PROPOSED CRITERION REVISION: GS-8, GS-34, GS-36, GS-37, GS-40, GS-41, GS-52, GS-53 Volatile Organic Compound Content Section Revisions.

Transcription

1 December 4, 2012 PROPOSED CRITERION REVISION: GS-8, GS-34, GS-36, GS-37, GS-40, GS-41, GS-52, GS-53 Volatile Organic Compound Content Section Revisions. Green Seal is proposing revisions to the criterion in the following standards that evaluate the volatile organic compound (VOC) content of a product: Green Seal Standard for Cleaning Products for Household Use, GS-8: Section 3.8 Air Pollutants; Green Seal Standard for Cleaning and Degreasing Agents, GS-34: Section 3.6 Photochemical Smog and Oxidant Production; Green Seal Standard for Adhesives for Commercial Use, GS-36: Section 3.5 Volatile Organic Compounds; Green Seal Standard for Cleaning Products for Industrial and Institutional Use, GS-37: Section 3.9 Volatile Organic Compound Content; Green Seal Standard for Floor-Care Products for Industrial and Institutional Use, GS-40: Section 3.6 Air Quality; Green Seal Standard for Hand Cleaners for Industrial and Institutional Use, GS-41: Section 3.8 Photochemical Smog and Indoor Air Quality; Green Seal Standard for Specialty Cleaning Products for Household Use, GS-52: Section 3.12 Volatile Organic Compound Content; Green Seal Standard for Specialty Cleaning Products for Industrial and Institutional Use, GS-53: Section 3.12 Volatile Organic Compound Content Background Alignment of Volatile Organic Compound limits with CARB: Volatile organic compounds (VOCs), common ingredients in cleaning products, 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 cleaning products and ozone pollution on workers, children, and otherwise vulnerable or sensitive populations. The proposed revision has adopted the allowable VOC limits set by the State of California s Air Resources Board (CARB), with an exception for product categories where previous editions of Green Seal s standards already set stricter limits. These product categories will remain at their current allowable limit. Evaluation of Volatile Organic Compounds: The current language of the GS-37, GS-52, and GS-53 standards requires all components in a formula be reviewed for their contribution to VOC content. Green Seal is recommending a change to these standards to be consistent with the GS-8, GS-34, GS-40, and GS-41 standards to review only those components that are present at 0.01 percent(%) (100 parts per million) or greater. This criterion of GS-34 and GS-36 specifies the use of U.S. Environmental Protection Agency (EPA) Method 24. Green Seal is recommending a change to these standards to determine VOC content by the State of California s Air Resources Board (CARB) Method 310 for determining the acceptable levels of VOC content allowed in the various product classes. This method is established and well known.

2 Technical Considerations Volatile Organic Compounds CARB Alignment: It is Green Seal s policy to adopt the VOC limits set by the State of California s Air Resources Board (CARB). In past research conducted by Green Seal, it was found that VOC limits established by CARB set leadership levels for reduction of air emissions while still allowing for functional performance for the product categories that they cover. CARB amended its Regulation for Reducing Emissions from Consumer Products in 2010 with an effective date of December 31, 2012; therefore, Green Seal is updating the criterion in the GS-8, GS-34, GS-36, GS-37, GS-40, and GS-41 standards that address VOC limits to reflect this change. In addition, Green Seal is changing language to explicitly cite the CARB limits in our standards. An exception is being made for product categories where previous research conducted by Green Seal already set stricter limits; these product categories will remain at their current allowable limit. Evaluation of Volatile Organic Compounds: Individual components present below 0.01% contribute only a negligible amount to the overall VOC content and reviewing these ingredients is not warranted. The proposed revision will establish clear language across all Green Seal standards for cleaning products, that the VOC content may be evaluated by summing contributions only from those components that are present at 0.01% by weight, or more, in the product. This change is also recommended for the laundry care standards, GS-48 (Household Use) and GS-51 (Industrial and Institutional Use), so that this revision can be made prior to the finalization of these standards. CARB Method 310 includes references by incorporation of EPA Method 24 and other methods from the American Society for Testing and Materials (ASTM). Therefore, by referencing CARB Method 310, or equivalent test methods, Green Seal is expanding beyond EPA Method 24 for determining the VOC content in various product categories in GS-34 and GS-36 as well as establishing consistency across Green Seal s standards. Proposed Revisions Green Seal is proposing to revise the limits of VOCs in Green Seal s standards for cleaning products and commercial adhesives. The proposed revisions are as follows, noted in red text and strikethrough: Green Seal Standard for Cleaning Products for Household Use, GS Air Pollutants Volatile Organic Compound (VOC) Content. The VOC content of the product as used shall not contain no more than the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. substances that contribute significantly to the production of photochemical smog, tropospheric ozone, or poor indoor-air quality. The volatile organic content of shall be determined by California Air Resources Board Method 310 or as demonstrated through product constituent calculation, and shall not exceed the following: Additionally, the VOC of the product as used for these product categories shall not exceed the following: 0.1% by weight for dilutable carpet cleaners 1% by weight for bathroom cleaners 3% by weight for general-purpose cleaners 3% by weight for glass cleaners 3% by weight for ready-to-use carpet cleaners

