The Vote is Cast: National Rule Regarding the VOC (Volatile Organic Compound) - BodyShop Business
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The Vote is Cast: National Rule Regarding the VOC (Volatile Organic Compound)

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Mark R. Clark is owner of Professional PBE Systems in Waterloo, Iowa. He’s a popular industry speaker and consultant and is celebrating his 32nd year as a contributing editor to BodyShop Business.

In currently regulated areas, many shops
had a learning curve with new low-VOC products that will be shortened
considerably for the rest of us. What they discovered when they
began using high-solids products was that their main problems
were getting the finish to lie down smoothly and getting the paint
work to dry in the time they were accustom to.

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It looks like we’re finally
there. The Environmental Protection Agency (EPA) will at long
last offer a uniform National Rule regarding the VOC (Volatile
Organic Compound) content of our paint products. Given the EPA’s
ability to mandate virtually any level of VOCs they desired for
automotive refinish products, their final rule is good news indeed.

I’m pleased and happy to report that thanks
to lots of input from the members of the Auto Refinish Coalition
of the National Paint & Coatings Association, the new regulations
call for products that are good for the environment while still
being friendly to the painter.

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The Rule

The Clean Air Act of 1990 called for the EPA to draft regulations
that would reduce the total amount of VOCs dumped into the air
above the United States by 15 percent, and this new rule purports
to reduce the VOCs from auto refinish by 36,000 tons per year
– or a savings of 37 percent below our output today. To ensure
that paint productivity wasn’t drastically affected, members of
the Auto Refinish Coalition worked with regulators to help them
see there was a limit on how far they could reduce solvent content.

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Both body shops and paint jobbers owe a big "thank you"
to the paint manufacturers who went to bat for us in Washington
(and 17 different states). Thanks in large part to their input,
the new rule applies only to the manufacturers, processors and
importers of auto refinish products offered for sale in the United
States. As part of this new rule, each product will carry the
date it was manufactured on either the label or the lid of the
can. Coating manufacturers or importers will also file a single
report with the EPA, listing their name, address and an explanation
of their date coding if it wasn’t printed as the actual analog
date. Further reporting is required only if they change their
date coding method.

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There is no record keeping, application or equipment mandate for
body shops. Likewise there are no requirements for distributors
of these products to either report or restrict the sale of auto
paint.

"We wanted a uniform regulation that was good for the whole
industry," says Carl Schultz, Environmental Consultant to
the E.I. DuPont Company. "One set of product inventory keeps
our distributor’s costs down and also evens the playing field
for all body shops to compete equally."

How does the rule even the playing field? By equalizing the regulations
for all body shops. Until now, many shops in regulated areas competed
with shops across the river or across the county who were unregulated
and free to spray any finish they chose. This new rule will eliminate
the patchwork of regulations across the country, which made life
difficult for shops and distributors. (Paint jobbers had to carry
two or three inventories to service all their customers.)

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The National Rule won’t override existing state regulations, and
it also won’t contain any requirements for high-transfer spray
guns or closed-container gun washers. But state rules that call
for this equipment will still be in force. Common sense says that
even though they’re not required, both HVLP spray guns and automatic
gun washers are proven time and money savers in any body shop.

As for state reporting requirements, the purpose of most of them
is to demonstrate that shops are using compliant material. Most
states in the last several years have used the EPA’s ACT guidelines
and have rules with similar emission limits to the new National
Rule. With this in mind, it’s likely some states will remove their
reporting requirements because, after all, only compliant products
will be available for use. And of course, none of this affects
those "lucky" shops in Southern California, who must
use products with ultralow solvent content.

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According to Mark Morris, the EPA Environmental Engineer in charge
of drafting this rule, the EPA plans to publish the final rule
in the Federal Register in February 1997. Four months later, or
in June 1997, the automotive coatings manufacturers will stop
production of noncompliant finishes.

Paint-Shop Adjustments

The pollution prevention savings in VOC emissions comes from reformulating
the coatings products we currently use to contain more solids
and less solvent. The good news is that the levels of solvent
permitted by the new National Rule are still user friendly. As
any shop owner in Southern California can tell you, low/low VOC
products are tough to apply smoothly and take a long time to dry.

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The shops that are in a relatively recently regulated area, such
as Massachusetts, Rhode Island or Wisconsin, will see very little
change as a result of the uniform VOC rule. Other than a minor
adjustment in reduction or catalyzation, the products they’re
successfully using today already comply.

