United States Office of EPA/560/2-91-002
Environmental Protection Toxic Substances September 1991
Agency (TS-778)
&EPA Carpet Policy Dialogue
Compendium Report
September 27,1991
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CARPET POLICY DIALOGUE
Compendium Report
September 27, 1991
Prepared for:
Office of Toxic Substances
U.S. Environmental Protection Agency
Washington, D.C. 20460
Prepared by:
The Carpet Policy Dialogue Group
Project Coordinator
Richard W. Leukroth, Jr.
U.S. Environmental Protection Agency
^s« JaS fc;|, 12
Chicago, IL 60604-3^0
,-- -: Printed on Recycled Paper
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ACKNOWLEDGEMENTS
September 27, 1991
As the Carpet Policy Dialogue comes to a close, I would like to take this opportunity to
express my sincere appreciation to the members of the Carpet Policy Dialogue, the working
Subgroups, and the project staff for their dedication to this year-long effort.
The Carpet Policy Dialogue has been a major initiative for the Office of Toxic Substances.
It provided a first opportunity to apply pollution prevention principles to an issue concerning
indoor air. The Dialogue process itself represented a new approach to problem resolution for
the Office. The full and active participation by all members of the Dialogue was essential to
achieving success with this project.
The basis for success in a Dialogue is measured by the willingness of all participants to find
common objectives and then for the dialogue Group to encompass these points into voluntary
actions for the public interest. I am aware that participation in the Carpet Policy Dialogue
necessitated considerable focus of energy, thought, time, and resources. The Dialogue
process involved listening to and sharing of views and ideas, and I greatly appreciate the
willingness of all participants to work productively and cooperatively in this effort with
Dialogue members who shared diverse viewpoints.
I would like to assure that the Environmental Protection Agency is committed to follow
through on the recommendations of the Carpet Policy Dialogue. The actions set in place
through the testing and reporting programs recommended by the Dialogue and implemented
via a series of Memoranda of Understanding between EPA and the affected industries
provide a viable and effective basis for the Agency to meet the objectives outlined in the
April 24, 1990, Federal Register notice.
Thanks to all those who participated in helping the Environmental Protection Agency achieve
notable progress on the issue of TVOC emissions from carpet floor covering products.
Sincerely,
Charles M. Auer
Director, Existing Chemicals Assessment Division
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TABLE OF CONTENTS
Page
Foreword i
Executive Summary iii
1.0. Chapter 1: Carpet Policy Dialogue Plenary Report 1-1
1.1. Introduction 1-1
1.1.1. Background 1-1
1.1.2. Implementation of the Carpet Policy Dialogue 1-2
1.1.3. Structural Organization 1-3
1.1.4. Nature of Dialogue Consensus Statements and Voluntary Actions 1-3
1.1.5. Dialogue Discussions 1-4
1.1.5.1. Health Concerns 1-5
1.1.5.2. Proprietary or Confidential Information 1-6
1.1.5.3. TVOC Data and Chemical Speciation 1-6
1.2. Summary of the Subgroup Activities 1-7
1.2.1. Product Testing Subgroup 1-8
1.2.2. Process Engineering Subgroup 1-9
1.2.3. Public Communications Subgroup 1-10
1.3. Carpet Related Activities 1-11
1.3.1. Styrene Butadiene Latex Manufacturers 1-11
1.3.2. Carpet Manufacturers 1-12
1.3.3. Carpet Cushion Manufacturers 1-12
1.3.4. Adhesive Manufacturers 1-13
1.3.5. Consumer Product Safety Commission 1-13
1.3.6. EPA Carpet Installation Study 1-13
1.3.7. Floor Covering Installation Contractors Association 1-14
1.3.8. Collaborative Research 1-14
1.3.9. General Services Administration 1-14
1.3.10. Environmental Protection Agency and General Services
Administration 1-15
1.4. Future Considerations 1-15
1.5. Summary 1-17
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TABLE OF CONTENTS
Page
2.0. Chapter 2: Product Testing Subgroup: Methods and Accomplishments 2-1
2.1. Introduction 2-1
2.2. Test Method Development 2-1
2.2.1. Total Volatile Organic Compounds 2-2
2.2.2. Evaluation of Alternative Test Methods 2-2
2.2.2.1. Quality Control/Internal Processing Test Methods 2-3
2.2.2.2. Method Elements and Test Parameters 2-3
2.2.3. Standard Test Method 2-4
2.3. Consensus on Voluntary Testing Agreements 2-5
2.3.1. Carpet Testing Program 2-6
2.3.2. Carpet Cushion Testing Program 2-8
2.3.3. Carpet Installation Adhesive Testing Program 2-10
3.0. Chapter 3: Process Engineering Subgroup Summary Report 3-1
3.1. Introduction 3-1
3.1.1. Background 3-1
3.1.2. Charter and Charge of Dialogue 3-1
3.1.3. Dialogue Defined 3-2
3.1.4. Process Engineering Subgroup 3-3
3.1.4.1. Scope of Subgroup Activities 3-3
3.1.4.2. Organization and Operational Structure 3-3
3.1.4.3. Process Engineering Subgroup Proceedings 3-4
3.1.4.4. Purpose of This Chapter 3-8
3.2. Styrene Butadiene Latex Manufacturing 3-8
3.2.1. Process Description 3-8
3.2.2. VOC Reductions Already Achieved 3-13
3.2.3. Potential VOC Reduction Mechanisms 3-15
3.2.4. Process Engineering Subgroup Proceedings 3-18
3.2.5. Information and Research Considerations 3-19
3.2.6. Subgroup Recommendations to Plenary 3-20
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TABLE OF CONTENTS
Page
3.3. Adhesives Manufacturing/Formulation 3-20
3.3.1. Overview of Carpet Adhesives and Formulation Process 3-20
3.3.1.1. Adhesive Properties 3-20
3.3.1.2. Types of Adhesives 3-21
3.3.1.3. Raw Materials and Formulation 3-22
3.3.2. Use of Adhesives During Carpet Installation 3-24
3.3.2.1, Multipurpose Adhesives 3-24
3.3.2.2. Pressure-Sensitive Adhesive 3-26
3.3.3. VOC Reductions Already Achieved 3-26
3.3.4. Potential VOC Reduction Methods 3-28
3.3.5. Process Engineering Subgroup Proceedings 3-31
3.3.6. Information and Research Considerations 3-31
3.3.7. Subgroup Recommendation to Plenary 3-32
3.4. Carpet Cushion Manufacturing Process Description 3-32
3.4.1. Process Description 3-32
3.4.1.1. Prime Urethane Foam Carpet Cushion 3-33
3.4.1.2. Bonded Urethane Carpet Cushion 3-38
3.4.1.3. Cellular Sponge Rubber Carpet Cushion 3-41
3.4.1.4. Rubberized Jute Carpet Cushion 3-43
3.4.1.5. Synthetic Fiber Carpet Cushion 3-44
3.4.2. VOC Reductions Already Achieved 3-45
3.4.3. Potential VOC Reduction Methods 3-46
3.4.4. Process Engineering Subgroup Proceedings 3-46
3.4.5. Information and Research Considerations 3-47
3.4.6. Subgroup Recommendations to Plenary 3-48
3.5. Carpet Manufacturing 3-49
3.5.1. Process Description 3-49
3.5.1.1. Carpet Face Fiber 3-49
3.5.1.2. Carpet Yarn Manufacturing 3-51
3.5.1.3. Carpet Coloration 3-51
3.5.1.4. Carpet Formation 3-65
3.5.1.5. Carpet Finishing 3-73
3.5.1.6. Stain Resist Technology for Nylon 3-79
3.5.1.7. Soil Release 3-82
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TABLE OF CONTENTS
Page
3.5.2. VOC Reductions Already Achieved , 3-85
3.5.3. Dr. Van Ert's Laboratory-Scale Study 3-85
3.5.4. Industry-Sponsored Plant-Scale Study 3-87
3.5.5. Process Engineering Subgroup Proceedings 3-88
3.5.6. Information and Research Considerations 3-89
3.5.7. Subgroup Recommendations to Plenary 3-89
3.6. Carpet Installation/Ventilation 3-89
3.6.1. Introduction 3-89
3.6.2. The Scope of Existing Guidelines for Installation 3-90
3.6.3. An Overview of the Installation Process 3-90
3.6.4. Training, Education, and Certification Programs 3-92
3.6.5. Specific Guidelines Which May Impact VOC Exposures 3-93
3.6.6. Practical Experience in Compliance With Installation Guidelines 3-94
3.6.7. Effects of Ventilation During Carpet Installation on VOC Emissions . . 3-95
3.6.7.1. Indoor Air Quality 3-95
3.6.7.2. Ventilation in Office Buildings 3-95
3.6.7.3. Effects of Ventilation Rates on Indoor Air
Concentrations of 4-Phenylcyclohexene from Carpet
Emissions 3-102
3.6.7.4. General Concepts of Physical Processes Affecting VOC Carpet
Emissions 3-105
3.6.7.5. Practical Control Strategies for Carpet System VOC
Emissions and Residual Indoor Air Concentrations .... 3-105
3.6.8. Process Engineering Subgroup Proceedings 3-109
3.6.9. Research Consideration 3-110
3.6.10. Subgroup Recommendations to Plenary 3-110
4.0. Chapter 4: Public Communications Subgroup Report 4-1
4.1. Introduction 4-1
4.2. Scope of Work 4-1
4.2.1. Setting Goals 4-2
4.2.2. Operating Procedures 4-3
4.2.3. Principles Governing Dialogue Communication Activities 4-3
4.2.4. Discussion Topics 4-4
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TABLE OF CONTENTS
Page
4.3. Communications Planning 4-6
4.3.1. Step 1: Situation Analysis 4-6
4.3.2. Step 2: Set Objectives 4-8
4.3.3. Step 3: Identify Target Audiences 4-8
4.3.4. Step 4: Identify Issues and Concerns 4-9
4.3.5. Step 5: Develop Messages 4-9
4.3.6. Step 6: Establish Strategy 4-9
4.3.7. Step 7: Select Media/products 4-10
4.3.8. Step 8: Determine Budget 4-10
4.3.9. Step 9: Set Time Table to Implement Plan 4-10
4.3.10. Step 10: Evaluate Results 4-10
4.4. Public Communication Outreach Products 4-11
4.4.1. Interim Progress Report 4-13
4.4.2. Executive Summary 4-14
4.4.3. Public Information Brochure 4-15
4.4.4. Compendium Report 4-19
5.0. References 5-1
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TABLE OF CONTENTS
Appendix A. List of Carpet Policy Dialogue Participants
Appendix B. Federal Register, Vol. 55. No. 79; Part VII, Environmental Protection Agency,
Carpet Response to Citizens' Petition; Notice
Appendix C. Federal Register, Vol. 55, No. 130; Carpet Emissions Reduction; Policy
Dialogue
Appendix D. Schedule of Carpet Policy Dialogue Meetings
Appendix E. Test Method for Determining Total Volatile Organic Compound Emission
Factors from Carpet Under Defined Test Conditions Using Small Environmental
Chambers
Attachment E-l. Annex
Appendix F. Carpet and Rug Institute Consensus Statement: Testing Program for Carpet
Products
Attachment F-l. The Carpet and Rug Institute Consensus Statement: Carpet
Emissions Decay Study
Attachment F-2. Minority Report on Carpet Testing Agreement
Appendix G. Carpet Cushion Council Consensus Statement: Testing Program for Carpet
Cushions
Appendix H. Floor Covering Adhesive Manufacturers Committee Consensus Statement:
Testing Program for Carpet Installation Adhesives
Appendix I. Memorandum of Understanding Between the Carpet and Rug Institute and the
U.S. Environmental Protection Agency
Attachment 1-1. Federal Register: Carpet Policy Dialogue; Memorandum of
Understanding: Testing Program for Carpet Products and
Receipt of the Carpet Policy Dialogue Interim Progress
Report
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TABLE OF CONTENTS
Appendix J. Memorandum of Understanding Between the Carpet Cushion Council and the
U.S. Environmental Protection Agency
Attachment J-l. Federal Register: Carpet Policy Dialogue; Memorandum of
Understanding: Testing Program for Carpet Cushion
Products
Appendix K. Memorandum of Understanding Between the Floor Covering Adhesive
Manufacturers Committee and the U.S. Environmental Protection Agency
Attachment K-l. Federal Register: Carpet Policy Dialogue; Memorandum of
Understanding: Testing Program for Carpet Installation
Adhesives
Appendix L. Memorandum of Understanding Between the Styrene Butadiene Latex
Manufacturers' Council and the U.S. Environmental Protection Agency
Attachment L-l Quantitation of 4-Phenylcyclohexene in Styrene Butadiene
Latex
Attachment L-2 Federal Register: Carpet Policy Dialogue; Memorandum of
Understanding: SBLMC Reporting Program for 4-PC
Appendix M. Final Text of Public Information Brochure: "Indoor Air Quality and New
Carpet, What You Should Know"
Appendix N. Final Report: "Investigating the Impact of Various Cure Parameters on the
Release of 4-Phenylcyclohexene (4-PCH) from Carpet Backed with
Compounds Based on Carboxylated SBR Latex"
Attachment N-l Preparation of Carpet Backed with Styrene Butadiene
Rubber Latex
Appendix O. Effects of Selected Process Parameters on Emission Rates of TVOC From
Carpet
Appendix P. CRI Commercial Carpet Installation Standard
Appendix Q. CRI Residential Carpet Installation Standard
Appendix R. Indoor Air Quality Evaluation of Carpet for the Carpet and Rug Institute
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LIST OF TABLES
Page
Table 3-1. Technical Presentations Made to the Process Engineering Subgroup ... 3-5
Table 3-2. U.S. Companies Producing SB Latex 3-11
Table 3-3. Adhesive Components and Associated VOC Range 3-25
Table 3-4. Prime Urethane Foam Carpet Cushion Components and
Typical Raw Materials 3-34
Table 3-5. Raw Materials of Carpet Cushion-Ranked in Order of Use 3-39
Table 3-6. TVOC and 4-Phenylcyclohexene 24-Hour Emission Rates
of New Carpet 3-86
Table 4-1. Tentative List of Discussion Topics for the Public Communication Subgroup 4-5
Table 4-2. Potential Public Communications Outreach Products 4-12
Table 4-3. List of Organizations That Agreed to Be Listed on the Brochure 4-18
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LIST OF FIGURES
Page
Figure 3-1. Flowchart of the SBL Process 3-12
Figure 3-2. 4-Phenylcyclohexene Reduction History 3-14
Figure 3-3. VOC Range of Multi-Purpose Adhesives 3-29
Figure 3-4. VOC Range of Pressure Sensitive Adhesives 3-30
Figure 3-5. Flexible PUR Slabstock Process Line 3-37
Figure 3-6. Model of Simplified Loom 3-72
Figure 3-7. General Structure of Stain Resist Agents 3-80
Figure 3-8. Ventilation Rates and Indoor Air VOC Concentration 3-96
Figure 3-9. Flow Diagram of a Typical Building Ventilation System 3-97
Figure 3-10. Air Exchange Rates in the Portland East Federal Office Building . . . 3-99
Figure 3-11. Summary of Air Exchange Rates in Buildings Studies by NIST .... 3-100
Figure 3-12. Distribution of Air Exchange Rates in Buildings Studied by NIST . . . 3-101
Figure 3-13. Effect of Air Exchange Rate (Outside Air) 3-103
Figure 3-14. Effect of Airing Out Prior to Installation 3-104
Figure 3-15. Temperature and Vapor Pressure Relationship for Three Compounds . 3-106
Figure 3-16. Evaporation Under Equilibrium Conditions 3-107
Figure 3-17. Accelerated Evaporation in the Presence of Increased Contact
Air Velocity 3-108
Figure 4-1. Communications Planning Process 4-7
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EPA FOREWORD
The Carpet Policy Dialogue, convened by the U.S. Environmental Protection
Agency,1 was engaged in a 1-year effort to develop consensus and voluntary commitments
with respect to approaches for minimizing exposure to volatile organic compounds (VOCs)
emitted by carpet, carpet cushion, and carpet floor covering installation adhesives (FR: April
24, 1990 - "Carpet: Response to Citizens' Petition" p. 17404-17409; and, FR: August 3,
1990 - "Carpet Emissions Reduction; Policy Dialogue" p.31640-34641).
This document conveys the Compendium Report of the Carpet Policy Dialogue
Plenary regarding activities of the Carpet Policy Dialogue from August 21, 1990, through
September 27, 1991. The report is an assembly of the various products and materials
developed by the three working Subgroups of the Carpet Policy Dialogue (Product Testing,
Process Engineering, and Public Communications). It is a summary document encapsulating
the considerations, deliberations, accomplishments, conclusions, and recommendations
reached by the Carpet Policy Dialogue and its various Subgroups during the Dialogue year.
This report was a product of the Public Communications Subgroup of the Carpet Policy
Dialogue. It has been reviewed by the Carpet Policy Dialogue Plenary and approved for
distribution.
Approval of this report and other products and agreements of the Carpet Policy
Dialogue were attained by the consensus process described in this report. Such agreement
does not signify that the contents of such materials necessarily reflect the views and policies
of the groups or organizations (governmental or nongovernmental) participating in the Carpet
Policy Dialogue. Listing the names of individuals as participants in the Carpet Policy
Dialogue (Appendix A) does not necessarily imply that these individuals concur with all
aspects of the materials and products developed during the Dialogue year. Listing of these
individuals also does not imply the official approval or endorsement by the organization
(governmental or non governmental) they represented.
This report was submitted into the Carpet Emissions Administrative Record at the
TSCA Public Docket Office located at: Environmental Protection Agency, Rm. NE-G004,
401 M St., SW, Washington, DC 20460. The Carpet Emissions Administrative Record will
also contain data and information about TVOC emissions to be developed under the terms
and conditions of a series of Memoranda of Understanding established between EPA and the
Carpet and Rug Institute, the Carpet Cushion Council, the Floor Covering Adhesive
Manufacturers Committee of the National Association of Floor Covering Distributors, and
the Styrene Butadiene Latex Manufacturers Council. This report and the data bases to be
developed under the previously mentioned voluntary testing and reporting programs responds
to the charge set by EPA to the Carpet Policy Dialogue.
1 Activities of the Carpet Policy Dialogue were facilitated under Delivery Order #39 of Contract Number EPA
68-W8-0072 and Delivery Order #3 of Contract 68-W1-0014.
i
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EXECUTIVE SUMMARY
September 27, 1991
CARPET POLICY DIALOGUE PURPOSE
Government, industry, and other interested parties worked together in a voluntary
framework to reduce total volatile organic compound (TVOC) emissions associated with new
carpet installation. These groups worked towards: (1) characterizing the nature of TVOC
emissions from carpet, carpet cushion, and carpet installation adhesives; (2) developing a
standard test method for measuring TVOC emissions; (3) increasing industry's commitment
to conduct voluntary product testing for TVOC's; (4) evaluating potential process or
engineering changes that could lead to reduction in TVOC emissions from newly
manufactured carpet products and associated installation technologies for such products; and
(5) providing the interested public with information on TVOC emissions from new carpet,
carpet cushions, and adhesives used in carpet installation.
BACKGROUND
In 1990, EPA received a citizen's petition under Section 21 of the Toxic
Substances Control Act (TSCA) from Local 2050 of the National Federation of
Federal Employees (NFFE). The petition focused attention on employee
concerns about a variety of health reports claimed to be related to the emission
of 4-phenylcyclohexene (4-PC) from newly installed carpets and sought EPA
regulatory action to remedy exposure concerns. Following a review of the
petition, EPA published a Federal Register notice (April 24, 1990) denying the
petition on the basis that there was insufficient data to support the conclusions
and remedies sought by the union. However, the EPA stated that as a matter
of policy, "it is prudent to minimize indoor human exposure to VOC's where
reasonable."
The Carpet Policy Dialogue served as EPA's forum to encourage actions that
will reduce TVOC emissions from carpet, carpet cushion, and carpet adhesive
products. The Carpet Policy Dialogue was initiated on August 21, 1990. It
was composed of representatives from industry, public interest groups, labor,
other interested government agencies, and members of the scientific and
research communities. To address the objectives (see above), the Carpet
Policy Dialogue formed three technical subgroups: Product Testing, Process
Engineering, and Public Communications.
The Carpet Policy Dialogue was a 1-year effort which ended in September of
1991. Information gathered under the charter of the Carpet Policy Dialogue
has been assembled into a Compendium Report which describes the
information and findings from its deliberations. In addition, data and
information developed from testing programs and other follow-on activities
initiated during the Carpet Policy Dialogue year will be entered into the TSCA
Carpet Emissions Administrative Record as they become available.
iii
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information developed from testing programs and other follow-on activities
initiated during the Carpet Policy Dialogue year will be entered into the TSCA
Carpet Emissions Administrative Record as they become available.
ACCOMPLISHMENTS
The Carpet Policy Dialogue made progress in several areas of exposure reduction
(pollution prevention) and industry-wide product stewardship/responsible product care. The
industry (i.e., manufacturers of carpet, carpet cushion, carpet installation adhesives, and raw
materials such as fibers and latex) and installers of carpet systems demonstrated a willingness
to commit the time and resources to working constructively toward an effective program to
understand the role of new carpet, carpet associated products, and carpet installation
practices on indoor air quality. The objective of the Carpet Policy Dialogue was to take
practical steps to help reduce the public's exposure to TVOC emissions.
The Carpet Policy Dialogue produced a standardized small chamber test
method which was peer reviewed. TVOC emissions from carpet and related
materials can be scientifically measured and compared. This procedure was
submitted to the ASTM as the basis for a new standard method.
The Carpet and Rug Institute (CRI) voluntarily agreed to conduct a major
study to define carpet TVOC emission decay characteristics. In addition, the
CRI will also conduct a comprehensive study of carpet product types, to
provide the information necessary to assess and compare carpet emissions on
an industry-wide basis.
The Carpet Cushion Council voluntarily agreed to conduct a testing program
which will report a profile of TVOC emissions coming from new carpet
cushion. The voluntary testing program will include decay curve testing of
TVOC emissions for each of the five carpet cushion product types available in
commerce.
Manufacturers of carpet cushion agreed to set in place technical and
manufacturing task forces to investigate ways in which TVOC emissions from
new carpet cushion can be reduced at the manufacturing and process level for
each of the five generic types of carpet cushion.
The Carpet Policy Dialogue encouraged participation of the Floor Covering
Adhesive Manufacturers Committee of the National Association of Floor
Covering Distributors to represent the carpet installation adhesives industry in
the Carpet Policy Dialogue and to provide the vehicle by which this industry
could address voluntary testing for these products.
IV
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Members of the Floor Covering Adhesive Manufacturers Committee agreed to
support the research activities necessary to modify the standard analytical test
method to obtain TVOC emissions measurements for floor covering adhesive
products.
The Floor Covering Adhesive Manufacturers Committee committed to a
voluntary testing program that will provide a baseline of comparative TVOC
emissions information for floor covering adhesives and sealers.
The Carpet Policy Dialogue reinforced a market climate which encouraged the
introduction of low-emitting carpet adhesives.
The Styrene Butadiene Latex Manufacturers Council report that this industry
reduced VOC emissions from their product in recent years, and that they have
completed a series of toxicity tests for a VOC contaminant (4-PC) in latex
products.
The Styrene Butadiene Latex Manufacturers Council agreed to provide data
from their ongoing quality analysis programs and to report the company-by-
company weighted average of 4-PC in styrene butadiene latex sold for carpet
backing applications for 1991 and 1992 as the data becomes available. This
information will be used to assess the feasibility of utilizing the information to
develop future quality control activities.
The Floor Covering Installation Contractors Association agreed to enhance
training programs to include information about indoor air quality, educate
carpet installers about proper installation procedures, and encourage installers
to adhere to the Carpet and Rug Institute installation guidelines (CRI 104; CRT
105).
The Carpet Policy Dialogue compiled information about conceivable process
engineering research activities that deserve consideration for identifying
potential control measures that may lead to reduced VOC emission levels in
carpet related sources in the future.
The Carpet Policy Dialogue suggested potential control strategies to minimize
VOC emissions from carpet floor covering systems in new construction and
renovation projects.
The General Services Administration (GSA) established an initiative to develop
requirements to make a low VOC carpet floor covering available for use in
Government offices. It is anticipated that a low TVOC emitting carpet floor
covering could be available from the GSA Federal Supply Schedule for the
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contract period beginning April 1994, provided adequate technical data is
available from the TSCA Carpet Emissions Administrative Record.
The Carpet Policy Dialogue prepared a brochure to provide the interested
public with information about carpet emissions, indoor air quality, exposure
reduction (pollution prevention). Sixteen (16) organizations signed on as
participants in the development of this brochure.
The Carpet Policy Dialogue prepared a Compendium Report describing the
group's activities, findings, accomplishments, and recommendations for the
Dialogue year.
VI
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CHAPTER 1
Carpet Policy Dialogue
Plenary Report
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1.0 CHAPTER 1: PLENARY REPORT
1.1. INTRODUCTION
This report of the Carpet Policy Dialogue Group documents the activities,
accomplishments, findings, and recommendations of the Carpet Policy Dialogue. It
summarizes information from minutes of meetings held between August 21, 1990, and
September 27, 1991. While the activities of the Carpet Policy Dialogue concluded on
September 27, 1991, the Dialogue process established mechanisms whereby follow-on
activities, information, and data resulting from a series of voluntary agreements will continue
to be reported into the Toxic Substances Control Act (TSCA) Carpet Emissions
Administrative Record.
This report contains information based on discussions among Dialogue participants.
These individuals presented their views independently and as representatives of the industry,
group, and organization (governmental or nongovernmental) that invited them to participate
in the Carpet Policy Dialogue. The Carpet Policy Dialogue accepts responsibility for
accurately reporting the information presented to it; however, listing these individuals in
Appendix A, List of Carpet Policy Dialogue Participants, does not imply that they
specifically endorse all elements of the materials presented.
The Carpet Policy Dialogue Plenary Group and the Public Communications Subgroup
reviewed this report. However, it should be noted that while this is a report of the Carpet
Policy Dialogue Group, it does not necessarily reflect the opinion of individual constituent
members of the industries, groups, and organizations (governmental or non-governmental)
that provide representation to the Carpet Policy Dialogue.
The dialogue process on total volatile organic compound (TVOC) emissions for carpet
and carpet floor covering materials is a nonregulatory approach. It focuses on product
stewardship through voluntary actions on the part of industry. It also emphasizes exposure
reduction (pollution prevention) philosophies, and addresses the public desire for information
that could lead to consumer choice. The Carpet Policy Dialogue is an example of how
Government, industry, the interested public, and the scientific community can work together
to resolve exposure reduction and pollution prevention issues, including those related to
indoor air exposures.
1.1.1. Background
On January 11, 1990, Local 2050 of the National Federation of Federal Employees
(NFFE) petitioned the U.S. Environmental Protection Agency (EPA) under section 21 of the
Toxic Substances Control Act (TSCA) to initiate rule making proceedings, under sections 4,
6, and 8 of TSCA to reduce emissions from new carpets (NFFE/USEPA 1989, 1990). The
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EPA decided not to initiate the specific rule making proceedings requested by NFFE because
the Agency disagreed with the specific assertions regarding health risks posed by carpet and
with the remedies sought by NFFE. The EPA denied the petition (55 FR 17404, April 24,
1990). (See Appendix B.)
However, the EPA recognized that the combined total of VOC emissions from new
carpet may significantly increase indoor air exposures to VOCs in general, and that it is
prudent to minimize indoor exposure to these chemicals where reasonable. Thus, EPA
sought an approach to reduce TVOC exposure in the absence of a well-defined health risk
and to encourage manufacturer's efforts to reduce product emissions. In lieu of the section
21 proceedings, EPA convened the Carpet Policy Dialogue on August 21, 1990, and set a
different mission for the group. (See Appendix C.)
The Carpet Policy Dialogue was initiated by EPA as a one year process to clarify
scientific issues about carpet emission concerns and to identify methods for improving indoor
air quality. The charges to the Carpet Policy Dialogue were laid out in the Federal Register
notices of April 24, 1990 (55 FR 17404) and August 3, 1990 (55 FR 31640). These charges
included:
Develop standard methods for testing carpet emissions and obtain commitments
from industry to voluntarily commence appropriate periodic testing of carpet to
quantify the emissions of total VOCs from their products on a periodic basis
so as to provide the interested public with comparative information on TVOC
emissions from new products;
Identify information needs for assessment of emission control feasibility,
including data on carpet manufacture and installation technology and
commercial activities associated with carpet installation;
Evaluate potential controls for reducing emissions; and
Identify VOC exposures which are associated with carpet installation but not
necessarily from a carpet source and recommend any appropriate actions to
reduce them.
1.1.2. Implementation of the Carpet Policy Dialogue
EPA oversight for the Carpet Policy Dialogue was assigned to the Office of Toxic
Substances (OTS), Existing Chemical Assessment Division (ECAD). OTS/ECAD requested
that the EPA Regulatory Negotiations Project provide facilitator and meetings support
services via a contract with the Conservation Foundation and their subcontractor, CDR
Associates. Several categories of participants were identified from the Federal Register
notices. These included industry, public interest groups, representatives of labor, interested
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Government agencies, and members of the scientific and research communities. In
conjunction with representatives from EPA, the subcontractor identified a list of names of
individuals and organizations to participate in the Carpet Policy Dialogue. In general,
representation was sought and received from the following groups: industry (Carpet and Rug
Institute [CRI], American Fiber Manufacturers Association [AFMA], American Textile
Manufacturers Institute [ATMI], Styrene Butadiene Latex Manufacturers Council [SBLMC],
Floor Covering Installation Contractors Association [FCICA], Carpet Cushion Council
[CCC], and Floor Covering Adhesives Manufacturers Committee [FCAMC] of the National
Association of Floor Covering Distributors [NAFCD], The Adhesive and Sealant Council,
Inc. [ASC]), public interest groups (Consumer Federation of America [CFA], American
Lung Association [ALA], and American Public Health Association [APHA]), representatives
from labor (National Federation of Federal Employees, Local 2050 [NFFE], American
Federation of State, County and Municipal Employees [AFSCME]), other Government
agencies (Occupational Safety and Health Administration [OSHA], National Institute for
Occupational Safety and Health [NIOSH], National Institute of Standards and Technology
[NIST], Consumer Product Safety Commission [CPSC], General Services Administration
[GSA]), other offices within EPA (Office of Air and Radiation/Indoor Air Division [OAR],
Office of Research and Development [ORD]), and distinguished scientists from industry,
academia, and the scientific community in general (Air Quality Sciences, Inc. [AQS],
American Society for Testing and Materials, Subcommittee D22.05 on Indoor Air [ASTM],
Georgia Tech Research Institute [GTRI], Research Triangle Institute [RTI]). A list of Carpet
Policy Dialogue participants is included as Appendix A. Representatives to the Carpet Policy
Dialogue were qualified on the basis of their technical expertise and training.
1.1.3. Structural Organization
All meetings of the Carpet Policy Dialogue were considered "open," to facilitate a
solution-oriented, problem-solving approach to the issues discussed. Confidential materials
that provided useful information for the purpose of deliberative discussions were identified as
such. The distribution and use of confidential materials were limited to recognized dialogue
participants who agreed that such information was restricted for any use beyond dialogue
discussions. Statements issued to inform the public about dialogue meetings and
deliberations were joint releases prepared and approved by the Carpet Policy Dialogue
Plenary.
To address the Federal Register objectives, three technical subgroups were formed
under the oversight of the Carpet Policy Dialogue Plenary. These subgroups were the
Product Testing, Process Engineering, and Public Communications Subgroups. EPA
provided staff to coordinate subgroup meetings and provide liaison among dialogue
participants. The subgroups provided a forum for the presentation and discussion of
information. Recommendations, conditional decisions, and reports developed by these
subgroups were presented to the Carpet Policy Dialogue Plenary for discussion, approval,
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and follow-up actions. The schedule of Carpet Policy Dialogue meetings is provided as
Appendix D.
1.1.4. Nature of Dialogue Consensus Statements and Voluntary Actions
Proposed consensus statements were voluntary actions submitted to the Carpet Policy
Dialogue Plenary for the benefit of a consensus process of review and comment. Consensus
agreement by the Carpet Policy Dialogue Plenary indicates that interests and concerns were
identified and discussed. After consideration of these various interests, solutions were
developed to take these into account. A consensus does not mean unanimity. A consensus
was the best agreement that could be obtained among the Carpet Policy Dialogue
participants. It does not imply that all individuals or the industries, groups, or organizations
(governmental or non-governmental) specifically endorsed all elements of such agreements.
During consensus discussions, participants were provided the following options: (1) agree,
(2) submit a minority report, (3) stand aside, or (4) block consensus. Minority reports were
included in the public record, included with minutes to meetings, and as attachments to
specific agreements. In reaching a consensus agreement, the Carpet Policy Dialogue Group
indicated to its sponsor (EPA) that such a statement could provide the basis for a
Memorandum of Understanding to initiate voluntary action(s) in response to the charter set
by EPA in the Federal Register notices.
Voluntary agreements (e.g., to conduct TVOC emissions testing of products) were
undertaken by dialogue participants as part of a continuing commitment to product
stewardship, reduction of TVOC emissions, or public education. Voluntary actions
implemented with respect to products as produced by the manufacturer may include industry
guidelines for proper use, maintenance and care of products, or data base development.
Such voluntary agreements will operate where reasonable and appropriate as governed by the
economics of the designed program. As data are generated from such programs, they serve
as the reference point for ongoing testing and evaluation, which was one of the goals of the
Federal Register charter. Voluntary actions were implemented with consideration to preserve
necessary proprietary information and establish the basis for appropriate inter-product
comparison.
1.1.5. Dialogue Discussions
The Carpet Policy Dialogue was convened on August 21, 1990. At this meeting,
participants of the Carpet Policy Dialogue Plenary discussed the scope of work, boundaries
of the subject, composition of the Carpet Policy Dialogue, time constraints, technical
approach, and criteria by which accomplishments would be measured. The Carpet Policy
Dialogue Plenary accepted, in principle, the objectives defined in the Federal Register notices
and recognized their responsibility for making final decisions (i.e., acceptance of materials
produced by their deliberations). Procedural guidelines were set to identify the roles of the
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facilitator, sponsor, dialogue participants and their alternates, resource individuals, observers,
and relations with the press.
