Paints & Coatings

Dave Fuhr - Thu Sep 16 10:32:29 2004

make sure that the paint and coating catergories are quite well defined as to paint versus clear coatings, spray stains,wiping stains, sealers, acrylic, urethane, or acrylic urethane blends. Also if there is to be "clear" class A or B flame retardents as well. When mentioning primers, make sure their is a seperate class for "wood primers". Also each group should have an interior or exterior section as well. This may sound like alot, however for the correct product selection, especially using EPP products, my experience shows that this is very necessary. We provide CD's with all of our information, including MSDS for easy access or posting to your designated site. Within the TDS (technical data sheet) items such as basic use, (what, when, where, how, why) should be addressed along with VOC, HAP & VHAP information, volume & Weight solids. Solvent based products, although using exempt solvents, should not be allowed within this catergory. There is currently to many good products that comply with good quality.

Fred Bauer - Thu Sep 23 15:48:06 2004

If the product is to include post consumer material, the specifications will be approximately the average of past product on the market. This includes almost all specifications of existing product; VOC's, coverage, etc. The key environmental issue that should be addressed is post consumer content. I would recommend 75%!

Greg Shank - Thu Sep 30 15:07:20 2004

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:

• No industry standards (ASTM, Federal Specifications, etc) are referenced – how will these be incorporated into the database?
• 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?
• What is the workable definition of an Environmentally Preferred Product that would help us better understand what products will fit into the definition?
• If a product is listed as "Preferred" does that mean builders can still use other products?
• 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?
• 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?
• 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