Recommended CCME Standards and Guidelines for the ... · Reduction of VOC Emissions from Canadian Industrial Maintenance Coatings 1 1.0 Introduction 1.1 Background The Federal Smog

Recommended CCME Standardsand guidelines for the Reduction of VOC Emissions from CanadianIndustrial Maintenance Coatings

PN 1320

1 Canadian Automotive Parts Coatings Operations

The Canadian Council of Ministers of the Environment (CCME) is the major intergovernmental forum in Canada for discussion and joint action on environmental issues of national, international and globalconcern. The 14 member governments work as partners in developing nationally consistentenvironmental standards, practices and legislation.

Canadian Council of Ministers of the Environment123 Main , Suite 360

Winnipeg, Manitoba R3C 1A3Tel: (204) 948-2090Fax: (204) 948-2125

For additional copies, please contact:

CCME DocumentsToll Free 1-800-805-3025

www.ccme.ca

Comments regarding the content of this document and the contribution of material developed toimplement it would be greatly appreciated. Please send your contributions to:

Sustainable Consumption divisionNational Office of Pollution PreventionToxics Pollution Prevention Directorate

Environment CanadaOttawa, Canada K1A 0H3

Tel: (819) 953-1607Fax: (819) 953-5595

Prepared bythe Technical Sub Group for the Reduction of VOCs

from Canadian Industrial Maintenance Coatingsfor the CCME Working Group for Surface Coating Initiatives

VOC Phase I Management PlanInitiative V307

ISBN: 1-896997-21-X

© Canadian Council of Ministers of the Environment Inc., 2002

Table of Contents

Section I: National Standards & Guidelines for the Reduction of Volatile Organic Compounds from Industrial Maintenance Coatings: Non-Traffic Applications ............................................1

1.0 Introduction ..................................................................................................................................................11.1 Background .......................................................................................................................................11.2 The Industrial Maintenance Coatings Sector ....................................................................................1

2.0 Abbreviations & Definitions .....................................................................................................................32.1 Abbreviations ....................................................................................................................................32.2 Definitions .........................................................................................................................................3

3.0 Standards and Guidelines .........................................................................................................................53.1 Principles ...........................................................................................................................................53.2 Applicability ......................................................................................................................................53.3 VOC Content Limits .........................................................................................................................53.4 Operations .........................................................................................................................................63.5 Codes of Good Practice .....................................................................................................................63.6 VOC Content Calculation .................................................................................................................6

4.0 Technical Working Group Participating & Corresponding Members Industrials Maintenance Coatings: Stakeholder Lists (Non-Traffic and Traffic Markings) .........8

Section II: National Standards & Guidelines for the Reduction of Volatile Organic Compounds from Industrial Maintenance Coatings: Traffic Markings .........................................................13

1.0 Introduction................................................................................................................................................131.1 Background .....................................................................................................................................131.2 The Industrial Maintenance Coatings Sector ..................................................................................13

2.0 Abbreviations & Definitions ...................................................................................................................152.1 Abbreviations ..................................................................................................................................152.2 Definitions .......................................................................................................................................15

3.0 Standards and Guidelines: Traffic Paints.............................................................................................163.1 Applicability ....................................................................................................................................163.2 VOC Content Limits .......................................................................................................................163.3 Operations .......................................................................................................................................163.4 Codes of Good Practice ...................................................................................................................163.5 VOC Content Calculations ..............................................................................................................17

Reduction of VOC Emissions from Canadian Industrial Maintenance Coatings i

ii Reduction of VOC Emissions from Canadian Industrial Maintenance Coatings

4.0 Technical Working Group Participating & Corresponding Members .........................................18

Section III: Codes of Good Practice for Industrial Maintenance Coatings Operations (Traffic Markings & Non-Traffic Applications).............................................................................21

1.0 Elements of the Code of Good Practice .............................................................................................211.1 Solvent Management .......................................................................................................................211.2 Training ...........................................................................................................................................221.3 Materials Handling ..........................................................................................................................221.4 Equipment Operation, Maintenance and Cleaning .........................................................................23

2.0 Check List for Codes of Good Practices..............................................................................................25

SECTION I

NATIONAL STANDARDS & GUIDELINESFOR THE REDUCTION OF VOLATILE ORGANIC COMPOUNDS

FROM INDUSTRIAL MAINTENANCE COATINGS:

NON-TRAFFIC APPLICATIONS

Reduction of VOC Emissions from Canadian Industrial Maintenance Coatings 1

1.0 Introduction

1.1 Background

The Federal Smog Management Plan is a three-phase control program aimed at fully resolvingground level ozone problems by the year 2005.Phase 1 of the CCME Management Plan forNitrogen Oxides (NOx) and Volatile OrganicCompounds (VOCs) was published in 1990, Phase 2Federal Smog Management Plan in 1997, and Phase3 is currently under development by EnvironmentCanada and several government partners to refine theFederal Smog Management Plan initiatives.

The recommendations contained in this report weredeveloped pursuant to initiatives identified in thePhase 2 Federal Smog Management Plan, (1997),which called for a multi-stakeholder review of theIndustrial Maintenance Coatings (IMC) sector toverify Volatile Organic Compound (VOC) emissionestimates, assess the potential for reductions, anddevelop measures to ensure VOC emissionreductions from this sector.

These Standards and Guidelines apply to the non-traffic sub-sector of the IMC sector, i.e., they do notapply to traffic markings. They were developed inconsultation with a Technical Working Groupconsisting of industry stakeholders, representativesof federal and provincial governments, andrepresentatives of environmental public interestgroups (Part 4.0). The contributions of allparticipants and stakeholders who helped developthese guidelines are gratefully acknowledged.

While these Standards and Guidelines establishbroad measures for reducing VOC emissions inproducts and operations, it is acknowledged thatfederal, provincial/territorial or regionalenvironmental authorities may impose morestringent measures in response to regional or local problems.

