Document pmwvDGkGqmgDLdGKR1bV5ovVD

National May 34, 1994 TO i THOM: HE i Air Quality Committee Architectural Coating# Committee Induatrial Coatings committee Labeling and Product Safety Committee Manufacturing Management Committee Hater Quality/Haste Management committee soonie MeDavid, Assistant Director Environmental Affairs DRAFT Green seal Standard on Anti-corrosive Faints Enclosed is a draft Green seal Environmental Criteria for Anti corrosive Paints dated May 30, 1994. Green Seal is seeking comments to this proposed standard vhich will toe used in a product certification program. Please revise and return your oosmentr to me by dene 10, 1994. Green Seal was founded in 1990 by Earth Day founder Dennis Says# to help identify environmentally preferable products in an effort to 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. MPCA commented on Green Seal's Environmental standard for Faints (primarily focused on architectural coatings), which was focused on a life-cycle analysis approach, in 1992. 1300 Rhode Island Avenue. NW Washington. DC 2000S-SS97 202/462-6272 FAX 202/462-8549 SL 107318 0 May 20,1994 Ms. Soony McDavid Director Environmental Affair* NPCA 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 anticorrosive paints. Green Seal's existing standard for paint, GS-11, covers primarily architectural coatings. A separate standard for anti-corrosive paints allows Green Scal to establish environmental requirements more appropriate far this category and to develop performance criteria to evaluate die rust inhibiting properties of products. - While the proposed standard Is still in draft form. Green Seal is soUdting 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 indude in tills standard. Enclosed is an outline of proposed criteria for evaluating antt-corroaive 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, Project Manager Mila* ceixMHiwtMitn MMfSnWionMm * MmMina WlKMllMW. SL 107319 May 20, 1994 GC-03 GREEN SEAL environmental CRITERIA FOR ANTI-CORROSIVE PAINTS >, May 20, 1994 COPYRIGHT O 1994 GREEN SEAL, INC. ALL RIGHTS RESERVED. Qm amtw IWIUI U--r----W Or-- 4l* <!*> m iwrtMilw SIj GREEN SEAL Green Seel is a non-profit organization devoted to environmental standard setting, product certification, 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, Qreen Seal* identifies products that are designed and manufactured in an oivironmeatally preferable manner, w offers scientific analysis to help consumers make educated purchasing decisions regarding environmental impacts; ensures consumers that any product bearing the Green Seal Oerdficadon 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 intern 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-caregory basis, Environmental Standards focus on opportunities to significantly reduce a product's environmental impact Each Green Seal Environmental Stended it 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 ait then established after careful 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 producufor 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 Certification 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 SL 10732 My 10. it* Draft Eiitraaw<Hitl Criteria , TABLE OF CONTENTS % * Summary of Comment! Requested ..... ~.................................. 4 Draft Environmental Criteria 1 Scope .................................................. ,....5 2 Definitions ..................................................................................... 3 3 Product-Specific PerformanceRequirements......... ....................... 5 4 Product-Specific EnvironmentalRequirements.............................. 5 p 5 Packaging Requirements ....................................... 7 Appendix > f Labeling Requirements................................................................... 