The Plenary group of the Carpet Policy Dialogue held nine (9) meetings during the
Dialogue year. A record of these meetings has been recorded in the minutes prepared by the
Carpet Policy Dialogue facilitator (CDR Associates). These minutes are available in the
TSCA Carpet Emissions Administrative Record.
Meetings of the Carpet Policy Dialogue Plenary included: consideration of Agenda
items, progress reports from the subgroups, summary presentations of data and information
previously reviewed by the subgroups, proposals from industry representatives for consensus
review, and project scheduling. The Carpet Policy Dialogue Plenary invested considerable
effort in reviewing and finalizing text materials for the various products attributed to the
Carpet Policy Dialogue.
Discussions of the Subgroups (Product Testing, Process Engineering, and Public
Communications) are incorporated into Chapters 2, 3, and 4 respectively. It became
apparent early in the Dialogue process that additional meetings of the Plenary were needed to
review information and proposals emanating from subgroup activities, assess progress made
by the subgroups and provide guidance or course changes as needed, resolve issues that
impeded progress, and to signal its sponsor, EPA, when consensus agreement had been
attained. Additional meetings were scheduled.
During the Dialogue year, several topics recurred during the course of deliberations.
These topics included the subject of health concerns, the use of proprietary or confidential
information, and the subject of chemical speciation. Some representatives to the Plenary and
the Subgroups were of the opinion that sufficient latitude had not been provided to the Carpet
Policy Dialogue to address the full charge set by EPA in the Federal Register notices; while
other representatives shared the opionion that the Dialogue could operate within the
boundaries described by the Federal Register notices. The Carpet Policy Dialogue addressed
these issues giving consideration to the variety of views shared among the Dialogue
representatives and the advantages and limitations of their decisions as set within the
framework of the dialogue process, the scope of work, and the boundaries of the subject
established by the Federal Register notices of April 24, 1990 (55 FR 17404) and August 3,
1990 (55 FR 31640).
1.1.5.1. Health Concerns
The dichotomy of separating health assessment from exposure reduction proved
challenging to the Carpet Policy Dialogue. In general, most participants recognized a
relationship between volatile organic compound emissions, indoor air quality, and health.
Furthermore, participants acknowledged the rationale behind the EPA premise that it is
prudent to minimize indoor exposure to volatile organic compound emissions where
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reasonable, and that this was one of the prime objectives for the Dialogue. Nevertheless, the
EPA charge to the Carpet Policy Dialogue specifically stated:
"The goal of the dialogue will be to characterize emissions and identify low-impact,
feasible VOC controls that could be implemented in the near term, not to further characterize
the health effects of chemicals emitted from carpeting.'
The Group was directed by EPA to adhere to the objectives of the Federal Register and to
refrain from becoming involved in the issues of health effects; it complied with that
direction.
1.1.5.2. Proprietary or Confidential Information
During the course of the Dialogue year, it became necessary for the Carpet Policy
Dialogue Plenary, the Product Testing, and the Process Engineering Subgroups to gain
access to information that was considered proprietary or confidential by industry
representatives. This was problematic as information presented to the Carpet Policy
Dialogue would then become public knowledge. Industry representatives expressed concern
that such information and preliminary data could be misunderstood by the general public or
could compromise the competitive advantage among individual manufacturers. The Carpet
Policy Dialogue Plenary responded to these concerns by establishing a mechanism whereby
such information could be identified as confidential and restricted for any use beyond
Dialogue discussions.
By the conclusion of the Dialogue year, much of the information that was initially
marked as proprietary or confidential was released in original or blinded form for enclosure
in the various reports associated with the Carpet Policy Dialogue or submitted to the TSCA
Carpet Emissions Administrative Record. In general, participants to the Carpet Policy
Dialogue agreed that a limitation inherent to the Dialogue process was the difficulty in
obtaining this type of information for review and analysis by the various working groups of
the Dialogue.
1.1.5.3. TVOC Data and Chemical Speciation
TVOCs implies the sum total of volatile organic compounds emitted from a test
material as measured by a specified analytical test method. TVOC is specifically mentioned
throughout the Federal Register notice (55 FR 17404) as the priority datum for consideration
by the Carpet Policy Dialogue. Yet, neither the method by which TVOC was to be
determined, nor the use of information gathered in the course of obtaining TVOC values was
specified. Speciation issues were discussed at both the Product Testing and Process
Engineering Subgroup.
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The analytical test method developed by the Product Testing Subgroup produces a
TVOC emission factor. The test method can also be used to identify individual VOC
chemicals emitted from the test specimen. (See Appendix E.)
Some representatives noted that the limited data available for many of the products
that would be included in the various testing programs showed that the TVOC levels were
low after 24 hours and that reporting speciated data at such low levels would not only
produce results which could be subject to misinterpretation, but could also result in
disclosure of confidential business information. They questioned the value of committing the
costly scientific resources needed to obtain chemical speciation. Some other representatives
shared a different opinion on this subject (e.g., Hirzy, 1990).
For the testing program, EPA directed the Plenary and the Testing Subgroup to
follow the charge of the Federal Register regarding TVOC for the purpose of testing. A
minority report was filed on this subject and is included as Attachment F-2 to the Carpet and
Rug Institute Consensus Statement (Appendix F).
The speciation issue was also addressed by the Process Engineering Subgroup. Some
members of the Process Engineering Subgroup were of the opinion that the Subgroup could
not fully address its charge to identify opportunities to reduce emissions in the absence of
information about the nature of the materials used in product manufacturer that could
contribute to VOC emissions. Other Subgroup members contended that such information
was proprietary, not readily available, or that available information would not be relevant
because of changes in analytical procedures or changes in manufacturing processes. Some
Subgroup members expressed concern that without such information, the Subgroup would not
be able to fully evaluate the advantages or limitations of various process variables among
different manufacturing processes. EPA stated that, consistent with the directives of the
Federal Register notice, new studies developing speciation data were not within the scope of
the Dialogue but requested that existing speciation data be provided for consideration by the
Process Engineering Subgroup.
An account of the deliberative proceedings on the speciated data issue can be found in
Chapters 2 and 3. Additional information on this subject is included in the minutes to the
meetings of the Carpet Policy Dialogue which are filed in the Carpet Emissions
Administrative Record.
1.2. SUMMARY OF THE SUBGROUP ACTrVITIES
The Carpet Policy Dialogue accomplished numerous objectives during the Dialogue
year. Products developed by the Carpet Policy Dialogue emanated from Subgroup activities.
The primary focus of these products related to the Dialogue's objectives (e.g., progress in
reducing TVOC emissions, data base development, identifying and conveying information).
In some instances, Subgroup activities and Dialogue accomplishments reinforced ongoing
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activities outside the Dialogue or encouraged new initiatives by other groups which related to
the Dialogue's objectives.
1.2.1. Product Testing Subgroup
The mission of the Product Testing Subgroup was to develop standard test methods
for testing TVOC emissions from carpet floor covering materials (carpet, carpet cushion, and
carpet floor covering adhesives) and to obtain voluntary agreements from industry to conduct
testing to quantify the TVOC emissions for newly manufactured products on a periodic basis.
During the Dialogue year, the Subgroup held ten (10) meetings and numerous telephone
conferences. A description of the deliberative activities and products developed by the
Product Testing Subgroup are included as Chapter 2 of this report. The following
summarizes the accomplishments of this Subgroup.
Related to the mission of this Subgroup was the development of criteria to understand
the nature of TVOC emissions and the scientific considerations for obtaining analytical
measurements of TVOC emissions from carpet floor covering materials. For the purposes of
the Carpet Policy Dialogue, the Subgroup defined TVOCs as the sum of volatile organic
compounds that can be analyzed and measured using a specified analytical method. On
November 29, 1990, the Carpet Policy Dialogue Plenary accepted the recommendation from
the Product Testing Subgroup that a small chamber method be used for measuring TVOC
emissions from carpet floor covering materials.
The test method, "Standard Test Method for Determining Total Volatile Organic
Compound Emission Factors from Carpet Under Defined Test Conditions Using Small
Environmental Chambers" reports TVOC as an emission factor from flooring materials using
standard test conditions. Quantitative measurement is determined by gas chromatography or
gas chromatography/mass spectrometry. The observed test chamber concentration is
converted to an emission factor, which may be a product specific variable. An addendum to
document protocol changes necessitated for testing of carpet installation adhesives has yet to
be finalized and will be attached to the principal document pending the results of preliminary
studies in progress. (See Appendix E.)
The test method was peer reviewed by a select group of accomplished experts (listed
in Appendix A). It is anticipated that the final method including addendum revisions will be
submitted to the American Society for Testing and Materials (ASTM), subcommittee D22.05
on Indoor Air for ASTM balloting procedures as a proposed "Standard Method" during
1992. Further validation by interested laboratories is expected over the next 2 years.
The Product Testing Subgroup developed protocols for carpet floor covering product
testing. Testing programs were individualized to give consideration to the unique
characteristics for each component of a carpeted floor covering system (i.e., carpet, carpet
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cushion, and carpet floor covering adhesives), the product types currently available in
commerce, and the nature of the industries involved in the manufacture of these products.
These protocols were developed into consensus statements by industry representatives
and submitted to the Carpet Policy Dialogue Plenary. The Carpet Policy Dialogue reached
agreement on three consensus statements:
February 28, 1991
June 28, 1991
June 28, 1991
Testing Program for Carpet Products
Testing Program for Carpet Cushion
Testing Program for Carpet Installation Adhesives
Copies of the approved consensus statements along with all attachments are provided as
Appendices F, G, and H.
Subsequent to the Carpet Policy Dialogue consensus approval of the testing programs,
EPA entered into a series of Memoranda of Understanding (MOU) with the Carpet and Rug
Institute (55 FR 37912, August 9, 1991), the Carpet Cushion Council (55 FR 61245,
December 2, 1991), and the Floor Covering Adhesive Manufacturers Committee of the
National Association of Floor Covering Distributors (55 FR 61246, December 2, 1991). The
MOUs formally established the framework by which voluntary product testing programs
sponsored by industry would be initiated in response to the desired outcomes described in the
Federal Register notice (55 FR 17404, April 24, 1990). These MOUs and the corresponding
Federal Register announcements are provided as Appendices I, J, and K. Test results,
reports, and information on follow-on activities developed under the terms and conditions of
these MOUs will become a matter of public record available from the TSCA Carpet
Emissions Administrative Record.
1.2.2. Process Engineering Subgroup
The mission of the Process Engineering Subgroup was to evaluate potential process or
engineering changes for reducing VOC emissions from carpet and carpet-related sources and
installation activities; as well as, identification of information gaps. During the Dialogue
year, the Process Engineering Subgroup held eight (8) meetings. A description of the
deliberative activities and products developed by the Process Engineering Subgroup are
included as Chapter 3 of this report. The following summarizes the accomplishments of this
Subgroup.
Representatives from industry, labor, interested Government agencies, associated
professional organizations, and scientific experts provided this Subgroup with information
and a series of informative presentations summarizing research activities, describing
manufacturing processes, and installation practices and procedures. For example, data
relevant to determining improved carpet curing oven operating conditions were reviewed by
the Subgroup. Specifically, the Subgroup received information about the manufacture of
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styrene butadiene rubber latex, adhesive manufacture and formulation, carpet cushion
manufacture, carpet manufacture, and carpet installation practices and building ventilation.
Wherever possible, these presentations identified potential sources of VOC emissions from
product formulations, manufacturing processes, and installation practices.
In its report to the Carpet Policy Dialogue (Chapter 3), the Process Engineering
Subgroup provided information about the current state of knowledge on the manufacturing
processes, procedures, and practices for the industries involved in the manufacture of carpet
floor covering materials. This information includes a discussion of the process description,
historical perspective on VOC reduction, evaluation of potential methods to reduce VOCs,
ideas for assessing feasibility of additional process changes that would reduce VOCs,
opportunities for research, and recommendations based on their deliberative findings.
The Subgroup expressed interest in the relationship between 4-phenylcyclohexene (4-
PC) emissions that may contribute significantly to TVOC from styrene butadiene latex (SB
latex) used for carpet applications and that data on 4-PC could potentially be made available
from ongoing styrene butadiene latex manufacturers quality analysis programs. The
Subgroup observed that 4-PC data could potentially provide useful information about TVOC
emissions from SBR-latex and proposed that the Dialogue encourage industry reporting. The
Carpet Policy Dialogue reached consensus agreement on this Subgroup proposal and
recommended that the EPA and the SBLMC enter into a MOU for the SBLMC to conduct an
industry wide survey of 4-PC levels in SBR-latex during the last quarter of 1991 and 1992
and to make such information publicly available through the EPA Carpet Emissions
Administrative Record. This formed the basis for a Memoranda of Understanding between
the EPA and the SBLMC which was signed on September 26, 1991. Details of this MOU
(55 FR 61247, December 2, 1991) are described in Appendix L.
1.2.3. Public Communications Subgroup
The mission of the Public Communications Subgroup was to serve as the common
voice for the Carpet Policy Dialogue in responding to the public communications objective
stated in the Federal Register (55 FR 17404, April 24, 1990). This Subgroup held six (6)
meetings during the Dialogue year to define the scope of work, identify potential
communications products, consider mechanisms for message development, and to discuss
communication strategies. A description of the deliberative activities and products developed
by the Public Communications Subgroup are included as Chapter 4 of this report. The
following summarizes the accomplishments of this Subgroup.
The focus of the Public Communications Subgroup activity was on communication
outside the Dialogue. The Carpet Policy Dialogue Plenary provided oversight for review of
materials developed by the Subgroup and offered a mechanism for approval and distribution
of materials that convey information to the public about Carpet Policy Dialogue activities.
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The products attributed to the Public Communications Subgroup included: 1) the
Interim Progress Report of the Carpet Policy Dialogue (55 FR 37912); 2) a public
information brochure - "Indoor Air Quality and New Carpet, What You Should Know"
(Appendix M); 3) the Compendium Report of the Carpet Policy Dialogue, and 4) an
executive summary of Dialogue accomplishments.
These products were submitted to the EPA in response to the public communications
objective stated in the Federal Register (55 FR 17404, April 24, 1990) and made available to
the public by announcements in the Federal Register and other distribution channels. They
provide factual information for use by dialogue participants and those responsible for
communicating information about the EPA Carpet Policy Dialogue process. In addition,
these communication products provide the interested public with an explanation of the
findings and information developed during the Dialogue year. The materials identify
common denominators among Dialogue participants for message development and
information distribution on the subject of TVOC emissions from carpet floor covering
materials and indoor air quality and formed the basis for joint statements, agreements, and
voluntary communications efforts supported by Carpet Policy Dialogue Participants.
1.3. CARPET RELATED ACTIVITIES
Several industries, groups, and organizations (governmental and nongovernmental)
that participated in the Carpet Policy Dialogue have taken steps to voluntarily reduce TVOC
emissions from products, develop TVOC emissions data, conduct other carpet related
research, or support education and training awareness programs. The following is a brief
description of these activities.
1.3.1. Styrene Butadiene Latex Manufacturers
The Styrene Butadiene Latex Manufacturers Council (SBLMC) reported several
voluntary activities including sponsoring a series of toxicity tests for a VOC contaminant (4-
PC). Results of these tests have been shared with EPA to assist in its study of indoor air
quality issues. These data have also been made available to carpet manufacturers.
SBLMC also reported that in the past 2 years, they have achieved a 50 percent
reduction in 4-PC in SBR-latex products through the implementation of engineering
techniques. They made a commitment to provide the Carpet Policy Dialogue with additional
4-PC monitoring data for SBR-latex products sold to the carpet trade as part of the SBR-latex
manufacturers' ongoing quality assurance program. (See Appendix L.)
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1.3.2. Carpet Manufacturers
Under the leadership of the Carpet and Rug Institute (CRT), the carpet industry
voluntarily conducted pilot testing of carpet products before the Carpet Policy Dialogue
began. This preliminary set of data (Black et al., 1991) provided the Carpet Policy Dialogue
with valuable information about the emissions characteristics of softback carpet and formed
the basis for a consensus agreement for a Carpet Testing Program. (See Appendix F.)
Upon extensive discussion and consensus through the Dialogue process, the CRI
voluntarily agreed to fund a testing program for 25 carpet product types. This will provide
an industry-wide profile of comparative TVOC emissions for carpet product types currently
available in the marketplace. The study will include both SBR and non-SBR latex-backed
carpet types. Implementation of these actions are described in a Memorandum of
Understanding between EPA and the Carpet and Rug Institute. (See Appendix I.)
In addition, the CRI committed to several voluntary actions beyond product testing for
TVOC emissions. This includes (a) the generation of a history of TVOC levels through on-
going, periodic monitoring, which would be available for trend analysis and could be used
for remedial action (i.e., motivating manufacturers to voluntarily institute quality assurance
measures to reduce TVOC emissions); and (b) a CRI-established certification program to
encourage manufacturers to reduce emissions from new carpet. The CRI also committed to
inform the general public and carpet customers of the carpet industry's quality assurance
program and its results on a periodic basis.
1.3.3. Carpet Cushion Manufacturers
The Carpet Cushion Council, acting on behalf of 98 per cent of the carpet cushion
industry, entered into a Memorandum of Understanding with the EPA wherein the industry
will voluntarily conduct a testing program. (See Appendix G.)
The testing program is outlined specifically in the Consensus Statement which was
agreed upon between the Carpet Cushion Council and the Carpet Policy Dialogue Plenary.
(See Appendix J.) The voluntary testing program will include decay curve testing of TVOC
emissions for each of the five carpet cushion product types available in commerce. It is the
intent of this testing program to provide the basis of an ongoing profile study and to meet the
objectives set out in the Federal Register notice (55 FR 17404).
Additionally, this industry agreed to set in place technical and manufacturing task
forces to investigate ways in which TVOC emissions from new carpet cushion can be
reduced at the manufacturing and process level for each of the five generic types of carpet
cushion.
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1.3.4. Adhesive Manufacturers
Prior to the Carpet Policy Dialogue, floor covering adhesive manufacturers did not
have a common spokesperson to address regulatory issues. During the Carpet Policy
Dialogue year, these manufacturers organized their industry under the leadership of the Floor
Covering Adhesive Manufacturers Committee (FCAMC) of the National Association of Floor
Covering Distributors (NAFCD).
This group agreed to support the research activities necessary to modify the standard
analytical test method to obtain TVOC emissions measurements for adhesive products. (See
Appendix E, Attachment E-l.) They also committed to a voluntary testing program that will
provide a baseline of comparative TVOC emissions information for floor covering adhesives
and sealers. (See Appendices H and K.) The data collected in the Carpet Installation
Adhesive Testing Program will also form the basis for a series of proposed follow-on
activities that include an annual reporting of the aggregate history of carpet installation
adhesive product type sales performance for at least three years and the development of a
program to motivate producers to institute voluntary indoor air quality assurance measures
with respect to their installation adhesive products. Details of these follow-on programs will
be worked out jointly by EPA and the Floor Covering Adhesive Manufacturers Committee.
Public concern in general has encouraged the introduction of low-emitting adhesives.
In California, concern about hydrocarbon precursors to photochemical smog resulted in
codification actions requiring reduction in VOC emissions (SCAQMD 1990). The Carpet
Policy Dialogue has fostered these regional activities by offering a national forum to
encourage continued emissions reduction for these adhesives products. There is an
accelerated trend among floorcovering adhesive manufacturers to produce low VOC emitting
adhesives to replace the high-emitters of the past.
1.3.5. Consumer Product Safety Commission
The Consumer Product Safety Commission completed limited small chamber testing
to identify specific VOCs released from carpet. They are also conducting large-chamber
testing at Lawrence Berkeley Laboratory to determine the VOC emission time profile from
selected carpets. Additional small chamber testing is being conducted in order to compare
small and large chamber measurements under similar environmental conditions. A report is
anticipated in 1992.
1.3.6. EPA Carpet Installation Study
The EPA has conducted a study to measure VOC emissions from installed urethane
backed carpet (USEPA 1991). Comparative VOC measurements were made using a dynamic
chamber and ambient air measurements taken during installation and again one week after
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installation. The report calculates the decay curve and speciates VOC's emitted from the
carpet, carpet installation adhesives, and the carpet seam sealer used. This study
demonstrated that the selection of low VOC emiting carpet floor covering materials can
reduce TVOC concentrations following new carpet installation.
1.3.7. Floor Covering Installation Contractors Association
The Floor Covering Installation Contractors Association (FCICA) has undertaken an
initiative to further develop industry-wide communications programs to educate carpet floor
covering installers about the importance of proper installation procedures. In addition, the
FCICA will include information about the availability of low VOC emitting materials (e.g.,
adhesives) in training courses offered to carpet installer instructors and carpet installers.
1.3.8. Collaborative Research
Information was provided to the Carpet Policy Dialogue from collaborative studies
voluntarily undertaken by industry. Examples include extensive studies undertaken to
evaluate the effects of process engineering variables on carpet curing with respect to carpet
product integrity and VOC emissions (December 1989; Van Ert, 1990; and Hawkins et al.
1991).
1.3.9. General Services Administration
The General Services Administration (GSA) established an initiative to develop
requirements to make a low VOC carpet floor covering available for use in Government
offices (USGSA, 1991a; USGSA 1991b). GSA representatives will evaluate the use of the
standard analytical test method to measure TVOC (Appendix E) as one consideration in
establishing procurement requirements for low TVOC emitting carpet floor covering.
Information provided to the TSCA Carpet Emissions Administrative Record from the various
industry testing programs will also be considered by GSA.
It is anticipated that a low TVOC emitting carpet floor covering could be available
from the GSA Federal Supply Schedule for the open season contract period beginning April
1994, provided adequate technical data is available from the TSCA Carpet Emissions
Administrative Record.
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1.3.10. Environmental Protection Agency and General Services Administration
EPA and GSA agreed to work together to identify low VOC-emitting carpet floor
covering products. They agreed to exchange information and utilize data developed from the
Carpet Policy Dialogue. This will include the data and materials submitted to the TSCA
Carpet Emissions Administrative Record from the various industry-wide testing programs.
The initiatives to improve indoor air quality, TVOC exposure reduction, and pollution
prevention will provide the basis for this collaborative activity.
1.4. FUTURE CONSIDERATIONS
One factor in determining the accomplishments of the Carpet Policy Dialogue was the
effect of the time constraint set by EPA. The Carpet Policy Dialogue was given a 1-year
timeframe to complete the primary objectives of the mission outlined in the Federal Register
notice (55 FR 17404). This time constraint not only served as a motivating force to drive
the Dialogue, but also influenced the selection of priorities as well as the nature and extent of
activities which the Dialogue could support during the course of the Dialogue year.
As a consequence, the Carpet Policy Dialogue established mechanisms by which
information would continue to be developed under a series of proposed follow-on activities
that were incorporated into the various testing program consensus agreements. In addition,
the Carpet Policy Dialogue also identified other matters that could not be fully addressed
within the 1-year term of the Carpet Policy Dialogue. These topics are listed here for the
record as future considerations.
The Carpet Policy Dialogue recognizes that the testing programs initiated by industry
are an initial step to understand the nature of TVOC emissions from the component elements
of the carpet floor covering system. Important future considerations will be to gain a better
understanding of TVOC emissions from carpet floor covering system assemblies (i.e., carpet
and cushion; carpet and adhesive; carpet, cushion, and adhesive), as well as the role of aging
carpet. This is needed to determine the relative and absolute TVOC contributions of the
individual component materials. It can also provide information about these products as they
are installed, rather than as newly manufactured or under predetermined test conditions such
as those cited in the test method developed by the Carpet Policy Dialogue. To accomplish
this, the Carpet Policy Dialogue recommends that additional test method development be
initiated. This could take the form of modifications to the standard test method. Such
modifications may include, but are not limited to, setting different procurement and
conditioning or treatment protocols.
The Carpet Policy Dialogue notes that variability of TVOC emissions within any
given carpet type (or from any given carpet mill) cannot be assessed under the existing carpet
testing program. That is, the existing program was not designed to predict how often carpet
of a given type (or from a given carpet mill) may be produced which emits at significantly
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higher or lower rates than the values determined from the current testing programs. For
these reasons, the consensus agreement reached by the Carpet Policy Dialogue calls for a
technical evaluation by EPA for the purpose of determining the need for follow-on testing, if
required. Tne EPA reserves the right to assess the suitability of test program results
submitted for evaluation by industry to assure that the EPA has met the goals and concepts of
the Federal Register notice. Issues identified by EPA will be discussed as follow-on
activities with the parties named in the testing agreements. Details of these matters will be
worked out by joint consultation by EPA and the industries sponsoring the testing and could
be the subject of additional Memoranda of Understanding.
Although individual species of VOC emissions was not a major consideration of the
Carpet Policy Dialogue, the Process Engineering Subgroup did consider that determining the
dominant VOC species emitted from a carpet floor covering product could be helpful for
assessing potential emission reduction measures in the future.
EPA will need to monitor and evaluate the information reported to the TSCA Carpet
Emissions Administrative Record from the industry-wide testing and reporting programs.
This information is expected to provide guidance about the nature of TVOC emissions and
the overall effectiveness of the Carpet Policy Dialogue in influencing the reduction of
exposures to VOCs from carpet floor covering materials. The data base can provide useful
information to all parties interested in improving indoor air quality. EPA should seek
opportunities to share this important information with decision makers involved in the
purchase of or interior design consideration of the materials tested.
There is a need to evaluate the effectiveness of the various means for communicating
information regarding carpet TVOCs and indoor air quality. A follow-up effort is needed to
determine what information was communicated most effectively by the public information
brochure developed by the Carpet Policy Dialogue Public Communications Subgroup. This
effort should include consideration of the breadth of distribution among industry, installers,
and retail outlets; as well as an assessment of additional or changing information needs of
consumers.
The Plenary encourages the EPA to continue and expand research into developing an
understanding of health effects from exposures encountered in the indoor environment which
are a result of a variety of products and activities.
There is a need to expand efforts to understand how carpet attributes impact carpet's
role as a re-emitting sink.
There is a need to expand efforts to understand how carpet cleaning and maintenance
practices affect VOC concentrations in indoor air.
As noted previously, many of the consensus agreements of the Carpet Policy Dialogue
contain provisions for follow-on activities. These include annual industry reports of data and
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information useful to the goals and purposes of the Carpet Policy Dialogue, provisions for
follow-on testing activities, if needed, development of a public communication program to
inform the interested public about conclusions drawn from the various testing programs and
TVOC emissions, establishment of an information repository in the Carpet Emissions
Administrative Record, and in some cases establishment of quality product certification
programs within particular industries. The reader is referred to more detailed discussions
about follow-on activities which are described in the various consensus and MOU agreements
developed by the Carpet Dialogue. (See Appendicies F, G, H, I, J, K, and L.)
1.5. SUMMARY
The Carpet Policy Dialogue Group has identified a series of accomplishments attained
during the period of August 21, 1990, through September 27, 1991. These include:
The Dialogue Group reached consensus agreement on three (3) testing programs to
measure TVOC emissions factors from carpet, carpet cushion, and carpet installation
adhesive products.
The Dialogue Group contributed to the development of an analytical test method for
determining TVOC emissions from carpet-related products which may provide the
basis for an ASTM test method.
The Carpet and Rug Institute (CRI) agreed to release TVOC decays of previously-
tested SBR latex-backed carpet for review and determination of an appropriate point
in time to conduct emissions testing.
The CRI committed to a TVOC emission decay curve study for non-SBR latex-
backed carpet product types.
The CRI committed to an industry-wide profile study to provide comparative TVOC
emissions of carpet product types currently available in the marketplace. The study
will include both SBR and non-SBR latex-backed carpet types.
The CRI committed to additional voluntary actions beyond product testing including:
(1) generation of a history of TVOC levels through ongoing, periodic monitoring,
which would be available for trend analysis; (2) motivating manufacturers to institute
voluntarily quality assurance measures to reduce TVOC emissions through a
CRI-established certification program; and (3) inform the general public and carpet
customers of the carpet industry's quality assurance program and its results on a
periodic basis.
The Carpet Cushion Council (CCC) committed to a testing program to measure
TVOC emissions from carpet cushion products.
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The CCC agreed to address the need for additional information about process
engineering by formation of technical task groups in each product area to investigate
ways to reduce VOC emissions from these products.
The Floor Covering Adhesive Manufacturers Committee (FCAMC) of the National
Association of Floorcovering Distributors (NAFCD) accelerated organizational
activities to represent the floorcovering adhesives industry and become the vehicle
by which this industry can develop information to address voluntary testing actions
under the Carpet Policy Dialogue charter.
The FCAMC committed to support research needed to modify the standard analytical
test method to determine TVOC emissions from carpet installation adhesives and
carpet seam sealers.
The FCAMC committed to conduct preliminary testing studies to measure TVOC
emission decays from carpet installation adhesives and carpet seam sealers.
The FCAMC reported an accelerated trend in which low-emitting multi-purpose
carpet adhesives are entering into the marketplace.
The Carpet Policy Dialogue reinforced a market climate encouraging the introduction
of low-emitting carpet adhesives. Most of the member companies of FCAMC are
now producing such products.
The Styrene Butadiene Latex Manufacturers Council (SBLMC) report that this
industry reduced VOC emissions from their product in recent years, and that they
completed a series of toxicity tests for a VOC contaminant (4PC) in latex products.
The SBLMC agreed to provide data from their ongoing quality analysis programs
and to report the company-by-company weighted average of 4-PC in styrene
butadiene latex sold for carpet backing applications for 1991 and 1992 as the data
becomes available. This information will be used to assess the feasibility of utilizing
the information to develop future quality control activities.
The Floor Covering Installation Contractors Association agreed to enhance training
programs to include information about indoor air quality and educate installers about
proper installation procedures and encourage them to adhere to carpet industry
installation guidelines (CRI 104 and CRI 105).
The Dialogue Group compiled information about manufacturing processes for carpet,
carpet cushion, carpet installation adhesives, styrene butadiene latex, and carpet
installation practice.
The Dialogue Group compiled potential research which may identify process control
measures to reduce TVOC levels in carpet-related sources that deserve consideration.
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The Dialogue Group compiled suggested potential control strategies to minimize
carpet system VOC emissions in new construction and renovation projects.
The General Services Administration (GSA) established an initiative to develop
requirements to make a low VOC carpet floor covering available for use in
Government offices. It is anticipated that a low TVOC emitting carpet floor
covering could be available from the GSA Federal Supply Schedule for the contract
period beginning April 1994, provided adequate technical data is available from the
TSCA Carpet Emissions Administrative Record.
The Dialogue Group developed a public brochure on information about new carpet
and indoor air quality, which will be available for general distribution.
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CHAPTER 2
Product Testing Subgroup:
Methods and Accomplishments
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2.0. PRODUCT TESTING SUBGROUP: METHODS
AND ACCOMPLISHMENTS
2.1. INTRODUCTION
The Product Testing Subgroup was comprised of selected technical representatives of
the carpet industry, related component industries, various consumer and public interest
groups, academia and other organizations, and Government agencies participating in the
Carpet Policy Dialogue Process. These individuals were selected by their respective
organizations to provide technical support for the development of methodologies to test and
quantify TVOC emissions from carpets and carpet flooring system products. They specify
test protocols and sampling plans for the voluntary testing programs prescribed in the Federal
Register notice. The Subgroup operated under the oversight of the Carpet Policy Dialogue
Plenary Group.
Two primary accomplishments were achieved by the Product Testing Subgroup during
the Carpet Policy Dialogue year. These accomplishments were (1) the development of a
standard test method for testing TVOC emissions from carpets and related carpet flooring
system products, and (2) the development of voluntary testing agreements for the carpet,
carpet cushion, and carpet installation adhesive industries. Ten formal meetings and
numerous teleconference calls and working party sessions were conducted to realize these
achievements.
This chapter provides an overview of the approach followed by the Subgroup in
meeting its goals. It documents the primary issues, concerns, and decisions made by the
Subgroup during the development of the test method and the three industry testing programs.
Numerous hours were spent discussing design options, resolving conflicts, and reaching
consensus on the testing programs proposed by industry. This chapter summarizes the
results of the successful negotiation and problem resolution process that evolved during these
discussions. These successes are attributable to the positive spirit and degree of cooperation
that was evidenced among Subgroup members.
2.2. TEST METHOD DEVELOPMENT
The development of a standard test method for the detection, identification, and
quantification of total volatile organic compound emissions from carpets and related carpet
flooring system products was a multifaceted process that involved several key technical
issues. These issues are addressed below.
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2.2.1. Total Volatile Organic Compounds
The Federal Register notice specifies that total volatile organic compound (TVOC)
emissions be measured in the voluntary testing programs to be conducted by the carpet and
its related component industries. Several discussions concerning the detection and
quantification of the individual chemical constituents of TVOC emissions from carpet
products were held. The Plenary, however, confirmed that the testing programs would focus
exclusively on TVOC emissions. Nonetheless, it was agreed that the method endorsed by the
Carpet Policy Dialogue should have the dual capability of measuring TVOC, as well as its
chemical constituent, emissions.
The first task facing the Subgroup was formulation of a definition or algorithm for
calculation of total volatile organic compounds. After consideration of the various options, it
was agreed that the definition of TVOCs would be derived from the method chosen for use
in the Carpet Policy Dialogue Testing Programs.
2.2.2. Evaluation of Alternative Test Methods
In initial discussions, it was decided that the Product Testing Subgroup would explore
state-of-the-art methodologies that could be used to detect and quantify accurate and precise
TVOC emission factors. Further, the nature of tests and their reporting should allow
comparison to typical emission factors of similar products. However, it was agreed that the
Subgroup would not develop method validation criteria, e.g., unit cost per analysis sample,
specification of the number of laboratories needed to validate the method, and qualifications
of personnel who would conduct the analyses.
The Subgroup members acknowledged that more than one method may produce
reliable TVOC emission data. They also emphasized that a uniform, agreed-upon approach
was needed for testing. A concern was raised that if multiple protocols were used in the
testing programs or if a certain procedure was changed after testing had begun, the data
analyzed by "inappropriate" methods would be invalidated. Thus, it was agreed that the
Subgroup would pursue the development of one test method for use in the testing programs.