1.2 The Industrial Maintenance Coatings Sector

For the purposes of these Standards and Guidelines,the term Industrial Maintenance Coatings applies toall non-architectural maintenance coatings used onstationary objects in field applications. TheseStandards and Guidelines apply to industrial coatingsused in restorative applications only, as opposed tocoatings applied to new equipment and products. Allarchitectural coatings are excluded since they werecovered by initiative V101 of the Phase IManagement Plan. These Standards and Guidelinesdo not apply to maintenance coatings applied to anymobile object such as railroad rolling stock andmotorized vehicles. Marine coatings are excluded inthe case of mobile vessels and structures, howeverthe Standards and Guidelines do apply to fixed,stationary structures such as oil rigs.

The IMC sector is made up of a number of sub-sectors, the most important of which are described inthe following list:

• structural steel;• bridges;• refineries and storage tanks;• drilling rigs;• chemical process plants;• pulp and paper plants; and,• road marking (traffic) paints.

Note that the last item, traffic markings, is not part ofthese Standards and Guidelines but is the subject ofseparate Standards and Guidelines (see Section II).

The volume usage in the various sub-sectors alsoranges widely, as do VOC emissions. Solvent-bornetraffic paints have a fairly high VOC content per litreand represent a substantial volume of annual productuse. Drilling rigs, on the other hand, have highlyspecialized requirements, which include a long

Section I

service life under severe exposure conditions, andthe coatings technology capable of providing therequired performance may inherently have a lowVOC content.

Despite the differences between the various IMCsub-sectors, there are also some clear similarities:

• the coatings are generally cured under ambientconditions and some (e.g., drilling rigs) may haveparticularly stringent cure requirements;

• the coatings are applied by commercialapplicators, specializing in the application of alimited range of end uses, (e.g., chemical orpetroleum facilities);

• the in-situ application of many of the productsmakes the use of emission control devicesimpractical;

• in-situ application means that some applicationefficiency enhancement technologies such aselectrostatic application are not feasible; and,

• the current application technologies used suggestlimited potential for further VOC reductionthrough improved coating efficiency, as thetechnology may already be efficient.

The main focus of these Standards and Guidelines ison product VOC content limits and good operatingpractices that minimize VOC emissions.

The only significant technological option applicableto the IMC sector appears to be limiting the use ofthe relatively inefficient conventional air spraytechnique for non-traffic IMC coating operations, tothe extent that it is still used. In general, the industryhas seen a dramatic shift in the past 10-20 yearsaway from the use of conventional spray. Roughestimates provided by the industry stakeholders whoparticipated in this study suggested that conventionalair spray may represent up to about 15% of all paintapplied, by volume, for the non-traffic IMC sub-sector. The trend is towards a lower proportion ofconventional spray use in the future for this sub-sector. As there are some applications whereconventional spray is needed (e.g., for fine metalwork, or where access is restricted) conventionalspray may not be eliminated entirely.The implementation of these Standards andGuidelines distinguishes between the manufactureand import of Industrial Maintenance Coatings, onthe one hand, and users (application) of IndustrialMaintenance Coatings, on the other. Implementationof limits applicable to the former activities willprecede limitations on IMC use.

2 Reduction of VOC Emissions from Canadian Industrial Maintenance Coatings


2.1 Abbreviations

ASTM American Society for Testing and Materials

BATEA Best Available Technology Economically Achievable

CCME Canadian Council of Ministers of the Environment

CPCA Canadian Paint and Coatings Association

NAICC National Air Issues Co-ordinating Committee

NOx Nitrogen oxides

U.S. EPA United States Environmental Protection Agency

VOC Volatile organic compound

2.2 Definitions

Architectural coatings: Coatings recommended forapplication to stationary structures and theirappurtenances. Includes residential homes,apartments, office buildings, institutions, factorybuildings, etc. This does not include industrialmaintenance coatings, which are restorative coatingsapplied to metal structures and their appurtenances in the field.

Extreme high durability coatings: An air drycoating, including a fluoropolymer-based coating,that is formulated and recommended for touch-up ofpre-coated aluminium extrusions and panels.

High temperature coatings: High performancecoatings formulated and recommended forapplication to substrates exposed continuously orintermittently to temperatures above 202ºC (400ºF).

Industrial maintenance coatings: Highperformance coatings, including (but not limited to)primers, sealers, undercoaters, intermediate coats,topcoats, anti-fouling coatings, nuclear coatings andquick-dry coatings, that are formulated andrecommended for application to metal and othersubstrates exposed to one or more of the followingextreme environmental conditions in an industrial,commercial or institutional setting:

• Immersion in water, wastewater, or chemicalsolutions (aqueous and non-aqueous solutions),or chronic exposure of interior surfaces tomoisture condensation,

• Acute or chronic exposure to corrosive, caustic,or acidic agents, or to chemicals, chemical fumes,or chemical mixtures or solutions;

• Repeated exposure to temperatures above 120ºC(250ºF);

• Repeated (frequent) heavy abrasion, includingmechanical wear and repeated (frequent)scrubbing with industrial solvents, cleansers,or scouring agents; or

• Exterior exposure of metal and other structuresand structural components.

2.0 Abbreviations & Definitions

Metallic pigmented coatings: Non-bituminous anti-corrosion coatings containing at least 0.048 kilogramof metallic pigment per litre of coating (0.4 poundper gallon) including (but not limited to) zinc pigment.

Pre-treatment wash primers: Primers that containsa minimum of 0.5 percent acid by weight and thatare formulated and recommended for applicationdirectly to bare metal surfaces in thin films toprovide corrosion resistance and to promoteadhesion of subsequent topcoats.

