Ask the Expert Question-and-Answer Archive

by Ron Joseph

November, 2003

Are VCIs considered coatings?

Q. Are volatile corrosion inhibitors (Vis) considered coatings by the Coatings Industry?

If so, shouldn't VCI manufacturers be required to list the VOC information on their MSDSs?

VCIs include a variety of chemicals combined to have sufficient vapor pressure to volatilize out of packaging, fill the packaging void space with vapor, and partially adsorb onto equipment surfaces. As the packaging is removed the VCI chemicals are supposed to volatilize back into the airspace. Most VCI manufacturers do not list any VCI or solvent chemicals on their MSDSs and so far have escaped governmental scrutiny.

A. In all probability the Vapor Corrosion Inhibitors should be considered as coatings for the very reasons that you pointed out. I can't answer as to why they might have fallen through the cracks with regard to reporting VOCs. However, here are two issues we might need to consider:

1. They VCIs are usually shipped in very small packages and their total VOC content in the package is probably only a few grams.

2. It is possible that the manufacturers of the VCIs are already reporting the VOC content of the chemicals, even though you are the person receiving them. California, for instance, requires that a manufacturer who ships VOCs to a customer in very small quantities must report the VOC as if they were evaporated at the manufacturer's facility. The following example serves to illustrate the point. A printing company in California was shipping thousands of magazines throughout the US. A fraction of the inks used to print the magazines remain in the paper and do not evaporate at the time the magazines are shrink wrapped for shipment. Truck drivers who deliver thousands of magazines to customers across the US have reported that when they open the doors of their trucks, they are overpowered by the vapors. The printing company wanted to take a credit for the VOCs that were being evaporated outside of its facility, (in other words in the trucks, or when the shrink wrap is ultimately removed in supermarkets, etc. The local air pollution agency argued that all of the VOCs should be reported by the company, regardless of where the remaining adsorbed solvents are finally be emitted. The agency argued that in each state VOCs are shipped out in some products and are imported in others. Therefore, rather than ask the recipient companies to report on these small emissions, it was more efficacious to require the manufacture to report the total emissions as if they are being evaporated in one location.

I don't know of either of my points apply to this industry, but if you want to pursue this further you should contact the EPA or your state agency directly. Alternatively, you might want to speak to the environmental manager at one of the VCI vendors.