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Industry Forum: What is in the Price of Paint? A Regulatory Reflection

March 1, 2005
The cost of electrocoat includes more than just the product. Other than raw materials, the container, and delivery and service costs, what is included in the price of paint to the end user? This is a timeless question frequently asked by suppliers and users alike in these days of cost constraints and intense market competition. Given some additional thought, one might come up with the cost for the research and development of the product, advertising costs and other miscellaneous expenses. One issue, often neglected in my opinion, is the regulatory cost associated with coatings, including electrocoat.

I am not going to opine about the "old days," when regulatory oversight was non-existent and associated costs were minimal. These same good old days saw some shocking environmental problems. Companies that were responsible with chemical usage were notable exceptions. The various federal, state and local regulations were enacted to create a more environmentally focused and socially responsible chemical industry. Still, costs have accrued as the industry adopts standards and complies with myriad regulatory statutes. I wanted to reflect on some of these regulatory requirements because some are not well known by coatings users.

One of the chief requirements of any supplier is to ensure that all coatings formulations are registered under the U.S. Federal Law named Toxic Substances Control Act (TSCA). All polymer systems and every other chemical used in coatings must be registered with the U.S. EPA, which performs reviews and assesses the hazardous nature of the formulation.

Another aspect is the use of biocides, fungicides and other agents used for control of microorganisms in electrodeposition systems. It is important to have a supplier knowledgeable in the registration and use of biocides under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). Not all biocides are created equal, and some can be severely detrimental to the environment if used inappropriately. Competent electrocoat suppliers are well aware of the regulations and can advise you of which biocide to use based on its regulatory status.

Suppliers support your environmental needs for air quality permits and other required filings under the Clear Air and Clean Water Acts. Most people are familiar with the regulations for volatile organic compound (VOC) content of electrodeposition coatings but there are numerous other regulations that impact your business. For instance, do you know acetone is no longer considered a VOC or that ethylene glycol monobutyl ether was recently removed from the hazardous air pollutants (HAPs) list?

In addition to keeping you advised about regulatory concerns, full-line suppliers are involved in activities that allow enhanced performance for your electrocoat systems. As partners with the National Paint and Coatings Association (NPCA), efforts to remove substances such as methyl isobutyl ketone (MIBK) and methyl ethyl ketone (MEK) from the HAPs list continue. This could benefit all electrocoat users without causing harm to the environment, based on data collected by the NPCA. Additionally, many suppliers participate in nationally sponsored industry groups, such as the American Society for Testing and Materials (ASTM), which advise federal and state environmental departments about test method reliability and repeatability. This takes significant effort on the part of coatings producers, but this effort enhances the overall quality of legislation by ensuring the methods accurately measure what the ruling intended. Can you imagine the difficulties that might ensue if your coating line had to shut down for a VOC problem that later proved only to be a measurement problem?

Electrocoat product suppliers can be your partner in ensuring product quality, delivery and regulatory compliance. Yes, it is in the price and when you see the overall cost of an electrocoat product, take a moment to consider if your supplier is there to back you up in all aspects of the product's use.

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