California Air Resources Board Rule 1145, revised effective January 2021, sets VOC limits for institutional and industrial cleaning products that are 30 to 50 percent lower than the prior limits. A floor stripper with 10 percent VOC content by weight complies in most states but fails California's 3 percent limit for floor strippers under CARB Rule 1145. A BSC operating in California who does not verify product VOC content against current state limits is selling a service that may violate state air quality rules, and the client who buys that service may face permit violations under their facility air permit.
At the federal level, EPA regulates VOC emissions under the Clean Air Act through the National Volatile Organic Compound Emission Standards for Consumer Products at 40 CFR Part 59, Subpart C. Federal limits apply nationally, but California and the Ozone Transport Commission (OTC) states have adopted stricter limits that govern product formulation and sale in those jurisdictions.
What the Regulations Require
Federal and state VOC rules for cleaning products operate on a product-category framework. Each product type (floor stripper, general purpose cleaner, glass cleaner, restroom cleaner, etc.) has a specific VOC content limit expressed as grams of VOC per liter of product, or as percent by weight. Products sold or used in regulated jurisdictions must not exceed the applicable limit.
| Product Category | Federal Limit (g/L) | California (CARB) Limit | OTC Limit |
|---|---|---|---|
| General purpose cleaners | No federal consumer limit; institutional covered by SCAQMD or state rules | 0.5% VOC by weight (institutional) | Varies by state, typically 4% or lower |
| Floor strippers | No federal institutional limit | 3% VOC by weight | 3 to 7% by state |
| Disinfectants/sanitizers | No federal limit for institutional products | 3% VOC by weight (hard surface) | 3% in some OTC states |
| Degreasers | No federal limit; state rules apply | 6% VOC by weight | 6 to 12% by state |
| Air fresheners | Covered under 40 CFR Part 59 Subpart C | 3% VOC by weight | Per 40 CFR 59 or state equivalent |
The OTC region covers Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, Virginia, and Washington D.C. Many OTC states have adopted the California limits for institutional cleaners. A BSC operating in multiple states needs a product-by-product VOC compliance matrix that maps each product to the most restrictive applicable jurisdiction. The EPA Ozone Transport Commission page provides current OTC membership and coordination activities.
Exempt Solvents
VOC regulations exclude certain compounds from the VOC calculation because they have been determined to have negligible photochemical reactivity. Acetone, methyl acetate, parachlorobenzotrifluoride (PCBTF), and several other solvents are EPA-exempt at the federal level. California also exempts certain compounds but the list differs from the federal list. A product reformulated with exempt solvents to meet a VOC limit is genuinely compliant, not simply substituting one ozone precursor for another. SDS Section 2 (Hazardous Ingredients) combined with Section 9 (Physical/Chemical Properties) should disclose the VOC content and whether exempt solvents are used.
Who It Applies To
VOC limits apply to manufacturers and distributors at the point of sale. A product that does not meet California's limits cannot legally be sold in California, regardless of where the end user is located. For cleaning contractors, the practical exposure is purchasing a non-compliant product from an out-of-state distributor or using legacy product inventory that predates tightened limits. The contractor is not typically cited by CARB for using a non-compliant product, but the manufacturer and distributor face civil penalties. However, a facility with an air permit that includes a VOC content restriction on cleaning products used on-site can cite the contractor for introducing non-compliant products to the facility.
What Regulators Look At
CARB and OTC state air quality agencies inspect manufacturing and distribution, not routine cleaning operations. For BSCs, the compliance exposure comes through facility air permits and client requirements rather than direct regulatory inspection of cleaning activities.
| Compliance Check | Common Gap | Consequence |
|---|---|---|
| Product VOC content verification | Products in inventory with VOC content above California or OTC limits; SDS VOC data not reviewed | Facility permit violation; product sale violation in California |
| Reformulated product updates | Product reformulated by manufacturer to lower VOC; contractor using legacy stock above new limit | Facility compliance gap |
| Exempt solvent documentation | No SDS documentation of which solvents are VOC-exempt; VOC calculation methodology not verifiable | Difficulty demonstrating compliance to facility EHS |
| Contract language | Client contracts with VOC content requirements; BSC not tracking compliance against those requirements | Contract breach; potential facility permit violation |
Common Compliance Gaps and What They Cost
CARB enforcement against product sellers for exceeding institutional cleaning product VOC limits has resulted in civil penalty settlements ranging from $10,000 to $250,000 depending on the volume of non-compliant product sold and the extent of cooperation during the investigation. For BSCs, the more immediate risk is a client EHS audit that finds the cleaning products in use exceed the facility's air permit limits or green purchasing policy requirements. Losing an account over a VOC compliance gap that could have been resolved with a product swap represents a larger financial exposure than any direct regulatory penalty a contractor would face.
Tradeoffs and Operator Reality
Low-VOC reformulations sometimes sacrifice cleaning speed or require longer dwell times, particularly for floor care and degreasing applications. A conventional solvent-based stripper may remove wax buildup in one pass; a compliant low-VOC alternative may require two passes with extended dwell time. In a production facility with an overnight cleaning window, the time cost of a second pass can add 20 to 30 minutes per 10,000 square feet to the floor care cycle. Bidding this account with a compliant product requires pricing the additional time into the labor estimate, which increases the bid. Clients in California and OTC states who have EHS teams understand this cost difference. Clients who do not may resist the higher price without understanding the compliance rationale, which is where documentation of the VOC standard requirement becomes part of the sales conversation.
What to Put in the SOW and Training Matrix
For accounts in California or OTC states, the SOW should specify that all cleaning products used at the account comply with applicable state VOC limits, identify the applicable state standard (CARB Rule 1145 or state equivalent), and confirm the VOC content of each product category in the service program. The product specification list attached to the SOW should include the VOC content value from each product's SDS and confirm compliance with the applicable limit.
Use the VOC compliance tool to check product VOC content against the applicable state limits for your operating jurisdictions. For the RCRA hazardous waste implications of solvent-based cleaning products, see EPA RCRA Hazardous Waste for Cleaning Operations. For Safer Choice certified alternatives that are designed for VOC compliance, see EPA Safer Choice and DfE Procurement. The Federal Register VOC consumer products final rule (1999) provides the background for 40 CFR Part 59 Subpart C. Full compliance reference at Opora Compliance Library. For industrial cleaning programs where VOC compliance is most often contractually required, see the industrial cleaning vertical hub.
By the Opora Editorial Team · Last updated: 2026