Proposed Revisions for Green Seal Standards GS-11 and GS-47 3/31/15

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1 PROPOSED REVISIONS TO GREEN SEAL STANDARDS FOR PAINTS AND COATINGS, GS-11, AND STAINS AND FINISHES, GS-47 Scope Expansion: Transparent Wall Coatings, Floor Coatings, Concrete/Masonry Sealers, and Fire Resistant Coatings Criterion Revisions: VOCs, Carcinogens, Prohibited Ingredients, Packaging, Consumer Education, Labels Criterion Removal: Leftover Paint Combination: GS-11 and GS-47 into a Single Standard Green Seal s mission is to advance a green economy by identifying products that provide leadership levels of performance and protection of human health and environment. Our science-based standards must be applicable and appropriate for the products currently available in the market, and our vision can be realized only when a substantial minority of products can meet the requirements in the standards. At this time, Green Seal is proposing an update to the Standard for Paints and Coatings, GS-11, and the Standard for Stains and Finishes, GS-47, to combine the standards, expand the scope to new product categories, and update the VOC criteria. The criteria established in Green Seal standards are intended to identify, for a given product category, the appropriate levels of leadership that currently exist in the market for protection of human health and environment. This proposed update includes the following changes: GS-11 and GS-47 will be combined into a single standard, titled GS-11, Green Seal Standard for Paints, Coatings, Stains, and Sealers. GS-47 will then be withdrawn. Additional product categories will be added to the scope of the standard: transparent wall coatings, floor coatings, concrete/masonry sealers, and fire resistant coatings. Anti-graffiti coatings and products containing nanoparticles will be explicitly excluded from the scope and therefore will not be certifiable under this standard. The limits on Volatile Organic Compounds (VOCs) will be updated to reference California Air Resources Board (CARB) regulations. VOC measurement methods will be harmonized with programs that regulate VOCs by including evaluation of VOCs by formulation data and difference methods (e.g., CARB Method 310), in addition to the GC/MS methods currently specified. The definition of VOCs will be harmonized with VOC regulatory programs, and individual VOCs will be evaluated only for compounds present in the product above 0.01%. The criteria for carcinogens, prohibited ingredients (halogenated solvents), and packaging, will have limited prohibitions and exemptions added for specific ingredients: o prohibition for triclosan o allowance for PCBTF at a limited concentration in metal lacquers o clarification related to crystalline silica o exemption from recovered content for packages that must meet DOT requirements for transport of dangerous goods Clarifications, corrections, and editorial changes will be made Green Seal invites comments on two additional issues: o Proposed deletion of the requirement that leftover paint from the manufacturing process shall be used locally or domestically where there are existing markets (GS-11, Section 4.2) o The possibility of a future exemption for diphenyl ketone (unsubstituted benzophenone) from the prohibition on carcinogens Other than the update of VOC measurement methods and limits, the proposed revisions do not include major changes to the current human health and environmental requirements listed in the current editions 1 / 20

2 of GS-11 and GS-47. However, products currently certified to GS-11 and GS-47 may need to make changes if all proposed revisions are included in the final revised standard. In this document, text quoted from the proposed standard is indented and surrounded by a box for quick identification. In general, deleted text from the current version is presented in strikethrough, and added text is presented in underline. However, it was not possible to present all changes in this fashion. The following documents are available as PDF attachments on our online forum and our website 1 : (1) this rationale document, (2) a comparison of the current and proposed editions, and (3) the proposed standard. Remaining Stages in the Standard Revision Process: Receive comments on proposed revisions from stakeholders Review stakeholder comments Release formal response to comments Issue revised standard 1.0 Merging GS-11 and GS-47 PROPOSED REVISIONS Green Seal currently has two separate standards for coatings: GS-11 for paints & coatings, and GS-47 for stains & finishes. Performance criteria were established separately for each product category, but despite the fact that the standards were developed separately, the other requirements are nearly identical for all product categories. Green Seal has faced a number of situations where it was unclear which standard would be the most appropriate for a specific product. In order to prevent this problem in the future, Green Seal proposes to merge the two standards into a single standard, titled GS-11, Green Seal Standard for Paints, Coatings, Stains, and Sealers. The proposed standard will maintain separate performance requirements for each product category, but will change the classifications of the categories to better accommodate the ones that have been added. In order to clarify the criteria for each product category, all performance requirements will be listed in a single subsection for each product category. Requirements that are common to both GS-11 and GS-47 will be harmonized so they are consistent for all product categories included in the next edition of GS-11, and do not add additional restrictions to what is currently specified in GS-11. These include: requirements for consumer education will be required for all products (Section 4.1) currently not required in GS-47 a minimum of 20% recovered content will be required as one option for packaging currently a minimum of 25% is required in GS-47 source-reduced packaging will be added as an option for packaging (5.1) currently allowed in GS-47 but not in GS-11 bisphenol A and chlorinated compounds will not be prohibited in packaging (5.2) currently prohibited in GS-47 but not in GS-11 all products must now meet requirements for labels (6.1) currently required in GS-11 but not in GS / 20

