VOC Regulations

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Technical Advisory Document TAD0025

VOC Regulations for Coatings on Buildings

Current European legislation for VOC emissions is covered by the following EC directives:

Directive 1999/13/EC – Otherwise known as the Solvent Emissions Directive (SED), implemented in the UK by the Process Guidance Note PG6/23 of the Environmental Protection Act. This legislation essentially covers solvent emissions from permanent painting installations, and compliance is determined by the paint user submitting data to their local authority regarding the weight ratio of paint solids to VOC, which must fall within stated limits. The painting installation is deemed ‘compliant’, rather than the coatings themselves.

Current limits as follows:

1. Installations using below 5 tonnes VOC per annum: Exempt from SED (but must still keep records of inventory to prove consumption levels).
2. Installations using between 5 – 15 tonnes VOC per annum: Weight ratio of paint solids to VOC shall be below 1:0.60
3. Installations using over 15 tonnes VOC per annum: Weight ratio of paint solids to VOC shall be below 1:0.37

For non-SED applications, an amendment to the SED has been issued, namely:

Directive 2004/42/CE – Otherwise known as the Paint Product Directive (PPD), implemented in the UK as Statutory Implement 2005 No 2773.

This act applies VOC limits to paints applied in-situ to buildings, their trim, fittings and associated structures for decorative, functional or protective purpose.

Initially this act was intended to cover just decorative coatings and automotive refinish sectors, however it has been extended to include the word ‘protection’, therefore site applied corrosion protection and fire protection could now come into scope.

The PPD sub-divides coatings into a number of categories, most of which do not apply to Leighs product range. VOC limits are imposed for solvent based and water based coatings within each category, in much the same way that we applied VOC limits to all coatings up to 2005, i.e. before ‘compliant coatings’ were replaced by the SED.

The main categories of interest within the PPD are:

Category (i) “One pack performance coatings” – defined as coatings designed for applications requiring a special performance such as primer and topcoats for plastics, ferrous and non ferrous metals, floor coatings, graffiti resistance, flame retardant and hygiene standards. (This is now generally taken to include fire protection).

Category (j) “Two pack performance coatings” – as category (i), but with a secondary component added prior to application.

For both category (i) and (j), the maximum VOC content as from 1st Jan 2010 is:

Water based <140gms/litre

Solvent based <500gms/litre

The technical data sheet values for practical VOC content in grams per litre will indicate whether any particular product is compliant within the limits of the PPD.

Shop applied Coatings delivered to Site

Any coatings which are applied within a painting installation which is controlled under the SED are specifically excluded from the requirements of the PPD. Once the shop applied coating has been allowed to cure and is delivered to site, the legislation assumes that there will be no further VOC emission from the coating.

BREEAM

A lot of queries are raised whether specific coatings are compliant under ‘BREEAM‘ (Building Research Establishment Environmental Assessment Method).

Essentially, BREEAM is a complex scoring system to assess the Eco-friendliness of any new building, in terms of energy efficiency, sustainability etc. The only part of a BREEAM document where paint is stated is in relation to VOCs in the Health & Wellbeing section of the assessment. This section states that building designers must try to consider sourcing materials and specify internal finishes and fittings which contribute low VOCs where practical.

The practical upshot is that any coating that is compliant under the PPD is considered to be BREEAM compatible.

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