Adhesives & Sealants
A transcript of the outreach meeting on September 23 will be posted on this page within two weeks.
In order to maximize the available time for information collection, we have created individual pages for each of the topics listed in SB 373. Links to these pages are above.
These pages are intended to organize the collaboration between manufacturers, stakeholders, and the EPP Database Team regarding the key factors to be considered in developing an environmentally preferable product specification.
Please use this home page to discuss logistics issues and any items that do not fall under one of the topic-specific pages. Use the topic-specific pages to submit and discuss relevant information sources, product data, definitions, benchmarks, etc.
HOW TO COMMENT ON THESE PAGES
To maintain an open and transparent development process, we ask that you submit your comments directly on our website, where possible. To post your comments, you must first register on the website and login (click on "Register" button at top of this page). Once you are logged in, you can return to this page and you will see a text box at the bottom of the page allowing you to post comments. You may email documents or web links you wish to be considered to gshank@ctg-net.com and we will add them to our information resources page.
R. Kelly Johnson - 2004-07-13 17:06:26 1. To define the scope of the Sealants specification, you should include sealants for interior use and exterior use. Interior sealants can be defined as both elastomeric or non-elastomeric depending on the specific application. Elastomeric sealants are those high-performance sealants that are rubber in nature (elastic quality - sealants that stretch and fully recover) with a great deal of movement capability such as polysulfides, polyurethanes, silicones, and urethane/silicone hybrid. Non-elastomeric sealants are those sealants or caulks that are not rubber in nature, they don't have a lot of movement capability, such as acrylics, latexes, and butyls. Exterior sealants should only be elastomeric-type sealants because of excessive thermal expansion and contraction that occurs in exterior building substrates. Elastomeric sealants generally have UV stabilizers in them as well to resist the affects of weathering. 2. Life cycle analysis can be obtained from most sealant manufacturers technical service departments on their specific products. For Pecora Corporation sealants, contact Roy Cannon, Director of Technical Service at 800-523-6688 ext. 7520. Some manufacturers conduct these tests in-house, which may be considered biased. Other manufacturers may have independent laboratories conduct these tests, which are obviously unbiased and perceived more credible. 3. Another reference document that can be used is the San Diego Air Pollution Control Department (SDAPCD) Rule 67.21 for Adhesive Material Application Operation. 4. I do not believe Pecora Corporation participates in the Green Seal program. 5. Obviously, the key environmental issue to be considered with adhesives and sealants is the solvent content of the product and the release of that solvent into the atmosphere. 6. Once a sealant is fully cured, it is no longer releasing VOCs. Therefore, sealants don't pose anymore risk in schools than they would anywhere else, which is none, unless consumed in large quantities.
NOTE: New technology has made it possible for a few major sealant manufacturers, Pecora Corporation being one of them, to produce high-performance, low VOC urethane/silicone hybrid sealants that are solvent-free, with no harmful isocyanates. These sealants are very environmentally friendly products, while at the same time, giving the building owner a high-performance sealant with a long life expectancy. This technology can be used to produce other products that have traditionally been high in solvents, such as elastomeric deck coatings.
Mark Stypczynski - 2004-07-15 11:46:49 Good Morning,
Concerning reference documents, you may wish to include the California Air Resources Board (CARB) Consumer Product Regulations and the Ozone Transport Commission's Model Rule for Consumer Products. The CARB regulation is a good example of an agency/public/industry consensus standard insofar as adhesives and sealants are concerned. The standard achieves a balance between the need for reduction of VOC's and product efficacy and performance. I caution against using South Coast AQMD Rule 1168 as a standard anywhere outside of the Southern California area, as this regulation makes no pretense of considering product performance and, by the admission of SCAQMD, takes into account only the climatic conditions of their area.
The key environmental issue with adhesives and sealants is volatile organic compound content-how much is released and what hazards do they present. I would recommend VOC limits (in line with the previously mentioned CARB regulations) and possibly inclusion of proper safety and health practices for use in adhesive and sealant application and in post occupation of the area (for example: a waiting time before reoccupation of an area, how to ventilate an area, etc.).
Concerning dividing products between interior and exterior, I believe this to be a performance issue, not an EPP issue. There are many products, latexes included, that can be successfully used in both areas, with the performance requirements being determined by the specific needs of a structure in a particular climate. Macco Adhesives is currently not a participant in the Green Seal program. We know of no one performing in-depth life cycle analysis in the adhesive industry at this time.
Mark Collatz - 2004-07-15 13:40:24
The Adhesive and Sealant Council, Inc. (ASC) is an international trade association representing 120 manufacturers of adhesives and sealants and suppliers of raw materials to the industry. In the past the Council and its members have been involved with or commented on the Green Seal program for commercial adhesives. We have also provided comments to the U.S. Green Building Council with regard certain specifications incorporated within Leadership and Energy and Environmental Design (LEED) Rating System and the U.S. Environmental Protection Agency with regard to their Whole Building Design Guide. In addition, we presently are working with National Association of Home Builders (NAHB) Research Center on a project to set green building guidelines for use by the home building industry. It should also be noted that ASC and its members have worked closely with the California Air Resources Board (ARB) and South Coast Air Quality Management District (SCAQMD) for more than 15 years in developing products with reduced VOC emissions that still maintain the quality standards that our customers in California expect.