Several test methods were considered by the Subgroup. These included static
headspace, purge and trap, and dynamic chamber techniques. There was early agreement
that environmental chamber testing was the most appropriate method for measuring chemical
emissions from carpets. This method would provide an accurate and realistic approach to
measuring carpet emissions. It would also provide reproducible TVOC determinations, for
both single-point-in-time measurements and decay curve analysis. Studies were cited which
indicated no correlation between purge and trap and environmental chamber results.
Although it was decided that the environmental chamber methodology would be the basic
technology to be used in the testing programs, another method was briefly considered.
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2.2.2.1. Quality Control/Internal Processing Test Methods
As stated in the Federal Register notice, it was initially believed that carpet products
would need to be tested on a company-by-company, product-by-product basis. Intense
market competition among product lines warranted the dissemination of comprehensive
TVOC emission factor information to the consumer. In response to this need, the Subgroup
investigated the feasibility of developing a quality control test method. This method could be
used for on-line, process monitoring.
Early on in the development process, however, the Carpet and Rug Institute (CRI)
presented exploratory data which indicated that the variability in TVOC emission factors
between carpet products made with SBR latex was not significant and that testing at an
aggregate or product class level, rather than at a company-by-company level, was
appropriate. Further, the data demonstrated that TVOC emissions from carpets were
relatively low, as compared to emissions from many other indoor products. While these
assertions were neither supported nor rejected by the Subgroup, it was agreed that Dialogue
testing would focus on the characterization of TVOC emission factors for selected product
classifications or groups of product types. If it was found that more extensive testing (i.e.,
on a company-by-company and product line-by-product line basis) was needed, it would be
pursued after completion of the Dialogue year. Additional details concerning the design of
the testing program for carpets are provided in Section 2.3.1.
Although the value of a quality control type method was clearly recognized, it was
acknowledged that one drawback to the use of the proposed method was that on-line product
testing for TVOC emissions could not be completed in sufficient time to provide information
to adjust process parameters. As such, it was not useful as a quality assurance tool.
Further, it was concluded that correlation of TVOC measurements between the quality
control and the environmental chamber test methods was impractical. Since it was unclear
what compound(s) the quality control method was measuring, it was also believed that the
method would not yield meaningful results. Thus, development of the quality control/process
monitoring test method, as sponsored by the Carpet Policy Dialogue, was abandoned.
2.2.2.2. Method Elements and Test Parameters
Several technical issues needed to be resolved concerning the environmental chamber
test method. One concern was whether the test method was sufficiently flexible to measure
emissions from all carpet flooring system products, that is, from carpet cushions and carpet
installation adhesives. Adhesives were cited as posing unique challenges for sample
application, air sampling and chemical analysis techniques. For example, the emission
profile of "wet" sources, like adhesives, will differ significantly from other components of
the flooring system. In addition, different compound classes than those released from carpet
products may be emitted from adhesives. After much discussion, it was agreed that the
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environmental chamber test method, with minor modifications, should be able to identify and
quantify TVOC emissions from carpets, as well as from other flooring products.
Other technical issues involved the specification of method elements and test
parameters. Fifteen key elements of the test protocol for flooring materials were identified.
These elements are:
Product Collection;
Product Packaging;
Product Delivery;
Product System Preparation;
Chamber Preparation;
Chamber Loading;
Chamber Testing;
Sample Collection;
Sample Introduction;
Chemical Analysis;
Quantification;
Results;
Quality Assurance;
Archiving Sample; and
Report Format.
The environmental chamber test parameters discussed were chamber size, material,
TVOC recovery, temperature, relative humidity, and air change rate. Sampling issues
included time point(s), media, volume of air, and collection methods. Desorption
temperature, time, and flow were important for sample introduction. The chemical analysis
concerns included technique, methodology, and detection. Quantification involved the
method detection limit (MDL) and minimum quantifiable limit (MQL). Calibration, use of
internal and external standards, and response reporting were also cited. Quality assurance
issues included chamber and analysis instrument controls and laboratory quality control
samples. A test method working party was established to provide the details of the standard
test method.
2.2.3. Standard Test Method
Based on the concerns and decisions described above, on November 29, 1990, the
Carpet Policy Dialogue Plenary accepted the Product Testing Subgroup's recommendation
that a small chamber method be used for measuring TVOC emissions from carpet products.
This method was documented by the EPA. in its report, "Indoor Air Sources: Using Small
Environmental Chambers to Characterize Organic Emissions for Indoor Materials and
Products" (EPA 600/8-89-074). It follows an ASTM standard, "Standard Guide for Small-
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Scale Environmental Chamber Determinations of Organic Emissions from Indoor
Materials/Products" (ASTM D5116-90).
The test method, "Test Method for Determining Total Volatile Organic Compound
Emission Factors from Carpet Under Defined Test Conditions Using Small Environmental
Chambers," reports TVOC as an emission factor from flooring materials using standard test
conditions. Quantitative measurement is determined by gas chromatography with flame
ionization detection or gas chromatography/mass spectrometry. The observed test chamber
concentration is converted to an emission factor, which may be a product specific variable.
An addendum to document protocol changes necessitated for testing of carpet installation
adhesives has yet to be finalized and will be attached to the principal document pending
results of preliminary studies in progress. (See Appendix E.)
The test method was peer reviewed by a select group of accomplished experts (listed
in Appendix A). It is anticipated that the method will be submitted to the American Society
for Testing and Materials (ASTM), subcommittee D22.05 on Indoor Air, for ASTM balloting
procedures as a proposed "Standard Method." Further validation by interested laboratories is
expected over the next 2 years.
2.3. CONSENSUS ON VOLUNTARY TESTING AGREEMENTS
The second major accomplishment of the Product Testing Subgroup was the
development of voluntary testing agreements from the carpet, carpet cushion, and carpet
installation adhesive industries. These agreements describe each industry's commitment to
conduct periodic testing to quantify TVOC emissions from newly manufactured products.
A component approach to testing was adopted by the Subgroup. That is, three testing
programs, describing the sampling and analysis plans adopted by the carpet, carpet cushion,
and carpet installation adhesive industries, were developed. Although the need for testing of
the total carpet flooring system was cited, carpet assemblies will not be tested under the
auspices of the Carpet Policy Dialogue. This approach is in recognition of the fact that from
a pollution prevention standpoint, each manufacturer only has control over their respective
component of the total flooring system.
The Federal Register notice states that EPA "will be requesting the carpet industry to
voluntarily commence appropriate periodic testing (probably on a company-by-company,
product-by-product basis) to quantify the total emissions of VOCs from their products to
provide the interested public with comparative information on total VOC emissions from new
carpets." In response to this charge to the Carpet Policy Dialogue, the Product Testing
Subgroup embarked on a mission to design testing programs to obtain industry-wide product-
specific TVOC emission data. This strategy was slightly modified during the Dialogue year
as the needs of each component industry were addressed. Since testing will be conducted on
newly manufactured products, the Subgroup agreed that the Dialogue testing would focus on
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characterizing the TVOC emission profile of individual carpet, carpet cushion, and carpet
installation adhesive products. A description of the process followed to obtain the three
carpet industry agreements follows.
2.3.1. Carpet Testing Program
On October 25, 1990, in Plenary session, the Carpet and Rug Institute (CRT)
presented the results of an exploratory effort, conducted in the previous year, which indicated
that there may not be significant variability in TVOC emission factors between carpet
products made with SBR latex. CRI recommended that future testing be conducted at a
product class level, rather than at a company-by-company level. While the Subgroup neither
accepted nor rejected this assertion, it was agreed that product testing should initially be
conducted on a random sample of carpet products, selected from those product classifications
identified by the industry as potential contributors to TVOC emissions. If it was determined
that company-by-company and product line-by-product line testing was warranted, the carpet
industry would pursue this approach in future testing.
In response to this decision, the overall objective of the Carpet Testing Program was
redefined to characterize the distribution of TVOC emissions factor performance of carpet
product types currently in commerce. The data collected under the program would address
the question of TVOC emission variability, or lack thereof, across carpet product types. The
specific goals of the Carpet Testing Program are to:
Characterize TVOC emissions in a representative sample of carpet products;
Determine the range of TVOC emissions in various carpet products;
Assess whether TVOC emissions factors are different between specific product
types; and
Generate a data base of TVOC emission factors over time.
In order to meet these objectives, a description of the carpet product universe was
needed. Carpets were defined as a variety of fabric products used for floor covering that are
manufactured from various materials by tufting, weaving, knitting, needle punching, custom
tufting, or fusion bonding. Six compositional elements are used in the manufacture of
carpets. These elements are face fiber, primary backing, latex, secondary backing,
dye/colorant, and topical treatment. There are numerous materials and processing
procedures that can be brought together to form the many combinations that comprise the full
range of carpet products currently available in the market place.
Carpet product types are further resolved into two general groupings: softback and
hardback. The softback group is a broadloom carpet product, comprising 94 percent of the
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total market share, and produced at about 151 finishing lines. The hardback group is a tile
product with a thicker backing, comprising 6 percent of the market share, and produced at
about 20 finishing lines.
For the purposes of Dialogue testing, three materials factors were used to classify
carpet product types. These factors are face fiber (nylon, olefm, polyester and wool), topical
treatment (no treatment, application of soil release treatment, and application of soil release
and stain resistant treatment) and backing (Styrene Butadiene Rubber (SBR) latex,
Amorphous Resin (AR) hardback, Urethane foam, Polyvinyl chloride (PVC) hardback,
Ethylene vinyl acetate (EVA) hardback, Urethane hardback, and Bitumen hardback). A
canvas of the industry was conducted by CRI in early 1991 to obtain information on current
products. The survey found 25 carpet product types in commerce. Eight SBR latex-backed
carpet product types, accounting for approximately 94 percent of the market, and 17 non-
SBR latex-backed carpet product types, accounting for 6 percent of the market, were
identified. It was judged that this roster comprised over 98 percent of carpet types produced
for general and commercial commerce. A listing of the 25 product types is provided in the
document, "Carpet and Rug Institute Consensus Statement: Testing Program for Carpet
Products".
Upon further evaluation, it was realized that identification of an air sampling time
point(s) for data collection was needed. That is, it needed to be determined whether a single
number, or single air sampling time point, to indicate TVOC emissions was sufficient or
whether emission time profile testing was required. Although it was acknowledged that for
product testing of the universe of carpet products, a single number resulted in lower analysis
costs, it was also recognized that in order to characterize the emission profile of specific
product classes (e.g., softback versus hardback carpets), the method would have to provide
more than a single number. Furthermore, in order to designate a sampling point(s), TVOC
emission data to characterize the decay rate of the carpet product types specified in the
design were also needed. As part of its exploratory work, CRI had collected decay curve
data on TVOC emissions of carpets made with SBR latex. The Subgroup agreed that a 24-
hour air sampling point was appropriate for analysis of softback carpets. However,
corresponding data were needed for hardback products. CRI agreed to conduct testing to
characterize the decay rate of hardback carpets.
The Carpet Testing Program is organized into two distinct studies. The first study
developed decay curve emission data on six hardback carpet product types. Eighteen
hardback carpet samples were collected and analyzed. A comprehensive decay curve
analysis was conducted to determine the appropriate sampling time point was 24 hours to use
in measuring TVOC emissions in an industry profile study. The second study began to build
a data base of TVOC emissions from a representative sample of carpet product types.
Information to assess whether average TVOC emissions factors between carpet product types
are different was obtained. These data address the variability questions raised by CRI in its
earlier work. Fifty-four SBR latex-backed carpet samples and 6 additional hardback samples
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are being collected in the second study. All carpet samples are being obtained at the end of
a manufacturer's finishing line.
The results of both studies will be combined and analyzed in an industry-wide profile
study of TVOC emissions for carpet products currently available in commerce. A total of 78
carpet samples will be statistically analyzed in the Profile Study. The appropriate air
sampling time point(s) will be used in this analysis. These data will also form the basis for a
series of proposed follow-on activities that include an annual reporting of carpet TVOC
emissions performance and a carpet product certification program. Details of these follow-on
programs will be worked out jointly by EPA and the Carpet and Rug Institute.
The Plenary reached consensus agreement on the CRI Carpet Testing Program on
February 28, 1991. The first study, on hardback products has been completed. The results
of the decay curve analysis will be submitted to the EPA and a report will be entered into the
Carpet Emissions Administrative Record when the EPA review and evaluation is completed.
The second study, on all softback and several hardback products, began in the fall of 1991.
A copy of the consensus statement and attachment to the consensus statement is provided in
Appendix F.
2.3.2. Carpet Cushion Testing Program
A similar design process was followed in developing the Carpet Cushion Testing
Program. Exploratory data on generic types of carpet cushions developed in 1990 for the
Carpet Cushion Council demonstrated that TVOC emissions from carpet cushions, while
different among product classes, approximate that of carpet emissions. It was also shown
that carpet forms a barrier to emissions from carpet cushion that significantly slows down the
permeation of TVOCs into indoor air. However, limited information about the
characteristics of the decay curve for various carpet cushion product types exists. No data
on the variability of TVOC emissions from cushions of the same product type (manufactured
at different finishing lines) or on the differences between average TVOC emission factors for
carpet cushion product types are available. Thus, decay curve data were needed on the
various carpet cushion product types. The overall objectives of the Carpet Cushion Testing
Program were defined to characterize the TVOC decay curve characteristics for each of the
carpet cushion product types currently in commerce and to determine the appropriate air
sampling time point(s) to use in measuring TVOC emissions in future studies.
Carpet cushions are composed of various raw materials, to a large extent, scrap
materials from the manufacture of products used in other industries. The scrap materials are
obtained from numerous worldwide sources and recycled for use in the manufacture of carpet
cushions. As such, the chemical makeup of an individual cushion, in particular bonded and
jute cushions, can vary and may be dependent on the time of the year and location of the
purchase of its raw materials.
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Carpet cushions are placed underneath carpet on a wall-to-wall type of installation that
completely covers the surface and sides of the carpet cushion when installed. It was
estimated that new carpet cushion is placed under approximately 50 percent of all new
broadloom carpet sold. Vinyl non-skid rug pads and other non-skid rug pads weighing less
than 14 ounces per square yard, for placement underneath area rugs, were defined to be
beyond the scope of the Testing Program.
Carpet cushions are classified into five product types: bonded, prime, rubber,
synthetic, and rubberized jute. These products are manufactured on an estimated total of 75
finishing lines, representing approximately 35 companies. Bonded cushions comprise 56
percent of the total market share (based on square yards shipped); prime cushions constitute
33 percent of the market. Rubber cushions constitute 6 percent of the total market, while
synthetic cushions represent 3 percent of the market. Rubberized jute cushions comprise 2
percent of the market.
The Carpet Cushion Testing Program will be conducted in two phases. Fifteen
samples will be collected in the combined testing program. The first phase will develop
decay curve emission data on bonded and prime carpet cushion product types, representing
89 percent of the entire market. Three samples from each product type, or a total of six
samples, will be tested. Phase n will collect corresponding information on rubber, synthetic
and rubberized jute carpet cushions. A total of nine samples will be collected in Phase II.
All carpet cushion samples will be obtained at the end of a manufacturer's finishing line.
The decay curve data established for the five carpet cushion product types will be
compared with existing data on carpet cushion TVOC emissions. They will also be used to
determine the appropriate air sampling time point, or points, to use in measuring TVOC
emissions. This single point(s) will be used to characterize carpet cushion TVOC emissions
in a larger industry-wide study, to be conducted as a follow-on activity to the Carpet Policy
Dialogue. The industry study will build a data base of TVOC emissions, collected from a
representative sample of carpet cushion products over time. Additional follow-on activities
to be conducted by the Carpet Cushion Council include an annual reporting of the aggregate
history of carpet cushion industry TVOC emission product performance for at least 3 years,
and development of a program to motivate producers to institute voluntary indoor air quality
assurance measures with respect to their carpet cushion products. Details of these follow-on
programs will be worked out jointly by EPA and the Carpet Cushion Council.
The Plenary reached consensus agreement on the Carpet Cushion Council Carpet
Cushion Testing Program on June 28, 1991. The Phase I study, on bonded and prime
products, began in the fall of 1991. Phase n, on rubber, synthetic and rubberized jute
products, will be conducted as resources become available but within a 1-year period. A
copy of the consensus statement and attachment to the consensus statement is provided in
Appendix G.
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2.3.3. Carpet Installation Adhesive Testing Program
The process followed by the carpet installation adhesives industry in developing a test
program was similar in many ways to the process followed by the carpet and carpet cushion
industries. At the start of the Dialogue year, however, the Floor Covering Adhesive
Manufacturers Committee had not been directing its efforts toward testing of TVOC
emissions from adhesive products. It needed to organize its members to respond to the
Federal Register notice and to address voluntary testing actions under the Carpet Policy
Dialogue charter. Nonetheless, the Committee reacted promptly, and a testing program was
developed.
Most carpet installation adhesive manufacturers have been calculating VOC content
using standards set by the South Coast Air Quality Management District (ASTM D3960-81
and/or ASTM D2369-87). Prior to 1990, the majority of carpet installation adhesives were
at a calculated VOC of 150 g/1 or higher. With the pressure of South Coast's Rule 1168,
manufacturers reformulated their products to a calculated VOC at or below the required 150
g/1 limit ("Rule 1168 - Control of Volatile Organic Compound Emissions from Adhesive
Application," Amended February, 1991).
A survey was taken in February, 1991, by the Floor Covering Adhesive
Manufacturers Committee asking manufacturers to report on the range of calculated VOCs in
the products they were making by product type current formulas versus new generation
formulas. The responses ranged from 40 g/1 to 150 g/1 on current formula lines and from 0
g/1 to 20 g/1 on new generation lines. At the National Association of Floor Covering
Distributors Convention, held May 5-8, 1991, 14 of the 15 carpet installation adhesive
manufacturers who had booths displayed a low VOC emission carpet installation adhesive or
a line of low VOC emission products. This trend in the manufacture of low-emitting
multipurpose carpet adhesives is regarded as a significant accomplishment of the carpet
installation adhesives industry. However, no data on the relationship between these
calculated values to TVOC emission rates from carpet installation adhesives have been
established.
Only a limited understanding about the decay curve characteristics of carpet
installation adhesives exists. Additional information to address whether a single sampling
point is sufficient to characterize TVOC emissions from carpet installation adhesives and
whether there are significant differences in the emission profiles of various adhesive product
types is needed. If a single point for TVOC measurement is reasonable, then the appropriate
point must also be determined. Further, questions concerning the applicability of the
standard test method described in Section 2.2.3. (e.g., application rate, method of
application, and type of substrate material) were raised during technical discussions on the
design of a testing program to characterize the decay curve of floor covering adhesive
products. These data gaps resulted in the need to develop a different testing design for the
adhesives industry.
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In response to the data needs identified by the Product Testing Subgroup, the overall
objective of the Carpet Installation Adhesive Testing Program was defined to characterize the
decay curve characteristics of a sample or samples from each of the carpet installation
adhesive product classifications currently in commerce. The program will not provide data
on the distribution of TVOC emissions across the universe of carpet installation adhesive
product types.
Carpet installation adhesives are formulated through a composition of several basic
ingredients, combined in varying proportions depending upon the functions of the adhesive.
Adhesive formulating and the choice of raw materials used is based on price, performance,
and environmental issues. Six functional components are generally used: vehicle (e.g.,
water, solvents, or a combination of both), binder (e.g., latex (SBR is the major latex used)
or resins (sometimes referred to as tackifiers), fillers (limestone, gypsum, sand, or clay),
viscosity control agents, preservatives, and freeze-thaw stability agents (e.g., methanol or
ethylene glycol). These raw materials are obtained from numerous sources and added to the
final mixture in amounts determined by the manufacturer. Adhesive manufacturers typically
offer a qualitative range of carpet installation adhesives, with good (economy), better, best
(premium), and specialty products. Further, variations of adhesive formulas are needed in
different geographical markets, due to variable temperature and humidity conditions.
For Dialogue testing, carpet installation adhesives were classified into five product
classifications: multipurpose, pressure sensitive, vinyl backed, pad cement, and seam sealer.
These products are manufactured by 16 member companies. Multipurpose adhesives
comprise 75 percent of the total carpet installation adhesive market and are produced by 16
companies at 32 plants. Pressure sensitive adhesives constitute 17 percent of the market and
are produced at about 26 plants, representing 16 companies. Vinyl backed adhesives
constitute 5 pecent of the total market and are produced at 28 plants (17 companies). Pad
cement (2 percent of the market) is produced at 17 plants by 12 companies. Seam sealers
are produced at 15 plants (12 companies) and comprise 1 percent of the carpet installation
adhesive market.
The Carpet Installation Adhesive Testing Program will be conducted in two phases.
Prior to commencement of the program, a preliminary study was conducted to establish
specific testing parameters for carpet installation adhesives. The Preliminary Study will
provide data to refine the test protocol for use in characterizing TVOC emissions from the
multipurpose and pressure sensitive carpet installation adhesive product classifications. It
will create and evaluate alternative test protocols to determine which procedures are most
appropriate for use in characterizing TVOC emissions from carpet installation adhesive
products. Four samples will be tested.
Following preliminary testing, Phase I will determine the TVOC decay curve
characteristics for multipurpose and pressure sensitive adhesives. These adhesives represent
approximately 92 percent of the carpet installation adhesive market. TVOC decay curves
will be analytically determined on a sample(s) of each of the product classifications.
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Measurements will be taken at the number of time points determined in the Preliminary
Study. This information could be used by the industry to determine the appropriate air
sampling time point, or points, for follow-on activities. This single point(s) could also be
used to characterize carpet installation adhesive TVOC emissions by individual companies as
they test their products in a follow-on activity to the Carpet Policy Dialogue. Fifteen
samples will be analyzed in the Phase I study.
Phase II will include decay curve testing on vinyl backed adhesives, pad cement, and
seam sealers. This testing will be conducted as resources can be made available, but within
a 1-year period. Preliminary test method development may also be needed prior to initiating
testing of these three product classifications. The number of samples to be collected in Phase
II testing will be determined upon the completion and evaluation of Phase I testing. All
carpet installation adhesive samples will be obtained directly from the distributor. The Floor
Covering Adhesive Manufacturers Committee indicated that these products have a rapid
turnover at the distributor, ensuring that newly manufactured products will be sampled in the
testing program.
The data collected in the Carpet Installation Adhesive Testing Program will also form
the basis for a series of proposed follow-on activities that include an annual reporting of the
aggregate history of carpet installation adhesive industry product type sales performance for
at least 3 years and the development of a program to motivate producers to institute
voluntary indoor air quality assurance measures with respect to their carpet installation
adhesive products. Details of these follow-on programs will be worked out jointly by EPA
and the Floor Covering Adhesive Manufacturers Committee.
The Plenary reached consensus agreement on the Floor Covering Adhesive
Manufacturers Committee Carpet Installation Adhesive Testing Program on June 28, 1991.
The Preliminary Study began in the summer of 1991. The Testing Program will begin as
resources become available but within a 1-year period. A copy of the consensus statement
and attachment to the consensus statement is provided in Appendix H.
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CHAPTERS
Process Engineering Subgroup
Summary Report
DISCLAIMER
The data/information presented in this report has not been subjected to formal peer review. In addition,
there has been limited second source verification of information presented here. The recommendations of the
Subgroup do not necessarily represent the positions and policies of individual Subgroup participants but represent
a consensus view of the Subgroup.
-------
3.0. PROCESS ENGINEER SUBGROUP
SUMMARY REPORT
3.1. INTRODUCTION
3.1.1. Background
On January 11, 1990, the U.S. Environmental Protection Agency (EPA) received a
petition from the National Federation of Federal Employees (NFFE), Local 2050, requesting
EPA to promulgate rules under section 4, 6, and 8 of the Toxic Substances Control Act
(TSCA), to reduce emissions from new carpets. [Federal Register, Vol. 55, No. 79, April
24, 1990]. In response, EPA denied the petition. However, the Agency believed that "an
absence of scientific certainty does not necessarily mean an absence of risk." EPA
recognized that "new carpet may be a significant source of human exposure to low levels of
volatile organic compounds (VOCs)" and stated that "as a matter of policy it is prudent to
minimize indoor human exposure ... where reasonable." The Agency, therefore, took three
major initiatives:
"The Agency is formally requesting that the carpet industry undertake a voluntary
program to conduct periodic total VOC analyses on a company-by-company and
product-by-product basis to provide the interested public with comparative information
on total VOC emissions. Second, the Agency is inviting all interested parties to
participate in a one-year dialogue process designed to work out the details of the
voluntary testing program mentioned above and to explore and, where possible, to
reach agreement on a variety of issues including: the sampling and analytical
methods for the voluntary testing, any additional information needed, and cost-
effective process changes to reduce emissions.... Thirdly, the Agency will continue its
on-going exposure reduction and research activities on indoor air quality issues
generally and on the potential health effects of exposure to low level VOC mixtures, in
particular.'
3.1.2. Charter and Charge of Dialogue
The charter for the Carpet Policy Dialogue was given in the Federal Register notice.
To complement the new initiatives, the Federal Register notice also laid out the following
"specific charges to the participants in the Dialogue."
" 1. Develop standard methodologies for testing carpet emissions and to obtain
commitments to test carpeting. The Agency will be requesting the carpet industry to
voluntarily commence appropriate periodic testing (probably on a company-by-
company, product-by-product basis) to quantify the total emissions of VOCs from
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their products to provide the interested public with comparative information on total
VOC emissions from new carpets."
"2. Identify information needs for assessment of emissions control feasibility,
including data on carpet manufacture and installation technology and commercial
activities associated with carpet installation."
"3. Evaluate potential controls for reducing emissions, including product and/or
emission standards, and labeling of carpet for VOC emissions."
"4. Identify VOC exposures which are associated with carpet installation but not
necessarily from a carpet source (adhesives, floor preparation, etc.) and recommend
any appropriate actions to reduce them."
3.1.3. Dialogue Defined
The Dialogue was initiated by an EPA Federal Register notice of August 3, 1990,
"Carpet Emission Reduction; Policy Dialogue", p. 31640-41. The Dialogue was to run for 1
year, ending sometime in the April to August 1991 period. It was to be run on a consensus
basis by a facilitator and be sponsored by the EPA. At the end of the process, when the
Carpet Policy Dialogue Group meeting in Plenary had agreed on a response to the charges of
its charter consisting of voluntary actions committed or undertaken by industry, the EPA
would determine whether any rulemaking was necessary to obtain the information or produce
the pollution-preventive action desired. The hope and goal of the Dialogue process was to
engender voluntary actions by industry that would adequately address the issues raised and so
obviate the need for Federal regulation under Sections 4 [testing] and 8 [reporting] of TSCA.
Participants in the Carpet Policy Dialogue included representatives from associations
or manufacturers of carpet and carpet-related sources (latex, adhesive, and cushion), the
installation industry, public interest groups, labor unions, research experts in assessment
methodology, building consultants, the public health community, and other Government
agencies.
Three Subgroups were formed to help carry-out the tasks in the Federal Register
notice: the Testing Subgroup, the Process Engineering Subgroup, and the Public
Communications Subgroup. The scope of work for the Process Engineering Subgroup is dis-
cussed below. The scopes of work for the other two Subgroups are discussed in other
Subgroup Reports. All the Subgroups reported their findings and recommendations to the
Dialogue Policy Group which then made the final decisions.
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3.1.4. Process Engineering Subgroup
3.1.4.1. Scope of Subgroup Activities
The Process Engineering Subgroup was established in order to develop a response to
the charter and charges for the Carpet Policy Dialogue Group. The scope of the Process
Engineering Subgroup activities included charges 2, 3, and 4 listed in section 3.1.2. The
goal of the Subgroup, based on these charges, was mainly to identify information gaps and
potential cost-effective methods to reduce VOC emission from carpet and other related carpet
sources and installation activities. Also, as stated in the Federal Register notice, this goal
was to be achieved by sometime in April to August 1991.
In order to meet the commitments of the Federal Register notice, a boundary on the
scope of work was set by the Carpet Policy Dialogue Group to include carpet, latex, adhe-
sives, and cushion and installation activities, exclusively. The Carpet Policy Dialogue
Group, in setting this boundary, acknowledged that there may be other sources of VOC
contributors. Also, it was understood that the Agency, through its on-going research activi-
ties on indoor air issues, would consider other sources of VOC contributors.
3.1.4.2. Organization and Operational Structure
To effectively carry-out the charges above, the Process Engineering Subgroup had
limited the number of participants in the Subgroup to include only representatives from the
following participating organizations. These participants were chosen to provide adequate
representations of all various interest and concerned groups in the Carpet Policy Dialogue
Group. A complete list of Subgroup members and their affiliations is included in Appendix
A.
Corporate or Organizational
Constituency Individuals Affiliation
Architects Hal Levin ASTM Subcommittee D22.05
on Indoor Air
Carpet Adhesive Charles Cline Floor Covering Adhesives
Formulators Ken Knudtzon Manufacturers Committee
Ron Swope ALCO Chemical
Carpet Cushion Mfg. William Oler Carpet Cushion Council
Carpet Installers James Dipelesi Floor Covering Installation
Contractors Association
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(continued)
Constituency
Carpet Mfg.
EPA
Fiber Mfg.
Labor
National Institute of Standards
and Technology (NIST)
Styrene-Butadiene Latex Mfg.
Individuals
Ron VanGelderen
Ken Mclntosh
Joe Smrekar
Wardner Penberthy
Robert Axelrad
John Girman
Henry Fogle
William Hirzy
Andrew Persily
Randy Arnott
Werner Braun
Corporate or Organizational
Affiliation
The Carpet and Rug Institute
Milliken and Company
EPA, Office of Toxic
Substances
EPA, Office of Air and
Radiation
EPA, Office of Air and
Radiation
American Fibre
Manufacturers Association
National Federation of Federal
Employees, Local 2050
NIST Indoor Air Quality
Group
Reichhold Chemicals, Inc.
Dow Chemical USA
The operational structure of the Process Engineering Subgroup consisted of a series of
Subgroup meetings. The agenda for these meetings generally included presentations by
representatives from various participating organizations. (See Table 3-1.) Topics covered
included information on the manufacturing processes of latex, adhesives, cushion, and carpet;
installation procedures; ventilation; and research activities. Available data on VOCs and
VOC emissions from carpet and carpet-related sources were also presented.
3.1.4.3.
Process Engineering Subgroup Proceedings
The Subgroup reviewed extensive amounts of technical information related to carpet
and carpet component manufacturing processes, carpet installation, as well as data related to
VOC emissions from carpet and carpet-related sources. By considering these topics, the
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TABLE 3-1
TECHNICAL PRESENTATIONS MADE TO THE PROCESS
ENGINEERING SUBGROUP
I. SB Latex
Tom Potts (Reichhold Chemicals, Inc.) and Jessie Roeck (Dow Chemical USA),
9/26/90. Presented information on latex manufacturing process, quality control, and
4-phenylcyclohexene reduction achievements.
Distributed copies of Dr. Van Ert's report to workgroup members on 9/26/90. The
report summarizes Dr. Van Ert's laboratory-scale study of carpet oven curing
parameters on VOC emissions.
Randy Arnott, Styrene-Butadiene Latex Manufacturers Council (SBLMC), 5/21/91.
Presented company-by-company 4-phenylcyclohexene data from May 1988 to
February 1991.
II. Adhesives
Ken Knudtzon, Floor Covering Adhesives Manufacturers Committee (FCAMC),
9/26/90. Gave an overview of carpet adhesive market and formulations.
Steve Chase, Floor Covering Adhesive Manufacturers Committee (FCAMC),
10/24/90. Presented detailed information on carpet adhesive formulations,
components that make up adhesives, and potential VOC levels in those components.
IE. Carpet Cushion
William H. Oler, Carpet Cushion Council (CCC), 9/26/90. Gave an overview of
carpet cushion market, and manufacturing process of Bonded Carpet Cushion and
Prime Urethane Carpet Cushion.
William H. Oler, CCC, 11/30/90. Presented information on manufacturing process.
William H. Oler, CCC, 4/9/91. Presented information on carpet cushion market and
potential methods of reducing VOCs from carpet cushion.
IV. Carpet Manufacturing
Ron VanGelderen and others, Carpet and Rug Institute (CRI), 9/26/90. Presented
information on carpet market and carpet manufacturing process.
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TABLE 3-1
TECHNICAL PRESENTATIONS MADE TO THE PROCESS
ENGINEERING SUBGROUP
(continued)
IV. Carpet Manufacturing (continued)
Alan Luedtke, Du Pont, 10/24/90. Presented data on an industry cooperative plant-
scale study (Du Pont, Shaw, Dow, and Ciba-Geigy) on the effect of carpet curing
oven operating parameters on VOC emissions.
V. Carpet Installation/Ventilation
Jim Dipelesi, Floor Covering Installation Contractors Association (FCICA), 9/26/90.
Presented information on installation methods, installation parameters, and guidelines.
Jeff Davidson, EPA, 11/30/90. Gave a presentation on the EPA Carpet Installation
Study about VOC emissions from installed urethane backed carpet (USEPA 1991).
This study demonstrated that the selection of low VOC emiting carpet floor covering
materials can reduce TVOC concentrations following new carpet installation. A copy
of this study has been entered into the EPA TSCA Carpet Emissions Administrative
Record.
Hal Levin, Hal Levin Associates, 4/9/91. Gave a presentation defining the
relationship between building ventilation rates and indoor air VOC concentrations and
setting forth practical control strategies for controlling carpet system VOC emissions.
Andy Persily, National Institute of Standards and Technology (MIST), 4/9/91. Gave
a presentation reporting the results of an NIST Study comparing actual versus design
ventilation rates in selected Federal Office Buildings.
Bruce Tichenor, EPA, 4/9/91. Gave a presentation on the effects of ventilation rates
and conditioning times on indoor concentrations of 4-phenylcyclohexene.
John Girman, EPA, 4/9/91. Gave a presentation on general concepts of physical
processes affecting VOC carpet emissions.
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In order to provide a better understanding of the Subgroup deliberations of particular
topics (e.g., latex manufacturing, carpet installations), this Summary Report includes a
section called Process Engineering Subgroup Proceedings, which is included at the end of
each chapter presenting the topic. Subgroup issues that were of a general nature or related to
all the topics are discussed below.
