notes Mr. Mulvehill. On the negative side, some companies believe that a few paint industry members have attempted to achieve "regulatory capture of markets" by advocating or supporting regulations that will ban a competitor's products, or in some way create more of a burden to the competitor than to themselves.

RESPONDING TO REGULATORY CHALLENGES

To deal with the regulatory climate, participants in the paint and coatings industry have taken several different approaches. All companies have invested in R & D efforts to develop new products and technologies to enable compliance with the regulations. Trade associations such as the National Paint & Coatings Association (NPCA) and the Allied Local and Regional Manufacturers (ALARM) have attempted to work with regulatory bodies to establish reasonable limitations on VOCs and HAPS. The VOC Policy Subcommittee of the NPCA Board was created to work with regulators to develop a realistic transitional plan for the industry. "The intent is to create collaborative dialogue with regulators as they develop regulations vs. having to respond to regulations once they are announced," says Mr. Ciepiel. The subcommittee, chaired by Peter Flood, who is chairman and CEO of The Flood Company, aims to help regulators reach their goals while maintaining good products at affordable prices. Leading local and regional paint companies in Southern California utilized their trade association's Environmental Legislative & Regulatory Advocacy Program (EL RAP) to focus efforts on defending high quality coatings before local districts in California. Several companies themselves have instituted litigation proceedings challenging both federal and state air quality agencies and certain regulatory limits on VOC content in paints and coatings.

Education has been a primary effort of the industry. "The first thing the industry did in all cases was to understand that only education could lead to the development of a reasonable set of regulations," says Mr. Richards. "The need for lower-VOC products has been acknowledged, and regulations that drive technology are supported so long as there is good understanding of capabilities and performance demands on the resulting coatings. This educational partnership with the regulators has extended to educating the end-users about why product evolution has occurred and the best ways to use products for optimum performance while protecting the environment," he adds.

For Dunn-Edwards, the approach has been to "formulate, negotiate, litigate, and investigate," according to Mr. Wendoll. Lessons learned about the limitations of lower-VOC formulations provided valuable information to support negotiating with regulators. "Litigation has been an unfortunate necessity to stop product bans that would be economically damaging and even environmentally counterproductive," he notes. Industry members have also devoted a great deal of time and attention to investigating alternative, innovative regulatory solutions such as the "averaging" of low-VOC and higher-VOC product production. More recently the industry has become more involved in promoting scientific research on VOC reactivity to demonstrate the variable ability of VOCs to affect ozone formation. Current regulations sometimes lead to substitution of smaller quantities of more reactive VOCs that can possibly cause more harm to the environment.

Four major types of coatings technologies have become the technologies of choice for meeting low-VOC requirements. Waterborne coatings, which were introduced long before VOC regulations were implemented, have become the largest volume technology. High-solids solvent-based coatings have become the second largest type of coating technology based on volume of sales. Powder and radiation cured coatings are technologies that have been advanced in direct response to the need for low-VOC formulations.

Water-based coatings find applications in all areas of the paint and coatings market, including the original equipment manufacture, architectural, and special purpose sectors. In the OEM market, however, waterborne coatings are widely used but there is still significant potential for growth, since solvent-based coatings are still used for many applications, according to Steven Nerlfi of Kusumgar, Nerlfi & Growney, a market research firm.

"The bulk of architectural paints--both interior and exterior--are waterborne coatings, not because of VOC regulations but because of performance," says Mr. Nerlfi. Mr. Johnson agrees that water-based technologies have evolved to meet most of the applications in the architectural market. "Water-based paint has long been preferred for easy clean up and the reduced odor from traditional solvent-based coatings. This trend to water-based has been accelerated by the inability of low molecular weight solvent-based products to meet the former performance requirements demanded by the homeowner," he notes. Scott Lewis, product manager with ICI Paints, adds that the new VOC laws have contributed to the decline of exterior alkyd house paints. "Latex house paints offer superior durability and longer term beauty for the homeowner. The color lasts longer, resists mildew better, resists fading and chalking, and retains the gloss better when compared to alkyds," he explains.

