Interim Progress Report on Paint Product Steward Initiative Project #8 For the Period July 1, 2005 through September 16, 2005 Preliminary Research on Certification Options, Current Paint Recycling Manufacturing, Recycled Paint Testing Prepared for the Paint Product Stewardship Initiative Acknowledgement This work was sponsored by Portland Metro Regional Government Portland, Oregon and The Dunn-Edwards Corporation Los Angeles, California Prepared by Dane Jones, Professor Ray Fernando, Professor Department of Chemistry and Biochemistry California Polytechnic State University San Luis Obispo, CA 93407 September 16, 2005 DISCLAIMER The statements and conclusions in this report are those of the authors. The mention of commercial products, their source, or their use in connection with material reported herein is not to be construed as actual or implied endorsement of such products. This document is intended for use by the PPSI Markets Workgroup. ii ABSTRACT A survey was made of recycled paint manufacturers participating in the PPSI Markets Workgroup to provide an overview of current recycled paint manufacturing practices. Concurrently, research was undertaken to determine what standards and certification options are currently available for recycled paint products. The results of the survey showed manufacturers typically produce either consolidated paint (water-based or both water and solvent-based) made from virtually >95% post-consumer waste material or they produce reprocessed (remanufactured) water-based paint using at least 50% postconsumer waste (PCW) material and other virgin materials. The Federal Government, through EPA and the General Services Administration (GSA), provides recommendations and standards for recycled paint products with recommended PCW levels for various products. The Master Painters Institute (MPI) provides comprehensive performance standards applicable to reprocessed paint. Recycled paint products meeting relevant MPI standards would be equal to virgin paint materials in terms of performance and safety. The Building for Environmental and Economic Sustainability (BEES) research provides a method for evaluating the environmental performance of recycled paint products using the life-cycle assessment approach but is not a “certification” as there is no “seal” to put on a label to demonstrate a certain level of environmental performance. Green Seal provides unique certification opportunities for recycled paint products. The EPA recommended levels of PCW material provide useful guidelines for development of specific levels for quality recycled paint products. iii TABLE OF CONTENTS DISCLAIMER.................................................................................................................... i ABSTRACT ....................................................................................................................... ii TABLE OF CONTENTS ................................................................................................ iii LIST OF TABLES ........................................................................................................... vi I. Work this Reporting Period .........................................................................................1 A. Research on current recycled paint manufacturing ..........................................1 Questionnaire on recycled paint manufacturing .................................................1 Summary of Questionnaire Responses .................................................................5 B. Research on Recycled Paint Performance Standards .......................................6 EPA .........................................................................................................................6 GSA .........................................................................................................................6 California Public Contract Code ..........................................................................7 MPI ..........................................................................................................................7 BEES .....................................................................................................................12 SCS ........................................................................................................................13 Green Seal .............................................................................................................13 ASTM ....................................................................................................................13 Certification and Standards Matrix ..................................................................14 C. Summary ..............................................................................................................15 II. Future Work ...............................................................................................................17 iv LIST OF TABLES Table I Cal Poly Questionnaire on Recycled Paint Manufacturing ............................3 Table II MPI Standard Categories Relevant to Recycled Latex Paint Products ......11 Table III Recycled Paint Certification and Performance Standards Matrix ............14 Table IV Post-consumer Waste Content for Recycled Paint Products ......................16 v I. Work This Reporting Period This report summarizes work performed on Phase II of Project 8, Recycled Paint Certification System, of the Paint Product Stewardship Initiative from July 1 through August 15, 2005. A. Research on Current Recycled Paint Manufacturing Paint products produced from post-consumer waste (PCW – also called leftover paint) products