COMDTINST 10360.4A
21 AUG 1991 3.
In addition, the laws and regulations require painters and personnel using other VOC
materials to keep daily logs for consumption of all paints, solvents and other VOC
materials. VOC laws and regulations also extend liability for Clean Air Act violations to
any person who solicits or requires (either orally or in writing) any other person to use
coatings which violate VOC limits.
c.
The EPA and the local Air Quality Management Boards make no distinction regarding
the methods which an agency chooses to achieve compliance. The regulators simply
require compliance. For example, an agency may make budgetary decisions to comply
with air quality rules by reformulating coatings to reduce solvent emissions, if
technically possible, or, alternatively, the agency may purchase catalytic incinerators to
eliminate solvent emissions from paint sheds. Personnel at every organizational level
should be aware of the need for compliance. The personnel entrusted with achieving
compliance include those involved with policy, procedures, and the generation of EC&R
or AC&I expenditures as their decisions may inadvertently predetermine the
specification of noncomplying materials.
d.
Examples of VOC laws and regulations include: Marine Coating Operations Rules,
Wood Flat Stock Coating Operations Rules, Coating of Metal Parts and Products Rules,
Aerospace Assembly and Component Coating Operations Rules, Metal Container
Coatings Operations Rules, Graphic Arts Rules, Wood Products, Motor Vehicle and
Equipment Non-Assembly line Coating Operations Rules, Adhesives Applications
Rules, Plastic Rubber and Glass Coatings Rules, Semiconductor and Electronics
Manufacturing Rules, etc. Copies of the rules are available from local Air Quality
Management Districts.
4.
PROCEDURES
a.
MLC's shall acquire local VOC laws and regulations and provide copies and assistance
(as required to comply with the regulations) to civilian and military personnel
responsible for painting vessels, aircraft, facilities, ATON and other capital equipment.