New VOC Regulations Threatened the Quality of Roofing Assemblies until the Roofing Industry Became Involved

Ellen Thorp, associate executive director of the EPDM Roofing Association, makes it a point to be responsive to the many inquiries she gets. Most deal with routine requests for information about EPDM, but one phone call Thorp fielded six years ago from one of ERA’s member companies stood out from the rest. Ultimately, it changed the way ERA and the roofing industry do business.

A manufacturer’s rep had heard from a customer in Connecticut that the state was about to implement VOC regulations. The problem: The new regulations would ban some of the adhesives, sealants, and primers essential to installing EPDM and other roofing products, and there were no substitute products available to meet the new standards. If the new regulations went into effect as scheduled, they threatened to negatively impact the safety and quality of roofing assemblies in the affected area and the roofing industry as a whole.

The proposed regulations were part of an effort by the Ozone Transport Commission, or OTC, to achieve federally mandated air-quality standards in the Northeast and Mid-Atlantic. The OTC was created under the Clean Air Act to develop solutions for the New England states, as well as Delaware; Maryland; New Jersey; New York; Pennsylvania; Virginia; and Washington, D.C. At the time of OTC’s creation, most of these states had not attained federally mandated ozone standards, and the region lagged behind other parts of the U.S. in achieving compliance.

As part of its initial work, OTC developed a Model Rule for Adhesives and Sealants, based on regulations used in California, incorporating provisions effective in the climactic and market conditions of that state. At the time of the phone call to Thorp, the OTC had released the model rule, and states were beginning to draft their own regulations that included implementation dates within the next year. “The VOC limits the OTC was proposing would have required products that did not exist in the Northeast and Mid-Atlantic,” Thorp explains. “It was also concerning that they were basing the limits on California regulations. The climate in the Northeast is very different than in California, so we didn’t feel it was good science to be creating a model rule based on a place that had a completely different climate.”

Thorp and the ERA member companies were very interested in working with state regulators. “It certainly is our priority to reduce VOC emissions wherever possible, but it also is important to us to have regulations that our industry could work with and are based on the best available science,” she says. In fact, products that would meet the new regulations were in development but were not yet available. In addition, the new adhesives and sealants would require new or modified application techniques. That meant the roofing industry needed time to train thousands of roofing contractors.

ERA’s first step was to support its assertion that the climate of the Northeast differed dramatically from that of California. ERA hired Jim Hoff of Tegnos Research Inc. to review weather data and the effects the weather has on low-VOC products. “At ERA’s expense, we assembled relevant scientific data and provided it to the state regulators,” Thorp adds.

ERA worked with regulators in each state, sharing the results of its research. ERA provided the state environmental protection and air quality bureaus with detailed information about what sealants were available and explained the time needed to train roofing contractors. Working together, the regulatory bodies and ERA were able to agree on a phased-in or seasonal approach. For instance, in a majority of the states, the new low-VOC products were required initially only in the summer for three months. The year after, they were required for five months. Then, the following year, they were required year-round. Once these states had found success with this approach, others followed suit. “We explained to the regulators the importance of being consistent since many roofing companies do work across multiple states, especially in the Northeast where the states are small and roofing companies are likely to work across state lines,” Thorp notes.

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Roofing Manufacturers and Contractors Embrace Recycling

In the early 2000s, as the green-building movement reached its tipping point, the roofing industry’s contributions to sustainability focused on increasing energy efficiency, improving long-term durability and addressing the heat-island effect. In the years since, significant strides have been made in all three of these areas for commercial and residential buildings.

In recent years, increasing attention has been given to the benefits and challenges of recycling roofing materials at the end of their useful life. This is no trivial task: Owens Corning estimates asphalt shingles alone comprise up to 5 percent of building-related landfill waste. This doesn’t take into account other roofing materials, including EPDM, thermoplastic PVC and metal.

Not surprisingly, rising removal costs, coupled with the growing demand in some areas of the country to legislate landfill content, are putting pressure on contractors and building owners to seek alternatives to traditional roof construction scrap and tear-off disposal methods.

In response, greater numbers of roofing manufacturers and contractors are driving strategies to avoid the landfill. A general review of emerging trends across the roofing industry suggests manufacturers and contractors increasingly are turning to recycling to steer these materials from the waste stream.