At the first Carpet Policy Dialogue Plenary meeting, various industry participants
raised their concerns about the open nature of the dialogue process. For example, concern
was expressed that some information presented at the Plenary and Subgroup meetings may
not have been peer-reviewed or verified for accuracy. It was suggested that information and
documentation presented to the Subgroup should include all sources and references used.
The Subgroup also suggested that a disclaimer be included in all draft documents presented
to the Dialogue to reflect that some information could not be verified, was tentative, or that
conclusions do not necessarily reflect positions of individual organizations participating in the
dialogue. The suggested disclaimer was, "Not verified or endorsed as fact by the EPA
Carpet Dialogue GroupFor discussion purposes only. Do not quote or cite!"
A recurring issue in the Subgroup deliberations was whether speciated data on VOC
components from carpet and carpet-related sources could be made available to the Subgroup.
It was suggested by some members of the Subgroup that speciated data could allow the
Subgroup to focus their investigations into reducing Total Volatile Organic Compounds
(TVOC) in a more efficient manner. Also, it was suggested that this kind of data could
allow the most significant TVOC sources to be targeted from more detailed evaluations of
potential actions to reduce TVOC.
Some members of the Subgroup suggested that speciated data could not be shared
with the public due to litigation. Other members suggested that speciated data might not be
available; also, most current analytical methods might not be accurate in determining
individual VOCs. No consensus agreement was reached by the Subgroup on this issue and,
therefore, the issue was referred to the Plenary for further consideration.
It was suggested at the Plenary that existing sources of speciation data be investigated.
Some very limited speciation data were later provided to the Subgroup by various industry
groups. These data are included in this Subgroup Summary Report. Details on the
discussions of this issue can be found in the Carpet Dialogue minutes of the October 25,
1990; November 29-30, 1990; February 27-28, 1991; April 8-10, 1991; and May 21-22,
1991, meetings; a March 5, 1991, letter from Hal Levin to Charles Auer citing sources of
speciated data on carpet emissions; a presentation by William Hirzy on the need for data,
given to the Plenary at the November 29, 1990, Plenary Session; and the Minority Report to
the Carpet Testing Agreement.1
Available in the Administrative Record.
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Another recurring issue in the Subgroup deliberations was how proprietary
information could be handled. The Subgroup, in general, sought as much process
information as possible about the carpet and carpet TVOC related sources, especially
manufacturing process information. Much of this information was considered proprietary by
Subgroup members. One mechanism used to help protect proprietary information was
blinding or aggregating the pertinent data. In addition, confidentiality agreements were at
times used. However, in many circumstances, proprietary interests of the companies
involved prevented extremely detailed discussion of some relevant process information or
related issues. In some of these instances, issues that could not be addressed by the
Subgroup have become an information or research item or recommendation to the Plenary
for further consideration.
3.1.4.4. Purpose of This Chapter
This Chapter is intended to partially fulfill part of the requirements of the Federal
Register notice-mainly the identification and evaluation of potential methods of reducing
VOC emissions from carpet and carpet-related sources and installation activities and
identification of information gaps. This Chapter presents information that was presented in
the Process Engineering Subgroup meetings and recommendations the Subgroup has made
based on this information. Section 3.2 presents information on styrene-butadiene latex
manufacturing process. The section presents information on process description, historical
perspective on VOC reduction, evaluation of potential methods to reduce VOCs, and
identifies information and research considerations and Subgroup recommendations.
Subsequent sections, structured in a similar format to Section 3.2, include information on
adhesives, carpet cushion, carpet manufacturing processes, and installation practice and
ventilation, respectively.
Each section of the Chapter was initially written by representatives of the various
industry sectors who presented the information to the Subgroup.
3.2. STYRENE BUTADIENE LATEX MANUFACTURING
3.2.1. Process Description
This section provides an overview of the styrene-butadiene (SB) latex manufacturing
process. A great majority of information presented in this section was provided to the
Process Engineering Subgroup of the Carpet Policy Dialogue by the Styrene-Butadiene Latex
Manufacturers Council (SBLMC).
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Emulsion polymerization processes are used to manufacture styrene butadiene latexes
(SBL) for carpet manufacturing. SBL is a copolymer of styrene and 1,3-butadiene. The
reaction sequence is as follows:
HC - CH
rCH - CH 2CH2-CH . CH - CH
Styrene
CH - CH » CH
Butadiene
Styrene-butadiene unit
During polymerization, an unwanted byproduct, 4-phenylcyclohexene, is formed as a result
of the Diels-Alder side reaction of butadiene with styrene. This side reaction proceeds as
follows:
HC « CH
2
+ CH - CH CH - CH
Styrene
Butadiene
4-Phenylcyctohexene
Another possible byproduct of the polymerization reaction is 4-vinylcyclohexene.
This unwanted byproduct is formed as a result of a Diels-Alder side reaction of two
butadiene molecules. The reaction proceeds as follows:
CH = CH - CH = CH
2 2
+
CH - CH - CH » CH
2 2
H
H
Butadiene
Butadiene
4-Vmylcyclohexene
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Emulsion polymerization is the polymerization of monomer droplets suspended in a dilute
aqueous phase. Prior to and/or during polymerization, the monomers (styrene and
butadiene), soap solution, initiator, and modifiers, are fed to the reactors. The amounts and
types of these ingredients vary among manufacturers. The soap solution acts as an
emulsifier. The initiator facilitates the generation of free radicals at lower temperatures, and
the modifier controls the chain length and molecular weight distribution of the SBL.
In most plants, polymerization temperature is typically about 60° - 100°C. Some
plants employ "cold" processes, which are operated at about 4°C. In the cold process, which
is employed in less than 5 percent of carpet latex manufacturing, conversion of monomers to
copolymer is less complete than is achieved by the hot process. A list of companies,
manufacturing plants, and their production methods is included in Table 3-2.
Normally, polymerization takes from 4 to 24 hours to complete. Polymerization
proceeds in the reactor vessels to 96 - 99 percent completion. A shortstop is added to halt
the polymerization.
Following polymerization, the newly-synthesized latex is directed to a blowdown tank
where unreacted monomers, monomer impurities, and byproducts remain. The latex is then
transferred to flash tanks where 1,3-butadiene is vaporized and then fed to a steam stripper
for the removal of styrene. (See Figure 3-1.) The latex is then transferred to process tanks
where additives, including anti-oxidants, are introduced. Subsequently, the latex is filtered
and sent to storage from which the latex is packaged into drums or loaded into rail tank cars
or tank trucks for delivery to carpet mills.
Styrene-butadiene latex products sold to the carpet industry are produced on a
consistent basis utilizing Quality Management and Statistical Process Control techniques.
Raw materials used in the latex manufacturing process are monitored for conformance to
specifications prior to use. Certificates of Analysis are required and supplier audits are
periodically performed. TVOC content is not currently a raw material specification.
Critical process parameters in the polymerization phase are monitored during the
reaction and adjusted to maintain statistically established control limits. Typical latex proper-
ties specified for analysis include: pH, total solids, residual monomer (styrene), particle
size, and viscosity. Only latex that meets all specifications agreed to by a supplier and its
customer is released for shipment. To further assure quality products and conformance to
rigid specifications, Technical Sales and Service personnel are available on customer request
to offer technical assistance at carpet manufacturing locations.
Styrene-butadiene latex suppliers recognized many years ago the importance of
providing products that consistently meet customer needs. Through the development of
computerized and statistical process controls, along with tighter customer performance
specifications, a high quality product is assured. TVOC or 4-phenylcyclohexene are not
currently specifications of SB latex product.
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X
UJ
CO
W
o
z
O
D
O
O
cr
a.
UJ
Q.
O
O
D
-------
FIGURE 3-1
FLOWCHART OF THE SBL PROCESS
SOAP SOLUTION
CATALYST
MODIFIER
STYflENE
BLTTADIENE
STEAM
Source: PEI Associates, Inc., 1984. Worker Exposure to
1,3-Butadiene in the Plastics and Rubber Industry.
Prepared for the U.S. Environmental Protection Agency.
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More detailed technical information describing emulsion polymerization processes can
be found in the published technical literature.
The sources of VOCs in the manufacture of SB latex include: unreactable monomer
impurities, unwanted Diels-Alder reaction products (4-phenylcyclohexene and 4-vinylcyclo-
hexene), and residual unreacted monomer. Unreacted monomer is typically the highest
concentration of VOC components found in latex at the conclusion of polymerization, and is
reduced via steam stripping. (See Section 3.2.3. below.)
Typically, the most persistent VOC component in the finished latex, and the finished
carpet, is the Diels-Alder reaction product of styrene and butadiene, 4-phenylcyclohexene,
which is unavoidably formed during the polymerization process.
Process variables which can affect SB latex 4-phenylcyclohexene concentrations are
discussed in Section 3.2.3.
3.2.2. VOC Reductions Already Achieved
In mid-1988, in light of questions raised about 4-phenylcyclohexene, SB latex
manufacturers began to review the levels of 4-phenylcyclohexene present in their finished
product. SBLMC began several research projects, including the development of a validated
analytical method, to assure consistent results. Latex manufacturers individually examined
their processes to determine if process changes could reduce the levels of
4-phenylcyclohexene.
Voluntary actions by individual latex manufacturers have achieved significant
reductions in 4-phenylcyclohexene levels over the last 2 years. Because 4-phenylcyclohexene
was not an issue until recently, and because the current validated analytical method was only
developed in 1989, manufacturers are unable to provide comparable quantitative data on
historical levels of 4-phenylcyclohexene in latex used in carpet manufacturing prior to 1988.
In the 2 years between 1988 and 1990, latex manufacturers have voluntarily improved
processes so as to reduce 4-phenylcyclohexene content in latex sold to the carpet
manufacturing industry by almost 50 percent, to an industry average of about 125 ppm. (See
Figure 3-2.) These data were compiled from information provided confidentially by SBLMC
members for the months of May 1988, May 1990, and January to February 1991. This 50
percent reduction has been achieved only through major technical efforts and significant
operating and capital costs estimated at about $10,000,000.
Each SBLMC member company has expended considerable effort to reduce
4-phenylcyclohexene levels. Each member company also recognizes that reduction of VOCs
presents an opportunity for a competitive advantage. Any company that could develop a
latex with substantially reduced VOCs could market the product with a considerable
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FIGURE 3-2
4-PHENYLCYCLOHEXENE REDUCTION HISTORY
260 I
4-PCH, PPM
200-
160-
100-
60
Industry Avtrag*
+ Individual Company
Avtragaa
fttay *M
10
'91
Styrene Butadiene Latex
Manufacturers Council
May 1991
*Data include 320 individual measurements
representing approximately 94% of Jan.-Feb.
1991 shipments to the carpet trade. This
represents an average of 50% reduction since
1988.
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advantage in the existing highly competitive marketplace. This is the operative mechanism
that has already resulted in lower 4-phenylcyclohexene levels.
3.2.3. Potential VOC Reduction Mechanisms
During the course of the Carpet Policy Dialogue, questions have been raised
concerning the effect of several recipe and process control variables on the concentration of
4-phenylcyclohexene in SB latex.
During the last 2 years, all six SBLMC member companies dedicated considerable
research and development efforts toward reduction of 4-phenylcyclohexene in their respective
latexes. While process and recipe variables were studied, these parameters are unique for
each plant. Each manufacturer has a unique configuration of equipment combined with a
unique production recipe which has been developed over years to work efficiently on that
equipment. The proprietary nature of these methods differentiates competitors in a highly
competitive market. The details of these efforts constitute valuable trade secrets. The
following process variables theoretically can affect 4-phenylcyclohexene formation and
removal: (1) reactor temperature; (2) reactor pressure; (3) reactant concentration; (4) reactor
residence time; (5) reaction catalyst and initiators; (6) additives and anti-oxidants; and
(7) stripping conditions.
Reactor Temperature
The reaction rates to form both 4-phenylcyclohexene and polymer are temperature
dependent. It is almost impossible, therefore, to utilize temperature independently as a
variable to reduce 4-phenylcyclohexene levels without adversely affecting polymerization
rates and end-use polymer performance.
Reactor Pressure
Reactor pressure itself is not an independent factor in 4-phenylcyclohexene formation.
Reactor pressure is a measured parameter in the polymerization of styrene and butadiene and
is indicative of the unreacted butadiene in the vessel. Therefore, higher observed pressures
may indicate a higher concentration of reactants in the reactor, which would favor both
4-phenylcyclohexene and polymer formation as described below.
Reactant Concentration
To produce carpet latex with the desired performance properties, the ratio of styrene
to butadiene during polymerization must be near a 1:1 molar ratio. Molar equivalency is
worst case in favor of Diels-Alder formation of 4-phenylcyclohexene. To obtain the desired
product properties with a 1:1 monomer molar ratio, it is also important to polymerize the
monomers in a nearly random fashion which requires them to be present in the reaction
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vessel simultaneously. Deviation from this random polymerization results in a significantly
different product with unacceptable physical properties.
Any parameter that may affect the concentrations of styrene and butadiene during
polymerization will also affect the formation rate of 4-phenylcyclohexene. In addition, the
monomer concentration cannot be changed arbitrarily without affecting the performance
properties of the final latex. The polymerization parameters have been optimized during
product design to produce a latex that will have the performance required by the customer.
These parameters include polymerization temperature, initiator level, and reactant concen-
tration. Having achieved the necessary product performance, no obvious options remain for
changing the monomer concentrations to reduce 4-phenylcyclohexene formation rates during
polymerization.
Monomer concentration is the most significant factor in the formation of
4-phenylcyclohexene. Increased monomer concentration will increase the Diels-Alder
formation of 4-phenylcyclohexene. This factor is greatly influenced by the uniqueness of
manufacturing processes and uniqueness of recipes.
Reactor Residence Time
Residence time is not a factor in 4-phenylcyclohexene formation, except as it relates
to reactant concentration. Longer residence times for semi-batch polymerizations could yield
reduced unreacted monomer concentrations at any given point in time. Lower concentrations
of unreacted monomer could potentially yield reduced 4-phenylcyclohexene formation as de-
scribed in "reactant concentration." However, reactor residence time is a major factor in
end-use performance of the polymer and cannot be significantly lengthened without
unacceptable product and production impact.
Reaction Catalysts and Initiators
The generally recognized distinction between catalyst and initiator is that a reaction
initiator is consumed in the reaction and a catalyst is not. Latex manufacturers do not use
catalysts in the polymerization of SB latex and, therefore, catalysts are not a factor.
Although in some cases it may be possible to catalyze Diels-Alder reactions, no catalyst is
needed and none is present in the latex polymerization reactor.
The rate of the Diels-Alder reaction of styrene and butadiene to form 4-phenyl-
cyclohexene is not affected by free radicals. Most mechanistic evidence suggests that the
reaction takes place by a one-step, concerted process that does not involve free radicals.
Further, there is no known means for inhibiting the Diels-Alder reaction. (See J. March,
Advanced Organic Chemistry: Reactions, Mechanisms, and Structure, 2nd edition, McGraw
Hill, 1977, pp. 761-767.)
3-16
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Free radical initiator concentrations affect the polymerization rate of styrene and
butadiene monomers and, therefore, might have an indirect effect on a 4-phenylcyclohexene
formation. Increasing the polymerization rate will lower the monomer concentration in the
reactor at any point in time. As previously described, monomer concentrations cannot be
arbitrarily changed without significant negative impact on the performance properties of the
latex.
Additive and Anti-Oxidants
No additives that would reduce 4-phenylcyclohexene formation are known. Post-
reaction additives are not known to contain 4-phenylcyclohexene and, therefore, are not
likely to affect levels other than through very slight dilution. Similarly, anti-oxidants will
not reduce 4-phenylcyclohexene content.
Stripping Conditions
All SB latex producers currently steam strip final polymerization batches to reduce
residual monomers. As a consequence, other volatile components, including
4-phenylcyclohexene, are also reduced. However, industry claims further significant
4-phenylcyclohexene reduction through additional steam stripping is considered impractical
because of adverse impact on product quality and increased energy, capital and other costs.
During steam stripping, the removal rate for a volatile component depends primarily
on its vapor pressure and molecular weight. Since the vapor pressure of
4-phenylcyclohexene is much lower than that of styrene, an amount of stripping that provides
a 50 percent reduction in styrene concentration will only reduce 4-phenylcyclohexene concen-
tration by about 4 percent. Industry claims increases in residence time, or decreases in feed
rates for column strippers could reduce TVOC but will have only a minimal effect on
4-phenylcyclohexene reduction. No information is available to the Subgroup which would
help to define the optimum conditions for TVOC removal.
The mechanical stability of SB latex may be adversely affected by severe steam
stripping. Extreme stripping could result in products that do not meet customer
specifications and major difficulties in carpet manufacturing would arise. However, the
maximum TVOC removal that can be realized without unacceptable impact on SB latex
properties remains to be defined. The impact of steam stripping on latex product quality
needs to be considered when defining optimum conditions.
The manufacture of SB latex may be viewed as two sequential steps: (1) the reaction
step; and (2) the monomer removal (steam stripping) step. Most plants have been designed
so that these processes take roughly the same time. Therefore, an increase in the time of
steam stripping could result in a loss in plant capacity. For example, twice as much batch
stripping could potentially cut the plant capacity in half.
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Additional steam stripping sufficient to lower 4-phenylcyclohexene levels significantly
could also create more organic-contaminated condensate and solid latex waste that would
need to be disposed or further processed. Aqueous effluent from the plant could increase
roughly in proportion to the additional stripping.
In summary, additional steam stripping, which is energy intensive and potentially
detrimental to product quality and plant capacity, could require considerable further capital
and operating costs. No studies are available to the Subgroup which quantify TVOC
reductions, increased capital and operating costs, reduction in plant capacity, and negative
impacts on latex product quality as a function of more extensive steam stripping.
3.2.4. Process Engineering Subgroup Proceedings
At the September 26, 1990, Process Engineering Subgroup meeting, the SBLMC
presented an overview of the latex manufacturing process and reported that since 1988,
concentrations of 4-phenylcyclohexene in latex have been reduced by 50 percent. This
presentation provided the basis for a chapter of the Summary Report on the latex
manufacturing process and Subgroup discussions of this topic.
Comments on this chapter were discussed by the Subgroup at the February 28, 1991,
meeting. The Subgroup expressed interest in having company-by-company and/or plant-by-
plant data, as opposed to aggregated industry-wide data, to support the conclusion that a 50
percent reduction has been achieved. SBLMC positively responded by presenting company-
by-company data at a later meeting. The Subgroup showed a keen interest in better
understanding the relationship between 4-phenylcyclohexene and TVOC levels in latex.
An additional topic of discussion included the effects of SB latex manufacturing
conditions (particularly the reaction and stripping operations) on 4-phenylcyclohexene levels
in latex. Due to the highly proprietary nature of related process information, discussions of
the details of the reaction operation were limited. The Subgroup considered whether the
steam stripping operation could be generically discussed. One suggestion was to perform a
computer simulation of this operation which could result in a paper parametric study on VOC
residuals. The Subgroup deferred undertaking development of a generic model pending the
company-by-company 4-phenylcyclohexene data to be later provided by SBLMC.
The Subgroup discussed whether information on individual VOC components in SB
latex could be made available to the Subgroup by SBLMC. It was suggested that these kind
of data could be useful to the Process Engineering Subgroup; the data could help evaluate
potential controls for reducing TVOC emissions. SBLMC commented that they only had 4-
phenylcyclohexene data and that they would provide these data to the Subgroup. These data
were later provided by SBLMC and are included in this Summary Report.
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In general, a wide range of issues related to carpet TVOC emission rates was
discussed in the Subgroup sessions. Issues that could not be resolved were included in the
Subgroup's list of information or research considerations or recommendations forwarded to
the Plenary.
At the May 21, 1991, Subgroup meeting, the Subgroup recommended that the Plenary
accept SBLMC's proposal to conduct an industry wide survey of 4-phenylcyclohexene levels
in SB latex during 1991 and 1992 and to make such data publicly available through EPA.
The Subgroup also recommended that SBLMC and Carpet and Rug Institute (CRT) investigate
the feasibility of developing an industry standard for 4-phenylcyclohexene and report to the
EPA periodically on their progress. These information/research considerations and Subgroup
recommendations are cited in detail in sections 3.2.5 and 3.2.6 below.
3.2.5. Information and Research Considerations
The following ideas were raised by some members of the Subgroup considering
information that may help in identifying control measures to reduce TVOC. These
suggestions do not necessarily represent the consensus of the Subgroup. These are presented
as suggestions for future consideration of EPA or industry.
1. While the focus of the Carpet Policy Dialogue is TVOC and not
4-phenylcyclohexene, the 4-phenylcyclohexene reduction achievements of the
SBLMC are very important. To expand the relevance of the 4-phenylcyclohexene
data presented, a discussion of whether SB latex 4-phenylcyclohexene levels relate
to TVOC and, if such correlation exists, how this correlation or lack of
correlation has been determined.
2. An evaluation of technological alternatives to steam stripping for removing TVOC
from SB latex.
3. An evaluation of the impact of stripping conditions on latex VOC emissions would
be helpful. While detailed information on reactor operation is extremely
important, stripping may have a greater impact on TVOC removal. Stripping
could be a method of further reducing the levels of VOCs in latex. Therefore, a
detailed quantitative evaluation of stripping as a method of reducing VOC contents
in latex should be undertaken. This evaluation should quantify TVOC reductions,
increased capital and operating costs, reductions in plant capacity and negative
impacts on latex product quality as a function of more extensive stripping.
4. A comprehensive list of VOCs in the final latex product would be very useful, as
well as individual plants' TVOC and 4-phenylcyclohexene levels in final latex.
These data could provide insight into the specific sources of VOCs in the final
latex product and could help better define the potential for process or engineering
3-19
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changes for reducing SB latex VOC emissions. The correlation of latex TVOC to
carpet TVOC would also be helpful.
3.2.6. Subgroup Recommendations to Plenary
1. The Plenary should make a recommendation to the Agency to consider developing
a Memorandum of Understanding (MOU) regarding SBLMC's proposal for an
industry-wide survey of 4-phenylcyclohexene levels in SB latex in 1991 and 1992
to demonstrate continued quality assurance.
2. The Plenary should recommend to SBLMC and CRI to jointly discuss the
feasibility of developing an industry standard for 4-phenylcyclohexene in SB latex
and report to EPA on their progress. The Agency should consider developing a
MOU on this issue with SBLMC and CRI.
3.3. ADHESIVES MANUFACTURING/FORMULATION
3.3.1. Overview of Carpet Adhesives and Formulation Process
This section provides an overview of the carpet adhesives and formulation process. A
great majority of this section was supplied to the Process Engineering Subgroup of the Carpet
Policy Dialogue by the Floor Covering Adhesives Manufacturers Committee (FCAMC).
3.3.1.1. Adhesive Properties
The success or failure of any adhesive depends upon its ability to adhere to the
materials being bonded, and its own internal strength characteristics. Although the
phenomenon of how one material adheres to another is still not well understood, what makes
an adhesive fail to adhere is well known. Failure to adhere-or bond-means the adhesive
system does not have the ability to bond adequately due to lack of, or weakness in, one of
the following characteristics.
Wetting
The ability of an adhesive to wet (or distribute itself over) the surfaces to which it is
bonding. Wetting is an essential property in that it maximizes the points of contact between
the adhesive and the adherents (substrates).
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Mechanical
The facility by which a rough and irregular surface provides undercuts and a jagged
condition conducive to locking - or keying - which induces mechanical meshing and a good
bond. An example of good locking - or keying - is the way in which metal lath holds
gypsum plaster.
Chemical
The ability of an adhesive to adhere by an internal force to another substance, just as
the opposite poles of a magnet attract.
These characteristics are affected by three human-related factors that are common
causes of bond failure. The first is in the improper choice of the adhesive itself - using the
wrong product for the job. The second is improper preparation of the surfaces, the result of
lack of experience or carelessness. The third is improper application of the adhesive,
resulting from lack of know-how or from the rush to finish the job.
3,3.1.2. Types ofAdhesives
There are generally five types of carpet adhesives: multipurpose adhesives, pressure-
sensitive, vinyl-back adhesives, pad cements, and seam sealers. Of these, the multipurpose
and pressure-sensitive adhesives represent over 90 percent (by volume) of the adhesives
being used and are discussed in more detail below.
Multipurpose adhesives used in carpet installation are thick pastes that are applied to
the floor by a notched trowel. The amount of adhesive applied is controlled by the size and
spacing of the trowel notches. The amount required is dependent upon several factors,
including the type and construction of the carpet back and the subflooring material. A
coverage of 10-15 square yards-per-gallon is typical.
Pressure-sensitive adhesives are, as the name implies, materials that remain tacky
after drying. They are used predominantly when it is desirable that the carpet can be
removed from the floor and reapplied a number of times during its useful life or more
recently for foam pad in double-stick applications.
Pressure-sensitive adhesives may be applied to the floor with a notched trowel, with a
napped roller similar to a paint roller, or by spraying. The amount of adhesives required
depends upon the substrate type and conditions and the carpet backing. The coverage rate
for pressure-sensitive adhesives is approximately 35-50 square yards-per-gallon.
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3.3.1.3. Raw Materials and Formulation
3.3.1.3.1. Multipurpose adhesives
Multipurpose adhesives, produced by 15-20 adhesive manufacturers, typically are
made in a variety of grades from economy to premium products. The choice of the adhesive
is based principally upon the performance characteristics required and the warranty of the
carpet. Obviously, the adhesive must perform its function for the lifetime of the carpet. The
various grades are achieved by varying the ratio of the ingredients discussed below. In
addition, the density of the adhesive ranges from 9.0 to 10.0 pounds per gallon, with an
average density of 9.5 pounds-per-gallon.
Different formulas for the same grade of adhesive are needed in different
geographical markets due to different temperature and humidity conditions. For example,
there is a great difference in application conditions in Florida, New Mexico, or North
Dakota.
The vehicle is the liquid portion of the adhesive that maintains the product in a fluid
state until it is applied. As the vehicle evaporates, the adhesive's characteristics appear. The
earliest manifestation of the loss of the vehicle is tackiness followed by progressive increases
in the strength of adhesion between the subfloor and the carpet.
The predominant vehicle in multipurpose adhesive is water augmented by petroleum
solvents such as mineral spirits and VM & P naphtha. Water may constitute up to 50
percent of the adhesive formulation. In recently developed formulations, solvents represent 0
to 5 percent of the adhesive formulation.
Binder
The binder used in multipurpose adhesives is an elastomeric polymer usually in an
emulsion (latex) form, A variety of polymers have been used including natural, neoprene,
acrylic, styrene-butadiene, etc. Styrene-butadiene latex is the predominant choice. The
styrene-butadiene latex used in the multipurpose adhesive is usually manufactured by the
"cold polymerization" process. This gives a more "rubbery" characteristic than the styrene-
butadiene rubber typically used in carpet backing.
According to a leading SB latex manufacturer, the typical SB latex used in the
manufacture of carpet adhesive has less than 10 ppm of 4-phenylcyclohexene when tested by
the method specified by SBLMC.
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Fillers or Extenders
Fillers or extenders are inert materials generally inorganic in nature such as
limestone, gypsum, silica, or clay, that are used to extend and reinforce the adhesive.
Greater cohesive strength and lower materials cost can be achieved by incorporating
extenders into the formulation. Extenders may comprise 20-40 percent of the total adhesive
formulation with the economy grades containing the highest proportions.
Freeze-Thaw Stabilizers
Freeze-thaw stabilizers are incorporated into the formulation to protect the adhesive at
reduced temperatures encountered during storage and shipment. The most often used
stabilizers are ethylene glycol and/or methanol and may constitute 1 to 5 percent of the
adhesive formula. Various manufacturers stabilize their products to different levels ranging
from -15° to -H5°F. It is expected that the adhesive may be cycled 3-5 times through these
temperatures without destabilizing.
Resins
Hydrocarbon resins provide adhesion and tack to the adhesive. The resins are the
polymerization product of a variety of unsaturated petroleum feed stocks derived from the
ethylene cracking process. For incorporation into the formulation, resins which are hard and
brittle are usually predissolved in processing oils and solvents.
Processing Oils
Processing oils which are refined petroleum hydrocarbon oils are used to plasticize or
soften the adhesive formulation. As the level of processing oil increases, the adhesive (in its
dry state) becomes softer. In combination with resins, processing oils also enhance tack.
Viscosity Modifier
Without the incorporation of viscosity modifier, the adhesive would be thin and
watery and incapable of being applied in a useful manner by trowel. Examples of viscosity
modifiers used in adhesives are sodium polyacrylate solutions and alkali-soluble emulsion
polymers.
Preservatives
Because some of the materials in adhesives are nutrients for bacteria and fungi, a
biocide is usually added to control their growth. A wide variety of biocides are available and
are chosen based upon their cost and efficacy. They usually comprise less than 0.10 percent
of the total adhesive composition.
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3.3.1.3.2. Pressure-sensitive carpet adhesive
Pressure-sensitive carpet adhesives are used primarily for the installation of carpet
squares and for adhering carpet pad to the subfloor in double-stick installations. Most of the
manufacturers producing multipurpose adhesives also produce this type of product. These
products do not have the grade classifications associated with multipurpose adhesives.
The principal ingredient in pressure-sensitive carpet adhesives is a pressure-sensitive
polymer latex derived from acrylic ester copolymer. Comonomers may include styrene,
vinyl acetate, ethylene, etc. Typical modification includes viscosity adjustment with the
same type of viscosity modifier discussed above and the incorporation of a freeze-thaw
additive. A tackifying resin emulsion may also be included. Preservatives are used in these
products.
3.3.1.3.3. VOC ranges in adhesive components
Table 3-3 presents a table of the VOC content of the various components of adhesive
and the approximate percentage amount of each component in adhesive products.
3.3.2. Use of Adhesives During Carpet Installation
3.3.2.1. Multipurpose Adhesives
Installation of broadloom carpet with adhesive begins by laying out the carpet and
rough cutting to the area dimensions. The carpet is then folded back into 1/2 carpet widths
and the adhesive spread over the exposed subfloor at the recommended rate.
When the spread adhesive begins to feel "tacky" to the touch, the carpet is unfolded
into the adhesive, the other carpet folded back, the process repeated. Smoothing and rolling
of the carpet completes the installation with the exception of any seaming that must be done
and trimming the excess carpet at the wall.
In very large areas, several breadths of carpet may be installed. The installation crew
starts at the longest wall and follows the above procedure breadth by breadth.
Multipurpose adhesives "cure" by dissipation of the vehicle either by absorption into
the substrate or evaporation through the carpet. The rate of evaporation is controlled by the
type of substrate, the carpet construction, temperature, humidity, and ventilation. Generally,
90 to 95 percent of the ultimate strength of the adhesive is obtained after 24 hours and is
usually completely "cured" within 7 days.
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TABLE 3-3
ADHESIVE COMPONENTS AND ASSOCIATED VOC RANGES
MATERIALS
Vehicle
Binder
Fillers/Extenders
Resins
Process Oil
Freeze-Thaw Stabilizers
Viscosity Modifier
Preservatives
RANGE OF VOC
IN COMPONENT
0-10%
0
100%
0-3%
0-100%
AMOUNT OF COMPONENT
IN ADHESIVE
30-55%
5-15%
20-30%
5-15%
5-15%
1-5%
<0.5%
Source: C. Cline, Para-Chem Southern, Inc. Letter to Ward Penberthy, U.S. Environmental
Protection Agency, July 3, 1991.
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Adhesive installation of carpet should be done only in well ventilated areas. The
Carpet and Rug Institute's Bulletin CRI-104 stresses proper ventilation and details by which
to achieve it. (See section 3.6.)
3.3.2.2. Pressure-Sensitive Adhesive
Carpet squares or modules are usually set in a bed of pressure-sensitive adhesive. A
thin film of the adhesive is troweled, rolled, or sprayed on the substrate and allowed to dry.
This requires 30 minutes to an hour depending on the temperature, humidity, and ventilation.
The squares are then placed into position.
The advantage of this type of installation is that individual squares can be removed
and repositioned without the need for additional adhesive. Wiring ducts or terminals in the
floor or occasional damage to the carpet makes this installation attractive in offices or other
commercial buildings.
A recent innovation is the installation of broadloom carpet over pad with adhesives.
In this case, the carpet pad is adhered to the subfloor with a pressure-sensitive adhesive and
the broadloom carpet adhered to the pad with a multipurpose-type adhesive as described
above.
3.3.3. VOC Reductions Already Achieved
During the last 10-15 years, there have been many major advances to provide safer,
less hazardous and less VOC-emitting floor covering adhesives. The initial advancements
were in response to reducing the flammability of these products. This was done by replacing
the flammable solvents with either nonflammable chlorinated solvents or with water/solvent
blends containing a lower VOC content. Although the non flammable chlorinated solvents
did not reduce VOC content, they were preferred over the water/solvent blends because they
performed more like the solvent-based adhesives favored by customers. The nonflammable
chlorinated solvent-based adhesives provided a useful transition between the fast setting,
flammable solvent-based adhesives and the less aggressive, slower setting, water-based
adhesives which did provide a lower VOC content. It also gave the adhesives industry the
time necessary to develop water-based adhesives with performance more similar to solvent-
based adhesives, while at the same time allowing customers to adjust to this change in
technology. As this change reduced the fire hazards associated with floor covering
adhesives, the need to reduce solvent levels and eliminate the problem of indoor air
emissions became the next priority.
Today, most floor covering adhesives for the installation of carpeting are high solids
(50 to 65 percent), nonflammable, water/solvent blends. With time, testing, and research,
the solvent blends have dropped significantly over the past 5-7 years from levels averaging 8
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to 12 percent to current levels of less than 5 percent without significantly affecting the
performance of these materials. Further reduction/elimination of solvents will be costly and
time consuming but necessary in order to further reduce indoor air emissions. The
challenges facing the adhesives industry lie not only in further reducing solvent levels but
also in improving adhesive performance without the use of solvents to meet the installation
needs of today's carpet backings.
Other responsible adhesive changes and advancements made recently are as follows:
Developed latex-based carpet pad adhesives to reduce the need for solvent
containing pad adhesives;
Developed water-based pressure sensitive adhesives for the releasable installation
of carpet tile;
Developed high solids, latex-based adhesives. This reduces the amount of solvent
needed.