8 SL 107322 M*v M, 1W Ofmfi CrilwU SUMMARY OF COMMENTS REQUESTED When reviewing the standard please pay particulc attention id the following areas: 4 Peifonnance Requirements His Green Seal chosen appropriate testing protocols for adhesion and hiding power? When developing the standard, it came oo 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 s paint's rust inhibiting properties. The corroeion/weathering teat also reportedly produces more consistent results on a product by product basis. What would be the advantages and disadvantages ofGreen Seal using the conDfiion/weathering test currently under development tnxtead of the salt fog test? ;. * What would constitute acceptable peifonnance by a product when using the test protocols ofthesaltfog test7 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 and-corrosive paints? Are there any differences in the use and concentrations of heavy meals 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? SL 107323 Mav 10. 194 Prmfl gBlrwwwt> CrlMrts 5 environmental standard X Scope. This Standard establishes environmental requirements for anti-oonodve paints. 2 Definitions. Far the purpose of this Standard, the following definitions apply. 2.1 Paints; Liquid, liquefiable or mastic composition that Is converted to a solid proteem . or functional adherent film after application as a thin layer. These coatings are intended for application to metal surfaces to provide protection from lusting. 2.2 Volatile Organic Compounds (VOCs): Compounds is defined by U. S. Environmental Protection Agency (EPA) in 40 CFR i 31.100 (g). (s) (1). 2.3 Aromatic Compounds: Hydrocarbon compounds containing one or more 6-carbon benzene tings 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 Methodsfor Measuring Adhesion by Tape Test. 3.2 CorrostonAVeathering (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 (Opaidty). The product shall demonstrate a minimum 0.93 contrast rati at 400 square feet per gallon as determined by ASTM D2805-88, Standard Test Methodfor Hiding Power of Paints by Rqlectomtry, 4 Product-Specific Environmental Requirements. 4.1Chemical Component Limitations. 4.1.1 VOCs. The VOC concentrations of the product shall not exceed those USted below as determined by U. S. Environmental Protaction Agency (EPA) Reference Test Method 24 (Determination of Volatile Matter Content, Water Content, Density Volume Solids, and Weight Solids of Surface Coadngs), 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. SL 107324 MiT-y^jgy. _pfft lavlwMfwm Crtwrta Costing Dsc YQC aright in mms/tog ofvajna mni ww Gloss Setm-Glo*! Satin and Flat 250 225 200 4.1.2 Aromatic Compounds. Hie product must contain no more than 1.0% by weight of the aom total of aromatic compounds. Testing far the concentration of these compounds will be performed if they are determined to be preaentin the product during a material* audit 4.2 Chemical Component Restrictions. The manufacturer shall demonstrate that the following chemical compounds are not used v ingredients in the manufacture of the final product 4.2.1 Halomethanea methylene chloride 4.2.2 Chlorinated ethanes _ 1,1,1'trichloroethane --- 4.2.3 Aromatic solvents benzene toluene (methylbenzene) ethylbenzene 4.2.4 Chlorinated ethylenes vinyl chloride 4.2.5 Polynuclear aromatics naphthalene 4.2.5 Chlorobenzenes 1 ^dichlorobenaene 4.2.7 Phthalate esters di (2-ethylhexyl) phthalate butyl benzyl phthalate di-n-butyl phthalate di-n-octyl phthalate SL 107325 ' f*T 10. 1W_________ diethyl phthalate dimethyl phthalate Prft KwTlr--miml CtUtU 7 4.2.8 Miicellaneoiu aemi-volatile organics Isophorone 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. SL 107326 Mn at. 1W------------------------PmttJInvIrwimom _______________ Aawnrflc ljh#lln Rn..lrmntl for Ortlflr.Hnn h fl--n fil Unless tberwlae approved in writing by. Green Seal, the following libeling requirement* *h*U ipply: 1 The Green Seal Certficarion Marie mutt ippeir on the packaging. 