Steel is the most recycled material in building construction today. PHOTO: STEEL RECYCLING INSTITUTE

Steel is the most recycled material in building construction today. PHOTO: STEEL RECYCLING INSTITUTE

METAL

Metal roofing’s sustainable attributes are significant. Industry experts cite its ability to improve a building’s energy efficiency, and metal today contains anywhere from 25 to 95 percent recycled material.

On its website, the Chicago-based Metal Construction Association (MCA) encourages installing metal roofing directly over an existing roof, thus eliminating the need to dispose of the original materials. But when an older metal roof or new-construction debris must be removed from a site, contractors and owners in most regions of the country can quickly identify scrap yards that take metal.

“Steel is the most recycled material in building construction today,” says MCA Technical Director Scott Kriner. “There’s an infrastructure that supports it, and metal in general is virtually 100 percent recyclable.” Kriner notes MCA supports recycling as part of the metal industry’s overall commitment to environmental sustainability and transparency in business.

PVC

PVC has been used in roofing systems since the 1960s, and the post-consumer recycling of roof membranes began in North America in 1999—a nice symmetry when one considers roofs in terms of 30-year life cycles.

In general terms, the recycling of PVC roofing is a relatively straightforward process. The material is sliced into long strips, rolled up, lifted off the roof and transported to a recycling center. Recyclers run the PVC through a conveyor system, where fasteners and other metal objects are removed.

Initially, the recovered membrane was ground into powder for reuse in molded roof walkway pads. More recently, some manufacturers have been incorporating a granulated form into new PVC roofing membranes, exclusively on the backside to avoid aesthetic issues with color variations. The first installations of membrane produced with post-consumer recycled composition occurred in the mid-1990s. So far, its field performance has matched that of PVC roofing produced with virgin raw materials.

The Vinyl Institute, Alexandria, Va., says close to 1 billion pounds of vinyl are recycled at the postindustrial level yearly. “The vinyl industry has a history of supporting recycling,” the institute reports on its website, “and this effort continues as companies, alone and through their trade associations, expand existing programs and explore new opportunities to recover vinyl products at the end of their useful life.”

EPDM

Ethylene propylene diene terpolymer is used extensively on low-slope commercial buildings. Yet even this durable synthetic rubber membrane must eventually be replaced, and today recycling is a viable option.

The removal process generally involves power-vacuuming off the stone ballast, where present, to expose the EPDM membrane below. The membrane can then be cut into manageable squares, which are folded and stacked on pallets, loaded onto a truck and transported for recycling. The recycler grinds it into crumbs or powder, depending on the end use. A growing number of recycling centers nationwide now handles EPDM.

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Ballasted EPDM Roof Has Been in Service Since 1979

Rob Nelson is a 44-year-old software consultant who owns a multi-tenant, 137,000-square-foot building in Kingston, Pa. Rob’s dad bought the building in 1985, when it was an abandoned cigar factory and Rob took over management of it in 2002. He considers it to have been a good investment for many reasons. It has attracted a variety of tenants and currently houses about 25 businesses, including small, single-office enterprises, an engineering firm and a home-health nursing business. Rob’s family operates a furniture business and an indoor self-storage facility in the building, as well.

Roof Consultant Mark Sobeck inspects a 35-year-old ballasted EPDM roof on a multi-tenant building in Kingston, Pa.

Roof Consultant Mark Sobeck inspects a 35-year-old ballasted EPDM roof on a multi-tenant building in Kingston, Pa.

Besides its track record of attracting tenants, Rob also values his building for another very important reason: its ballasted EPDM roof has been in place since 1979. If you do the math, that’s 35 years. And Rob’s roofing consultant, Mark Sobeck, based in Wilkes-Barre, Pa., says he can realistically expect his building to get another 10 or 15 years of protection from the roof.

Rob and Mark emphasize that maintenance has been important to the roofing system as a whole. One-third of the original roof has been replaced for reasons not related to the membrane performance, and the flashing and expansion joints have been replaced on the original section of the roof. But the membrane itself, according to Sobeck, is still in great shape. “It’s amazing how the EPDM rubber is still lasting. At thirty-five years, it’s still stretchy and pliable and looks good.”