In developing any green building guidelines, ASC and its members believe that VOC limits for building construction adhesives should be based the Air Resources Board’s limit of 15 percent VOC rather than lower limits mandated by SCAQMD in Rule 1168. While the Rule 1168 limits imposed on adhesives utilized in construction generally provides satisfactory results in the climatic conditions found in Southern California, these same products may be challenged in performance in other areas of the state, particularly northern California, where temperatures and moisture may be more variable. Most of the low VOC alternatives mandated by South Coast will perform adequately in a dry environment as they are “water resistant” but not waterproof. A waterproof product is required in construction and remodeling situations where either cold or inclement weather can occur.
It should be noted that when South Coast revised the construction adhesive categories to their present limits in 2000, the accompanying staff report acknowledged that the new limits “may have performance difficulties in extreme temperature and humidity conditions” but discounted those concerns for their revisions because of Southern California’s unique climatic conditions. For these same reasons the Council would also suggest the adoption of a 4 percent VOC limit for caulks and sealants as mandated by the ARB’s Consumer Rule.
If you have any further questions about the development of the amendments to Rule 1168 or these suggestions, please contact me at 301/986-9700 ext. 112
Heidi McAuliffe - 2004-07-23 09:25:57
The National Paint and Coatings Association is a voluntary non-profit industry association, originally organized in 1888 and comprised today of some 400 members who are engaged in the manufacture and distribution of paint, coatings, adhesives, sealants, caulks and related products, including the raw materials suppliers to the industry. As the preeminent organization representing the coatings industry in the United States, NPCA’s primary role is to serve as ally and advocate on legislative, regulatory and judicial issues at the federal, state and local levels.
NPCA’s Caulks, Sealants and Adhesives Committee was intimately involved with OTC workgroup in drafting the Consumer Products Model Proposal. We worked diligently to ensure that the model rule provided consistent and reasonable standards for all consumer products. In addition, our committee has worked extensively with the California Air Resources Board staff persons, first negotiating a RACT/BARCT determination for adhesives and then later, incorporating this work into the consumer products rule that was adopted in 1998. In addition, we have participated in many rulemakings in many of the air districts in California, including the Bay Area Air Quality Management District, South Coast Air Quality Management District, and San Joaquin Valley, among others. Over the years, NPCA has been extensively involved in the development of volatile organic compound (VOC) regulations for adhesive products at all levels of government.
We are pleased to participate in this process and hope that we will have substantive discussions regarding the performance characteristics relative to the environmental impacts of these products. While we are not aware of any life cycle analyses (LCAs) of adhesive and sealant products or specifically for building products, we would to bring to your attention the Handbook of Adhesives and Sealants by Irving Skeist. This handbook is a textbook on these products and, historically, is considered a primary source of information about these products. In addition to the Skeist Handbook, there are a multitude of other handbooks and textbooks on these products. In addition, existing product specifications for adhesives and sealants should also be considered as resources.
There are a myriad of regulations which govern adhesives and sealants, including the consumer products regulation at the Air Resources Board along with various air district rules. These regulations should be considered, keeping in mind that the most stringent standards in the South Coast Air Quality Management District were adopted because of the unique circumstances present in that District.
Manufacturers of adhesives and sealants typically formulate products that are designed to meet multiple needs. Any product issues specific to use in schools would have been considered when formulating a product for use in a building occupied by humans. In addition, product issues would also have been considered by the applicator when selecting the product for a specific use. We look forward to participating in this process. If you have any questions, do not hesitate to contact me.
Best regards, Heidi K. McAuliffe Counsel, Government Affairs National Paint & Coatings Association, Inc. 1500 Rhode Island Avenue, NW Washington, DC 20005 202-462-6272
Ben Mack - 2004-07-26 12:48:49
To help define the scope of the Adhesive specification, you may want to consider the criteria established for emission standards by the Carpet and Rug Institute (CRI). As a manufacturer of flooring adhesives, the CRI has a "Green Label" program that serves as a test for indoor air quality. Carpets and adhesives, as part of the CRI "Green Label" program, are tested for chemical emissions by Air Quality Sciences, an Atlanta-based, independent laboratory. The test methodology was developed by consensus during an official dialogue with the EPA and has been adopted by the American Society for Testing and Materials (ASTM). In order to be a part of the "Green Label" program, the adhesive must be measured at 10.0 mg/m2*hr or less.
