Project #9: Health, Safety, Environmental & Regulatory Issues
NPCA developed a document that details the health, safety, and environmental regulations to which paint manufacturers must comply, and identified regulatory barriers to the manufacturer of reblended or recycled post-consumer content latex and solvent-based paint. The document, entitled Health, Safety, Environmental and Regulatory Issues White Paper, was reviewed by the Regulatory Workgroup and approved by the full PPSI group. PSI edited the document, assisted in resolving key issues, and finalized it in January 2007.
The workgroup found that the biggest barrier for recycled paint manufacturers is that they deal with an unknown material content, and must set up extensive sorting and testing protocols to ensure that they meet hazard communication requirements. Virgin paint manufacturers, conversely, deal with known materials and use formulation data to verify product content from raw materials.
Three recommendations were considered that could reduce the barriers to the manufacture of recycled paint:
|Extend the volatile organic content (VOC) content provisions of the federal Architectural and Industrial Maintenance rule for recycled content paint to Ozone Transport Commission States (Maine to Virginia) and others.|
|2.||Creation of a uniform system of regulations for recycled paint manufacture, based on recycled material being a "product” and not a "waste.”|
|3.||Use of OSHA’s "mixture rule” to address hazard communication requirements.|
The PPSI group decided that the final document should include a recommendation to extend the VOC content provisions. The completion of the recycled paint standard bolsters the argument to extend the VOC content provisions. PSI will now assist PPSI participants in implementing the recommendation. PSI has also begun to follow up with U.S. Occupational Safety and Health Administration (OSHA) to obtain its acceptance in writing regarding the current procedure followed by paint recyclers using virgin paint material safety data sheets (MSDSs) as representative of the contents of recycled paint.
Project #10: Financing System Research and Model Development
This project prepared PPSI participants for discussions on financing related to the development of a nationally coordinated paint management system.
Following an extensive presentation by state and local government officials at the September 20-21, 2006 dialogue meeting in Charlotte, North Carolina, industry participants agreed that there is the need for a new type of financing system. "Financing system" is defined as a mechanism that can provide short-term (preferably) or longer-term funding to offset the differential between the cost of collection, transportation, and processing of leftover paint and the value of the finished product. Dialogue participants agreed that, if there is a national system for managing leftover paint, someone will have to pay for it, and that a sustainable financing system was, therefore, needed. This decision was made ahead of the January 1, 2007, decision as called for in the MOU.
As originally scoped, PSI was asked to conduct research on transitional and long-term financing models and evaluate their potential application to the leftover paint financing discussions. PSI was also set to prepare a list of options and attempt to recommend a fair funding scenario for a future nationally coordinated paint management system. PSI did not receive the full funding estimated in the original project scope. Currently, funding is available to conduct only limited research. Additional funding will be required to perform the full set of tasks.
Project #11: Lifecycle Balance of Costs and Benefits
One of the key questions raised during the paint dialogue has been whether the lifecycle benefit to reusing or recycling latex paint outweighs the costs, and how these costs and benefits compare to disposing of the latex paint. This project will scientifically evaluate the environmental and other lifecycle costs and benefits of managing leftover paint through six specific management scenarios, ranging from simple drying/solid waste disposal to reuse and recycling.
NPCA has funded the project. NPCA, on behalf of the Lifecycle Workgroup, hired ICF to scope the cost-benefit analysis (CBA), and a combined team of First Environment and Franklin Associates to scope the life-cycle assessment (LCA). These scoping documents were finalized in December 2005 with significant workgroup input and PSI facilitation. The workgroup issued a second RFP in mid-December for the actual CBA and LCA. NPCA, on behalf of the Lifecycle Workgroup, hired the Eastern Research Group (the parent company of Franklin Associates) to complete the LCA and CBA. A draft LCA was completed, along with numerous consultant documents, and comments on the documents from government and industry participants. Following several delays, PSI facilitated remaining issues among government and industry stakeholders in spring 2008. A revised LCA is expected by summer 2008, and a draft CBA sometime thereafter.
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