December 1996

If you own or operate equipment that uses products that contain chemicals, it is your responsibility to determine if your company is required to comply with environmental regulations.

Material Safety Data Sheets (MSDSs) typically are used by businesses to determine the health hazards and precautions for safe handling and use of process materials. You also can use a MSDS to determine if a product contains chemicals regulated by the EPA.

The 1990 Clean Air Act (CAA) directs the U.S. Environmental Protection Agency (EPA) to regulate emissions into the air of 189 toxic chemicals. These chemicals, called Hazardous Air Pollutants (HAPs), are known or suspected carcinogens, and have high usage and emissions in a wide variety of industries, including printing, metal fabrication, autobody repair, automotive repair, wood finishing, dry cleaning and others. Consequently, the EPA has determined that emissions of these chemicals present a threat to human health or the environment.

As an owner or operator of equipment that uses products that contain chemicals, it is your responsibility to determine if your company uses any of the 189 regulated chemicals and whether you are required to adhere to strict controls. To determine if your company uses any of these chemicals (and, if so, in what annual quantities), do the following:

Find the Material Safety Data Sheet (MSDS) for each product you buy (solvents, paints, cleaners, thinners, inks, varnishes, primers, etc.). If you do not have a MSDS for each product, ask your vendor(s) to provide them to you. Vendors and suppliers of chemicals and other process materials are required by law to provide you with a MSDS for each product you purchase.

Look at Section II of the MSDS, usually titled "Hazardous Ingredients" (see example below), to determine if any of the 189 HAPs are used in that product. Compare the chemicals listed in Section II with the complete list of 189 HAPs. Some commonly used chemicals include: ethyl benzene, ethylene glycol, methyl ethyl ketone, methyl isobutyl ketone, toluene and xylene.

Example of Section II of a MSDS:

SECTION II - HAZARDOUS INGREDIENTS


                                      OCCUPATIONAL EXPOSURE LIMITS  WEIGHT
 HAZARDOUS COMPONENTS     CAS NUMBER    OSHA PEL     ACGIH TLV      PERCENT 
 -----------------------------------------------------------------------------
 XYLENES                  1330-20-7     435 MG/M3     435 MG/M3     40
 ETHYLBENZENE             100-41-4      100 PPM       100 PPM       8
 LIGHT AROMATIC NAPTHA    64742-95-6    N/A           N/A           <5.0%
 ALIPHATIC HYDROCARBON    N/A           N/A           N/A           <5.0%

Set aside the MSDSs for all products that contain any of the 189 HAPs. You are now ready to calculate your total annual usage of these chemicals. However, you may be able to avoid this task by reducing or eliminating these chemicals from your process materials. To learn how, continue reading the next section. To calculate your annual chemical usage, take your set-aside MSDSs and follow the steps on the Emissions Estimating Worksheet further down on this Web page.

AN ALTERNATIVE: POLLUTION PREVENTION

If calculating and tracking your use of regulated chemicals seems burdensome or confusing, or you don't want to worry about your compliance status, there may be steps you can take — for example, stop using the toxic materials that are regulated. Eliminating or minimizing the use of toxic substances is called "pollution prevention." The following pollution prevention opportunity can help your company:

• meet federal regulations and cut your paperwork burden;
• reduce costs by using fewer raw materials;
• cut waste transportation and disposal costs; and
• reduce long-term liability and insurance costs.

ELIMINATE USING REGULATED CHEMICALS

There are several approaches to eliminating the use of products that contain regulated chemicals. Following are some suggestions:

• Talk to your suppliers. Explain to them your interest in finding a way to eliminate the use of regulated chemicals. Ask if they supply other products that can get the job done but do not contain regulated chemicals or have harmful health effects. If your suppliers don't have any suggestions, get recommendations from your peers or potential new suppliers.
• Inquire about changing customer specifications. If external specifications require that you use a product containing regulated chemicals, ask the customer if a change would be acceptable. Propose a viable alternative that will reduce both your and their liability while improving the safety of the workplace.
• Ask for help from government technical assistance programs. You can get recommendations for alternative, non-regulated products, as well as help estimating air pollution emissions or other assistance, from government technical assistance programs.

CASE STUDY: SMALL METAL FABRICATOR WORKS WITH PAINT SUPPLIER TO REPLACE PROCESS MATERIALS

Capital Industries, Inc. is a metal fabricator in Seattle, Washington. The company, which was founded in 1952, employs approximately 100 shop employees and produces a wide variety of fabricated metal products.

Part of Capital Industries' daily production involves coating metal products with liquid paint. Owners Ronald and David Taylor were concerned about the environmental liability and permitting expenses associated with using paint products containing heavily regulated air pollutants. To address this concern they directed paintshop personnel to investigate less-toxic alternatives to the paints and primers the company was using.