3 2.0 Scope Expansion Green Seal has received a number of requests for the certification of product categories that are not currently covered under the scopes of GS-11 and GS-47. To accommodate these needs in the coatings market, Green Seal proposes to add the following product categories and performance criteria relevant to each: 2.1 Transparent Wall Coatings In the coatings industry, transparent wall coatings (clear and tinted) are used to provide decoration and protection. At this time, we are proposing to add the following transparent wall coatings to the scope of GS-11, for interior use: Hygienic Wall Coatings Interior-use film-forming products that are used to coat wall tiles and grout in order to create a surface that is easier to clean. Tiles often cover the walls in restrooms, kitchens, and other locations that require hygienic conditions; however, the permeability of the tile and grout can limit cleaning and create potential for bacterial growth. Decorative Wall Coatings Decorative interior wall coating systems are used to provide both protective and decorative functions. They have purposes and formulations similar to those of decorative floor coating products. Impact Resistant Wall Coatings Walls in commercial buildings, public transit areas, and other highuse areas are subject to frequent impacts and abrasions. Impact resistant wall coatings are used to reinforce wall surfaces and help protect from damage. These three product types are typically used in interior settings; therefore, GS-11 will only cover transparent wall coatings that are intended for interior use. The product chemistry, such as acrylic or polyurethane-based resin emulsions, is similar to other transparent finishes that are currently covered under GS-47; therefore, we are proposing to apply the current health and environmental criteria to transparent wall coatings. The proposed VOC limit for transparent wall coatings is that specified by CARB for the category of Low Solids Coatings (currently 120 g/l), or for their labeled use, as appropriate. For decorative wall coatings, as with floor coatings below, we are proposing to remove the existing GS- 11 prohibition for color chips or flakes. With the exception of impact-resistance, the primary performance considerations for transparent wall coatings adhesion, flow and leveling, scrubbability, and washability are covered under the existing GS-11 criteria for interior paint topcoats. Therefore, these criteria are applied to transparent wall coating under the proposed scope expansion. For transparent wall coatings that are marked for impact-resistance, an additional performance test must be conducted to demonstrate that the product has equivalent functional performance to a benchmark national-market leading product in its category. The requirement for Hiding Power (Opacity) will be modified to apply only to those products that are intended to be opaque. 2.1 Wall and Ceiling Coatings for Interior Use. All paints, primers, and transparent coatings intended for interior use shall meet the following performance requirements General Requirements Adhesion. 3 / 20

4 Products intended to be applied on concrete shall demonstrate 200 psi failure in the concrete as determined by ASTM D7234. Products not intended to be applied on concrete shall demonstrate a minimum of 50% or better rating for wet and dry adhesion over the intended substrate as determined by ASTM D Applicability (Flow and Leveling). The product shall demonstrate applicability by either a minimum 6 rating for foaming, leveling, and spatter resistance as determined by ASTM D7073. OR a minimum drawdown as tested by ASTM D Interior Topcoats. Interior topcoats intended as wall coatings shall also meet the following requirements: Scrubbability (Abrasion Resistance). Using a shim, the product shall demonstrate 400 scrub cycles before failure per Leneta Calibration Scrub Panel Form P121-C as determined by ASTM D Washability (Stain Removal). The product shall demonstrate the following minimum requirements for stain removal as determined by ASTM Flat Topcoat Non-Flat Topcoat 5 minimum rating 7 minimum rating Hiding Power (Opacity). Products intended to be opaque shall also demonstrate a minimum 0.95 contrast ratio at 400 square feet per gallon as determined by ASTM D2805 will be determined on dried film of the un-tinted product having a minimum 80% reflectance Impact Resistance. Products that are formulated and marketed to provide impact resistance shall demonstrate impact resistance that is equivalent to or better than that of a benchmark product in its product class when tested according to ASTM D2794 An additional type of transparent wall coating, anti-graffiti wall coatings, will remain outside the scope of GS-11 because of the significant differences in chemistry and performance. Interior and exterior transparent wall coatings that are intended for water resistance are covered separately, under the category of Concrete/Masonry Sealers. 2.2 Floor Coatings The coatings industry makes a clear distinction between floor paints and more durable floor coatings. While floor paints are formulated to withstand light abrasion, such as foot traffic, they are not formulated for long-term durability in high foot-traffic areas, or those that are subject to chemical exposure or vehicle traffic. In comparison to floor paints, floor coatings are commonly formulated with more durable base polymer chemistry, such as epoxy, urethane, or polyaspartic/polyurea resins in a solvent- or water-based emulsion, and typically have a greater dry film thickness. Floor coatings may be single-component products or multi-component systems, and when a greater dry film thickness is required for a specific application, the components(s) may be applied using a squeegee and leveler, rather than a brush or roller. 4 / 20

