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by Ron Joseph

December, 2007

Product Compliance

Q: Through my employment a company that provides certain products for cleaning automobiles. A couple of products they sell now have terrible odors to them that does not dissipate. One is a liquid coat for tires and the other is a aerosol for vinyl and plastic.

How are these products treated to make them compliant and who decides what is used to accomplish this? Also who verifies the product has satisfied the regulation?

My understanding brings me to think there is no testing of the compliant product. Plus the ingredient used makes the product almost unusable.

A: I'm not aware of any regulations concerning the odor of a paint or coating. The regulations of which I am aware concern the VOC (volatile organic compound, or solvent) content of coatings, and this should be stated on the label of the can. Typical VOC contents in the US are 3.5 lbs/gal, 2.0 lbs/gal, less water, etc.  However, VOCs contribute to the formation of photochemical smog, the brown haze that you see on the horizon of many industrial cities. As you well know, some solvents have a strong odor, other do not.  Some are pleasant smelling, others are not.

To the best of my knowledge, the coatings are compliant if they meet the standards set by the EPA or your local state agency. Bad odor is not incorporated into the regulations.

On the other hand, bad or unpleasant odors are causes for nuisance complaints and friends and neighbors have a right to complain to the local air pollution agency. If several complaints (defined in local agency regulations) are received by the agency, an inspector will be asked to go out and inspect the nuisance complaint.  The (San Francisco) Bay Area Air Quality Control District (BAAQMD) has published an excellent outline of its procedures concerning odor complaints.   

http://www.baaqmd.gov/enf/policies_and_procedures/final_complaint_guidelines.pdf 

If the odor complaint is warranted the offending party might be asked to take steps to minimize or eliminate the odors. 

As a consultant, I have been asked to assist offenders to find ways of eliminating odors. In some cases it was possible to vent the volatile emissions through a carbon canister, where the carbon acted much like a filter at the end of a cigarette. It adsorbed the offending vapors. In one case, a large industrial fan was installed on the roof of the building and the vapors were exhausted into the air at a level of approximately 30 ft above ground level.  In some cases the offending party can schedule painting or printing, etc., so that the emissions occur after the neighbors have gone home for the night. If the bad odor can be significantly reduced so as not to be objectionable, neighbors might be satisfied.  Odor nuisance complaints are usually remediated on a case-by-case basis, and it is not always necessary for the offending party to altogether eliminate the chemical compound from it operations.

Regards,

Ron Joseph


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