Regulatory Information vhap FAQs
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?
· ITW TACC website – www.itwtacc.com
o Regulatory Assistance
o EPA web site – links to the federal regulations (i.e. Subpart JJ)
o State Environmental Agencies – links to all 50 state agencies
· ITW TACC Customer Service – to obtain a Certified Product Data Sheet (CPDS)
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