include consolidated paint (both water-based and solvent-based) and reprocessed latex (waterbased) paint. Consolidated paint usually consists of at least 95% PCW paint, with possible addition of very small amounts of additives. Paint consolidation is the process of combining leftover paints that have similar characteristics into batches. Consolidation is done at municipal facilities following collection events and at a small number of retailers. The consolidation process typically involves the following steps: 1) 2) 3) 4) 5) Screening out of unusable paint Sorting paint based on whether it is oil or latex paint Sorting by characteristics such as color, finish, and type (e.g., interior vs. exterior); Pouring the latex leftover paint from the original containers into collection drums; and Mixing. Consolidation operations also filter the paint to remove large particles and other solids. Many perform periodic testing for contaminants. The consolidated paint is often packaged in 5-gallon containers for reuse. This activity is conducted mostly by local programs in batch sizes ranging from 30 to 200 gallons.1 Reprocessed latex paint is a completely remanufactured product using PCW latex paint as a primary ingredient. Production of reprocessed paint involves processes characteristic of virgin latex paint production, and thus is not typically done at municipal collection facilities. PCW is combined with virgin ingredients (resin, pigments, additives) and secondary industrial materials including surplus paint (miss-tints, off-batches, discontinued products) to produce the reprocessed paint. PCW content of reprocessed latex paint often varies depending on the manufacturer, the PCW, and the product desired. Manufacturers maintain a minimum of 50% recycled content (PCW and secondary industrial materials). Manufacturers use a variety of sorting protocols often perform preliminary testing on the PCW collected. A variety of tests are also performed on the final product. In order to obtain a clearer picture of current recycled paint manufacturing processes, a questionnaire was developed and sent to members of the Markets Workgroup involved in recycled paint manufacturing in both the United States and Canada. The questions from the questionnaire are listed below: 1 PPSI Background Report, www.productstewardship.us/prod_paint_dialogdocs.html PPSI #8, Cal Poly 1 September 16, 2005 Questionnaire on Recycled Paint Manufacturing 1. What types of recycled paint products do you produce? For example, interior, exterior, flats, non-flats, primers, white base, pre-tinted colors, etc. 2. What tests, if any, do you perform on the post-consumer waste paint collected for recycling? 3. How do you sort the paint collected for recycling? 4. What is the post-consumer waste content in your final product? Is the content the same for all products or does it vary from product to product? 5. In producing your final product, do you blend the post-consumer waste with virgin paint or with virgin raw materials (resin, pigments, additives) or some combination? 6. What tests, if any, do you perform on your final products? Do you also test recycled paint products produced by other companies? What comparison tests do you do? 7. What standards or certification, if any, must your recycled paint products meet? 8. What information is contained on the labels of your recycled paint products? What information on the content and formulation is provided to the buyer or consumer? 9. What are the current markets for your recycled paint products? Responses from the Markets Workgroup members were tabulated. Results are given in Table I below. PPSI #8, Cal Poly 2 September 16, 2005 Table I Cal Poly Questionnaire on Recycled Paint Manufacturing Question # 1 2 3 4 5 area products produced PC-waste tests sorting PC-waste content remanufacturing Q consolidated paint: interior latex and alkyd paint and stain, exterior oil and stain, clear varnish, interior/exterior oil-based rust paint, interior visual inspection R consolidated exterior latex paint none company S two consolidated recycled paint product lines: latex – interior/exterior – satin flat , alkyd – exterior – satin flat Both latex and alkyd are available in 8 colors – white, beige, yellow, green, blue, rose, brown and grey. T 100% post-consumer latex paint raw material (also collect oil-based paint used for energy content as fuel) separate oil and latex, 12 colors, special for varnish, 100% post-consumer paint wood preserv. sort whiltes and bulk in 55 gal drums Each can visually inspected for eligibility (visual, stirring, odor). Extensive sorting protocol Cans are then sorted into to determine if eligible, a) acrylic latex paint, b) analysis for pH, VOCs, non-acrylic latex paint, c) PCBs, and heavy metals latex enamels and such as lead, mercury and bathroom paints with chromium; must comply biocides, d) post with the standards set out in production -retail mistints, the Federal Specification manufacturer’s overruns, #TT-P-2846 date expired product etc, e) 8 different colors as stated above none sort by color additives (below 0.1%) for QC, anti-fungal in latex 100% - mixture of flat, semiall post-consumer, minor gloss and gloss white and additives off-white latex paints 100% post consumer content. Except for the small percentage of paint from category (d) which is actually post production as opposed to post consumer 100% post consumer paint. Post production paint may be included. If QC analysis indicates a quality deficiency or an extreme color discrepancy, some additives may be introduced. This may happen occasionally but it is not a regular occurrence. 