In today’s global marketplace, industries are becoming more aware of the impact that solvents and heavy metals have on employees’ health, the environment, and waste-disposal costs. With global issues such as the Montreal or Kyoto Protocols, recent efforts by the Ozone Transport Commission (OTC) and the new U.S. National Emission Standards regulating hazardous air pollutants (HAPs), one’s business future can easily feel threatened. Keeping up with the changing regulations impacting today’s global businesses - or even simply doing business in the United States - can be a full-time job, especially when considering that the actual regulatory outlook on these issues varies by region. However, with an understanding of the various regulations, as well as the options available for compliance and typical costs, adhesive-processing companies can navigate successfully through the regulation storm.
External RealityFrom conferences to magazine articles, the changing regulation landscape is a hot topic. While Japan’s new restrictions will influence increased use of aqueous technology, solvent-based technology is expected to prevail in the current planning climate in Europe and the United States. Although the rest of the world is simply a mixed bag, solvent-based technology will generally prevail. How are companies dealing with the constant change?
According to a survey conducted by LORD Corp. at the American Chemical Society (ACS) Conference in November 2005, companies are feeling the pressure to respond to these changing regulations. Survey respondents - 23% of whom are in the auto industry, 5% in aerospace and 72% in other industries - cited price pressure due to global competition and environmental regulations (40% and 26%, respectively) as the key issues significantly affecting strategic decisions in today’s rubber industry, followed by employee health and safety (20%), and consolidation within the rubber industry (14%).
What does this mean? In essence, businesses are faced with the decision to install an incineration methodology or convert to products that do not contain solvents known to harm the environment. As part of the survey, companies were asked to comment on their future plans for compliance methods. The results are shown in Figure 1.
Once we understand the manufacturer’s external reality for using rubber-to-metal adhesives, we can all be better positioned to respond to the needs of the industry. As cost pressures continue to drive us to explore alternate locations for manufacturing globally, it seems that we need to approach these opportunities with a focus and understanding of the local regulations for rubber-to-metal adhesive systems.
Japanese Regulations on Air EmissionThe regulatory requirements for VOC emissions from stationary sources, such as industrial facilities using adhesives, have a short history in Japan. These regulations were implemented in 2004 when the Amended Air Pollution Control Law (the Japanese counterpart to the U.S. Clean Air Act) went into effect. The regulatory requirements for specific VOC emission control measures were imposed on the nine specific industrial stationary sources in June 2005. Even though adhesives are identified as one of the sources of VOCs in the regulations, the Japanese adhesive industry as a whole is not required to comply with specific VOC content limits or any operational VOC emission control measures by the VOC regulations, which went into effect in April 2006. Instead, they are subject to an administrative guidance with the Ministry of Economy, Trade and Industry - a powerful federal agency charged with voluntarily reducing the VOC emission from their products and operations by 30% from levels in the year 2000.
In accordance with the guidance, the Japan Adhesive Industry Association (JAIA) - the trade association for the adhesives industry in Japan - produced the VOC Emission Control Guideline in October 2005. This guide, which spells out the voluntary efforts to reduce VOC emissions in the operations of their member companies, sets the VOC emission reduction goal to be achieved by the industry at 17% and 30% by 2007 and 2010, respectively, with Year 2000 VOC emission levels as the baseline. In the guide, the JAIA has selected six chemicals for use reduction based on the identification of major photochemical oxidant generation sources in the industry. These chemicals, in order of photochemical ozone creation potential (POCP), are: xylene, toluene, n-hexane, methylethylkerone (MEK), ethylacetate and methanol. Toluene and xylene are targeted for 30% and 50% use reduction by 2007 and 2010, respectively, while the rest of the VOC chemicals are targeted for 10% and 20% use reduction by 2007 and 2010, respectively. In all, the JAIA aims to achieve a 31% reduction in VOC as solvents by 2010. As such, the JAIA is encouraging its members to develop high-solid adhesives, water-based adhesives and non-solvent adhesives; by doing so, they will reduce the use of VOC. The JAIA will revisit the plan in 2008 for readjustment, if necessary.
VOC Regulations in ChinaIn China, regulatory requirements for VOC emissions from stationary sources, such as industrial facilities using adhesives, have not been established. The Chinese government did enact a state standard for coating products in 2001, which requires the VOC emission from coating products not to exceed 200g/L. However, this standard is more focused on indoor-air quality and protecting people’s health than on environmental protection. Because of growing international interest in environmental protection, the Chinese government has become aware of the importance of proactive measures; however, legislation efforts still fall behind the main focus of economic development.