Some limited data were provided to the Carpet Policy Dialogue by the Carpet and
Rug Institute. These data should not be considered broadly representative of carpet adhesive
TVOC emission rates. The measurements reported" were:
Sample TVOC Emission Rate (mg/m* hr)
24 hr 144 hr
Multipurpose Latex 90.0 11.9
Multipurpose Latex 76.6 3.95
Multipurpose Latex 99.0 17.2
Synthetic, "Low VOC" 0.698 0.076
Data are extracted from "Volatile Organic Compound Emissions from Carpet and
Associated Products," by Marilyn S. Black et al., January 8, 1991.
Due to the varied manufacturing complexities and raw material choices available
today, it is extremely difficult to list and subsequently regulate individual VOCs. Therefore,
regulatory agencies such as the South Coast Air Quality Management District (SCAQMD),
have adopted rules governing TVOC.
Prior to 1990, the majority of floor covering adhesives used to install carpet were at a
calculated VOC of 150 g/1 or higher. However, with the pressure of Rule 1168 of the
California South Coast Air Quality District, all of the manufacturers reformulated to
calculated VOC of 150 g/1 or lower. By September 1990, one manufacturer introduced a
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new generation adhesive with a calculated VOC of 0 g/1. By February 1991, eight
manufacturers reported they had developed solvent-free, low emission adhesives. At the
NAFCD Convention, held May 5-8, 1991, 14 of the 15 adhesive manufacturers who had
booths displayed a low emission adhesive or a line of low emission products. According to
the FCAMC, the adhesives industry has already committed to meeting the SCAQMD VOC
limits for carpet adhesives on a nationwide basis.
A survey was taken in February of 1991 asking manufacturers to report on the range
of calculated VOCs in the products they were making by product type current formulas
versus new generation formulas. The responses ranged from 40 g/1 to 150 g/1 on current
formula lines and 0 g/1 to 20 g/1 on new generation lines. Figures 3-3 and 3-4 indicate VOC
levels in multi-purpose and pressure-sensitive adhesives, respectively, for various adhesive
manufacturers.
3.3.4. Potential VOC Reduction Methods
While the industry has already obtained significant VOC reductions in adhesives, the
very low TVOC adhesive products have not gained total acceptance in the marketplace. The
capability exists to produce adhesives with nearly no VOC, but the performance
characteristics are not as yet fully acceptable. The most noticeable performance deficiency is
adhesion development during installation. Ultimate adhesion with the newer products is
considered satisfactory.
To reduce VOCs, the industry is or will be examining SB latexes, resins, freeze-thaw
additives, processing oils, and viscosity control additives. Certain solvents could be replaced
with water with similar final bond results. The current freeze thaw level is -15°F, but the
industry may be able to shift this level to a higher temperature, such as 0°F. However,
according to the FCAMC, few manufacturers would give up freeze-thaw capability, as it
would be very easy to lose truckloads of adhesives in cold weather, and users may neglect to
store adhesives in a nonfreeze location. The performance need and demand by installers for
quicker grabbing adhesives has made it difficult for the adhesives manufacturing industry to
move as quickly as it could to sell reduced VOC adhesives.
The cost of reduced VOC raw materials must also be balanced with performance and
the benefit gained in TVOC reduction. As producers of the raw materials attempt to reduce
VOCs, their processing costs are likely to increase, resulting in an increase in the cost of the
raw material and hence the adhesive with only marginal reduction in TVOC of the finished
adhesive.
3-28
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3.3.5. Process Engineering Subgroup Proceedings
At the September 26, 1990, Process Engineering Subgroup meeting, the FCAMC
presented an overview of the carpet adhesives market and product formulations. Additional
information on the carpet adhesives manufacturing/formulation processes was presented to
the Subgroup at the October 24, 1990, meeting. These two presentations provided the basis
for a chapter of the Summary Report on adhesives manufacturing and Subgroup discussions
of this topic.
Comments on this chapter were discussed by the Subgroup at the April 8, 1991,
Subgroup meeting. The Subgroup expressed interest in the identification of specific
chemicals which contribute most to TVOC levels in adhesive formulations as well as their
concentrations in carpet adhesives. At the May 12, 1991, Subgroup meeting, the FCAMC
responded to the Subgroup's request by presenting company-by-company TVOC levels in
various types of adhesive formulations and products.
The Subgroup also discussed briefly the feasibility of raising the industry freeze-thaw
standard from -15° to 0°F, and whether this could be a viable TVOC reduction strategy. The
Subgroup discussed this idea as a possible recommendation to the Plenary. FCAMC
commented that the industry freeze-thaw standard might not be lowered any further. It was
suggested that, as an alternative, an investigation into the feasibility of alternative freeze-thaw
agents that could reduce adhesive TVOC be conducted. The Subgroup later agreed to make
this suggestion a research item for future consideration of FJPA or industry. The main
freeze-thaw agent additives currently in use are ethylene glycol and methyl alcohol which are
VOCs.
It was suggested that existing data on TVOC levels in adhesives and the adhesives
manufacturers' efforts to comply with the SCAQMD standard of 150 g/1 of TVOC in
adhesive formulations should be included in the Summary Report. Information was provided
to the Subgroup by FCAMC and is included in this Summary Report. The role of viscosity
control agents and preservatives as a source of VOCs in adhesive formulations was also
discussed on a limited basis. The Subgroup considered making a recommendation to the
Plenary to reduce the VOC contribution from these potential sources. These
information/research considerations and Subgroup recommendations are cited in detail in
sections 3.3.6 and 3.3.7 below.
3.3.6. Information and Research Considerations
The following ideas were raised by some members of the Subgroup considering
information that may help in identifying control measures to reduce TVOC. The suggestions
do not necessarily represent the consensus of the Subgroup. These are presented as
suggestions for future consideration of EPA or industry.
3-31
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1. An investigation into the contribution of 4-phenylcyclohexene from adhesive
formulation to TVOC emission rates after carpet system installation.
2. An investigation into the feasibility of alternative freeze-thaw agents that could
reduce adhesive TVOC.
3.3.7. Subgroup Recommendation to Plenary
1. The Plenary should encourage the Floor Covering Adhesives Manufacturers
Committee to advise the manufacturers to continue their search for low TVOC
freeze-thaw agents, viscosity control agents, and preservatives.
3.4. CARPET CUSHION MANUFACTURING PROCESS DESCRIPTION
3.4.1. Process Description
This section presents an overview of the carpet cushion manufacturing process for
five cushion products. A great majority of the information presented in this section was
supplied to the Process Engineering Subgroup of the Policy Dialogue by the Carpet Cushion
Council (CCC).
The carpet cushion industry is made up of 35 manufacturers. Sixteen of these
manufacturers are part of the Carpet Cushion Council, which represents 75 percent of the
carpet cushion produced.
There are five different types of carpet cushion, each having different shares of the
market:
Bonded Urethane 56%
Prime Polyurethane 33%
Rubber 6%
Synthetic Fiber 3%
Rubberized Jute 2%
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3.4.1.1. Prime Urethane Foam Carpet Cushion
The following description of the raw materials and the manufacturing process for
flexible prime urethane foam carpet cushion is general in nature and is intended to provide a
broad overview of the process. It is not intended to be a definitive technical treatise, but
rather to provide a general understanding of the manufacturing process.
Flexible urethane is used as a principal part of many products serving many markets,
a few of which are the furniture, bedding, automotive and textile markets. The same
manufacturing process is common to the manufacture of almost all of these products
including carpet cushion. Prime urethane carpet cushion represents 33 percent of total U.S.
carpet cushion manufacture.
Raw Materials
There are four principal raw materials used in the manufacture of prime urethane
foam carpet cushion: polyol, TDI, water and laminating film. The predominant raw
materials are polyol, TDI, and water, which make up about 95 percent of the finished
product.
Polyol is a chemical derived from propylene oxide. TDI, or toluene diisocyanate, is
reacted with polyol and water to form flexible polyurethane foam. Small amounts of
catalysts, surfactant, and possibly auxiliary foaming agents are also added to cause the
mixture to rise once the reaction starts. (See Table 3-4.)
Laminating film is used as a coating on most prime urethane carpet cushion products
to make it easier for the carpet to slide over the cushion during installation. It is used on
only one side of the cushion and is applied at the very end of the manufacturing process.
Laminating film is a very thin coating of polyurethane polymer or a combination of
polyethylene and ethylene acrylic acid or sometimes etnylene vinyl acetate polymers.
Laminating films account for 1 or 2 percent of the weight of carpet cushion.
Manufacturing Process
Most flexible polyurethane foams are manufactured in a continuous process from the
reaction of the diisocyanate, water and the polyol. The reaction occurs by the addition of the
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TABLE 3-4
PRIME URETHANE FOAM CARPET CUSHION
COMPONENTS AND TYPICAL RAW MATERIALS'
RELATIVE AMOUNTS
USED WITHIN
COMPONENT TYPICAL MATERIALS INDUSTRY
Diisocyante Toluene diisocyanate (TDI) 90%
Methylenebis(phenylisocyanate) 10%
(MDI)
Polyol Polyether >90%
Water Water 100%
Catalyst Tertiary amines 67%
Stannous octoate 33 %
Surfactant Polysiloxanepolyester glycols
Blowing Agents CFCs
Methylene chloride
Methyl chloroform
1 Data obtained from Bruce Ernst, Marketing Manager, Flexible Slabstock Polyurethane Foam, APCI, Trexlertown
(Allentown), Pennsylvania, March 25, 1991.
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alcohol bond of the polyol to the nitrogen-carbon isocyanate bond to form a carbamate or
urethane as follows:
M.C.O
N.C.O
CM,
HO--CHCM-0--
CM,
CHCHj- OH
0
0C n
0
CH-
1-fCHCH~<
The water added in the process reacts to form carbon dioxide (COj) and a substituted
urea.
N.C-0
N.C-0
N«C-0
CO,
The diisocyante formed can further react with polyol to become part of the polymer.
The polymerization reaction takes place in the presence of a blowing agent. A
common blowing agent used in the past has been CFC-11. Flexible urethane foams have
open cells that release the blowing agent during foam formation. No information on residual
amounts of the blowing agent in manufactured prime urethane foams was made available to
the dialogue.
Most flexible prime urethane foam manufacturing today brings the principal
ingredients of polyol, TDI, water and other chemicals together in a mixing head at a point
just ahead of a trough about 6-feet wide and 3- to 4-feet high. A conveyor trough about 60-
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feet long, lined with a special release paper, bottom and sides, moves the mixture along as
the foaming process takes place. The initial few feet of the trough contains complex
geometry pertinent to the speed and type of reaction which will take place. The mixing head
meters the chemicals in a precise manner and distributes the mixture evenly across the front
of the trough. As the reaction takes place, the liquid mixture forms a cellular structure
which rises to a height of 3 to 4 feet depending on the product being produced.
Flexible prime urethane foam is produced by two main processes: slabstock and
molded. There are an estimated 105 facilities operated by 47 firms producing flexible
polyurethane slabstock, which is the source of prime urethane foams in carpet cushion, and
39 facilities operated by 28 firms which produce flexible polyurethane molded foam.
Flexible slabstock foam facilities typically operate less than 4 hours per day, while flexible
molded foam facilities operate from 8 to 24 hours-per-day. Both types of facilities typically
operate 250 days-per-year.
Slabstock-Figure 3-5 presents a process flow diagram for the production of slabstock
foam. Flexible foam slabstock is produced primarily by the "one-shot" process, where the
foam is in a bun or a loaf. For this continuous process, the polyol, polyisocyanate, water,
and auxiliary blowing agent are pumped from pressurized storage tanks, through heat
exchangers, and to a multiple stream metering and mixing head. The foam mixture is then
poured onto a continuously moving conveyor belt where it expands to fill the foam tunnel.
Most foam machines use "trough dispensing" where the liquid foam mixture is dispensed into
a trough at the front end of the conveyor. This type of foam injection applies a more evenly
spread liquid onto the conveyor resulting in a more rectangular slab requiring less trimming
waste. Once the foam travels through the foam tunnel, a bun is cut off of the slab which is
cured and stored until it is sold.
The process is continuous. Depending on the type of finishing machinery available,
the reacted foam product, or "bun", keeps coming out of the end of the foaming machine and
can reach a length of 200 feet before it is cut and moved to a storage area for curing and
cooling. Since the reaction is exothermic, heat keeps building in the "bun" after it has been
stored, and it can take 1 to 2 days before the reaction is complete and the "bun" is ready for
the next operation.
After curing, many "buns" are cut into short lengths and shipped to fabricators for
use in other industries. "Buns" for carpet cushion must be slit into proper thickness for
finished product. In general, there are two types of slitters: horizontal and circular:
1) Horizontal - The horizontal slitter is usually a reciprocating table which places a
slab 60 feet in length on the slitter table and slits carpet cushion in finished lengths for
transfer to laminating.
2) Circular - The circular slitter, or "Baumer Loop" is a spectacular piece of
equipment which looks like a ferns wheel. A 200-foot "bun" is placed in this machine
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3-37
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where it is fed around the loop until the front and back ends meet, where they are cemented
together to form a complete circle. The machine then starts rotating around a fixed blade
which slits a predetermined thickness and creates master rolls of carpet cushion for transfer
to laminating.
Laminating film measuring .7 to 1 mil in thickness is placed on a roll in a laminator,
and fed on top of the prime urethane foam carpet cushion coming from another roll. A
heated cylinder applies pressure and fuses the laminating film to the surface of the prime
urethane foam carpet cushion which is being rolled up, cut into 60-foot finished lengths and
loaded into a polyethylene bag for transfer to a finished goods warehouse. Sometimes a spun
bonded nylon or polyester non-woven scrim is placed in a similar manner to the top of the
prime carpet cushion to give it a more durable surface. In this case the polyethylene film
which is placed between the scrim and the cushion acts as a fusing agent.
3.4.1.2. Bonded Urethane Carpet Cushion
Bonded urethane carpet cushion manufacturing represents approximately 56 percent of
the total 605 million-square-yards of carpet cushion produced in the United States.
Raw Materials
There are three raw materials used in the manufacture of bonded urethane carpet
cushion: scrap polyurethane foam, prepolymer and laminating film. The raw material, scrap
polyurethane, accounts for approximately 90 percent of the weight of bonded carpet cushion.
Table 3-5 presents approximate percentages for the raw material composition of bonded
urethane carpet cushion and other carpet cushion types.
Scrap polyurethane foam conies from leftover material from the fabrication of flexible
polyurethane foam parts destined for use in other industries. While there are many uses for
flexible polyurethane foam, the principal markets are:
a) The upholstered furniture market for use in sofas and chairs;
b) The bedding market for use in mattresses;
c) The automotive market for use in door panels, seat cushions, padded sun visors
and headliners;
d) The prime urethane foam carpet cushion market; and
e) The textile and clothing market for use as liners and insulators.
Between 400- and 50-million pounds of scrap polyurethane foam are gathered annually from
all over the world from the fabrication of products for the above markets. It is compressed,
baled and transported to about 30 factories throughout the United States, where it is
converted into bonded urethane carpet cushion making it one of the largest uses of reused
materials in the world.
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TABLE 3-5
RAW MATERIALS OF CARPET CUSHION - RANKED IN ORDER OF USE
Percentage By Weight in Product
Bonded Urethane
Scrap Polyurethane 90%
Binder
Polyol 7%
TD1 (or TDI/MDI Mixture) 3%
Prime Polvurethane
Polyol 69%
TDI 27%
Water 2%
Other chemicals in varying quantities 2%
Catalysts
Surfactants (e.g., silicones)
Fire Retardants (e.g., phosphate esters)
Pigments
Rubber
Whiting (calcium carbonate) 60%
Rubber (natural or synthetic) 25 %
Other processing chemicals in varying quantities 15%
Plasticizers (e.g., stearic Acid)
Fire Retardant (e.g., aluminum trihydrate)
Viscosity reducers (e.g., process oil, tall oil)
Antioxidants (e.g., zinc oxide, sodium bicarbonate)
Vulcanizing Agents (e.g., sulfur)
Accelerators and other chemicals (MET, MBTS,
TMTD, methyl zymate, BK, Celogen OT)
Synthetic Fiber
Waste synthetic carpet fiber 90%
Fire Retardant (aluminum trihydrate) 5%
Carrier (polyprolylene mesh) 5%
Resin (at times) up to 10%
Rubberized Jute
Jute, bagging and shredded carpet strips 85%
Fire Retardant (e.g., aluminum trihydrate) 5%
SBR Rubber latex coating 7%
Carrier (Polypropylene mesh) 3 %
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Prepolymer, which makes up about 8 to 9 percent of the weight of bonded urethane
carpet cushion, is made from two chemicals: Polyol and TDI (or a mixture of TDI and
MDI). It is the bonding agent for bonded urethane carpet cushion and is made from the
same two chemicals that are the principal raw materials for the flexible polyurethane foam
products from which the scrap itself is made.
Laminating film is used as a coating on most bonded products to make it easier for
the carpet to slide over the cushion during installation and to add tensile strength. It is used
on only one side of the cushion and is applied at the very end of the manufacturing process.
Laminating film is a very thin coating of polyethylene polymer or a combination of
polyethylene and ethylene acrylic acid or sometimes ethylene vinyl acetate polymers.
Laminating films account for 1 or 2 percent of the weight of carpet cushion.
Manufacturing Process
Scrap is received from vendors in a compressed, baled state. It is first released from
the bales and then put into a shredder and grinder which reduces the scrap to pieces ranging
from 1/4 inch to 1 inch depending upon the characteristics desired in the end product. It is
then fed into a blender where it is mixed with the prepolymer.
Prepolymer, made from polyol and TDI (or TDI and MDI), is premixed and stored in
tanks at the plant site. It is piped to the blender where it is mixed with the polyurethane
foam scrap just prior to entry into the bonding mold.
Although there are two types of manufacturing processes, Box Type and Cylinder
Type, from which bonded urethane carpet cushion is produced, both use the same casting
concept. In the Box Type process, the blend of scrap and prepolymer is fed into a
rectangular steel box measuring about 6 feet by 10 feet, to a height of 30 to 48 inches
depending on the density required. A platen of the same dimensions is lowered on top of the
mixture compressing it to about 24 inches in height. Casting is accomplished by injecting a
catalyst to start the bonding reaction. Water is the catalyst. In most operations water is
injected in the form of steam, although some plants inject it in its liquid state. The catalyst
starts the reaction between the polyol and the TDI in the prepolymer accomplishing the
bonding process. Since the reaction is exothermic, a considerable amount of heat is created.
This takes about 10 minutes. After that time, the bonded block is released from the box and
stored for cooling and drying for removal of excess moisture, which takes several hours
depending on the ambient temperature and humidity. Six blocks are placed end to end and
cemented together to form a slab 6 feet wide and 60 feet long. It is then placed in a
horizontal slitter where rolls of carpet cushion are produced, rolled up and staged for
laminating.
In the Cylinder Type process, the blend of scrap and prepolymer is fed into a cylinder
measuring up to 5 feet in diameter and standing between 10- and 15-feet high permitting
scrap to be loaded freely. After loading the blend, a circular platen of the same diameter is
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lowered on top of the blend compressing it to about 6 feet in height. The bonding reaction is
accomplished in the same way as in the Box type process. After cooling, the cylindrical
block is turned on its side, cored and placed on a rotating cutting machine which peels the
cylinder in the thickness required for the finished carpet cushion. It is then rolled up and
staged for laminating.
Laminating film measuring from .7 to 1 mil in thickness is placed on a roll and
placed on top of the carpet cushion coming from another roll. A heated cylinder applies
pressure and fuses the laminating film to the surface of the bonded urethane carpet cushion
which is being rolled up, cut into 60-foot finished lengths and loaded into a polyurethane
shipping bag for transfer to a finished goods warehouse. Sometimes a polypropylene netting
is placed between the laminating film and the carpet cushion to add abrasion resistance and
tensile strength.
3.4.1.3. Cellular Sponge Rubber Carpet Cushion
Sponge rubber is by definition an elastic porous mass with interconnecting cells
obtained by compounding with gas releasing materials which react prior to vulcanization,
thus providing the structure from which its name is derived. There are only three
manufacturers of sponge rubber carpet cushion in the United States today and the product
makes up about 6 percent of the market.
Raw Materials
There are two principal raw materials in cellular sponge rubber carpet cushion -
rubber and filler. Together these raw materials make up about 85 percent of the product.
The balance is made up of various accelerators, blowing agents, plasticizers, anti-oxidants
and other chemicals which are critical to the vulcanization process.
The rubber used in the manufacturing of sponge rubber carpet cushion is either
natural rubber from the plantations in Southeast Asia, Nigeria, and South America, or
synthetic rubber made from styrene and butadiene developed by our rubber tire companies
during World War n. Both are rubber hydrocarbon resins and arrive at manufacturing plants
in solid form packaged in bales from the producers. Rubber hydrocarbon makes up between
20 to 25 percent of the finished carpet cushion product.
By far the most widely used filler is whiting (limestone) from large deposits in the
southern and southwestern United States and from smaller limestone deposits all over the
country. This inert mineral makes up about 60 to 65 percent of the finished carpet cushion
product. In order to meet certain flammability requirements, some of the whiting may be
replaced by hydrated aluminum oxide.
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Manufacturing Process
In order to be introduced into the forming line, a rubber compound must first be
processed into a thin film. Most forming lines or "ranges" in the industry are 9-feet wide,
although some are 54 inches. Getting the rubber compound into a thin film 9-feet wide is a
complicated process.
It starts with the rubber resin arriving at the plant in a bale. Even though rubber is a
solid, it is usually packed in polyethylene bags before baling to keep the bales separate and
also to keep them from flowing if extremely bad weather is encountered during the long
ocean trip.
The manufacture of rubber carpet cushion is an energy intensive process. Bales are
broken up in a guillotine type cutter and sent to large banbury mixers to start the
compounding process. The rubber resin must be thoroughly mixed with the filler and other
chemicals in order to assure uniformity and proper viscosity before going to the next step in
the process. Banbury mixers require a lot of horsepower to break up the resin bales and mix
them with fillers and other chemicals.
Motors as large as 600 horsepower are not unusual in this phase of the process.
Resin, chemicals and fillers are precisely measured before being sent to the banbury. In
order to reduce viscosity, plasticizers are introduced also at this point in the form of
petroleum or organic oils.
Proportions and types of chemical ingredients which are used in the process are
proprietary and are carefully protected trade secrets.
From the banburies, rubber compounds are sent to primary and secondary calendars
which take the compounds and gradually reduce the mixture into a thin rubber film. This
film is then placed on a moving steel belt which is shaped in the form of a grid. The steel
belt carries the rubber film into the "range" which is a vulcanizing oven about 100- to 120-
feet long. Heat activates the blowing agents which chemically expand the rubber into the
grid to form the rippled appearance of the finished product. The heat in the range rises to
about 450°F which finally vulcanizes the whole sheet.
At the end of the "range", a very thin scrim made of spun bonded nylon or polyester
is placed on top of the rippled surface while the rubber is still hot. This scrim provides
dimensional stability to the carpet cushion as well as making it smooth so that carpet may be
easily spread over it during carpet installation.
After the scrim has been applied to the cushion, it goes into an accumulator and then
to a roll-up machine where the 9-feet wide carpet cushion is slit into 54-inch widths and cut
to length. It is then placed into a polyethylene bag and sent to a warehouse for storage.
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3.4.1.4. Rubberized Jute Carpet Cushion
Rubberized jute or hair and jute carpet cushion is the oldest type of carpet underlay
used in this country. It was introduced around the turn of the century and was originally a
product made strictly from cattle hair. Cattle hair was obtained as a byproduct of the leather
tanning process. Its great resilience and durability made it a natural product for carpet
underlay.
With the great growth of the carpet industry during the 1930s, 1940s, and 1950s,
carpet product far outstripped the availability of cattle hair and so a substitute was sought.
The jute plant was discovered to impart similar qualities. Hair carpet cushion gradually
became a mixture of more and more jute. The chemical tanning process, which dissolves
cattle hair, all but eliminated cattle hair from the market. Today, only one manufacturer
offers a hair underlay. That manufacturer and two others make a rubberized jute product
which comprises the bulk of the natural fiber market. At that, the natural fiber share of the
carpet cushion market is less than 2 percent.
Raw Materials
There are two principal raw materials which make up the bulk of rubberized jute
carpet cushion - jute and latex rubber. Jute, which is provided in three forms, makes up
between 85 to 90 percent of the product with latex rubber making up the balance. The
percentage of each which is blended into the product (jute cuttings, bagging, or carpet strips)
is a function of economics and availability at any given time.
Jute Cuttings - Jute is a fibrous plant that is grown in Bangladesh and Thailand. It is
harvested there and sent to India for processing and weaving into jute backing for carpet and
for burlap bags. In the harvesting process, the lower part of the plant, or jute butt, is
unsuitable for weaving and is baled and sent from Bangladesh and Thailand directly to the
United States for use in the carpet underlay market. Between 10,000 and 15,000 tons of this
product are consumed in this market annually.
Foreign and Domestic Bagging - Burlap bags are used for packaging products in all
parts of the world. After their use has been exhausted, these bags are collected and shipped
to the carpet cushion plants for reuse in rubberized jute carpet cushion.
Carpet Strips - Carpet which has been tufted into jute primary backing or which has a
jute secondary backing applied is edge cut prior to finishing. These strips are collected and
sent to carpet cushion plants for reuse in rubberized jute cushion. With most carpet being
tufted into synthetic primary and secondary backing today, carpet strips are less desirable as
a raw material than they once were since they are more difficult to shred and do not have the
resilience of jute. Nevertheless, they still provide bulk and make up about 10 percent of the
product.
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Between 10 and 15 percent of rubberized jute carpet cushion is made up of latex
rubber. This is a filled SBR latex which is applied as a coating on both sides of the jute
product to act as a sealer and to ease installation.
Manufacturing Process
Jute cutting, bagging, and carpet strips are received at the manufacturing sites in
bales. The bales are sent to a guillotine type cutter which breaks up the bales into small
pieces. The material is processed through opening equipment, such as a card willow and
pickers, and transported to rotary devices called garnets. Garnets separate and align fibers
into layers that are either air or mechanically laid onto a moving belt 12-feet wide, which
conveys them to a needlepunch loom.
A needlepunch loom is comprised of a board with needles spaced about 1/2-inch apart
which comes down through the web into a board with matching holes below the web. The
layers of fibers usually have a carrier which is introduced between the layers to make sure
the mass stays contiguous. This carrier is generally a polypropylene mesh with 1/4-inch or
1/2-inch spacing. The needlepunch press is about 12-feet wide. It holds a single needle
board about 12-inches deep which contains several thousand needles.
The web will go through at least two looms before the webbing is at the proper
thickness and density. After the webbing has been properly formed, it goes into a spray area
where the latex coating is applied, first one side and then the other. Usually about 2 to 3
ounces of latex per square yard are sprayed on each side. The web then passes over
embossing rolls which impart a pattern into the latex coating for customizing the finished
product.
After latexing, the product goes across an inspection table and into a roll-up machine
which cuts the product into a finished roll. Usually this roll is slit into two 6-foot widths,
although it may also be left in its full 12-foot width and then wrapped in either paper or
polyethylene. Finished rolls are transported to a warehouse for storage.
3.4.1.5. Synthetic Fiber Carpet Cushion
The synthetic fiber industry has grown at an extraordinary rate over the last three
decades. The use of synthetic fiber in the carpet industry alone has catapulted its
consumption to over 2-billion pounds annually just in the United States. Likewise, large
amounts of synthetic fiber are used in the manufacture of clothing and other textile products.
In these manufacturing processes, off-specification material is produced, sometimes in very
large quantities. Needlepunching it into a carpet cushion underlay is a natural end use.
Today, synthetic carpet cushion makes up 3 percent of the carpet cushion market.
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Raw Material
Almost 100 percent of synthetic fiber carpet cushion is made from off-specification
synthetic fiber. It is collected from fiber producers, spinners, dyers, and yarn producers
from all over the world. The fiber is baled and transported to about seven or eight synthetic
carpet cushion producers in the United States.
Manufacturing Process
Waste synthetic fiber is furnished in bales to the synthetic carpet cushion plants.
Bales are placed in breakers where the fiber is broken down into manageable portions and
then fed into garnets which separate the fibers and align them. A garnet has a number of
cylinders with wire teeth on them which perform the alignment process.
Fibers are then spread onto an apron by mechanical means in widths up to 12 feet.
Frequently, but not always, a woven polypropylene carrier is included with the web for
purposes of providing stability and strength to the product.
The apron carries the web to a needlepunch loom where the product is punched and
needled into itself. The needlepunch loom (greater than 12-feet wide) incorporates either a
single needle board or multiple needle boards. These boards are approximately 12-inches
deep and contain thousands of needles spaced in a specific needling pattern. The web may
go through one or more needling looms before the product is finished. In some
manufacturing processes where the fiber length is short, a resin binder may be used to
further bind the fiber web.
Packaging
The needled synthetic carpet cushion comes off the end of the line and is rolled up in
a paper wrapping, or placed in a polyethylene bag. It is usually split into two 6-foot widths,
but may also be left in its 12-foot width prior to wrapping. Finished rolls are then sent to a
warehouse for storage.
3.4.2. VOC Reductions Already Achieved
No specific actions that have resulted in carpet cushion VOC reductions have been
reported to the Carpet Policy Dialogue's Process Engineering Subgroup. Extremely limited
data (three small chamber emission rate measurements) on carpet cushions were supplied to
the Carpet Policy Dialogue by the Carpet and Rug Institute. These data should not be
considered broadly representative of carpet cushion TVOC emission rates. The
measurements reported were:
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Product TVOC Emission Rate Cmg/m2hr')
24 hr 144 hr
Polyurethane Rebond 0.123 0.059
Hair/Jute 0.240 0.012
Flat Rubber 3.36 8.11
* Data are extracted from "Volatile Organic Compound Emissions From Carpet and
Associated Products," by Marilyn S. Black and et al., January 8, 1991.
Clearly, more data are needed to better characterize carpet cushion TVOC emission rates.
3.4.3. Potential VOC Reduction Methods
No potential TVOC reduction methods were identified for carpet cushion
manufacturing by the Process Engineering Subgroup. The result does not indicate that
methods do not exist, but only there was insufficient technical information accessible to the
Subgroup for a meaningful review of possible TVOC reduction strategies.
3.4.4. Process Engineering Subgroup Proceedings
The Carpet Cushion Council (CCC) gave several presentations to the Process
Engineering Subgroup. At the September 26, 1990, Subgroup meeting, the CCC presented
an overview of the carpet cushion market, manufacturing processes of Bonded Carpet
Cushion and Prime Urethane Carpet Cushion. At the November 30, 1990, Subgroup
meeting, the CCC presented additional information on the manufacturing processes. At the
April 9, 1991, meeting the CCC presented information on the carpet cushion market and
potential methods of reducing VOCs from carpet cushion.
At the February 28, 1991, meeting, the Subgroup discussed the scrap materials used
to produce carpet cushion and the possible VOC contributions from these materials. Also
discussed were an overview of the raw materials used in the various processes and whether
some of the raw materials could be VOCs. Other issues discussed included the significance
of process steps and conditions such as the use of blowing agents, additives, and the
temperature and residence time of the curing process on VOC emissions. No definitive
recommendations were developed by the Subgroup.
The Subgroup discussed the possible availability of some Air Quality Science (AQS)
data on carpet cushion VOC emissions as well as the possible inclusion of these data in the
Carpet Manufacturing chapter of the Summary Report. These data are included in this
document. Also discussed were the feasibility of establishing standards for urethane scrap
3-46
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and whether industry efforts in reducing TVOC from carpet cushions should focus on
treating scrap or establishing raw materials scrap requirements.
It was suggested that the identification of raw materials which could be VOCs, as well
as specific additives and process variables that affect cushion VOCs for the various
manufacturing processes, could be useful information to include in the Summary Report.
At the May 21, 1991, Subgroup meeting, comments on the carpet cushion chapter of
the Summary Report were reviewed by the Subgroup. During that meeting, the Subgroup
made a recommendation to the Plenary to accept the CCC's proposals to form five task
forces to conduct TVOC reduction studies. The charge to the task forces is to examine
manufacturing processes of the respective carpet cushion types with the objective of reducing
TVOC in the finished products. These information/research considerations and
recommendations are cited in detail in sections 4.5 and 4.6 below.
3.4.5. Information and Research Considerations
The following ideas were raised by some members of the Subgroup considering
information that may help in identifying control measures to reduce TVOC. These
suggestions do not necessarily represent the consensus of the Subgroup. These are presented
as suggestions for future consideration of EPA or industry.
1. Development of a baseline data set that can be used to characterize TVOC
emission from carpet cushion.
2. An evaluation of the potential sources of TVOC and process variables that affect
cushion VOCs for the various manufacturing processes should be undertaken.
This evaluation should consider such questions as:
Bonded Carpet Cushion
a. Are blowing agents significant VOC sources? Are VOC blowing agents a
viable process change?
b. How do foam curing process conditions like temperature, pressure and
residence time impact carpet cushion residual TVOC?
c. Of the two casting processes, which process creates the most VOCs? What
are the percentages for industry's use of these two casting processes?
d. During box type casting, does the drying of the bonded block accelerate the
release of VOCs?
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e. Can scrap polyurethane be treated to remove TVOC before being converted to
bonded carpet cushion?
Prime Urethane Foam Carpet Cushion
a. Are blowing agents significant VOC sources? Are VOC blowing agents a
viable process change?
b. How do foam curing process conditions like temperature, pressure, and
residence time impact carpet cushion residual TVOC?
Cellular Sponge Rubber Carpet Cushion
a. A discussion on the effect of vulcanization process conditions like temperature,
curing time, and oven residence time on cushion TVOC emissions should be
included.
3.4.6. Subgroup Recommendations to Plenary
1. The Plenary should make a recommendation to the Agency to consider obtaining
an agreement from the Carpet Cushion Council to sponsor a monitoring program
which makes available to the public data on carpet cushion TVOC emissions.
This program should be conducted on an ongoing basis to demonstrate continued
product quality assurance. This monitoring program will be the same as the
testing program agreed to in the Testing Subgroup.
