ASC Government Relations Issues & Accomplishments
1995 - Present

Massachusetts Board of Building Regulations and Standards (MBBRS) Efforts to Indirectly Eliminate Use Polyurethane Adhesives from  Modular Home --Present
ASC learned MBBRS was considering changing the state building codes to require modular home manufacturers to reinforce polyurethane adhesives utilized in modular homes  with nails and metal fasteners.  Board members were concerned that polyurethane adhesives were a contributing factor to flammability of modular homes.

Working with the Modular Building Systems Association, ASC has organized and provided information to Council members that convinced companies to participate in funding flammability testing program that is expected to be undertaken in the Summer of 2010.  Results of the testing will be shared  with MBBRS in Fall 2010 with the intention that the new data will dissuade the Board from requiring metal fasteners be included in modular home construction.

Hire Coalition 2009—Present
Joined with a number of other associations to establish the American Home Furnishings and Buildings Coalition.  Throughout  the   111th  Congress, AHFBC has worked  to secure passage of H.R. 3382, the Home Improvements Revitalize the Economy Act of 2009 (Hire Act).

This  legislation would create  a tax deduction of up to $2,000 per family ($1,000 per individual) for purchase and/or   for qualified building products and home furnishings or building products for families making up to $300, 000 a year ($150,000 for individuals).  It would also provide a $10, 000 tax credit for contractors and retailers for the purchase  of qualifying home furnishings or building products for resale.  The tax credit would be applicable for the years 2009 through 2011.

Chemical Interest Group (CIG) 2008-Present
Anticipating that a new Democratic Administration would trigger a long expected overhaul of the Toxic Substance Control Act (TSCA), ASC has joined with other chemical related associations to establish the Chemical Interest Group.  This group continues to work at establishing a cooperative response to expected legislative proposals that would significantly impact testing and chemical registration  for both  chemical production and utilization industries.  Originally it was expected that final action on TSCA revision would take place during the 111th Congress, but it now appears that final action on any legislation may slip until 2011.

EPA Control Technology Guideline: 2006-2008
Worked with EPA in their development of a final National Control Technology Guide which addresses VOC emission for miscellaneous industrial adhesive applications.  CTG was finalized in October 2008.

Polychloroprene Shortage & Tariff Removal 2006-2008
Acted as mediator between manufacturing member companies and a major supplier of polychloroprene products to extend production of certain product grades being phased out as well as helping to secure tariff removal for certain products that allowed member companies to secure overseas alternatives.

REACH Webinar—2008
Organized a free webinar to help member companies understand Registration, Evaluation, Authorisation and Restriction of Chemical (REACH), the new European Union (EU) chemical management regulations, taking effect in 2008.  Also served as conduit for documents developed by the EU on compliance with REACH.

Sealants Consortium 2004-Present
Served as a n intermediary for sealant manufacturers and a professional advocacy group engaged to promote continued congressional funding of a research program related to housing and building construction.

OTC Draft Model Rules: 2000-Present
Testified at the Ozone Transport Commission hearing on the draft model rule that could set new VOC limits for consumer and industrial application adhesives and sealants.  Presently monitoring activities of OTC member states to assure consistency with model.

California VOC Limits: 1999-Present
Serves  as industry liaison with the California Air Resources Board (CARB) in developing new VOC limits for existing categories of consumer adhesives while developing limits for new categories of adhesives and sealants to be regulated following a court ordered agreement requiring CARB to meet State Implementation Plan (SIP) limits.

EPA  MON Rule: 1996-2005
Serve as industry liaison with EPA in developing Miscellaneous Organic NESHAP (MON) Rule, a regulation that will eventually set HAP limits and mandate control technologies adhesive facilities considered major source.  ASC activities include:

• Convincing EPA to separate industries regulated under MON into reactive and non-reactive processors which would likely result in adhesive manufacturers having to meet less restrictive and expensive control equipment requirements;
• Organizing and distributing industry surveys;
• Reviewing preliminary MACT standard proposals and providing member feed back to EPA on industry concerns;
• Arranging EPA MON project leader to meet with ASC Government Relations Committee;
• Meeting with Office of Management and Budget officials to discuss concerns of cost to the industry with regard to a preliminary MACT proposal
• Providing comments to EPA regarding proposed rule highlighting concerns members
• Following issuance of final rule in September, ASC began working with EPA, state regulators, and other associations with impacted members to develop materials to assist members with compliance issues. 

Federal Resource Directory for Regulatory Assistance Providers : 2003-Present
Created and maintained a Directory of Regulatory Assistance Providers that lists names, phone numbers and emails of directors and immediate subordinates for various EPA and OSHA offices at both the national and regional level.

