Prepared for the

EPDM Roofmg Association

For submission to the

Maryland Department of the Environment

January 12, 2008

Dr. James L. Hoff, DBA

TEGNOS Research, Inc

3575 Seminole Dr. 609 Post Way

Carmel, IN 46032 Tubac, AZ 85646

Tel 317-679-1542

www.tegnos.org

UNDERSTANDING THE BUiLDING ENVELOPE

“
g 

, but these technologies have not yet been tested and demonstrated on a large scale, especially in the Northeast United States.

• Although the CARB model rule is described in the preamble of the OTC Model Rule to be a “reasonably available control technology,” the CARB rule was developed in a region of the United States with climatic and economic factors that may differ significantly from the Northeast United States.

• Many of the adhesives developed by the roofmg industry to meet the requirements ofthe California-based model rule were also developed to be effective primarily within the climatic and market conditions that occur in

California; and some ofthese conditions differ significantly from conditions and practices in the Northeast.

• The average temperature differentials between the California and Maryland during the late fall, winter, and early spring, are very different with average temperatures for the Maryland cities declining and dropping below 40°F.• Alternative technologies carry cost penalties between two and four times the cost of current high-VOC bonding adhesives. Although cost may not be an overriding consideration in view of the larger mission to reduce the environmental impact of VOCs, this cost differential must be considered in terms of its past effect in restricting research and new product development.

• Roof membrane bonding adhesives may also be formulated using low-VOC solvents, including acetone and

water. Because these solvents do not volatize at low temperatures, their operating range is typically limited to

temperatures consistently at or above 40°F.

• Because of differences in application skills and methods, any abrupt change made by the roofing contractor community could increase the risk of compromised roofing installations and roofing-related construction litigation.

• Because low temperature extremes at the beginning and the end ofthe Northeast ozone season may frequently fall below the optimal operating range for low-VOC roof bonding adhesives, and because the commercial roofing industry in Maryland has yet to implement an extensive education and training program for its 20,000 workers, it would be reasonable to further provide a transitional period that would temporarily allow the use of high VOC adhesives during the critical months at the beginning and end of the ozone season.

• It is interesting to note that a similar two-season approach has already been proposed for the asphalt paving industry in the state of Connecticut.

Recommendation:

• Use the Proposed Connecticut Asphalt Paving Rule as a Model for Commercial Roofing in the Northeast which is

a two-season approach.

• Provide a Transitional Period for Roofmg Contractors to Adapt to Low-VOC Adhesives.

Year: 250 p / I Required Durinp:

2009 July through August

2010 June through September

2011 May through September

• Develop a Reliable and Effective Industry-Sponsored Program to Assure Compliance with a Seasonal Approach.

For a copy of the full report, please contact the EPDM Roofing Association at 301-654-5090.
The Low-Slope Commercial Roofmg Industry in the Northeast United States and

the Ozone Transport Commission Model Rule for Adhesives and Sealants:

A Study of Risks and Options for Effective Implementation

Prepared for the

EPDM Roofmg Association

For submission to the

Maryland Department of the Environment

January 12, 2008

Dr. James L. Hoff, DBA

TEGNOS Research, Inc

3575 Seminole Dr. 609 Post WayCarmel, IN 46032 Tubac, AZ 85646

Tel 317-679-1542

www.tegnos.org

rrn

UNDERSTANDING THE BUILDING ENVELOPE ‘V
Page

1. INTRODUCTION 3

2. STUDY OBJECTIVES 5

3. ANALYSIS 6

A. VOC Reduction in Roofing Systems: Technology Review

B. Climatic Factors: California v. Northeast U.S.

C. Product Usage Factors: California v. Northeast U.S.

D. VOC Emissions and Commercial Roofmg Adhesives

4. OVERALL RISK ASSESSMENT 14

A. Wind & Storm Risks

B. Training & Performance Risks

C. Seasonal Work Disruption and Uncertainty

5. CONCLUSIONS 16

6. RECOMMENDATIONS 18

Copyright 2007 TEGNOS Research, Inc.

2
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mit

the VOC content ofspecified adhesives, sealants and primers sold in the state, and 2) use

restrictions that apply primarily to commercial/industrial applications. The OTC Model

Rule was published by the OTC in 2007, with the stated goal of adoption and

enforcement by individual states and local pollution control districts on or before January

1,2009.