Volatile Organic Compound (VOC): Any organiccompound that participates in atmosphericphotochemical reactions. This excludes the followingcompounds due to their negligible photochemicalreactivity:

• Acetone• Methane• Ethane• Methyl chloroform• Methylene chloride• PCTBF (parachlorobenzotrifluoride)• Chlorofluorocarbons (CFCs)• Fluorocarbons (FCs)• Hydrochlorofluorocarbons (HCFCs)


3.0 Standards and Guidelines


3.1 Principles

These Standards and Guidelines are based on theprinciples listed below.

1. The implementation of these standards shouldachieve reductions in VOC emissions consistentwith the targets of the CCME Management Planfor NOx and VOCs for industrial maintenancecoatings operations.

2. The standards should be based on the principle of Best Available Technology EconomicallyAchievable (BATEA).

3. The standards should be expressed in the simplestpossible form while remaining effective.

4. Where possible, the standards should allowflexibility in the choice of method for achievingcompliance.

5. The standards should be uniformly applied to newand existing sources (after an appropriate phase-in period if appropriate).

6. Implementation of the standards should becompatible with and supportive of the objectivesand concept of pollution prevention.

7. Implementation of the standards should take intoconsideration opportunities for minimizing thegeneration of greenhouse gases and otherpollutants.

8. The standards should take into considerationother VOC reduction initiatives in otherjurisdictions, particularly in the United States.

3.2 Applicability

These recommended Standards are applicable tofield-applied products intended for use on stationaryequipment and for the purpose of restoringprotection from environmental exposure. Examplesof sub-sectors that account for IndustrialMaintenance coatings applications include, but arenot limited to:

• structural steel;• bridges;• refineries and storage tanks;• drilling rigs;• chemical process plants; and,• pulp and paper plants.

The recommended standards do not apply toproducts intended for use for application on:

• objects in a coating facility as part of themanufacturing operation;

• architectural coatings, including (but not limitedto) products used for industrial, commercial,institutional or residential buildings; and,

• mobile vehicles or equipment including but notlimited to motor vehicles, railroad rolling stock,aircraft or marine vessels.

3.3 VOC Content Limits

Effective January 1, 2003 for manufacture andimport of Industrial Maintenance Coatings, andJanuary 1, 2005 for IMC applicators (use).

Table 1 specifies the maximum VOC content foreach IMC product type. The VOC content mustinclude the maximum quantity of thinnerrecommended by the coating manufacturer. VOC content calculation methodology is given inSection 3.6.

Table 1 VOC Content Limits

PRODUCT CATEGORY MaximumVOC Content(g/L as used)

Pre-treatment wash primers 780

Extreme high durability coatings 800

High temperature coatings 650

General maintenance coatings 340

Metallic pigmented coatings 500

Manufacturers and importers should ensure that thedate of formulation of the product be displayed onthe label and/or container in order to determinewhether the product was formulated prior to January1, 2003. Coatings formulated prior to this date willbe exempted from the VOC limits described above,and may still be used after the limitation on IMC usecomes into effect (January 1, 2005).

3.4 Operations

Effective January 1, 2005:

All operations in the field applying maintenancecoatings should:

• use only products meeting the applicable VOC content for the product category (with theexception of products manufactured in orimported into Canada prior to January 1, 2003).

• limit the use of conventional air atomized sprayequipment as far as possible when these standardsand guidelines come into effect; such applicationsshould not exceed 5% of total coating volumesapplied; and,

• meet or exceed Codes of Good Practiceprocedures.

3.5 Codes of Good Practice

Each facility or operator should have written specificCodes of Good Practice for their operations. TheCodes of Good Practice may be modified in detailfrom those suggested in these Standards andGuidelines as appropriate for the type of operation.The modifications, however, should be consistentwith the principles contained in the prototype and, asa minimum, include the following elements:• a solvent management plan;• training provisions;• materials handling procedures; and,• equipment operation, maintenance

and cleaning procedures.

The description of Codes of Good Practice providedin these Standards and Guidelines should be viewedas an acceptable example. It is not intended toprovide a definitive document. Rather it should betaken as a guide to the development of an effectiveprogram suited to the operations for which it isintended.

3.6 VOC Content Calculation

VOC content per litre as used is calculated using the following formulas.

VOC Content = (Ws - Ww - Wec) / (Vm - Vw - Vec)

Where:

Ws = weight of total volatiles, in grams

Ww = weight of water, in grams

Wec = weight of exempt compounds,in grams

Vm = volume of coating, in litres

Vw = volume of water, in litres

Vec = volume of exempt compounds,in litres



All weights and volumes are the weights andvolumes of the material as used and include thequantity of thinner added for use based on themaximum recommended thinner addition.

The following methods may be used to determine theweight and volumes of the material:

i) US EPA Method 24 of Appendix A, US 40 Codeof Federal Register, Part 60, or

ii) The value derived from the theoreticalformulation for the product and thinners.

IMC (non-traffic) Technical Working Group: Participating Members

Name Organization Tel. No. Fax No. E-Mail

Dan Agnew Amercoat Canada 905-847-1500 905-847-5899 [email protected](Dennis O’Reilly / Tony Bantleman)

Lorraine Bennett ICI Canada 905-660-8940 905-669-3407 [email protected]

Shiwei Guan Madison Chemical 905-878-8863 905-878-1449 [email protected] Inc

Madelyn Harding Sherwin-Williams 216-566-2630 216-263-8635 [email protected]

Brian LeClair Ontario Ministry 416-314-3878 416-314-7930 [email protected] the Environment

Jim Lefler International Paints 519-821-0808 519-821-4103 [email protected](Canada) Ltd.

