A NEWERA 1 N ROOFING EPDM ROOFING ASSOCIATION January

16, 2008 Ms. Deborah Rabin Regulations Coordinator,

Air and Radiation Management Maryland Department

of the 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

of factors,

but industry surveys suggest

the most important factor

is the ability

of rubber 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 roof substrates during

the colder months

of the 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

of the 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

of the 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‘andover90%ofallrubberroofingbondingadhesivesintheNortheastUnitedStatesandMaryland.Giventhebroadinvolvementofourmembersinthesaleanddeliveryofrubberroofingadhesives,itwouldbereasonabletocalluponthemtoactthroughtheirtradeassociationtoprovideareliableandeffectiveprogramtoassurethathigh-VOCadhesivesarenotavailableorusedduringthecriticalozoneseason.Keyelementsofthisprograminclude:1.Amoratoriumonshipmentsofhigh-VOCbondingadhesivesbyERAmembersintoMarylandduringthemonthsofMaythroughSeptember.2.Amaximumlimitationonshipmentsofhigh-VOCbondingadhesivesintoMarylandduringthemonthsofMarchandAprilinordertoreducethepotentialforstockpilingpriortothestartoftheozoneseason.ThislimitationwouldbebasedonhistoricalshipmentrecordsofERAmembersalongwithareasonablepercentageincreaseformarketgrowth.Intheeventthataverylargeroofingprojectrequiresanunusualquantityofadhesiveduringthisperiod,anexceptionprogramalsowouldbeestablishedtoassureandverifythattheadhesivesareintendedforspecificidentifiedprojectsscheduledtobecompletedpriortothebeginningoftheozoneseason.3.Areportingprogramtoverifythata)allcustomerstocksofhigh-VOCadhesiveshavebeenusedpriortothebeginningoftheozoneseason,orb)anyremainingstocksofhighVOCadhesiveswillbesafelystoreduntiltheendoftheozoneseasonorreturnedtothemanufacturerfordisposalorre-shipmentoutsideofMaryland.4.AreportingprogramtoprovidetheMarylandDEPwithannualshipmentinformationandVOCcontentofallrubberroofingadhesivesshippedintoMaryland.Webelievesuchaprogramwouldbehighlyeffectiveinrestrictinghigh-VOCbondingadhesiveproductsduringtheozoneseasonwhileallowingroofmgcontractorstocontinuetoprovideMarylandbuildingownerswithrubberroofingsystemsandrepairsonayear-roundbasis.Wearealsopreparedtoofferthisprogramtoanymanufacturerormarketerofsingle-plyroofingsystemsregardlessofmembershipinERA,providingthatthemanufacturerormarketerbearsareasonableandproportionatecostofthisprogramandcomplieswiththeregulationsoftheprogram.Inadditiontosponsoringanongoingprogramtoassurecompliance,ERAalsoproposestosponsorastate-wideworkertraininginitiativetoassurethattheapproximately20,000roofingworkersinMarylandareproperlytrainedintheeffectiveuseoflow-VOCbondingadhesiveproductsduringtheozoneseason,withaparticularemphasisonthetransitionalperiodsatthebeginningandendoftheseasonwhenapplicationoflow-VOCadhesivesmaybedifficult.Becauseover75%ofallcommercialsingle-plyroofingsystemsreceiveawarrantyissuedbythemanufacturer,ERAmembersalreadyareengagedinextensivecontractorsupporteffortsonover20millionsquarefeetofroofsinstalledeachyearinMaryland.Thesesupporteffortsincludeperiodicformaltrainingseminarsconductedbyexperiencedroofingeducators,on-the-roofandin-shoptrainingsessionsconductedbysalariedtechnicalrepresentativesofERAmembers,andongoingauditsandinspectionsofwarrantedroofingsystemsacrossthestate.Building

on these existing training, audit and inspection programs,
ERA proposes

to develop

a comprehensive low-VOC adhesive training program

that can reach

all 15,000 roofmg workers

in Maryland during

the transition period from 2008 through 2010.

As with the long-term industry reporting program,
ERA

is prepared

to offer participation

in this training program

to any manufacturer

or marketer

of single-ply roofing systems regardless

of membership

in ERA, providing

that the manufacturer

or marketer bears

a reasonable

and proportionate

cost
of this program. 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

of the 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