Low odor is a benefit of low-VOC, water-based coatings that has been utilized for new application areas by several companies. "Applicators of architectural coatings are finding that some of the 'zero VOC' coatings can be applied in environments that historically would have required evacuation of the occupants because of the odor associated with these products," says Mr. Brown. In addition, these low odor paints can be used for interior painting with the homeowner's windows closed. "Practically, this extends the painting season as well as providing a positive environmental image for the coatings' industry," Mr. Johnson adds.

The special purpose segment, which includes industrial maintenance, traffic, marine, fire retardant, and many other coatings is much more difficult to define. Fire retardant coatings are water-based. Some special purpose applications like traffic paints have almost entirely switched to water-based coatings. The auto refinish sector has also trended toward waterborne coatings. "The effort and focus on meeting various VOC requirements have led manufacturers of automotive refinish coatings to look to new or non-traditional solutions, such as aerosol-can delivery methods and UV curing," notes Mr. Richards. Marine coatings are largely solvent-based and expected to remain that way, notes Mr. Nerlfi. For industrial maintenance applications, some high performance waterborne topcoats have been introduced to the market, but solvent-based epoxys primers and alkyd topcoats remain the leading products in this market sector.

TECHNOLOGY DEVELOPMENTS

Water-based Technologies

Air Products Polymers has developed second generation vinyl acetate ethylene (VAE) copolymers designed for the low-VOC architectural coatings market. Airflex EF811 is a high performance, cost-competitive replacement for vinyl acrylic polymers. Air Products also developed Hybridur[R] 870 and Hybridur[R] 878 waterborne resin technologies that entangle acrylic and urethane polymers in an interpenetrating network. These cost-effective waterborne resins combine the affordability of an acrylic with the abrasion and chemical resistance of a polyurethane dispersion (PUD). The technology enables the formulation of N-methylpyrrolidone (NMP) free coatings and inks, and according to Curt Junge, North American epoxy market manager for Air Products, is an NMP-free hybrid that maintains all of the properties of a PUD.

Reichhold has several new waterborne technologies on the market. Kelsol[R] 8100 is a waterborne alkyd acrylic hybrid resin for stain applications that offers very good shelf stability. The company is also developing a line of water-dispersed alkyd resins for architectural and industrial maintenance applications and a one-component waterborne urethane product line for, wood flooring and other wood care applications. Arolon[R] 848 is a water-based acrylic emulsion resin that is low-VOC and low HAPS. Designed for airless spray applications, it possesses excellent corrosion resistance and finds use in direct-to-metal OEM and industrial maintenance applications

Arolon[R] 5900, the first in a new line of water-dispersible polyols from Reichhold that are designed for two-component waterborne coatings for industrial applications, offers performance similar to that provided by traditional solids-containing coatings. Burnoc[R] DNW5000 is the first in a new line of water-dispersible polyisocyanates for two-component urethane systems from Reichhold's parent company, DIC. This product has potential applications for wood flooring, industrial maintenance, and some OEM uses.

Resolution Performance Products offers DPW 6520 epoxy dispersion with DPC 6870 curing agent dispersion for corrosion-resistant, waterborne epoxy coatings that perform equivalently or better than traditional solventborne systems. High performance midcoat and primer formulations (starting point formulas 1700, 1728, and 1729) are also available.

Rohm and Haas has developed reduced VOC offsets for a number of its current offerings that are being evaluated and trialed by customers. Rhoplex Multilobe[TM] 300 emulsion polymer is a 50 g/l VOC capable version of its conventional VOC counterpart Rhoplex Multilobe 200--the industry standard for 100% acrylic binders used in exterior flat and satin house paints. Rhoplex[TM]SG-30 is a 100% acrylic emulsion designed to meet the needs of new regulations for 150 g/L VOC semigloss interior and exterior architectural paints that enables paint manufacturers to formulate at lower VOC while maintaining key properties of conventional products.

