Ask the Expert Question-and-Answer Archive

by Ron Joseph

January, 2005

Calculating VOC Compliance for Navy Antennas

Q. I provide oversight on contractor's resurfacing of antenna arrays. I understand that when the contractor resurfaces an antenna he has to certafy that the VOC content of the products he uses is less than or equal to the Federal VOC content (530 g/L for antennas). The contractor uses Xylene to solvent clean the surfaces. Xylene's VOC is over 530 g/L. It's 875 g/L. The contractor also uses a primer that's over the 530 g/L limit. My question is how is this in compliance? Is it because the solvent cleaner is not considered a part of the coating? What about the primer?

They only use 1.125 pints of primer per antenna. Does this allow it to be used?

Unfortunately, I do not know to which regulation you are referring; therefore, I can't give you a direct answer. In most regulations, the solvent used to prepare the metal surface is not included in the calculation of VOC for the coating. On the other hand, if the paint is thinned with the solvent, then the calculation does include the solvent. In the regulation to which you are referring the Xylene might not be regulated, since according to what you wrote it is used solely to prepare the surfaces.

If the primer has a VOC that is outside the limit of the regulation, then your assumption that it is out of compliance is correct. You need to see if the regulation has separate values for primer and topcoat.

Finally, many regulations exempt low quantity usage. This can be based on a daily, monthly or annual basis, and you will need to read the regulation to see if the contractor falls into such an exemption. If the contractor uses 1.125 pints of coating per antenna, but refurbishes 100 antennas, then the coating usage is no longer a small qnantity.

I hope this helps, but without actually seeing the specific regulation to which you are referring, I cannot help you further.

Best wishes,

Ron Joseph