The first step Paintshop Lead Ken Grimm took was to look at the MSDSs for each paint product purchased in the past year to determine which products contained regulated chemicals. He discovered that the paints and primers Capital Industries was using contained high percentages (40-60%) of xylene, toluene and isopropyl alcohol.

The second step Grimm took was to contact the company's primary supplier of paints and primers — Daniel Boone, Inc. of Tukwila, Washington — to find some viable alternatives. After several conversations and a few paint tests, Capital Industries began replacing the high-solvent-based paints and primers with high-solids/low-solvent paints and primers.

Through product replacement, Capital Industries went from using an annual 50 tons (100,000 lbs.) of xylene, toluene and isopropyl alcohol combined to an annual 15 tons (30,000 lbs.) of these chemicals combined — with no additional cost to production. In fact, the per unit paint cost went down because of better product transfer efficiency and less wasted material. The reduction of air pollutants also alleviated some reporting and permitting requirements, as well as improved the quality of the work environment.

Emissions Estimating Worksheet
(For use with the 189 Hazardous Air Pollutants List.)

Use this worksheet to do a mass-balance calculation of your annual emissions. This method is used to estimate the amount of chemical in your products, and assumes 100 percent of the chemical is emitted.

Make a separate copy of this worksheet for each product you have identified as containing regulated chemicals (see list of 189 HAPs). Write down the product name and the chemicals that are in that product in the appropriate spaces of the table. Then, follow Steps 1-5 to determine how many chemicals, and in what quantities, you use annually.

Step 1: Calculate Total Annual usage of Regulated Chemicals

Using invoices, add up the total gallons purchased of a product in one year. Multiply this total by the weight (lbs./gal.) of the product and record this figure in the "Total Pounds of Product" column in the table above. (The lbs./gal. is shown in the Physical/Chemical Data section of the MSDS.)

If specific gravity is given instead of actual lbs./gal., multiply the specific gravity by 8.34 to get lbs./gal. Multiply this figure by total gallons purchased, and record the total in the "Total Pounds of Product" column.

For example, say you purchased 2,000 gallons of a particular paint product, which weighs 9.17 lbs./gal., or has a specific gravity of 1.1. (To convert specific gravity to lbs./gal., multiply 1.1 by 8.34, which equals 9.17.) Next, multiply 2,000 gallons by 9.17 to calculate the total pounds of the product.

Example: 2,000 x 9.17 = 18,340
Enter 18,340 in the "Total Pounds of Product" column.

Section II of the MSDS lists the percentage of each chemical in the product. Often, this is called "Weight Percent." Find this number (if a range is given, use the highest number) and convert it to a decimal (multiply by 0.01). Record the new figure in the "Weight Percent" column in the table above. If weight percent is provided in a decimal, simply record that figure in the "Weight Percent" column.

For example, if Chemical "X" in the paint product you bought has a weight percent of 40, multiply 40 by 0.01 to calculate the weight percent.

Example: 40 x .01 = 0.4
Enter 0.4 in the "Weight Percent" column.

Multiply the number in the "Weight Percent" column with the quantity in "Total Pounds of Product" column, and record the total in the "Total Pounds of Chemical" column in the table above. Put a check in Column A if you know this chemical is found in other products. This will help remind you to add up the totals for each chemical from other worksheets.

For example, for Chemical "X" you would multiply the weight percent (0.4) by the total pounds of the chemical (18,340) to determine the total pound of the chemical.

Example: 0.4 x 18,340 = 7,336
Enter 7,336 in the "Total Pounds of Chemical" column.

Add the totals in the Total Pounds of Chemical column for each product, and divide by 2,000. This number is your total tons per year for all chemicals used in your process materials. Next, add the total pounds of each chemical (refer to Column A to identify chemicals found in multiple products) and divide by 2,000. This number is your total tons per year for each particular chemical.

For example, if Chemical "X" is found only in one product (i.e. Column A is not checked), you would divide the total pounds of the chemical (7,336) by 2,000 to determine the total tons of Chemical "X" you use in one year.

Example: 7,336 ÷ 2,000 = 3.67
Enter 3.67 in the "Total Tons of Chemical" column.

Add the Total Pounds/Year figures from each worksheet to determine the total pounds of all chemicals you use. Divide this figure by 2,000 to determine Total Tons/Year. Enter this figure in the Grand Total Tons of Chemicals (below the table). Depending on the quantity of chemicals you estimated your business uses, you may need to comply with several environmental regulations.

WHO TO CALL FOR HELP

Through each state in the Northwest, non-regulatory assistance is available for small businesses with air quality questions. The purpose of these programs is to:

• explain the air quality rules and recommend ways to comply;
• provide free, on-site technical assistance visits;
• help businesses estimate their air pollution emissions;
• refer businesses to needed resources; and
• provide information on potential sources of financing for compliance requirements.

For free, non-regulatory assistance and referrals, contact PPRC.

This fact sheet is intended for general reference only; it is not a complete statement of the technical or legal requirements associated with this regulation.