SCAQMD Rule 1168 - The South Coast Air Quality Management District's Rule 1168 allows a calculated number based on VOC's that go into a product. The criteria does not attempt to measure the emissions coming from a finished adhesive product. The CRI Green Label Program measures actual emissions coming from the finished adhesive in a specific time period.
Along with being high-performance adhesives, our environmental products are designed to have No Discernable Odor. This is a part of the matrix that goes along with lower VOC emissions and Indoor Air Quality (IAQ).
Thank you for your consideration.
Ben Mack - W.W. Henry Company, 400 Ardex Park Drive, Aliquippa, PA 15001 - (724) 203-5000
Mary Ellen Roddy - 2004-08-16 07:17:47
We believe that performance characteristics should be a primary focus when defining the scope of the specification for Adhesives and Sealants. As for distinguishing between interior and exterior uses, we believe this is strictly driven by matching the performance characteristics of the product to the structural and climatic needs the job or application requires. Many of the products on the market today are typically all-purpose, so there is no need to differentiate between interior and exterior.
While we do not perform any 'Life Cycle Analysis', we are also not aware of anyone in the adhesive and sealant industry that performs in-depth life cycle analysis. Further, many areas of life cycle analysis are 'guess work' and we don't feel you can rely on that type of data.
As far as reference documents go, we would recommend the existing Consumer Products Regulation developed by the California Air Resources Board (with significant industry input), California's RACT/BARCT determination for Adhesives and Sealants, the model rule for Ozone Transport Commission, and the various ASTM Test Methods that specify the performance characteristics that adhesives and sealants must meet.
We believe the key environmental issues with adhesives and sealants are the volatile organic compound content and following manufacturer's recommended safety and health practices during and after application. Both of these issues apply mainly during the application and curing process. Once fully cured, these products to not present these environmental issues.
Other than performance characteristics, we do not feel that use of these products in schools presents product issues that are any different than use in a consumer's home. We feel that performance expectations should be higher due to the structure and use of schools vs. a residential home.
We do not participate in the Green Seal program for our White Lightning and Pro Select brands. Thank you for the opportunity to comment.
Mary Ellen Roddy, Regulatory Specialist
(this letter was sent via email by Bob DeCaprio on 9/23/04)
Roof Coatings Manufacturers Association 1156 – 15th Street, NW, Suite 900 Washington, DC 20005 Tele: 202-207-9019 Fax: 202-223-9741 www.roofcoatings.org
Mr. Gregory Shank DSA Headquarters 1102 Q Street, Suite 5100 Sacramento, CA
Dear Mr. Shrank: The Roof Coating Manufacturers Association (RCMA) is the national trade association representing the producers of roof coatings, adhesives and sealants for use in a variety of roofing, waterproofing, and dampproofing applications. We are writing to comment on the California Division of the State Architect, draft EPP Database project. Based on our current understanding of the product list RCMA members’ products would be listed under the (Adhesives and Sealants) and the (Paints & Coatings) categories. At this time we have two main points to share with the DSA.
Firstly, we are unclear if our products are intended for inclusion under the criteria of SB 373, which concerns “healthy indoor environments for children”. Our members’ products are designed for exterior application, and as such, should have little or no impact on interior air quality. However, neither SB 373, nor DSA’s product categories delineates between interior and exterior applications. Many RCMA member products fall under the well established regulatory definitions of “architectural coatings” and are regulated as specialty products under the same rules as house paint, interior adhesives and similar coatings. However, our member products, both sealants and coatings, are designed as exterior roofing, waterproofing and dampproofing materials and as such should have little or no impact on indoor air. We respectfully ask the DSA to consider redefining the category so as to exclude these types of products.
Secondly, we do not support the project proposal as currently envisioned and ask the DSA to allow significant stakeholder input and to revisit and define the listing/screening criteria before any further action is taken. We feel that the result of the current proposal will far exceed the intent of SB 373 upon which the proposal is based, that the current criteria are vague, and will create an unworkable purchasing standard for state schools.
For instance we have the following concerns and questions:
o No industry standards (ASTM, Federal Specifications, etc) are referenced – how will these be incorporated into the database? o No Codes, ICC or NFPA, are referenced – again how will the database account for compliance (or non-compliance) of these products with the new listing? o What is the workable definition of an Environmentally Preferred Product that would help us better understand what products will fit into the definition? o If a product is listed as "Preferred" does that mean builders can still use other products? o The proposal calls for metrics like “less than” and “more than”, but does not define the benchmark. How will these criteria be determined? How far upstream will the criteria apply given the breadth of raw materials used in various products? o Our products are already regulated for environmental concerns by the California Air Resources Board, Cal OSHA, Cal EPA, and other state and federal regulations. How will the EPP criteria differ from, complement or contradict existing regulation? o The technical requirements for coatings and sealants vary substantially from one specialized function to another. How are the standards being defined to accommodate this?
We appreciate the opportunity to make our views known to the DSA and look forward to participating in this project as a stakeholder.
Sincerely Reed Hitchcock General Manager RCMA