Regulation 8, Rule 51 establishes volatile organic compound (VOC) content limits for adhesives and sealants used by industrial and commercial facilities and by consumers. VOC emissions are a precursor to ozone or urban smog. The proposed amendments would exempt methyl acetate from the definition of volatile organic compound found in the rule because methyl acetate has been found by the U.S. Environmental Protection Agency to be negligibly reactive in forming ozone. The following underlined changes are proposed to Section 8-51-226 of the rule:

8-51-226 Volatile Organic Compound (VOC) Content: All organic compounds (excluding methane, carbon monoxide, carbon dioxide, carbonic acid, metallic carbides ofor carbonates, and ammonium carbonate) which would be emitted during use, application, curing, or drying of an adhesive or sealant product.

226.1 For the purposes of calculating the VOC content of an adhesive, sealant, or primer, water and the following compounds:

  acetone

  parachlorobenzotrifluoride (PCBTF)

  cyclic, branched, or linear, fully completely methylated siloxanes (VMS)

  difluoroethane (HFC-152a)

  methyl acetate

shall not be considered part of the product.

226.2 For the purposes of calculating the VOC content of low solids adhesives, sealants and primers, as defined in Section 8-51-234, any water shall be considered to be part of the product. The following compounds:

  acetone

  parachlorobenzotrifluoride (PCBTF)

  cyclic, branched, or linear, fully completely methylated siloxanes (VMS)

  methyl acetate

shall not be considered part of the VOC content of the product.

In addition, references to test methods that the BAAQMD lab would use in determining compliance with VOC limits for products containing VMS or methyl acetate are proposed for addition to Section 8-51-601 of the rule:

8-51-601 Analysis of Samples: The VOC content of adhesive and sealant products shall be analyzed for compliance with the limits specified in Sections 8-51-115, 125, 126, 301, 302, and 304 using Manual of Procedures, Volume III, Method 21 or 22. The VOC content of low solids adhesive, sealant products or primers as defined in Section 8-51-234 shall be analyzed using Manual of Procedures, Volume III, Method 31. Samples containing parachlorobenzotrifluoride shall be analyzed using Manual of Procedures, Volume III, Method 41. Samples containing cyclic, branched, or linear completely methylated siloxanes shall be analyzed using Manual of Procedures, Volume III, Laboratory Method 43: “Determination of Volatile Methylsiloxanes in Solvent-Based Coatings, Inks, and Related Materials.” Samples containing methyl acetate shall be analyzed using ASTM Method D-6133-00: “Standard Test Method for Acetone, PCBTF, Methyl Acetate or t-Butyl Acetate Content of Solvent-Reducible and Water Reducible Paints, Coatings, Resins, and Raw Materials by Direct Injection Into a Gas Chromatograph.”

The above amendments to the rule are the only amendments being proposed. The practical effect of the proposed amendments is to allow product formulators to reduce VOC content by substituting methyl acetate for conventional solvents like hexane and toluene, both of which are classified as VOCs by the rule and as toxic air contaminants by the California Air Resources Board. These substitutions will occur primarily in contact adhesives.

Pursuant to the California Environmental Quality Act (Public Resources Code Section 21000 et seq.), District staff has conducted an initial study for the proposed amendments to Regulation 8, Rule 51 and has concluded that the proposed amendments would not have significant environmental impacts, primarily because methyl acetate is less hazardous than the chemicals it would be likely to replace. Notice is hereby given that the District intends to adopt a negative declaration for the proposed amendments to Regulation 8, Rule 51 pursuant to Public Resources Code Section 21080(c) and CEQA Guidelines 15070 et seq. Written comments on the proposed negative declaration must be addressed to Ellen Garvey, Air Pollution Control Officer, Bay Area Air Quality Management District, 939 Ellis Street, San Francisco, California, 94109. Comments must be received by 5:00 p.m. on Monday, July 8, 2002.

A copy of the entire rule with proposed amendments noted, the CEQA document, and a staff report are available on the District’s web site at www.baaqmd.gov, or by request. Copies may be requested by calling Lilia Martinez at (415) 749-4664. Comments on the proposal should be directed to Bill Guy, Bay Area Air Quality Management District, 939 Ellis Street, San Francisco, California 91409, telephone (415) 749-4773, or e-mail wguy@baaqmd.gov. Written comments must be received by the District prior to 5:00 p.m. on Monday, July 8, 2002.