Document 7OmGYBQ3zQ2mE0MBbrB5xVzQR

May 24, 1994 National Fttint& Coatings Association TO: from: RE; Air Quality Committee Architectural Coatings Committee Industrial coatings Committee Labeling and product safety Committee Manufacturing Management Committee water Quality/Waste Management committee soonie MeDavid, Assistant Director Environmental Affairs DRAFT Green Seal Standard on Anti-Corrosive .Paints Enclosed is a DRAFT Green Seal Environmental Criteria for Anti corrosive Paints dated May 20, 1994. Green Seal is seeXing comments to this proposed standard which will be used in a product certification program. Please review and return your comments-1 me by dune 10/ 1994. Green Seal was founded in 1990 by Earth Day founder Dennis Hayes to help identify environmentally preferable products in an effort t encourage consumers to purchase products with reduced environmental impacts/burdens. Green Seal hopes to encourage manufacturers to develop products which are significantly less damaging to the environment than their predecessors. NFCA commented on Green seal's Environmental standard for Paints (primarily focused on architectural coatings), which was focused on a life-cycle analysis approach, in 1992. 1500 Rhode Island Avenue. NW Washington, DC 20005-5597 202/462-6272 FAX 202/462-8549 CMA 118054 0 May 20,1994 Ms. Soony McDavid Director Environmental Affairs NFCA 1500 Rhode Island Avenue, NW Washington, DC 20005 Dear Ms. McDavid: Green Seal is now accepting comments on proposed environmental criteria we are developing for anti-corrosive paints. Green Seal's existing standard for paint, GS-11, covers primarily architectural coatings. A separate standard for anti-corrosive paints allows Green Seal to establish environmental requirements more appropriate for this category and to develop performance criteria to evaluate the rust inhibiting properties of products. -- While the proposed standard is still in draft form, Green Seal is soliciting comment on the appropriateness of the criteria we have chosen for evaluating environmentally preferable anti-corrosive paints- We also would appreciate suggestions regarding other performance or environmental requirements you believe Green Seal should include in this standard. Enclosed Is an outline of proposed criteria for evaluating anti-corrosive paints. In lieu of, or in addition to written comments, I hope to discuss with you directly any comments you have about the proposed Standards. Thank you in advance for your time. I will call you next week to discuss the proposed environmental criteria with you. Or feel free to contact me at Green Seal at 202-331-7337. Sincerely, Amy Li Hitchcock Project Manager mntM K JWMVI ta(|U1| 1917113 CMA 118055 May 10, 1994 GC*03 GREEN SEAL ENVIRONMENTAL CRITERIA FOR ANTI-CORROSIVE PAINTS May 20, 1994 COPYRIGHT O 1994 GREEN SEAL INC. ALL RIGHTS RESERVED. Oram Smit CnvtrawnmUl 8lindir4* ara a,yrighlad M pntacl Cram 1U*I' yatUcatlm ripMa, lvo to nulrw Bwlr am I* product dMifn ar (raloaUm. CMA 118056 GREEN SEAL Green Seal i$ a non-profit organization devoted to environmental standard setting, product certificanon, and public education. Green Seal helps identify environmentally preferable products in order to encourage and enable consumers to purchase such products with reduced impacts on the earth. Through Us standard setting, certification and education programs, Green Seal: identifies products that are designed and manufactured in an environmentally preferable manner, offers scientific analysis to help consumers make educated purchasing decisions regarding environmental impacts; ensures consumers that any product bearing the Green Seal Certification Mark has earned the right to use it; and encourages manufacturers to develop new products that are significantly less damaging to The environment than their predecessors. THE ENVIRONMENTAL STANDARDS The intent of Green Seal's standards is to reduce, to the extent technologically and economically feasible, the environmental impacts associated with the manufacture, use, and disposal of .. products. Set on a category-by-category basis, Environmental Standards focus on opportunities to significantly reduce a product's environmental impact Each Green Seal Environmental Standard is first issued in proposed form. Industry, trade associations, government agencies, environmental and other public interest organizations, users, and other interested parties are encouraged to comment on the proposal. Standards are then established aftercareful review and consideration of the comments. Green Seal offers the opportunity to achieve certification to all products covered by its standards. Manufacturers may submit their products for evaluation by Green Seal. Those which comply with Green Seal's requirements may be authorized to use the Green Seal Certification Mark on products and in product advertising. Manufacturers authorized to use the Green Seal Cenification Mark on their product are subject to an ongoing program of testing, inspection, and enforcement. Underwriters Laboratories Inc., the nation's premier product testing and inspection organization, serves as Green Seal's primary testing and factory inspection contractor. For additional information on Green Seal or any of its programs, contact; Green Seal 1250 23rd Street, NW, Suite 275 Washington, DC 20037-1101 (202) 331-7337 CMA 118057 MV 10. 1W< t>fft Eny|roiifnBm CrlUrla , TABLE OF CONTENTS ___________ j * Summary of Comments Requested .............................................4 Draft Environmental Criteria 1 Scope .................................................. 5 2 Definitions ..................................................................................... 3 3 Product-Specific Performance Requirements............................. ,5 4 .4 5 Product-Specific Environmental Requirements............................ 5 * Packaging Requirements ....................................... 