Proposed Amended Rule 1168 – Adhesive and Sealant Applications

PAR 1168 proposes to: 1) extend the parachlorobenzotrifluoride (pCBtF) prohibition date for Roof Adhesive Primers to allow more time for reformulations; 2) delay the effective dates of volatile organic compound (VOC) emission limits for three categories of adhesives and sealants to allow more time for reformulations; 3) include equivalent alternative reactivity-based limits for Top and Trim Adhesives and Roof Adhesive Primers; 4) delete the exemption that allows facilities to use up to 55-gallons of non-compliant products per year; 5) require manufacturers to provide a list of their distributors annually; 6) transition reporting to a recordkeeping requirement for distributors; 7) include a new category for battery adhesives with an extended pCBtF prohibition date; and 8) provide clarifications, updates to definitions, and cross references to maintain consistency with other South Coast AQMD rules. PAR 1168 is expected to result in delayed VOC emission reductions of 0.115 ton per day (tpd) from Top and Trim Adhesives until January 1, 2030; 0.020 tpd from Rubber Vulcanization Adhesives until January 1, 2029; and 0.011 tpd from Clear, Paintable, Immediately Water-Resistant Sealant until January 1, 2028. Extending the pCBtF prohibition date for Roof Adhesive Primers would also delay the benefit of reducing the use of and exposure to pCBtF, a known carcinogen. The Draft SEA concluded that significant and unavoidable adverse environmental impacts may occur for air quality during operation. No other significant adverse impacts were identified. While products subject to PAR 1168 may be used at facilities and other locations within the South Coast AQMD jurisdiction that may be identified on lists compiled by the California Department of Toxic Substances Control per Government Code Section 65962.5, implementation of PAR 1168 will not alter the status of the facilities and other locations on these lists. Delaying the compliance dates in PAR 1168 for certain adhesives and sealants will benefit manufacturers by providing additional time to reformulate these products in response to the needs highlighted in the technology assessment while avoiding market disruptions and allowing temporary continued access to users of these commercially available products.