5 Green Seal is proposing to add floor coatings to the scope of GS-11 as a separate category from floor paints, with application-specific performance criteria. The proposed definitions are as follows: Coating. A material applied onto or impregnated into a substrate for decorating; protecting; identifying; filling or concealing of surface irregularities; modifying light and heat radiation characteristics; or other functional purposes. Floor Coating. Coatings that are intended to be applied to interior flooring surfaces for long-term durability in high foot-traffic areas, or those that are subject to chemical exposure or vehicle traffic. 2 For the purposes of this standard, floor coatings do not include finishes intended for wood floors, or floor-care products designed to be periodically removed and reapplied. Floor Paint. Paints intended for floors and are applied by roller or brush. For the purposes of this standard, floor paints do not include epoxy or urethane flooring systems, or those that include coarse aggregates, color chips, or flakes as part of a multi-part flooring system. Under the proposal, the existing performance criteria for floor paints will be maintained. Floor coatings will have to demonstrate performance for the following parameters, with test methods and thresholds appropriate for the product type: adhesion, abrasion resistance, slip resistance, and water resistance. 2.4 Floor Coatings For testing purposes, the product dry film thickness and curing duration shall be consistent with the manufacturer-recommended application Adhesion. The product shall demonstrate dry pull-off adhesion of at least 400 psi as determined by ASTM D Abrasion Resistance. Using a CS-17 wheel, 1000 gram weight, and 1000 cycles, the product shall have a weight loss of 100 mg or less as determined by ASTM D Slip Resistance. The product shall have a dry static coefficient of friction of at least 0.5 as measured by either ASTM D2047 or UL Water and Salt Water Resistance. The product shall show no signs of lifting, wrinkling, disintegration, or color change after 7 days of exposure to water when tested according to ASTM D1308. Products that will be subject to vehicular traffic shall also show no signs of lifting, wrinkling, disintegration, or color change after 7 days of exposure to a 15% sodium chloride solution when tested according to ASTM D Chemical Resistance. The product shall demonstrate chemical resistance that is equivalent to or better than that of a benchmark product in its product class for the majority of tested chemicals. Testing shall be conducted according to ASTM D1308 with a 16 hour exposure period. Testing shall include a minimum of 7 representative chemicals covering at least 3 of the following classes: detergents, acids, alkalis, alcohols, and aliphatic solvents. The selection of test chemicals shall be based on the marketed uses of the product Hot Tire Resistance. Products that will be subject to tire traffic shall demonstrate hot tire resistance with no loss of adhesion at a temperature of 140 o F and a force that is representative of the product s marketed use.. Testing shall be conducted using an objective, scientifically-validated method conducted under controlled and reproducible 2 e.g., concrete, masonry, tile, and terrazzo, typically found on surfaces such as hallways, lobbies, stores, garages, or steps. Floor coatings may be opaque, transparent, or clear. 5 / 20

6 laboratory conditions. Test methodology and results shall be documented in sufficient detail and provided to the certification program. 3 Our proposal also includes an update for the requirement for comparative testing that is available as an option for all functional performance parameters in GS-11. We are proposing comparative testing for the chemical resistance parameter because of the wide variety of applications for this product category. For example, the chemical resistance of a floor coating intended for light commercial use would be compared to another product with the same application. Finally, floor coatings that would be used in areas with vehicle traffic would be required to demonstrate resistance to salt water and to hot tire pick-up. (to replace current Section 2.9 in GS-11) 2.17 Alternative Performance Requirements. Alternatively, the product shall demonstrate that it performs as well as or better than a benchmark product in its product class, for the key parameters required for it to fulfill the intended function(s), as defined in the previous subsections in Section 2.0. This comparison shall be conducted using an objective, scientifically-validated method conducted under controlled and reproducible laboratory conditions. Test methodology and results shall be documented in sufficient detail and provided to the certification program. Green Seal is proposing the following definitions for parameters evaluated in the comparison testing: Benchmark Product. A product used for comparison in performance testing; for the purposes of this standard this is considered a national market-leading product, typically selected from the top three or four selling brands or companies for its product class from nation-wide data. 4 Product Class. Products that are formulated and labeled to perform similar performance functions on similar substrates. Coatings within the same class are intended for equivalent function and performance, e.g., similar levels of durability and similar dry film thicknesses. A survey of the current market of floor coatings shows that a sufficient number of leadership products meet the current health and environmental criteria in GS-11, while providing the functionality necessary for residential, commercial, and institutional use, and for a variety of industrial applications as well. Therefore, environmentally-preferable floor coatings can be required to meet these criteria, and we are proposing to apply the current criteria to this product category. The current criteria restrict use of the following commonly used chemicals in floor coatings: Methyl methacrylate (MMA) Hazardous Air Pollutant Methylene diphenyl diisocyanate (MDI) Carcinogen and Hazardous Air Pollutant Phthalates Prohibited Ingredient Bisphenol A Prohibited Ingredients Crystalline Silica Prohibited Ingredient 3 Test methodology should typically include use of a tire material sample. Tire pressure should be representative of the intended application for the floor coating (e.g., 50 to 150 psi) based on typical loads. 4 It is recommended that manufacturers discuss their product testing with Green Seal before the testing is performed to ensure that the choice of comparison product(s) is appropriate. 6 / 20

