Ms. Deborah RabinRegulations Coordinator, Air and Radiation ManagementMaryland Department ofthe Environment

1800 Washington Boulevard, Suite 730

Baltimore, Maryland 21230-1720Reference: Proposed Regulation for Control of Emissions of Volatile Organic Compounds

from Adhesives and Sealants

Dear Ms. Rabin:

Each year for the past decade, over 22,000,000 square feet of EPDM or “rubber” roofing systems

have been installed in the state ofMaryland accounting for 35% of all low-slope commercialroofing installations in the state. Based on industry shipment statistics, no other single roofing

membrane is used as widely in Maryland as EPDM. The preference for EPDM roofing systems

by the building owners ofMaryland is based on a number of factors, but industry surveys

suggest the most important factor is the ability ofrubber roofing to withstand extreme seasonal

temperature swings while providing consistent leak-free performance over decades ofservice.

For commercial roofing contractors in Maryland, the fact that EPDM roofing systems may be

effectively installed on a year-round basis also is an important factor in the pre-eminence of

rubber roofing in the state.

Although the rubber roofing industry has developed low-VOC adhesives and sealants that are

suitable for effective installation during the late spring, summer and early fall in Maryland, there

is no currently available technology that can supplement the need for high-VOC adhesives to

bond the rubber membrane to roofsubstrates during the colder months of the year. Because of

the lack of effective low-VOC installation technology during the early spring, late fall and wintermonths, ERA recommends a seasonal approach to VOC regulation, requiring low-VOC

adhesives during the warmer “ozone season” months while continuing to allow high-VOCadhesives during the colder months outside ofthe ozone season. Documentation for this seasonalapproach is provided in the January 12, 2007 research report titled, “The Low-Slope CommercialRoofing Industry in the Northeast United States and the Ozone Transport Commission ModelRule for Adhesives and Sealants: A Study ofRisks and Options for Effective Implementation”

conducted by TEGNOS Research, Inc. and attached for your review.

7315 Wisconsin Aye, Suite 400E, Bethesda, MD 20814 • 301.654.5090 • Fax: 301.951.8401 • www.epdmroofs.org

roofing adhesives, it would be reasonable to call upon them to act through their trade association

to provide a reliable and effective program to assure that high-VOC adhesives are not available

or used during the critical ozone season. Key elements ofthis program include:

I. A moratorium on shipments of high-VOC bonding adhesives by ERA members into

Maryland during the months of May through September.

2. A maximum limitation on shipments of high-VOC bonding adhesives into Maryland

during the months of March and April in order to reduce the potential for stockpiling

prior to the start ofthe ozone season. This limitation would be based on historical

shipment records of ERA members 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 also would be established to assure

and verify that the adhesives are intended for specific identified projects scheduled to becompleted prior to the beginning ofthe ozone season.

3. A reporting program to verify that a) all customer stocks of high-VOC adhesives have

been used prior to the beginning ofthe ozone season, orb) any remaining stocks of high

VOC adhesives will be safely stored until the end ofthe ozone season or returned to themanufacturer for disposal or re-shipment outside of Maryland.

4. A reporting program to provide the Maryland DEP with annual shipment information and

VOC content of all rubber roofing adhesives shipped into Maryland.

We believe such a program would be highly effective in restricting high-VOC bonding adhesive

products during the ozone season while allowing roofing contractors to continue to provide

Maryland building owners with rubber roofing systems and repairs on a year-round basis. We

are also prepared to offer this program to any manufacturer or marketer ofsingle-ply roofingsystems regardless ofmembership in ERA, providing that the manufacturer or marketer bears a

reasonable and proportionate cost ofthis program and complies with the regulations of theprogram.

In addition to sponsoring an ongoing program to assure compliance, ERA also proposes to

sponsor a state-wide worker training initiative to assure that the approximately 20,000 roofing

workers in Maryland are properly trained in the effective use oflow-VOC bonding adhesive

products during the ozone season, with a particular emphasis on the transitional periods at thebeginning and end ofthe season when application of low-VOC adhesives may be difficult.

Because over 75% of all commercial single-ply roofing systems receive a warranty issued by the

manufacturer, ERA members already are engaged in extensive contractor support efforts on over
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reporting program, ERA is prepared to offer participation in this training program to anymanufacturer or marketer ofsingle-ply roofing systems regardless ofmembership in ERA,providing that the manufacturer or marketer bears a reasonable and proportionate cost ofthisprogram.

In summary, ERA proposes that 1) the seasonal approach to the use ofrubber roofing bonding

adhesives as recommended in the TEGNOS Research report be implemented by Maryland, 2) anERA-sponsored compliance program be established to assure that this seasonal approach is

successful in reducing VOCs during the ozone season, and 3) an ERA-sponsored training

initiative be established to assure that Maryland roofing workers are effectively trained to uselow-VOC bonding adhesives during the ozone season without adversely affecting the quality ofroofing installations in Maryland. We believe this proposal will allow for a significant reduction

in roofing-related VOCs while maintaining the year-round availability of the most popular

commercial membrane roofing system in the state of Maryland. Representatives of our

association would be happy to clarify any element ofthis program and work with you to formally

define and implement this compliance program.

Sincerely,Jared 0. BlumExecutive Director
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