7 Appendix Labeling Requirements.......................................... ........................8 CMA118058 May 10, 1W Pratt gnvltwmimrtal Criurla SUMMARY OF COMMENTS REQUESTED 4 When reviewing the standard please pay particular attention to the following areas: Performance Requirements Has Green Seal chosen appropriate testing protocols for adhesion and hiding power? When developing the standard, it came to our attention that a test protocol for corrosion/weathering is currently under development by ASTM subcommittee 27. This test reportedly imitates real world corrosion characteristics better than the traditional salt fog test for measuring a paint's rust inhibiting properties. The corrosion/weathering test also reportedly produces more consistent results on a product by product basis. What would be the advantages and disadvantages of Green Seal using the coiTOsion/weaxhering test currently under development instead of the salt fog test? . What would constitute acceptable performance by a product when using the test protocols of the salt fog test? Should other performance requirements be specified? Environmental Requirements Has Green Seal chosen appropriate VOC limits to recognize environmentally preferable anti-corrosive paints? If not, what levels should be specified? How widespread is the use of heavy metals In anti-corrosive palms? Are there any differences in the use and concentrations of heavy metals in Industrial anti-corrosive paints versus consumer anti-corrosive paints? Are the chemical component restrictions appropriate? Should additional compounds be added or should any listed components be deleted? CMA 118059 M'y 20, 1994 Drift Ei>)r<wim)ul CrlfrU 5 ENVIRONMENTAL STANDARD 1 Scope. This Standard establishes environmental requirements for anti-corrosive paints. 2 Definitions. 4 Far the purpose of this Standard, the following definitions apply. 2.1 Paints: Liquid, liquefiable or mastic composition that is converted to a solid protects . or functional adherent film after application as a thin layer. These coatings are intended for application to metal surfaces to provide protection from rusting. 2.2 Volatile Organic Compounds (VOCs): Compounds as defined by U. S. Environmental Protection Agency (EPA) in 40 CFR $ 51.100 (s), (s) Cl). 2.3 Aromatic Compounds: Hydrocarbon compounds containing one or more 6-carbon benzene rings in the molecular structure. 3 Product-Specific Performance Requirements. 3.1 Adhesion. The product shall demonstrate a minimum of Classification 4B according to ASTM D3359-90 Method B, Standard Test Methods for Measuring Adhesion by Tape Test. 3.2 Corrosion/Weathering (Prohesion QUV) Test, (protocols to be determined.) OR Salt Spray (fog) Testing according to ASTM designation B117-90. (parameters to be determined) 3.3 Hiding Power (Opacity). The product shall demonstrate a minimum 0.93 contrast ratio at 400 square feet per gallon as determined by ASTM D2805-88, Standard Test Methodfor Hiding Power of Paints by Refitdometry. 4 Product-Specific Environmental Requirements. 4.1Chemical Component Limitations. 4.1.1 VOCs. The VOC concentrations of the product shall not exceed those listed below as determined by U. S. Environmental Protection Agency (EPA) Reference Test Method 24 (Determination of Volatile Matter Content, Water Content, Density Volume Solids, and Weight Solids of Surface Coatings), Code of Federal Regulations Title 40, Part 60, Appendix A. The calculation of VOCs shall exclude water and tinting color added at the point of sale. CMA118060 1. 1W4 Dff IH^IWUWWUI Iffl-Hl < COtitoglTOS VQC weight in orams/Kter of product minus water Clots Semi-Gloss 250 225 Satin and Flat 200 . 4.1.2 Aromatic Compounds. The product must contain no more than 1.0% by weight of the sum total of aromatic compounds. Testing for the concentration of these compounds will be performed if they are determined to be present in the product during a materials audit 4.2 Chemical Component Restrictions. The manufacturer shall demonstrate that the following chemical compounds are not used as ingredients in the manufacture of the final product 4.2.1 Halomethgnes methylene chloride 4.2.2 Chlorinated ethanes 1,1,1-trichloroethane ,, 4.2.3 Aromatic solvents benzene toluene (methylbenzene) ethylbenzene 4.2.4 Chlorinated ethylcnes vinyl chloride 4.2.5 Polynuclear aromatics naphthalene 4.2.5 Chlorobenzenes l ,2-dichlorobenzene 4,2.7 Phthalate esters di (2-cthylhexyl) phthalate butyl benzyl phthalate di-n-butyl phthalate di-n-octyl phthalate CMA118061 fftV 10, W4 diethyl phthalate dimethyl phthalate Draft &w*lnmtnm CrlurU 7 4.2.8 Miscellaneous semi-volatile organics isophoronc 472.9 Metals and their compounds antimony cadmium hcxavalent chromium lead mercury 4.2.10 Preservatives (antifouling agents) formaldehyde 4.2.11 Ketones methyl ethyl ketone methyl isobutyl ketone 4.2.12 Miscellaneous volatile organics acrolein acrylonitrile 5 Packaging Requirements. 5.1Toxics in Packaging. 5.1.1 The manufacturer shall demonstrate that paint cans and their components are not fabricated with lead. CMA 118062 mt 79, 19*1Dug gnvlrnmui ____________________ Annendbr: Labglfny Requirement* far Cgrtlflcartnn hv flrwn EU > Unless otherwise approved in writing by Green Seal, the following labeling requirements shall apply: 1 The Green Seal Certification Marie must appear on the packaging. 2 Whenever the certification mark appears on a package orproduct, the product or package must tontain a description of the basis for the certification. The description shall be in a location style, and typeface that are easily readable by the consumer. The description shall read as follows: This product has reduced volatile organic compound (VOC) levels: does not contain specified toxic chemicals. 3 Paints which have been formulated without YOCs shall be designated Class A and may contain a special designation to that effect on the label. > CMA118063