7 Our proposal will require floor coatings to meet the VOC limits specified by CARB for floor coatings, currently 100 g/l. While the CARB floor coating definition is limited to opaque coatings, it is appropriate to extend this limit to leadership-level clear and transparent floor coatings as well. 2.3 Concrete/Masonry Sealers (New Section 2.10) We are proposing to add to the scope of GS-11 products that are intended to seal concrete, masonry, stone, and similar interior and exterior surfaces. There are a wide variety of products within the category of concrete/masonry sealers, with variations in chemistry and intended function. Concrete/masonry sealers can be clear, transparent, or opaque; penetrating or film-forming; transmissive or prohibitive to water vapor; intended for interior or exterior surfaces; and can perform a variety of sealing functions. Product chemistry varies from acrylic film-forming products, via penetrating siloxane-based emulsions, to other resin-based products. The primary function of these products is typically to provide resistance to water, stains, abrasion, fungi, and additional chemicals, with less of an emphasis on long-term durability. CARB provides this definition of Concrete/Masonry Sealers: A clear or opaque coating that is labeled and formulated primarily for application to concrete and masonry surfaces to perform one or more of the following functions: prevent penetration of water; provide resistance against abrasion, alkalis, acids, mildew, staining, or ultraviolet light; or harden or dustproof the surface of aged or cured concrete. In this proposal, we have included products that perform the following functions: Film-Forming and Penetrating Sealers Water resistance, abrasion resistance, alkali resistance, acid resistance, fungi resistance, staining resistance, UV resistance, and/or hardening of aged or cured concrete Basement Specialty Coatings Hydrostatic seal coatings for below-grade concrete, masonry, stone, and similar substrates. These will be required to meet additional requirements for water and fungi resistance. Definitions: Basement Specialty Coating. A clear, transparent, or opaque coating that is labeled and formulated for application to concrete and masonry surfaces to provide a hydrostatic seal for basements and other below-grade surfaces. Benchmark Product. A product used for comparison in performance testing; for the purposes of this standard this is considered a national market-leading product, typically selected from the top three or four selling brands or companies for its product class from nation-wide data. 5 Concrete/Masonry Sealer. A clear, transparent, or opaque coating that is intended primarily for application to concrete and masonry surfaces to perform one or more of the following functions: prevent penetration of water; provide resistance against abrasion, alkalis, acids, mildew, staining, or ultraviolet light; or harden or dustproof the surface of aged or cured concrete. Film-Forming. A product that provides a solid dry film on a substrate by creating a pliable, cohesive, and continuous covering. 5 It is recommended that manufacturers discuss their product testing with Green Seal before the testing is performed to ensure that the choice of comparison product(s) is appropriate. 7 / 20

8 Penetrating. Coating designed to penetrate the substrate without forming a surface film and without hiding the grain. Under our proposal, concrete/masonry sealers will be required to demonstrate performance for their intended function. Film-forming and penetrating sealers will be required to demonstrate equivalent functional performance for marketed use(s) against a national-market leading benchmark product. In addition, CARB includes performance parameters, methods, and thresholds for the performance of basement specialty coatings, and these have been included in our proposal Concrete/Masonry Sealers. Concrete/Masonry Sealers include penetrating and filmforming products for interior and exterior use and basement specialty coatings for interior use General Requirements. Except for basement specialty coatings, concrete/masonry sealers shall be tested to demonstrate that, for each performance parameter in this section included on the product labeling or marketing, the product performs as well or better than a benchmark product in its product class. For purposes of the test, the curing duration of the concrete/masonry sealer shall be similar to that of the benchmark product, and for film forming products, the dry film thickness of the concrete/masonry sealer shall be similar to that of the benchmark product. Both shall be representative of the manufacturer-recommended application. Testing shall be performed according to the following standard test methods or equivalent test methods: Water Resistance. ASTM C67, ASTM C97, or ASTM C Abrasion Resistance or Hardening of Cured Concrete. ASTM D Alkali Resistance. ASTM D Acid Resistance. ASTM D Fungi Resistance. ASTM D3273 or ASTM D Staining Resistance. ASTM D UV Light Resistance. ASTM G Water Vapor Transmission. ASTM E96/E96M Basement Specialty Coatings. Basement Specialty Coatings shall meet the following performance criteria: Water Resistance. The product must be capable of withstanding at least 10 psi of hydrostatic pressure, as determined in accordance with ASTM D Fungi Resistance. The product must be resistant to mold and mildew growth and must achieve a microbial growth rating of 8 or more, as determined in accordance with ASTM D3273 and ASTM D3274 The chemistry of environmentally-preferable products in this category, such as acrylic-based resin and siloxane emulsions, can meet the current health and environmental criteria in GS-11. Therefore, we are proposing to apply the current criteria to concrete/masonry sealers. Our proposal will require the VOC limits specified by CARB. For concrete/masonry sealers, CARB VOC limits vary by product function: 8 / 20

