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RadTech Test Method Approved by EPA
At the beginning of the month, the U.S. Environmental Protection Agency announced its approved use of ASTM D-7767-11—Standard Test Method to Measure Volatiles from radiation curable acrylate monomers, oligomers, and blends and thin coatings made from them—a test method developed by RadTech members for UV/EB thin films.
According to reports, the action was part of the approval of the South Coast Air Quality Management District’s (SCAQMD) Graphic Arts rule (Rule 1130).
The approval announcement marks the first time the EPA has approved a rule that includes a test method specifically for UV/EB thin films.
"We are grateful to the EPA, the SCAQMD Board and especially to our committed RadTech members who dedicated their time and resources,” said Rita Loof, RadTech Director of Regulatory Affairs.
The test method was developed by RadTech members as both federal and local regulators recognized the inadequacy of standard EPA Method 24 for UV/EB materials, but was unable to produce a suitable alternative.
Specifically, the industry was asked to develop a method for thin films. Upon that request, RadTech embarked on the effort, which ended up involving 25 member companies to get ASTM approval. This would ultimately yield ASTM D-7767 in 2011. ASTM D-5403-93, which can be used for non-thin films, was also incorporated by reference in Method 24.
The EPA approved the rule as part of the State Implementation Plan approval process and validates the ASTM method. ASTM D-7767-11 offers additional certainty to raw material suppliers, formulators and end users who may wish to employ the method to determine Volatile Organic Compound (VOC) content in UV/EB thin film operations.
Other Standard Discussions
In March, the Association for Materials Protection and Performance standards committee for surface preparation was slated to discuss SSPC-SP 13/NACE No. 6, “Surface Preparation of Concrete.”
SSPC-SP 13/NACE No. 6, “Surface Preparation of Concrete,” was originally published in 1997, reaffirmed in 2003 and then every five years until it was updated in 2018. Currently, there is debate in the industry as to whether the document should be considered more of a guide than a standard.
In an article published in the January issue of the Journal of Protective Coatings & Linings, committee Chair Bill Jenkins of International Paint LLC/AkzoNobel outlines both sides of the discussion and offers a potential compromise ahead of the meeting in March.
“Since the latest version was published in 2018, many people in the industry have considered it more of a guide than an actual standard, but is that really fair to the document? Is it possible that this is a perception based on hearsay or preconceived notions and not on the actual content of the currently published document?” wrote Jenkins.
“Let’s first consider that The Association for Materials Protection and Performance (AMPP) says a standard must define the requirements and recommendations for the selection, design, installation or operation of a system or material and must provide detailed descriptions of requirements for quality of the product or process that can be incorporated into a procurement document. SSPC-SP 13/NACE No. 6 does exactly that!”
On the opposing side, Jenkins wrote that some feel it should be a guide rather than a standard since the specifier is required to make a number of choices to implement it.
“This is an important topic, as concrete substrates exist and require protection in nearly every market segment. It is imperative that that the needs of the industry are properly addressed as new standards are developed through AMPP,” wrote Jenkins.
“The committee for surface preparation of concrete will meet during the AMPP conference the week of March 7 in San Antonio, and we would like to hear from you. Please share any thoughts you might have on this important subject.”
Prior to the end of 2021, the EPA announced plans to hold property management companies (PMCs) responsible for lead-based paint safety requirements.
The notice intends to improve compliance and strengthen enforcement of the lead-based paint Renovation, Repair and Painting (RRP) Rule and the Toxic Substances Control Act (TSCA) as they apply to PMCs that perform, offer or claim to perform regulated renovations without certification from the EPA in pre-1978 housing or child-occupied facilities.
“Health impacts from exposure to lead-based paint continue to be a significant problem in the United States, particularly in underserved and overburdened communities,” said Larry Starfield, Acting Assistant Administrator for the EPA’s Office of Enforcement and Compliance Assurance. “Through this proposed action, the EPA will improve compliance with the RRP Rule in rental properties managed by property management companies and protect tenants from lead exposure.”
On Nov. 4, the EPA published the notice in the Federal Register. However, to hold PMCs accountable for the lead-based paint safety requirements, the EPA must first withdraw previously published answers to two Frequently Asked Questions (FAQs) concerning property management companies and their compliance responsibilities under the TSCA and RRP rule.
More recently, last month, JPCL Editorial Advisor, Alison B. Kaelin, outlined some of the expected lead paint standards updates and directed where industry stakeholders can go to submit comments and get more information in August’s Perspective, “Finally! OSHA Provides Advanced Notice of Proposed Rulemaking for Lead Standards.”
