The American Coatings Association would like to provide the following comments on the Definition of Volatile Organic Compound (Rev. E14) rulemaking.  

The American Coatings Association (ACA) is a voluntary, nonprofit trade association working to advance the needs of the paint and coatings industry and the professionals who work in it. The organization represents approximately 350 paint and coatings manufacturers, raw materials suppliers, distributors, and technical professionals.

ACA supports the proposed exemption of 2-amino-2-methyl-1-propanol (AMP) as a Volatile Organic Compound. On June 25, 2014, EPA added AMP to the list of compounds which are excluded from the definition of VOC on the basis that this compounds makes a negligible contribution to tropospheric ozone formation.

The coatings industry is under constant pressure to reformulate products to lower and lower VOC content. As a result there is a critical and urgent need for safe, effective and affordable exempt solvents and coating formulators need all available tools to formulate both lower VOC and reactivity coatings. AMP could prove useful for coatings formulations.

If exempted, there may be an incentive for industry to use these negligibly reactive compounds in place of more highly reactive compounds that are regulated as VOCs. As such, ACA requests exempting this compound as a VOC.

In advance, thank you for your consideration of our request.  Please do not hesitate to contact me for additional information or if you have questions.

David Darling, P.E.

Senior Director, Environmental Affairs

American Coatings Association

1500 Rhode Island Ave., N.W.

Washington, DC 20005

ddarling@paint.org

202-719-3689