6.1.11 Implementation Methods - Coating Processes (including Spray Painting), Diisocyanate and Organic Plasticiser Processes
22.214.171.124 Permitted Activity Rule – Coating Processes (including Spray Painting) and Diisocyanate and Organic Plasticiser Processes
The discharge of contaminants into air in connection with:
- The stoving of enamel or baking and drying of any substance where the rate of heat input into the process does not exceed 500 kilowatts (measured by the higher heating value of the input fuel) or where 500 kilowatts or less of electrical energy is used, or
- The spray application of coating materials at a rate of consumption which does not exceed 30 litres per day except in the case of roads, buildings, bridges pipelines, transmission towers, or such structures, or
- Any process involving the use of di-isocyanates or organic plasticisers at a rate which does not exceed eight litres per day;
is a permitted activity subject to the following conditions:
- With reference to parts 1, 2 and 3 of this Rule, the discharge of particulate matter shall not exceed a concentration of 100 milligrams per cubic metre (at zero degrees Celsius, one atmosphere pressure, dry gas basis) measured at the point of discharge from the premises except in the case where the application is outdoors.
- As specified in Section 6.1.8 conditions a) to e) of this Plan.
- If good practice techniques are applied in relation to part 3 this should avoid any adverse effects occurring.
- Refer also to policies in Section 5.2.3 and enforcement method in Section 126.96.36.199 in the discharges to land section of this Plan.
- If any of these conditions are not complied with then the activity is a discretionary activity in accordance with Rule 188.8.131.52.
Explanation and Principal Reasons for Adopting Method 184.108.40.206
Rule 220.127.116.11 applies to the discharge of contaminants to air from both industrial or trade premises and non-industrial or trade premises.
Coating processes as provided for in Rule 18.104.22.168 parts 1 and 2 include the spraying of paints and lacquers, and coating with electrostatic powders. The stoving, baking or drying of enamel or other coating substances provided for in part 1 is necessary to ensure that the enamel, paints or lacquers are hardened and fixed to the surface of an object. This process typically occurs in the ceramics and metal production and finishing industries such as in the finishing of whiteware. The limit in Rule 22.214.171.124 part 1 of 500 kilowatts represents a small scale of activity where adverse effects should not occur if the operator adopts good practice techniques.
Rule 126.96.36.199 also provides for the spray application of paint, paint solvents, varnish, lacquer, dyes, metal oxide coatings, adhesive coatings, elastomer coatings, stains and polishes. The limit of 30 litres represents a small scale of activity where adverse effects should not occur if the operator adopts good practice techniques. The application of paints by paint brushes is a permitted activity regardless of the size of the area being painted as this activity does not result in the discharge of contaminants to air of any consequence.
Part 2 also allows for the painting of roadways (for road marking) buildings, bridges and pipelines. The effects from these activities also have a low risk of having adverse effects on air quality. However by its nature this activity has the potential for discharging contaminants to enter water or soil. However, if good practice techniques are applied in relation to this activity adverse effects on air, land and water should not occur.
Rule 188.8.131.52 part 3 provides for the use of di-isocyanates and organic plasticisers. Diisocyanates are used in the production of polyurethane materials. In New Zealand the manufacture of flexible and rigid polyurethane foam accounts for the majority of diisocyanate use, with polyurethane paints and lacquers also having considerable use. Other processes using isocyanates are the manufacture of urethane rubbers, adhesives and binders. Organic plasticisers are chemicals that are mixed with plastic materials to increase the product’s flexibility and workability. There is potential for the fugitive release of additive chemicals during plastics manufacture.
The use of less than eight litres per day of diisocyanates and organic plasticisers is unlikely to result in any adverse effect as long as the conditions and good practice are adhered to. Processes involving larger quantities of diisocyanates and plasticisers can result in significant discharges of vapours, aerosols and particulate matter that can irritate the membranes of the nose, throat, lungs and eyes. Prolonged exposure usually in the workplace can result in individuals becoming sensitised or can exacerbate existing health problems such as asthmatic attacks. Therefore, Waikato Regional Council needs to consider such effects under Rule 184.108.40.206.