The OTC Model Rule is essentially identical to a similar model rule published by the

California Air Resources Board (CARB) in 1998. In the years 1998-2001, the provisions

ofthe CARB rule were adopted in regulatory form by various air pollution control

districts in the state ofCalifornia. Although the CARE model rule is described in the

preamble ofthe OTC Model Rule to be a “reasonably available control technology,” the

CARE rule was developed in a region of the United States with climatic and economic

factors that may differ significantly from the Northeast United States. In addition, these

climatic and economic factors may have a significant influence on the effectiveness andoverall impact of the OTC Model Rule on the environment and economy of the Northeast.

The commercial low-slope roofing industry may provide an important example of how amodel rule based on the climatic and market demands of California may adversely impact

such a rule’s effectiveness in other areas ofthe country. Although it accounts for a

relatively small portion ofthe larger economy within the Northeast United States, the

commercial roofing industry provides a vital service to assure public safety and support

commerce. By assuring the weather-tight integrity of buildings, properly installed and

maintained commercial roofs protect the public from damage from storms and minimize

long-term health problems associated with mold and other problems associated withleaky roofs. And by developing application technologies that can be utilized throughout

the entire year in the Northeast United States, commercial roofers enable the larger

commercial construction industry to operate on a year-round basis.

Unfortunately, many ofthe adhesives developed by the roofing industry to meet the

requirements ofthe California-based model rule were also developed to be effective

primarily within the climatic and market conditions that occur in California; and some ofthese conditions differ significantly from conditions and practices in the Northeast. As an

example, the adhesives used to secure modern roofing membranes to the roof surface(“bonding adhesives”) are generally effective and can only be applied when ambient air

temperatures are at or above 40°F and rising. While average minimum daily temperatures

in California usually exceed the 40°F minimum, this temperature is generally not

available in the Northeast for many fall, winter and spring months. As a result, the

conditions that currently allow the commercial roofing industry to provide safe and

3
Because of concerns regarding the overall impact ofthe OTC Model Rule, several

organizations representing the commercial roofing industry have commissioned this

study of the OTC Model Rule and its impact on commercial roofing in the Northeast.

4
y 

y 

Model Rule as it applies to the commercial roofing industry.

C. Identify and quantify and potentially significant adverse effects ofthe OTC Model

Rule and commercial roofing in regard to commerce and public safety in Northeast

states.

D. Identify possible options that may maximize the effectiveness ofthe OTC Model

Rule to reduce roofing-related VOC emissions in Northeast states while also

maintaining the effectiveness ofthe roofing industry to perform its role of protectingthe public and promoting commerce.

5
2) bonding adhesives used to bond the surface ofroofing membranes to roofsubstrates and walls, and 3) sealants used to seal edges and terminations ofroofing membranes to walls and roofprojections. Ofthe three VOC product categories, two categories already employ low-VOC (less than 250 g/l) formulations throughout the United States and North

America. In the case ofsplice adhesives, almost all single-ply roofing seams are currently mated using either 100% solids tapes (in the case ofEPDM or rubber roofing materials), heat-welding (in the case of PVC / TPO or thermoplastic roofing materials), or hot asphalt (in the case of traditional asphalt and modified bitumen roofing materials). In the

case ofsealants, low-VOC, 100% solids products are both widely available and widely used throughout North America. Given the widespread use of low-VOC splicing and sealing technologies, the remaining category of bonding adhesive appears to be accountable for the overwhelming majority of VOCs produced in commercial roofing. This is due to both the current typical high-VOC content ofthe adhesives as well as the

overall quantity ofroofsurface area requiring bonding as compared to the relatively small areas requiring panel seaming and edge sealing.

The amount of VOCs generated by bonding adhesives may vary with the type ofroofing system and the type of adhesive employed. In the case of asphalt roofing membranes, hot asphalt is the predominant adhesive, either applied with a mop to the membrane surface

or derived from the membrane using a roofing torch. In the case ofsingle-ply membranes, the predominant adhesives are contact adhesives that are sprayed or roller- applied to both the membrane surface and the roofing substrate. These bonding adhesives

are composed of polymeric resins suspended in a variety ofsolvents. The majority ofthe solvents in single-ply bonding adhesives used today contain VOCs at rates higher than the 250 g/l standard established in the OTC Model Rule. Examples ofthese solvents include toluene, hexane and heptane. Because these solvents volatize at relatively low

temperatures, they allow the effective application ofsingle-ply roofing membranes within

a relatively wide temperature range

— from below freezing up to 100°F and beyond. Because of this wide useful temperature range, bonding adhesives using high VOC solvents are the preferred product choice for the commercial roofing contractor.

