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VOCs in Traffic Marking Coatings Meeting September 22, 2005 Kensington Calgary Marriott Hotel, Calgary, Alberta ENGO

GO Report Prepared by: Jim Mahon October 12, 2005 The intention of this report is to provide comments and recommendations regarding the proposed VOC content limit for traffic marking coatings and an implementation date for this coating category. The report will provide feedback regarding the meeting as well as my perspective as an ENGO representative of the Ontario Environment Network on the initiative of Low VOC Traffic Marking and Coatings. Introduction: AIM coatings include a variety of products paints, stains, varnishes and sealing products for application on site to buildings, furniture, pavement, concrete, metal and a wide variety of surfaces present in residential, commercial, institutional and industrial settings. Based on Canadas 2000 inventory of Criteria Air Contaminants (CACs), solvents are the second largest contributor to VOC emissions. The portion of VOCs from consumer and commercial products has already been addressed. In March 2004, the Minister of the Environment and the Minister of Health published a Notice of Intent (NOI) in the Canada Gazette, Part 1, which outlined the federal agenda for addressing those emissions (Notice of Intent: Now the AIM coating sector is under evaluation, since 13% of VOC emissions are from this sector. Further, this sector is growing due to increased demand for its products worldwide. Environment Canada has introduced regulation to reduce VOC emissions from the AIM coatings sector that would specify concentration limits of VOCs for the various products of this sector (50 categories of products are indicated). The proposed limits would require reformulation for some of these products to contain lower levels of VOCs. The rationale for this proposed regulation is based on a number of factors related to health and Canadas obligations under CEPA 1999, under which VOCs have been declared toxic1. In addition, Canada has made commitments under the Ozone Annex to reduce VOCs and align with US standards. The proposal of 150 g/L of VOC content limit for regulations on VOC in Architectural and Industrial Maintenance (AIM) Coatings is consistent with the Ozone Transport Commission (OTC) model rule the US Environmental Protection Agency (EPA) National Rule and the California Air Resources Board (CARB) . Most regions with low VOC paint regulations are meeting the regulations by moving to water based paints. Water-based paints are known for their outstanding durability, toughness, and excellent adhesion to various surfaces and rapid drying. When applied in traffic paints, the
'On July 2, 2003, an Order was published in the Canada Gazette Part II adding VOCs to Schedule 1 (List of Toxic Substances) of the Canadian Environmental Protection Act 1999 (CEPA, 1999). VOCs were added to Schedule 1 due to their role as precursors in the development of ground-level ozone and particulate matter. This listing of the precursors gives the Government of Canada the legislative authority necessary to control he emissions contributing to PM and ozone.

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properties allow quick and easy application and provide long lasting performance on the road, therefore reducing annualized cost. Water-Based Acrylic Traffic Paints Water-based technology has the lowest impact on the environment. Release of volatile organic compounds (VOC) is minimized. Water-based road marking paints minimize the solvent content, can be applied at ambient temperatures, are non-flammable, non-hazardous and therefore much safer to use. Water-based acrylics have improved flexibility over solvent based acrylics or alkyds, and maintain their toughness and flexibility upon prolonged weathering, which helps to keep the glass beads embedded in line for durability and safety for drivers, especially in rainy conditions. The use of water-based pure acrylic paints for road marking applications lowers environmental impact and improves safety for the paint applier. Some available material suggests that water based traffic marking materials provide good dry-night visibility however they present poor wetnight visibility1. Non Water-Based Road Marking Paints The two non water-based road-marking paints on the market are solvent based low VOC traffic paint and Epoxy based traffic paint. Acrylic, Acetone-Based Low VOC Traffic Paint Acrylic , Acetone-based low VOC traffic paint is a current option on the market. It has an advantage over water-based road marking paints in that it can be used with the traditional solvent based conventional paint striping equipment currently in use in provinces across Canada. As a solvent based paint it can be applied at lower temperatures than the recommended 100 C that is currently recommended for water-based traffic coatings. Of course as a solvent based paint, fire and explosions remain a Health and Safety concern with this product although research suggests the risk is low in an open atmosphere application. Epoxy-Based Traffic Paint Epoxy-based traffic paint is a low VOC market option as presented at the meeting in Calgary by Poly-Carb. The presentation suggested that the product was more expensive but lasted longer so the cost per year was financially attractive. One-component Epoxy products have an advantage over the two component Epoxy product that was presented by Poly-Carb from a health and safety viewpoint. There is less potential for epoxy sensitization with a one-component epoxy. Epoxy sensitization is a relatively common allergic body response from those working with epoxy coatings. The allergic reaction can be as mild as a skin rash and as severe as major respiratory distress.