Rovace[TM] 9900 emulsion polymer from Rohm and Haas is a vinyl acrylic binder for architectural coatings that does not require the use of coalescing solvents for film formation and application properties. The solvent-free PVA demonstrates comparable or even higher scrub resistance than the best of the high scrub PVAs at various PVC levels and volume solids. The polymer also has low odor in both the emulsion and in the finished paint. Excellent pigment binding allows a wide range of pigment volume concentrations from flat to semigloss with outstanding properties.

Solventborne Paints

The second most prevalent technology is high-solids solventborne paints and coatings. Solids content has increased dramatically as manufacturers have reformulated their coating products with alternative solvents that provide the desired performance level expected by customers. "One benefit of the increased solids content is that applicators of high-solids coatings have noted significant labor savings due to their ability to more quickly build film than with lower solids materials," says Mr. Brown. Reformulation has enabled the continued use of solvent-based coatings in market segments where waterborne coatings cannot provide the desired cost/performance benefit.

EPS CCA offers patented self-coalescing emulsions that are designed to allow maximum use of glycols for open time adjustments. "Open time has a direct correlation to the final appearance of the job resulting in continued satisfaction of the homeowner of either their own or the contractor's application of the coatings," notes Mr. Johnson. "This addresses the major concern of users about the final appearance advantage for solvent-based coatings."

Resolution Performance Products (RPP) offers a broad range of products designed to meet the latest regulatory requirements for industrial maintenance coatings. The company has launched a new grade of Bis-F liquid epoxy resin called EPON[TM] Resin 863 with low viscosity and improved crystallization resistance for these types of applications. EPON Resin 8021 is one of a full line of rapid-cure, low-viscosity epoxy-polyacrylate hybrids that yield low-VOC coatings with rapid, room temperature amine cure.

Powder Coatings

The global powder coatings market was estimated by The ChemQuest Group to be $3.3 billion in 2002, with North America claiming a 23% share, Europe 43%, Asia Pacific 25%, and the rest of the world the remaining 9% of the market. It is becoming a mature market, with application limited to the OEM sector. Special equipment and a controlled environment are required for powder coatings. It is expected that market growth will come from use of powder coatings on wood substrates, according to Mr. Nerlfi.

Reichhold recently launched its Fineclad[R] M8230 and M8913 super durable polyester resins for powder coatings, which unlike conventional polyesters, offer exterior durability for 5+ years in industrial paint applications. Reichhold's parent company, DIC, now offers its new GMA acrylic powder coating technology for high-end automotive applications. These coatings provide exterior durability and excellent clarity in clear coat applications. Recently, Reichhold expanded its global capacity for powder resins at both its Vienna, Austria and St. Louis, MO facilities.

Radiation-Cured Coatings

Radiation-cured coatings have drawn interest owing to their high performance and because most formulations are 100% solids. Ultraviolet (UV) and electron beam (EB) technology has found application only in the OEM sector because these coatings require a controlled environment and specialized equipment. Formulation costs are also expensive when compared to other coating technologies; however, because of the high solids content, more square feet of surface can be covered per gallon. "There is significant room for growth for UV/EB technology," says Mr. Brown. Benefits of the technology include increased line speeds, reduced curing temperatures, smaller equipment footprint, and improved product performance. In North America, UV/EB technology accounts for perhaps 3-5% of the overall market for coatings, inks, and adhesives and totals $700 million, which is approximately 40% of the global market. Mr. Brown anticipates that, like powder coatings, UV/EB technology could replace 10-20% of the market eventually.

Surface Specialties UCB has developed new UV-curable powder coatings, Uvecoat[R], that have allowed its customers to capitalize on creative yet sound curing alternatives, especially in applications where outstanding weatherability is sought. The company also has several waterborne UV-cure systems for industrial coating and graphic arts applications.