100% None U consolidated interior, exterior flat, eggshell, semi-gloss, primer, elastomeric no response segregate by color and sheen, interior and exterior ~50%, varies by color. Darker colors may have more post-consumer content paint is combination of post-consumer paint, post-industrial paint (mistints, dented cans, discountinued products, off spec products) and virgin ingredients (resin, colorant, TiO2) W reprocessed interior/exterior, low sheen, variety of colors visual and odor, stir color 99-100%, mostly 100%, may add thickener all post-consumer X pH, viscosity, density, reprocessed latex fineness of grind, color, by color, driven by market interior/exterior, various flat: >95%, glosses periodically VOC's, % customer, visually grade: glosses - flat, eggshell, semidepending on virgin material solids, volume and weight, high quality, poor quality, gloss, standard colors, color required, always >70% %water, volume and weight, solids match scrub Y reprocessed latex flat & semigloss, interior/exterior, standard colors, color match PPSI #8, Cal Poly visual, smell color, sheen 3 min. 50% , varies 50-100% virgin paint materials added vigin raw materials, completely remanufactured September 16, 2005 Table I Cal Poly Questionnaire on Recycled Paint Manufacturing (con’t) Question # 6 7 8 9 area tests on final product standards/certification label markets brand, 100% post-consumer primarily consumer (through hardware, box store), exported company Q Pg, Hg, Cr, oil for PCB's, grind, gloss, viscosity, sag and standards based on specs for leveling, dry time, pH, some new paint exterior and UV durability R VOC (bi-annually) VOC<250 g/L off-white exterior recycled latex paint, VOC < 250 g/L general public S Only runs analysis on own product. Testing parameters: color consistency, odor, viscosity, drying time, hiding factor, smoothness, application property, freezethaw stability, adhesion, VOC level, lead, mercury, chromium, formaldehyde, pH, specific gravity, bacterial content. Weather testing is randomly conducted to compare recycled product with virgin product. Use USA Federal Procurement Specification TT-P-2846 as guideline. Products sold to customers outside of North America. Different countries have different requirements, eg. China requested test for formaldehyde and Jamaica requested a shower test. Most countries insist on receiving samples for their own government analysis prior to issuing permission for the paint to be imported. Products are shipped in bulk (55 gallon drums)and repackaged locally for selling in the destination country, so label content is minimal. The labels on the individual smaller containers are designed and printed by the customer, in their language, to meet the requirements of the local market place. Product information is discussed with the client during the purchase negotiations. Products not sold in Canada or the USA. Sold in 26 different countries, eg. Chile, Guatemala, Qatar, Dominican Republic, Trinidad, Poland, Russia, Indonesia, Mexico, Sri Lanka, Africa countries, India. T None None N/A Provide "raw material" for other recycled paint manufacturers U mold, fungus, VOC content, sag, scrub own quality standards, certify at least 50% post-consumer content W environmental, scrub, stain, washability, adhesion, hiding, addel. Weathering, sag, flow, leveling, roll out, density, % solids, pH, viscosity, gloss regulatory (EPA, CPSC) X same as PC-waste testing, do not test other company products PPSI #8, Cal Poly internal standards based on tests 4 type of product, surface pre., color, application, dry time, private sector and government stpread rate, thinning, clean (state agencies) up, at least 50% postconsumer content recycled content, use, coveratge, surf. Prep, paint prep, paint app. general public, commercial, reseller, non-profit, government interior/exterior for properly prepped drywall, masonry, wood, metal, min. 50% PC private label, cities and paint, max VOC 250 g/L, also counties, contractors, general have PI sheet:acrylic public copolymer, NVV 30-40%, NVW 40-55%, wpg 10.0 min. September 16, 2005 Summary of Questionnaire Responses Eight manufacturers of recycled paint products in the United States and Canada were contacted and all eight provided responses. Consolidated paint Five of the eight manufacturers produce only consolidated paint. Three of these produce only latex paint while two produce latex and alkyd. One company also produces stains, varnishes and primers. The primary latex paint produced is exterior or exterior/interior but some manufacturers produce separate interior and exterior latex paints. Initial inspection for these products ranges from fairly simple visual and odor tests to much more comprehensive tests including VOC level, pH, and heavy metal analysis. Incoming material is primarily sorted by color. Other sorting parameters include gloss level or sheen, resin type, and listed application (interior/exterior). These products are all 100% or nearly 100% PCW. Some manufacturers include manufacturing overruns, expired products, and mistints in these products. Minor amounts of additives are sometimes added, particularly antifungal agents. Testing on these products varies widely. Tests used include VOC analysis, heavy metal analysis, PCB analysis, gloss, grind, density, viscosity, sag and leveling, dry time, pH, percent solids, mold and fungus, freeze-thaw stability, color and performance testing (scrub, stain, washability, adhesion, and even exterior weathering and UV durability. Virtually no information was collected on the frequency of any of these tests nor standards used for comparison in these tests. It is assumed relevant ASTM testing procedures are used. No manufacturer currently certifies their consolidated paint as meeting any published