Ask the Expert Question-and-Answer Archive

by Ron Joseph

March, 2002

Labeling of Paint Cans

Q. We manufacture a VOC-free hybrid-epoxy coating. It seems all regulations are for coatings containing VOCs and hazardous materials. With 100% solids and no components regulated as hazardous - what labeling requirements apply?

A. Since your coatings are 100% solids and apparently do not contain any hazardous ingredients as defined by OSHA, you might not be subject to any labeling regulations. Since I'm not an expert on labeling, please don't take my word for this. However, I spend lots of time with large-volume coating end users and can assure you that they read the labels and MSDS with great care. Some companies, and in particular many military bases have sophisticated data bases in which they enter every smidgen of information that might need to be recorded.

Therefore, even if you are not subject to labeling regulations, it is my personal opinion that you should indicate very clearly on your labels and MSDS that your products have zero VOC, zero HAP, and are 100% solid. I assume, that the coatings are applied as packaged and that no VOC are added prior to application? Again, in my opinion you should make this very clear so that purchasing agents don't disqualify your product because they might think you are holding back information.

An excellent guideline for deciding on what information should be provided can be found in the South Coast Air Quality Management District (SCAQMD) Rule 443.1 which you can download from www.aqmd.gov.