9 Concrete/Masonry Sealers: 100 g/l Basement Specialty Coatings: 400 g/l 2.4 Fire Resistive and Intumescent Coatings (Section 2.9) We are proposing to expand the scope of GS-11 to apply to products that increase the fire resistance of substrates. Such products are used to protect structures from fire damage by slowing the progress of a fire. A survey of the current market of fire resistive coatings shows that a sufficient number of leadership products meet the current health and environmental criteria in GS-11, while providing the functionality necessary for products rated for fire resistance up to 4 hours. Therefore, environmentally-preferable products in this category can be required to meet these criteria, and we are proposing to apply the current criteria to these product categories. Definitions: Fire Resistive Coating. A coating that reduces the spread of fire on combustible and noncombustible substrates. The Fire Resistive category includes sprayed fire resistive materials and intumescent fire resistive coatings that are used to bring structural materials into compliance with federal, state, and local building code requirements. Intumescent Coating. A type of fire resistive coating that reduces the spread of fire on combustible and non-combustible substrates through chemical reaction that causes the coating to swell and form a protective barrier. Must meet VOC limits for fire resistive coatings. Under our proposal, Fire Resistive Coatings will be required to demonstrate performance for the following parameters: flame spread, smoke development, and fire resistance, in addition to adhesion and flow and leveling (which are covered under the existing GS-11 criteria for paints and coatings). 2.9 Fire Resistive and Intumescent Coatings Adhesion. The product shall demonstrate a minimum of 50% or better rating for wet and dry adhesion over the intended substrate as determined by ASTM D Applicability (Flow and Leveling). The product shall demonstrate applicability by either a minimum 6 rating for foaming, leveling, and spatter resistance as determined by ASTM D7073. OR a minimum drawdown as tested by ASTM D Fire Resistance. The product shall demonstrate a fire resistance rating that is consistent with the labeling, 6 as determined by ASTM Designation E119. Fire Resistive coatings and testing agencies must be approved by building code officials Flame Spread and Smoke Development. The product shall demonstrate a Flame Spread Index of 0 25 (Class A) and a Smoke Development Index of (Class A) based on the Life Safety Code (NFPA 101)[5] and Section of the International Building Code as determined using ASTM E E.g., 1-hour, 2-hour, or 4-hour. 9 / 20

10 3.0 VOC Revisions 3.1 Alignment of Volatile Organic Compound limits with CARB Background Volatile organic compounds (VOCs), a major component of coatings, include many hazardous chemicals that can cause ground level ozone, as well as indoor and outdoor air pollution associated with carcinogenicity and respiratory ailments including asthma. Limits on the content of VOCs are essential for minimizing the potential environmental and health effects of coatings on workers, children, and otherwise vulnerable or sensitive populations. The proposed revision has adopted the VOC limits set by the State of California s Air Resources Board (CARB), making this standard consistent with the 2013 revision of our standards for cleaning products and adhesives (GS-8, GS-34, GS-36, GS-37, GS-40, GS- 41, GS-48, GS-51, GS-52, & GS-53) to conform with applicable CARB levels. 7 Technical Considerations Green Seals standards are intended to reflect the national levels of leadership attainable by a sufficient selection of products that are currently available on the market. It is not our intent to establish aspirational goals that exceed that general level of current leadership. Adopting criteria that are extremely stringent from a national perspective would prevent our standards from transforming the marketplace as quickly and broadly as possible. It is Green Seal s policy generally to adopt the VOC limits established by the State of California s Air Resources Board (CARB) because these limits represent the appropriate level of leadership from a national perspective. In contrast, the South Coast Air Quality Management District (SCAQMD) has established limits that are intended to provide a solution to the exceptional conditions of air pollution in the Los Angeles area. In addition, the moderate climate found there allows coatings to perform better than they would in harsher climates. Since these conditions are not prevalent in most other areas of the United States, the VOC control limits that are appropriate for the south coast of California are not appropriate leadership levels nationally. Past research conducted by Green Seal found that the VOC limits established by CARB represent national leadership levels for the reduction of air emissions, while still allowing for functional performance in all regions of the United States. Therefore, Green Seal considers the VOC control measures established by CARB to be the most appropriate choice to represent national leadership. Proposal Green Seal is proposing to revise the criteria in GS-11 to explicitly cite the VOC limits set by the California Air Resources Board (CARB). An informational section will be added with the current VOC limits set by CARB for the coating product categories included in the proposed revision of GS Volatile Organic Compounds (VOC). The VOC content of the product shall not exceed the current control measures for its product category, as set by the California Air Resources Board (CARB), 8 unless specified otherwise These limits are an explicit reference to the current VOC limits specified in California Air Resources Board Suggested Control Measure for Architectural Coatings (2007). This reference will be updated to reflect any amendments made by CARB in the future. 10 / 20