Art Stelzig Environment Canada 819- 953-1131 819-953-5595 [email protected]

Bruce Walker STOP 514-393-9959 514-393-9588 No e-mail. send regular mail to:STOP / 2050 de Maisoneuve St./Apt. 501 / Montreal, Quebec / H3H 1K7

Stan F. Walker Carboline/Stonecorp 1-905-430-3333 [email protected]

Rick Williams Sherwin-Williams 905-728-8531 905-728-4177 [email protected] (non-traffic) Technical Working Group:


4.0 Technical Working Group Participating & Corresponding Members

Industrials Maintenance Coatings: Stakeholder Lists (Non-Traffic and Traffic Markings)


IMC (non-traffic) Technical Working Group: Corresponding Members


Al Atkinson Dow Corning 905-826-9600 [email protected] Inc.

George Brophy Franklin Paint 508-528-0303 [email protected]

Valerie Braund General Paint 604-253-3131 604-253-3122 [email protected]

Ken Campbell Sigma Coatings 905-548-0924 [email protected]

Jacques Eberle Hempel Coatings 604-273-3200 604-273-6110 [email protected](Canada) Ltd.

Robert Ellis Ibis Products Ltd. 416-757-3241 416-757-8196 [email protected]

John Fierheller PPG Canada Inc. 905-238-6441 905-238-6450 [email protected]

Mark Herbert Franklin Paint [email protected]

John Irwin SICO Inc. 416-743-4200 416-743-8231 [email protected]

Chantal Langlois Laurentide Inc. 819-537-6630 819-537-5293 [email protected]. 263

Ross Mitchell Madison Chemical 905-878-8863 905-878-7425 [email protected]

R.W. Murry CPCA 514-745-2611 514-745-2031 [email protected]

Susan Peterson ICI Paints 905-660-8930 905-669-3407 [email protected]

Karen Phillips Benjamin Moore Co. 905-335-3561 905-332-5414 no email(Burlington)

Jason Powell Tectyl Industrial 1-800-331-2116 905-331-9753 [email protected] Box # 9903

Bill Reinhart Rust-Oleum 416-410-5040 905-669-0994 no email (use fax)(Canada) Ltd.

Terry Wiseman Devoe Coatings 705-688-8450 216-263-0036 [email protected]

SECTION II

NATIONAL STANDARDS & GUIDELINESFOR THE REDUCTION OF VOLATILE ORGANIC COMPOUNDS

FROM INDUSTRIAL MAINTENANCE COATINGS:

TRAFFIC MARKINGS


Section II

1.0 Introduction

1.1 Background

The Federal Smog Management Plan is a three-phase control program aimed at completely resolvingground level ozone problems by the year 2005.Phase 1 of the Federal Smog Management Plan waspublished in 1990, Phase 2 in 1997, and Phase 3 iscurrently under development by EnvironmentCanada and several government partners to refine theFederal Smog Management Plan initiatives.

The recommendations contained in this report weredeveloped pursuant to initiatives identified in thePhase 2 Federal Smog Management Plan, (1997),which called for a multi-stakeholder review of theIndustrial Maintenance Coatings (IMC) sector toverify Volatile Organic Compound (VOC) emissionestimates, assess the potential for reductions, anddevelop measures to ensure VOC emissionreductions from this sector.

These Standards and Guidelines apply to the trafficmarking sub-sector of the IMC sector. They weredeveloped in consultation with a Technical WorkingGroup consisting of industry stakeholders,representatives of federal and provincialgovernments, and representatives of environmentalpublic interest groups (Part 4.0). The contributions ofall participants and stakeholders who helped developthese guidelines are gratefully acknowledged.

While these Standards and Guidelines establishbroad measures for reducing VOC emissions in products and operations, it is acknowledged that federal, provincial/territorial or regionalenvironmental authorities may impose morestringent measures in response to regional or localproblems.

1.2 The Industrial MaintenanceCoatings Sector

For the purposes of these Standards and Guidelines,the term Industrial Maintenance Coatings applies to all non-architectural maintenance coatings used on stationary objects in field applications. TheseStandards and Guidelines apply to industrial coatingsused in restorative applications only, as opposed tocoatings applied to new equipment and products. Allarchitectural coatings are excluded since they werecovered by initiative V101 of the Phase IManagement Plan. These Standards and Guidelinesdo not apply to maintenance coatings applied to anymobile object such as railroad rolling stock andmotorized vehicles. Marine coatings are excluded inthe case of mobile vessels and structures, howeverthe Standards and Guidelines do apply to fixed,stationary structures such as oil rigs.

The IMC sector is made up of a number of sub-sectors, the most important of which are described inthe following list:

• structural steel;• bridges;• refineries and storage tanks;• drilling rigs;• chemical process plants;• pulp and paper plants; and,• road marking (traffic) paints.

Note that only the last item, traffic markings, is partof these Standards and Guidelines. The other sectorsare covered in separate Standards and Guidelines (see Section III).


The volume usage in the various sub-sectors alsoranges widely, as do VOC emissions. Solvent-bornetraffic paints have a fairly high VOC content per litreand represent a substantial volume of annual productuse. Drilling rigs, on the other hand, have highlyspecialized requirements, which include a longservice life under severe exposure conditions, andthe coatings technology capable of providing therequired performance may inherently have a lowVOC content.

The main focus of these Standards and Guidelines ison product VOC content limits and good operatingpractices that minimize VOC emissions.

Traffic painting operations include new pavementmarking, maintenance of road markings, as well as asub-category referred to as Zone Markings, whichcorresponds to other pavement marking operationssuch as parking lot, crosswalk, and factory floormarkings. These Standards and Guidelines apply toZone Markings as well as Traffic Markings. Trafficpaints are applied by provincial or municipalgovernment departments, or by private contractors.

In the case of traffic paint applications, a largepotential for reducing VOC emissions was identified,involving the replacement of solvent based paintswith water-borne paints. There is evidencesupporting the possibility of using water-borne traffic paints in Canada for at least a part of thepainting season. Water-borne paints account forapproximately 16% of all traffic coating applicationsby volume in Canada. However, seasonalconsiderations restrict the extent to which water-borne coatings may be used. Water based paintscannot be applied successfully below 10*C, norduring periods of high humidity, and particularlywhen these conditions are present simultaneously.