performance standards. Manufacturers certify their products comply with requirements for VOC content and mercury and lead levels. Some use published standards as guidelines and most have internal standards, sometimes based on virgin paint specifications. These consolidated paint products are primarily sold to consumers either directly by the manufacturer or through retail outlets but they are also used by commercial and governmental agencies. Products are also shipped overseas. Reprocessed paint Three of the eight companies produce reprocessed paint. According to survey results, these companies do not generally also produce consolidated paint products. The products produced are almost entirely interior, interior/exterior and exterior latex paints. Small amounts of elastomeric coatings (highly flexible barrier coatings) are also produced. Testing on collected PCW ranges from only visual and odor to pH, viscosity, density, grind, color, percent solids, water content, and VOC levels. Incoming material is sorted by color, gloss level, interior/exterior, solids, and quality (no parameters specified). PPSI #8, Cal Poly 5 September 16, 2005 The PCW content of the reprocessed paints ranges from 50-95%. One manufacturer always maintains PCW content above 70%. The PCW content may depend on gloss level desired (higher gloss generally means lower PCW content) and color (darker colors may have higher PCS content). Materials added to PCW in remanufacturing include virgin resin, pigments, colorants, rheological additives, biocides, and generally any ingredient added to virgin paint. Tests on the final product are generally the same as those done on virgin paint products of similar type. These include VOC level, sag, scrub, viscosity, gloss, pH, coalescence, adhesion, percent solids, etc. One manufacturer also tests competitors recycled paint products. Internal standards are used to insure quality. No manufacturer currently certifies their reprocessed paint as meeting any published performance standards. Manufacturers certify their products comply with requirements for VOC content and mercury and lead levels. The reprocessed paint products are sold through company-owned stores or contracted vendors. Users include government agencies, consumers, contractors, school districts, and non-profit organizations. The labels used on both consolidated and reprocessed paints generally give information on the PCW content of the product. For consolidated paints, labels give simple directions for use, clean-up, disposal and cautions concerning ventilation, keeping away from children, ingestion, contact and washing after use. For reprocessed paints, labels are more detailed, describing maximum VOC content, surface preparation, priming, material preparation, application, coverage, dry time, clean up, first aid and cautions similar to those for consolidated paint including protection from freezing. B. Research on Recycled Paint Performance Standards As stated in the previous section, currently, no manufacturer of reprocessed latex paint certifies their product as meeting any nationally recognized standard. One goal of this project is the development of a performance standard for recycled paint, including a sorting protocol, ensuring it performs equally to virgin paint in a given category with respect to product quality and health and environmental protection. Ideally, the reprocessed latex paint should be held to the same performance standards as virgin paint, to insure product quality and consumer confidence. Currently available standards and certifications for both recycled and virgin paint were researched. An attempt was made to identify all relevant procurement standards including those from public agencies and the private sector, including the United States Environmental Protection Agency (EPA) and Federal General Services Administration (GSA), California Public Contract Code. Additionally, this report attempts to identify all relevant national performance and environmental standards, testing, and certification organizations including the Master Painters Institute (MPI), Scientific Certification Systems (SCS), ASTM International and non-governmental organizations involved with environmental standards, such as Building for Environmental and Sustainability (BEES) and Green Seal, and individual manufacturers. EPA (United States Environmental Protection Agency) PPSI #8, Cal Poly 6 September 16, 2005 The Environmental Protection Agency worked through the 1990’s to develop guidelines for reprocessed and consolidated paints. Input was solicited from all sectors of the coatings industry. The recommended recovered materials content levels for reprocessed and consolidated latex paints developed as a result of this work are given below: Product Reprocessed Latex Paint White, off-white, pastel colors Grey, brown, earth tones, and other dark colors Consolidated Latex Paint Postconsumer Content (%) Total Recovered Materials Content (%) 20 50-99 20 50-99 100 100 Originally, the EPA product recommendation for reprocessed and consolidated latex paint was GSA specification TT-P-2846, Paint, Latex (Recycled with Post Consumer Waste). TT-P-2846 was withdrawn in 2001 and EPA now recommends procuring agencies refer to GSA commercial item (CID) A-A-3185 Paint, Latex (Containing Post-consumer Material) described more fully under the GSA heading below. The relevant information is available at http://www.epa.gov/cpg/products/paint.htm#recommended Although it does not have a specific specification for recycled paint, EPA does specify procedures for determining environmental properties of paint, notably Method 24 for determination of VOC levels in paint available at