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Understanding Volatile Organic Compound (VOC) Regulations in the Roofing Industry DWAYNE WACENSKE Firestone Building Products 250 West 96th Steeet, Indianapolis, IN 46260 Phone: 317­816­3856 • E­mail: [email protected] Proceedings of the RCI 25th International Convention Wachenske ­ 243 ABSTRACT There have been many changes in the regulations governing materials used in the roofing industry in recent years. The regulations set maximum allowable amounts of volatile organic compounds (VOC) that products may contain. Complicating matters is that these rules and regulations are being enacted at the state level and sometimes on the local level, making it very difficult for the roofing community to understand their obligations and responsibilities. This paper will try to clarify these rules and regulations as well as the implementation of them. A discussion on the products available to meet these requirements will also be included. SPEAKER Dwayne Wacenske is the TPO product manager for Firestone Building Products. Wacenske has more than 20 years of experience in the plastics industry and 10 years in the roofing industry. Wacenske holds a bachelor of science degree in chemistry from the University of Akron. Wachenske ­ 244 Proceedings of the RCI 25th International Convention Understanding Volatile Organic Compound (VOC) Regulations in the Roofing Industry INTRODUCTION these rules and regulations as well as ozone. Ground­level ozone is an air There have been many changes in the implementation of them. A dis­ pollutant that is harmful to breathe, the regulations governing materials cussion on the strategies employed to damages crops, trees and other vege­ used in the low­slope commercial meet these requirements also is tation, and is the main ingredient of roofing industry in recent years. The included. urban smog. The troposphere extends regulations set maximum allowable up from the ground about six miles, amounts of volatile organic com­ Disclaimer where it meets the stratosphere (e.g., pounds (VOCs) that products may Unless otherwise specifically stat­ the ozone layer). The remaining 90% contain. Complicating matters further ed, the information presented in this of ozone occurs naturally in the is the fact that these rules and regu­ paper is based on publicly available stratosphere, an area that stretches lations are being enacted at the state information and is accurate as of the about 30 miles up from the top of the level and sometimes even locally, date it was written. The information troposphere. This “good” ozone making it very difficult for the overall contained in this paper should not be shields the Earth from the sun's roofing community to understand considered legal advice, and you harmful ultraviolet (UV) radiation. their obligations and responsibilities. should not act or refrain from acting Ground­level ozone is not emitted Typically, these regulations apply to on the basis of any content included directly into the air, but is created by the users, sellers, and manufacturers in this paper without seeking advice chemical reactions between oxides of of these products. However, some from local authorities or a qualified nitrogen (NOX) and VOCs in the pres­ jurisdictions also include the specifier legal professional. ence of sunlight. of the product. ➜ Why Regulate VOCs? VOC + NOX + Heat + Sunlight Many of the products used in roof­ Ozone ing systems, such as adhesives, To understand why VOCs are reg­ sealants, primers, and coatings, con­ ulated, it is important first to under­ The VOCs that are of concern for tain organic solvents. These solvents stand the relationship between VOCs, the environment are those that are may or may not be exempt for the ozone, and smog. photochemically reactive. VOCs that are determined to have negligible purposes of calculating the VOC con­ Smog is a brownish haze that pol­ photochemical reactivity may be tent, depending on the jurisdiction. lutes the air in urban areas. Many exempt from being included in VOC Thus, it is difficult to determine the people have difficulty breathing when content calculations because these VOC content of a product if the status the air is polluted with smog. chemicals do not lead to the forma­ of a solvent varies by location. Visibility also is adversely affected by tion of ground­level ozone. Another factor is that 12 smog. Northeastern and Mid­Atlantic states The primary component of smog is Solvents and the District of Columbia have ozone. While the two terms often are The main source of both NOX and joined to form the Ozone Transport used interchangeably for general use, VOCs is automobile exhaust emis­ Commission (OTC). This organization smog is more complex. Smog is pri­ sions. However, the second largest was formed to coordinate the member marily made up of ground­level ozone source of VOCs is solvents. Figure 1 states’ efforts to reduce ground­level combined with other gases and par­ shows the quantity of VOC emissions ozone in the