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Ask the Expert Question-and-Answer Archive

by Ron Joseph

August, 2005

What VOC Do You Report on an MSDS?

Q. I am responsible for the MSDS's for our products. We are a 4 men blending plant for cleaners.
In the MSDS I want to mention the total solvent content and the VOC content. In Europe a VOC is a organic compound with a vapour pressure of 0.01 kPa or more at 293 degr. K. (68 F). The definition for the USA is not clear to me.

On your site you say, "Volatile Organic Compound (VOC) means any compound of carbon, excluding carbonmonoxide, carbondioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate, which participate in atmospheric photachemical reactions. This definition then is followed by the exceptions."

Some main ingredients of our cleaners are:
butylglycol CAS 111-76-2
butyldiglycol CAS112-34-5
methyldiproxitol CAS 34590-94-8
hexyleneglycol CAS 107-41-5
triethanolamine CAS 102-76-6
Oleic Acid CAS 112-80-1

Can you help me? Do I have to give the values in %wt or wt per volume. I would be very thankfull if you can help us.
Greetings from the Netherlands!

A. Almost all solvents and organic compounds that evaporate are considered as "smog forming" VOCs. The EPA has specifically listed those volatile organic compounds that, even though they might evaporate do not form smog. We call these "exempt compounds". Therefore, acetone, methylene chloride, p-chlorobenzotrifluorid (PCBTD), t-butyl acetate and others are exempt (they do not form smog) yet they are volatile organic compounds.

In the distant past the EPA used a vapor pressure of 0.1 mm HG (0.01 kPa) as the definition for a volatile organic compound, but that old definition has been replaced.

For OSHA purposes your MSDS must list all "hazardous ingredients" as defined by OSHA (unfortunately I don't have a definition), and that includes both smog forming and exempt volatile organic compounds. However, the total VOC content for EPA purposes is simply the sum of all there smog forming VOCs, in other words all volatile organic compounds minus exempt compounds.

If you are still confused I will gladly help you, but I will need to charge a small consulting fee.

Best wishes,

Ron Joseph

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