2. The Plenary should make a recommendation to the Agency to consider adopting
the Carpet Cushion Council's preliminary proposal to form five task forces of
technical and manufacturing personnel of each type of carpet cushion to study the
means by which TVOC can be reduced. The charge to each of these task forces
is to examine manufacturing processes of the respective carpet cushion types
within the constraints permitted by proprietary considerations with the objective of
reducing TVOC in the five generic cushion types taking into consideration, along
with other factors as may be identified by the task forces, suggestions made by
the Plenary in 4.5 above. Results will be reported to the EPA on a basis to be
determined.
3. The Plenary should make a recommendation to the Agency to consider obtaining
an agreement from the Carpet Cushion Council to solicit all carpet cushion
manufacturers for information concerning historical work done in reducing TVOC
from carpet cushion. Information regarding specific VOCs already available from
manufacturers or vendors will be used in the evaluation of the various
manufacturing processes by the task force groups.
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3.5. CARPET MANUFACTURING
3.5.1. Process Description
This section presents an overview of the carpet manufacturing process. A great
majority of this section was supplied to the Process Engineering Subgroup of the Carpet
Policy Dialogue by the Carpet and Rug Institute.
3.5.1.1. Carpet Face Fiber
The key to any discussion of modem carpet manufacturing is a close look at the fibers
used in the surface of the carpet. The face yarn or face fibers represent between 70 and 85
percent of the carpet cost and is, therefore, the single most important economic factor
affecting carpet costs. Additionally, the characteristics of today's fibers, in many cases,
dramatically affect the manner in which carpet will perform when placed into service.
Within the United States, where approximately 46 percent of all carpet is
manufactured worldwide; the manmade fiber, nylon, is the most important product for use in
carpet. Historically, wool was the important fiber in the carpet industry, but as the market
exploded in growth from 1960 onward, it was impossible for this natural fiber to compete
economically or for it to be processed readily through some of the more modern
manufacturing equipment. To clearly understand the role of face fiber in carpet, a brief
analysis of the various fiber types used for the manufacture of carpet in the United States is
presented.
Nylon
Around 1955, nylon staple fiber which previously had been used in blends of wool
and acrylic, was used to produce early nylon staple carpet. It was during this time that loop
pile styling was predominant in the United States. It was quickly determined that with the
spinning systems available at that time, woolen spun nylon did not produce acceptable loop
pile carpet. The problem was associated with pilling and fuzzing.
In 1956 - 1957, initial experiments were made with long staple spinning of staple
nylon to see if the pilling and fuzzing problems could be overcome. This problem was
alleviated to some degree, but by 1958, Du Pont had internally developed the first bulked
continuous filament (BCF) nylon for carpet, Nylon BCF, in combination with the tufting
machine, began what could be described as an "industrial revolution" in itself. Although
there were initial problems associated with yarn streaking and processing, Du Pont, and later
the other major fiber manufacturers, produced BCF nylon yarns which created an entirely
new carpet industry. Bulked continuous filament nylon can be received by the tufted carpet
manufacturer directly from the fiber producer and rapidly processed into white carpet (called
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greige goods). It can then be dyed, one or more rolls at a time, to produce exactly the
number of rolls of the correct color required by the marketing department. This is a far
more rapid turnaround of raw materials, and hence money, as opposed to the old stock dyed
processing required for wool fiber. In the case of wool, the carpet manufacturer first buys
the fiber, which then must be sent to the dye company and then to the spinning company or
division within the major corporations prior to obtaining the fiber in "yarn form", for tufting
and weaving. In order to dye and process by this technique, relatively large amounts of
material had to be produced in one color at one time, resulting in not only expensive
processing, but in high inventories of colored carpet which might not be selling at that time.
Following rapidly on the heel of BCF nylon, staple nylon became more interesting to
the carpet manufacturers who developed a new and different spinning system. This spinning
system, the modified worsted or parallel spinning system, was more economical, but the new
system allowed for the production of 7-inch or longer staple yarns which performed better in
the carpet being produced.
Polyester
In the early 1960s, polyester was introduced into the carpet industry. It was during
this time that polyester/cotton had become a standard household world because of the easy
care fabrics so popular at that time. Polyester, as a carpet fiber, was introduced to the
carpet consumer as an easy care material, much like the clothing material the consumer was
accustomed to using. Polyester also had the advantage of long staple processing which had
been developed primarily for nylon.
Polypropylene
Immediately prior to 1960, polypropylene was similar to nylon in many ways with the
exception that it was not possible to piece dye the fiber. This meant that there were greater
limitations in color choice for the ultimate consumer.
Polypropylene's accelerated growth into the carpet industry came with the
development of indoor/outdoor carpet. Indoor/outdoor carpet was initially a needlepunch
product, but when the true outdoor synthetic grass carpet was made using polypropylene
ribbon yarns, then polypropylene began an accelerated growth within the market.
Polypropylene is a by-product of the oil refining business, and the technology
associated with the extrusion of polypropylene is considerably less difficult than the
technology for extruding nylon.
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Wool
Wool was originally the important fiber used for carpet, not only in the United States,
but also worldwide. Authorities differ in their estimates by several hundred years, but wool
carpet was produced at least as early as the 14th century.
Although wool represents only about 1 percent of the fiber used to produce carpet in
the United States, it is still the most prestigious of fibers. One of the primary reasons wool
no longer dominates the market is the simple fact that it would be impossible for all carpet
throughout the world to be made from wool because of insufficient production of wool
worldwide. Not all wool can be used in carpet. Surprisingly, Australia, recognized as one
of the major wool producing areas of the world, does not produce any wool for use in carpet
applications. The major production areas for this type of wool today are New Zealand,
Argentina, and China. However, if all the production from these countries and other
countries that produce wool for carpet was shipped to the United States, the 20 largest carpet
manufacturers in this country alone would have produced more square yards of carpet in
1986 than could have been produced from all this wool available. This type of demand
would cause a shortage of wool which would in turn skyrocket the price, deter the growth of
the carpet industry, and prevent growth in carpet wools.
3.5.1,2. Carpet Yarn Manufacturing
Since the carpet yarn manufacturing process may be considered a mechanical/physical
operation with no chemical applications, no process details or information are included in this
report which has been prepared for distribution to the EPA Carpet Dialogue Group.
3.5.1.3. Carpet Coloration
Basically dyeing techniques can be divided into two major categories. First there is
pre-dyeing, which is the technique used to dye the loose fiber or the yarn before the carpet is
manufactured. Post-dyeing is the technique whereby the carpet is dyed after it has been
produced. This latter method offers considerable advantages to the carpet manufacturer in
that it allows for longer color line choices to be made available to the consumer without
additional large inventory costs.
3.5.1.3.1. Pre-dye systems
Solution Dyeing
Solution dyeing represents approximately 10 percent of the carpet market's dye
systems. Solution dyeing is the addition of color pigments to the molten polymer prior to
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extruding the fiber. Pigments can be added to the polymer at a number of stages during the
manufacturing process. These pigments are either inorganic or metallized-organic
compounds and, as far as color is concerned, they simulate paint coloring products in that the
pigments are highly colored microscopic particles, and they are suspended within the fiber
polymer. Choice of pigments must be carefully made. Items of importance include:
Particle size - uniformity and dispersibility;
Sunlight resistance;
Resistance to gas fumes;
Resistance to ozone; and
Compatibility with the polymer.
Stock Dyeing
Stock dyeing involves taking cut staple fiber, packing it into a kettle, and then forcing
dye liquor through the "pack" and recirculating the liquor as temperature is increased to the
maximum. The dyeing continues until the dyestuff has completely exhausted from the bath
onto the fiber.
Stock dye kettles come in two types, atmospheric and pressure. In the first, dyeing is
done at or close to the boil; in the second, pressure is adjusted to increase dyeability but not
enough to cause tendering or damage to the fiber involved. Since wool fiber represent by far
the most used stock dyed fiber for carpet, the great majority of stock dyeing is atmospheric.
However, when dyeing polyester and occasionally nylon, where high pressures do not affect
the fiber and where high pressures can significantly accelerate the dyeing, pressure dyeing
units are used. In particular, when dyeing polyester, the use of a pressure unit makes it
unnecessary to use dye assist chemicals to achieve the darker colors.
Most stock dyeing kettles range from 200- to 1000-pound capacity. They are fed from
a circulating tank equipped with a centrifugal pump and the fiber pack is encapsulated in the
kettle in a manner that allows uniform flow through the fiber pack with a minimum of
"channeling" of the dye liquor.
After dyeing, the residual liquor is drained and the fiber is thoroughly rinsed while
still in the kettle. At this point, an afterscour or hydroscour can be applied to minimize
cracking or bleeding of the dyed fiber and in the final bath an application of softeners or
finish is made to the fiber to facilitate yarn spinning.
The dyed fiber is then removed from the kettle and placed into a centrifuge to remove
excess water. It is then dried in an oven on an endless belt or rotating drum type dryer. It
is also possible to finish the dyed staple on a continuous line, where an endless belt feeds
into an air blower-conveyer system and then directly on to a baling operation.
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Different fibers require different dyestuffs and the dyes and chemicals involved in
each dyeing vary considerably. However, general information is available from all the
dyestuff suppliers who will supply formulations and dye recommendations along with the
performance testing of the resultant dyed product. A typical general formula and procedure
for stock dyeing wool and nylon follows:
Wool
Prescour to remove oil, dirt, etc.
2-4% Scouring Agents (Non-Ionic surfactant)
4-6% Bleaching/Reducing Agent (Sodium Bisulfite) 20 minutes at 180°F
Dyeing
X% Acid Dyestuffs, premetallized acid dyes or chrome dyes.
7% Sodium Sulfate (Glaubers Salt)
0.4% Sequestrant
0.1 Sodium Thiosulfate (Antichlor)
0.5% Leveling Agent (Non-Ionic Surfactant)
Y% Acetic Acid (to lower pH to 4.0-5.0)
Dyestuffs are boiled and strained, then added to the mixing tank with the chemicals
listed above. The dye liquor is then heated to 140°F and metered into the dyeing kettle,
circulating with an inside-out flow. Heat is raised 2° - 3°F per minute and after reaching the
boil, bath is held for 30 - 45 minutes. When batch is checked satisfactory for shade, the
liquor is drained and the fiber pack is rinsed until clear of dyestuff residuals. If a spinning
finish is required, this is added and circulated at about 130°F for 20 minutes in order to allow
the fiber to assimilate the finish from the water bath. The liquor is then dropped, and fiber
removed from the kettle for centrifuge extracting, followed by drying.
Note: For atmospheric stock dyeing, a temperature of 210° to 212°F is used. For pressure
dyeing, temperatures of 220° to 225°F are the maximum that should be used, since excessive
temperature tends to tender and weaken the wool fiber.
Nylon
Acid dyes, premetallized acid dyes,and selected disperse dyes can be used in the
pressure kettle.
X% Dyestuff
0.5% Dyeing Assistant (Anionic Surfactant)
2.0% Monosodium Phosphate (M.S.P.)
0.4% Sequestrant
0.2% Sodium Thiosulfate (Antichlor)
Y% Acetic Acid (to pH 4.5)
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The procedure is generally the same as for wool; however, in some instances,
prescouring can be omitted. The afterscour is usually not required, as rinsing alone is
sufficient. A finish bath is required with nylon, and cationic type finish is used in order that
subsequent yarn processing will be satisfactory. This can be applied either in the kettle, or
as an after finish application in the continuous washer systems available in some plant
operations.
Yarn Dyeing
One of the classic ways to color yarns is to make a skein and apply the dyestuff to the
fiber while it is in this form. All fibers, primarily wool and nylon, may be dyed by this
method.
It is possible to skein dye at either atmospheric pressure or under pressure similar to
stock dyeing. A modern skein dye unit usually has a perforated arm on which the skeins are
loaded. During dyeing, the dye liquor is forced through holes in the arms. When immersed,
this allows for uniform application and absorption of the dye by the yarn. If the skeins are
not uniformly loaded, dye liquor channeling can occur, thus causing streaky or un-level
dyeing of the skeins.
There is a considerable amount of manual labor involved with skein dyeing. Listed
below are the steps involved:
Skein preparation and lacing;
Loading of the dyeing arms;
Dyeing operation, including rinsing and finishing;
Centrifuging or extracting;
Dyeing;
Conditioning;
Expanding the skeins to remove tangles; and
Reconing.
The primary use for solid color skein yarn dyeing in the carpet field is for woven
carpeting. It is also used for accent colors in the Omnipoint and Graphic tufting styles.
Here the requirements for many colors, some in very small quantities such as 200 - 400
pounds-per-color, requires a method of production for which skein dyeing is entirely suitable.
This type of system also provides a product with excellent bulk and a lofty hand, both
desirable characteristics.
The dyeing procedure is dependent upon the type of fiber involved, but the same
principles apply to all dyeing.
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1. Prewash to remove oil and foreign materials, rinse.
2. Mix dyes and chemicals - add to holding tank.
3. Add to kettle.
4. Raise temperature uniformly at 2° to 3°F per minute until proper dyeing
temperature is reached.
5. Dye to exhaustion - 30 to 60 minutes (dependent on fiber) at the dyeing
temperature.
6. Drop bath - rinse.
7. After-scour, if necessary.
8. Add finish - 10 - 20 minutes dwell for exhaustion at 120° to 140°F.
9. Drop bath - centrifuge.
Typical formulation for nylon:
X% Level dyeing acid dyestuffs;
1-5% Leveling agent (anionic surfactant);
0.4% Non-Silicon antiform;
0.5% Sequestrant; and
0 -.4% Sodium Thiosulfate.
Package Dyeing
There is very little package dyeing used today for dyeing yarns to be used in carpets.
The prime use is only in a few woven carpet styles, and it is essentially used only for special
colorations such as effect colors in Axminster designs. The cost of package dyeing has been
one of the main reasons for the lack of interest in this system.
In package dyeing, the yarn is wound onto a special cone, usually a perforated tube or
a stainless steel spring. It is then placed onto a carrier with special perforated rods designed
to emit dye liquor and force it through the yarn package. The entire unit is then enclosed in
a pressure kettle and dye liquor forced through the yarn and recirculated until the dyestuff is
exhausted from the bath.
Space Dyeing
The modern space dyeing technique for production of carpet began in approximately
1959 - 1960 as a technique developed to change the color of the yarn approximately every
1/4 inch along its length. In the late 1960s and early 1970s, the space dyed look in the
carpet represented at least 15 percent of all pounds of yarn dyed and converted into carpet.
Today, it is less popular and presents approximately 5-percent share of the market.
This system is based on knitting a plain circular knit tubing or a sock from the
supplied yarn. These knitting units are usually dependable, trouble free units requiring a
minimum of attention and technology, provided the supply yarn is uniform and contains a
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minimum of knots or splices. There are numerous variations possible, but a 3-inch diameter
circular knitting unit seems to be the most commonly used system, however there are some
space dyers using a flat bed machine that knits up to a 25-inch flat tube to be used in the
space dyeing process. In either case, the coloration techniques are the same, whereby the
knit yams are printed with dyestuffs in a multicolored pattern after which they are then
steamed, washed, extracted, and dried, and the yarn de-knitted and rewound onto cones.
Various types of printing heads are used, the most common being the engraved roller
printer. Normally there is a base shade that is applied by a pad dyeing technique where the
tubings are completely covered in solid dye or print bath, then forced through a press roller
to give a residual 90- to 100-percent take-up of pad dye liquor. This is followed immediately
by a series of engraved rollers that overprint "wet-on-wet" several other colors in stripe
patterns onto the tubings. In order to minimize "chevroning" or patterning in the carpet, it is
necessary to print the stripes at various angles to the tubing. It also is a necessary practice to
print several colors on one side of the tube and then turn the tubing over to print several
other colors on the reverse side without getting too much of one color applied to the same
side. Patterns are quite complicated, but once a good pattern has been developed, it usually
enjoys a long production life.
In printing, it must be remembered that there is usually a base color, and that all
shades on the "print" are "overprints" or shades including the base shade color. This
involves careful color matching and requires considerable expertise.
After the printer, the tubing is plaited into an endless belt steamer for fixing the print
color onto the yarn. In most instances, steaming time of 6-12 minutes is needed and
temperatures of 220° to 230°F are desirable. There are more sophisticated steamers available
capable of higher temperatures and dwell times, but normally the above quoted requirements
are adequate. Immediately after the steamer, a series of wash boxes and/or pressure sprays
remove excess color from the tubing.
At this point, it is usually necessary to have an extra wash bath equipped with pad
rolls where an antistat finish is added to the yarn to assist in the subsequent de-knitting and
tufting process. After the finish bath, the tubing is then processed through a drying
operation. There are various types of driers, and the choice of drier usually depends upon
the required production. After drying, the knit tubings are collected in individual boxes or
cans, one tube per box and then reversed so that they will de-knit more readily. It has been
found that when an attempt is made to pull the yarn out of the stock tube by starting the yarn
from the wrong end, considerable processing difficulties are encountered. This loosened
yarn end is then threaded through several tension bar guides and wound directly onto a cone
to be shipped to the tufting or weaving mill.
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3.5.1.3.2. Post-dye systems
Beck Dyeing
The beck dyeing process involves placing undyed carpet in a stainless steel vat or
beck and rotating the carpet in dye liquor as the water, chemicals, and dyestuffs are slowly
heated. When the dyes have been transferred from the water or dyebath to the carpet, the
dyeing process is complete and the beck is drained. The beck is then refilled with water and
the carpet is rinsed free of loose dye particles and other dyebath residuals. The carpet is then
removed from the beck, placed in buggies and made ready for the drying process.
The mechanical handling of the volume and weight of a 12- or 15-foot wide carpet
hundreds of yards long can obviously be a major problem; the modern carpet beck has been
designed to handle these problems well.
It is important that the temperature of the carpet and the dyebath be kept as uniform
as possible and not subjected to rapid temperature changes. A carpet dye beck is filled to
about 3/4 capacity with water and dyes. As the carpet is rotated, it is lifted out of the water
and the dye liquor cascades over the exposed carpet section. Considerable dyeing occurs
during this part of the operation, and it is necessary to keep the dye liquor and the carpet
from cooling off during this time. Modem dye becks have doors which can be closed to
minimize loss of heat by evaporation and radiation.
If a prescour is required, before dyeing, the beck is filled with warm (100°F) water.
Scouring compounds are then added and the bath is heated to about 120° to 130°F and held
for 5 to 10 minutes while soil and yarn lubricants are removed from the carpet. At this
point, if necessary, the carpet may be pre-bleached to remove excess tints. For bleaching,
higher temperatures up to 160° to 165°F are used.
Bleach Scour Procedure:
Set fresh bath with water at SOT with:
4.0% Sodium Perborate (mild bleach);
0.15% Non-ionic Surfactant;
0.25% Trisodium Phosphate (Detergent - pH control);
Enter carpet and run 5 minutes at 80°F;
Raise temperature to 60°F and run 15 minutes; and
Drop bath - rinse warm at 100°F.
After draining, the beck is refilled with water, the dyestuffs are added along with the
dyebath ingredients such as retarding agents, detergents, and sequestering agents. The bath
is then raised slowly to the dyeing temperature at a rate of 2° to 38F per-minute. At 205° to
210°F, the bath reaches its operating temperature and dyeing continues for 30 to 45 minutes.
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During the entire operation, the reel on the beck is constantly rotating and moving the carpet
through the dyebath.
After approximately 30 to 45 minutes, a sample is taken to determine whether the
carpet is "on shade." This is done by cutting a small square from the carpet in three places
(edge-center-edge) across the width, so that any evidence of unevenness can be assessed;
samples are then dried and checked against the standard.
If the color is incorrect, then a dyestuff addition is needed to bring the carpet on
shade. These additions to the beck are made by dropping the temperature to 180°F, slowly
allowing the dye liquor to return to the dyeing temperature and continue for 15 to 20
minutes. Sampling is repeated and again the shade is checked to the standard. Once on
shade, the carpet is rinsed by dropping the dyebath, refilling with fresh water and rinsing for
5 to 10 minutes or until the rinse bath is clear. After rinsing, in some cases, a final finish
bath may be required. If so, a finish bath is prepared by adding the chemicals involved to a
clear bath, raising temperature to 130°F and running for 5 to 15 minutes. The bath is then
dropped, and the carpet is removed.
The carpet is unloaded by stripping out the sewing thread seam or cutting the sewn
edge. Next the carpet is threaded around the outside unloading reel and then plaited into a
large stainless steel or plastic tub with casters and drainage holes in the bottom and sides.
Then the carpet is positioned for extraction of excess water and the drying process.
There are two basic types of beck dyeing:
(1) Open width; and
(2) Rope dyeing.
Open Width
In the case of open width dyeing, the beck is equipped with a "spreader" roll. This is
a full- length, spiraled roller over which the carpet is pulled and literally spreads the carpet
so that it does not tangle or crease during its passage through the dye liquor and around the
reel. The carpet is sewn in an endless belt and passed over this spreader roll and/or also
over the top of the reel. The reel is a circular or oval cylinder which is usually covered with
cloth to prevent "snagging" of the back of the carpet. The cloth surface also gives the reel
the ability to pull the carpet without excessively distorting or abrading the surface. The reel
is motor driven and the better quality becks are equipped to change the revolutions or speed
of the reel. The optimum surface speed of carpet should be about 60 to 80 yards-a-minute;
faster speeds distort the carpet, slower speeds tend to give the carpet time to fold or crease,
and, therefore, dye unevenly.
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Rope Dyeing
The procedure for rope dyeing is basically the same as open width dyeing except the
manner in which the carpet is loaded into the beck and the elimination of the spreader roll.
The carpet is entered by first roping or pleating the carpet to form a short width and then
allowing the carpet to plait in a crushed or pleated manner into the beck. The carpet is then
sewn into a continuous loop. The roping at the start of the loading causes the carpet to
slowly advance from one side to the other side of the beck during the dyeing process.
As would be expected, this procedure allows creases in the carpet during dyeing;
however, a surprising number of carpet constructions can be dyed crease-free by this roping
system. The creases formed are soft and can be readily penetrated by the dye liquor and for
this reason a large number of operations prefer the rope dyeing method. They claim it gives
a better fabric finish, side to side color match, and the beck can handle a greater load than
with open width dyeing.
Super Caacit
In beck dyeing, the size of the vessel governs the maximum capacity of a given dye
lot; thus, if the carpet to be dyed exceeds the becks capacity, then more than one dyeing will
be required to complete the order. Unfortunately, when multiple dyeings are made of the
same color, they may not match perfectly. This was one of the prime reasons for the
development of continuous dyeing; however, continuous dyeing also has its disadvantages.
Certain carpet styles are aesthetically and technically more desirable to dye in a beckthus,
the development of the super becks.
The super becks, unlike the normal size becks that are still very numerous in the
industry, are oblong in shape giving them a greater capacity. Some of these becks can dye
twice the amount of carpet as to the regular dye beck.
Due to the large amount of carpet and design of the beck, it is necessary to dye in
open width form. An intricate part of the design of the super beck is the complicated
pumping and filtering systems which are used to circulate the dyebath evenly throughout the
vessel.
Pressure Dye Becks
In pressure dyeing, the dye beck has the ability to exceed the boiling point
temperature which will increase diffusion of dye molecules into the fibers of the carpet. This
is particularly desirable when dyeing polyester fiber because of its hydrophobic nature.
The original pressure becks developed over 20-years ago were designed very similar
to an open atmospheric dye beck with the exception of the doors which could be sealed. Due
to carpet handling problems and variances in temperature of the dye bath, this original type
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of pressure beck never became very popular. The new pressure becks, referred to as "jet
becks", being used in the carpet industry today are radically different in design from the
older pressure becks.
The cost savings that pressure "jet" becks offer carpet manufacturers can be quite
significant. Another attractive feature of these pressure "jet" becks is the dye lot size.
Depending on supplier, these becks can dye up to 5,000 pounds of carpet.
The machine construction consists of a long stainless steel vessel with a diameter of
approximately 80 inches and a length of approximately SO feet. Inside the beck is a
transition tube with the venture and drive reel. The flush flow out of the venture transports
the carpet to the end of the transition tube where the carpet lays out freely and relaxed. The
dye liquid which is recycled through a filtering system and heat exchanger.
Continuous Dyeing
There are two categories in which all continuous dyeing can be placed.
1. Solid Color Carpets and
2. Multicolored Carpets.
Both systems will utilize the same basic equipment with the exception of the dye
applicator itself. For solid color dyeing only one applicator will be used coloring the carpet
evenly with dye liquors from side to side of the carpet. When using the dye range for
multicolored carpets, a series of applicators will be used. Some applicators will apply color
to the carpet in random type pattern effects while other applicators will dye the remainder of
the carpet a solid color. There are many possible variations of sequence and placement of
the individual machines to consider. Cost, productivity, and operational efficiency must be
prime considerations in addition to the more exciting aspects of color styling and versatility.
Even the most exotic coloration system is of little value if it cannot produce a rapid return on
investment for the carpet manufacturer.
The sequence in which these applicators are used to produce different styles are too
numerous to count. Because more than one applicator may be utilized, the space
requirements are somewhat increased, but the versatility of the dye range is greatly
enhanced.
Composite Dye Range
The following schematic indicates the six steps used in carpet dyeing. These six steps
are described in subsequent sections.
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»
U -9-
! 3
1. Sew In Area
Buggies or rolls of carpets are sewn end to end to create a continuous belt of carpet.
Afterwards the carpets are fed into a holding box (J-Box). The most important factors at this
stage in production are to have enough linear footage accumulated to ensure that at no time
the production line has to be stopped and that the carpet is squarely sewn end to end.
2. Pre-Conditioning
In this area of the production dye range a couple of different things happen: 1) the
carpet is almost always back-beaten and vacuumed to remove as much loose fiber and trash
as possible; and 2) the carpet is wet out by either spraying with pre-mixed water and wetting
chemicals, or by dipping in pre-mixed water and wetting chemicals.
The primary reason for wetting out the carpet is to slow down the absorption of dye
liquors in order to aid in the overall levelness of the dye application. The secondary reason
for wetting out the carpet is to remove spinning oils, tint, etc., from the fiber to promote
better performance when dyeing.
After the wetting out processes, the carpet is then extracted or squeezed to remove
excess water and level out the consistency of moisture content across the width of the carpet.
Approximately 100 percent or less pick up (increase in weight) is the average for the carpet
industry.
Some companies prefer to pre-steam instead of wet out. This does introduce moisture
to promote bulkiness and elevates the surface temperature of the fabric, which is believed to
increase total color yield. This process is especially desirable for the new type dye
applicators such as the Kuster Fluidyer which can utilize thermal dyeing technique.
3. Dye Applicators
This is the area where dye liquors are applied either by a single applicator for solid
color carpet or by multiple applicators for the multicoloration styles.
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As the industry moved into the mid 1970s, a company called Kuster developed a
precise applicator for dyestuffs. A plain roller rotating in a trough containing dyestuffs,
water, and chemicals, picked up a surface coating of these dyestuffs which were then
carefully "doctored off1 the surface of the roller and allowed to evenly flow down a metal or
fiberglass sheet angled at 45 degrees to the surface of the carpet where it was absorbed as the
carpet passed underneath the doctor blade. Following this application of dye liquors, the
carpet again was processed through a steaming chamber for fixation of dyestuff.
As technology advanced in the early 1980s, a more precise applicator was developed
by Kuster. The versatility of this piece of equipment suited the carpet manufacturer very well
in that it was much more flexible where speeds were concerned having a maximum of 150
feet-per-minute and a minimum of 20 feet-per-minute. The average pick up (total dye liquor
applied) used by the carpet industry is between 300 and 350 percent; however, as low as 50
percent can be applied if foam is utilized. The change from one running color to another
running color could be made in a matter of feet, whereas, the predecessors would virtually
have to stop the line and rethread the entire range, thus losing much time just in order to
change from one color to another.
Carpet is fed towards the dye applicator head where there is a slot approximately 3/8-
inch wide, which is fed by a series of individual tubes 1-inch apart. All these tubes come
from a central distributor thus having an even flow and pressure of dye liquor in the slot at
any one time. As the carpet passes under the slot, an air cushion forces the carpet tightly
against the slot, thus forcing the dye liquors into the pile yams of the carpet, then
immediately after exiting, the carpet enters a steam chamber for dye fixation.
The developments of the multicoloration effects resulted from the solid color
applicator, which picks up the dyestuff on a smooth roller and then delivers a sheet of
dyestuff onto an incline plane that is then poured onto the surface of the carpet. By having
oscillating bars, wire fingers or squeegees that could break apart the sheet of dye liquor, it
was found that droplets of color could be placed onto the surface of the carpet. By having
two, three or four of these applicators each with a different color, random coloration effects,
which were initially aimed at producing space dye type carpet but evolved into more of the
multicolor effects which are known today, were produced. The first systems became known
as the TAKE or Multi-TAKE coloration methods. By combining some of these processing
techniques where drops of color are placed randomly on the surface of the carpet with gum
layers and other chemical modifications, attractive random multicolor fabrics were produced,
but they could only generally be duplicated, never exactly duplicated.
Kuster TAKE Unit: This is a programmable color drop applicator operated by
forming color rivulets and intersecting them with moving wires. The volume of rivulet flow,
the speed of the wire drop cutters, the oscillation of the rivulets and the sequence spacing of
the rivulet streams are all adjustable through a relatively wide range to give multicolor
effects in random so called patterns. This unit usually has two color capability; and there are
Quadra-TAKE units that have four separate colors operating simultaneously. Styling
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possibilities of TAX units are limited, since they cannot produce anything but random
effects. However, when the system is equipped with gum applicators (one in front, one in
back of the TAKE), a variety of multicoloration effects are possible and this unit represents
the classic "Gum TAKE" styling machinery.
Kuster Multi-TAKE: The multi-TAKE can be considered an ultimate effort at pattern
formation from a standard TAKE unit. The primary change involves replacing the solid
doctor blade with a patterned doctor blade. This results in producing strips of color on the
polished roll, and these can be altered into geometric patterns of color when the doctor blade
is oscillated in precise relation to the roller speed and the speed on the carpet. The
multi-TAKE is still sufficiently versatile to be styling tool in the industry today.
Kuster Color: This unit involved the basic solid color Kuster applicator with the
addition of an oscillating jet roller As a sheet of dye liquor was scraped off the applicator
roller, the jet roller would send a burst of air to displace the dye to form a pattern effect.
The jet ports could be plugged in any given manner to produce different effects.
A further development of this technique was the Jet Kuster which basically was a
Kuster Color with a unit on top of which there are 56 flexible tubes that are fed by separate
dye liquors. This unit utilized the foam dying system so that the liquors are interblended,
but not mixed; therefore, a marbleized effect is obtained.
Multicolor Spray Dyeing: The Otting Jet Foam unit was the first spray applicator
known to be specifically developed for commercial broadwidth carpet dyeing. Dye liquor is
pumped in precise measured quantities to jets in front of which compressed air is introduced
into the feed line, resulting in a fine spray of dye solution being directed at the carpet pile.
Spray dyeing is the newest technology in multicoloration. By putting three different spray
bars in place across the width of the carpet and by turning these on and off in various
sequences, it is possible to obtain the type of multicolor carpet that is still in demand. Each
spray head applied one color. The jets are turned on and off by a series of sensors reading
an acetate design or by the newer computer system.
4. Steamer
Steamers, regardless of their configuration and design, serve a simple, common
function: to provide the energy necessary to exhaust the dye liquor onto the fiber, whether it
be continuous solid color, multicolor, or printing. Most solid color continuous dye lines,
after the dye liquor application, go directly into a vertical type steamer where the carpet
moves up and down over a series of rollers. The dyestuffs can cascade back and forth
achieving a good overall levelness of color. On a multicolor dye range, normally the carpet
enters a horizontal steamer to fix the dyestuffs that were applied in some form of pattern
effect before entering the vertical steamer. If not, then smearing and loss of pattern would
be the final result.
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There are many types and producers of steaming equipment for the carpet industry.
The basic parameters that any steamer has to meet are to have an even temperature from side
to side and front to back; sufficient wet-bulb temperature (212°F) to get good diffusion of
dyestuffs into the fiber; and sufficient dry-bulb temperature (slightly over 212°F) to keep
down condensation inside the steamer.
Normally, the carpet will remain in the steamer anywhere from two to six minutes,
depending on the speed at which the dye range is operating and the accumulation of carpet
inside the steamer.
In the older type steamers, the carpet entered through the top then went downwards
around the first roller and proceeding back to the top. Much energy was lost in the entrance
and exits of these steamers. These steamers usually work with the principle of a wet sump
in the bottom of the steamer; there are still many of these in operation in the United States.
The newer technology "cloud" steamers with the carpet entrance and exit in the
bottom below the steam kyer (cloud) are much more energy efficient as very little steam is
vented. The principle behind these steamers is to use low-pressure, superheated steam instead
of a wet sump.
5. Washing
In this area as the carpet immediately exits the steamer, it is either dipped or sprayed
and vacuumed by a series of devices. The most important function at this stage in production
is to remove all residual dyestuffs and chemicals that were used during the dyeing process.
If not washed thoroughly, then quality problems such as fastness to water, shampoo, and
cracking may arise at a later date.
6. Dryer
There are many types and fabricators of drying ovens in the carpet industry. All of
them accomplish one design function which is the removal of moisture from the carpet.
Immediately after exiting the washing cycle the carpet enters the dryer, usually carried by
tenter chains to hold the carpet tightly during the drying process.
Two basic design principles governing most dryers:
1) Impingement dryers--the carpet is surrounded by heat top, sides and
bottom.
2) Flowthrough dryers-hot air passes through the carpet top to bottom or
bottom to top and is then recirculated.
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The latter of the two is more efficient and is utilized more in continuous dyeing; the other is
primarily processed. After drying, the carpet is rolled up and is readied for the secondary
backing.
3.5.1.4. Carpet Formation
As in the case of yarn manufacturing, the carpet formation operation may be
considered a mechanical/physical process with no chemical applications. However, a general
overview of carpet formation information is presented so that members of the EPA Carpet
Dialogue Group can develop an understanding of various methods and materials used in the
final finished composite carpet product.
There are numerous techniques for producing pile floor covering:
Tufting;
Weaving;
Fusion Bonding;
Hand Knotting; and
Braiding.