Electrodeposition coatings are applied in automotive manufacturing facilities onto the chassis of cars as the first coat onto the metal surface. Some companies are using electrodeposition coatings as the primer and topcoat. "This approach is a viable technology, but it requires special equipment, computer control, and training," notes Mr. Nerlfi. Because these coatings are tied so closely to the auto industry, they have experienced only incremental growth. "While electrodeposition coatings are widely used in the auto industry, the pressure from car makers to reduce cost through reduction of coating thickness (while retaining the same level of corrosion protection) has resulted in volume declines," Mr. Nerlfi adds.

The development of these different technologies has helped the industry comply with the increasing VOC regulations over the past 30 years. "VOC emissions will continue to go down, not because of new regulations, but because the existing regulations force emissions reductions as new technology for doing so becomes available," says John Gilbert, technology manager for BASF Automotive OEM Coatings in North America. "Although it is tempting to criticize the complexity of these regulations, they actually achieve their intended purpose of steadily lowering emission rates as new technology is developed, without being a detriment to commerce. One danger is that coatings operations will move to less-regulated countries, where older, cheaper, higher-VOC technologies can still be used," he continues.

Some disagree that the appropriate technology is available to meet the regulatory requirements. According to Mr. Lewis, the justification that "technology exists" is not a sound basis for making new regulations. "Regulators should consider how well the existing technology works and not just whether or not technology is available," he notes. Mr. Ciepiel of The Flood Company is also concerned that regulators will move faster than appropriate technology can be developed. "The result will be that consumers will end up with inferior products and the credibility of both manufacturers and retailers will be negatively impacted," he says.

The frantic pace of technology development over the last three decades has left the industry very fragmented from a technology standpoint, according to Mr. Brown. "I expect the industry will consolidate its technology options around a small number of choices, with waterborne the standard for architectural and high-solids, and 100% solids the standard for the OEM markets," he adds. A harmonized, global approach to regulation is also needed, according to Mr. Richards. "The existing diverse set of regulations makes it more difficult than ever to argue the business case for many products as the time between new regulations becomes ever shorter in any given region and product life cycles also become shorter and shorter," he explains.

LOOKING AHEAD

Further regulation is a given. "VOC regulations will continue to drive changes in the way we do business," says Mr. Scoville. "Regulations are just as significant as other economic factors. The main challenge will be to stay ahead of the curve of change," he notes. "All businesses must generate a return on the R & D investment made for reduced-VOC coatings," adds Mr. Gilbert. "If the customer is not willing to pay for reduced-VOC coatings, then there will be no return on the R & D investment." The main challenge will be the continued development of technologies that allow paint formulators to introduce low VOC coatings that meet or exceed the performance of traditional coatings, notes Mr. Mittica.

The paint and coatings industry must make a strong effort to work with regulators to ensure that future restrictions allow for the production of products that meet the cost and performance criteria of consumers and also achieve the goal of reducing VOC and HAP emissions. "Although the various regulatory agencies may consider their work done, industry must continue to partner with each body to see that the regulations are effectively and efficiently implemented for the environment and for this industry," says Mr. Richards. Mr. Ciepiel adds that "individual companies like Flood Company can increase our research and development efforts to find new solutions and seek to work with regulators through trade associations." He expects that the VOC Policy Subcommittee of the NPCA Board will be successful in collaborating with regulators in the formulation of a realistic transitional plan to lower VOC paints. "We believe that some categories might have more relief from regulation than others as more reasonable restrictions are agreed upon," he adds.

Modification of regulatory approaches is also anticipated by many in the industry. "Investment in developing innovative concepts for alternative regulatory strategies and methods for assessing the true economic and environmental impacts of regulation is as important as investing in R & D efforts to develop innovative products that meet the VOC requirements," stresses Mr. Wendoll. Longer-term, Dunn-Edwards expects to see incorporation of VOC reactivity criteria into regulatory standards, along with a related factor known as "atmospheric availability"--the degree to which a specific VOC is volatilized, and how readily it is subtracted from air by processes other than ozone formation. Other innovative approaches such as performance-based standards that consider coverage and durability, exemption of low volatility compounds, simplified product line averaging, seasonal and regional deregulation, and public advisories should be evaluated as well.

