Understanding Canada’s VOC regulations

All images courtesy WR Meadows
All images courtesy WR Meadows

By Dianne Carey, CSI, CDT
For years, the phrase ‘volatile organic compounds (VOCs)’ has been associated with issues such as smog, greenhouse gases (GHGs), air pollution, and ozone layer depletion. Still, many Canadian design professionals are not overly familiar with the specific regulations limiting VOC release into the atmosphere. Even more problematically, many are not sure how these rules have an impact on common building products.

When released into the air, VOCs photochemically react with nitrogen oxides (NOX) found in the atmosphere to form ground-level ozone and particulates. The more VOCs released into the atmosphere, the more ground-level ozone and particulates are produced, resulting in increased ozone formation.

At ground level, ozone is considered one of the primary components of smog. In basic terms:

VOCs + NOx + Sunlight = Ozone
Ozone + Particulates = Smog

In addition to having a negative impact on air quality, these emissions and the resulting smog formation can also be a significant health concern. Exposure to VOCs and smog may contribute to numerous adverse health effects, including:

  • eye irritation;
  • respiratory tract irritation;
  • difficulty breathing;
  • headaches;
  • allergic reactions;
  • rashes;
  • dizziness;
  • nausea;
  • fatigue;
  • loss of co-ordination; and
  • possible damage to the liver, kidneys, and central nervous system.

Exposure to excessive smog can also exacerbate existing medical conditions such as asthma.

A common misconception is all harmful VOCs released into the atmosphere come from the transportation sector (e.g. car/truck exhaust). However, these emissions can come from either synthetic or natural sources, both indoors and out. VOCs found inside buildings include those released by products and materials used, installed, or applied in the built environment.

With each passing generation, the quantity of VOCs emitted into the atmosphere continues to increase at a staggering rate. Beyond regulating VOCs from transportation/exhaust sources, governments and regulatory agencies worldwide now find it necessary to place limits on emissions from both consumer and industrial products.

Numerous jurisdictions have enacted VOC restrictions on consumer products such as aerosols, hair sprays, deodorants, air fresheners, and household cleaners. Additionally, many jurisdictions have now also passed regulations limiting VOCs on commercial and industrial products such as architectural coatings and paints, adhesives, and sealants.

Volatile organic compound (VOC) restrictions across North America.
Volatile organic compound (VOC) restrictions across North America.

Regulating VOCs
In 1999, the U.S. Environmental Protection Agency (EPA) issued the Architectural and Industrial Maintenance (AIM) Coatings Rule. ‘Architectural coatings’ are defined as paints, stains, varnishes, lacquers, and primers applied to stationary structures or traffic surfaces.

Both the United States and Canada now have enacted national or federal architectural coatings VOC regulations that govern their respective countries. The U.S. AIM Rule was enacted to restrict VOC emissions on a national/federal level and in areas of the United States not already governed by another regional, state, or local regulation. The map in Figure 1 illustrates the areas in North America that currently have regulations restricting VOCs on architectural coatings. There are also numerous coatings VOC regulations found worldwide, including China, Japan, Korea, Hong Kong, and the European Union (except Luxemburg).

Along with the consumer product and architectural coating VOC regulations, there are numerous U.S. jurisdictions that have also implemented regulations restricting VOC emissions on adhesive and sealant products. The Ozone Transport Commission (OTC) region (i.e. northeastern states, excluding Massachusetts and Vermont), certain air districts in California, and Washington, D.C., currently have region-specific adhesive and sealant VOC regulations. Currently, there are no federal or national adhesive and sealant regulations in North America.

Understanding national, provincial, and local rules regarding VOCs is critical for properly specifying and using products such as this non-yellowing curing and sealing compound.
Understanding national, provincial, and local rules regarding VOCs is critical for properly specifying and using products such as this non-yellowing curing and sealing compound.

VOCs and Canada
In September 1999, Environment Canada passed into law the Canadian Environmental Protection Act (CEPA), aimed at “respecting pollution prevention and the protection of the environment and human health in order to contribute to sustainable development.” After its introduction, studies indicated implementation of an architectural coatings VOC regulation could significantly reduce the VOCs being emitted.

At the time, Environment Canada determined the federal U.S. AIM regulation was too lax in some of the product categories. At the same time, the more stringent VOC requirements found in some of the California air districts were too restrictive, given the colder Canadian climate and levels of smog and pollution present at that time.

Additional investigations indicated the OTC rule specific to the northeast United States would be the most appropriate regulation after which to model a future Canadian rule. The similar weather conditions found in the OTC states, along with the potential benefit of having alike VOC requirements in regions close in proximity, were two persuading factors.

Once the specifics of the proposed Canadian regulation had been decided on, additional studies determined that the amount of improvement expected with the implementation of such a regulation. In 2005, Environment Canada estimated 51 kilotonnes of VOCs were being emitted into the atmosphere from architectural coatings throughout the country. By enacting the architectural coatings VOC regulation, Environment Canada estimated that they could reduce this amount by approximately 28 per cent. (For more information, visit www.gazette.gc.ca/rp-pr/p1/2008/2008-04-26/html/reg1-eng.html).

Applied in residential applications, this curing and sealing compound complies with current Canadian volatile organic compound (VOC) regulations. It is spray-applied to seal stamped concrete.
Applied in residential applications, this curing and sealing compound complies with current Canadian volatile organic compound (VOC) regulations. It is spray-applied to seal stamped concrete.

In September 2009, a decade after CEPA, the Minister of the Environment enacted the Canadian Architectural Coatings VOC Regulation. In Canada, an architectural coating is defined as:

a product to be applied onto or impregnated into a substrate, for use on traffic surfaces such as streets and highways, curbs, berms, driveways, parking lots, sidewalks and airport runways, or stationary structures, including temporary buildings and their appurtenances, whether installed or detached. (To read more, visit www.gazette.gc.ca/rp-pr/p2/2009/2009-09-30/html/sor-dors264-eng.html).

The regulation sets mandatory, maximum allowable VOC concentration limits for 53 categories of architectural coatings and governs any such products manufactured, imported, sold, or offered for sale in all Canadian provinces and territories. Figure 2 provides an example of some of the product categories.

VOC product limits.
VOC product limits.

Coming into force
The Canadian Architectural Coatings VOC Regulation includes a table column titled, “Regulations Come into Force.” Listed as “1st,” “2nd,” “3rd,” etc., this value is the corresponding anniversary date (from the date the regulation was enacted) on which the VOC rule for that specific product category will be enforced. For example, a category that “comes into force” on the first anniversary would take effect on the first anniversary of the date the regulation was originally passed into law (September 9, 2009), which would make it enforceable on September 9, 2010. A category that takes effect on the second anniversary would have an enforcement date of September 9, 2011.

The fact there is not just a single, encompassing enforcement date for all product categories is considered by many to be the most confusing aspect of the regulation. Manufacturers, design/construction professionals, and users alike need to be extremely diligent about ensuring the products they are manufacturing, specifying, and using are in compliance with the regulation.

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