http://www.epa.gov/ttn/emc/promgate.html GSA (United States General Services Administration) As mentioned above, the General Services Administration had published a specification for recycled paint as TT-P-2846, Paint, Latex (Recycled with Post Consumer Waste). This specification was withdrawn in 2001 and was replaced with CID A-A-3185 Paint, Latex (Containing Post-consumer Material). The reason for the replacement of TT-P-2846 is not known by the authors of this report. A-A-3185 was adopted on April 3, 2001 and can be found at http://dsp.dla.mil/ Once to the site, select “online specs”, then “click here to get DSP files” then “assist quick search”. For ID use A-A-3185. A-A-3185 covers latex emulsion paint containing a minimum of 20% post-consumer materials. Latex paint is classified into three types: I - interior, II - exterior, III - interior/exterior; three classes: 1 – flat (low sheen), 2 – eggshell, 3 – semi-gloss; and three grades: A – 40% minimum volume solids, B – 30% minimum solids, C – utility (for graffiti abatement). The standard lists prohibited materials, condition in container, color tolerance, accelerated storage, freeze-thaw stability, application properties, odor, dry-through, consistency, VOC content, contrast ratio, alkali resistance, flexibility, scrub resistance, biological growth, total solids, fineness of dispersion, gloss, adhesion, and special marking of “DO NOT FREEZE”. Quantitative PPSI #8, Cal Poly 7 September 16, 2005 requirements for each grade and class are specified as are test methods (either ASTM or Federal Standard). Grades A and B, white/off-white/pastel must contain 20% minimum PCW. Grades A and B, grey/brown, earth tones, dark must contain 50% minimum PCW. All Grade C must contain 100% PCW. All must have <200 g/L VOC (calculated less water and exempt solvents). The intended use and surface preparation are also described. Ordering data and bid evaluation information are also given. National Stock Numbers (NSNs) have been assigned for all types, classes and grades. California Public Contract Code The California Public Contract Code discusses recycled paint in section 12170, paragraph 4: 4. (A) Recycled paint means having a recycled content consisting of at least 50 percent post-consumer paint. Pre-consumer or secondary paint does not qualify as recycled paint pursuant to this subparagraph. (B) If paint containing 50 percent post-consumer is unavailable, a state agency may substitute paint with the maximum amount of postconsumer content, but not less than 10 percent post-consumer content.2 Although this is not a performance standard, it does provide a relevant definition of recycled paint in terms of post-consumer waste content. MPI (Master Painters Institute) The Master Painters Institute was created in 1996 and evolved over a period of 100 years from the The Master House Painters and Decorators Association of USA MPI maintains an extensive website at http://www.paintinfo.com/ Two of the most significant MPI publications are their Maintenance Repainting Manual and Architectural Painting Specification Manual. These manuals provide extensive guidelines on choosing the appropriate paint for a particular surface and describe in detail how the surface should be prepared and how the paint should be applied. MPI provides detailed guidelines on writing paint specifications for a particular application. MPI maintains the MPI Approved Products List identifying manufacturers whose products have been tested and approved by MPI for over 170 different categories of paint. Each of these categories described a paint designed for a particular application, with particular performance and appearance properties. According to Barry Law, MPI President, MPI Standards have replaced the former U.S. Federal Paint Standards, and are now referenced by the U.S. government, the U.S. Military, the IA MasterSpec, Spec Link, the Canadian Government’s National Master Specification, etc. etc. 2 http://www.leginfo.ca.gov/calaw.html PPSI #8, Cal Poly 8 September 16, 2005 They pretty much are “all the relevant standards” relative to virgin architectural coatings. In developing its standards, MPI has also developed its own gloss and sheen classifications, given below. MPI Gloss and Sheen Standards Gloss Level 1 Gloss Level 5 A traditional matte finish - flat Max. 5 units, and A high side sheen flat - 'a Max. 10 units, velvet-like' finish and A traditional 'eggshell-like' 10-25 units, finish and A 'satin-like' finish 20-35 units, and A traditional semi-gloss 35-70 units Gloss Level 6 A traditional gloss 70-85 units Gloss Level 7 A high gloss More than 85 units Gloss Level 2 Gloss Level 3 Gloss Level 4 PPSI #8, Cal Poly Gloss@60° 9 Sheen@85° Max. 10 units 10-35 units 10-35 units Min. 35 units September 16, 2005 More than one MPI standard might apply to a particular type of paint, for example, an “eggshell” interior latex: MPI # 52 139 145 151 Category name Interior Latex, MPI Gloss Level 3 (an ‘eggshell-like’ finish) Interior High Performance Latex, MPI Gloss Level 3 Institutional Low Odor/VOC Interior Latex, MPI Gloss Level 3 Interior W.B. Light Industrial Coating, MPI Gloss Level 3 The MPI #52 standard lists specifications for toxic elements, viscosity, fineness of grind, gloss, hiding power, reflectance, alkali resistance, scrubbability, package stability, applicability and appearance and flexibility. The MPI #139 standard has more stringent scrubbability specifications and additional specifications for burnish resistance and cleansablility. The MPI #145 standard adds a VOC limit of 10 g/L and an odor specification to the MPI #139 standard. The MPI #151 standard is the same as that for MPI # 52 with a more stringent scrubbability specification, a