Roof membrane bonding adhesives may also be formulated using low-VOC solvents, including acetone and water. Because these solvents do not volatize at low temperatures, their operating range is typically limited to temperatures consistently at or above 40°F. In addition, because they tend to vol atize more slowly than high-VOC solvents, they are much more affected by ambient conditions, such as relative humidity and solar shading factors. As an example, a roofing membrane exposed partially to the sun and partially in the shade may “over dry” on the sunlit surface while the shaded surface remains too wet

6
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market. Shipping reports from EPDM Roofing Association (ERA) members indicate thatover 95% of all single-ply bonding adhesives sold in the United States continue to

employ high-VOC formulations. The only region of the country where low-VOC

bonding adhesives currently dominate is the state of California, where low-VOC bonding

adhesives have been mandated since the late I 990s. This would appear to indicate thatcustomer preference will be difficult to change without a mandated regulation. However,

this also suggests that little learning, preparation or adaptation to the special applicationrequirements oflow-VOC adhesives has occurred outside ofmandated regions.The commercial roofing industry is currently working on several technologies that may

reduce the VOC content of bonding adhesives, but these technologies have not yet been

tested and demonstrated on a large scale, especially in the Northeast United States.

Examples of these technologies include polyurethane foams, 100% solids, highmolecular-weight solvents, and thixotropic compounds. These technologies appear tooffer value in addressing the needs of the roofing industry, especially in adapting to theextreme temperature range required for rooftop application. However, each ofthese

technologies also comes with risks that have not yet been fully evaluated. Examples ofthese risks include 1) applicator familiarity and training, 2) long-term durability and

service life, and 3) health concerns with some ofthe chemicals involved.In addition, all ofthese alternative technologies carry cost penalties between two and four

times the cost of current high-VOC bonding adhesives. Although cost may not be an

overriding consideration in view ofthe larger mission to reduce the environmental impactofVOCs, this cost differential must be considered in terms ofits past effect in restricting

research and new product development. Because roofing contractors and their building

owner customers have been very reluctant to pay the current cost premiums required by

alternative technologies, roofing manufacturers have been unable to conduct extensive

testing and marketing of these products. Given sufficient development time, however,roofing manufacturers appear to be confident that a successful transition can be made

from today’s high-VOC bonding adhesives to new low-VOC alternatives that can

successfully address cold temperature applications.B. Climatic Factors: California v. Northeast U.S.

A comparison of climate between California and Maryland indicates both similarities and

contrasts. Figure 1 compares average monthly minimum and maximum temperature

between cities in southern California (Los Angeles), northern California (Oakland),

coastal Maryland (Baltimore), and inland Maryland (Hagerstown).

7
::

30 Ozone Season

20 (Northeast US)

10

Jan F.b Mar Apr May Jun Jul Aug Sep Oct Nov 0.0

Oakland, CalifornIa

90

60

40

30 Ozone Season

20 (Northeast US)

10

Jan F.b Mar Apr May Jun Jul Aug S.p Oct Nov D.c

Baltimore, Maryland

30 1 Ozone Season 3

(Northeast US) 20

10

Jan F.b Mar Apr May Jun Jul Aug S.p Oct Nov De

Hagerstown, MD 100

OF

..

E

2

Jan F•b Mar Apr May Jun Jul Aug S.p Oct Nov 0.

Av.rag. High Av.rage Low

Op.ratlng Rang. of VOC-Compliant SIngi.-Piy Rooflng Gondlng Adh.aiv. under OTC Mod.) Ru). (<250 gm / I)

8
range for currently available VOC-compliant membrane bonding adhesive technologiesmentioned previously. It should be noted that the period from May through September,

when average temperatures for the Maryland cities fall within the range of current VOC

compliant bonding adhesive technology, coincides with the “Ozone Season” for the

Northeast United States as defined by the Ozone Transport Commission.

