Vinyl Industry Urges EPA to Recognize Diversity of PVC Products
The vinyl industry has submitted comments to the Environmental Protection Agency supporting proposed Maximum Achievable Control Technology (MACT) regulations for PVC manufacturing, but urging the agency to ensure the final rule better reflects the diversity and variability of the industry that makes a broad range of products, the Vinyl Institute reports.
MACT rules are written under the Clean Air Act for various industry sectors and must be updated periodically. They require all facilities in a sector to reduce air emissions to the level of the top performers–five facilities, in the case of the PVC resin industry. A final PVC MACT rule is due in January 2012. To follow the rulemaking process and to read comments, visit www.regulations.gov, docket EPA–HQ–OAR–2002–0037.
“The agency’s proposal addresses the right issues and lays out a good framework, but the final rule should acknowledge that each PVC resin is carefully developed for a particular end use and the performance demands associated with that use,” says Allen Blakey, VI's acting president. “One resin can be so different from another that it is actually a different product, and should be regulated as such.”
The comments seek to improve the proposal in a way that both follows the Clean Air Act and recognizes the complexity of PVC resin, officials note. “There are more than 100 different recipes for resin," explains Richard Krock, VI technical director. "Different types and grades of resin involve different chemistries and require different types of processing equipment and operations, all of which affect product behavior and performance. The final regulation must reflect that.”
Additional VI comments addressed statistical calculations related to various emissions control devices and called for consistent test methodologies to set limits and measure compliance. VI also submitted historical data to expand the database supporting the proposed rule.
Comments were filed by other vinyl product groups and companies, including the American Architectural Manufacturers Association. Vinyl windows and doors account for 67 percent of all conventional residential sales of these products in the United States, notes Rich Walker, AAMA president and CEO. “The extrusions purchased from vinyl producers to create window profiles are designed to perform to specific criteria to meet or exceed established standards of energy-efficiency; impact resistance and weathering capabilities,” he explains.
Vinyl siding is warranted by most manufacturers for 50 years or longer and must retain certain physical properties for the length of the warranty, says Jery Huntley, president and CEO of the Vinyl Siding Institute. The siding is made on high speed lines that require a high flow compound to fill the die, yet higher resin inherent viscosity (IV) for impact resistance. Also tight color control is required for long-term weatherability and color retention as well as uniformity of look. She is urging EPA “to carefully consider the impact of the proposal on the ability of the industry to supply resin grades” meeting the needs of product manufacturers.
PVC manufacturers spent millions of dollars in tests over the past three years at 18 production facilities to give EPA emissions data to use in drafting the proposed rules, VI officials note. The organization supports effective regulation, Blakey stresses. “This rule-making process, along with state regulations, voluntary industry actions and other drivers, historically has helped the entire industry continually improve,” he concludes.