There are various technical considerations that affectdifferent contractors in different ways, e.g.,provincial government operations are more likely tohave the financial resources to acquire equipment forwater-borne applications than small contractors. Thetarget for use of water based traffic paints would bemore applicable to traffic marking maintenancepainting operations as opposed to new pavementmarking, as the latter are generally driven byconstruction schedules that tend to involve work inlate autumn/early winter (during cold conditionswhere water based paint application may beproblematic), and allows for less flexibility inscheduling. Stakeholders have estimated that onlyabout 5% of all traffic markings are applied to newpavement. The Standards and Guidelines allow foran exemption for new pavement (construction) trafficmarking applications.

In general, using water-borne paints for trafficmarkings are comparable in cost to using solventbased paints. The paint itself is usually moreexpensive, but it also lasts longer and spreads furtherbecause of their higher solids content, and they mayalso be more efficient to apply. Particularly asproduct technology improves, the cost advantages of using water-borne traffic markings may offset theassociated costs.


2.0 Abbreviations & Definitions

2.1 Abbreviations

ASTM American Society for Testing and Materials

BATEA Best Available Technology Economically Achievable

CCME Canadian Council of Ministers of the Environment

CPCA Canadian Paint and Coatings Association

NAICC National Air Issues Co-ordinating Committee

NOx Nitrogen oxides

U.S. EPA United States Environmental Protection Agency

VOC Volatile organic compound

2.2 Definitions

Industrial maintenance coatings: Highperformance coatings, including (but not limited to)primers, sealers, undercoaters, intermediate coats,topcoats, anti-fouling coatings, nuclear coatings andquick-dry coatings, that are formulated andrecommended for application to metal and othersubstrates exposed to one or more of the followingextreme environmental conditions in an industrial,commercial or institutional setting:

• Immersion in water, wastewater, or chemicalsolutions (aqueous and non-aqueous solutions), orchronic exposure of interior surfaces to moisturecondensation,

• Acute or chronic exposure to corrosive, caustic,or acidic agents, or to chemicals, chemical fumes,or chemical mixtures or solutions;

• Repeated exposure to temperatures above 120ºC(250ºF);

• Repeated (frequent) heavy abrasion, includingmechanical wear and repeated (frequent)scrubbing with industrial solvents, cleansers, orscouring agents; or,

• Exterior exposure of metal and other structuresand structural components.

Traffic markings: Coatings formulated andrecommended for marking and striping streets,highways, or other traffic surfaces including, but notlimited to, curbs, berms, driveways, parking lots,sidewalks, and airport runways. Includes a sub-category called zone markings.

Volatile Organic Compound (VOC): Any organiccompound that participates in atmosphericphotochemical reactions. This excludes the followingcompounds due to their negligible photochemicalreactivity:

• Acetone• Methane• Ethane• Methyl chloroform• Methylene chloride• PCTBF (parachlorobenzotrifluoride)• Chlorofluorocarbons (CFCs)• Fluorocarbons (FCs)• Hydrochlorofluorocarbons (HCFCs)

Water-borne coatings: Coatings formulated withaqueous as opposed to organic solvent. For thepurposes of these Standards and Guidelines, thisdefinition is not meant to exclude other types ofcoatings that meet the 150 g/L limit, i.e., suchcoatings should be considered in the category of“water-borne coatings.”

Zone markings: A sub-category of traffic markings,referring to pavement markings used on parking lots,crosswalks, and factory floors. These coatings aretypically applied by small contractors using paintspurchased in containers of 20L or less.


3.0 Standards & Guidelines: Traffic Paints

3.1 Applicability

The recommended Standards presented here apply toboth Traffic Markings and Zone Markings. TrafficMarking coatings are intended for use on streets,highways and other roadways including centre lines,lane markings, intersections and crosswalks. TrafficMarking coatings products are generally packaged incontainers greater than 20 litres (L). Zone Markingpaints are generally intended for use for markingparking space delineation, aisles and other floormarkings in factories and warehouses.

3.2 VOC Content Limits

Effective January 1, 2005.

Table 1 specifies the maximum VOC content foreach Industrial Maintenance coating product type forTraffic Marking and Zone Marking coatings. Thecontent must include the maximum quantity ofthinner recommended by the coating manufacturer as calculated using the methodology described in Part 3.5.

Table 1 VOC Content Limits

Product Type Maximum VOC Content(g/l as used)

Solvent-borne coatings 450

Water-borne coatings* 150

* Or any other coatings that meet this VOC limit (see definitions).

3.3 Operations

Effective date: January 1, 2005

Traffic and Zone Marking applicators should:

• use only products meeting the applicable VOCcontent for the product category;

• use only water-borne products for all coatingsapplications with the exception of newconstruction coatings applications (i.e.,construction sites, freshly-laid asphalt, or freshly-planed surfaces), during the period from May 15th to September 30th; and,

• meet or exceed the Codes of Good Practiceprocedures described in these Standards andGuidelines.

3.4 Codes of Good Practice

Each operator should have written Codes of GoodPractice specific to the Traffic Marking and/or ZoneMarking operations. The Codes of Good Practicemay be modified in detail from those suggested inthese Standards and Guidelines as appropriate for thetype of operation. The modifications, however,should be consistent with the principles contained in the prototype and, as a minimum, include thefollowing elements:

– a solvent management plan;– provisions for training;– materials handling procedures; and,– equipment operation, maintenance

and cleaning procedures.

The description of Codes of Good Practice inSection III should be viewed as an acceptableexample. It is not intended to provide a definitivedocument. Rather it should be taken as a guide to thedevelopment of an effective program suited to theoperations for which it is intended.