These techniques are described in the remainder of this section.
Tufting
Tufting is a process whereby tufts of yarn are inserted into a woven or non-woven
fabric or primary backing. The tufts of yarn are inserted by vertical, reciprocating needles
similar to the principle of conventional sewing machines. In fact, a modern tufting machine
can be visualized as a giant sewing machine having hundreds of threaded needles in a row
across the width of the machine.
A closer look at a tufting machine will reveal that individual cones of yarn or large
beams are arranged in racks or a creel. A guide or tube is provided for each yarn end
coming from the creel which feeds on needle. From the creek, the yarns pass through guides
or tubes to the yam puller rolls of the tufting machine. Adjusting the speed of these puller
rolls controls the amount of yarn supplied to the machine, and with other factors determines
the pile height of the carpet.
Following the feed rolls, the yarns pass through a series of vertically aligned, fixed
guides. These guides direct the flow of the yarns without becoming tangled to the jerker
bar. The jerker bar forms a combination of guides consisting of a fixed guide attached to the
machine body and a guide located on the top of an arm extending from the needle bar of the
machine. When the needle bar moves up and down, the relationship between the two guides
is changed to take up the slack yarn delivered during the upward stroke of the needles.
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From the jerker bar, the yarns are threaded through their respective needles in the
needle bar. Modem tufting machines normally have hundreds of equally spaced needles
arranged in a row along the length of the needle bar. For example, a 12-foot, 5/64th-gauge
machine will have approximately 1868 needles while the more popular 3/16-inch gauge
machine 12-feet wide will have 780 needles. The needles tuft simultaneously between 500 to
1400 strokes or stitches per minute on conventional tufting machines. At such speeds, a
tufting machine in good condition can produce up to 8000 square yards of 12-foot carpet in
an eight-hour shift, or more than 6.0 million square-yards-per-year.
The primary backing into which the yarns are inserted is supplied in roll form,
located in front of the tufting machine. Spiked rolls positioned on the front and back sides of
the tufting machine draw the backing over the bed plate and through the machine. The speed
of the spiked rolls controls the stitches per inch. Moving the primary backing slower
produces more stitches per inch while a faster rate produces fewer stitches per inch.
Located below the bed plate of the tufting machine are loopers (for loop pile) and
looper and knife combinations (for cut pile and cut/loop only) which pick up and hold
momentarily the yarns carried by the needles. In both cases, the loopers' work is timed with
the stroke of the needles. When tufting cut pile, the looper and knife combinations hold and
cut the yarns in a single operation. When forming loop pile, loopers shaped like inverted
hockey sticks are positioned in the machine so that the formed loops move away from the
loopers as the backing is advanced through the machine.
Loopers for a cut pile are reversed C-shape with a cutting surface on the top inside
edge of the crescent shape. They are used in combinations with knives having a ground
cutting edge on one end. As a backing advances through the machine toward the cut pile
loopers, the yarns pick up from the needles are cut with a scissor-like action between the
back of the looper and knife cutting against the edge of the looper.
For a cut/loop construction, a special looper and conventional cutting knife
combination is used. The looper is similar to a cut pile looper, however, a special spring
clip device is positioned at the top of the looper. In a conventional cut/loop construction, if
a loop pile desired, a patterning device slows the feed of the yarn and thus applies more
tension to the yarn. This tension is enough to cause the yarn loop already formed on the
looper to pull itself past the spring clip tension device and become loop pile. If a cut pile
section is desired, the patterning device feeds more yarn which in turn reduces tension to
such a degree that there is not enough tension to puU the yam off the looper and thus is cut
similar to a conventional cut pile construction.
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Tufting Machine Characteristics'.
1. Surface Textures
There are three basic surface constructions of tufted carpet commonly being used in
the industry today. These constructions are loop, cut, and cut-loop. The loop pile was the
first construction introduced in the tufted carpet industry and was followed by tufted cut pile
carpets and lastly by the cut-loop construction.
a. Loop
The loop pile construction can be further subdivided into three different categories.
In level loop constructions, all loops arc the same height from row to row. The next
classification is that of high-low or patterned loop which uses a patterning attachment to
achieve different pile heights in a pattern repeat tufted to either two different pile heights or
in some cases three different pile heights. The third classification of loop pile construction is
that of textured loop. Although there is some pile height variation in textured loop in order
to give the carpet more surface interests than regular level loop, the pile surface interests the
regular level loop, the pile height differentiation is usually slight and has little or no pattern
definition as in the case of the patterned loop.
b. Cut Pile
With conventional cut pile tufting machines, the carpet pile surface is always level
with all of the yarn tufts being the same pile height. Patterned effects can be created in the
cut pile constructions by using different colors of pre-dyed yarns and through a pattern
attachment called a shifting needle bar, various geometric designs can be created.
c. Cut-Loop
The cut-loop classification can be broken down into two subcategories. The first
category is the more common high-low construction where patterning is achieved by the high
pile always being cut pile and the low pile always being loop pile. By using a pattern
attachment similar to that used in the high-low loop construction, a cut-loop construction can
be attained by selectively varying the yarn tension, which controls whether the tuft will be
cut of loop in form.
The second cut loop construction deals with a variation of cut-loop whereby the
tufting machine make tufts of cut pile and loop pile at the same pile height to give a more
woven-like effect. These are commonly referred to as the "Velva-loop" and "Level-
Cut-Loop" tufting machines.
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2. Gauge
Gauge can be defined in a number of ways; however, it is the density or the
positioning of yarns as defined by the number of needles across the needlebar, or the
width-wise portion of the tufting machine. Normally, gauge is referred to in fractions of an
inch. For example, a 5/32 gauge means that the center of each needle is 5/32 of an inch
apart. A 1/8 gauge has the needles 1/8 of an inch apart (gauge is the equivalent of pitch on
the weaving loom).
3. Stitches Per Inch
The control of yarn weight and density in the lengthwise direction of carpet is
achieved by varying the stitches per inch. Assuming a single row of needles positioned in a
straight line in the needle bar and that the needle bar is connected to the main drive shaft,
each stitch is in actuality a row of tufts across the width of the carpet.
4. Pile Height
The third dimension of pile height is generally measured from the surface of the
primary backing to the top of tufted yarn. The height of the tuft can be controlled by a
number of methods, such as the height of the bed plate, which is the metal surface on which
the primary backing rests, in its relationship to the needle. The degree of penetration of the
needle through the primary backing can be adjusted. Slight adjustments in the pile height
can also be made by the amount of tension placed on the yarn as it is being fed from the
creel.
The pile height of carpet is also influenced by the gauge of the tufting machine.
Finer gauge tufting machines obviously mean a higher number of tufts per square inch which
result in heavier weight carpets. In order to reduce the weight of the carpet face yams, the
pile height can be lowered. Therefore, as a general rule, finer gauge carpet normally have a
lower pile height than coarser gauge carpets.
Pile height is the second most often used factor in adjusting yam weight. It involves
more time and detail that stitches per inch; however, there are times when stitches per inch
can only be adjusted to a certain degree after which pile height must be adjusted.
High Speed Tufting
High speed tufting involves speeds in excess of 1,000 rpm and in most cases applies
to cut pile tufting machines. Recently, however, many loop pile and cut-loop tufting
machines have been built using high speed frames.
If a shifting needlebar attachments are used, machine speeds are obviously reduced
because of the additional time and mechanical force required for shifting of the needlebar. In
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most cases, the shifting needlebar attachments are operated at speeds in the range of 600 -
800 rpm.
Creels
1. Yarn Package Creels
A creel is a devise to hold yarn as the yam is tufted. There are two basic types of
creels; yarn package creels and beams.
The yam package creel is a large metal framework with a special yarn cone holding
device for each cone of yarn as well as an additional or back-up cone. A nylon tubing is run
from each yarn package to the yarn feed rolls of the tufting machine.
The main advantage of a yam package creel is that it is more efficient with lower
waste on longer production runs and more flexible in case of off quality yarns. Most
importantly, yarn package creels can be used on all constructions. Any machine that uses a
patterning device for a cut-loop or high-low loop style constructions must exert various
tensions or yarn feeds which make the use of beams virtually impossible since a beam must
feed all yarn at uniform rate of speed.
Some disadvantages of a creel are that they require a greater amount of floor space
than beams. This is especially significant in finer gauge where there are a greater number of
needles per inch and thus more cones of yarn.
2. Beams
Beaming involves winding packaged cones of yarn onto large wooden or metal spools
or beams. After beaming the yam, the beams are taken to beam racks and positioned for
tufting.
The main advantage of a beaming operation is that it generates relatively lower waste
poundage on smaller yarn lots than yarn package creels. On most machines, especially finer
gauge machines, beams reduce the among of necessary floor space.
The disadvantages are that beams that require the intermediate operation of beaming
the yarn can cause some processing problems, the main disadvantage being that they cannot
be used on high/low patterned constructions and thus can only be used for level loop,
textured loop and cut pile constructions.
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Primary Backing Characteristics
1. Jute
Jute as a primary backing material is basically non-existent in today's carpet market.
It was originally used as a primary backing in the early days of the tufted carpet industry,
however, during the 1960s and 1970s, its use as a primary backing has gradually declined to
the point where it is no longer a viable portion of the market.
2. Woven Polypropylene
Woven polypropylene primary backings totally dominate the carpet market at the
present time. The main reason these backings dominate the market is their consistency and
uniformity of quality, price, and supply.
Fusion Bonding
Fusion bonding is a recent manufacturing technique. Basically, bonding involves
implanting yarns, fiber webs, or fiber batts in cut pile or loop configuration onto an
adhesive-coated backing. Thus, with bonding, more yarn is on the surface of the carpet
instead of on the back or through the backing as is the case with tufting. Bonded carpets in
the United States are less than 1 percent based on total square yards sold.
To simplify the techniques, fusion bonding can be divided into two major
sub-categories:
1. Single Ends Implantation and
2. Multiple Fold Implantation.
Single End Implantation
Single end implantation refers to a single end of yarn being implanted on an adhesive
backing. Several systems have been developed for commercial use, while other have not
made it past initial development stages.
1. Bondi
The process begins with a special shuttleless loom and pattern device. The pattern
device reads the pattern. According to the pattern, different sequences of different colored
filling yams are woven with a minimum number of warp yarns, and is some cases, no warp
yams at all.
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The woven "fabric" is then folded in a precise zigzag or accordion formation known
at a "pack". The pack of folded yarn is then turned at a right angle to the backing and cut to
a certain pile height for implantation into the backing.
After cutting the pack, a bonded carpet is formed with the cut ends of the pack of fill
yarn giving a pinpoint pattern depending on the spacing of the different colors during
weaving. In other words, the Bondi system is a cross section of the pack that is secured to a
backing and thus forming a bonded patterned carpet. Pile heights are infinitely variable up
to 1.2 inches.
Multifold Implantation
1. Neko Process
Basically, the process is as follows: From opposite sides of the machines, backing
fabrics move toward the center of the machine. Before reaching the center, an adhesive is
applied to the top of the backings. At the center of the machine, the coated backings turn 90
degrees into a narrow, vertical section of the machine. At the top of the column, two
reciprocating blades fold the fiber web into a corrugated form. The ends of the corrugated
folds are pressed into the adhesive backing by the pressure from the reciprocating blades to
form a corrugated yarn "sandwich".
The face-to-face carpet moves through a infra-red oven section to cure the adhesive.
From the oven, a cutter is used to cut the face-to-face carpet down the middle to form two
separate rolls of carpet. This cutting technique is similar to the method used in plush
weaving.
2. Vernier System
This bonding system is similar to the Neko process except, at the manufacturer's
option, a hot melt type of adhesive may be used which eliminates the need for an oven
section. Also, the Vernier system uses a four blade system rather than the Neko two blade
system.
3. Milstar Process
One of the most familiar bonding techniques in the United States is the Milstar
Process. This patented process is a yarn utilizing variation, of the Vernier bonding system.
4. Titan or Deletex
The Titan or Deletex is similar to the Milstar and Neko systems previously
mentioned. The system can produce two cut pile carpets or one loop pile carpet. If two cut
pile carpets are being manufactured, two 12-ounce per-square-yard jute, PVC-coated backing
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fabrics are fed into the pile formation area. Similar to the Neko System and Milstar, yarn is
implanted into the two coated backings that are facing each other to form a face-to-face
carpet similar to Milstar and Neko.
The carpet then passes through a heating zone to cure the PVC plastisol. A cutting
section then cuts the two carpets apart as in the other bonding systems.
If a loop pile carpet is desired, only one backing is used so the loop will be formed
on the opposite side where the second backing would normally be.
Woven Carpet
The fundamental principles underlying machine woven carpet may be illustrated by a
simple loom. A wood frame, a piece of cardboard, a bodkin, and a comb are sufficient to
construct such a loom as shown in Figure 3-6, below.
FIGURE 3-6 MODEL OF SIMPLIFIED LOOM
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Weaving is reduced to its simplest terms on the homemade loom. (1) and (2)
represent the warp beams. The piece of cardboard (3), the equivalent of the heddle in the
power loom, has alternate holes (a) and slots (b). The comb (c) represents the reed in the
power loom. A bodkin takes the part of the shuttle. Warp yarns are threaded alternately
through the holes and slots of the heddle and fastened securely to the warp beams. The warp
sheds for the passing of the bodkin- shuttle are formed by alternately raising and lowering
the heddle. The comb is used to beat-up each shot of weft against those preceding.
Although there are several different methods of carpet weaving, there remains a
number of basic similarities within each type. In general, the back or body of the woven
carpet is provided by the interweaving of warp and weft yarns.
3.5.1.5. Carpet Finishing
The final and probably the most important step in the manufacturing process of
producing a square yard of carpet involves the finishing of the product. The finishing
operations are often a multiple step process which is used to give the carpet its final
appearance and finish before being shipped to the customer.
The basic steps in the finishing process involve the following sequence of events:
1. Drying;
2. Pre-shearing;
3. Application of secondary backing; and
4. Final shearing.
3.5.1.5.1. Drying
The first stage of carpet finishing involves drying of the dyed carpet. It is of
importance to note that the only time during which it is possible to improve the hand and
surface appearance of carpets containing thermoplastic fibers is when they are in a hot, wet,
or damp stage. It follows, therefore, that during drying of the carpet, some effort must be
made to reduce wrinkles or creases, to attempt to erect crushed or matted areas of the pile,
and to create a full, fluffy, uniform hand to the carpet. Due to this situation, a good carpet
dryer is set up to have several "pre" and "post" mechanical aids to maximize the bulk
development, pile raising, and crease removal.
As a start, carpet must enter the dryer in a uniform state of moisture. A wet-out bath
followed by a vacuum extractor represents the first step in the system. On exiting from the
extractor slot, the carpet is usually given a rapid vibration and "back beating" on a series of
rapidly rotating serrated rolls and/or back beater beltings. This vibrates or flutters the carpet
to open up any crushed pile and to remove soft creases and distortions in the carpet. During
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the process, the carpet is held first by a tenter frame arrangement that carries the carpet
through the dryer. The tenter frame is required to accurately control the width of the carpet
and thus inhibit any change of dimension or shrinkage during the drying phase.
The dryer is usually of the impingement type, in which the heated air is forced into
the carpet from either one or both sides; or of the through-flow circulation types where air is
forced completely through the carpet, usually from the face side. The "through-flow" dryers
operate at a higher speed because of increased efficiency; however, some constructions, such
as high pile shags and saxonies, do not receive as good as texture and appearance from
"through" circulation as from the impingement type dryers.
Beater bar system can be used both on the face and the back of carpet and at both
ends of the dryer to give a more uniform appearance and texture and to erect the pile by high
speed mechanical agitation. After drying, a cooling stage is included because some fibers
will permanently deform if rolled up while still hot.
3.5.1.5.2. Pre-shearing
During the dyeing and drying operations, many carpets develop a very hairy and
fuzzy appearance on the surface. This is caused by loose fibers coming to the surface during
all the mechanical agitation which occurs during the dyeing and drying processes.
It is necessary to remove these loose fibers in order to obtain the most attractive
appearance of the finished carpet. This operation was normally done after the secondary
backing was applied to the carpet; however, in recent years, with the trend to finer gauges
and smaller yam counts, it has been found that the best finish can be achieved by
pre-shearing prior to the application of the secondary backing. The unbacked carpet is softer
and more pliable, allowing the tufts to be opened up and presented more uniformly to the
shearing machine.
The shearing machine is a unit which heavily brushes the carpet pile to make it both
erect and uniform. Carpet then passes under a series of rotary cutting knives which shear or
cut off the fiber tips at a precise and controlled height. These rotary cutting heads have
spiraled cutting blades imbedded into the surface. The carpet is passed over a small diameter
(approximately 3/4 inch) roller bar in an inverted "V" configuration. This opens up the pile
yarns and presents the individual tufts to the shearing head which allows a precise and
uniform cut.
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3.5.1.5.3. Secondary backing
Introduction
After the drying and pre-shearing operations, it is then necessary to apply some sort
of secondary backing material to the carpet. This is done primarily to stabilize the carpet
and reduce shedding of pile yarns by applying a coating of adhesive followed by the
lamination of a secondary fabric or foam material onto the back of the carpet. Some of the
more important aspects of the secondary backing are as follow:
To anchor the pile yarns and prevent pull-out of the tufts;
To minimize loosening of the pile and reduce shedding;
To obtain dimensional stability;
To prevent edge fraying during cutting;
To improve resilience;
To improve sound and thermal insulation; and
To provide cushioning underfoot.
A good secondary backing system should meet all of the above requirements and in
addition, be easy to apply. Otherwise, the system must offer some unique or special
technical performance criteria that cannot be achieved with conventional systems. There are
many available products which have been used for secondary backings.
Woven carpets as a rule are backcoated with an adhesive and/or resins in order to
achieve tuft bind and reduce pilling and fuzzing, as well as give improved hand in finish to
the carpet. Because of the woven structure of the carpet, no secondary type scrim is
required.
Tufted carpets are normally backcoated with a latex which is used to achieve tuft
bind, reduce pilling and fuzzing, and improve edge raveling resistance. The tufted carpet
can be installed with this pre-coating of adhesive only, particularly when it is going to be
glued directly to a floor and not installed over padding and tack-strip. Normally, however,
the adhesive coating also acts as a laminant in order to glue a jute, woven polypropylene, or
non-woven polypropylene scrim material to the back of the carpet. The function of this
scrim is to add further stabilization to the carpet as well as additional hard and resilience.
Attached foam cushion backings can also be applied to the carpets using either latex,
PVC, or urethane. The attached cushion backings, once a significant segment of the
secondary backing market, are now limited to specialty areas.
Secondary Backing Types
Over the years, there have been numerous systems and types of secondary backings
developed and tried for the carpet industry. The original woven type carpets utilized a
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coating of plain latex, starch, or other resin which was used primarily as the stabilizing
agent, as well as giving tuft bind and resistance to pilling and fuzzing.
With the advent of tufted carpets, the same basic technology and equipment was used
for applying simple coatings of adhesive to the back of tufted carpets to give the same
properties that were required of woven carpets. However, it was found that for most uses, a
simple coating of adhesive was not sufficient to give adequate stability to tufted type carpet
constructions, but that another secondary backing material was required for the additional
strength and stability required for the tufted carpets.
Many different types of scrim or fabric material were tried as the secondary backing
for tufted carpets. Initially, a type of woven craft paper scrim was laminated to the back
with natural latex adhesive. Although the material was cheap, it was not found to have
sufficient technical performance properties that would make it suitable for secondary backing
material.
Finally, a woven jute material was developed that was sufficiently inexpensive and
had the proper technical performance criteria which made it suitable for a secondary backing
application. Jute has been the dominant secondary backing for tufted carpets until very
recently.
Jute backing material is not available from U.S. suppliers, but instead comes from
either India or Bangladesh. The many problems in supply of jute from a foreign country
such as fluctuating prices, shipping delays, dock strikes, droughts, civil wars, etc., which
have caused the U.S. carpet manufacturers to actively look for an alternative domestically
produced material that is more readily available at stable prices.
Attached cushion secondary backings, while at one time a significant part of the U.S.
secondary backing market, now represent only a very small portion of the total backing
consumption. Other materials have been used on a limited basis, however, it has been found
that most of these cannot compete economically with jute or woven polypropylene secondary
backings.
The unitary type secondary backings have obtained a substantial share of the market.
In recent years, the institutional contract market has seen increased usage of unitary type
backings where the carpets have a direct glue-down installation in heavy traffic commercial
areas. This market segment can be expected to increase during the coming years as the
commercial contract market becomes a more important segment of the total industry.
The other types of backing materials such as PVC are used for very specialized end
use applications. Specifically in the commercial contract tile market, a heavy weight, high-
density product is required for stability and lay down properties.
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Jute or Synthetic Backing Application
Both of these types of backings are applied in exactly the same manner and
procedures. The first step involves applying a coating of styrene-butadiene rubber latex
which has been filled with calcium carbonate or alumina trihydrate. This coating of adhesive
also acts as a laminant in order to adhere the jute or synthetic backing to the underside of the
carpet.
Lamination is used primarily in tufted carpet and has an important functional role in
making tufted carpet a stable product which will perform properly when installed. The
backing also enhances the aesthetics and hand of the carpet.
Jute or synthetic backing is a multi-step operation where first the back of the carpet is
coated, usually by means of a roller rotating in the latex mix, the top side of which contacts
the bottom side of the carpet. This is immediately followed by a doctor blade which spreads
and evens the application of the liquid latex. The latex is a viscous solution, usually from
12,000 - 20,000 centipoise viscosity. The function of the doctor blade is to force latex into
the base of the tufts on the primary backing. Normally, between 24 and 32 ounces of latex
are applied, depending of the construction and style of the carpet. This latex coating acts as
an adhesive for the pile yarns and also to attach the secondary jute or synthetic backing.
The second part of the coating operating occurs when a separate roll of secondary
backing (jute or synthetic) is positioned onto the latex coating which has previously been
placed on the back of the tufted material. This secondary backing has to be positioned
carefully in order to have the edges match the tufted product and the two materials must be
carefully pressed together by a marriage roller. This laminate is then dried and cured
through a long oven, usually from 80- to 200-feet long where the latex is dried and cured at
from 240° to 300°F. Approximately 2 to 5 minutes of curing time are required, depending
upon oven efficiency, latex weight, moisture content, etc.
Normally, the first zone or penthouse will use elevated temperatures since the carpet
and backing materials must be heated up. Here the temperatures on the back may be as high
as 450°F, while the pile side is usually lower, 400° to 425CF. Temperatures in the subsequent
penthouses are reduced to about 350° to 375°F to avoid burning of the carpet and to reduce
energy consumption. In the longer ovens, the temperature may even be cut off completely in
the last penthouse. Even though high temperatures are used, proper air circulation and
control must be used to avoid heating the pile yarns and backing materials above 270" to
280°F.
A high rate of evaporation is important for carpet drying and the ovens must have
adequate forced hot air movement along the precisely controlled heating zones. It is
important that, as the carpet goes through the dryer and after it leaves the dryer to the
cooling station and the wind-up station, that the carpet remains flat and unflexed. During
most of the passage through the dryer, the latex curing is incomplete. If the partially cured
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film is flexed, creased or otherwise disturbed, the film breaks down and results in poor
lamination of the backing to the carpet.
Although double lamination backcoating is almost mandatory for most residential type
carpets, there are several large volume uses of broadloom carpet that can utilize merely the
latex unitary coated carpet, namely direct glue down commercial applications and room size
rugs. In this instance, a single coating of about 24 to 32 ounces of latex is applied without a
secondary backing of any kind.
Vinyl - Polyvinyl chloride
In the specialized area of backcoating, there is the vinyl (polyvinyl chloride)
application. This can be applied as either a sheet or a foam, depending on requirements.
Vinyl has some advantages over latex from the standpoint of strength, pile lock,
mold-ability and slip resistance. Unfortunately, there are several problems to the use of
vinyl.
Vinyl must be cured at very high temperatures; 1 to 15 minutes at 300° to 400°F is
required. This requires either very slow oven speeds and/or extra heat capacity or a longer
oven to adequately process the product. In the case of foams, the same situation occurs.
In the commercial tile market, approximately 100 ounces-per-square-yard of PVC are
applied to the back of the carpet. Normal procedures for applying the PVC involve gauging
a layer of thickness of the PVC onto a teflon-coated, continuous fiberglass belt. The tufted
carpet is then laid on top of this coating of PVC and passed through the curing section of the
oven. The curing is accomplished by a series of heated coils underneath the belt which
activates the PVC curing process.
Hot Melt Adhesives
These hot melt adhesives are special co-polymers of ethylene vinyl acetate with
terpene resins and petroleum waxes. They have particular properties in that they can be
melted and calendared freely onto a substrate. As they cool, they return to a solid state with
almost complete encapsulation of the substrate surface. In tufted carpets, this means that hot
melts give excellent and superior tuft lock to latex and can be applied in considerably lower
add-on amounts than can conventional latex. In the past, the speed of operation of hot melt
lines was significantly faster than conventional latex. The average speed of a hot melt line is
60 ft./min. This compares to present day speeds of 50 to 90 feet-per-minute on conventional
styrene-butadiene rubber latex.
The objectionable feature to hot melts is the fact that they require a completely new
machine and compounding equipment to apply them to carpet. In operation, the carpet is fed
into a tenter frame to fix the width and then onto the hot melt head, to a post heating tunnel,
to refrigerated nip rolls, through sets of cooling rolls and, finally, to a roll-up mechanism.
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The post heat tunnel holds the hot melt temperature at about 375°F to control the
polymer's geometric penetration to the carpet back. Correct spread of the hot melt to the
fiber bundle is vital to get proper tuft and bundle lock without melt migration onto the carpet
face yarns. The secondary backing is placed in contact with the carpet as it emerges from
the hot melt head and at this point the laminate is welded together by the liquid molten
polymer.
3.5.1.5.4. Final shearing
After drying and backcoating, the carpet surface should have a level color and a
uniform appearance. However, due to the mechanical drag and abrasion that occurs in the
final finishing operation, the surface of the carpet may become fuzzy and "hairy". This
appearance detracts significantly from the carpet. In order to correct the problem, it is
necessary to lightly post-shear the carpet.
The final shearing operation is identical to the pre-shearing process that is explained
in section 3.5.1.5.2, Pre-Shearing. In the final shearing operation, it is common to have at
least two shearing heads operating in line. It is better to have two very light cuttings rather
than one heavy cutting in order to achieve the maximum effect at higher speeds.
3.5.1.6. Stain Resist Technology for Nylon
3.5.1.6.1. Introduction
The use of stain-resist agents for common food dyes on nylon carpet has become
prevalent. The success of stain-resist technology in the carpet industry has resulted in
widespread use of a class of complex mixtures called "syntans", sulfonated novolacs, or
sulfonated aromatic aldehyde condensation products (SACs). The general structure of these
compounds is represented in Figure 3-7, which generally describes most structures. It is
possible to include in the condensation other aromatic compounds not shown here. A
random sequence of the various monomer units is implied, with subscripts "a" through "c"
representing mole fractions, and subscript "n" related to the number average molecular
weight. The nature of the complex mixtures resulting from this flexible chemistry makes
careful study of this type of material difficult. The very flexibility of the synthesis makes
possible a wide variety of mixtures with overall different characteristics.
3.5.1.6.2. Stain-resist mechanism
Since the number and type of compounds in a particular mixture are quite numerous,
the exact mechanism by which these materials impart stain resistance to fibers is not
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FIGURES-?
GENERAL STRUCTURE OF STAIN RESIST AGENTS
ON
"
OH
O
-
OH
o
A
o
V
SOjH
_ OH ^
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completely understood. Previous workers in the field (although most were investigating
SACs for use in wetfastness enhancement, not as stain-resist agents) have suggested that a
barrier effect against the diffusant is the principal mechanistic concept, and that this barrier
may be both physical and electrical in nature. It was also thought to be most effective as a
result of concentration of the SAC near the fiber surface creating a "ring dyed" placement
effect. In work performed using model compounds such as pamoic acid:
MOOC OM MO COON
and also the acetate ester of pamoic acid, dye sorption measurement of the treated materials
indicated that for anionic diffusants, the electrical part of the barrier effect is the most
important, the ester derivative having significantly greater dye up-take. It is thought that the
degree to which the SAC hinders the diffusion of nonionic diffusants depends on the SAC
molecular volume, and packing near the surface end results in increased tortuosity to the
diffusant. It has also been shown that the anion-rich barrier more effectively slows the
diffusion of the more basic anionic dyes. Therefore, the key to the use of SACs as "stain
barriers" is because most water soluble food colorants are, in fact, dibasic acid dyes. Recent
work suggests that these concepts as they related to stain resistance in general is correct and
provides supportive evidence that concentration of the SAC near the fiber surface is critical
to the effectiveness of the stain resist properties of the treated fiber. This surface
concentration effect is influenced by the nature of the SAC chemistry, the morphology of the
fiber, and the application conditions. Therefore, optimization of the chemistry and
application conditions is essential for the best stain resistance performance.
3.5.1.6.3. Application of stain-resist chemistry
The main attractive forces between the stain-resist and the fiber are hydrogen bonding
between the uncharged polar hydroxyl groups of the stain-resist agent and the amide linkages
in the nylon and electrostatic attraction between the sulfonic acid groups of the fiber. The
stain-resist treatment performs best when applied at pH of less than 2.5. This is believed to
be related to both increased exhaustion of the material onto the surface and also the high
electrostatic attraction for the nylon which inhibits diffusion into the fiber. The addition of
divalent salts, such as magnesium sulfate (epsom salt), to the treatment liquor may often
enhance the stain resistance properties of the treated carpet. The effective concentration
generally varies depending on the morphology of the substrate being treated and the
concentration of the SAC in the application bath. While this effect is not completely
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understood, a possible mechanism is that the salt modifies the SAC micelle formation in
water and increases the sorption of the SAC at the fiber/liquor interface.
The most used method for application of the stain-resist chemistry is by an
"aftertreatment," after the carpet is already dyed. This minimizes any influence on the
dyeing process, makes the application more easily controlled, and yields the most repeatable
carpet performance.
The aftertreatment may be either a batch or continuous process. The most
commercially significant aftertreatment process involves continuous application of the
treatment liquor using a specially designed applicator, such as a Kuster Flex-nip or Otting
Thermal Chem, which is then followed by a dwell period at elevated temperature using a
short vertical steamer.
The application of 1-percent on the weight of the fiber (owf) of the SAC in a batch
process is normally carried out at a 30:1 liquor-to-fiber ratio, adjusted to a pH of 2 with
sulfamic acid. The fiber carpet is introduced into the bath at 26°C. The temperature is
raised to 71°C at approximately 1.5°C per minute, and then held at 71°C for 20 minutes. The
carpet is rinsed thoroughly in cold distilled water, extracted of excess water.
3.5.1.6.4. Conclusions
Industry experience clearly indicates that the molecular size distribution and polarity
are critically important parameters for successful use of SACs as stainblockers. In addition,
the placement of, or concentration of the chemistry near the fiber surface is shown to be the
most important criterion.
3.5.1.7. Soil Release
3.5.1.7.1. Introduction
In 1972, after extensive research, a soil resistant fluorochemical finish, sturdy enough
to withstand the abrasive punishment to which carpet is subjected, was developed. Today,
most residential carpets have a fluorochemical treatment which, according to applications
research, allows the carpet to remain clean up to three to four times longer than untreated
carpet.
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3.5.1.7.2. Soil release chemistry
Fluorochemical is a general term applied to a wide variety of organic fluorine
compounds. Such compounds are man-made, uniting the elements carbon and fluorine.
When these compounds contain an aliphatic group where all carbon-bonded hydrogen atoms
are replaced by fluorine, the designation perfluoro- is used. Compounds which contain a
perfluoro- chain or ring, attached to a reactive group to facilitate further synthesis as shown:
Perfluoro-compound
The principal qualities of all fluorochemicals are: 1) their extreme stability as a
compound; 2) their incompatibility with oil and water; and 3) their outstanding surface
properties. The composition of the fluorochemical can be varied to provide different
performance. Compounds can be designed for use as protective finishes for textiles, paper
and leather; as inert fluids for testing in the electronic industry; as fluoroelastomers or
rubbers with special resistant properties; as surfactants, or as fire fighting foams with special
surface properties.
Perfluoro-compounds are often converted to polymers or high molecular weight
chemicals for use as textile finishes. When dried or cured on a fiber, the fluorochemical
tails orientate themselves away from the fiber to produce a very low surface energy barrier.
The theory of repellency can be explained in part by surface energy and spreading
coefficients. It has been found that a direct correlation exists between wetting ability and
surface energy. Materials having low surface energy are difficult to wet. Fluorochemicals
having long chain perfluoroaliphatic groups produce the lowest surface energy of any class of
materials.
The spreading coefficient measures the tendency for the individual fibers to be wet by
a liquid. It relates surface energy of the substrate, surface tension of the liquid, and
interfacial tension between the substrate and the liquid. It does not take into consideration
the surface roughness, capillary effect, or uniformity of the treatment on the textile substrate.
Simply stated, fluorochemicals derive their repellency properties by lowering the
critical surface energy of the treated fabric surface below that of the wetting liquid. This
provides a chemical barrier to liquid penetration. There is no need to incorporate a
continuous physical barrier. In addition, fluorochemicals function at relatively low levels.
Therefore, a fluorochemical treatment can provide a protective barrier without unduly
affecting other desired properties. On a practical basis, this means that as a textile treatment,
a fluorochemical surface resists wetting by oily and watery liquids. And, a properly
designed fluorochemical will also provide resistance to soiling. It also means that there is
minimal effect on hand, feel or breathability of the fabric.
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Fluorochemical textile finishes offer specific performance properties that set them
apart from all other textile finishes. They have the unique property of oil repellency, plus
the properties of water repellency and soil resistance. They have greater durability to
laundering or drycleaning. Lower chemical add-on is required, thereby providing advantages
in having less effect on shade change, mark-off, hand (or feel), and breathability of the
fabric.
3.5.1.7.3. Application of soil-resist on carpet
In the carpet market, soil resistance is one of the most desired features. The
fluorochemical compound is required not only to be highly soil resistant, but must be durable
to walk-on, provide good durability to cleaning, and also be abrasion resistant. Soil gets
tracked onto the carpet; dirt is ground into the carpet with walking; and carpets are
vacuumed to remove the dirt.
