Printech Archive
Re: Use of acetone in reformulated products

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From: Burmark, Robert C. (
Date: Fri May 28 1999 - 13:19:15 CDT


I am writing this from a state air regulator point of view, but I think I
see the problem you have with the VOC delisting of acetone and acetone's
other hazardous properties. Your answer implies that you feel that
delisting of acetone as a VOC removes it from all regulatory controls. This
is a misconception. Try this explanation out as an answer:

First realize that listing of any chemical as a non VOC under the Clean Air
Act only ties it to its ability to form ozone. Organic chemicals that
participate in ozone formation (ozone precursors) less than ethane does seem
to currently be those that can possibly be listed as non VOCs. Note that a
volatile organic chemical has to be listed as a non VOC under the Clean Air
Act. Otherwise an organic chemical that tests positive under EPA's protocol
test (basically heats the chemical at a certain temperature for a certain
time and measures the weight loss) is a VOC (ozone precursor) by default (I

Other hazardous properties of a chemical (like acetone) are covered by other
laws, such as hazardous waste, transportation, fire regulations, OSHA, etc.
These laws are still in effect, and were not touched by the EPA's listing of
acteone as a non VOC. Non VOC status means that acetone is no longer
counted by the states when determining their VOC emissions inventory, so it
has a little less regulatory pressure on it than other organic solvents, and
might be chosen as the best alternative to use when a company is comparing
solvent or cleaning alternatives for a process (two of the most common uses
of acetone). All flammability, hazardous waste, and OSHA worker protection
laws and reguations are still fully applicable.

-----Original Message-----
From: []
Sent: Monday, May 24, 1999 8:37 AM
Subject: Re: Use of acetone in reformulated products


You are absolutely correct in describing the EPA position on the delisting
acetone and other chemicals. However, the response completely misses the
point that Marci raised. With its high vapor pressure and low ignition point

the use of acetone in an industrial environment becomes quite hazardous.
Shouldn't the EPA be concerned about such hazards as they contemplate
removing such materials from the basic control system provided by the VOC
regulations? Apparently there is no one in the EPA who will admit to having

such a responsibility. I've asked around with no success.

Alex Ross

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