3.5 VOC Content Calculations

VOC content per litre as used is calculated using thefollowing formulas.

VOC Content = (Ws - Ww - Wec) / (Vm - Vw - Vec)

Where:

Ws = weight of total volatiles, in gramsWw = weight of water, in gramsWec = weight of exempt compounds,

in gramsVm = volume of coating, in litresVw = volume of water, in litresVec = volume of exempt compounds,

in litres

All weights and volumes are the weights andvolumes of the material as used and include thequantity of thinner added for use based on themaximum recommended thinner addition.

The following methods may be used to determine theweight and volumes of the material:

i) US EPA Method 24 of Appendix A, US 40 Codeof Federal Register, Part 60, or

ii) The value derived from the theoreticalformulation for the product and thinners.


4.0 Technical Working Group Participating & Corresponding Members

Traffic Markings Technical Working Group: Participating Members


Stan Bowditch Saskatchewan 306-778-8365 306-778-8560 [email protected] & Transport

John Brousseau Total Traffic. 905-678-9779 905-678-9776 [email protected] Ltd

Henry Chu City of Toronto 416-396-2677 416-392-8504 [email protected]

Miles Currie City of Toronto 416-397-5179 416-392-8504 [email protected]

Jim Gillberry Lafrentz Road 905-842-6010 905-842-7001 [email protected] Ltd

Dean George Metro Pavement 519-853-3650 519-853-1036 [email protected] Ltd

John George Metro Pavement 519-853-3650 519-853-1036 [email protected] Ltd

William George KDN Pavement 519-856-9236 519-856-1291 [email protected]

Kelly KDN Pavement 519-856-9236 519-856-1291 [email protected] Markings

Dean Harbottle Mid-Western 519-599-2775 519-599-4578 [email protected] Striping

Ted Keen Ontario Ministry 905-704-2978 905-704-2848 [email protected] Transportation

Brian LeClair Ontario Ministry 416-314-3878 416-314-7930 [email protected] the Environment

Michael Parks City of Brampton 905-874-2574 905-874-2599 [email protected]

Gord Peckover Linetech 905-685-0005 905-685-4447 [email protected]

Grant Ridley Ontario Ministry 416-235-5395 416-235-5338 [email protected] Transportation

Ellis Robert Ibis Products Ltd. 416-757-3241 416-757-8196 [email protected]

Ray Shannon Guild Electric 416-288-8222 416-288-0884

Art Stelzig Environment Canada 819-953-1131 819-953-5595 [email protected]

Christine Stone Ibis Products Ltd 416-757-3241 416-757-8196 [email protected]


Traffic Markings Technical Working Group: Corresponding Members


Luigi Armano Canadian Pacific 403-319-3436 403-205-9031 [email protected]

Keith Cleary Ontario Hydro 416-592-6947 416-592-4446 [email protected]

Barry Day Permashell Coating 905-850-1250 905-850-1252 [email protected]

Robert Evans Ontario Hydro 416-592-6002 416-592-4446 [email protected]

Ron Ingram Mark-All 905-951-2700 905-951-2660 [email protected] Ltd.

Gerald Marquis Canmec Inc 418-543-6161 418-543-5564 [email protected]

Mac McCulley Dynacor 604-946-0136 604-946-1640 no e-mail - use faxCoatings Ltd.

Mike Mousseau Clark & Pattison 250-652-5233 250-652-5234 [email protected](Victoria) Ltd.

Ken Nepaul Guild Electric Co. 416-288-8222 416-288-0769 [email protected]

David Opie Linetech Design 1-800-446-4896 905-685-4447 [email protected]& Mfg. Ltd.

Geoff Robertson Rainbow 403-279-7012 403-279-6660 [email protected] Ltd.

SECTION III

CODES OF GOOD PRACTICE FORINDUSTRIAL MAINTENANCE COATINGS OPERATIONS(TRAFFIC MARKINGS & NON-TRAFFIC APPLICATIONS)


The following Codes of Good Practice apply to theIMC sector in general, including both traffic andnon-traffic painting applications. During thedevelopment of these recommended Standards andGuidelines, specific suggestions for these Codes ofGood Practice were provided for traffic paintingapplications by a special stakeholder working group.These suggestions were incorporated into thefollowing text. A Check List for Codes of GoodPractices can be found in Part 2.0.

Previous studies have shown that good operatingpractices can provide significant reductions in VOCemissions. In addition to the reduction of VOCemissions, the practices can also result in materialand waste disposal cost savings.

The Code of Good Practice is comprised of fourdistinct elements:

1. Solvent Management;2. Training;3. Materials Handling; and4. Equipment Operation,

Maintenance and Cleaning.

Each of these four elements is an important andintegral part of the Codes of Good Practice and aneffective program to minimize fugitive VOCemissions cannot be achieved if any one of theseelements is ignored.

1.1 Solvent Management

The application of a well thought out health, safetyand environmental management systems is anintegral part of a program to achieve VOC reductionobjectives in an effective and efficient way. Thesemanagement systems should have a specified scopeand be capable of demonstrating that:

– the system is understood,effective and implemented;

– the performance criteria satisfy all applicablelegal requirements as well as the health andenvironmental policies of the organization;

– the system is based primarily on prevention ratherthan correction after an incident; and,

– the system is flexible and capable of modificationand evolutionary change.

Certain characteristics of any management systemshould be in place to ensure that the program iscarried out efficiently and effectively. The followingcharacteristics are sufficiently generic so as to applyto systems for managing virtually any technicalactivity and in particular to solvent managementsystems:

1. Planninga) Explicit goals and objectivesb) Well defined scopec) Well defined inputs and resource

requirementsd) Identification of needed tools and training

2. Organizationa) Clear lines of authority and explicit

assignment of roles, responsibilitiesb) Variance procedures and audit mechanismsc) Corrective action mechanismsd) Formal procedures

3. Implementationa) Detailed work plansb) Specific milestones for accomplishmentsc) Initiating mechanisms

4. Controla) Performance standards

and measurement methodsb) Performance measurement and reportingc) Checks and balancesd) Internal reviews

Section III

1.0 Elements of the Code of Good Practice


Not all features or characteristics may be needed inevery specific situation. Exceptions and departuresbased on local circumstances are acceptable andsuggested changes and additions based on actualexperience are to be encouraged.

