New VOC Regulations Threatened the Quality of Roofing Assemblies until the Roofing Industry Became Involved

Ellen Thorp, associate executive director of the EPDM Roofing Association, makes it a point to be responsive to the many inquiries she gets. Most deal with routine requests for information about EPDM, but one phone call Thorp fielded six years ago from one of ERA’s member companies stood out from the rest. Ultimately, it changed the way ERA and the roofing industry do business.

A manufacturer’s rep had heard from a customer in Connecticut that the state was about to implement VOC regulations. The problem: The new regulations would ban some of the adhesives, sealants, and primers essential to installing EPDM and other roofing products, and there were no substitute products available to meet the new standards. If the new regulations went into effect as scheduled, they threatened to negatively impact the safety and quality of roofing assemblies in the affected area and the roofing industry as a whole.

The proposed regulations were part of an effort by the Ozone Transport Commission, or OTC, to achieve federally mandated air-quality standards in the Northeast and Mid-Atlantic. The OTC was created under the Clean Air Act to develop solutions for the New England states, as well as Delaware; Maryland; New Jersey; New York; Pennsylvania; Virginia; and Washington, D.C. At the time of OTC’s creation, most of these states had not attained federally mandated ozone standards, and the region lagged behind other parts of the U.S. in achieving compliance.

As part of its initial work, OTC developed a Model Rule for Adhesives and Sealants, based on regulations used in California, incorporating provisions effective in the climactic and market conditions of that state. At the time of the phone call to Thorp, the OTC had released the model rule, and states were beginning to draft their own regulations that included implementation dates within the next year. “The VOC limits the OTC was proposing would have required products that did not exist in the Northeast and Mid-Atlantic,” Thorp explains. “It was also concerning that they were basing the limits on California regulations. The climate in the Northeast is very different than in California, so we didn’t feel it was good science to be creating a model rule based on a place that had a completely different climate.”

Thorp and the ERA member companies were very interested in working with state regulators. “It certainly is our priority to reduce VOC emissions wherever possible, but it also is important to us to have regulations that our industry could work with and are based on the best available science,” she says. In fact, products that would meet the new regulations were in development but were not yet available. In addition, the new adhesives and sealants would require new or modified application techniques. That meant the roofing industry needed time to train thousands of roofing contractors.

ERA’s first step was to support its assertion that the climate of the Northeast differed dramatically from that of California. ERA hired Jim Hoff of Tegnos Research Inc. to review weather data and the effects the weather has on low-VOC products. “At ERA’s expense, we assembled relevant scientific data and provided it to the state regulators,” Thorp adds.

ERA worked with regulators in each state, sharing the results of its research. ERA provided the state environmental protection and air quality bureaus with detailed information about what sealants were available and explained the time needed to train roofing contractors. Working together, the regulatory bodies and ERA were able to agree on a phased-in or seasonal approach. For instance, in a majority of the states, the new low-VOC products were required initially only in the summer for three months. The year after, they were required for five months. Then, the following year, they were required year-round. Once these states had found success with this approach, others followed suit. “We explained to the regulators the importance of being consistent since many roofing companies do work across multiple states, especially in the Northeast where the states are small and roofing companies are likely to work across state lines,” Thorp notes.

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