2 Whenever the certification mark appears on a par.kage orproduct, the product or must Contain a description of the basis for the certification. The description shaU be m a location, style, and typcfiice that are easily icadabla by the consumer. The description shah read is follows: This product has reduced volatile organic compound (YOC) levels: does not contain specified toxic chemicals. 3 Paints which have been formulated without VOCs shall be designated Class A and may contain a special designation to that effect on the label Si* June 22, 1994 DRAFT RECOMMENDED INHALATION TESTING HAZARDOUS AIR POLLUTANTS TO BE CONSIDERED FOR TSCA SECTION 4 TEST RULE PROCESS (1ST RULE) Biphenyl Acute/Subchronic Systemic Acute/Subchronic Respiratory Acute/Subchronic Neurotoxicity l species Developmental Toxicity 2-Generation Reproductive Test Carbonvl Sulfide Acute/Subchronic Systemic Acute/Subchronic Respiratory Acute/Subchronic Neurotoxicity 2 species Developmental Toxicity 2-Generation Reproductive Test Cancer test (2 species in both sexes) Ames, In vitro gene mutation mammalian test, bone marrow cytogenetics SMarine Acute Systemic (in both sexes) Acute Respiratory (in both sexes) Chlorobenzene Acute/Subchronic Systemic Acute/Subchronic Respiratory Acute/Subchronic Neurotoxicity Chioroprene Acute Systemic Acute Respiratory Acute/Subchronic Neurotoxicity 1 species Developmental Toxicity 2-Generation Reproductive Test erssols(mixture or isomers) Acute/Subchronic Systemic Acute/Subchronic Respiratory Acute Neurotoxicity SL 107328 Cumene Acute Systemic Acute Respiratory Acute Neurotoxicity 2-Generation Reproductive Test Dlbutvl Phthalata Acute/Subchronic Systemic Acute/Subchronic Respiratory Acute/Subchronic Neurotoxicity 2 species Developmental Toxicity Diethanolamine Acute/Subchronic Systemic Acute/Subchronic Respiratory Acute/Subchronic Neurotoxicity 2 species Developmental Toxicity 2-Generation Reproductive Test Ethylbenzene Acute Systemic Acute Respiratory Acute/Subchronic Neurotoxicity l species Developmental Toxicity 2-Generation Reproductive Test Ethvl Chloride Acute/Subchronic Neurotoxicity 1 species Developmental Toxicity 2-Generation Reproductive Test Ethylene Plchlorlde Acute/Subchronic Systemic Acute/subchronic Respiratory Acute/Subchronic Neurotoxicity 1 species Developmental Toxicity 2-Generation Reproductive Test Ethylene Glvcol Acute/Subchronic Systemic Acute/Subchronic Respiratory Acute/subchronic Neurotoxicity lO^2 Hydrochloric Acid Acute Respiratory Hvdrooen Fluoride Acute/Subchronic Systemic Acute/Subchronic Respiratory Acute/Subchronic Neurotoxicity 2 species Developmental Toxicity 2-Generation Reproductive Test Maleic Anhydride Acute Systemic Acute Respiratory Acute/Subchronic Neurotoxicity 1 species Developmental Toxicity Cancer Test (2 species in both sexes) Methyl Isobutvl Ketone Acute Systemic Acute Respiratory 2-Generation Reproductive Test Mathvl Methacrylate Acute Systemic Acute Respiratory Acute/Subchronic Neurotoxicity 2-Generation Reproductive Test Naphthalene Acute Systemic Acute Respiratory Acute/Subchronic Neurotoxicity 2-Generation Reproductive Test Acute Systemic Acute Respiratory Fhthallc Anhydride Acute/Subchronic Systemic Acute/Subchronic Respiratory Acute/Subchronic Neurotoxicity 2 species Developmental Toxicity 2-Generation Reproductive Test Cancer Test(2 species in both sexes) 1.2.4 Trichlorobenzene Acute Systemic Acute Respiratory Acute/Subchronic Neurotoxicity 2 species Developmental Toxicity 1.1.2 Trichloroethane Acute/Subchronic Systemic Acute/Subchronic Respiratory Acute/Subchronic Neurotoxicity 2 species Developmental Toxicity 2-Generation