Because there are no regulatory requirements for VOC emissions for the adhesives industry, we can look to the coatings industry for information. The State Environmental Protection Administration of China’s Coating Industry Pollutant Emission Standard requires VOC emissions to be limited in the new state standard. Enforcement will vary depending on whether the plant was in operation before or after January 2008. Plants established before the law was issued will receive a two- to three-year transition period.
Although VOC emissions control is still not regulated by the Chinese government (and the China Adhesives Industry Association has no action plan to adopt any such regulations), it is likely that the Chinese government will pay more attention to VOC emissions control in the future as international pressure to conform increases.
VOC Legislation in EuropeIn contrast, Europe’s regulations for VOCs are source-specific, which theoretically allows every source to negotiate with their local government. The European Commission (EC) Council Directive 1999/13/EC limiting the use of organic solvents in certain activities, amended by EC Directive 2004/42/CE, affected the use of organic solvents in certain paints, varnishes and vehicle-refinishing products.
In essence, there were no changes to the maximum VOC limits specified; rather, the initial objective of the 1999/13 VOC Directive was to ensure the phasing out of solvents that were classified as carcinogens, mutagens or toxic to reproduction under Directive 67/548/EEC. The solvents targeted were chlorinated solvents such as trichloroethylene. The emission limit of 50 mg carbon per cubic meter of air refers to existing installations that operate abatement equipment that complies with the following emission limit values: 50 mg C/m³ in the case of incineration and 150 mg C/m³ in the case of any other abatement equipment. In the latter case, the installation is exempt from the waste gases emission limit values in the table in Annex IIA for a period of 12 years after the date referred to in Article 15, provided the total emissions of the whole installation do not exceed those that would have resulted had all the requirements of the table been met. Finally, all EC member states should have implemented legislation to enable compliance with the Solvent Emissions Directives to include the submission of information to the commission on the implementation of the directive in the form of a report every three years.
Restriction of Hazardous Substance in Environment (RoHS)Although it has no direct impact on VOC emissions in the rubber-to-metal marketplace, the RoHS Directive, which stands for “the restriction of the use of certain hazardous substances in electrical and electronic equipment,” has far-reaching impact on the raw materials often used to formulate rubber-to-metal adhesives. This directive bans the placement of new electrical and electronic equipment containing higher-than-agreed-upon levels of lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyl (PBB), and polybrominated diphenyl ether (PBDE) flame-retardants. The RoHS Directive and the UK RoHS regulations went into effect July 1, 2006.
OTC RACT Rule in North AmericaHigh concentrations of ozone continue to impact air quality in a number of regions throughout the United States, resulting in a changing regulatory landscape in the rest of North America as well. The EPA regulates six common air pollutants that are found in the air throughout the U.S. under Title I of the Clean Air Act: ozone, carbon monoxide, total suspended particulates, sulfur dioxide, lead, and nitrogen oxide. These pollutants can injure health, harm the environment and cause property damage. (The EPA calls them “air pollutants” according to its health-based criteria [science-based guidelines], which serve as the basis for setting permissible levels.) Ozone is of particular interest to the chemical industry because it is formed by the complex interaction of VOC with nitrogen oxide in the presence of sunlight.
The EPA is taking a range of national actions that will help specific areas of the country significantly improve ozone air quality. For example, reducing the Regional Transport of Ozone (RTO) and ozone precursors (including nitrogen oxides, or NOx) is necessary to help certain states attain the health standards for ground-level ozone (smog). Both the OTC and Lake Michigan Air Directors Consortium (LADCO) are examples of multi-state organizations created under the Clean Air Act with the express purpose of advising and working with the federal EPA on transport issues. These groups are responsible for developing and implementing regional solutions to the ground-level ozone problem in the Northeast and Mid-Atlantic regions, as well as the regional haze problem in the Midwest.
After significant rule-making activities in the Architectural Industrial Maintenance (AIM) and Consumer products areas, the OTC (a consortium including the northeastern states) is now targeting VOC emission limits on a range of industrial adhesive categories. Because of limited resources, the commission has chosen to adopt the California RACT/BARCT document, which was finalized in 1998. Ultimately, the intent of the OTC is to provide states a guidance document that can be either directly promulgated as a state rule or adopted with some minor modification. However, in the interim, the rule enacted applies to any person (entity) who supplies, sells, offers for sale or uses adhesives, sealants, or adhesive or sealant primers. This statement generally extends compliance to manufacturers as well as users. A “prohibition of sales” clause applies to products that are supplied or sold to persons within the OTC states.