The average temperature differentials between the two states increases further, however,

during the late fall, winter, and early spring, with average temperatures for the Maryland

cities declining and dropping below 40°F. During the months from November through - March, average temperatures for the Maryland cities are either well below or barely at the

minimum operating temperatures required for current VOC-compliant roofing membrane

adhesive technology. It should be noted, however that the period from October through

April, when average temperatures in Washington drop below the range of current VOC

compliant bonding adhesive technology, falls outside the “Ozone Season” for the

Northeast United States as defined by the Ozone Transport Commission.

9
100

80

e

40

20

0

-20

100

80

€0

4020

0

-20

Jan F.b Mar Apr May Jun Jul Aug S.p Oct Nov 0.0

Hagerstown, MD

Jan F.b Mar Apr May Jun Jul Aug Sap Oct Nov D.c

R.cord High R.ccrd Low

... Op.r.tlng Rang, of VOC-Compliant Singl.-Piy Roofing Bonding Adh.siv. und.r

OTC Moda4 Rul. (250 gm I I)

Even during the most extreme events recorded, the high and low temperatures in theCalifornia cities still fall within the operating range for currently available VOC

compliant membrane bonding adhesive technologies throughout the entire year. In

Maryland, however, the designated “ozone” months of May and September, whichappear to be hospitable to low-VOC bonding adhesive in terms of average temperatures,

may frequently experience low temperatures well below the 40°F minimum for

successful application of low-VOC bonding adhesives.

rn

—

:::::::.

—

::::::::..::.:::.:.:

—

Ozen• S.aaon

-7 (North.ast US) -:

—

—----:

-

L

10
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more and

more gallons of gasoline from every barrel of oil. As a consequence, the asphalt

remaining at the “bottom ofthe barrel” contained fewer plastic elements and became

more brittle. Increasing concerns about the health hazards of asbestos exerted a similar

effect on roofing felts, as asbestos was replaced with weaker organic materials. The oilembargo also increased concerns about energy conservation, driving up the thickness of

roofinsulation. As roof insulation thickness increased, the overlying asphalt roof

membrane became isolated thermally from the remainder ofthe building. As a result ofthis “thermal isolation,” the roofing membrane became subject to increasing temperature

swings from solar heating during the day and freezing temperatures at night. Frequently,

the embrittled asphalt and the weakened roofing felts frequently were unable to

accommodate the thermal movement produced by these temperature swings.

Starting in the 1 970s single-ply roofing membranes made from rubber and plastic

materials began to supplant traditional flat asphalt roofing. In place ofredundant layers

of felts, these materials provided a single, monolithic waterproofing layer. And instead of

hot asphalt, single-ply membranes were frequently attached to the roofing substrate with

contact adhesives. During the 1 980s, sales ofsingle-ply membranes began to accelerate,

driven by the growth of one type ofmembrane in particular: EPDM, or rubber roofing.

By the end ofthel98Os, annual sales of EPDM roofing membranes had grown to over

one billion square feet, or approximately 1/3 of the entire low-slope commercial roofing

market in the United States.

2) Regional Market Differences. The strong growth of EPDM roofing was not uniform

throughout the United States, however. In regions with infrequent freezing temperatures

such as the West and Southwest, asphalt materials continued to dominate. However, in

regions with frequent freezing temperatures such as the Midwest and Northeast, EPDM’s

share ofthe commercial roofing market exceeds its 33% national average. The trendstarted in the 1980s continues to be demonstrated today in industry shipment statistics.Figure 3 compares the market share of EPDM, asphalt, and other single-ply (PVC &

TPO) roofing membranes for the state of Maryland as compared to California in 2006.

11
69%

46%

29%

In the state of California in 2006, EPDM roofing accounted for only 2% oftotal lowslope roofing installations, as compared to 69% for asphalt membranes. However, in

Maryland the ratio is significantly different, with EPDM membranes accounting for over

1/3 of all roofing projects. Looking at the current mix ofroofing materials used in

Maryland and California, the data suggests that product preferences are influenced by climate. In Maryland, where temperature swings and freeze-thaw cycle are intense, the

high flexibility ofrubber roofing appears to be a significant consumer choice to avoid

premature roof failure due to cracking or splitting.