Likewise, shops that are using any paint manufacturer’s warranty
system are almost compliant, too. No paint manufacturer can afford
to offer a life-long consumer paint warranty unless it has products
that will really last the life of the vehicle.

Automotive finishes with long lives are made by using high-solids
formulas of durable and sophisticated resins and are almost uniformly
2K (two component, i.e. requires hardener). Not surprisingly,
the same high-solids/low-solvent products that last the life of
the car also exude less pollution into the air. These high-solids
products are available for sale today from your paint supplier.

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Will they work in your shop though? Like any change in technology,
how big a disruption it causes in your production is dependent
upon where your shop was before the change took place. If you
haven’t yet switched to two-component primer/surfacer and are
still using lacquer primer/surfacer in your shop, the newly mandated
high-solids surfacers will be quite different. What the 50 percent
of body shops that are already using 2K surfacer have discovered
is that even though the coats dry slower, fewer of them are required
to reach the same level of fill.

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Dry times of the newly required products will be similar to the
dry times of the high-solids products your shop is using now.
Clears, in particular, show off some of the benefits of high-solids/low-VOC
chemistry. These clears offer great gloss, have no haze back,
polish easily and resist the weather like gangbusters.

As highly productive shops have discovered, heating the finish
to drive out the solvent quickly makes for many more cars painted
in a day. As every paint shop in the country comes to use the
mandated products, most also will discover the magic of heat.
Heating the products you use today will speed your production,
period; heating the higher-solids products will do the same.

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"The new regulations won’t have a significant effect for
a well-capitalized, well-equipped body shop," says Ray Sieradzki,
technical director for Akzo-Nobel and member of the Auto Refinish
Coalition, adding that heat is essential to keep tack free time
down when using higher-solids products.

Also, keep in mind that a clean spray area becomes even more important
when the dust-free times take longer to arrive, so downdraft airflow
and a heated cure cycle are smart investments when using high-solids
paints.

Besides equipment, painter training will also affect how well
high-solids perform for your shop. All the major paint manufacturers
have been showing off their compliant-product offerings for more
than a year in their training centers, and they’ve also been instructing
their painter customers how to make the products look great. When
making shop calls in currently unregulated areas, paint reps have
been talking up the new stuff – obviously trying to be proactive
and calm their shop customers fears.

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Fear not folks, most of you are using products right now that
are compliant, or darn close. "In and around areas that already
contain state regulations, I calculate that 60 percent of the
body shops and 75 percent of the products they already use will
fall within the new compliance limits," says Ron Hilovsky,
manager of Regulatory Affairs for PPG Automotive Refinish Coatings,
a member of the Auto Refinish Coalition.

The Cost of Politics

The EPA says that all this cool technology will only increase
your cost by 10 cents per gallon or 30 cents per repair. I, however,
think this is unlikely.

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Through the magic of numbers, statistics and averages, the EPA
figures that a paint product that costs 30 percent more per gallon
but has 30 percent more resin solids will paint 30 percent more
area – for a net effect of basically zero. In fact, transfer efficiency
isn’t theoretical in the real world. The overspray cloud may look
similar, but it’s 30 percent more expensive as it’s sucked out
of the booth. And the residue in the bottom of an "empty"
can costs more, as does the excess product you overmixed.

In the original EPA ACT document, they calculated the cost to
reduce VOCs to the new rule’s limits would be about $600 per ton.
If you multiply that by the 36,000 tons they predict we’ll save
and divide the total by the 50,000 body shops in the United States,
the answer is about $400 per shop as a result of the new rule.
It seems to me that something more on the order of 10 percent
– not 10 cents – will be closer to reality.

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Still, another way to guess what the cost to your shop might be
goes like this: If the average collision is $1,500 and 10 percent
of that is total material for the job ($150) and 70 percent of
that is the paint costs ($100) and it really is a 10 percent price
hike for the compliant stuff, it comes to about $10 more per average
repair.

How much of an increase your shop experiences depends on what
you use now. If you use a high-solids or downdraft clear (approximately
25-35 percent of shops use one now), you’ll see little cost difference.
If your shop is still using lacquer undercoats and older acrylic
enamels, you may be in for sticker shock. Just remember, even
though the stuff costs more, it’ll go much further and look better
doing it.

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"Those shops working with warranted paint systems will see
little cost difference," says Bradley Richards, manager of
Coatings R & D for BASF Refinish, which is a member of the
Auto Refinish Coalition. "Those shops using older, high-VOC
finishes will see a moderate increase in cost due to increased
solids levels and the upgraded technology required for undercoats."