Nelson’s experience with the longevity of his roof is backed up by in-depth testing by the EPDM Roofing Association (ERA). ERA commissioned studies of five EPDM roofs that had been in use for between 28 and 32 years. The roofs, ballasted and fully-adhered, were first inspected in the field, and then small samples of the EPDM membrane were sent to Momentum Technologies, a testing facility for the roofing industry in Uniontown, Ohio. Five key performance characteristics of the samples were tested: elongation, tensile strength, cross-direction thickness, machine-direction thickness and factory-seam strength. The lab results showed that all the samples had physical characteristic properties above or just below the minimum physical characteristics of a newly manufactured 45-mil EPDM membrane. Put another way, after three decades of use, they were performing like new. Roofing experts point out that installation materials and methods have advanced considerably in the last 30 years, giving new roofing systems an expectation of an even longer service life.

A roof that lasts a long time will deliver obvious financial savings to building owners. In an era when environmental benefits must also be considered, experts say that its important to look at sustainability in the broadest possible terms. “If a roof lasts a very long time,” says John Geary, director of Education and Industry Relations for Firestone Building Products and chairman of the board of ERA, “that’s very good news for the environment. Compared to a roof that has to be replaced every 10 years or so, the choice of EPDM means fewer resources are ultimately used in the manufacturing and maintenance of the roofing system. Additionally, EPDM can be recycled, so it also means less materials winds up in a landfill.”

Rob Nelson may not have seen the results of EPDM lab tests, but he sees proof of the durability and longevity of EPDM every time he visits his building. “It’s pretty wild and definitely surprising that we are still kicking along after 35 years,” he says. Given consultant Mark Sobeck’s projections, Nelson can expect another 15 years or so of “wild” service from his EPDM roof.

ERA Challenges LBNL Study about White Roofs

The Bethesda, Md.-based EPDM Roofing Association (ERA) is challenging a study released by Lawrence Berkeley National Laboratory, Berkeley, Calif., which cites white roofs as the most “cost-effective” roofing option over a 50-year time span. The study, published in the March 2014 issue of Energy and Buildings, also calls for the phase-out of black roofs.

“Our members make both black and white roofing membranes. We strongly oppose any recommendation that irresponsibly promotes the use of one of our products over another based on faulty science. We question the validity of this study since it is based on a sample size of only 22 roofs, and we are challenging the conclusions that the authors draw from the data,” says Ellen Thorp, ERA’s associate executive director. “Due to the complexity of roof and building science, prescriptive requirements that limit design choices are not in the best interests of architects, design professionals or building owners.”

To help provide clarity regarding roofing-system choice and refute some errors in the study, ERA convened a panel of experts to review the LBNL science and its conclusions. A complete analysis can be found on the ERA website.

Overall, the LBNL study was marked by “a systematic failure to understand that roofs are systems, not a single component,” says Thomas W. Hutchinson, AIA, FRCI, RRC, principal of Hutchinson Design Group Ltd., Barrington, Ill., an internationally recognized expert on roof system design and a Roofing editorial advisor. “Additionally, the study completely ignored
ballasted EPDM systems that, in other studies, have proven to be the roof system that provides the greatest service life and energy savings. To suggest that a comparatively ‘new’ roofing material will have a longer service life than EPDM, a material proven to last over 30 years, is naïve.”

“Our members—Firestone Building Products, Carlisle SynTec Systems and Johns Manville—have a vested interest in providing accurate information to our customers,” Thorp adds. “Their knowledge is based on marketing, installing and maintaining thousands of roofing systems. We hope that architects, specifiers and roofing consultants will continue to rely on their field-based knowledge about the comparative costs and effectiveness of roofing systems, rather than on flawed science based on flimsy and biased data.”

Benjamin Mandel, a research assistant in the Heat Island Group at LBNL and an author of the LBNL study, recently responded to ERA’s remarks on Today’s Facility Manager’s website.
Read Mandel’s reaction at bit.ly/1hcD0HR.

ERA Recommends EPA Base Procurement Guidelines on Assessed Risk

The EPDM Roofing Association (ERA) is recommending that the EPA base proposed environmental performance guidelines on “assessed risk” of referenced chemicals, rather than on the concept of “intrinsic hazard”. In comments to the EPA on its proposed Draft Guidelines for Product Environmental Performance Standards & Ecolabels for Voluntary Use in Federal Procurement, ERA stated, “The concept of “intrinsic hazard” as used in the draft neglects the importance of overall risk assessment as the best approach to identifying potential and actual environmental or human health danger of a product. Taken as a whole, the potential for product exclusion within broad hazard-based protocols may be significant for many segments of the building material industry.”

