BOARD MEETING DATE: September 15, 2000 AGENDA NO. 33

Rule 1168 – Adhesive Applications, controls VOC emissions from the use of adhesives and sealants used by industrial and commercial sources. Industrial sources use a wide variety of adhesives and sealants primarily for structural, thermal, or electrical applications to bond metals, plastics and composites of plastics, glass, ceramics, rubber, and paper to themselves or to each other. Companies in the South Coast Air Basin (Basin) that use adhesives and sealants are engaged in a variety of activities including the assembly of corrugated boxes, motor vehicle parts and accessories, motor homes, metal and wood office furniture, pen and mechanical pencil parts, tire retreading and repairs, hardwood veneers, plastic foam products, wood office furniture and shelving, wood kitchen cabinets, fabricated metal parts and products, household furniture, electronic components and accessories, industrial machinery, and fabricated textile products.

The commercial sector of the adhesives market is largely architecturally based. Application examples include: indoor and outdoor carpeting, carpet pad, wood flooring, ceramic tile, drywall, paneling, subfloor, rubber floor, cove base, vinyl composition tile (VCT) and asphalt tile, single-ply roof membrane adhesives, and most of the plastic pipe welding and priming applications.

The entire inventory of Rule 1168 is approximately 7.8 tons of VOC per day, with the bulk of emissions resulting from the use of adhesives in the commercial sector. The industrial sector contributes only about 0.6 tons of VOC per day. Therefore, the proposed amendments to Rule 1168 primarily focus on the commercial applications (architectural) for further reductions.

Newer resin technologies that perform well under the Basin’s favorable climatic conditions such as moderate temperatures and humidity, pave the way for the promulgation of very low VOC limits for adhesive and sealant applications.

The proposed amendments to Rule 1168 will result in reducing the current inventory by 5 tons per day, at an estimated cost-effectiveness of $620 per ton of VOC abated.

The staff proposal will lower VOC contents for the following adhesives (in grams per liter, less water and less exempt compounds):

Effective September 1, 2001	From	To
• Indoor Carpet Adhesives	150	50
• Carpet Pad Adhesives	150	50
• Outdoor Carpet Adhesives	250	150
• Wood Flooring Adhesives	150	100
• Rubber Flooring Adhesives	150	60
• Subfloor Adhesives	200	50
• Ceramic Tile Adhesives	130	65
• VCT and Asphalt Tile Adhesives	150	50
• Dry Wall and Panel Adhesives	200	50
• Cove Base Adhesives	150	50
• Multipurpose Constructions Adhesives	200	70
• Adhesives used on Plastic Foams	120	50
• Adhesives used on Porous Materials	120	50
• Adhesives used on Fiberglass	200	80

Effective January 1, 2003	From	To
• Contact Adhesives	250	80
(Certain special purpose contact adhesives remain at 250 grams per liter.)

Effective Day of Adoption	From	To
• Structural Wood Member Adhesive	200	140

The proposal will establish a prohibition of sale of non-compliant adhesives and sealants, together with a sell through exemption period of one year after the effective dates of VOC limits.

On September 1, 2001 the small user exemptions will expire, unless the user demonstrates that the total volume of non-compliant adhesives and sealants is less that 55 gallons per rolling 12-month period, but not allowing the exemption for architectural adhesives, contact adhesives, and adhesives used on porous substrates.

Because they contain very small amounts of VOC, light and electron beam curable adhesives and sealants, as well as cyanoacrylate adhesives, are proposed to be exempt. The VOC limit of 850 grams per liter for sheet applied rubber lining operations, which has expired as of January 1, 2000, is proposed for continuation. AQMD VOC Test Method 316B for cyanoacrylate adhesives is USEPA approved and is incorporated in this rule revision. In addition, adhesive and sealant consumer products regulated by CARB's consumer product regulations are explicitly exempted for clarity. Other language changes and definitions are added to improve rule clarity.

While acknowledging the availability and performance of low VOC contact adhesives, some manufacturers requested a small user exemption to address potential learning curve issues associated with their use. Staff has already modified its original proposal to create a special purpose contact adhesive category to allow for a higher VOC limit for certain substrates with application and performance difficulties. Relative to the other uses of contact adhesives, staff's research with manufacturers and users indicates that there is a variety of compliant products available that perform adequately and with learning curves not particularly challenging. Staff's proposed January 1, 2003 future effective date for contact adhesives provides ample time to users to experiment with the new products and the manufacturers and suppliers to provide the necessary assistance.

The California Health and Safety Code requires the AQMD to adopt an Air Quality Management Plan (AQMP) to meet state and federal ambient air standards in the Basin. In addition, the California Health and Safety Code requires that the AQMD adopt rules and regulations that carry out the objectives of the AQMP. Control measure CTS-02E in the 1997 AQMP, as amended in 1999, calls for greater use of waterborne, hot melt, UV cured, moisture cured or reactive diluent adhesives to achieve further reductions in daily VOC emissions. These are the types of adhesives the proposed amendment relies on for achieving the expected VOC reductions of 5 tons per day. The cost effectiveness of these reductions is $620 per ton of VOC reduced. The proposed amendments also implement the SIP settlement agreement reached in 1999.

Pursuant to the California Environmental Quality Act (CEQA) and the AQMD’s Certified Regulatory Program (Rule 110), the AQMD prepared a Draft Environmental Assessment (EA) for Proposed Amended Rule 1168 – Adhesive and Sealant Applications, which was released for a 30-day public review period. No Comments on the Draft EA were received. A Final EA has been prepared and is included as part of this Adopt Hearing package.

The socioeconomic report for this proposed amendment is prepared and is attached to the Staff Report. No significant socioeconomic impacts have been identified as a result of the proposed amendments.

Staff will continue current inspection practices to facilities subject to Rule 1168. However, elimination of the small use exemption may necessitate more small facility inspections. Two industry associations have been involved with the rule development process. These associations provide a large part of the adhesives industry with up-to-date regulatory information. Any smaller operations will be informed of the amendments by mail, outreach, and Internet posting on the AQMD website.

Implementation of the proposed amendments is not expected to have impacts on staff or fiscal resources.

A. Summary of Proposed Amendments
B. Rule Development Process
C. Key Contacts List
D. Resolution
E. Rule Language
F. Staff Report
G. Environmental Assessment

South Coast Air Quality Management District