California Air Quality Regulations: 2000
Testified at a South Coast AQMD hearing regarding latest revisions to Rule 1168.  Convinced District to allow industry’s customers to take advantage of the annual 55 gallon exemption for non compliant adhesive until their inventories are fully depleted.

ISAC Membership : 2003
Earlier this year ASC joined a new chemical industry “Chemical Sector Information Sharing and Analysis Center” (Chemical Sector ISAC) created by a formal agreement between the American Chemistry Council (ACC) and the FBI’s National Infrastructure Protection Center (NIPC).. The ISAC is designed to provide a system for two-way communication between the NIPC and ISAC participants. This system will provide timely security related information to participating companies and provide a simple, secure mechanism for those companies to provide information regarding suspicious or malicious incidents back to the NIPC. The ISAC is designed to communicate physical and cyber-security related information.

The Chemical Sector ISAC is an integral component of the industry's overall security strategy, supporting both physical and cyber-security performance objectives. In time, the ISAC has the potential to expand its scope of activities to include services such as (1) enabling experts to jointly analyze incidents, (2) maintaining a database of solutions to specific incidents, and (3) providing a means to collect and share best security-related management practices.
Because of ASC’s ISAC membership, its member companies are now being offered the opportunity to join the ISAC.

Security Program – 2002
As part of the 2002 Spring Convention ASC offered a day long program exploring various aspects of how security issues have changed for manufacturing facilities since 9/11. Some aspects of the program included: making a facility physically secure; cyber security; insurance; what to do first when the “worst-case scenario” happens.  Speakers included both security professionals from both inside industry and the U.S. and state government.

U.S. Green Seal Proposal: 1999-2000
Organized a task force to address a Green Seal proposal that would establish environmentally preferable adhesives for flooring and construction adhesives. ASC input allowed industry to moderate requirements for an acceptable final standard.

EPA Test Method 24: 2000-2006
Organized a task force to address an EPA draft proposal to revise EPA Test Method 24 for measuring VOC emissions adhesives, coating and inks.  EPA’s original proposed method would utilize a Perkin Elmer automated tube desorber by thermally desorbing the volatiles from a weighed sample of coating and then utilizing a flame ionization detector of a gas chromatograph to estimate the total amount of VOCs  in the volatized material.  ASC and the task force after several discussions with met with EPA. It was agreed that industry develop some other type of "referee method" against which the revised EPA method or a possibly less complicated test method could be measured.

Subsequently, the Task Force developed this referee test method, which was based on earlier studies utilizing a gas-chromatography-based (GC) method for TVOC measurement of coatings and adhesives that was accepted by EPA in November 2002. Since early 2003 the group has been looking at both emulsion polymers and adhesives, as well as some paints in an effort to develop a simple but accurate test method for determining emissions for a broad range of high water/low TVOC products

U.S. Tax Code: 1998-2000
Testified at IRS hearing urging the agency not to extend $0.24 tax increase levied on kerosene to mineral spirits (a raw material used in adhesives).  IRS accepted industry position and dropped the tax extension.

EPA Sealant Classification: 1998-2000
Successfully defended industry before EPA to retain “treated article” exemption, which allowed sealant manufacturers to utilize pesticides for esthetic preservation without undertaking timely and expensive registration process mandated by FIFRA.

California VOC Limits: 1997
Established list of VOC limits/categories for California air districts (information posted on ASC website).

California Air Quality Regulations: 1997-1998
Guided CARB with the development of a RACT/BARCT guidance document that would assist California air districts without industrial/commercial VOC regulations for adhesives and sealants in adopting a consistent regulation that would be acceptable to the industry.

California Bay Area VOC Limits: 1996
Counseled Bay Area Air Quality Management District to temporarily raise VOC limits for contact adhesive for a two-year period because of difficulties in developing compliant products for certain customer needs.

California Consumer VOC Limits: 1995
Guided CARB in developing industry survey that eventually resulted in most adhesive and sealant products being dropped from consideration under mid-term consumer VOC regulations.

NJ Consumer Product VOC Limits: 1995
Testified at NJ Department Environmental Protection hearing urging that the state retain consistency of VOC limits in their state consumer VOC regulation.  Convinced DEP in final rule to expand container size for consumer products that would reduce impact of possible future regulations directed at industrial adhesives.

Federal Consumer Product VOC Limits: 1995-1997
Guided U.S. EPA in developing VOC limits and ancillary regulations for adhesives to be included in the federal consumer product VOC regulation (note: industry was given assurance that regulations were consistent with those already developed by the California Air Resources Board (CARB).

For further information on government relations issues and accomplishments, please contact Mark Collatz, ASC's Director of Government Relations, at (301) 986-9700 ext. 112.