One piece of extremely good news is that since most mixing tints
will comply with the new rule, color match will not be affected
by this change. At one point, the paint manufacturers were fearful
that they’d have to create new mixing tints to meet very low-VOC
limits. This meant starting all over on color match – not only
every color reformulated but every alternate match as well. Thanks
to the Refinish Coalition, this isn’t necessary.

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Count on market competition keeping prices in line for the new
stuff. No paint manufacturer can afford to ask $100 a gallon for
a compliant product their competitor sells for $50. Just like
today, there’ll be a range of products available. And just like
today, there also will be a difference in how Brand A primer sprays
or how Brand B clear buffs. Trust your current supplier to offer
not only compliant products, but also productive ones.

"Our common goal was to achieve the EPA’s objective to lower
VOC emissions from the industry, while keeping costs to all as
low as possible," says Marc Kruzer, manager of Regulatory
Affairs for Sherwin-Williams Automotive Finishes Corp., a member
of the Auto Refinish Coalition. "We’ve worked to introduce
products that not only meet the proposed rule, but are of the
quality and performance our customers require."

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Money will be saved if the painter mixes all paint products in
suitably small amounts. If your shop doesn’t measure your undercoats
by the ounce now, seriously consider doing so when the higher-solids,
more expensive paints arrive at your shop.

The Vote is Cast

The new National VOC Rule will help save the atmosphere while
leaving our current paint technology mostly intact. Compliant
products from every paint manufacturer have been on the market
for several years now, so you can feel confident that when your
shop converts, the new products will work well and look great.

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"Our primary concern throughout this process has been the
ability of our customers to productively use the mandated products,"
says Jim Sell, senior council for the National Paint & Coatings
Association. "We made sure the EPA understood the body shop’s
problems, and I believe we’ve succeeded."

Special thanks to all the members of the Auto Refinish Coalition.

Categories and Limits

The EPA has proscribed solvent content limits on six categories
of automotive finishes: pretreatment/wash primer, primer/primer-surfacer,
primer/sealer, single and two-stage topcoats, three- or more-stage
topcoats and a category called specialty coatings. For each class
of product, the EPA has set solvent limits similar to many products
in use now.

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Specialty coatings include things like adhesion promoters, antiglare
coatings and elastomeric (flexible) coatings.

"We strongly support a broad definition of ‘specialty coatings’
in the National Rule to facilitate the introduction of new coating
products," says Ken Hine, technical, safety, health and environment
director for ICI Autocolor North America, which is a member of
the Auto Refinish Coalition. "We need to meet the requirements
of the OEM vehicle manufacturers for new plastic and metal-alloy
finishes that are specially formulated to deliver the performance
characteristics required by the car manufacturer."

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Point well taken. Without the option of calling a new primer for
some exotic magnesium alloy a "specialty coating," it
could take years to produce a workable product that had VOC content
low enough to fit in the regular "primer" category.

Time Limits – or Lack Thereof

With the National Rule, there’s no time limit for a distributor
to sell, or a body shop to use, current paint products. If you’re
in love with some particular product, you could buy a large stock
before June 1997 and legally spray it forever.

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The new rule applies only to paint manufacturers and only to products
they’ll manufacturer after June ’97. Every paint product in our
industry on the street now will be legal to use until it’s gone
(unless your state currently says otherwise). This easy transition
will help soften the blow for many shops.

Count on most major paint manufacturers to produce a little extra
of the current material to extend the time their customers can
continue to spray the old stuff. This opportunity to use up everyone’s
current inventory prevents a huge hazardous-waste problem. If
the EPA demanded that we all begin using new, higher-solids products
as of a specific date, all the current material would be illegal
and immediately become waste.

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Following Directions

Read any new directions carefully. A major cost to the paint manufacturers
will be to reprint all product literature.

Product bulletins or data sheets today may offer several reduction
options to suit a particular purpose, but some of the over-reduced
choices will no longer comply with the new rule – which measures
VOCs when paint is mixed up and ready to spray.

Be sure to ask your jobber or paint rep for current product literature
and some in-shop training when the rule takes effect.

The Regulatees

The EPA has identified four groups as requiring regulation to
reduce their contribution to air pollution, and auto refinish
is in the first group to be regulated. As you probably know, VOCs
combine with oxides of nitrogen and sunlight to form ground-level
ozone (smog). The less VOCs in the air, the less smog.

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In two-year cycles, the EPA will draft regulations for other groups
like commercial/industrial adhesives, wood processing and even
ship building.

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