1.2 Training

The VOC emissions generated outside of the primarycoating operations are comparatively small. Further,they arise from a variety of sources and operations,some of which may not be recognized for theircontribution to the VOC emission pool. It isimportant, therefore, that all personnel involved inthese operations is made aware of this contributionand the need to reduce or eliminate it whereverpossible. This can best be accomplished by acomprehensive and effective training of supervisoryand operating personnel.

Training should therefore be provided in thefollowing areas commensurate with their specificresponsibilities:

1. the theory, characteristics and value of solventmanagement systems;

2. applicable health, safety and environmental lawsand regulations including those governinglabelling, spills, emergencies and reporting andwaste handling and disposal;

3. all applicable aspects of this Code of GoodPractice including:a) equipment and operating standards,b) solvent storage and handling,c) waste handling and disposal,d) record keeping,e) test methods;

4. All applicable operating procedures and standards including:a) normal operations including daily check lists,b) routine maintenance,c) solvent conservation and maintenance,d) cleaning and maintaining equipment

including safety,e) procedures and entry requirements,f) Containment and recovery of spills,g) Handling and disposal of wastes,h) Equipment start-up, shut down and

emergency responses;

i) Test methods and procedures;j) Use of personal protective and monitoring

equipment; andk) Intent and benefits of following this Code

of Good Practice.

1.3 Materials Handling

1.3.1 Returnable Containers

1.3.1.1 Drums• All paint drums arriving should be returnable and

re-usable where feasible and appropriate to themanufacturer’s handling requirements.

• During transfer operations to the applicationvessel, the ventilation bung may be removed butshould be securely replaced immediatelythereafter.

• Where possible, separate loading pumps shouldbe used for different paint colours, in order toavoid the need to flush with solvent.

• Where possible, sequence colour applications forminimum flushing.

• If it is necessary, because of system design, toremove the lid for access to the material, e.g. forviscosity adjustment or pumping, the open drumshould be covered with a flexible covering in sucha way as to minimize VOC losses to theatmosphere. The lids should be carefully stored inthe interim to ensure that they are notinadvertently damaged during this period and thatthey are used to reseal the container when empty.

• Steps should be taken to make certain that theempty drums are tightly closed, and all bungsreplaced to avoid possible fugitive emissionsduring the return to the supplier or drum cleaner.


1.3.1.2 Totes• Totes, during transportation and while in storage,

should be completely sealed to avoid thepossibility of fugitive emissions of VolatileOrganic Compounds (VOCs) into the atmosphere.

• During the transfer of the materials in totes to anapplication equipment vessel or tank or into otherstorage vessels, a small ventilation opening maybe utilized to prevent the creation of a vacuum inthe container. Failure to do so could result in onlypartial emptying of the container and result inunexpected large spillage when the transferringoperation is thought to be complete and the tote isdisconnected. As a precaution against thiseventuality and to avoid even small losses in thisway, the tote valve should be secured in theclosed position before disconnection.Immediately after this has been done the lids andvents on the tote should be tightly closed toprevent any subsequent escape of VOCs from thecontainer.

• Lids, vents and other openings should bedesigned to eliminate the possibility of leakingduring the return transportation.

• Totes should be shipped back to the materialssupplier or a qualified processor of such emptycontainers for cleaning and re-use.

• By prior agreement a small amount of solvent (orde-ionized water as appropriate) may be added tothe totes before their return for cleaning. This stepwill ensure that only a minimum quantity ofcleaner (probably also a VOC) is required for thecleaning operation by preventing the drying ofpaint to the inside walls, valves and other fittings.Care must be taken to control the amount ofsolvent added for this purpose to ensure that theclassification of the container as “Empty”is not affected.

1.3.2 Non-Returnable Containers• All full and part full non-returnable containers

should be shipped and stored with lids and otheropenings sealed air tight.

• Handling during transfer operations to mixing orcirculating tanks should be done, as closely aspossible, in the same way as returnablecontainers.

• If any thinning is required, at least a portion of therequired solvent should be added to the justemptied container to assist in minimizing anyresidual material. The solvent/ paint mixtureshould then be added to the material justremoved.

• After emptying, the non-returnable containershould immediately be processed by approvedmethods as waste or hazardous waste asappropriate to the residues, if any, remaining inthe container.

• The use of non-returnable containers should bereduced or, if possible, be discontinued, to theextent feasible and appropriate to the materialshandling procedures in use at the coating facility.

1.4 Equipment Operation, Maintenance and Cleaning

1.4.1 Application Equipment

The operation of application equipment should include:

• Written procedures for the proper operation of the equipment.

• Training of employees in the operation andmonitoring of the equipment used for theapplication of the coatings.

• All necessary test equipment required for settingand monitoring the proper operation of the equipment.

• Record keeping procedures.

• Monitoring of the operation of the equipment and of the records kept.

• Periodic retraining and review of procedures.

1.4.2 Equipment Cleaning

1.4.2.1 Paint System Flushing

Paint systems must, of necessity, be cleaned periodically.Cleaning can generate significant quantities of solvent tobe recycled. When system flushing does becomenecessary, cleaning agents should be carefully selectedfor minimum VOC content, lowest photochemicalreactivity while still remaining effective. The coatingssupplier should recommend the cleaning solutioncomposition keeping all of the above three factors in mind.

• As an initial step, as much old paint as possibleshould be blown back using compressed air and ifnecessary solvent.

