Maryland Department ofthe Environment

1800 Washington Boulevard, Suite 730

Baltimore, Maryland 2 1230-1720

Reference: 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” roofmg systems have been installed in the state of Maryland accounting for 35% of all low-slope commercial roofing 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 of Maryland is based on a number offactors, 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 of service.

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 ofthe year. Because of the lack of effective low-VOC installation technology during the early spring, late fall and winter months, ERA recommends a seasonal approach to VOC regulation, requiring low-VOC

adhesives during the warmer “ozone season” months while continuing to allow high-VOC adhesives during the colder months outside ofthe ozone season. Documentation for this seasonal

approach is provided in the January 12, 2007 research report titled, “The Low-Slope Commercial Roofing 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” conducted by TEGNOS Research, Inc. and attached for your review.

In an effort to help assure that such a seasonal approach will maximize the reduction of VOCs

during the ozone season and reduce concerns that high-VOC adhesives might inadvertently be used during the warmer, ozone-prone months, the EPDM Roofing Association (ERA) proposes that an industry-sponsored program be implemented. The manufacturer members ofthe EPDM

Roofing Association are responsible for the shipment of almost all rubber roofing membranes

7315 Wisconsin Aye, Suite 400 East, Bethesda, MD 20814 • 301.654.5090 • Fax: 301 951.8401 • www epdmroofs. org

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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, or b) any remaining stocks ofhigh

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 roofmg contractors to continue to provide

Maryland building owners with rubber roofing systems and repairs on a year-round basis. Weare also prepared to offer this program to any manufacturer or marketer ofsingle-ply roofing

systems regardless ofmembership in ERA, providing that the manufacturer or marketer bears a

reasonable and proportionate cost ofthis program and complies with the regulations oftheprogram.

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

beginning 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 over20 million square feet ofroofs installed each year in Maryland. These support efforts include

periodic formal training seminars conducted by experienced roofing educators, on-the-roof and

in-shop training sessions conducted by salaried technical representatives of ERA members, andongoing audits and inspections of warranted roofing systems across the state.
In summary, ERA proposes that 1) the seasonal approach to the use of rubber roofing bonding adhesives as recommended in the TEGNOS Research report be implemented by Maryland, 2) an ERA-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 use low-VOC bonding adhesives during the ozone season without adversely affecting the quality of roofing installations in Maryland. We believe this proposal will allow for a significant reduction in roofing-related VOCs while maintaining the year-round availability ofthe most popular commercial membrane roofing system in the state of Maryland. Representatives of our association would be happy to clarify any element of this program and work with you to formally define and implement this compliance program.

,Sincerely,

Director