3 By summing the percent by weight contribution from all organic ingredients present in the product that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C According to the California Air Resources Board Method 310 or equivalent. Green Seal Standard for Cleaning and Degreasing Agents, GS Photochemical Smog and Oxidant Production Volatile Organic Compound (VOC) Content. The compound shall not contain substances that can contribute significantly to the production of photochemical smog and tropospheric ozone. Therefore, The VOC content of the product, as used, shall not exceed 50 g/l, as determined by EPA method 24 (40 CFR Part 60) contain no more than the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. By summing the percent by weight contribution from all organic ingredients present at 0.01% or more in the product that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C According to the California Air Resources Board Method 310 or equivalent. Green Seal Standard for Adhesives for Commercial Use, GS Volatile Organic Compounds (VOC) Content. The VOC concentrations of the product, as applied according to the manufacturer s recommendations, shall not exceed those listed below as determined by U.S. Environmental Protection Agency (EPA) Reference Test Method 24 (40 Code of Federal Regulations (CFR) Part 60) contain no more than the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. The volatile organic content shall be determined according to U.S. Environmental Protection Agency (EPA) Reference Test Method 24 (40 Code of Federal Regulations (CFR) Part 60) the Californian Air Resources Board Method 310, or equivalent. Additionally, for specialty applications not defined by CARB, the current regulatory limits of the South Coast Air Quality Management District (SCAQMD) Rule 1168 shall be used. Adhesive Type VOC weight in grams/liter minus water ABS Welding 400 Carpet Pad Installation 150 Ceramic Tile Installation 130 Contact Bond 250 Contact Bond-Specialty Substrates 400 Cove Base Installation 150 CPVC Welding 490 Indoor Floor Covering Installation 150 Multipurpose Construction 200 Nonmembrane Roof Installation/Repair 300 Other Plastic Cement Welding 510 Outdoor Floor Covering Installation 250 PVC Welding 510 Rubber Floor Installation 150 Single-Ply Roof Membrane Installation/Repair 250 Structural Glazing 100 Perimeter Bonded Sheet Vinyl Flooring Installation 660 Waterproof Resorcinol Glue 170 Wood Flooring Adhesive 150