• Used flushed paint and paint/flushing solventmixtures should be pumped into transportablesealable containers and sent for reclamation and reuse.

1.4.2.2 Mixing or Equipment Tanks

Paint deposits can build up on the insides of tanks usedto mix the coating or supply the application equipment.

• Heavy paint deposits on inside walls should bemanually removed by scraping with non-sparkingtools. Alternatively, they may be removed by blastingwith high pressure water streams.

• Collected waste material should be transferred totransportable containers having sealable lids.

• Wherever possible, VOC generating solvent washesshould be avoided and VOC-free cleaning agents usedif available.

• When necessary to use solvents for tank cleaning,managed amounts of strippers should be applied withbrushes or wipers.

• Used brushes, wipers and other equipment used forthis purpose should be stored for disposal, inapproved, sealable containers. If subject tospontaneous combustion, the storage container shouldcontain sufficient water to cover the waste.

• As far as possible, residual solvents in tanks should beremoved by pumping or draining into sealedcontainers and sent for recycling.

1.4.2.3 Paint Transfer and Spray Equipment • Paint transfer and application equipment such as

pumps, filters, regulators, valves, metering devices,spray guns, etc. should be cleaned using measuredamounts of VOC-creating solvents.

• Parts should be manually scrubbed, applying smallamounts of strippers.

• When soaking is required, containers with an air tightlid should be used.

• Used solvents should be returned to sealed containersof a waste collection system for recycling and reuse.

1.4.2.4 Filters• Filter vessels should be emptied before cleaning or

changing filter media by blowing out withcompressed air.

• Used filter bags should be immediately transferredinto containers equipped with sealable lids for storageand transportation.


Solvent Management

No. Practice Currently Comments(Y/N) Plans, Actions,

Timing

1 Effective solvent management plan in place.

2 Plan assessed for safety, health, legal, and environmental policy requirements.

3 Emphasis of plan on prevention rather than correction.

4 Plan designed for modification and change.

5 Audit mechanism in place.

6 Formal procedures in place.

7 Corrective action mechanisms.

8 Roles and responsibilities clearly assigned.

Training


Timing

1 Solvent management plan principles and objectives.

2 Applicable health, safety and environmental regulations.

3 Solvent conservation.

4 Solvent recovery and recycling.

5 Equipment and operating standards and procedures.

6 Use of personal protective and monitoring equipment.

7 Solvent storage and handling.

8 Spill prevention.

9 Containment and recovery of spills and leaks.

10 Cleaning and maintenance of equipment.

11 Waste handling and disposal.

12 Record keeping.

13 Test methods.


2.0 Check List for Codes of Good Practices


Materials Handling

Returnable Containers


Timing

1 Returnable containers completely sealed during transportation and storage.

2 Small ventilation opening during transfers to other vessels.

3 Valves secured in closed position after emptying and before disconnecting.

4 Ensure lids and vents are tightly closed after emptying container.

5 Lids, vents and other openings designed to prevent leaking during return transportation.

6 Any solvent/water added after emptying is by prior agreement with supplier.

7 Above additions controlled to avoid excessive use and reclassification of container as empty.

8 All drums arriving at the facility are returnable and reusable.

9 Drums covered with flexible covering if lids removed for pumping, viscosity adjustment, etc.

10 Removed lids safely stored to prevent damage to seal.

11 Lids removed during use promptly replaced and container tightly resealed.


Non-Returnable Containers


Timing

1 Use of non-returnable containers reduced to minimum possible.

2 Containers shipped with lids and openings tightly sealed.

3 Handling as for returnable containers to minimize losses.

4 Portion of thinner, if any added to emptied container to minimize residual material.

5 Empty containers to be promptly processed as hazardous waste.

Mix and Equipment Tanks


Timing

1 All tanks are kept tightly closed except for additions.

2 Procedures for additions designed to minimize fugitive emissions.

3 Lid gaskets regularly inspected and replaced if defective.

4 Tanks vented through flame arrestor/conservation vent.

5 Tanks not in use have vents and lids sealed.

6 Pumps, filters, valves, metering devices and vents inspected under regularly scheduled maintenance.

7 Repairs promptly made.

Bulk storage tanks


Timing

1 All bulk storage tanks are totally enclosed systems.

2 Ventilation of tanks is through flame arrestor/conservation vents.

3 Each tank has independent vent system. Tank vents are not inter-connected.

4 Fill lines enter tank from the top to prevent spills.

5 Pumps, filters, valves, metering devices and vents inspected under regularly scheduled maintenance.

6 Repairs promptly made.

Equipment Operations

Application Equipment


Timing

1 Written procedures provided.

2 Operators trained in the operation of the equipment.

3 Monitoring procedures for equipment operationsin place.

4 Scheduled maintenance program.

5 Record keeping procedures defined.

6 Operation and record keeping monitored.

7 Scheduled periodic retraining program.

Equipment Cleaning

Paint System Flushing


Timing

1 Paint system kept well maintained to minimize need for cleaning.

2 Cleaning solutions selected for minimum possible VOC content.

3 Paint in system blown back before cleaning solution added.

4 Recovered paint kept in sealed containers for reclamation, if possible or disposal.

5 Spent paint/cleaning solution pumped into transportable sealable containers.

6 Recovered paint, paint/cleaning solution sent for reclamation if possible.



Mix and Equipment Tanks


Timing

1 Initial cleaning done by non-VOC methods

2 Collected waste stored in transportable, sealed containers.

3 Use non-VOC cleaners.

4 Tanks cleaned using brushes or wipers where possible.

5 Cleaning brushes, wipers stored in approved, sealable containers.

6 Residual solvents removed by pumping where possible.

Filters


Timing

1 Filter vessels emptied before cleaning or changing by blowing out with compressed air.

2 Used filters immediately transferred to transportable, sealed containers.