What is a VHAP?
  • EPA regulates 189 toxic chemicals as Hazardous Air Pollutant (HAP)
  • 189 List includes non-volatile compounds, such as heavy metals (lead, mercury, etc.)
  • A VHAP is a volatile hazardous air pollutant
Who regulates VHAPs?
  • Federal and State Environmental Agencies only
    • Environmental Protection Agency (EPA)
    • State Department of Environmental Protection (DEP), or DEC, or DNR
How are VHAPs regulated?
  • EPA developed standards under the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for specific manufacturing industries.
  • Subpart JJ regulates the Wood Furniture Manufacturing Industry.
  • Emission limit set for contact adhesives for the following two categories of major source:
    • Existing facilities – 1.0 lb VHAP per lb Solid
    • New facilities – 0.2 lb VHAP per lb Solid
What does “major source” mean?
  • EPA defines facilities based on emissions as either major or minor
  • Major source is a facility that emits:
    • > 10 tons per year of one HAP (roughly, assuming 40% HAP, 7600 gal adhesives or 138 drums)
    • > 25 tons per year of the aggregate HAP
What is a “wood furniture manufacturing” company?
  • Wood Furniture – any product made of wood, a wood product such as ratten or wicker, or an engineered wood product such as particleboard that is manufactured under any of the following standard industrial classification codes (SIC) – 2434, 2511, 2512, 2517, 2519, 2521, 2531, 2541, 2599 or 5712.
  • Wood Furniture Component – means any part that is used in the manufacture of wood furniture. Examples include, but are not limited to, drawer sides, cabinet doors, seat cushions, and laminated tops. 
  • Wood Furniture Manufacturing Operations – the finishing, gluing, cleaning
What is considered to be a “new” facility?
  • Subpart JJ promulgated December 7, 1995
  • Any wood furniture manufacturing company constructed after 12/07/1995
  • Any existing wood furniture manufacturing company that becomes a major source (exceeds limits above)
  • Any reconstructed wood furniture manufacturing company
What is the difference between a VOC and a VHAP?
  • A compound can be both a VOC and a VHAP (e.g. Methyl Ethyl Ketone or Toluene).
  • A compound can be VHAP but not a VOC (e.g. Methylene Chloride – Exempt compound on VOC list)
What records am I required to keep to show compliance for my contact adhesives?
  • Certified Product Data Sheet (CPDS) for each contact adhesive used in the facility listing the lb VHAP per lb Solid
  • CPDS provided and certified by manufacturer of adhesive (i.e. TACC)
Where can I find out more information?
  • EPA web site – links to the federal regulations (i.e. Subpart JJ)
  • State Environmental Agencies – links to all 50 state agencies
  • ITW Polymers Sealants Customer Service – to obtain a Certified Product Data Sheet (CPDS)