PAINT LIFECYCLE/COST BENEFIT PROJECT – OUTSTANDING ISSUES (Full Group)
September 15, 2006
LCA Issue
Notes/Status/Next Steps to Resolution
#L1
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#L2
#L3
Estimate of average
household annual
generation of
leftover paint
Estimate of average
frequency of paint
management (e.g.,
how often do people
clear out the paint
they store;
household paint
throughput)
TRACI – human
health impacts of
smog included?
Barry sent Abt’s revised estimates 8/23.
Bev provided comments 8/24.
Dave D. sent a proposed resolution 8/25.
Barry and industry are in agreement (as of 8/30) at 0.33 gallons/household-year (latex).
Government group concurred with 0.33 gallon/household-year (9/13), noting that these are national
averages and that on the individual household level, paint is not discarded annually (separate issue see L2, below).
Current Status - Resolved
 The range is now estimated at 6-16% of sales (from a previous 8-22%), with a point estimate of
approximately 10% based on population.
 Lifecycle report will discount for latex and non-residential.
 Infrastructure report will not discount since latex and oil-based are included in system.
 Issue raised by government in 5/23 memo (response to 5/10 ERG memo; see comment 3b).
 ERG responded that survey results will help model this. However, 9/1 draft assumes that average
household discards their paint annually.
 Government objects: data shows that households hold on to their paint for more than a year. No
reason they discard it once every year. Data from paint age studies and McKenzie-Mohr research
help inform this.
Industry has concerns with the government proposal –
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Current Status: Industry to provide comments, discussions will continue in Charlotte.
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David A. asked Bill F. on 8/23.
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ERG checked with Jane Bare (TRACI developer): human health impacts of smog excluded. Bill F.
doesn’t want to create a “custom health impact” category.
9/6: government will reconsider, bring a proposal back to the full group.
Current Status: Waiting for response from government.
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PAINT LIFECYCLE/COST BENEFIT PROJECT – OUTSTANDING ISSUES (Full Group)
September 15, 2006
LCA Issue
Notes/Status/Next Steps to Resolution
#L4

Direct inhalation of
emissions from
drying/disposal of
latex paint (from
cans) and drying of
latex paint (on
walls) after use –
whether and how to
model, describe



7/31 David A. and Dave D. agreed that the LCA/CBA report should have a preface which states that
conclusions are the consultant’s, not those of any stakeholder.
8/16 ERG recommends reporting total VOC releases, but not modeling human health impacts.
Industry agrees and also expressed strong concern about what the report says about health impacts of
paint fumes.
What about emissions other than VOCs?
Current Status
 ERG: TRACI does not model health impacts from paint drying
NEW GOVERNMENT PROPOSAL
 Government believes that a certain percentage of residents will not be able to dry leftover latex paint
outdoors, and will be unwilling to dry leftover latex paint indoors (apartment/condo dwellers, no
porch/balcony/fenced yard, children/pets, high humidity regions, during winter in cold regions, etc.)
 Government believes that these people will either dispose of their paint improperly (which is not
being modeled) or will bring the leftover paint to a collection.
 Government therefore proposes that ERG limit Method 2 to less than 100% of leftover paint supply.
 Government also proposes that ERG state in the LCA that due to time and financial constraints, as
well as technical limitations, it was unable to model the health impacts from drying of paint, and not
to pursue these costs further unless government, in its own efforts, can provide “new” information

#L5
Land use impact
category – replace
with “total energy?”
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Industry has concerns with the government proposal, Industry will provide comments and suggests we
discuss at the Charlotte meeting
8/16 - ERG proposes replacing land use impact category with “total energy.”
8/25 - Government concurs.
9/6 – Industry concurs.
Current Status: Resolved
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PAINT LIFECYCLE/COST BENEFIT PROJECT – OUTSTANDING ISSUES (Full Group)
September 15, 2006
LCA Issue
Notes/Status/Next Steps to Resolution
#L6