4 For adhesives not listed above and applied to the following substrates, the following limits shall apply: Adhesives Application Onto Substrate VOC weight in g/l minus water Flexible vinyl 250 Fiberglass 200 Metal-to-Metal 30 Porous material 120 Plastic Foams 120 Rubber 250 Other substrates 250 Aerosol Adhesives: General purpose mist spray General purpose web spray Special purpose aerosol adhesives (all types) 65% VOCs by weight 55% VOCs by weight 70% VOCs by weight Green Seal Standard for Cleaning Products for Industrial and Institutional Use, GS Volatile Organic Compound (VOC) Content. The VOC content of the product as used shall not contain no more than the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. components that contribute significantly to the production of photochemical smog, tropospheric ozone, or poor indoor-air quality; i.e., the volatile organic compound content of the product as used Additionally, the volatile organic compound content of the product as used for these product categories shall not exceed the following: 0.1% by weight for dilutable carpet cleaners 1% by weight for general-purpose cleaners 1% by weight for restroom cleaners 1% by weight for glass cleaners 1% by weight for ready-to-use carpet cleaners The volatile organic compound content shall be determined either by summing the percent by weight contribution from all ingredients of the product that have a vapor pressure of greater than 0.1 mm mercury at standard conditions or by the California Air Resources Board Method 310, modified to not allow the exemption for fragrances specified under Method 310. By summing the percent by weight contribution from all components organic ingredients present in the product that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C According to the California Air Resources Board Method 310 or equivalent, modified to not allow the exemption for fragrances specified under Method 310. Green Seal Standard for Floor-Care Products for Industrial and Institutional Use, GS Air Quality Volatile Organic Compound (VOC) Content. The VOC conent product as used shall not contain substances that contribute significantly to the production of photochemical smog, tropospheric ozone, or poor indoor-air quality. Therefore, the volatile organic content of the finish product, as used, shall not exceed 7% by weight, and the volatile organic content of the stripper product, as used, shall not exceed 3% by weight at the greatest recommended amount of dilution (suitable for light to medium buildup), and shall not exceed 7% by weight for the least recommended amount of dilution (suitable for heavy buildup). Total volatile organic compound

5 content shall be determined according to California Air Resources Board Method 310 contain no more than the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. Additionally, the VOC content of stripper products, as used, shall not exceed 7% by weight for the least recommended amount of dilution (suitable for heavy buildup). By summing the percent by weight contribution from all organic ingredients present in the product that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C According to the California Air Resources Board Method 310 or equivalent. Green Seal Standard for Hand Cleaners for Industrial and Institutional Use, GS Photochemical Smog and Indoor Air Quality Volatile Organic Compound (VOC) Content. The product shall not contain VOCs in excess of the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. limits expressed in the table below as measured by U.S. Environmental Protection Agency (EPA) Method 24-24A, 40 Code of Federal Regulations, Part 60, Appendix A (1991), or Method 18,48 Federal Register 48, no. 202, October 18, 1983, or Method 1400 the National Institute for Occupational Safety and Health (NIOSH) Manual of Analytical Methods, Volume 1, February 1984, or EPA Method 8240 GC/MS Method for Volatile Organics, September 1986, or By summing the percent by weight contribution from all organic ingredients present in the product that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C According to the California Air Resources Board Method 310 or equivalent. GS 41 A GS 41 B Institutional Hand Cleaners Industrial Heavy Duty Hand Cleaners 1% 8% Green Seal Standard for Specialty Cleaning Products for Household Use, GS *Volatile Organic Compound (VOC) Content. The VOC content of the product as used shall contain no more than the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. For product categories not regulated by CARB, the VOC level shall not exceed 1% by weight. Additionally, the following shall apply: CARB VOC requirements for glass cleaners shall apply to optical lens cleaning products CARB VOC requirements for motor vehicle wax, polish, sealant, or glaze products shall apply to motor vehicle dressing products CARB VOC requirements for bug and tar removers shall apply to chewing gum remover products By summing the percent by weight contribution from all organic components present at 0.01% or more in the product that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C

6 According to the California Air Resources Board Method 310 or equivalent, modified to not allow the exemption for fragrances specified under Method 310. Green Seal Standard for Specialty Cleaning Products for Industrial and Institutional Use, GS *Volatile Organic Compound (VOC) Content. The VOC content of the product as used shall contain no more than the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. For product categories not regulated by CARB, the VOC level shall not exceed 1% by weight. Printing press cleaning products shall meet the South Coast Air Quality Management District requirements for solvent cleaning of ink application equipment found in Rule Solvent Cleaning Operations. Additionally, the following shall apply: CARB VOC requirements for glass cleaners shall apply to optical lens cleaning products CARB VOC requirements for motor vehicle wax, polish, sealant, or glaze products shall apply to motor vehicle dressing products CARB VOC requirements for bug and tar removers shall apply to chewing gum remover products The VOC content shall be determined in one the following ways: By summing the percent by weight contribution from all organic components present at 0.01% or more in the product that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C According to the California Air Resources Board Method 310 or equivalent, modified to not allow the exemption for fragrances specified under Method 310.