The U.S. Department of Transportation (DOT) oversees several different agencies, including the Pipeline and Hazardous Materials Safety Administration (PHMSA). PHMSA is responsible for promulgating regulations to ensure safety and security of the transportation of hazardous materials, including those paints and coatings classified as hazmat. As such, ACA directs policy in matters regarding the safe, secure, and economic transportation of industry products and the raw materials used in them. ACA also helps establish an industry position in matters of proposed legislation and regulation in the United States and in international forums on issues pertaining to the transportation of hazardous materials.

In November 2007, the Department of Homeland Security (DHS) developed the Chemical Facility Anti-Terrorism Standards (CFATS), which focuses on preventing chemicals of interest from being stolen, diverted, sabotaged, or deliberately released by terrorists or other bad actors. DHS implements the CFATS program under a variety of short-term authorizations by Congress. The CFATS program lapsed on July 27, 2023, after Congress allowed its statutory authorization to expire. The safe handling and use of chemicals is a priority of ACA and industry, and it is crucial that the CFATS program is reauthorized to help protect and secure our facilities from terrorism. ACA is currently working with Congress, DHS, and coalition partners to ensure that the CFATS program is swiftly reinstated.

Many coatings manufacturers utilize exempt volatile organic compounds (VOCs) because they are not counted towards the overall VOC content of the product. Air regulatory agencies also encourage coatings manufacturers to utilize certain exempt compounds because their products can then meet lower VOC limits. PCBTF (parachlorobenzotrifluoride or Oxsol 100) is the most widely used exempt compound in coatings manufacturing. In 2022, California’s South Coast Air Quality Management District (SCAQMD) officially prohibited the use of PCBTF and TBAC in industrial adhesives and sealants (Rule 1168). In November 2023, SCAQMD shifted its focus to prohibiting the use of this PCBTF in auto-refinish coatings (Rule 1151). It is clear that the district intends to phase out the use of PCBTF in all coatings when the applicable rule is open for amendment (e.g., Rules 1113, 1136, 1143). ACA will continue to coordinate industry advocacy efforts and comment on any changes that will be proposed in the future.

ACA’s Marine Coatings Council continues to engage in several issues relating to marine coatings at federal, state, and local levels in the United States. ACA’s advocacy efforts are currently focused on restricted uses of certain biocides in antifouling paints and the development of volatile organic compound (VOC) and hazardous air pollutant (HAP) regulations for marine and pleasure craft coatings.

Industrial applications of adhesives and sealants are subject to air quality regulations in various states and local air districts in California. Most states follow the U.S. Environmental Protection Agency’s (EPA) Control Technique Guideline (CTG) for Miscellaneous Industrial Adhesives, while local air districts in California primarily align their industrial adhesive and sealant rules with neighboring air district regulations. ACA expects more states and local air districts to propose more stringent industrial adhesive and sealant rules in the future that align with either U.S. EPA’s CTG for Miscellaneous Industrial Adhesives or neighboring California air district regulations.