EPA. 1988. Reduction of Volatile Organic Compound Emissions from the Application of Traffic Markings. U.S. Environmental Protection Agency, Control Technology Center, EPA-450/3-88/007. Research Triangle Park, North Carolina.

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September 22 Meeting The meeting at the Calgary Marriott Hotel was located in a convenient, assessable location. The participants present at the meeting could be broken down into 5 categories: Environment Canada representatives, Provincial Government representatives/employees, Municipal Government representatives/employees, Paint Manufacturer representatives/employees, Traffic Painting Company representatives/employees and two Environmental Non-Governmental representatives. Noticeably absent from the meeting was any representatives from Health Canada. The meeting facilitator did an excellent job of breaking the ice by having everyone introduce themselves and including the name of their favorite hockey team. The facilitator successfully established the tone and pace for the meeting in the opening minutes of the day. Facilitation was well done. Environment Canada The Environment Canada presentations were well paced and helped to present the historical perspective background to VOC regulations in North America. Presented were the driving factors for taking action on VOCs, the policy and the science, as well as sources of VOCs in Canada. The path that Environment Canada was taking for consultation as well as the path forward in the development of VOC regulations. As well, Environment Canada presented the proposed elements of the Architectural and Industrial Maintenance Coating proposal, the fifty proposed categories and the proposed VOC content limits and calculation of VOC content. The Traffic Marking Coatings were presented in a separate presentation which provided a definition, the proposed limit, and the range of products currently on the market that are capable of meeting the proposed limit. Noticeably missing from the Environment Canada presentations was any mention as to the health effects of ground level ozone and smog. I understand that this is the area of Health Canada but I personally thought this perspective was drastically needed to supplement the presentations of Environment Canada. Because VOC are precursors to ozone formation, the VOC reductions from architectural coatings will contribute to a decrease in adverse health effects that result from exposure to ground-level ozone. These health effects result from short-term or prolonged exposure to ground-level ozone and include respiratory symptoms, effects on exercise performance, increased airway responsiveness, increased susceptibility to respiratory infection, increased hospital admissions and emergency room visits, and pulmonary inflammation. Available information also suggests that long-term exposures to ozone may cause chronic health effects (e.g., structural damage to lung tissue and accelerated decline in baseline lung function). The Health Canada presentation at the AIM Coating meeting in Toronto, April 5, 2005 showed this very clearly. Health Canadas presentation showed the relationship between smog/air pollution and health and that there was a measurable increase in mortality rates with rises in air pollution. The health presented at that workshop showed the link between ozone pollution and human health. The presentation showed the relationship between chronic ozone exposures and strong evidence of respiratory outcomes and increased admissions at childrens hospitals. Why was the Health Canada presentation not made at the Calgary forum? Many of the participants were from an Industrial painting or municipal or provincial maintenance background and I thought failed to appreciate the seriousness of VOCs promoting increased ozone. This I thought was a serious omission of workshop organizers. 3 of 5

