Hazardous Air Pollutants HAPs and Right to Know Regulations

Title III (Air Toxics Program) of CAAA-90 directs EPA to evaluate and control the emission of HAPs. Among the 189 compounds identified in CAAA-90 as hazardous (HAPs list), Brezinski [15] identifies 24 that are used in coatings, 17 organic compounds, 6 metal salts, and ammonia. Some of the 17 organics are used as monomers in binder synthesis and therefore are not emitted to the atmosphere. The EPA has authority to delete or add compounds to the list, and industry groups may petition EPA to take compounds off the list (referred to as "delist"). Delisting petitions under consideration at the time of this writing include ethylene glycol monobutylether (EGBE) aka (EB), methyl ethyl ketone (MEK), and methyl isobutyl ketone (MIBK). EGBE has been used in numerous ways in waterborne coatings. MEK and MIBK have been widely used as active solvents in HSSB coatings. A petition to delist methanol was denied on May 2, 2001.

In 1991 the EPA targeted 17 compounds from the HAP list for rapid reduction in emissions by including them in the 33/50 Program. Companies that joined this voluntary program agreed to reduce emissions of targeted HAPs by 33% by 1992 and by 50% by 1995. The target compounds were selected, at least in part, by consideration of use level rather than toxicity level. MEK and MIBK are targeted, and these are among the least toxic of all 189 chemicals on the HAP list as indicated by current petitions to delist these as HAPs. Companies are expected to be reluctant to spend development time and incur expenses in trying to meet 33/50 for MEK an MIBK since these compounds may not remain on the HAP list.

The Emergency Planning and Community Right to Know Act (EPCRA, also known as SARA; 1986, Title III) is also administered by the EPA. The EPCRA does not regulate emissions but rather requires reporting of emissions of compounds that are on yet another list of about 300 compounds, claimed to be toxic. The number of lists maintained by EPA is large. One of the EPA's important documents is the "List of Lists." Under EPCRA, companies are required to keep records and issue annual reports of emissions of compounds on the specified list (SARA 313). Data is compiled and reported annually through the Toxics Release Inventory (TRI).

The Ketones and Oxo Process Panels of the Chemical Manufacturers Association provide a guide [21] to solvent users in 1994 for assistance in understanding

Table 6.3 Regulatory Status of Common Solvents

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