region. While the mem­ ticulate matter. from various sources in 2002 as bers have agreed in principle to what Within the Earth’s atmosphere, reported by the EPA. constitutes a VOC and the permissi­ ozone is present in two layers – the We are all well aware of the efforts ble VOC content of products, not all of troposphere and stratosphere. About to reduce automobile emissions. Less the states have actually enacted the 10% of the atmospheric ozone occurs obvious are the efforts to reduce VOC regulations. Others have enacted laws in the troposphere, which is the layer emissions from solvents. Solvents are with different enforcement periods. closest to the Earth’s surface, and is used in many industrial processes The goal of this paper is to clarify considered ground­level or “bad” Proceedings of the RCI 25th International Convention Wachenske ­ 245 as State Implementation Plans (SIPs), showing how they will attain the standards. It is with­ in these SIPs that states may propose stringent regulations such as limiting the VOC con­ tent of various products, which may include adhesives and sealants. Typically, the regulations limiting the VOC content of adhesives and sealants apply to people who use, sell, or manufacture these products. However, some jurisdictions have also included persons who “solicit, require the use, or specify the application” of adhesives and sealants. California’s Air Districts The first regulation con­ cerning adhesives and sealants was adopted by the South Coast Air Quality Figure 1 – National VOC emissions by source sector in 2002. Management District (SCAQMD) in the state of California in 1989. Rule 1168 regulates the VOC content of and in many consumer and commer­ (EPA), states, and cities to implement adhesive and sealants. Of concern to cial products. Since 1998, the EPA programs in order to further reduce the roofing industry are two cate­ has regulated the VOC content of emissions of ozone precursors from gories of materials: single­ply roof many of these products, including sources such as cars, fuels, industri­ membrane adhesives and single­ply automobile refinish coatings, con­ al facilities, power plants, and con­ roof membrane sealants. The VOC sumer products, architectural coat­ sumer/commercial products. content limits for these two materials ings, aerosol coatings, and portable Although the commercial roofing are 250 and 450 grams per liter fuel containers. Among the consumer industry supports the overall effort to respectively. products that are regulated are many improve air quality by reducing VOC The SCAQMD is one of 35 air dis­ household cleaners and personal care emissions, recent state regulatory tricts in California. Another 12 of the products. developments may have a significant California air districts have adopted The roofing industry uses many adverse effect on many widely used rules similar to the SCAQMD rule. products that contain solvents, products, roof application methods, The remaining 22 air districts do not including coatings, adhesives, and and ultimately, total installed costs. have rules governing adhesives at this sealants. Solvents are used to dis­ Currently, there are no direct fed­ time. solve polymers or bitumen to make eral regulations concerning the VOC Unfortunately, there are differ­ the material easier to apply. The sol­ content of adhesives and sealants. ences in the rules of the 13 air quali­ vent then evaporates, leaving the The CAA authorized the EPA to estab­ ty districts. The SCAQMD and some polymer behind. However, the quanti­ lish the National Ambient Air Quality other California air districts currently ty of solvents used in the commercial Standards (NAAQS). The CAA also do not exempt the solvent tertiary roofing industry is very small com­ establishes provisions defining when butyl acetate (TBAc) from VOC con­ pared to all other sources. and how the federal government can tent calculations. In 2004, the EPA impose sanctions on areas of the revised the definition of VOC to Regulating VOCs to reduce country that have not met certain exclude TBAc. The EPA made this Ground­Level Ozone conditions. As such, areas that do not revision on the basis that TBAc is The Federal Clean Air Act Amend ­ meet the NAAQS are designated as “negligibly reactive” and that using ments of 1990 (CCA) requires the U.S. nonattainment areas. These areas TBAc as a substitute solvent “will help Environmental Protection Agency must submit air quality plans, known Wachenske ­ 246 Proceedings of the RCI 25th International Convention VOC Content Limit Phase In­Periods Jurisdiction Status Adhesives Sealants 2009 2010 2011 2012 Connecticut Effective 10/3/2008 250 450 June 1 – Aug. 31 May 1 ­ Sept. 30 May 1 ­ Sept. 30 After Jan. 1 Delaware Effective 5/1/2009 250 450 June 1 – Aug. 31 May 1 ­ Sept. 30 May 1 ­ Sept. 30 After Jan. 1 D.C. Under Consideration Maine Effective 1/1/2011 250 450 N/A N/A May 1 ­ Sept. 30 After Jan. 1 Maryland Effective 1/1/2009 250 450 May 15 ­ Sept.

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