First Name | Mark |
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Last Name | Collatz |
Email Address | mark.collatz@ascouncil.org |
Affiliation | Adhesive and Sealant Council |
Subject | RE: Air Resources Board’s Third Staff Proposal for Regulation Changes to the Consumer Pro |
Comment | 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 |
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Date and Time Comment Was Submitted | 2006-10-12 06:44:35 |
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