TARKSOL

Clean Air Solvents and Exempt Solvents

1990 Clean Air Act and OTC States

Dec. 17, 05

Applied to Tarksone and Tarksol SC Plus

The Federal 1990 Clean Air Act mandated the States to implement Regulations to reduce and eliminate VOC’s (Volatile Organic Compounds) in Industrial, Consumer and AIM Coatings for use, manufacturing and sales.

Tarksol, Inc has been working on R&D for solvents and products to meet and exceed all the Regulations covered by the Clean Air Act, South Coast Air Quality Management and the OTC (Ozone Transport Commission) covering 13 states in the NE. Tarksol, Inc. has spent 15 years working on this technology, resulting in 3 issued US patents and several current pending patents. All technology is being developed for VOC compliant solvents for use in AIM Coatings, Consumer Products, and Industrial Applications.

Since, the 1990 Federal Clean Air Act has been implemented, the states have developed their own regulations pertaining to each individual state. The states are mandated to use Federal law, however, they can make the Regulations more stringent making the state regulation set precedence over the Federal law. This requires a manufacturer to comply with each individual state regulation.

Tarksol has been asked by several manufacturers to document “their’ product will meet the VOC regulations in particular states. Tarksol can not make that statement for several reasons; 1. The Tarksol products are designed to meet Federal and state laws and Regulations. 2. Tarksol can not monitor each state and all their different regulations. 3. Tarksol has no knowledge of the customer’s formulations and what other solvents or chemicals used in their products, and 3. It is the responsibility of the manufacturer or compounder to assure their product meets the individual state VOC regulations they are selling into.

Facts

For Tarksone and Tarksol SC Plus for use in compounded products

Tarksone - A VOC exempt product under Federal Law and all state regulations.

Tarksol SC Plus – A Clean Air Solvent as defined by AQMD and OTC ( New York State )

New York State

Consumer Products

New York State Rules and Regulations:

Subpart 235-3

235-3 (al) Consumer product means a chemically formulated product used by household and institutional consumers including, but not limited to, detergents; cleaning compounds; polishes; floor finishes; cosmetics; personal care products; home, lawn, and garden products; disinfectants; sanitizers; aerosol paints; and automotive specialty products; but does not include paint products, furniture coatings, or architectural coatings.

235-3 (cf) Institutional product or Industrial and Institutional (I&I) product means a consumer product that is designed for use in the maintenance or operation of an establishment that:

1.       manufactures, transports, or sells goods or commodities or provide services for profit; or

2.       is engaged in the nonprofit promotion of a particular public, educational, or charitable cause.

Establishments include, but not limited to, government agencies, factories, schools, hospitals, sanitariums, prisons, restaurants, hotels, stores, automobile service and parts centers, health clubs, theaters, or transportation companies. Institutional products does not include household products and products that are incorporated into or used exclusively in the manufacture or construction of the goods or commodities at the site of the establishment.

235-3 (cn) LVP-VOC means a chemical compound or mixture that contains at least one carbon atom and meets one of the following:

1.       has a vapor pressure less than 0.1 mm Hg at 20º C, as determine by CARB Method 310.

Tarksol SC Plus has a vapor pressure less then 0.1 mm Hg at 20º C.

235-4.1 (f) The VOC content limits specified in Section 235-3 of this part (the part) shall not apply to any LVP-VOC ( Tarksol SC Plus).

Federal Regulations 40 CFR Ch 1 ( 7-1-05 Edition) § 59.204 (I)

For hydrocarbon solvents that are complex mixtures of many different compounds and that are supplied on a specification basis for use in a consumer product, the vapor pressure of the hydrocarbon blend may be used to demonstrate compliance with the voc content limits of this section (§ 59.204). Identification of the concentration and vapor pressure for each component in the blend is not required for compliance with this subpart.

New York State

Paint, Furniture, Architectural Coatings

New York State Rules and Regulations:

Regulation 205

205.6 (a) Calculation of VOC content.

(1)     With the exception of low solids coatings, determine the VOC content in grams of VOC per liter of coating thinned to the manufacturer’s maximum recommendation, excluding the volume of any water and exempt compounds. Determine the VOC content using the following equation:

                                                         (Ws – Ww –Wec)

                          VOC Content =     ---------------------

                                                         (Vm)

VOC content = grams of VOC per liter of coating

Ws = weight of volatiles, in grams

Ww = weight of water, in grams

Wec = weight of exempted compounds, in grams

Vm = volume of coating, in liters

Vw = volume of water, in liters

Vec = volume of exempted compounds, in liters

Example of coating:

For calculation purpose of Architectural Coatings, we will assume a Clean Air Solvent is not exempt in this regulation and include it as a volatile. It is exempt under Consumer Products.

Ws = 774.1 grams (Tarksone + Tarksolene + Tarksol SC Plus)

Ww = 0

Wec = 688.6 grams (Tarksone + Tarksol SC Plus + 15% of Tarksolene)

Vm = 1 Liter

Vw = 0

Vec = .585 Liters

                                                                       (774.2) – (0) – (688.6)

                                             VOC Content =    ---------------------------------

(1)      

                                                      85.6                           

                                                    VOC Content =     --------------   = 85.6 grams/L

                                                        1 Liter                             

According to § 205.6 of the New York State Department of Environmental Conservation Rules and Regulations, the above coating would not be a VOC.

EPA Method 24 is the actual VOC measurement. Any finial coating formulation should be tested by Method 24 for actual VOC content.