11 The definition of VOCs in GS-11 will be changed in order to be consistent with other systems for VOC limits. The proposed definition of volatility is consistent with the EU definition. Definition: Volatile Organic Compound (VOC). Any organic compound which participates in atmospheric photochemical reactions as defined by the U.S. EPA in 40 CFR (s) and has a boiling point of less than or equal to 250 C at 1 standard atmosphere (101.3 kpa) an initial boiling point lower than or equal to 280 C measured at standard conditions of temperature and pressure. Exceptions to CARB VOC limits. Green Seal is proposing that products that are not specified by CARB, or that were specified in the current version of the Green Seal standards with higher (less stringent) limits than those specified by CARB, will be exempted from the CARB limits, using the limits that are currently specified in the standards. This is in order to avoid making the definition of leadership levels more stringent than those that were already established for these products. Exceptions to CARB limits: Product Type VOC level (g/l) Reflective Wall Coating 50 Reflective Roof Coating 100 Varnish 350 Conjugated Oil Varnish 450 Lacquer 550 Clear Brushing Lacquer 680 VOC limits for two types of products, sealers (200 g/l) and waterproofing sealers (250 g/l) for wood and metal substrates, were lower (more stringent) than the CARB limits for Wood Coatings (275 g/l). In order to increase the harmonization with the leadership limits already in wider use by the industry, these product categories will have to meet the CARB limits for Wood Coatings (275 g/l). Additional Proposed Criteria and Clarifications for VOCs: The calculation of VOC shall exclude water and shall exclude colorants added at the point-of-sale. Exception: VOC content for Low Solids Coatings shall be calculated according to the VOC- Actual definition provided by CARB, excluding colorants added at the point-of-sale. 9 9 i.e., the volume of the product for calculating VOC-Actual for low solids coatings includes the volume of water and exempt solvents. 11 / 20

12 Products sold in containers smaller than 1 liter will not be granted an exemption from these VOC limits. 10 Products labeled as Industrial Maintenance Coatings must meet the requirements for their general product category.11 Anti-corrosive coatings shall meet the VOC requirements for rust preventative coatings. Intumescent coatings shall meet the VOC requirements for fire resistive coatings. Sealers and waterproofing sealers labeled for use on wood or metal substrates shall meet the VOC requirements for wood coatings. 3.2 VOC Measurement Methods Background Green Seal is proposing a change to GS-11 to make it consistent with common methods of determination of VOC content, such as Method 310 of the State of California s Air Resources Board (CARB). The VOC measurement method currently specified in GS-11 analysis by GC/MS is not required by other major regulations or certifications. Technical Considerations GS-11 currently requires VOCs to be measured in the product by GC/MS analysis, using ASTM 6886 or ISO Neither of these methods is currently required for compliance with VOC limits specified by CARB, SCAQMD, EPA, the Ozone Transport Commission, LEED, Master Painter s Institute, or the EU. The current edition of GS-11 has also established a unique definition for VOC that is not consistent with the other VOC regulatory or certification systems. GS-11 currently defines VOCs to be compounds that have a boiling point of up to 280ºC; this is a modification of the EU definition of VOCs, which includes compounds that have a boiling point of up to 250ºC. Green Seal acknowledges that the VOC methods currently specified in GS-11 and GS-47 are not widely accepted, and are not used in the coatings industry. Since Green Seal s standards are intended to reflect the current level of leadership in the markets, we are proposing to harmonize the VOC requirements in GS-11 with the current practice of VOC regulators. Proposal Green Seal is proposing to expand the methods approved for measuring VOCs to harmonize them with regulatory measures that are common in the industry, as well as with the other Green Seal standards that were revised recently. Calculations based on formulation data (currently allowed by CARB) and difference methods (CARB Method 310, SCAQMD Method 304, and ISO ) will be added as acceptable alternatives to the GC/MS methods currently specified in GS-11 and GS-47. Measurement methods for VOCS: The VOC content shall be determined for compounds present in the product at 0.01% or more, in one of the following ways: 10 CARB currently grants an exemption from VOC limits to products sold in containers smaller than 1 liter (known as the Small Container Exemption). 11 i.e., they will not be allowed to meet the higher VOC limits set by CARB for Industrial Maintenance Coatings. 12 / 20

13 Product Formulation By summing the percent by weight contribution from all VOC ingredients listed in the formulation data. Difference Methods According to the CARB Method 310 (or equivalent), modified to include all VOC ingredients According to the SCAQMD Method 304 (or equivalent), modified to include all VOC ingredients According to ISO (or equivalent), modified to include all VOC ingredients GC/MS Methods According to ASTM D6886 or ISO Another scientifically validated test method may be used if accompanied by justification for the method modification and documented in sufficient detail. 3.3 Evaluation of Volatile Organic Compounds Background Green Seal is also proposing to revise GS-11 to include VOC limits only on those compounds that are present at 0.01% (100 parts per million) or greater (consistent also with our standards for cleaning products and adhesives). Technical Considerations Individual components that are present below 0.01% contribute only a negligible amount of the overall VOC content; including limits on these ingredients is, therefore, not warranted. The proposed revision provides that the VOC content may be evaluated by summing contributions only from those compounds that are present at 0.01% by weight, or more, in the product. Proposal Green Seal is proposing to revise GS-11 to include only those components that are present at 0.01% (100 parts per million) or greater. [This text also appears in the section on Measurement Methods, and is duplicated here for completeness.] Measurement methods for VOCS: The VOC content shall be determined for compounds present in the product at 0.01% or more, 12 in one of the following ways: 3.4 Colorants Added at the Point of Sale Technical Considerations 12 Evaluation of the VOC content in this standard includes all volatile organic compounds present in the product at 0.01% or more. Evaluation of the VOC content under CARB Method 310 exempts all volatile organic compounds present below 0.1%. 13 / 20

