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. 15 May 1 ­ Sept. 30 May 1 ­ Sept. 30 After Jan. 1 Massachusetts Nothing has been adopted New Hampshire No action yet New Jersey Effective 1/1/2009 250 450 June – Aug. May ­ Sept. May ­ Sept. After Jan. 1 New York Under Consideration Pennsylvania Proposed 250 450 Rhode Island Effective 7/1/2009 250 450 July 1 ­ Aug. 31 May 1 ­ Sept. 30 May 1 ­ Sept. 30 After Jan. 1 Vermont Nothing has been adopted Virginia Proposed 250 450 N/A May 1 ­ Sept 30 May 1 ­ Sept. 30 After Jan. 1

1. U.S Environmental Protection Agency, http://www.epa.gov/air/emissions/voc.htm (accessed 9/1/2009).

2. 40 C.F.R. § 59 National Volatile Organic Compound Emission Standards For Consumer And Commercial Products

3. Maine 06­096 Chapter 159 Control of Volatile Organic Compounds from Adhesives and Sealants, Section 2.G. (2009).

4. South Coast Air Quality Management District, Rule 1168 (2005), http://www.arb.ca.gov/DRDB/SC/CURHTML/R1168.PDF (accessed 9/1/2009).

5. U.S. Environmental Protection Agency, 11/18/2004. http://yosemite.epa.gov/opa /admpress.nsf/b1ab9f485b098972852562e7004dc686/50d1d8b63a857ce785256f500065d12e! OpenDocument (accessed 9/1/2009).

6. OTC Model Rule For Adhesives and Sealants, http://www.otcair.org/projects_details.asp?FID=99&fview=stationary# (accessed 9/1/2009).

7. Regulations of Connecticut State Agencies, Section 22a­174­44

8. Delaware Register of Regulations, Volume 12, Issue 10, Issue Date April 1, 2009, pp. 1333 – 35.

9. Maine 06­096 Chapter 159 Control of Volatile Organic Compounds from Adhesives and Sealants (2009).

10. Maryland Title 26, Subtitle 11, Chapter 35, Control of Emissions of Volatile Organic Compounds from Adhesives and Sealants (2008).

11. New Jersey Administrative Code, Title7, Chapter 27, Subchapter 26, Prevention of Air Pollution from Adhesives, Sealants, Adhesive Primers and Sealant Primers (2008).

12. Executive Summary – Amendments to 25 Pa. Code Chapters 121, 129 and 130, http://www.depweb.state.pa.us/pubpartcenter/lib/pubpartcenter/eqb/2008 /12162008/adhesivesexecutivesummaryeqbproposed11_7_2008.pdf (accessed 9/1/2009).

13. State of Rhode Island and Providence Plantations, Department of Environmental Management, Office of Air Resources, Air Pollution Control Regulation No. 44, Control of Volatile Organic Compounds from Adhesives and Sealants (2009).

14. Virginia Regulatory Town Hall, http://www.townhall.virginia.gov/L/viewchapter.cfm?chapterid=2497 (Accessed 9/1/2009)

Table 1 – Summary of OTC Rules on Single­Ply Roof Membrane Adhesives and Sealants. decrease ground­level ozone forma­ a multistate organization created consists of the eleven Northeastern tion.” TBAc has been found to be a under the CAA. It is responsible for states, Pennsylvania, and the District very good replacement solvent for advising the EPA on transport issues of Columbia. some commonly used solvents that and for developing and implementing The OTC developed a “model rule” are considered VOCs. Thus, materials regional solutions to the ground­level to reduce ozone levels in the region. that maybe compliant with regula­ ozone problem in the Northeast and However, the member states may opt tions in one air district may not be Mid­Atlantic regions. Ground­level to promulgate rules based on the compliant in another. ozone and other pollutants can travel model rule or they may modify the long distances by wind currents, cre­ model rule to fit the needs of their

The Ozone Transport Commission ating air quality problems far from the state. Some states have not yet adopt­ More recently, the Ozone Trans ­ source of the pollution. This migra­ ed any rules regarding the VOC con­ port Commission (OTC) created a mo ­ tion of pollutants is known as trans­ tent of adhesives and sealants. port and has lead to the regionaliza­ del rule to regulate the VOC content An important consideration for the of adhesives and sealants. The OTC is tion of air quality matters. The OTC