3) Regional Training / Experience Issues. Regardless of the factors behind the

differences in product choice between California and Maryland, the fact that rubber

roofing, which is a major product of choice in Maryland, has been rarely used in

California may bring into question the OTC assumption that the experience of the

California market provides a “reasonably available control technology” that can be

immediately implemented in either Maryland or the Northeast. Although Maryland is much smaller in terms of area and population, every year over 22 million of EPDM roofs

are installed as compared to only 3 million square feet in California. Because of the

paucity of EPDM installations in California, it takes over 7 years of roofing experience

New Jersey

EPDM fPVCITPO Asphaltic

12
contractors, little or no formal training on low-VOC adhesives has yet been undertaken.

In addition, shipment records of members ofthe EPDM Roofing Association indicate that

fewer than 1000 gallons oflow-VOC bonding adhesives are shipped annually to

Maryland— indicating that Maryland contractors and their crews have little or no

experience with low-VOC adhesives at this time.

The lack of contractor training and experience with low-VOC bonding adhesives is

particularly worrisome since the total number ofroofing workers involved in roofing

installation is relatively high. The consensus ofroofing contractors contacted and

interviewed for this study indicates that approximately 20,000 workers may be involved

in roofing applications in Maryland annually. In addition, the contractors report high

turnover rates that may increase this number, especially in terms oftraining needs.

13
wind design category of 70 miles per hour. In contrast, many areas ofthe Northeast fallwithin a much higher wind speed of 90 to 100 miles per hour, with even higher wind

speed considerations along Atlantic coastal areas.

Figure 4: Building Code Design Wind Speeds in the United States

(Source: Uniform Building Code)

In addition to higher design wind speeds, the consequences of wind-related roofing

failures may be much more severe in the Northeast, where almost all extreme winds areassociated with the cyclonic storms and hurricanes that may drop as much as 12 inches of

water in a single day. As a result, what might be a minor wind incident during a hot“Santa-Anna” gust in California may be a major disaster causing extensive building

damage compromising occupant safety during a significant wind and rain event inMaryland.

B. Training & Performance RisksAlthough roofing accounts for only about 6% ofthe total cost of a building, the National

Roofing Legal Resource Center reports that roofing problems account for over 25% of all

0

Fio.4 mc LkwoRiI Buwtic Cooc

USED W FIN PERMISSION

70 Miles per hour

• 80 Miles per hour

) 90 Miles per hour

• 100 Miles per hour

a iio Miles per hour

• 120 Miles per hour

CoLOR v Ti-n ssruCrER

14
Because of differences in application skills and methods, any abrupt change made by theroofing contractor community could increase the risk of compromised roofing

installations and rooting-related construction litigation. If roofing contractors inMaryland and the Northeast were to decide to return to a greater reliance on traditional

asphalt systems in order to minimize their risk, they would have to re-train a workforce ofapproximately 20,000 roofing crew members to re-gain the traditional skills associated

with applying and controlling hot asphalt. Ifthe roofing contractors decide to stay with

EPDM systems and immediately embrace low-VOC bonding adhesives, the same 20,000

crew members will again need extensive training to assure the proper application of anadhesive system little-used and little-understood in the Northeast.

C. Seasonal Work Disruption and Uncertainty

With the exception of extreme snow and ice conditions, roofing work in Maryland and

the Northeast continues throughout the year regardless ofthe season. Ifroofingcontractors are forced to move too quickly to low-VOC bonding adhesives that are

unsuitable for application at temperatures close to or below 40°F, it is likely that roofing

— crews will be unable to work at all during the late fall, winter and early spring. In

addition, even during the late spring and early fall, unsuitable daily temperatureconditions may occur at a frequency that may make it unprofitable for roofing contractors

to assemble and maintain crews available for work even on days when temperatures are

favorable. This situation may not only increase unemployment among roofing crew

members, but the disruption might spread to the entire commercial construction industry,

as partially completed building sit empty and exposed to the weather until temperatures

were suitable to install roofing materials.

15
gy 

overly compromising current roofing practice. And during the colder seasons of year

when ozone formation is not a concern, traditional higher VOC adhesives could still be

made available. Accordingly, a two-season approach may offer an effective optimization

of the competing goals of VOC reduction and effective roofing practice.