14 The requirements in GS-11 and GS-47 relate to the product produced by the manufacturer and do not include additives introduced at the point-of-sale. GS-11 includes an additional requirement on VOCs for colorants added at the point of sale, since they can add significant VOCs to the product. The limits currently specified in the table in Section 3.5 are 50 g/l above the amounts of VOC permitted for each product category. Proposal Limits in Section 3.5 on VOCs added at the point of sale will be set explicitly to 50 grams of VOC per liter of product above the levels allowed by CARB for all product categories in the scope. This revision does not change the existing criterion; it is intended to specify the existing colorant limits as a fixed increment above the VOC limits set by CARB for the product without colorants. 3.5 Colorant Added at the Point-of-Sale: VOC. The VOC concentration of the product including the colorant added at the point-of-sale shall not exceed 50 grams of VOC per liter of product above the levels allowed by CARB Proposed Exemptions 4.1 Carcinogens (Section 3.1) - Crystalline Silica. An exemption for by-products in naturally occurring ores was included in earlier versions of GS-47, but removed erroneously in the last version. Add the following exemption to Section 3.1: Exemption: Crystalline Silica. Free crystalline silica, which is currently listed as a known human carcinogen, shall not be intentionally added to the product as an ingredient. Crystalline silica present as a naturally-occurring contaminant in mineral-based raw materials 14 is not included in this prohibition. 4.2 Prohibited Ingredients (Section 3.2); Halogenated solvents PCBTF (Parachlorobenzotrifluoride, CAS# ), is a halogenated solvent with one aromatic ring. PCBTF is used as a component (5-12%) of low-voc compliant polyurethane finishes. PCBTF is sometimes referred to by manufacturers as a green solvent because it has been exempted by the EPA from the VOC list, due to low photochemical reactivity, and is not listed by the Clean Air Act as a Hazardous Air Pollutant. For these reasons it is increasingly used as a xylene replacement in cleaners, thinners and other aromatic hydrocarbon blends. Some concerns do exist, however, about potential health hazards that may be posed by PCBTF. Although the actual toxicity of PCBTF is unclear, many chlorinated aromatic solvents similar to PCBTF have been shown to have elevated toxicity. Although some concerns have been raised about PCBTF, but there has been no general determination that it is toxic. It is currently under review by the National Toxicology Project; public results from this review are not expected to be available for approximately two years. 13 VOC limits for the products without colorant are specified in Section 3.4. Examples of VOC limits for products with colorant added at the point-of-sale can be found in Appendix 2 14 e.g., mined extender pigments, calcium carbonate, diatomaceous earth, or other mineral-based raw materials. 14 / 20

15 As a functional ingredient in coatings, PCBTF can provide benefits for clear metal coatings that must dry quickly, especially when applied to vertical surfaces. The use of PCBTF as a solvent can allow a low- VOC product in this category to dry quickly before it streaks or creates an uneven finish that is unacceptable. Existing alternatives to PCBTF (e.g., xylene) can be demonstrably toxic, cause substandard performance, or increase the emissions of photochemically active VOCs that contribute to ozone pollution. Proposal: PCBTF is currently prohibited in GS-11 and GS-47 as a halogenated solvent. Green Seal is proposing to allow an exemption in Section 3.2 for PCBTF as a solvent in metal lacquers only, with a limit of 10% for the allowed concentration in the product. Exemption: For lacquers intended for metal substrates only, PCBTF (Parachlorobenzotrifluoride, CAS# ) shall be exempted from the prohibition on halogenated solvents and allowed at levels that do not exceed 10% by weight in the product. 4.3 Packaging (Section 5.1): Packages for Dangerous Goods. The packaging sections of GS-11 and GS-47 set requirements for sustainable packaging. One way packaging can meet this requirement is by containing a minimum of recycled content. Some packages must meet regulations for the transport of dangerous goods which preclude the use of recycled content in the packaging. Green Seal has received requests to reconsider the requirements for minimum recovered content for this class of packaging. These packaging materials may be certified by the federal UN certification program, which is in congruence with the US Department of Transportation Guidelines for the Transport of Hazardous Materials. California law, in the Public Resource Code (PRC) Section 42310, requires plastic containers to meet requirements for recycled content and reuse. Plastic packaging tested under the federal UN certification program is exempted from this requirement in Section 4230(d): Rigid plastic packaging containers which are manufactured for use in the shipment of hazardous materials and are prohibited from being manufactured with used material by federal packaging material specifications set forth in Sections and of Title 49 of the Code of Federal Regulations, or are subject to testing standards set forth in Sections to , inclusive, of Title 49 of the Code of Federal Regulations, or to which recommendations of the United Nations on the transport of dangerous goods are applicable. Green Seal is proposing to exempt UN certified packaging (containers for hazardous materials) from the requirements in this section, as they are not allowed to include recovered content and not practical for the other options listed in this section. 5.1 Packaging. The packaging shall be one of the following: contain a minimum of 20% recovered material content. recyclable as part of a manufacturer s take-back program. a source-reduced package. Exemption: Plastic packaging containers may be exempted from the requirements of this section if they are manufactured for use in the shipment of hazardous materials and are prohibited from being manufactured with used material by federal packaging material specifications set forth in Sections and of Title 49 of the Code of Federal Regulations, OR 15 / 20

