BETHESDA, Md.—The South Coast Air Quality Management District should modify its revision of a key toxics exposure rule to allow the continued use of water-based products in various architectural adhesive applications, the Adhesive and Sealant Council said in comments to the SCAQMD.
The ASC commented on the SCAQMD's revision of Rule 1168, which sets volatile organic compounds emissions limits for commercial adhesive and sealant product categories in the largest and most populous counties of the Los Angeles basin.
Reducing VOC percentages by 10 or 15 percent would be much fairer and more realistic than cuts of 50 to 80 percent as the agency proposes, the ASC said in its comments.
The council also opposed a new limit of 50 grams per liter for architectural sealants and non-membrane roofing sealants. That limit would eliminate solvent-based adhesives in these categories and force consumers to choose products that are not reusable after they are opened, creating more waste and expense, it said.
Among other things, the ASC also suggested that:
• The SCAQMD implement a mandatory survey every five years, or whenever it is considering revisions in Rule 1168, in lieu of a proposed annual survey;
• The agency change the requirement for keeping company sales information to three years from the proposed five; and
• The agency not restrict the sale of products manufactured before the effective date of the revision.
The ASC raised the issue of clear paintable and water-resistant sealants because the California Air Resources Board has never regulated them, said Mark Collatz, ASC director of regulatory affairs. The revision of Rule 1168 is the first attempt to do so in California, he said.
"Clearly this product type now needs a stand-alone definition and a higher VOC limit to maintain its efficacy," Collatz said.