Reproductive Test Cancer Test(modified, i.e. Huff Approach) Bone marrow cytogenetics Vinvl Acetate Acute Respiratory l species Developmental Toxicity Vinvlidene chloride Acute Systemic Acute Respiratory Acute/Subchronic Neurotoxicity *T SL 107331 TOXICITY TESTING OF HAZARDOUS AIR POLLUTANTS On June 22, 1994, EPA held a briefing to provide industry with background information on the Hazardous Air Pollutant (HAP) Test Rule that will be proposed this Fall. EPA also distributed a list of the HAPs and the testing that will be proposed for each of the chemicals. Briefings have already been held with the environmental groups and other interested parties. In order to make multi-chemical risk assessment/risk management decisions, the Office of Air Quality Planning and Standards has requested that 3 TSCA section 4 Test Rules be promulgated for HAPs that are missing inhalation data. The data generated by the test rules would provide EPA with a consistent/even data base and allow them to do residual risk analyses on mixtures. EPA's intent is that this test rule respond to the CAA concern for both cancer and non-cancer health effects and that a dose-response via the inhalation route be established. EPA stated that if the database for a chemical was rich in oral data, they might agree that focused pharmacokinetic will provide enough data for route-to-route extrapolation. In that case, EPA would also require subchronic inhalation studies to evaluate entry portal sensitivity and damage. Only drinking water or feeding studies will be considered when oral data is evaluated. EPA is seeking industry comment in several areas: There will be a problem testing low vapor pressure chemicals, EPA feels that conducting aerosol testing may mimic human exposure and is seeking comment. - Even though EPA wants all testing by the inhalation route, it is seeking industry input on the most appropriate routes of exposure. EPA is also soliciting feedback on what testing will give the best information to make risk assessments. - EPA realized that there may not be an adequate number of inhalation chambers available and is looking for ways to "piggyback" tests. Test standards will be proposed with the test rule and EPA will be seeking comment on the appropriateness of the methods. EPA is trying to generate good histopathological data on the respiratory system. The proposed rule will require all testing via the inhalation route. The rat will be the species of choice unless otherwise noted. EPA expects the proposed test rule to be published in the early or late Fall of 1994. (over) SL 107332 SELECTION OF CANDIDATE HAPs FOR TEST RULES EPA baa identified 189 chemicals as hazardous air pollutants. When deciding on the HAP test rule, this group was divided into those with TRI emissions of 50 tons/year or greater and those with TRI emissions of less than 50 tons/year or no TRI data. EPA determined that there are 66 HAPs in the 1st category. When the existing data was assessed, 16 HAPs had adequate data or were currently undergoing testing. Of the 50 remaining chemicals, 25 were proposed for the 1st test rule. For the 2nd test rule, EPA is evaluating the remaining 25 chemicals and 10 chemicals that have potential concern under the Great Waters and Urban Toxics provisions of the Clean Air Act. Industry has not been apprised which HAPs are being evaluated for this rule. The remaining 113 chemicals with TRI emissions of less than 50 tons/year will be evaluated for the 3rd test rule. EPA has stated that some HAPs will immediately be dropped from consideration, i.e. dioxin and asbestos. TENTATIVE HAPs TEST RULE SCHEDULE o 1994 o 1995 o 1996 o 1997 1st test rule proposed (25 HAPs) 1st test rule promulgated 2nd test rule proposed (approx. 25 HAPs) 2nd test rule promulgated 3rd test rule proposed (approx. 