Ask the Expert Question-and-Answer Archive

by Ron Joseph

March, 2007

EPA Requirements for Spray Painting of Filled Silicone Coatings

Q: Our company is seeking information in order to be in compliance with EPA requirements under the "Clean Air Act" for handling, mixing and spray painting of "FILLED SILICONE" ablative coatings to include paint booth exhaust and filtering as follows:

1. MI-15 Type II Ablator Base Part A - Trowelable
2. MI-15 Type I Ablator Base Part A (Sprayable)
3. Dibutylin dilaurate, MI-15 Type I, Curing Agent, Part B
4. MI-15 Type I Part C Silane Coupling Agent

All of the above are for an ablative coating application.

How much coating do you apply? .0055
Under what state regulation do you fall? none. small volume of work, local city rep says no permit required.
Do you fall into a NESHAP? not sure???
Do you have a spray booth in which you will apply the coating? yes, fully self contained & filtered built by NorAM.
What type of spray gun do you use? binks
Do you currently have any permits that allow you to apply coatings? none required due to small volume of work.

A: Based solely on what you’ve told me, I don't believe that you need to be concerned because the volume of paint you will be using is below the “de minimus” level.  However, do not under any circumstances take my answer to be fact. I suggest that you read your state or local air quality regulation and determine whether or not it contains a “de minimus” clause.  If so, does the coating you propose to use fall under that level?   It is also possible that the filled silicone ablative coating falls into a “Specialty Coatings” category for which no VOC limits have been set.  Have you checked the VOC level of the coating as it will be applied? Many ablative coatings have such high solids contents that they automatically comply with the regulations. Finally, if you have any lingering doubt, I suggest that you confirm this with your local air quality agency and perhaps also get the answer in writing.

Regards,

Ron Joseph