South Coast Air Quality Management District

Exercise Enforcement Discretion for Sale and Use of Contact Cement in Automotive Refinishing and Shoe Repair Industries

SYNOPSIS: 

The September 2000 amendments to Rule 1168 eliminated a small user exemption for contact cement that exceed 250 g/l of VOC. The amendments also included a prohibition of sale for contact cement that exceed 250 g/l. These amendments took effect on September 1, 2001. These amendments have created an unanticipated hardship for the automotive refinishing and shoe repair industries. Staff will be submitting a proposal to reinstate the small user exemption for these industries for Board consideration in the near future and proposes to use enforcement discretion in the interim.

COMMITTEE: 

None

RECOMMENDED ACTION:

Staff recommends that enforcement discretion be exercised with respect to the sale and use of contact cements in the automotive refinishing and shoe repair industries that exceed 250 g/l of VOC until the Board considers a staff proposal to reinstate the small user exemption for these industries.

Barry R. Wallerstein, D.Env.
Executive Officer

Background

Amendments to Rule 1168 in September 2000 prohibited the sale and use of contact cements that exceed 250 g/l of VOC. These amendments took effect September 1, 2001. There is no satisfactory alternative contact cement for numerous small shoe repair operations. These operations, which are too numerous for group Hearing Board relief, will be forced to cease any operations that require contact cements in excess of 250 g/l of VOC.

The automotive refinishing industry has a serious problem with complying with the new VOC limit. The only alternative product that will comply with the rule and meet the performance standards for the industry contains methylene chloride. This raises public health concerns associated with the use of toxic substances in small, enclosed spaces, such as automobiles when headliner material is installed.

Proposal

Exercise enforcement discretion as to the sale and use of contact cements in excess of 250 g/l of VOC until Rule 1168 can be amended to reinstate the small user exemption for the shoe repair and automotive refinishing industries.

Fiscal Impacts

None.

Attachments

None.

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