Michael Mills, Senior Manager, SCAQMD, provided the following response to a request for clarification regarding CO2 cleaning technology and VOC regulations.
“Thank you for your letter regarding alternate cleaning technologies.”
“SCAQMD Rule 1171 refers to Solvent Cleaning Operations. Definition on page 1171-5 states “VOLATILE ORGANIC COMPOUND (VOC) is any chemical compound which contains the element carbon, excluding methane, carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, ammonium carbonate, and exempt compounds. Our conclusion is that since carbon dioxide is by definition neither a VOC nor an air contaminant, the equipment and/or process is exempt from CAQMD permits pursuant to Rules 201 and 203.”
Michael D. Mills
South Coast Air Quality Management District (California)
Letter to Deflex Corporation, April 7, 1994