Update on Proposed Changes to SCAQMD Rule 1168 for Adhesive and Sealant Applications

Due to the concerns expressed by the rubber industry and related stakeholders, the South Coast Air Quality Management District (SCAQMD) has been working with RDAbbott to modify rule 1168 to allow the use of solvent-based Chemlok within the District.

Please recall, Chemlok adhesives are currently regulated at 250-gm/l, and only aqueous products comply. The only application exception is sheet applied rubber linings (e.g., tank linings) with a limit of 850-gm/l, which allows the use of solvent-based Chemlok for that area only.

The Rule also includes rule-wide exceptions (per Rule 1124) for Chemlok adhesives being used for aerospace components and facilities using less than 55-gal/12-months.

The District is pursuing our suggestion of “tightening” Rule 1168 by changing “sheet applied rubber linings” to “rubber vulcanization adhesives.” This would eliminate the potential use of high-VOC adhesives for bonding cured rubber sheets, such as flooring and mats, which were never the intention of that category.

The new definition will be drafted to include all products and processes that use Chemlok with a current limit of 850-gm/l. At a yet-to-be-determined future date, the hope is to reduce that limit to 250-gm/l. While we believe a limit of 250-gm/l across the board will never be possible for all elastomers, processes and environments, there are very good reasons for supporting this future limit in the rule.

At present, RDAbbott is working with the District to refine the definition of rubber vulcanization adhesives so it’s specific and inclusive, as well as negotiating the future date for reducing the limit to 250-gm/l.

These proposals are planned to be presented to the Public Review Board in October 2017, and we are working with a key environmental group known to oppose any such measure, in the hopes they do not speak out against our “tightening” proposal at the hearing. Our use of adhesives is combined with other adhesive industries, and those folks have pushed back on the rule change due to increased regulation on their usages. There is a strong possibility that the proposal to the Public Review Board will be delayed.

For more information, please visit the SCAQMD website at: http://www.aqmd.gov/


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