25 HAPs) 3rd test rule promulgated Sh 107333 July 5, 1994 Explanation of Vinyl Chloride Research Coordinator Budget An initial budget of $300,000 is proposed for the following activities: Contractor cost for the update of vinyl chloride epidemiology study Dow Chemical's expenses for designing, monitoring, consulting with the selected contractor, and reviewing interim, draft and final reports for the epidemiological update Consultant expenses for vinyl chloride risk assessment and short-term exposure effects studies Administrative expenses for update of the epidemiology study; follow-ups with EPA on VC risk assessment; follow-ups with EPA on VC and/or EDC testing under TSCA Section 4; follow-ups with consultants on VC risk assessment and short-term exposure effects studies; meeting planning, attendance, and other routine services; follow-up of action items resulting from meetings and conference calls; and, monitoring of regulatory activities impacting vinyl chloride manufacturing companies The VCRC has proposed to share the estimated $300,000 budget based upon the 1993 VC nameplate capacity. CMA has used the nameplate capacities for VC published in the attached chart from Chemical Data Inc., September 1993, to determine each company's pro-rata share as follows: Total 1993 VC Nameplate Capacity Westlake 1993 VC Nameplate Capacity Total 1993 VC Nameplate Capacity Used in Determining VCRC Member Companies Pro-Rata Share 12,918 M lbs. 1,000 M lbs. 11,918 M lbs. COMPANY NAMEPLATE CAPACITY (Million Lbs.) PRO-RATA SHARE Borden Chemical Dow Chemical Formosa Plastics GEON Georgia Gulf Occidental (w/OxyMar) PPG Industries Vista Chemical 935 2,210 1,793 1,400 1,260 2,600 840 880 23,536 55,630 45,133 35,241 31,717 65,447 21,145 22.151 TOTAL 11,918 300,000 If the above budget is committed by all companies , one-half of the commitment will be due in August, 1994 and the remainder in January, 1995. If Westlake joins the VCRC at a later date, your 1995 amount due will be adjusted accordingly. SL 107334 9 |0 >;ui*(po.r?ft4 fifipuouj PRODUCER Borden Chemical LOCATION Geismar, LA Gebmar, LA fiEPSTOCKS Ethylene Acetylene Dow Chemical Oyster Creek, TX Oyster Creek, IX Ptaquemine, LA Ethylene Ethylene Ethylene Formosa Plastics Point Comfort TX Baton Rouge, LA Baton Rouge, LA Ethylene Ethylene EDC Geon Calvert City, KY (formally Goodrich La Porte, TX Ethylene Ethylene Georgia Giif Ptaquemine. LA Ethylene Occidental Chem Deer Park, TX Ethylene OxyMar Corpus ChdstL TX Ethylene PPGInd. Lake Charles, LA Ethylene SheM Deer Park, TX Ethylene Vista Chemical Lake Charles, LA Ethylene Westake Monomers Calvert Cty, KY Ethylene US. VINYL CHLORIDE MONOMER AVERAGE DESIGN CAPACITY (MWons erf Pounds Per Year) im isaz 525 625 325 325 1988 im 525 568 325 325 1990 mi 1222 61Q 6t0 610 325 325 325 im 1281 610 610 325 325 1996 610 325 im 610 325 1997 eto 325 750 -- 810 -- 810 833 - 900 - 900 - 900 - 910 - 910 563 910 750 910 750 910 750 850 900 1,040 1,200 1,200 1,275 1,300 1,300 1,300 1.300 1,300 1,300 580 580 580 690 838 900 900 900 900 900 900 900 420 420 420 420 420 420 315 53 420 420 420 420 -- -- -- -- -- 537 840 840 840 840 840 1,000 1,000 1,000 1.000 -- - See VI restate Monomers -- _____ 1,100 1,100 1.250 1,300 1,300 1,400 1,400 1.400 1,400 1.400 1,400 1,400 1,025 1,100 1.220 1,260 1.260 1.260 1,260 1,280 1,260 1.260 1,260 1,280 - 450 925 1,100 1,100 1,100 1,100 1.100 1,100 1,100 1.100 1.100 - ~ - - - 1,467 1,500 1.500 1,500 1,500 1.500 1,500 600 750 800 800 840 840 840 840 840 840 840 840 900 450 id 700 738 750 825 825 825 835 880 910 970 990 990 -- -- __ 1.QQQ 1.000 IDOO 1.000 1.000 1.000 1050 1050 Total 0,775 9.148 9,645 10,320 10,618 12,322 12,822 12,918 13,878 14,125 14.196 14.196 s p fip g g 107335 SEPTEMBER 1990 QmA. \/c .IX % 'j 1 "fX f ^/,/^s ^<sr SL 107336