Comment Log Display

David Mallory
Manager, Stationary Source Division 
Air Resources Board
California Environmental Protection Agency
1000 I Street
Sacramento California 95812

Judy Yee
Manager, Stationary Source Division 
Air Resources Board
California Environmental Protection Agency
1000 I Street
Sacramento California 95812

RE:  Air Resources Board’s Third Staff Proposal for Regulation
Changes to the Consumer Products Regulation at the November 16
Board Hearing

Dear Mr. Mallory and Ms. Yee:

The Adhesive and Sealant Council, Inc. (ASC) is a North American
based trade association representing 120 manufacturers of
adhesives and sealants and suppliers of raw materials to the
industry.

As you are aware ASC and its members have been working with you
and others on the Air Resources Board (ARB) staff for several
months to revise the volatile organic content limit for the
category of construction, panel and floor covering adhesives in
the California consumer products regulation.  After reviewing the
ARB’s third staff proposal issued on August 25, it is the
agreement of ASC’s manufacturing members that a limit of 7 percent
for this category is technologically achievable.

It should be noted that within the industry concerns remain with
regard to subfloor adhesives at this reduced level being used to
bond some of the new technological materials that either exhibit
low surface energy or building materials that have been chemically
treated to resist mold or pest infestation.  As in the past
adhesive manufacturers will continue working in the area of
research and development to meet the challenges this new lower
limit will present for these particular types of applications.

In addition, manufacturers recognize ARB’s interest in eliminating
the three chlorinated compounds: methylene chloride,
perchloroethylene and trichloroethylene from this product
category.  Allowing for the continued use of these compounds in
the manufacturing process 

Page 2
October 12, 2006

through December 2008 with a sell-through provision of December
2011 that permits a
systematic inventory reduction seems to be a reasonable approach
to the eventual elimination of the compounds from this product
category.

As always, it has been my pleasure to work with you and your staff
in developing a reasonable new limit for this category and I look
forward to continuing this effort as we begin to address the caulk
and sealant category later this year.

	                     Best regards,

				
		             Mark Collatz
			     Director of Government Relations
                             Adhesive and Sealant, Council, Inc.


cc:  Janette Brooks, California ARB, Air Quality Measures Branch
Chief