BETHESDA, Md.—The EPDM Roofing Association is recommending to the EPA that it bases proposed environmental performance guidelines on “assessed risk” rather than the concept of “intrinsic hazard,” the association said.
The association cited a rage of widely used building products that could be excluded from the marketplace if the proposed guidelines are implemented as written.
The ERA filed these comments to the EPA on its proposed draft guidelines for product environmental performance standards and ecolabels for voluntary use in federal procurement. The ERA said the concept of “intrinsic hazard” as used in the draft neglects the importance of overall risk assessment as the best approach to identifying potential and actual environmental or human health danger as a product.
“We applaud the EPA for incorporating the expertise of impacted industries as they establish environmental standards,” said Ellen Thorp, associate executive director of the ERA, in a news release. “It is vitally important that we review all of the consequences, intended and unintended, of these proposed guidelines.”
The ERA listed a number of building envelope products that could be affected by the guidelines as written, the alleged hazardous materials they may contain and the reference list in parentheses from which the alleged hazard is identified:
• Thermoplastic roofing membranes: Titanium dioxide (California Prop 65);
• Rubber roofing membranes: Carbon black (California Prop 65);
• Asphaltic roofing and waterproofing products: Bitumen (California Prop 65);
• Reflective roof coatings: Titanium dioxide (California Prop 65);
• Fiber insulation: Wood dust (California Prop 65); and
• Foam insulation: Halogenated fire retardants (San Antonio Protocol)
The ERA stressed its only area of concern with the EPA's draft guidelines is the concept of “intrinsic hazard.”