Controlling Voc Pollution: What Laws Are Enforced?

Volatile organic compounds (VOCs) are chemicals that evaporate easily at room temperature and are found in many everyday products, from paints to cleaning supplies and even office equipment. While the pleasant new car smell or the fresh scent of a just-painted room might be enjoyable, VOCs are harmful to both human health and the environment. As a result, there are laws and regulations in place to control and reduce VOC emissions. These include federal regulations enforced by the Environmental Protection Agency (EPA) and stricter state laws, such as those adopted by the New England states, which require facilities to reduce VOC emissions. The EPA also provides guidance on RACT (Reasonably Available Control Technology) and reviews state regulations to ensure they meet RACT standards. Under the Clean Air Act (CAA), the EPA regulates emissions of hazardous air pollutants, including VOCs, and sets standards for pollutants that can harm public health and the environment.

The Clean Air Act (CAA)

The Act was first enacted in 1963 and has since been amended several times, including major revisions in 1977, 1990, and 2025. The 1990 amendments were particularly significant as they addressed four major threats to the environment and public health: acid rain, urban air pollution, toxic air emissions, and stratospheric ozone depletion.

The CAA has led to dramatic reductions in air pollution, preventing hundreds of thousands of serious health issues annually and improving US air quality. It has also contributed to substantial economic savings. The Act sets health-based air quality standards based on the latest scientific research, ensuring that emissions standards for sources are informed by available technologies.

Section 112 of the CAA specifically addresses emissions of hazardous air pollutants. The 1990 amendments revised this section to require the issuance of technology-based standards for "major sources" and certain "area sources." Major sources are defined as stationary sources emitting or capable of emitting 10 tons or more of a hazardous air pollutant per year, or 25 tons or more of a combination of such pollutants annually. These standards, known as "maximum achievable control technology" or "MACT" standards, mandate the highest degree of emissions reduction achievable.

The CAA also includes the National Ambient Air Quality Standards (NAAQS), which govern the permissible levels of ground-level ozone, carbon monoxide, particulate matter, lead, sulfur dioxide, and nitrogen dioxide in outdoor air. The Act's implementation has been a collaborative effort between state, local, tribal, and federal governments, demonstrating that clean air can coexist with a thriving economy.

National Ambient Air Quality Standards (NAAQS)

The National Ambient Air Quality Standards (NAAQS) are limits on the atmospheric concentration of six pollutants that cause smog, acid rain, and other health hazards. These six criteria air pollutants (CAP) or criteria pollutants are:

• Ozone (O3)
• Atmospheric particulate matter (PM2.5/PM10)
• Lead (Pb)
• Carbon monoxide (CO)
• Sulfur oxides (SOx)
• Nitrogen oxides (NOx)

The NAAQS are established by the United States Environmental Protection Agency (EPA) under the Clean Air Act (42 U.S.C. 7401 et seq.), which was last amended in 1990. The Clean Air Act requires the EPA to set National Ambient Air Quality Standards for these six principal pollutants, which are common in outdoor air, harmful to public health and the environment, and come from numerous and diverse sources.

The NAAQS are health-based and the EPA sets two types of standards: primary and secondary. The primary standards are designed to protect the health of 'sensitive' populations such as asthmatics, children, and the elderly. The secondary standards are concerned with protecting the environment, including soils, water, crops, vegetation, man-made materials, animals, wildlife, visibility, climate, and buildings. The EPA periodically reviews and revises these standards as appropriate.

The NAAQS also regulate ground-level ozone (O3), also known as tropospheric ozone, under the Clean Air Act. Ozone is a major component of smog, which causes negative health and environmental impacts when present in high concentrations at ground level. The National VOC Emission Standards for Consumer Products empower the EPA to limit the amount of VOCs emitted from products like household cleaners, personal care items, and automotive products.

EPA Guidelines

The Environmental Protection Agency (EPA) provides resources and recommendations to help reduce exposure to Volatile Organic Compounds (VOCs) and improve indoor air quality. While the EPA does not enforce regulations within private homes, it does offer valuable information for safer living.

The EPA's guidelines focus on both indoor and outdoor air quality, with differing regulations for each environment. For outdoor air, the EPA sets standards for pollutants that can harm public health and the environment under the Clean Air Act (CAA). This includes limiting the amount of VOCs emitted from products like household cleaners, personal care items, and automotive products. The National VOC Emission Standards for Consumer Products require manufacturers to limit the VOC content in their products, resulting in labels like "low-VOC" or "VOC compliant."

The EPA also regulates VOCs in some household products under the CAA. However, it's important to note that some chemicals that are toxic may be exempt from VOC regulations because they are not considered photochemically reactive. This means that products labeled as "no VOC" or "low VOC" may still contain volatile organic chemicals that are toxic. Additionally, the EPA has no authority to regulate indoor air quality or household products directly. Instead, their role is to research and disseminate information to the public.

To improve indoor air quality, the EPA encourages the use of low-VOC materials in construction and renovation projects. Organizations like LEED (Leadership in Energy and Environmental Design) promote the use of low-VOC paints and materials to enhance indoor air quality. Regular maintenance of HVAC systems can also help reduce VOC emissions and improve indoor air quality.

The EPA provides guidance on RACT (Reasonably Available Control Technology), the minimum level of stringency required for state VOC regulations. Through documents called Control Technique Guidelines, the EPA ensures that state regulations meet RACT and achieve the projected emissions reduction. Once a state adopts the VOC rule, the EPA approves it into the state's State Implementation Plan (SIP), making it federally enforceable.

State VOC regulations

While the EPA does not enforce regulations in homes, it provides resources and recommendations to help reduce VOC exposure at home. The EPA also offers guidance on RACT (Reasonably Available Control Technology) in documents called Control Technique Guidelines. The EPA reviews and comments on proposed State regulations to ensure that these rules meet RACT and will achieve the projected emissions reduction. Once a state adopts the VOC rule, the EPA approves it into the state's State Implementation Plan (SIP), and the VOC rule becomes federally enforceable.

To improve indoor air quality, regular maintenance of HVAC systems is recommended. Organisations like LEED (Leadership in Energy and Environmental Design) encourage the use of low-VOC materials in construction. Outdoor VOC regulations focus on air quality and environmental protection, as VOCs contribute to ground-level ozone and smog formation. Under the Clean Air Act, the EPA sets standards for pollutants that can harm public health and the environment.

Building standards

The EPA does, however, regulate VOCs in architectural coatings, such as paints and primers for buildings, under the Clean Air Act (CAA). This is because VOCs contribute to the formation of ground-level ozone and smog, which have negative health and environmental impacts. The National VOC Emission Standards for Consumer Products set limits on the amount of VOCs that can be emitted from products, including household cleaners and personal care items.

At the federal level, the EPA regulates VOCs in outdoor air pollution under 40 CFR 59, the National Volatile Organic Compound Emission Standards for Consumer and Commercial Products. This includes regulations for aerosol coatings, such as spray paints. The emphasis of concern for outdoor VOCs is different from indoors, as the primary focus outdoors is on the creation of photochemical smog, while indoors the focus is on potential adverse health impacts.

States also play a role in regulating VOC emissions, with many states adopting stricter standards than the federal government. State regulations must meet a level of stringency called Reasonably Available Control Technology (RACT), which is the lowest level of emissions achievable considering technical and economic factors. The EPA provides guidance on RACT and reviews state proposals to ensure they meet the required level of stringency.

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