From: GaryJGATF (email@example.com)
Date: Wed May 13 1998 - 21:15:26 CDT
1. I am not familiar with the specific cleaning product you are referring to
in you e-mail.
2. The only acceptable information for VOC content is the results of the
Method 24 testing. According to EPA guidance, formulation data is not
considered acceptable. Given that the VOC content is reported as 55.6%, I
would request a copy of the test results and would possibly conduct an
independent Method 24 test to confirm.
3. I am not sure what the basis would be to claim 0% VOC from either the ACT
for offset lithography or SQAMD Rule 1171, which regulates cleaning solvents.
There is nothing in either the ACt or Rule 1171 that would provide for such a
claim. The only thing that is remotely possible is that the CTG allows for a
50% retention factor in used shop towels for low vapor pressure (<10 mm Hg at
20oC). However, this retention factor is applied to VOC emissions and not VOC
content. This is commonly done by suppliers who do not understand the
difference between the two concepts. To the best of my knowledge, there is
nothing in Rule 1171 that allows for the use of a retention factor. Rule 1171
sets out VOC content limits for various types of cleaning solvnets used by
printers andother types of businesses.
I would contact the vendopr to determine the basis for the 0% VOC claim.
If you have any more questions, let me know. Also, let me know if you contact
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