Proceedings of the RCI 25th International Convention Wachenske ­ 247 OTC states is that the climate in the exempt solvents can be used as a membranes and flashings to the roof northeastern United States is quite substitute for some of the VOC sol­ deck, insulation, or other substrates. different from southern California. To vents. However, for many polymer Bonding adhesives are a critical part comply with the regulations in Cal i ­ systems, simple replacement is not an of fully adhered, single­ply roofing fornia, many manufacturers de­ option. Rather, complete reformula­ systems. veloped water­based materials. The tion of the product is needed. These adhesives usually use con­ climate in California allowed these Some of the solvents that the EPA tact adhesive technology. Contact materials to be used yearlong in most excludes from its definition of VOC adhesives provide very strong initial of the state. However, using water­ are acetone, parachlorobenzotrifluo­ and long­term bonds with high shear based materials in some OTC states ride (PCBTF), and TBAc. The use of resistance. This is needed in order for will severely limit the roofing season, these solvents will reduce the calcu­ the roofing membrane to resist wind as these materials do not perform well lated VOC content of the mixture, but uplift forces. Contact adhesives in cold climates or when tempera­ there will be consequences. Typically, require the adhesive to be applied to tures drop below 40°F. the cost of these solvents is much both surfaces. The adhesive is then The EPDM Roofing Association higher than traditional solvents. The allowed to dry before the two surfaces (ERA) has worked with several state working and drying time can also be are mated. environmental agencies to make them adversely affected. There are two key components of aware of the consequences of these Another option is to replace the any contact adhesive: the polymer new regulations on the roofing indus­ solvent­based products with water­ matrix and the solvent system. try. In response, some states have based products. Some polymer sys­ The polymer matrix determines decided to phase in the regulations tems are water­soluble and thus have for the roofing applications over a few the final performance characteristics zero or very little VOC content. Un ­ of the adhesive system. The polymer years. This has provided manufactur­ fortunately, water freezes at a much must meet some very demanding ers with additional time to develop higher temperature than most other requirements. It must be able to pro­ products to meet these unique solvents. Therefore, water­based vide excellent strength, yet remain requirements. coatings and adhesives cannot be flexible. It must be durable and exhib­

In most of the OTC states, the reg­ applied when the ambient tempera­ it this high level of performance for ulations for the VOC content of sin­ ture is near freezing. Many of these decades. It must be temperature­ gle­ply roofing adhesives, primers, adhesives and coatings will be ir ­ resistant, it must remain flexible at and sealants will be in effect during reparably damaged if they are allowed very low temperatures, and it must be the months of June through August to freeze before installation. There ­ stable at temperatures up to 200°F. In of 2009; May through September of fore, water­based adhesive must be addition, it must be fire resistant to

2010 and 2011; and after January 1, stored at temperatures greater than prevent spread of flame and to meet 2012. During these months, adhe­ 60°F. Manufacturers usually recom­ stringent building code requirements. sives, primers, and sealants that are mend that the adhesives be brought used with single­ply roofing mem­ to room temperature before and dur­ The solvent system determines branes must comply with the VOC ing application. many of the application characteris­ tics of the adhesive, for example vis­ content limits. Moreover, at low temperatures, it cosity, the ability to be spread or

Table 1 summarizes the regula­ can take an inordinate amount of sprayed, and its drying properties. tions in the OTC states at the time of time for these adhesives or coatings to this writing. Since several states have dry. Water has many shortcomings as Drying time is a critical require­ ment of bonding adhesives. The adhe­ not acted on this issue yet, it is rec­ a solvent for adhesives, sealants, and ommended that the reader consult coatings that are to be used outdoors. sive must dry in a reasonable period. Ideally, the drying time would be the environmental agency that has For some applications, there may equal to the application time. jurisdiction over the project to ensure be the option to eliminate solvents Excessive drying time will lead to loss that products used on a project com­ completely. Examples include 100% of productivity on the rooftop. ply with the current local regulations. solids systems, such as polyurethane sealants and adhesives, and epoxy Compliance Strategies Solvent­Based Bonding coatings. Adhesives In order to comply with VOC con­ tent regulations, manufacturers must Bonding Adhesives Most solvent­based bonding adhe­ sives in use today use polychloro­ reduce or eliminate solvents that con­ The products most affected by the prene rubber (PCR), such as DuPont’s tribute to the VOC content. Some sol­ VOC regulations are bonding adhe­ vents are not photochemically reac­ Neoprene, as the polymer matrix. This sives. Bonding adhesives are exten­ synthetic rubber provides excellent tive and are exempt from VOC mea­ sively used in the commercial roofing properties for a roofing adhesive. It is surements. In some cases, these industry to adhere single­ply roofing very stable over the entire service

Wachenske ­ 248 Proceedings of the RCI 25th International Convention temperature range experienced on a limit the use of these materials to six cludes butyl­based rubbers, hydro­ commercial, low­slope roof. It also months out of the year. carbon tackifying resins, and some­ possesses excellent physical proper­ Although water is a very inexpen­ times curatives. ties and good fire resistance. sive solvent, many water­based mate­ PCBTF has been found to be a Unfortunately, PCR is a difficult rials are relatively expensive com­ good substitute solvent for many polymer to dissolve. Typically, xylene, pared to a traditional solvent­based primers to comply with VOC content toluene, or a combination of the two material. Water­based bonding adhe­ limits. PCBTF­based primers require are used as the main solvents for sives may be 1½ to two times more longer open time than primers with PCR. Acetone (a VOC exempt solvent) expensive than a solvent­based adhe­ VOC­containing solvents. There is can only be used in PCR adhesive at sive. Some of this expense may be off­ also the potential that PCBTF­based low levels. Acetone has a relatively low set by increased coverage rates. primers may swell an EPDM mem­ flash point (1.4°F), which may cause The drying time of water­based brane to a greater degree than water to condense on the surface of adhesives is highly dependent on the primers that use VOC­containing sol­ the adhesive as the acetone evapo­ ambient conditions. Temperature, vents. Since primers are typically rates, causing the surface to cool. humidity, wind speed, and cloud coated much thinner than bonding