Further, the directive states that users cannot use any solvents with a composite vapor pressure of less than 45 mm Hg at 20°C, like toluene, to clean up adhesives, sealants, or adhesive or sealant primers from surfaces other than spray-application equipment. Also, a solvent used to clean, flush or soak filters, flush lines, pipes, pumps and other parts of application equipment must be used in an enclosed cleaning system, or the solvent must have a VOC content of 70 g/L of material or less.
While there are exemptions for containers of 16 fluid ounces or less and total annual usage of adhesives and clean-up solvents less than 55 gal per calendar year, in order to use the latter, the users must first notify the Executive Officer of the State in writing.
Current Options for End UsersThere are currently three options that can be used to address the aforementioned regulations: incineration to maintain solvent chemistry; process conversion to aqueous chemistry; and substitution with low-HAPs solvent chemistry.
Incineration is the leading option for customers who place a high priority on maintaining their current process and warranty risk, as well as have the scale to invest in incineration. It is predicted that increased environmental constraints in North America and the EU will drive the marketplace toward a contract coater market. The investment hurdle for incineration is minimized due to the scale of a contract coater operation. Some tier manufacturers may avoid the cost of implementing incineration by outsourcing the coating process. Contract coaters in the U.S. and EU generally understand that their investments in incineration represent a key plank in their value proposition. While the price of solvent and its performance provides the most attractive option for end-users who have the scale to invest in incineration (e.g., large custom coaters), it is generally accepted that the long-term viability of solvent systems is unknown and requires more review.
The second option for using aqueous adhesives does not have a clear cost-benefit profile in light of other options. The cost-in-use economics and performance of current aqueous adhesive offerings do not provide the incentive needed for a broad market switch in the absence of environmental regulatory drivers. However, at this time aqueous products are the only commercially viable solution to address and/or eliminate VOC, HAP and CO2 emissions resulting from adhesive application.
The third option for using low-HAP products may be a short-term solution for U.S. manufacturers. The EPA has limited the use of specified “HAP solvents” in current rubber-to-metal adhesives. Albeit more costly, substitute solvents, most of which are still considered VOCs, have allowed rubber-to-metal adhesive manufacturers to meet this current regulatory challenge, but it is not known how long this type of approach will serve its purpose before a more restrictive regulatory position is adopted by the U.S. government.
About LORD Corp.With headquarters in Cary, NC, and sales in excess of $630 MM, LORD Corp. is a privately held company that designs, manufactures, and markets devices and systems to manage mechanical motion and control noise and vibration; formulates, produces and sells general-purpose and specialty adhesives and coatings; and develops products and systems using magnetically responsive technologies. With manufacturing in nine countries and offices in more than 15 major business centers, the company employs more than 2,400 worldwide.
For more information, visit www.lord.com.
SIDEBAR: LORD Corp.'s Response to the Changing Global MarketplaceAs a manufacturer and user of a line of solvent-based industrial adhesives for rubber-to-metal bonding, LORD Corp. is uniquely positioned to understand and respond to concerns with respect to these and other changing environmental regulations. A leading supplier of adhesives for more than 50 years, we are working with a variety of global organizations to lead the efforts toward environmental stewardship. Building on a strong commitment to technology leadership, the company has adopted a three-pronged approach towards addressing the environmental concerns of the marketplace:
- We have developed a line of products with non-HAP solvents. These products are acceptable replacements for current high-HAP, solvent-based products and offer customers a way to reduce their current level of solvent emission.
- We have has developed a line of aqueous-based adhesives that are replacements for many of our solvent-based systems.
- Our process knowledge allows us to work with customers to design and optimize applications systems that reduce overall emissions.
The table (see inset) details details three options typically presented to customers in today’s marketplace. When a company is considering a long-term outlook, aqueous systems can be a viable option. Obviously, it is important to understand the cost drivers in order for a company to make a sound business decision.
Building on 50 years of experience in the industry, LORD has developed this decision-making matrix and assessment for customers by using a cost benefit technique. The proven combination of industry experience and this technique enables LORD to work with customers to generate meaningful assessments of their production system(s) and select a technology that optimizes their processing options in light of emerging regulation situations.
Today, the choice of method to reduce VOC emissions is not an obvious one. With technology and global markets changing rapidly, one must continue to focus on these situational issues to remain current. Solvent-based chemistry seems to provide the most straightforward path for best value-in-use economics from an end-user perspective. However, the choice is a strategic business decision and can best be made by involving senior production and business management from the original equipment manufacturer.