Report from the TRFA VOC Task Force Charles M. BartishAir Products Charles ZarnitzCVC Tom GeriakGarland Floors Derek KincaidHuntsman September 11, 2006 Montreal, Canada

2 Bartish Sept TRFA VOC Montreal Responsible Care ® Good Chemistry at Work TRFA and VOC’s: Background New US regulations are sharply reducing levels of VOC’s acceptable in coatings formulations Significant discussion in Regulatory Affairs session in Ft. Lauderdale re new VOC legislation Coatings, Civil Engineering, Flooring Committee requested effort to address issue for TRFA Team formed to address issue, focused on needs of TRFA companies Purpose of this presentation is to update the membership on accomplishments to date

3 Bartish Sept TRFA VOC Montreal Responsible Care ® Good Chemistry at Work Why is there concern about VOCs? Any volatile compound of carbon is a VOC for regulatory purposes, unless specifically exempted VOC + NO x + Sunlight  O 3 –Precursors: motor vehicle exhaust, industrial emissions, gasoline vapors, chemical solvents –Sunlight, hot weather lead to harmful concentrations –Winds carry O 3 and its precursors miles from sources Ozone is harmful to health and the environment –Triggers health problems even at very low levels –Long-term exposure may cause permanent lung damage –Damages plants and ecosystems

4 Bartish Sept TRFA VOC Montreal Responsible Care ® Good Chemistry at Work VOC’s are regulated federally and locally Federal Clean Air Revisions Act of 1996 –resulted in stricter national VOC regulations. –AIM (Architectural and Industrial Maintenance) regulations became effective in –EPA "non-attainment" areas exceeding 8-hr standards Some state regulations even tougher and impact coatings –California (CARB) and New Jersey strict standards –Southern California (SCAQMD) has the toughest rules Ozone Transport Commission (OTC) regulations –Areas from Northern Virginia to New England adopted lower VOC limits January More regulations coming –LADCO – Lake Michigan Air Directors Consortium –VISTA – Visibility Improvement State and Tribunal Association of the Southeast

5 Bartish Sept TRFA VOC Montreal Responsible Care ® Good Chemistry at Work Ozone 8-hr non-attainment areas

6 Bartish Sept TRFA VOC Montreal Responsible Care ® Good Chemistry at Work Impact: Regulations are driving down allowable VOC content in coatings VOC limit, gram/liter Coating Category US EPA today CARB / OTC SCAQMD Previous SCAQMD July 06 Flat Non-flat Primer Floor Wood Concrete Indus. Maint /

7 Bartish Sept TRFA VOC Montreal Responsible Care ® Good Chemistry at Work TRFA formed the VOC Task Force Industry team members with interest, commitment to address issue –Charlie BartishAir Products and Chemicals –Charlie ZarnitzCVC Specialty Chemicals –Tom GeriakGarland Floors –Derek KincaidHuntsman Significant participation from TRFA administration –Jeri Church –Kathy Fatz Benzyl alcohol suppliers asked, but declined to participate

8 Bartish Sept TRFA VOC Montreal Responsible Care ® Good Chemistry at Work Task Force approaches outlined Focus on VOC issues related to benzyl alcohol –Common ingredient in many formulated products –Limited volatilization; formulation dependent –Consider alternate performance-equivalent solvents; supplier feedback pessimistic based on work to date Define why benzyl alcohol should not be classified VOC –Existing analytical methods (EPA 24, ASTM 2369) overstate VOC impact of benzyl alcohol –Develop and get new method approved –Components can be excluded, i.e. reactive diluents –EPA process, although tedious, exists to delist chemicals from VOC list Work closely with other organizations with common interests –NPCA, ASTM, CARB, SCAQMD, EPA

9 Bartish Sept TRFA VOC Montreal Responsible Care ® Good Chemistry at Work Insights into new method development Current method EPA 24 –0.3 g sample; thin sample dissolved in 3 ml solvent –Hard to include fillers and other additives –Cure at 110°C for 1 hr in forced draft oven Benzyl alcohol has a low vapor pressure, but EPA method will encourage volatilization Methods should reflect real world use TRFA proposed experiments to characterize impact of temperature on VOC measurement Benzyl alcohol vapor pressure

10 Bartish Sept TRFA VOC Montreal Responsible Care ® Good Chemistry at Work TRFA experiments to characterize impact of temperature on VOC VOC measurement should be dependent on temperature of bake oven TRFA companies provided three hardeners containing benzyl alcohol from 30 – 50%. Formulated product gave benzyl alcohol in the range of 13 – 18%. CVC measured VOC content by EPA 24 on the formulated product, but varied temperature of test to measure impact

11 Bartish Sept TRFA VOC Montreal Responsible Care ® Good Chemistry at Work Reduced bake temperature in EPA 24 gives more realistic VOC results VOC, g/l (benzyl alcohol) Bake Temperature, deg C System Actual A B C control-5-40

12 Bartish Sept TRFA VOC Montreal Responsible Care ® Good Chemistry at Work ASTM task group D B proposed changes to ASTM 2369 ASTM task group leading efforts to change methods –Addressing high (>90%) solids coatings –Fred Gelfant (Stonhard) chairs task group Proposed changes include: –Sample size not limited to 0.3 g –Apply at thickness for product intended use –No solvent dilution required in test –Up to 24-hr cure time These changes could benefit the benzyl alcohol case. –Stonhard data supports conclusion –TRFA will work more closely with ASTM EPA letter will allow use of changes in certain areas

13 Bartish Sept TRFA VOC Montreal Responsible Care ® Good Chemistry at Work EPA exemption letter expected to allow use of revised procedure EPA committed to issue exemption letter –Timing still unclear Will allow changes to VOC test procedure for two-component, high solids coatings Revision of ASTM 2369 will include all changes described earlier

14 Bartish Sept TRFA VOC Montreal Responsible Care ® Good Chemistry at Work Next steps and what you can do to help Gain active support from CARB / SCAQMD re oven temperature change in method Validate Task Force lower temperature oven test results against proposed ASTM method changes Volunteer for ASTM analytical round robin test program Provide supporting data that benzyl alcohol has remained in coatings over time Join, support ASTM committee D.01 and signal approval of changes to ASTM D2369

15 Bartish Sept TRFA VOC Montreal Responsible Care ® Good Chemistry at Work Delisting benzyl alcohol as VOC or finding replacement is a long shot NPCA has experience leading effort to delist tertiary-butyl acetate as VOC –Nearly a five-year effort –Test data necessary –Three year effort abandoned on benzyl alcohol Finding alternate, drop-in carrier to benzyl alcohol not likely in near future –Supplier companies have had programs to identify alternate carriers –Challenge is to find performance equivalent materials (reactivity, physical properties)

16 Bartish Sept TRFA VOC Montreal Responsible Care ® Good Chemistry at Work Conclusions New VOC regulations require a response from TRFA formulators to meet new requirements Formulations containing benzyl alcohol need attention to meet new VOC limits TRFA VOC Task Force is formed and has reviewed several options for solutions Benzyl alcohol delisting or replacement low probability to meet time needs Modification of analytical methods EPA 24 / ASTM 2369 offers good potential for success and may be usable in near future TRFA VOC Task Force will work closely with ASTM to influence industry forward program