16 are subject to testing standards set forth in Sections to , inclusive, of Title 49 of the Code of Federal Regulations, OR to which recommendations of the United Nations on the transport of dangerous goods are applicable. 5.0 New Prohibitions and Scope Exclusions 5.1 Triclosan Triclosan (CAS# ) is widely considered as a chemical of concern. In light of the scientific consensus regarding the hazards of this chemical, Green Seal proposes to add triclosan to the list of prohibited ingredients in GS-11. Triclosan is already prohibited in a number of our recent standards (GS- 48, GS-50, GS-51, GS-52, and GS-53). Triclosan has been shown to contribute to the growth of antibiotic-resistant bacteria, 15 increase the risk of allergic responses in children, 16 and can cause the following effects in mice and rats: reduced fertility, 17 impaired muscle function, 18 lower sperm production, 19 underweight fetuses, 20 and delayed or irregular growth of the skull and paw bones. 21 A survey of the coatings industry shows that a variety of alternatives to triclosan are available on the market. 22 They provide antimicrobial functions in the final coating with the same level of protection against mold, mildew, and other contaminants.. Green Seal proposes to add triclosan to the list of prohibited ingredients in Section Prohibited Ingredients. The product shall not contain the following ingredients: 1,2-dichlorobenzene Alkylphenol ethoxylates Formaldehyde donors Hazardous air pollutants Halogenated solvents Ozone-depleting compounds Heavy metals: lead, mercury, cadmium, hexavalent chromium and antimony in the elemental form or compounds Phthalates Triphenyl tins and tributyl tins Triclosan 15 Norwegian Scientific Committee for Food Safety, 16 Johns Hopkins Children s Center, Linked-to-Allergy-Risk-in-Children.aspx 17 Reproductive Toxicology, 2012, 18 University of California, Davis, the National Academy of Sciences, 2012, 19 Reproductive Toxicology, 2009, 20 U.S. Environmental Protection Agency, 21 U.S. Food and Drug Administration, 22 e.g., zinc pyrithione (ZPT), CAS No: , calcium hydroxide, CAS No: / 20

17 5.2 Nanoparticles Nanoparticles are added to paint and coatings to increase hardness and scratch resistance, induce water repellant properties, and protect against corrosion and infrared radiation. Some nanoparticles are also effective anti-microbial agents and can remove pollutants from the air, improving air quality. Evidence is accumulating in studies on both animals and humans that nanoparticles may be associated with health hazards. A variety of nanoparticles (e.g., carbon nanotubes, titanium dioxide, gold, silver, and copper) have been linked to DNA breaks, chromosome damage, and inflammation, as well as accumulation in kidney and lung cells. The body can absorb and accumulate nanoparticles; they can even infiltrate cellular membranes, disrupting processes, where their accumulation could potentially have harmful long-term effects. Despite these concerns, there is great uncertainty regarding the potential hazards posed by nanoparticles in coatings. According to an EMPA study in the EU, only 1-2% of nanoparticles in paint on façades made their way into the environment. Paints containing nanoparticles had similar effects on the gastrointestinal and immune systems as did paints not containing nanoparticles. One study stated that changes observed in lung histopathology and function in high-dose animals appear in and of themselves to be minor. One thing is clear: much more research is necessary on this topic. The FDA has released a press announcement stating that it does not make a categorical judgment that nanotechnology is inherently safe or harmful, and will continue to consider the specific characteristics of individual products. 23 Concern exists over the potential hazards posed by nanoparticles in coatings, but a full survey of these issues is beyond the scope of this revision. We therefore propose to exclude coatings containing nanoparticles from the scope of GS-11; a future revision of this standard may address this issue. Defining precisely what constitutes a nanoparticle or nanomaterial is a complex process, especially when their potential hazards are to be considered. Both ISO/TS and ASTM E define approximate size ranges of nm, but acknowledge that this definition is problematic in terms of addressing size-related properties, and is essentially arbitrary. These standards also do not address size distributions of the materials. Green Seal is proposing a definition of nanoparticles for the scope exclusion, based on a definition developed by the European Scientific Committee on Emerging and Newly Identified Health Risks. 24 An excerpt from this document: In conclusion, - whereas physical and chemical properties of materials may change with size, there is no scientific justification for a single upper and lower size limit associated with these changes that can be applied to adequately define all nanomaterials; - there is no scientific evidence for a single methodology (or group of tests) that can be applied to all nanomaterials ; - size is universally applicable to define all nanomaterials and it is the most suitable measurand. Moreover, an understanding of the size distribution of a nanomaterial is essential and the number size distribution is the most relevant consideration; [...] As there is no scientific evidence to qualify the appropriateness of the 100 nm cut-off, it is important to consider the whole nanoscale metric (1-999 nm). This could be enabled by applying a tiered approach Scientific Basis for the Definition of the Term "nanomaterial", ISSN ISBN , doi: /39703 ND-AS EN-N / 20