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Paint & Coating Manufacturing (Liquid): Reasons for Change
Table of Contents
Background and Overview
Reasons for Change
P2 Opportunities
Where To Go for P2 Help
Complete List of Links

Essential Links:

Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Diagnostic tool and flowcharts to determine what NESHAP compliance efforts are necessary and how to ...

National Emission Standards for Hazardous Air Pollutants (NESHAP): Miscellaneous Organic Chemical Ma...
Final Rule for NESHAP for paint manufacturing

Paints and Coatings Resource Center
Membership organization - contains technical database of > 5,000 publications, offers compliance ass...

Paint production processes and raw material inputs do cause environmental impacts as do most manufacturing processes, from worker exposure, to air emissions, to energy and water consumption, and waste.

The following highlights industry progress in pollution prevention over the years, and also supports continued pollution prevention and source reduction efforts.

The industry can boast about environmental improvements in the past few decades, from reducing energy and water usage, lower VOC content in formulations, less of the traditional hazardous solvents, and reducing metal and other hazardous constituents. A few statistics from the Paint & Coatings Industry association, illustrate this:

  • Toxic Release Inventory (TRI) releases by the paint and coatings sector decreased by 80% between 1995 and 2011.
  • The industry has reduced generation of hazardous waste in the U.S. by 30%.
  • Volatile organic compound (VOC) and hazardous air pollutants (HAP) emissions from architectural coatings have decreased significantly over the last few decades, even while the use of architectural coatings has increased over the same time period nationwide. (This is also supported by Industry Research and Development (R&D), market-demand, recent regulatory developments, and the continuing market trends toward water-based coatings, and other processes, as well as lower-emitting coating products, have contributed to reductions in both HAP VOC emissions.
  • 83% of architectural coatings sales are for environmentally preferable water-based paint.
  • 97% of all waste solvents from paint and coatings manufacturing facilities are reclaimed for future use.

Source: American Coatings Association

Important reasons for taking steps to ensure these types of changes happen can help protect production employees, reduce air emissions and waste generation, and/or save manufacturers money and regulatory burden.

Occupational Exposure

Solvents are used in many paints, and also in equipment cleanup during manufacture. A study of over 180 paint production workers showed paint industry workers were at increased risk of several irritant and neuropsychological symptoms which significantly related to exposure to paint and organic solvents. (Source: Department of Community Occupational and Environmental Medicine, 2013, Zagazig University Egypt ).

Other paint constituents, such as respirable powders, nonylphenol ethoxylates (NPEs), nano-particles, formaldehude, antibacterial additives (e.g., triclosan), and heavy metal pigments, are also exposure concerns for those producing paints, and those applying paints (end users).

Triclosan was banned in paints by European Union (EU) Standing Committee on Biocidal Products in a March 2014 decision. Likewise, NPEs in paints are banned by the EU. Nanoparticles are restricted.

The Master Painter's Institute, GreenSeal, and the EU have imposed content restrictions on volatile and semi-volatile organic content in paints in their certified paint standards.

Solid and Hazardous Waste

Technology, equipment, inventory management, spill prevention, and other operational strategies can help reduce wastes from overproduction, changeovers, equipment cleanup and rinsing (e.g., washwater), expired material, and other sources of waste. This saves on purchase costs as well as disposal costs for both hazardous or solid waste. (See P2 Opportunities section for technology, equipment and operational strategy suggestions).

Energy and Water Use

Improved efficiency in energy and water saves money, greenhouse gases, and in the case of water – reduced wastewater and associated treatment and management.

Air Quality

Volatile constituents in some formulations of paint, and dust (from metals in pigments and crystalline silica), along with solvents used in mixing and cleaning, release to the air during material transfer, blending, settling or uncovered storage. VOCs contribute to low-level ozone smog, respiratory problems both occupationally and outside the manufacturing facility. Also, many VOCs have been listed as hazardous air pollutants (HAPs), which are regulated under air pollution programs, including National Emissions Standards for Hazardous Air Pollutants (NESHAP) 5H discussed below.

Dust, known as particulate matter, can be released during the above activities as well, from powdered ingredients. These may contain metals or crystalline silica (a carcinogen) or other respirable materials that adversely affect air quality and workplace health. Dust ventilation and collection systems capture much of the emissions, but some can still release in the workhouse environment. Once the powders are fully blended with liquids, the exposure from respirable dust is eliminated, during the production of paint.

On October 4, 2006, The EPA amended 40 CFR, part 63, subpart HHHHH, (or 5H) which was first finalized on December 11, 2003. This regulation requires paint and coating manufacturers to implement provisions to control the release of hazardous air pollutants during certain manufacturing processes. The rule sets limits on the amount of air toxics (HAPs and VOCs) that a facility can emit during coating production. It also allows manufacturers to comply with the rule by producing coatings that contain less than 5 percent (by weight) of air toxics. Affected processes include:

  • Process Vessels
  • Storage Tanks
  • Equipment Leaks
  • Wastewater and Heat Exchange Systems
  • Transfer Operations
  • Closed Vent Systems and Control Devices

Other Regulatory

There are many federal, state and local regulations relating to occupational, air and water/waste releases that may apply to the processes used in paint and coating manufacturing. Efforts to reduce waste, dust, air and wastewater emissions can reduce the regulatory burdens associated with pat manufacturing.


When calculating cost savings resulting from improved efficiency and pollution prevention implementations, consider the following reductions in actual cost and labor to manage the activities:

  • Disposal and sewerage
  • Spill response equipment
  • Emergency response plan
  • Storage
  • Secondary containment
  • Training: Right-to-know, spill preparedness, chemical awareness and hazard labelling (e.g., GHS)
  • Reporting and records
  • Safety training
  • Container labels
  • Emission control equipment
  • Sampling and Testing
  • Disposal
  • Permit preparation and fees
  • Inspection and monitoring
  • Discharge fees
  • Hazard analysis
  • Legal fees or environmental penalties
  • Insurance


The Topic Hub™ is a product of the Pollution Prevention Resource Exchange (P2Rx)

The Paint & Coating Manufacturing (Liquid) Topic Hub™ was developed by:

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Hub Last Updated: 7/22/2015