chemical resistance specification replacing the alkali resistance specification, and specifies the paint must be based on an acrylic resin. The MPI standards provide detailed instructions for test methods, often with references to ASTM or EPA methods. Labeling details are also specified. To be qualified and approved for listing by MPI, products must be tested by MPI to assure compliance. Continued compliance is confirmed by periodic MPI testing. All costs for testing are borne by the manufacturer. MPI recently announced its MPI Green Performance Standard for paints and coatings, designated GPS-1-05. The standard designates those products meeting performance requirements, banned chemical list requirements and current and future maximum VOC limits. A list of MPI standards thought to be relevant to recycled paints is given in Table II. These standards can be purchased from MPI for $20 each or $500 for the entire set of standards. PPSI #8, Cal Poly 10 September 16, 2005 Table II MPI Standard Categories Relevant to Recycled Latex Paint Products MPI Category Name # 6 Exterior Latex Wood Primer 10 Exterior Latex, Flat, MPI Gloss Level 1 11 Exterior Latex, Semi-Gloss, MPI Gloss Level 5 15 Exterior Latex, Low Sheen , MPI Gloss Level 3-4 16 Exterior Latex-Based Solid Hide Stain 40 Exterior High Build Latex 43 Interior Latex, MPI Gloss Level 4 (a 'satin-like' finish) 44 Interior Latex, MPI Gloss Level 2 (a high side sheen flat, 'velvet-like') 50 Interior Latex Primer Sealer 52 Interior Latex, MPI Gloss Level 3 (an ‘eggshell-like’ finish) 53 Interior Latex, Flat, MPI Gloss Level 1 54 Interior Latex, Semi-Gloss, MPI Gloss Level 5 60 Interior/Exterior Latex Floor Paint, Low Gloss 68 Interior/Exterior Latex Floor Enamel, Gloss 114 Interior Latex, Gloss, MPI Gloss Level 6 119 Exterior Latex, Gloss, MPI Gloss Level 6 138 Interior High Performance Latex, MPI Gloss Level 2 139 Interior High Performance Latex, MPI Gloss Level 3 140 Interior High Performance Latex, MPI Gloss Level 4 141 Interior High Performance Latex, MPI Gloss Level 5 143 Institutional Low Odor/VOC Interior Latex, Flat, MPI Gloss Level 1 144 Institutional Low Odor/VOC Interior Latex, MPI Gloss Level 2 145 Institutional Low Odor/VOC Interior Latex, MPI Gloss Level 3 146 Institutional Low Odor/VOC Interior Latex, MPI Gloss Level 4 147 Institutional Low Odor/VOC Interior Latex, Semi-Gloss, MPI Gloss Level 5 148 Institutional Low Odor/VOC Interior Latex, Gloss, MPI Gloss Level 6 149 Institutional Low Odor/VOC Interior Latex Primer Sealer Interior W.B. Light Industrial Coating, MPI Gloss Level 3 [Formerly, MPI # 110 - Gloss 151 Level 3] Interior W.B. Light Industrial Coating, Semi-Gloss, MPI Gloss Level 5 [Formerly, MPI # 153 110 - Gloss Level 5] Interior W.B. Light Industrial Coating, Gloss, MPI Gloss Level 6 [Formerly, MPI # 110 154 Gloss Level 6] PPSI #8, Cal Poly 11 September 16, 2005 Exterior W.B. Light Industrial Coating, MPI Gloss Level 3 [Formerly, MPI # 110 - Gloss Level 3] Exterior W.B. Light Industrial Coating, Semi-Gloss, MPI Gloss Level 5 [Formerly, MPI # 163 110 - Gloss Level 5] Exterior W.B. Light Industrial Coating, Gloss, MPI Gloss Level 6 [Formerly, MPI # 110 164 Gloss Level 6] 161 BEES (Building for Environmental and Economic Sustainability) BEES is a methodology taking a multidimensional, life-cycle approach to assessing impact of wide range of products on the environment. Economic analysis of products throughout their life-cycle is an integral part of this methodology. This automated method for measuring the life-cycle environmental and economic performance of building products has been developed by the Building and Fire Research Laboratory of the National Institute of Standards and Technology (NIST). The effect of 1 ft2 of a product over a 50 year cycle is used as a standard measure to compare alternative products for a given application. Environmental impact of a product is analyzed on the basis of 12 attributes listed below: Global Warming Acidification Eutrophication Fossil Fuel Depletion Indoor Air Quality Habitat Alteration Water Intake Criteria Air Pollutants Human Health Smog Ozone Depletion Ecological Toxicity Economic score is based on two attributes, First Cost and Future Costs. BEES 3.0 software package and an accompanying report can be downloaded from the BEES website, http://www.bfrl.nist.gov/oae/software/bees.html In the current version of BEES (Version 3.0) a generic, virgin, interior wall paint is compared with a generic recycled paint containing 65% recycled content. Based on the formulation information provided, the two examples are for white paints. In our assessment, although the assumptions used in analyzing the two examples require further review, BEES methodology is a useful tool that should be considered at a more detailed level during Phase III activities. Environmental and economic scores based on BEES can serve as a tool in an objective determination of the impact of recycling latex paints. A favorable BEES score would be a valuable marketing tool. According to Barbara Lippiatt of NIST, work on version 4.0 of BEES is in progress. Our project has the opportunity to provide timely input regarding the recycle paint analysis section of the new version of BEES. Current cost per product (subsidized by PPSI #8, Cal Poly 12 September 16, 2005 BEES funds) are $8,000 for first product and $4,000 each, for additional products. This cost covers BEES analysis including the twelve environmental impacts listed above. SCS (Scientific Certification Systems) SCS is a third-party certifying agency involved in certifying materials in a wide range of fields including food and agriculture, manufacturing, forestry, fisheries, electricity, and CSR (corporate social responsibility) purchasing. SCS services include environmental certifications and life-cycle assessments. Certification of paints and coatings would be handled through the Manufacturing Division. The familiarity of SCS with coatings and coating formulations appears to be very limited. Green Seal Green Seal is an independent non-profit organization, whose mission is “to achieve a more sustainable world by promoting environmentally responsible production, purchasing, and products.” Green Seal follows the Guiding Principles and Procedures for Type I Environmental Labeling adopted by the International Organization for Standardization (ISO 14024). As the Work Group members are aware, Green Seal is well known in the environmental community for its involvement in activities stated in their mission. Among many product certification standards available from Green Seal, there are two certification standards for paints, GS-11 (Paints) and GC-03 (Anti-Corrosive Paints). GS-11 deals with architectural interior top coats and exterior top coats, and thus, is relevant to this report. The complete GS-11 standard is available at http://www.greenseal.org/standards/paints.htm. Information on paint products along with names of manufacturers marketing virgin latex paints certified under GS-11 can be found at http://www.greenseal.org/certproducts.htm#paints. Currently, no recycled paint product is marketed with Green Seal certification. A recycled product meeting the GS-11 standard must pass Green Seal’s certification process including a life-cycle environmental impact analysis. In preparing for this project, PSI’s Paint Dialogue Team held discussions with Green Seal concerning certification of recycled paints. According to those discussions the certification costs could vary between $10,000 and $90,000. However, it is expected this cost would at the lower end because this project will generate most of the background information necessary for potential Green Seal certification. ASTM International (formerly known as the American Society for Testing and Materials or simply ASTM) ASTM standard test methods are widely used, both within the United States and internationally, in determining the performance of coatings and other materials. ASTM has no certification methodologies for paints or related products. However, ASTM test methods are integral to other certification methodologies discussed above. ASTM has developed standards for other recycled products, including paper. The possibility of ASTM developing a standard for recycled paint products will be investigated in Phase III. PPSI #8, Cal Poly 13 September 16, 2005 Certification and Standards Matrix Table III below presents the current state of our research on recycled paint performance standards and certification. This matrix will be used in Phase III to guide our activities in developing the certification process and related performance standards for recycled paint products. Table III Recycled Paint Certification and Performance Standards Matrix Organization EPA/GSA MPI BEES Services Offered Procurement Standards, Performance Standards Performance Certification Potential Benefits to PPSI National recognition, standard for recycled paint National recognition, listing of approved products Life-Cycle Methodology Impact Analysis allows objective comparison of recycled and virgin paints. Can be a valuable marketing tool. SCS Life-Cycle Assessment & Environmental Certification Green Seal Life-Cycle Assessment, Performance Standards & Environmental Certification ASTM Performance Testing Methods PPSI #8, Cal Poly Recommend ed Action Compare to MPI Use for performance standard Initiate dialog with NIST to refine method to fit paint products. Familiarity with None paint industry is limited. Services offered are duplicated by others being considered. Certification can Pursue validate products. Can be a valuable marketing tool. Test methods are widely used by other organizations. 14 Cost Current version (BEES 3.0) is free. NIST will conduct first product analysis for $8000. Cost for each additional product is $4000 N/A $10,000 to 90,000 to develop standard, 5-tier fee structure for product certification Maintain awareness of changes September 16, 2005 C. Summary Current Recycled Paint Manufacturing Current manufacturers of recycled paint products generally produce either consolidated paint products or reprocessed (remanufactured) paint products, not both. Reprocessed paint manufacturers produce latex interior, exterior or interior/exterior products. The post-consumer waste content of these reprocessed products is at least 50%. The screening of the PCW stream varies, ranging from simple visual and odor tests, to more extensive tests typically applied to virgin paint. The frequency of these more extensive tests is not known at this time. None of the manufacturers surveyed currently certifies their recycled paint products using any nationally recognized performance standard or certification. Having recycled paint products meet accepted performance standards should increase their marketability. Recycled Paint Certification Standards EPA, GSA, state contract codes, MPI, BEES and Green Seal are very relevant to our goals of developing standards for recycled paint products based on our review of certifying and regulatory organizations. Although some overlaps exist in their functions, each has certain unique features. Pursuing certification through SCS is not prudent at this time since SCS has limited familiarity with coatings and other more relevant options are available. The EPA has carefully developed recommended recovered materials content levels for reprocessed and consolidated latex paints and