Collection-based
“dry and dispose”
method for
management of
paint
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#L7
% of households
using kitty litter for
consumer-based
“dry and dispose”
Based on survey results, ERG found that large quantities of paint unsuitable for further use as paint
are going to Amazon. Survey didn’t identify any programs using Portland cement; instead, sawdust,
clay, and air drying are reported.
8/16 - ERG recommends modeling disposal limited to “true disposal methods” (not Amazon) and
evaluating clay and sawdust as additives (but not Portland cement). ERG would assume that sawdust
is free of production burdens, but clay assumes the mining impacts.
8/25 - Government concurs, but reserves right to reopen assumption that sawdust comes in free of
upstream burdens based on results of first draft report.
9/6 – Industry OK with this.
Current Status
 ERG is proceeding with its recommendation to model disposal limited to “true disposal” methods.
 Steve S., Dave D., David A., and Scott C. discussed this on 7/13.
 In the interest of time, 9/1 ERG draft is based on consumer drying the paint with no additives. ERG
proposes a sensitivity analysis based on the use of clay-based cat litter as a stabilizing agent.
 Government proposes that since cans over a certain fullness will require some additive, the base case
should be modeled as a blended average (some cans dried with, some without). Sensitivity analyses
could be conducted on the two extreme cases (0% additive, 100% additive), if desired.
 Industry prefers to model 0% and 100% and would be willing to work with government side on a base
case blended average however industry still concerned about purchasing additives – since many “zero
cost” additives exist.
Current Status: Need to develop base case blended average. Need to continue discussions on kitty litter
vs. “zero cost” additives.
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PAINT LIFECYCLE/COST BENEFIT PROJECT – OUTSTANDING ISSUES (Full Group)
September 15, 2006
LCA Issue
Notes/Status/Next Steps to Resolution
#L8
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What assumptions,
if any, should be
made about partial
cans?

#L9
#L10
Are 10 management
methods (6 pure, 4
modified)
adequately
described?
% of
recycled/reused
paint purchases that
displace virgin paint
(e.g., will recycled
paint displace virgin
paint)
See ERG 5/10 memo, question 2 and government 5/23/06 response.
ERG has comprehensive data from Metro and can develop a “fullness histogram”.
ERG will profile the number of cans of leftover paint generated vs. the number of cans of leftover
paint brought to an HHW facility. ERG will adjust survey results to account for households that don’t
send cans for collection (likely to be less full). ERG will determine the maximum number of inches of
leftover paint left in a paint can that HHW operators say can be managed through air drying vs.
needing a drying agent (assumed to be kitty litter applied at a ratio of 1:1).
Group decided to wait for results of survey, then review again.
Current Status: ERG to summarize Metro data; group will discuss.
 See ERG 5/10 memo, question 1 and government 5/23/06 response.
 Group decided to wait for results of survey, then review again.
 ERG addressed in 9/1 memos?
Current Status: In process (government and industry to review)
 LCA SOW treats this as two extremes: 0% displacement and 100% displacement. This may result in
two very different sets of conclusions.
 Government proposes that the Lifecycle workgroup jointly implement a simple survey of recycled
paint buyers to see if we could narrow this range. This work could be done with no extra work for the
consultants. Government and industry would agree on the survey design, and the survey could be
implemented by Metro Paint (Metro OR), Local Colors (Chittenden County VT), and other paint
recyclers.
 Industry would like to discuss the government survey details – however Industry is very concern
about the displacement assumptions considering that there are good reasons why there is no market
for recycled paint
Current Status: Will discuss in Charlotte
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PAINT LIFECYCLE/COST BENEFIT PROJECT – OUTSTANDING ISSUES (Full Group)
September 15, 2006
LCA Issue
Notes/Status/Next Steps to Resolution
#L11

