With its final rule, the EPA created a new class of VOCs for low-reactivity compounds like TBAC. This new category of exempt compounds requires users to report their emissions, but does not limit their use of the solvent. Fortunately, this requirement does not create a significant reporting burden for companies, since most are already required to report their VOC emissions. It has, however, complicated the state exemption process. For example, some states that made reference to the federal definition to automatically add new exempt compounds, now have to undertake rulemaking to add TBAC.
The federal exemption last December marked the beginning of a similar and, fortunately, more expeditious process at the state level. This article attempts to bring the reader up-to-date on the current status of the TBAC exemption and provides a technical overview of the coating technologies where TBAC will likely become an important HAP and VOC compliance tool.