Even though CSA is a fledgling committee in an association with a long history, it has achieved measurable success and has considerable membership. Its mission statement is clear:
"The Caulks, Sealants and Adhesives Committee addresses legislative and regulatory concerns of the industry by establishing positions for this industry segment and by providing direction for NPCA advocacy efforts on behalf of the industry and its products. The committee also assists in the application of existing NPCA goods and services to address industry interests and concerns; maintains liaison with related trade groups, state and federal governments, and the public; and works to develop programs to promote the general welfare of the industry and its products."
The committee, made up of manufacturers, suppliers and distributors of caulks, sealants and adhesives, meets at least three times during the year. A typical agenda contains regulatory items such as the Ozone Transport Commission (OTC) activities and air-district activities in California, along with legislative items and outreach activities designed to initiate action at the state or local level. NPCA staff, both from the Government Affairs and the Environmental, Health and International Affairs Divisions, is available to assist committee members with questions and satisfy committee objectives.
Success Both East and WestThose who are familiar with the NPCA from the paint industry know that it has a strong reputation for government relations and advocacy efforts. Putting this reputation and practice to work for the caulks, sealants and adhesives industry was challenging but has been extraordinarily successful. As is NPCA practice in its advocacy activities, the staff makes the legislative or regulatory effort focus on the technology available to the industry.
Not surprisingly, California initiated the CSA committee with its first challenge. During the latter part of the 1990s, the California Air Resources Board (CARB) along with the Adhesives Committee of the California Air Pollution Control Officers Association adopted its "RACT/BARCT determination" for adhesives.1 NPCA actively participated in several workshops and addressed a myriad of issues such as the VOC limits proposed for contact adhesives and aerosol adhesives; effective dates for certain categories; and the impact of exempt solvents on VOC calculations. While the final RACT/BARCT determination did not adopt all of the suggestions and comments of the NPCA committee, subsequent air districts have adopted many of these changes.
On its heels, CARB quickly followed with amendments to its consumer-products rule, which addressed many of the caulks, sealants and adhesives categories. During the course of the rulemaking, NPCA's CSA committee successfully negotiated with CARB to include additional categories for aerosol adhesives with specific, tailored VOC limits. Committee members and NPCA staff actually drafted and proposed the categories and their VOC limits.
A few years later, the Ozone Transport Commission in its model proposal for consumer products embraced these subcategories and their respective VOC limits. The OTC, established to deal with the transportation of ground-level ozone by natural forces in the Northeast states, includes the District of Columbia and the states from Maine to Virginia. According to a memorandum signed by all of the OTC states, the model rule for consumer products will be adopted by all 13 environmental agencies in the Northeast corridor. Consequently, the advocacy efforts expended in California by the CSA Committee are being richly rewarded since the adhesives subcategories and their VOC limits are now being uniformly adopted in the East.
The final result for the industry is that the regulations that currently exist for caulks, sealants and adhesives are slowly being harmonized. For NPCA member companies, this means that compliance is easier and more efficient.
Other issues that currently face the industry include harmonization of all the air-district rules in California, monitoring the Consumer Product Safety Commission for changes to the child-resistant packaging requirements, and "green building" initiatives launched by several states and municipalities and various EPA activities, which could impact the formulation or packaging of adhesives products.
CSA Committee Expands Industry Labeling GuideWhen the CSA Committee became a reality, NPCA was prepared to apply its existing goods and services to the adhesives industry. The problem, however, is that many of the association's compliance-assistance products were tailored strictly to the paint industry, rather than being general in nature.
Undaunted, committee members and staff immediately began to address this problem by participating in an endeavor to update and expand NPCA's Industry Labeling Guide. After months of workgroup meetings, conference calls, chapter reviews and vetting of sample labels, the Industry Labeling Guide now contains a chapter devoted solely to caulks, sealants and adhesives. This chapter includes sample labels for products ranging from a latex caulk or sealant to a hot melt adhesive to an isocyanate or polyisocyanate adhesive or sealant. In addition to the sample labels, there is also a reference resource for any federal or state regulation that could affect labeling decisions for these products.2
The adhesives, sealants and repair-products industry now has what the paint industry has benefited from for years -- guidance that recognizes the unique properties of these products and is specifically tailored to the industry's needs.
The CSA Committee is growing and becoming more active on issues every day. If there is impact on adhesive products, you should expect to hear from this committee with regard to the magnitude of the impact, the technology that is affected, the status of the technology that is currently in use and the recommended regulatory solution for the industry. Companies who are not members of this committee are missing an opportunity to shape regulations and legislation that impact their day-to-day activities.
- 1 This is also known as the "determination of reasonably available control technology (RACT) and best available retrofit control technology (BARCT) for controlling VOC emissions from the commercial and industrial application of solvent-based adhesives and sealants." RACT/BARCT determinations are developed to aid districts in developing regulations to attain and maintain the state ambient air-quality standards. A RACT/BARCT determination becomes a "model" rule for adoption by the air districts.
2 While this chapter alone will not provide complete guidance for the labeling of adhesive, sealant and repair products, it is designed to address and highlight those chemicals and properties that are unique to these products. It should be used to clarify and supplement the other chapters of the Guide.