The ERA comments cite a broad range of widely used building products that could be excluded from the marketplace if the proposed guidelines are implemented.

“We applaud the EPA for incorporating the expertise of impacted industries as they establish environmental standards,” said Ellen Thorp, Associate Executive Director, EPDM Roofing Association. “It’s vitally important that we review all of the consequences – intended and unintended – of these proposed guidelines. Roofing professionals who have extensive field experience with these products can provide uniquely valuable input.”

ERA further praised the EPA for incorporating “consideration of all viewpoints, the requirement for timely response to objections, the opportunity for appeal, and transparency in the development and communication process” in the draft guidelines. ERA underscored that these principles need to be emphasized in green standards development: “Only by doing so can we move green construction from the boutique privilege of a few to the mainstream of the built environment.”

The complete text of ERA’s comments on the Draft Guidelines for Product Environmental Performance Standards & Ecolabels for Voluntary Use in Federal Procurement is below.

ERA Comments Submitted to the EPA on April 24, 2014

The EPDM Roofing Association is the national trade association that represents EPDM roof membrane manufacturers and suppliers to the industry. ERA advances the use of sustainable EPDM roofing systems, while also providing technical and research support to the public and construction industry.

ERA appreciates and supports the development of forward looking standards grounded in the key principles of modern consensus processes. Given the importance of the burgeoning number of proposed green and/or healthy building guidelines and standards, the principles outlined in the EPA draft go a long way to ensuring progress that can be measurable and achievable by the nation’s building industry. The consideration of all viewpoints, the requirement for timely response to objections, the opportunity for appeal, and transparency in the development and communication process, are all key elements of the Draft Guidelines. Without a doubt, these principles need to be emphasized in green standards development, where true consensus processes have too often been ignored or compromised. Only by doing so can we move green construction from the boutique privilege of a few to the mainstream of the built environment.

The only area of concern we wish to comment on involves the concept of “intrinsic hazard” as described in the Section II, # 13, and Footnote 9 of the draft. The concept of “intrinsic hazard” as used in the draft neglects the importance of overall risk assessment as the best approach to identifying potential and actual environmental or human health danger of a product.

Taken as a whole, the potential for product exclusion within broad hazard-based protocols may be significant for many segments of the building material industry. As an example, Healthy Product Declarations (HPDs) for many building envelope products will likely include the disclosure of at least one ingredient alleged to be hazardous by one or more of the “authoritative” lists. The following is a listing of a number of these building envelope products, the alleged hazardous materials they may contain, and the reference list from which the alleged hazard is identified.
• Thermoplastic Roofing Membranes: Titanium Dioxide (California Prop 65)
• Rubber Roofing Membranes: Carbon Black (California Prop 65)
• Asphaltic Roofing and Waterproofing Products: Bitumen (California Prop 65)
• “Cool” (Reflective) Roof Coatings: Titanium Dioxide (California Prop 65)
• Fiber Insulation: Wood Dust (California Prop 65)
• Foam Insulation: Halogenated Fire Retardants (San Antonio Protocol)

This listing helps illustrate our serious concern about possible misuse of standards that are not focused on risk but rather the existence of hazard to make a use or not use decision. Knowledgeable chemists realize that many of these ingredients, like TiO2, wood dust or carbon black in roofing materials will likely never affect building occupants. But how will building designers respond to HPDs or similar hazard-based protocols that contain hazard warnings about cool roof coatings, wood, carbon black, and the like? They will now be possession of information stating the products they plan to specify contain ingredients potentially hazardous to the health of the clients. In short, if HPDs or similar protocols flag every building product as hazardous, their relevancy and usefulness will be lost.

As a result, we recommend that Section II, #13 be revised as follows:
“Product environmental criteria focus on the assessed risks of chemicals, and require safer substitutes to the extent possible, considering existing data and availability of functional alternatives.9”

In addition, we recommend that Footnote 9 also be revised to support risk assessment rather than hazard identification: “A risk-based approach, grounded in Green Chemistry principles, can reduce the use of hazardous substances, and lower overall risk to people and the environment. Key to this focus is an understanding of the actual risks of chemicals in terms of effect levels and exposure pathways, as well as the availability of safer alternatives.”

We thank you for the opportunity to provide these comments, and we look forward to the formal release of these guidelines.