TBAC VOC Exemption StatusIssuing time:2024-07-29 17:04 As of the date of publication, TBAC wasalready exempt in 28 states: Shasta County, CA; Pima County, AZ; the city of Louisville,KY; and Puerto Rico. TBAC is also VOC-exemptin Pennsylvania,but not for use in AIM (architectural and industrial maintenance) coatings.This is because the Pennsylvania Department of Environmental Protection AIMcoating rule includes California'slist of VOC-exempt compounds, which needs to be updated.2 The status of the TBAC exemption, as of November 2005, isshown on the map in Figure 1. The states in green either exempted TBACautomatically or have already completed their VOC definition update. States inyellow will grant some form of interim relief during the rulemaking period. Howthis relief is granted varies from state to state, with some states simplyrequiring that TBAC users report their emissions as required by the federalrule, while others will allow TBAC to be used as an exempt compound only viapermits or variances. The states that did not grant interim relief - Arizona, Kentucky, Michigan and Oregon- are expected to have completed their rulemaking process by early 2006. California has also begun the process to exempt TBAC. In a recent draftEnvironmental Impact Assessment,3 the Cali¬fornia Air Resources Board (CARB)indicates it plans to exempt TBAC in certain consumer product categories. CARBhas tied the exemption to its CONS-2 rulemaking process, which will probablynot be completed until 2007. So, TBAC will probably not be available as acompliance tool for consumer product categories for another year or two. However,in a Suggested Control Measures (SCM) for automotive refinish coatings,4 CARBsuggests that the Air Quality Management districts and counties may exempt TBACas a way to achieve mandated VOC reduction targets. CARB, the state regulatoryagency, regulates only consumer products, but provides regulatory guidance tothe Air Quality Management districts and counties. The districts and countiesregulate VOC emissions from point sources such as auto-body repair shops andwood coating operations. State guidance comes in the form of environmentalimpact assessments (EIAs) and SCMs. As a result, the South Coast Air QualityAir Management District (SCAQMD) has partially exempted TBAC in its automotivecoatings rule (1151).5 Other districts and counties are expected to follow thelead of SCAQMD and CARB. |