This is sometimes referred to as cover will all affect the drying time. adhesives, that possibility is mini­ blushing and can lead to poor bond­ Also critical is that the drying time mized. However, puddling or exces­ ing when the two surfaces are mated. needs to be consistent. Water­based sive application rates can lead to

Manufacturers have been able to adhesives may dry quickly in sunny membrane blistering and extended reformulate bonding adhesives using areas, yet remain wet in shaded open times. exempt solvents such as PCBTF or areas. Typically, the drying time of TBAc. However, there are trade­offs solvent­based adhesives is much less Sealants with these solvents. The drying time sensitive to the ambient conditions The definition of a sealant in the can be considerably longer, reducing than water­based adhesives. SCAQMD rule 1168 is any material productivity. There have been some that is used to fill, seal, or waterproof user complaints concerning the odor Polyurethane Adhesives gaps or joints between two surfaces. of some exempt solvents. PCBTF may There are some polyurethane The definition of sealants also cause swelling of EPDM membranes, adhesives used in the commercial includes many sealant primers and resulting in solvent blisters or areas roofing industry that contain no caulks. that are not adhered properly. In VOCs. These adhesives typically As noted, the VOC content of addition, both of these exempt sol­ require the use of a fleece backing on sealants is also regulated in many vents are relatively scarce and there­ the membrane. The backing is needed areas. When regulated, the VOC con­ fore, considerably more expensive because the polyurethane adhesives tent limit for sealants is 450 grams than the more readily available xylene usually do not bond well directly to per liter. This is considerably higher and toluene. the single­ply membranes. than the limit for adhesives (250 grams per liter). Water­Based Bonding Adhesives Adhesive Primers Sealants are an important part of

Water­based bonding adhesives Adhesive primers are needed in the waterproofing system, and failure have been available for single­ply many single­ply roofing systems to of a sealant may result in a leak. roofing applications for several years. prepare a surface (single­ply mem­ However, a sealant failure probably

Latex acrylic technology is used as brane, metal, insulation, etc.) to will not result in a catastrophic fail­ the polymer matrix in most water­ receive an adhesive or adhesive tape. ure of the roof the way that a bonding based bonding adhesives. These Primers are either included under adhesive failure could. acryl ic polymers are heat­resistant, the definition of an adhesive or given flexible, and strong. Additionally, the volume of their own category in the rules and sealants is relatively small compared

As mentioned above, the use of regulations for VOC content and are to that of bonding adhesives. water­based bonding adhesives is typically limited to 250 grams per Most roofing sealants have a much limited by the ambient temperature. liter. Most manufacturers recommend that higher solids content than adhesive The same approaches to lower the these adhesives only be used when and primers; thus, sealants contain VOC content of solvent­based bond­ the temperature is 40°F and rising. much less solvent. Most roofing ing adhesives have been used with Additionally, the adhesive must be sealants meet the VOC content regu­ primers: solvent substitution. Primers maintained at temperatures above lations. may have solids content as low as 5%, 40°F for 48 hours after application in meaning that the remainder of the What Lies Ahead? order for the adhesive to cure fully. In material will be solvents. The solid many areas of the country, this will There will continue to be changes por tion of the primer typically in ­ in the rules and regulations regarding

Proceedings of the RCI 25th International Convention Wachenske ­ 249 the environment that will affect the ensure that other issues are not com­ can be accomplished successfully roofing industry. In 2008, the EPA promised in the name of the environ­ with cooperation and open communi­ significantly strengthened the air ment. For example, if adhesives do cation between state and federal reg­ quality standards for ground­level not work properly and the integrity of ulatory bodies, roofing product man­ ozone. More areas around the country a roofing system is compromised dur­ ufacturers, specifiers, consultants, may be required to implement plans ing a storm event, then the safety of owners, installation contractors, and to reduce ground­level ozone levels. the people in that building may be at others. This will lead to more regulations on risk. the VOC content of many products, In particular, roofing system spec­ possibly including adhesives and ifiers must be aware of the current sealants used in the commercial roof­ and proposed regulation changes, ing industry. especially the phased­in, seasonal Advocates for the roofing industry implementation schedule that many must express their concerns to the states have already incorporated. This legislatures and rulemaking bodies to is an important industry issue that

Wachenske ­ 250 Proceedings of the RCI 25th International Convention