uses the CID A-A-3185 specification for latex paint. We believe EPA’s recommended PCW levels are an excellent guidepost for all reprocessed and consolidated latex paints. The GSA standard for latex paint with post-consumer waste, CID A-A-3185, provides a comprehensive array of tests and is a valuable standard. The standard classifies recycled paints into three types, three classes, and three grades. Recycled paints with minimum 40% volume solids (grade A) and meeting this standard should be comparable in quality to virgin paints of similar type. The MPI standards are by far the most comprehensive of the standards researched for this report. These standards were developed for virgin paint products, but there in no reason they could not be applied equally well to reprocessed paint products. If a can of paint meets the applicable MPI standard, it doesn’t matter if it was produced entirely from virgin materials or from a combination of PCW and virgin material -- it still meets the standard and should be listed as an approved MPI product. As stated by MPI President Barry Law, “… as it presently stands MPI is not prepared to list recycled product(s) unless they not only meet current MPI Standards but are confirmed as meeting those standards by the same MPI lab as all other MPI Approved Product Listings”. MPI certification would be “proof” a reprocessed paint was of equal quality in terms of performance and safety to a virgin paint. We see no reason to develop special new standards for reprocessed paint products. PPSI #8, Cal Poly 15 September 16, 2005 BEES offers the complete life-cycle analysis of products, a feature not offered by other approaches. The 50-year span used for analysis of paint products may be too long, although 50 years may be quite relevant for other products (e.g. roof shingles). The Work Group has the option to review this and other assumptions defining the BEES model making it a more useful tool for comparing virgin and recycled paints. A method for comparing virgin and recycled paints with equivalent performance in terms of the environmental and economic impact would be very useful. Green Seal certification would provide a recognized and respected validation of the positive environmental impact of recycled paint products. It is likely reprocessed paint meeting the appropriate MPI performance standard would also meet Green Seal’s GS 11 standard. The Recycled Paint Certification and Performance Standards Matrix in Table III will be used to focus our efforts in Phase III on development of certification and performance standards. Post-consumer Waste Content of Recycled Paint Based on the results of the manufacturer survey and available certification and standards options, the most logical approach is to continue the division of recycled paint into consolidated paint and reprocessed (remanufactured) paint. Consolidated paint will consist of 95% minimum post-consumer waste and a maximum of 5% other secondary industrial materials (off batches, mis-tints) and virgin additives, such as biocides and rheology modifiers. Reprocessed paint with performance properties matching those of virgin paint will be produced from post-consumer waste, virgin materials such as resin, pigments and additives, and other secondary industrial materials. This product can likely be produced containing at least 50% post-consumer waste for darker colors. A question remains whether or not high quality white paints can be produced at this level given the nature of the post-consumer waste stream. A recommended minimum level of 50% post-consumer waste for whites and pastels should be the goal. However, if whites and pastels containing 50% post-consumer waste are not available, product containing a minimum of 25% post-consumer waste and 50% minimum total recycled material content (post-consumer waste and secondary industrial materials) would be acceptable. However, all attempts should be made to keep the post-consumer waste content as high as possible while still maintaining quality equal to that of virgin paint. These recommendations are summarized in Table IV. Table IV Recommended Post-Consumer Waste Content for Recycled Paint Products Product Minimum % post consumer waste Consolidated paint 95% minimum Secondary industrial materials 5% maximum Reprocessed paint (darker colors) Reprocessed paint (whites, off-whites and pastels) 50% varies 5% maximum varies 50% if possible, 25% minimum with total recycled content at least 50% varies varies PPSI #8, Cal Poly 16 Virgin materials September 16, 2005 II. Future Work Phase III of Project 8 will commence upon submittal of this report. The primary responsibilities of the Cal Poly group in Phase III will be creation of a draft standard for recycled paint, development of a draft testing process for validation of the standard, manage peer review of standards and validation process and development of final standard. Several major questions will need to be answered to achieve these goals, some of which were raised during Phase II. For example, how often will recycled paint products need to be tested? What fraction of the collected PCW will need to be tested? Will all reprocessed paint have the same minimum PCW content or will some sliding scale be used. Can all reprocessed paint be held to the same performance standard? Can federal, state, and local agencies agree to a uniform standard and certification process? What costs will be associated with certification and product listing by recognized standards organizations? The input and cooperation of the PSSI Work Group will be critical to our being able to answer these and other questions and to achieve our ultimate goals. PPSI #8, Cal Poly 17 September 16, 2005