Letter to Environmental Quality Board Regarding AIM Regulations

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July 14th, 2003

Honorable Camille George
Pennsylvania House of Representatives
38-B East Wing Capitol Building
Harrisburg, PA 17120

RE: Environmental Quality Board July 15 Meeting on AIM regulation

Dear Representative George,

We are writing to express our support for – and to urge you to also support  -  the Department of Environmental Protection (DEP)  proposed regulation for control of volatile organic chemicals (VOC’s) from interior stains and varnishes, called the Architectural Industrial Maintenance (AIM) coatings rule (31 Pa. Bull. 6807).  On Tuesday July 15^th, the Environmental Quality Board will evaluate support for AIM.

Pennsylvania’s remaining ozone smog nonattainment area in southeastern Pennsylvania is within a critical time frame, needing to prove that its State Implementation Plan, EPA-approved cleanup strategies have successfully reduced the unhealthy ground-level ozone smog pollution that has become inherent to that five county area.     Philadelphia, Chester, Delaware, Montgomery and Bucks counties suffered from 10 exceedances of the current one-hour ozone standard during the 153 days of the ozone season of 2002, and 101 exceedances of the eight hour ozone standard.    We continue to struggle to maintain a hair trigger on ozone smog control violation in other Pennsylvania cities like Pittsburgh (34 exceedances of the eight hour ozone smog standard during 153 days of summer 2002), and Lancaster (19 exceedances of the eight hour ozone standard during summer 2002).  Across Pennsylvania, our citizens suffered through 570 recorded exceedances of the eight hour ozone smog limits during 2002, and 19 recorded exceedances of the current one-hour ozone smog limit.

DEP staff has accomplished extensive research into existing compliant stains and varnishes for interior use.  Their research has netted the following examples[i].  For clear wood interior varnishes, there are ten existing varnishes that already meet the proposed regulatory requirements of 350 g/L VOC from companies such as Behr, Clovedale, Columbia, Fuhr, Hallman Linsey, Pittsburgh Paints and Sherwin Williams.   For clear and transparent stains with maximum of 250 g/L there are five existing compliant interior clear and semi-transparent stains, made by American Formulating and Manufacturing, Fuhr, Van Technologies and Vista.    For gym floor sealers we have 4 examples within 350 g/L from Basic Coatings, Bona Kemi, Hillyard, and Valspar.  Additionally, we have found that companies such as Livos, AURO USA and BioShield have broken new ground with their offerings for low VOC and solvent free coatings.   These can be viewed at:  http://www.ecobusinesslinks.com/natural_paint_manufacturers.htm .   Pennsylvania State University currently uses alternative coatings on all gymnasium and concert center floors.   Environmental Building News included the Pittsburgh Paint “Pure Performance” zero VOC paint from PPG Architectural Finishes as one of their top ten green products of 2002 for homeowner use.

The Architectural, Industrial Maintenance rule is a requirement built into Pennsylvania’s compliance plan – the state implementation plan, SIP – already approved by EPA.   Pennsylvania’s failure to proceed with completing a final regulatory framework for this necessary reduction of VOC’s in the five county Philadelphia area would trigger a violation of our SIP.    This would trigger an enforcement action by EPA in the Philadelphia five county area, but  more importantly, would doom all of our citizens  across Pennsylvania –and including your district - to exposure to increased ground-level ozone smog air pollution levels and more dangerous health effects in our vulnerable senior citizens and young children.   

AIM will net us an expected 10,200 tons per year of VOC reduced by 2005 in the five county Philadelphia area;   the final year in which Pennsylvania must achieve ground-level ozone smog control and cleanup under the current one-hour ozone standard, and our final goal in achieving cleaner air under the current one hour ozone smog limits. Consequently, we urge you, at this critical time, to be a leader in consumer and public health protections and support the DEP final rule for AIM coatings.

Sincerely,

Nancy F. Parks
Chair Clean Air Committee

Sierra Club, Pennsylvania Chapter
201 West Aaron Square
P.O. Box 120
Aaronsburg, Pennsylvania 16820-0120