Municipal/ Provincial Presentations Presentations were made on behalf of the City of Calgary, the City of Fredericton, and the Province of Saskatchewan Highways and Transport. City of Calgary The City of Calgarys presentation was very interesting because the focus was on epoxy based traffic paint and provided an example of a Canadian city already dealing with a cold Canadian climate reality and already meeting the proposed 150 g/L VOC content limit. City of Fredericton The City of Fredericton presentation was great because it provided real world experience on switching from Alkyd traffic marking paint to water based traffic paint. The comments regarding ease of cleanup of water based paint and noting that water based paints were safer for employees was very useful to anyone planning on switching. The comment the presentation provided regarding the need to switch to stainless steel equipment was useful because of the need to plan for new equipment costs during the change over from Alkyd traffic marking paint to water based traffic paint. Saskatchewan Highways and Transport The presentation made on behalf of Saskatchewan Highways was especially useful because it highlighted the problem of maintaining pavement marking system in the harsh Canadian climate. They pointed out that they were using approximately 700,000 Litres of water-based paint April to September and approximately 450,000 Litres of Alkyd paint September to mid December. The presentation noted numerous advantages of water-based paint in the presentation such as: more durable, does not bleed through and that it does not damage the pavement. The presentation noted that Alkyd paint had been applied at -300 C with good durability. The presentation noted that they had five marking crews with forty-five employees perhaps a switch to 100% water-based paint might require more employees and equipment investment with a shorter application season. Paint Manufacturer/ Supplier Presentations Presentations were made on behalf of Rohm & Haas and Poly-Carb. Their presentations helped to provide a perspective of current products on the market and that of products to be made available to the market in the near future. Rohm & Haas Rohm & Haas is a supplier of materials that enhance paints and coatings. The Rohm & Haas presentation was very interesting because it gave a good overview of traffic marking options currently on the market and then it concluded by announcing that it would have materials available by the year end which would extend the waterbased traffic marking paint application season by another two months, by the end of this year.

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Poly-Carb Poly-Carb is a 31 year old manufacturer of specialty coatings and adhesives. The Poly-Carb presentation focused on their Mark-55 Hybridized Epoxy coating. This product is currently on the market and meets the proposed 150 g/L VOC content limit. The presentation emphasized reduced application frequency via long product life and low VOC content. They noted that the product cost was higher but the cost per annum favorably comparing to other traffic marking options currently on the market. As noted earlier in the report, two component epoxy products present a greater risk of epoxy sensitization than the one component epoxy products. However they clearly presented another option currently available on the market that meets the proposed 150 g/L VOC content limit. Meeting Comments The afternoon table discussions regarding the proposed VOC content limit was interesting because there was a good mix of people at my table and certainly a variety of viewpoints represented. A representative of Sherwin-Williams, Pete Ragone was sitting at my table. He informed us that many Northern States were currently meeting the 150 g/L VOC content limit using low VOC Acrylics. Painting contractors from the Calgary area talked about getting snow on August 22, 2005. The questions presented were such that a good discussion started at the table with enough knowledge base represented to produce good dialogue. ENGO Position I found the Calgary meeting very helpful in coming to a position regarding low VOC content traffic marking paint as this meeting in many ways alleviated many of the concerns I had surrounding the switch. I was concerned that water based paints could have a shorter lifespan than Alkyd paint meaning that painting would have to be performed at a higher frequency meaning an increase rather than a decrease in VOCs. This concern was alleviated after numerous presentations pointed to longer pavement life with water-based traffic paints. A new consideration for me in Calgary was the knowledge of a two testing period to get a specific paint approved for a jurisdiction. It was also pointed out that many Municipal/Provincial jurisdictions work on a three to five year budget cycle. I found it surprising that nobody seem to know what traffic paint was being used in Alaska. Given the climate in Alaska their experience with low VOC content traffic marking paint could have alleviated some of the concerns that some participants were expressing in the Calgary meeting. I feel that overall the Calgary meeting was very successful. The meeting provided the pertinent information that people needed to reach decision regarding switching to low VOC content traffic marking paint with the exception of the health information mentioned earlier. Canada has been put in the position of playing catch-up to the United States when it comes to VOC limits. The move to the 150 g/L VOC content limit for traffic marking coatings is now overdue. I feel that a thirtymonth implementation period would be sufficient to facilitate a switch to the proposed 150 g/L VOC content limit for traffic marking coatings. This time period would however require notice to all affected parties. This would allow time allow for proper budgeting and the needed test periods to get the low VOC content traffic marking paint approved in Canadian jurisdictions. Jim Mahon Ontario Environment Network Representative 5 of 5