VOC content of
virgin vs. postconsumer paint
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#L12
Recycled coatings
market demand
9/1 ERG draft assumes 150 g/L for all paints, based on limited responses to surveys and use of
national averages (not specific brands, facilities, product lines).
9/6 industry says recycled paint is older, therefore should have higher VOC content than virgin.
Industry’s concern is that the VOC content of virgin latex paint is 100 g/l or less (Industry is working
on the data; Barry Elman to support and Metro data already provided) yet the Green Seal Standard for
Recycled Paint is 250 g/l or less
Bev notes that since currently modeling only has VOCs impacting smog, any changes here likely
won’t have a big impact.
Current Status: Industry (and Barry) will provide VOC data then group will discuss again
 Survey data shows that some recycled paint has high transport due to shipments to Mexico, etc.
caused by insufficient demand.
 Data in 9/1 draft removed outliers, assumed there are or will be local markets. ERG recommends this
as a sensitivity analysis.
 9/6 industry says that outliers should be included in the base case, since market is the constraining
factor today.
 Government response: we aren’t modeling the current market; the certification standard should
improve the market; modeling impacts of recycled paint use in Mexico, China is exceptionally
problematic.
 Industry response – there is no evidence to indicate the current market will get any better – the current
data is the best we have – which shows that very high transport is needed to get the recycled paint to
the consumer (given lack of retail sales structure and lack of market within the us (no need to get into
foreign markets). These high transport costs are one way to model problems with recycled paint
market – so data points should be included in the base case.
Current Status: ERG proposes to evaluate market distance as a sensitivity analysis. Group will need to
discuss again.
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PAINT LIFECYCLE/COST BENEFIT PROJECT – OUTSTANDING ISSUES (Full Group)
September 15, 2006
CBA Issue
Notes/Status/Next Steps to Resolution
#C1
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Definition of
baseline
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#C2a
#C3
See government 8/3 memo, comment #5.
Is the baseline “current handling practices for latex paint” or “leftover paint remaining unmanaged in
consumers’ homes” (e.g., all stockpiled)?
Government believes the baseline should be modeled as all paint being stockpiled in consumers’
homes, since this is easier to derive as compared to current handling practices for latex paint.
It is important that we reach agreement on a clear baseline. However, since the CBA results will be
measured equally from this baseline, the result will not differ as a result of the choice of baseline.
9/6 Jeff C. states that baseline may not be needed since we’re not evaluating a “do nothing” scenario.
Defining a baseline was included in the SOW.
David A. to convene a subgroup (Jeff, Dave D., Barry, David A.) to discuss this further.
David A. sent clarifying question to Jeff on 9/14.
Current Status: In process (David A.)
Scarcity rent
 See government 8/3 memo, comment #11, and ERG 8/24 memo to David A.
(e.g., resource
 In 8/25 call with Jeff C., David A. asked about publicly-owned resources, such as oil and minerals
depletion; added
extracted from public lands. Jeff C. said he needs to defer to Drew L.
benefits on owning  Jeff C. to talk with Drew L. then respond to David A.
a scarce resource)
Current Status: In process (ERG)
Other issues in
 See government 8/3 memo, comments 1 – 2 and 4 - 10, and ERG 8/24 memo to David A.
7/19 ERG memo
 ERG says it will respond to specific comments in revisions to the methods discussion that will appear
“modeling the
in future draft reports.
environmental and  Industry says “no additional comments” - 8/23 email.
health benefits of
 ERG moving forward based on government comments.
leftover paint
management”
Current Status: In process (ERG)
(not shown above)
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PAINT LIFECYCLE/COST BENEFIT PROJECT – OUTSTANDING ISSUES (Full Group)
September 15, 2006
CBA Issue
Notes/Status/Next Steps to Resolution
#C4a
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#C5
#C6
EPA National
Center for
Environmental
Economics (NCEE)
review of 7/19 ERG
memo “modeling
the environmental
and health benefits
of leftover paint
management”
Other issues in 7/19
ERG memo
“modeling the
consumer benefits of
leftover latex paint
management”
EPA National
Center for
Environmental
Economics (NCEE)
review of 7/19 ERG
memo “modeling
the consumer
benefits of leftover
latex paint
management”
NCEE staff have reviewed the 7/19 memo but comments have not been transmitted yet.
Barry E. to transmit comments.
ERG, industry and government to review and discuss as needed.
Current Status: Unresolved (Barry to send comments)
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See preliminary industry comments in 7/21 e-mail from Dave D.; 8/23 e-mail “no additional
comments.”
See government 8/3 memo, comments 12 – 23, and ERG 8/24 memo to David A.
ERG says it will respond to specific comments in revisions to the methods discussion that will appear
in future draft reports.
ERG moving forward based on government comments.
Current Status: In process (ERG)
 NCEE staff have reviewed the 7/19 memo but comments have not been transmitted yet.
 Barry E. to transmit comments.
 ERG, industry and government to review and discuss as needed.

Current Status: Unresolved (Barry to send comments)
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PAINT LIFECYCLE/COST BENEFIT PROJECT – OUTSTANDING ISSUES (Full Group)
September 15, 2006
CBA Issue
Notes/Status/Next Steps to Resolution
#C7
Avoided travel and
purchase costs
(avoided virgin
paint).


#C8
Education costs
Government - 8/3 memo asked if these avoided costs would be included.
ERG - 8/23 memo and 8/25 conversation between Jeff C. and David A.: ERG says “yes, credit will be
provided.”
Current Status: Resolved
 See government 8/3 memo, comments 25 – 31.
 Based on earlier decision to model latex collection costs as “marginal” (or “incremental”) to oil-based
paint collection, government believes that education costs are marginal to a nationally-coordinated oil
paint collection (and outreach) effort. This applies to all collection (including pure method 6).
 Industry says “no additional comments” 8/23.
 9/6 Dave D. agrees.
Current Status
 ERG moving forward with assumption that education costs are marginal to a nationally-coordinated
oil paint collection (and outreach) effort.
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