Awareness of the impact of VOC regulations beyond resin and paint manufacturers is also important for the future success of the industry. "We need to keep in mind that the impact of VOC regulations is not limited to paint manufacturers. The impact also extends to retailers, painting contractors, builders, homeowners, and property owners of all stripes, including public agencies," says Mr. Wendoll. "The industry will need to put forth significant effort to educate retailers, contractors, and consumers on what to expect with regard to performance and application characteristics of low VOC paints and coatings," adds Mr. Ciepiel.

Table 1 -- EPA Categories of Industrial Surface Coatings Operations (a)

Automobile and Light Duty Truck Coating/Manufacturing
Boat Manufacturing
Fabric Coating, Printing, and Dyeing
Wood Building Products
Large Appliances
Metal Can
Metal Coil
Metal Furniture
Miscellaneous Metal Parts and Products
Paper and Other Web (Film and Foil)
Plastic Parts and Products
Reinforced Plastic Composites Manufacturing
Aerospace Coatings
Automobile Refinishing
Consumer Products
Shipbuilding
Wood Furniture Coatings

(a) Source: EPA website: www.epa.gov/ttn/atw/coat/coat.html.

Table 2 -- Selected U.S. Coating Regulations by Region*

                                                       Region
                                                           DE, NY,
                                            AIM      OTC   PA, VA   CARB
Coating                                     Current  2005  2005     2004

Gloss, 70+ @ 60                             380      250   250      250
Non-flat, 5-70 @ 60                         380      150   150      150
Flat, 15 @ 85, 5 @ 60                       250      100   100      100
Stain, does not conceal grain               550      250   250      250
Quick dry enamel, 70+ gloss, 8 hr dry hard  450      250   250      250
Quick dry primer, dry like enamel           450      200   200      350
Primer and undercoater                      350      200   200      200
Floor, opaque                               400      250   250      250
Varnish, clear wood finish                  450      350   350      350
Industrial maintenance, wood or metal,
  primer, mid- and topcoat,
  industrial use only                       450      340   340      250
Rust preventative, metal only               400      400            400
Dry gog                                     400      400   400      400
Sanding sealer                              550      350   350      350
Specialty primer, stain block type          --       350   350      350

                                                        Region
                                            SCAQMD  SCAQMD          Bay
                                            2002    2006    SCAQMD  Area
Coating                                     (July)  (July)  2008    2004

Gloss, 70+ @ 60                             150      50             250
Non-flat, 5-70 @ 60                         150      50             150
Flat, 15 @ 85, 5 @ 60                       100             50      100
Stain, does not conceal grain               250                     250
Quick dry enamel, 70+ gloss, 8 hr dry hard  250      50             250
Quick dry primer, dry like enamel           200     100             200
Primer and undercoater                      200     100             200
Floor, opaque                               100      50             250
Varnish, clear wood finish                  350                     350
Industrial maintenance, wood or metal,
  primer, mid- and topcoat,
  industrial use only                       250                     250
Rust preventative, metal only               400     100             400
Dry gog                                     400
Sanding sealer                                                      350
Specialty primer, stain block type          350     100

* All measurements are in grams per liter.

Table 3 -- Selected European Coating Regulations*

                                        2007            2010
Coatings                            Water  Solvent  Water  Solvent

Interior wall
  Gloss <25[degrees]                 75    400       30     30
  Gloss >25[degrees]                150    400      100    100
Exterior cementitious                75    400       40    450
Int. ext. wood or metal trim and
  clading                           150    400      130    300
Int. ext. transparent, semi-trans,
  opaque stain                      150    500      130    400
Low build wood stain                150    700      130    700
Primer and stainblock                50    450       50    350
Primer, substrate stabilizing,
  hydrophobic                        50    750       50    750
One-pack floor, hygiene, anti-
  grafitti, corrosion and flame
  retardant                         140    600      140    600
Two-pack as above                   140    550      140    500
Multi-color                         150    400      100    100
Decorative effect                   300    500      200    200

All measurements are in grams per liter.

by Cynthia Challener

JCT COATINGSTECH, Contributing Writer