It is interesting to note that a similar two-season approach has already been proposed for

the asphalt paving industry in the state of Connecticut. In a public hearing May 1, 2007, a

draft amendment for Subsection (k) of Section 22a-174-20 ofthe Regulations of

Connecticut Agencies was reviewed at a public hearing. This amendment, proposed for

implementation January 1, 2009, calls for a restriction on high-VOC asphalt productsduring the period from May 1 through September 30 of each year, with no restriction on

these products during the remainder ofthe year. The amendment also contains specific

requirements regarding the record-keeping necessary to assure the effective

implementation of such a two-season strategy. Specifically, the draft amendment for

asphalt paving requires that all manufacturers, sellers, and contractors using asphalt

paving materials to maintain and make available records oftest, formulation, and usage

data, and any other information necessary to determine compliance with the amendment

for a period offive years. In addition, the proposed amendment includes a procedure to

be followed by members ofthe paving industry in the event an exception to the

amendment is required due to special circumstances, such as extreme cold conditions.

Although the two-season proposal for asphalt paving may serve as an example for a

similar approach for commercial roofing, there are several differences between the two

industries that may require minor modification ofthe proposed asphalt paving rule to

adopt it to the roofing industry. The first difference involves the relative maturity of low

VOC technology for paving materials as compared to roofing materials. In the same

public hearing mentioned previously, the hearing officer stated that the technology of

low-VOC asphalt was well-developed and that the industry was experienced with

application differences:

“Emulsified asphalts (Ed: Low-VOC technology) have been proven to perform at

least as well as cutback asphalts (Ed: High-VOC technology) for all purposes

during the ozone season. We recognize that during the I 980s there were problems

with emulsified asphalts. Since that time there have been improvements in the

technology and most applicators have become comfortable with the differences in

application between cutback and emulsified asphalt. Additionally, asphalts that

comply with this amendment have been in use and demonstrated to be

16
reasonable basis for regulation of bonding adhesives within the commercial roofing

industry. In order to align the requirements for the commercial roofing industry with the

proposed rule for the paving industry, the OTC Model Rule for Adhesives and Sealants

should be revised so that the 250 gil maximum for “Single-Ply Roof MembraneInstallationlRepair” is required only during the ozone season months of May through

September.

B. Provide a Transitional Period for Roofmg Contractors to Adapt to Low-VOC

Adhesives.Because low temperature extremes at the beginning and the end ofthe Northeast ozone

season may frequently fall below the optimal operating range for low-VOC roof bondingadhesives, and because the commercial roofing industry in Maryland has yet to

implement an extensive education and training program for its 20,000 workers, it would

be reasonable to further provide a transitional period that would temporarily allow the use

of high-VOC adhesives during the critical months at the beginning and end ofthe ozoneseason. This approach would allow commercial roofing contractors to first train theircrews during the optimal months ofthe ozone season, and then extend this experience

into the less optimal months. Specifically, it is recommended that the 250 g / 1 maximum

for “Single-Ply RoofMembrane Installation/Repair” be phased according to thefollowing schedule:

Year: 250 /1 Required Durin2009 July through August

2010 June through September

2011 May through September

C. Develop a Reliable and Effective Industry-Sponsored Program to AssureCompliance with a Seasonal Approach

The manufacturer members of the EPDM Roofing Association are responsible for the

shipment of almost all rubber roofing membranes and over 90% of all rubber roofing

bonding adhesives in the Northeast United States and Maryland. Given the broad

involvement of the members ofthis trade association in the sale and delivery of rubberroofing adhesives, it would be reasonable to call upon them to act through their tradeassociation to provide a reliable and effective program to assure that high-VOC adhesives

18
p

stockpiling prior to the start of the ozone season. This limitation could be based

on historical shipment records along with a reasonable percentage increase for market growth. In the event that a very large roofing project requires an unusual quantity of adhesive during this period, an exception program could be established to assure and verify that the adhesives are intended for specific identified projects scheduled to be completed prior to the beginning of the ozone

season.

3. A reporting program to verify that all customer stocks of high-VOC adhesives have been used prior to the beginning of the ozone season, or that any remaining stocks are safely stored until the end of the ozone season or returned to the

manufacturer for disposal or re-shipment to areas of the country where high-VOC adhesives are permitted during the summer.

4. A reporting program to provide the Maryland DEP with annual shipment information and VOC content of all rubber roofing adhesives shipped into Maryland.

5. A requirement that all manufacturers and marketers ofrubber roofing systems participate in the industry program in order to be eligible to ship high-VOC adhesives into Maryland, along with a requirement that the industry program be available to all manufacturers and marketers ofrubber roofing systems regardless ofmembership in the industry trade association.

0

19
Performance Council for Constructed Roofing Systems.

20
-.1 )