Soil resistance protects the carpet by keeping dirt from sticking so tightly to the fiber.
Loosely held dirt can be removed more easily from the treated carpet with regular
vacuuming. A degree of oil repellency is needed because most soils are oily in nature.
Abrasion resistance and durability to walk-on prevents the fluorochemical from being worn
off or vacuumed away. Durability to cleaning is also required for eventually even a treated
carpet will get dirty enough to require cleaning.
Fluorochemical treatment of carpets is most commonly done by spray application.
They spray equipment must be designed to provide uniform chemical application, adequate
penetration, and variable liquid output. Amount of chemical and required output depend on
the carpet face fiber weight, and the operating speeds at the drying/curing oven.
Fluorochemicals can be applied to all carpet constructions and most fiber types. For the
purposes of treating, carpets fall into two categories: wet carpet or dry carpet.
Spray treating wet carpet is preferred, because less additional moisture is needed.
Wet carpets are found after piece dying or rinsing operations. Solution wet pick-up of 10 to
20 percent is sufficient since penetration can be more easily accomplished if the carpet is
already wet. Fluorochemical treatments deposit between 0.3- to 0.6-percent solids depending
on the weight of the carpet face fiber.
Spray application on dry carpet requires higher moisture add on to ensure adequate
penetration. Dry carpets are found at the back coating or laminating operation. Solution wet
pick-up of 20 to 40 percent is desirable, applying similar levels of fluorochemical solids;
i.e., 0.3 to 0.6 percent.
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3.5.2. VOC Reductions Already Achieved
No specific actions that have resulted in carpet VOC reductions have been reported to
the Carpet Policy Dialogue. However, some data on carpet emissions were supplied to the
Carpet Policy Dialogue by the Carpet and Rug Institute. These data should not be
considered broadly representative of carpet system TVOC and 4-phenylcyclohexene emission
rates. The measurements reported are presented in Table 3-6.
3.5.3. Dr. Van Ert's Laboratory-Scale Study
This laboratory scale study, conducted by Dr. Mark Van Ert and his associates at the
University of Arizona, was initiated by SBLMC to investigate the relationship between
4-phenylcyclohexene release from latex-backed carpet and selected carpet curing oven
operating variables. The study was completed using a laboratory-scale oven that may or may
not have been representative of industrial carpet curing ovens. Details of the study and the
results are included in Appendix N.
The variables selected for study in this set of experiments were: 1) cure time, 2) cure
temperature, and 3) air exchange rate. Other dependent factors that were considered during
the course of the study to determine their potential relationship to 4-phenylcyclohexene
release from the carpet samples included: humidity within the cure oven and moisture
content of carpet samples. In addition, the study included a preliminary investigation into the
effect of high velocity air on the release of 4-phenylcyclohexene from latex backed carpets.
Two types of latex were used: type A, which contained about 700 ppm and type B,
which contained about 250 ppm 4-phenylcyclohexene. The carpet samples, after coated with
these latexes, contained approximately 20- to 60-ppm 4-phenylcyclohexene by weight. In
order to account for the slight variation in the 4-phenylcyclohexene content in the carpets, all
data reflecting the impact of various cure parameters on the release of 4-phenylcyclohexene
were reported as a percentage of the absolute amount of 4-phenylcyclohexene remaining in a
latex coated carpet sample for the individual test run.
Inferences that may potentially be drawn from Dr. Van Ert's laboratory scale study
that may be relevant to industrial scale carpet curing ovens include:
1. Operating curing ovens at higher temperature may result in lower 4-phenyl-
cyclohexene emission rates (and possibly lower TVOC emission rates) from carpet.
2. Operating curing ovens at higher air velocity may result in lower 4-phenyl-
cyclohexene emission rates (and possibly lower TVOC emission rates) from carpet.
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TABLE 3-6
TVOC AND 4-PHENYLCYCLOHEXENE
24-HOUR EMISSION RATES OF NEW CARPET
GENERIC CARPET DESCRIPTION
FACE DYE
FIBER TYPE METHOD
SOIL/STAIN RESIST' TVOC EMISSION
TREATMENT RATE2
4-PHENYLCYCLO-
HEXENE
EMISSION
RATE1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
3
4
2
1
Continuous
Continuous
Continuous
Continuous
Continuous
Beck
Solution
Solution
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Beck
Solution
Stock
Beck
Solution
No
Yes
Yes
Yes
No
No
No
No
Yes
Yes
Yes
Yes
No
No
No
No
No
Yes
No
0.071
0.109
0.183
0.045
0.098
0.097
0.131
0.102
0.166
0.041
0.182
0.179
0.060
0.054
0.127
0.500
0.195
0.092
0.438
0.064
0.091
0.152
0.040
0.075
0.087
0.106
0.035
0.034
0.025
0.033
0.025
0.045
0.062
0.064
0.043
0.082
0.042
0.110
Mean
Standard
Deviation
0.151
0.123
0.064
0.034
1 The exact treatment was not known.
1 Emission rate taken after a 24-hour equilibration period within the environmental chamber.
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3.5.4. Industry-Sponsored Plant-Scale Study
A study with the objective of evaluating VOC as a function of process variables has
been completed. The text and data from this work is located in Appendix N.
The focus of the study was on four factors associated with application of secondary
backing to the carpet (finishing). The variables, curing oven residence time, curing oven
make-up air, carpet latex loading, and latex type, were selected from a broad spectrum of
potential factors. These particular variables were anticipated to be important based upon the
collective understanding of the participants of their respective products and of the carpet
manufacturing process.
The actual experiment was based upon a two-level factorial design. High and low
levels were selected slightly outside of reasonable operational limits. Routine production at
these operational limits would result in a significant increase in unacceptable products
(discoloration or delamination).
Multiple regression analysis of the TVOC data provided reasonable models. The R2
for the 24-hour model was 0.77, which indicates the variables account for a fair amount of
the variance in the data set. The 1-hour data were also collected, but correlated less well
with the variables studied (R2 = 0.58). The statistically significant process variables were
curing oven residence time and curing oven make up air.
Two additional qualitative observations can be made of the data. The range of TVOC
encountered at 24 hours was 0.174 mg/nfh, which in the view of the study's authors was not
particularly wide considering the test design. The average for the data set (24 hours) was
0.071 mg/m2-h. It was also observed that the emission factors for all samples dropped
significantly between the 1-hour and 24-hour sampling timesthe majority were below 0.100
mg/m2-h. The decline in TVOC is consistent with data obtained in other studies.
The results of the study suggest only limited opportunity for reductions in TVOC
levels in the indoor environment where styrene-butadiene rubber backed carpet is used (in
part because the levels attributable to latex-backed carpet are already low) via these process
factors. For example, the normal operating conditions for this process line are near the
center of the range of variable studied except for make-up air, which is close to the upper
extreme. If it were possible to push the key operating conditions to the "edge," the
estimated reductions in 24-hour TVOC levels would be no more than 20-30 ug/nf-h.
Recognize again, however, that manufacturers would face an unacceptable risk to carpet
aesthetics (more off-shade goods) and obviously higher energy consumption at the most
severe conditions tested.
Broader application of the above statements to other process lines and their resultant
products would, of course, be speculative. Nonetheless, it is important to recognize that
regardless of the specific line orientation and operating conditions, all styrene-butadiene
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rubber backed carpets are taken to a similar endpoint in finishing; i.e., a cured latex, which
is principally the removal of water. It is also very unlikely that a carpet mill will run a
finishing line process in a way that presents the possibility of yielding a "wet" backing out of
the curing oven. The result would be delamination, and, hence, unsalable carpet.
Therefore, one would predict other finishing lines will produce styrene-butadiene rubber
backed carpets with comparable TVOC emission levels to those observed in this study.
Only a few recommendations from this study can be made to the carpet industry. It
might be prudent for carpet mills to evaluate curing oven make-up air to ensure they were
removing water and VOC as efficiently as possible. Increasing oven residence time can be
considered, however, it is recognized this is more difficult to justify given the magnitude of
the reductions (approximately 30 ug/m2-h) predicted by this study. Decisions, of course, will
be mill (process line) dependent and balanced upon factors such as energy consumption,
capacity, cost, yield of first-grade product, etc. Research into reductions of VOC via the
products supplied to the carpet industry is known to be ongoing, but specifics are beyond the
scope of this report.
3.5.5. Process Engineering Subgroup Proceedings
Two technical presentations were given to the Subgroup on carpet manufacturing
process. At the September 26, 1990, Process Engineering Subgroup meeting, the Carpet and
Rug Institute (CRT) presented information on carpet market and carpet manufacturing
process. Also, at this meeting, a report on a laboratory-scale study of carpet oven curing
parameters on VOC emission was distributed by the SBLMC.
At the October 24, 1990, Subgroup meeting, CRI presented some data on an industry
cooperative plant-scale study on the effect of carpet curing oven operating parameters on
VOC emissions. CRI then provided the Subgroup with a draft chapter of the carpet
manufacturing process to be included in the Summary Report. Comments on this draft
chapter were discussed by the Subgroup at the April 8, 1991, Subgroup meeting. It was
suggested that the Summary Report should include a discussion of the market shares of the
various types of carpet fiber, dyeing systems, carpet formation techniques and carpet
finishing alternatives. It was also suggested that the document should include identification
of VOC components in all the manufacturing steps. Some of this information was provided
to the Subgroup by CRI and is included in this document.
The Subgroup endorsed the inclusion of the Air Quality Science (AQS) data on carpet
VOC emission rates (supplied to the Plenary on a confidential basis) in the Summary Report
to provide some perspective on VOC emissions from carpet as well as summaries of the
results obtained from the laboratory scale and plant-scale studies on the effect of carpet
curing oven parameters on VOC emissions from carpet. In addition, it was recommended
that CRI should provide guidance to its members on the impacts of carpet curing oven
parameters on carpet TVOC.
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The Subgroup also discussed potential research suggestions which included a
comprehensive assessment of the contribution of the various sources to carpet TVOC levels
and an evaluation of the feasibility of increasing carpet "airing out" time before shipment,
and increasing carpet curing oven time, temperature and air exchange rates. The information
and research considerations and Subgroup recommendations are cited in detail in sections
3.5.6 and 3.5.7 below.
3.5.6. Information and Research Considerations
The following ideas were raised by some members of the Subgroup considering
information that may help in identifying control measures to reduce TVOC. These
suggestions do not necessarily represent the consensus of the Subgroup. These are presented
as suggestions for future consideration of EPA or industry.
1. A comprehensive assessment of the contribution of the various sources to carpet's
TVOC levels would be useful. For example, how significant are SB latex TVOC
levels to final carpet TVOC levels.
2. Evaluation of the feasibility of increasing carpet "airing out" time before shipment;
and increasing carpet curing oven time, temperature, and air exchange rates.
3.5.7. Subgroup Recommendations to Plenary
1. The Plenary should make a recommendation to the Agency to consider obtaining
an agreement from the CRI to provide guidance to its members on the impacts of
carpet curing oven operating conditions on carpet TVOC.
3.6. CARPET INSTALLATION/VENTILATION
3.6.1. Introduction
This section presents an overview of the carpet installation process along with
applicable guidelines developed by the Carpet and Rug Institute to minimize TVOC
emissions during and after the installation process. The great majority of the information
regarding installation procedures and industry guidance was provided by the Floor Covering
Installation Contractors Association (FCICA). This section also includes information from
presentations by Mr. Hal Levin (ASTM Subcommittee D22.05 on Indoor Air), Mr. Andy
Persily (NIST), Mr. Bruce Tichenor (EPA), and Mr. John R. Girman (EPA), regarding the
relationship between building ventilation rates and indoor air VOC concentrations.
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3.6.2. The Scope of Existing Guidelines for Installation
Until 1982, the floor covering installation trade operated without the benefit of
consistent industry guidelines for installation. The Carpet and Rug Institute undertook the
task of coordinating input from installers, retailers, manufacturers, end-users, testing
laboratories, and others with specialized experience in the field to formulate a written set of
minimum standards known as CRI-104, "Commercial Carpet Installation Standard". In
1990, the Carpet and Rug Institute published CRI-105, "Residential Carpet Installation
Standard". These voluntary guidelines, included as Appendices P and Q, respectively, to this
Summary Report, are becoming the standard accepted by the installation community. They
are increasingly being specified by architects, designers, and carpet specifiers. As
installation methods and product technology have changed, the guidelines have been updated
to reflect these changes. The acceptance of these voluntary guidelines has been enhanced
through the use of the printed inserts included in each roll of carpet by manufacturers, the
development of the Floor Covering Installation Board national certification program primarily
based on compliance with the CRI-104, the development of the multi-industry Floor
Covering Installation Training Council, and the incorporation of the standards into the
training programs sponsored by each segment of the installation community. The standards
have also been embraced by most schools which train installers, inspectors, and claims
adjusters. As the acceptance of these standards broadens, it is becoming increasingly
difficult for installers to operate at levels less than acceptable under these guidelines.
3.6.3. An Overview of the Installation Process
Residential Installation
The residential market comprises well over one half of the carpet manufacturing and
installation industry. The residential installer will usually operate with one helper and will
either be self-employed as an "independent" or as an employee of a residential retail store or
installation firm. The majority of residential installers operate as "independents" and,
although not treated as employees, will be paid by the retailer upon completion of each job.
The typical residential installation occurs in the following sequence:
1. The installer and helper report to a retail store to receive or to competitively bid
(low bid) a job. In the case of an employee installer, the retailer assigns the job to
the installer.
2. The retailer provides the carpet and cushion, work order form, and sometimes a
sketch or diagram. The carpet should be cut to room size at the retail shop or
workroom.
3. The installer loads the carpet and cushion into his vehicle and picks up any
supplies needed for the day at a local tool and accessary distributor. In the case of
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an employee installer, the workroom or retailer will provide the supplies. These
supplies will normally include tackless strip, seaming tape, adhesives, and
sundries. Product selection will be based on previous experience and
recommendation by the supplier.
4. Upon arrival at the customer's home or installation site, the installer will begin
preparation for the installation. This may involve moving furniture, removal of
existing carpet and/or cushion, preparation of the floor, and layout of new carpet.
5. The installation procedure will follow the general guidelines outlined in CRI-105.
Power stretching carpet and sealing all seam edges are procedures now being
monitored more closely and being more widely practiced by installers as the direct
result of industry acknowledgement and acceptance of the CRI-104 and 105
guidelines.
6. Upon completion of the installation, the installer obtains the customer's signature
on the work order and leaves.
Commercial IPn (or Contract
Accounting for less than one half of all installation, commercial installation jobs are
generally either negotiated or obtained through the competitive bid process. The
management of these installations tends to be more complex due to the wide variety of
parties which may be involved on any given project, such as, architects/specifiers, building
owners, general contractors, commercial carpet retailers, and labor contractors. Working
conditions in the commercial installation industry can be very challenging due to construction
time deadlines, maintaining proper environmental conditions, transporting carpet into multi-
story buildings, and compliance with Federal safety and employment standards. A simplified
example of a commercial installation is as follows:
1. A building owner or tenant commissions an architect to design specifications for a
project.
2. The architect develops the specifications and puts the project out for competitive
bids or the owner may negotiate directly with a general contractor. These
specifications will normally include and detail the carpet and installation
procedures. A growing number of specifications require strict adherence to CRI-
104.
3. The general contractor obtains the bid for carpet installation from a dealer who
will either perform the installation or will subcontract the labor to an installation
labor shop.
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4. The dealer orders and receives the carpet, cushion, adhesives, and other supplies at
his warehouse, labor shop, or the job site.
5. The installation crew(s) will transport the materials to the job site or report to the
job site to begin the installation.
6. Once at the job site, the installers will handle floor preparation and begin the
actual installation of the carpet according to the specifications and the installation
instructions provided by the carpet, cushion, and adhesive manufacturers. The job
site conditions are checked prior to the arrival of the installers for excessive
moisture or alkalinity in concrete floors, extreme temperatures, and high humidity
levels.
7. Upon completion of the installation, a walk-through inspection is conducted by the
general contractor and owner. Upon addressing any recommended corrective
measures, the subcontractor receives his final payment. It is common for ten
percent of the subcontractor's bid price to be withheld by the general contractor
until acceptance of the installation.
3.6.4. Training, Education, and Certification Programs
The most comprehensive and consistent installation has been traditionally provided
through joint labor/management apprenticeship training programs. However, only about 15
percent of all carpet installation is performed by union installers. These union programs are
active in many areas of the country and also provide continuous education to the journeymen.
FCICA has estimated that the percentages reflecting employment classifications of installers
would be as follows: 85 percent are independent (self-employed); 10 percent are payroll
employees of bona fide installation firms; and 5 percent are employed by retail dealers. The
challenge of providing education and training to these installers is being addressed by many
organizations and programs. There are vocational school programs offering introductory
instruction in installation; installation schools are being conducted by certified instructors
through the Floor Covering Installation Training Council; clinics and schools are conducted
by the FCICA; independent training schools providing intensive schooling and on the job
training; product manufacturer sales clinics updating product developments; workshops
sponsored by local product distributors and retailers for installers. In addition, videos and
training tools are available which promote professionalism, installation guidelines, and
product application. The FCICA has recently produced a video summary of CRI-105
designed to promote the residential standard and to educate the residential installation
community on the guidelines recommended in the document. Installation firms may
participate in a voluntary certification program by agreeing to submit their firm to the
scrutiny of an independent board of their peers and representatives of the carpet
manufacturing and design communities. In addition, these installation firms agree to abide
by the CRI-104 installation guidelines and to a Ten-Point Plan for Installation Excellence.
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This Floor Covering Installation Board (FCffi) certification program has seen a significant
increase of applications during the past year, and this trend is continuing. The ultimate goal
is to have the program recognized by the entire industry, from the specifier to consumer.
3.6.5. Specific Guidelines Which May Impact VOC Exposures
CRI-104 and CRI-105 both contain sections devoted to environmental and carpet
conditions. The identification of these sections follows:
CRI-104:
page 4/section 5.3
"Conditions - The carpet and adhesive shall be conditioned on site in a heated dry
space at a minimum temperature of 65°F (18°C) and a relative humidity between 10
and 65 percent for at least 48 hours before installation. These conditions shall be
maintained night and day during installation and for at least 72 hours after
completion."
page 7/section 6.4
"Relax Carpet - Whenever possible and conditions permit, all carpet shall be unrolled,
relaxed, and allowed to ventilate with the induction of fresh air."
page 7/section 6.5
"Environmental Conditions - Fresh air ventilation during installation shall be
maintained by opening windows and doors, by utilizing exhaust fans, and by
operating the ventilation fans system at full Capacity. When conditions warrant, fresh
air ventilation shall be maintained after installation for 48-72 hours at normal room
temperatures by operating the ventilation fan system at full capacity and by opening
windows and doors if possible. This will help eliminate the existence of any lingering
odors."
CRI-105:
page 6/Consumer Checklist
"Ventilation... as with most new products, new carpet may initially have a slight
odor. This is normal. Adhesives or hot melt seaming tapes used to install the carpet
may have a slight odor while they are curing. Existing carpet or cushion, while being
removed, may create an odor. All removal or installation processes are best handled
under optimum fresh air ventilation conditions. During installation, be sure that
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windows and doors are open, conditions permitting. Ideally, the heating/air
conditioning/ventilation system should be operating at normal room temperature with
maximum fan speed. If you, a member of your family, or other occupants are
sensitive to certain odors, you may wish to be absent during installation. After the
installation has been completed, you may wish to ventilate the premises with fresh air
by opening windows and doors and operating the ventilation system at normal room
temperature with fan speed at maximum capacity for at least 48-72 hours. This will
help eliminate the existence of any lingering odors."
page 9/Good Customer Relations
"Carpet, cushion and adhesives used for seaming and/or installation often have a
slight odor while they are curing. This is normal. However, if the customer
expresses a sensitivity to these odors, be sure to recommend that the windows be kept
open and that the ventilation system continue to operate at full fan speed for at least
48-72 hours after the installation has been completed. Settings of the heating/air
conditioning system should be left at normal room temperature levels. This will help
eliminate the existence of any lingering odors."
page 24/Specific Reference Section
"6. Environmental Conditions - Fresh air ventilation during installation shall be
maintained by opening windows and doors, by utilizing exhaust fans, and by
operating the ventilation fan system at full capacity. When conditions warrant, fresh
air ventilation shall be maintained after installation for 48-72 hours at normal room
temperatures by operating the ventilation fan system at full capacity and by opening
windows and doors if possible. This will help eliminate the existence of any lingering
odors. Be sure that the room is adequately ventilated while you are working.
Windows and doors should be opened. The ventilation system should operate at full
fan speed. Utilize plenty of fresh air."
3.6.6. Practical Experience In Compliance With Installation Guidelines
Meeting the ventilation guidelines of the standards is often hindered by factors beyond
the control of the installer. Residential installations historically are more generous in the
opportunities to provide fresh air ventilation and air circulation. However, in severe weather
conditions, opening windows is impossible if other necessary environmental conditions are to
be maintained. In commercial installations, the installer is often faced with severe time
deadlines, the absence of proper ventilation systems, and conducting the installation in
occupied buildings. Maintaining full ventilation for 48-72 hours following the installation
cannot be guaranteed by the installer. However, it is a guideline which can be, and is,
recommended for the customer or owner.
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The process of conditioning the carpet and allowing it to be unrolled and to "relax" is
limited by time deadlines and other factors. The carpet is usually unrolled to be inspected,
measured, and cut for the specified areas prior to being delivered to the job site.
3.6.7. Effects of Ventilation During Carpet Installation on VOC Emissions
The purpose of this section is to define the relationship between building ventilation
rates and indoor air VOC concentrations, report on ventilation rate studies in selected
buildings, set forth the physical processes involved when VOCs are emitted from carpet
assemblies as well as the factors affecting these processes, and to provide some practical
control strategies for carpet system VOC emissions.
3.6.7.1. Indoor Air Quality (H. Levin, ASTM Subcommittee D22.0S on Indoor Air, April
9, 1991)
The graph in Figure 3-8 demonstrates the theoretical relationship between building
ventilation rates in Air Changes Per Hour (ACH) and indoor air VOC concentration. The
graph shows curves for three different source strengths.
It is known that increased ventilation or ACH will reduce pollutant levels, but the
graphical relationship makes it clear that there is a point of diminishing return and a section
of the curve on either side of the vertex where the maximum reduction in VOC concentration
can be achieved with the minimum increase in ACH. For weak sources, this point of
maximum pollutant reduction will be at lower ventilation rates than for strong sources. This
range of ventilation rates or ACH will vary from situation to situation but once defined will
serve to optimize the change in ACH required to reduce VOC concentrations to acceptable
levels. Most buildings operate in the range of 0.6 to 1.5 ACH.
3.6.7.2. Ventilation in Office Buildings: Studies by the National Institute of Standards
and Technology (A. PersUy, NIST, April 9, 1991)
Ventilation rate studies were conducted on both new and existing office buildings.
Findings included frequent discrepancies between designed ventilation rates and measured
values; considerable influence of outdoor climate conditions on ventilation; and common
ventilation system operational problems during construction. Operational problems are also
common after construction.
Figure 3-9 is a flow diagram of a typical building ventilation system. In many of the
buildings tested, infiltration was found to be of the same order of magnitude as the air intake
rate. Thus, in similar cases, pollutant levels will be better reduced by source reduction than
change in ventilation.
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FIGURE 3-8
VENTILATION RATES
AND INDOOR AIR VOC CONCENTRATION
Strong source
Normal source
I
2
I
5
1.5
Most buildings
in this area.
Ventilation (Air changes/hour)
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FIGURE 3-9
FLOW DIAGRAM OF A TYPICAL BUILDING
VENTILATION SYSTEM
OUTDOOR
AIR INTAKE
SPILL AIR
INFILTRATION
REC1RCULAT10N
AIR
SUPPLY AIR
RETURN AIR
BUILDING
VOLUME
EXF1LTRAT1C*
AND EXHAUST
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Figure 3-10 shows actual air exchange rates in the Portland East Federal Office
Building. The graph demonstrates the considerable influence of outdoor climate conditions
(temperature differentials) on ventilation.
Figure 3-11 summarizes actual exchange rates found in buildings studies by the
National Institute of Standards and Technology (NIST). Design values of minimum outdoor
air intake rates were found to vary from .36 to 1.7 air-changes-per-hour.
Figure 3-12 presents the distribution of air exchange rates in the buildings studied by
NIST. Forty percent of the measured air change rates were below the minimum design
specifications for outdoor air intake. The same percentage of the measured rates was below
20 CFM/person, the recommendation contained in the ASHRAE Standard 62-1989.
Actual ventilation rates and design rates were found to vary as a result of:
Conditions during construction,
Deviation from design, and
Building-to-building and within-building variability.
Because of the common differences between design and actual ventilation rates, one
needs to consider carefully the reliance on ventilation for pollution control, during
construction including carpet installation. Examples of important issues to consider regarding
ventilation rates are:
Fans
- Is the fan on or off?
- Is the fan operating in the proper direction?
- Is the impeller turning with the motor?
Airflow rates
- Is there a restricted supply?
- Is the outdoor air intake blocked?
Dampers
- Are the dampers in the proper position?
- Are the dampers in a fixed position and properly balanced?
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3-99
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FIGURE 3-11
SUMMARY OF AIR EXCHANGE RATES
IN BUILDINGS STUDIES BY NIST
CESIGN faen) MEASURED
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3-101
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Control system
- Is the control system operating?
- Is the control system sensor calibrated and operating?
It is clear that one cannot assume that a building is being ventilated or can be
ventilated at a stated rate. This is an even less valid assumption early in the life of the
building.
3.6.7.3. Effects of Ventilation Rates on Indoor Air Concentrations of
4-Phenylcyclohexene from Carpet Emissions (B. Tichenor, EPA, April 9, 1991)
The effects of ventilation rates and conditioning times on indoor concentrations of
4-phenylcyclohexene emitted from carpets were studied assuming first-order emission rate
decay:
EF = EF0(e-h).
From curves based on the EPA study of Waterside Mall carpet (B. Tichenor, August
25, 1988):
EF0 = 0.15 mg/m2 hr
k = 0.0036 hr'
From the AQS study of 19 carpet samples:
EF0 = 0.03-0.20 mg/m2 hr
k = 0.0034-0.018 hr1
The effect of air exchange rate (outside air) on 4-phenylcyclohexene concentration
over time is shown in Figure 3-13. The effect of conditioning times or airing out prior to
installation is shown in Figure 3-14. ACH was held constant at 1.0. The preliminary
conclusions derived from the study, which is contained in Appendix R, are:
Increasing the air exchange rate (outside air) will reduce the indoor levels of
4-phenylcyclohexene from carpets.
Airing out new carpet prior to installation will reduce indoor levels of
4-phenylcyclohexene.
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3.6.7.4. General Concepts of Physical Processes Affecting VOC Carpet Emissions
J. Girman, EPA, April 9, 1991)
There are a number of physical processes involved when VOCs are emitted from
carpet assemblies as well as factors affecting these processes. These processes include:
Diffusion - movement of matter in the absence of bulk flow. Diffusion is a weak
function of temperature and is also dependent on:
- Concentration difference between the carpet system and the indoor air
- Distance over which diffusion occurs; and
- Chemical characteristics of the contaminant such as molecular size.
Evaporation - driving force is vapor pressure. Figure 3-15 shows the significant
relationship between temperature and vapor pressure for selected compounds.
Figures 3-16 and 3-17 portray evaporation under equilibrium conditions and
accelerated evaporation in the process of increased contact air velocity,
respectively.
Adsorption - carpet will sorb materials other than those inherent in the carpet
manufacturing process (e.g., paint). For this reason, the location of carpet storage
is extremely important.
3.6.7.5. Practical Control Strategies for Carpet System VOC Emissions and Residual
Indoor Air Concentrations (H. Levin, ASTM Subcommittee D22.05 on Indoor
Air, April 9, 1991)
It is clear that ventilation can have a major role in efforts to minimize VOC emissions
from carpet systems in new construction and renovation projects. Practical control strategies
include:
Careful product selection based on knowledge of product performance;
Product modification;
Pretreatment prior to installation;
Changes in installation procedures;
Changes in ventilation system operating procedures;
Treatment in situ through the bake out process; and
Use of air cleaning techniques to control air contaminants.
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FIGURE 3-15
TEMPERATURE AND VAPOR PRESSURE
RELATIONSHIP FOR THREE COMPOUNDS
Vapor Pressure (torr)
20°C
40°C
40°C
20°C
Ethanol
43.9
135.3
3.08
Water
17.5
55.3
3.16
Toluene
22.3
59.1
2.65
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FIGURE 3-16
EVAPORATION UNDER EQUILIBRIUM CONDITIONS
vapor
3-107
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FIGURE 3-17
ACCELERATED EVAPORATION IN THE PRESENCE
OF INCREASED
CONTACT AIR VELOCITY
vapor
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Adequate ventilation before, during, and after installation of carpet system will
mitigate TVOC emissions.
3.6.8 Process Engineering Subgroup Proceedings
Several presentations were given to the Process Engineering Subgroup on carpet
installation and the effects of ventilation on VOC emission during carpet installation process.
At the September 26, 1990, Subgroup meeting, The Floor Covering Installation
Contractors Association (FCICA) presented some information on installation methods,
installation parameters, and installation guidelines.
At the April 8, 1991, meeting, several presentations on the effects of ventilation on
VOC emissions during carpet installations were given to the Subgroup. Hal Levin
representing ASTM presented information on the relationship between building ventilation
rates and indoor air VOC concentrations and discussed practical control strategies for
controlling carpet system VOC emissions. Andy Persily of NIST reported the results of an
NIST study comparing actual versus design ventilation rates in selected Federal Office
Buildings. Bruce Tichenor and John Girman of EPA presented information on the effects of
ventilation and conditioning times on indoor concentrations of 4-phenylcyclohexene and
general concepts of physical processes affecting VOC carpet emissions. In general, the
presenters indicated that ventilation can have a major role in efforts to minimize VOC
emissions from carpet systems.
It was recommended that the Carpet and Rug Institute (CRI) and FCICA should
expand their efforts to educate carpet installers through FCICA's ten-point education
program. It was also recommended that the CRI/FCICA should encourage all carpet
outlet/retail store owners to use installers who have been through FCICA's installation
program and communicate to all their installers about the importance of proper installation
procedures and encourage them to adhere to CRI installation guidelines.
The Subgroup considered a recommendation to obtain commitment from CRI and
FCICA to develop a program to educate customers about the recommended installation
guidelines and potential impacts of installers not abiding by them. Additionally, the
Subgroup considered a recommendation to obtain commitment from CRI and FCICA to
develop standard contract/bid conditions which will provide for additional money or time to
allow installers to comply with installation guidelines if architects, engineers, or owners do
not provide appropriate circumstances for compliance.
The Subgroup considered an evaluation of the quantitative impacts of not following
specific installation procedures on carpet system TVOC exposures as an information
suggestion for future consideration by the Plenary.
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The information/research considerations and Subgroup recommendations are cited in
detail in sections 3.6.9 and 3.6.10 of this document.
3.6.9. Research Consideration
The following idea was raised by some members of the Subgroup considering
information that may help in identifying control measures to reduce TVOC. This suggestion
does not necessarily represent the consensus of the Subgroup. It is presented as a suggestion
for future consideration of EPA or industry.
1. An evaluation of the quantitative impacts of various installation procedures on
carpet system TVOC exposures.
3.6.10. Subgroup Recommendations to Plenary
1. The Plenary should make a recommendation to the Agency to encourage CRI and
FCICA to study the impact of various installation procedures on carpet system
TVOC exposures, with the results to be shared with EPA.
2. The Plenary should make a recommendation to the Agency to consider obtaining a
commitment from CRI and FCICA to further develop industry-wide
communications programs which educate installers about the importance of proper
installation procedures and encourage them to adhere to CRI installation
guidelines. These programs should also target as many installation contractors as
possible.
3. The Plenary should make a recommendation to the Agency to consider obtaining a
commitment from CRI and FCICA to develop a program to encourage that all
carpet outlet/retail store owners require their installers to be certified.
4. The Plenary should make a recommendation to the Agency to consider obtaining a
commitment from CRI and FCICA to develop a program to educate customers
about the recommended guidelines and the potential impacts of installers not
abiding by them.
5. The Plenary should make a recommendation to the Agency to consider obtaining a
commitment from CRI and FCICA to develop standard contract/bid conditions
which will provide for additional money or time to allow installers to comply with
installation guidelines if architects, engineers, or owners do not provide
appropriate circumstances for compliance.
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6. The Plenary should encourage NIOSH to become involved in carpet installation
worker training programs sponsored by CRI and FCICA.
7. The Plenary should encourage OSHA to review CRI carpet installation guidelines
for consistency with ongoing OSHA programs.
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CHAPTER 4
Public Communications Subgroup:
Report to the Carpet Policy Dialogue
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4.0. PUBLIC COMMUNICATIONS SUBGROUP REPORT
4.1. INTRODUCTION
This chapter provides an overview of the Public Communications Subgroup activities
in response to the Federal Register notices (55 FR 17404; 55 FR 31640) about the Carpet
Policy Dialogue and the objectives set by the Carpet Policy Dialogue Plenary. It describes
the topics discussed, concerns addressed, and products developed by the Subgroup.
The Public Communications Subgroup was established at the request of the Carpet
Policy Dialogue Plenary on January 8, 1991. The purpose of the Subgroup was to serve as
the common voice for the Carpet Policy Dialogue. The Public Communications Subgroup
made recommendations to the Carpet Policy Dialogue Plenary on the type of information to
be communicated to the public. It also identified strategies and mechanisms by which such
information could be assembled and disseminated. The Subgroup's activity was focused on
communicating outside the Dialogue.
The Subgroup provided a forum for discussion and resolution of general and specific
issues of concern to the public communications effort. It offered opportunity for review and
incorporation of comments on various products prepared on behalf of the Carpet Policy
Dialogue. General activities of the Subgroup included administration of Carpet Policy
Dialogue Plenary reports, message development, and conveyance strategy. Another function
of the Subgroup was drafting, assembly, and review of products, materials, and information
presented to and discussed by Dialogue participants. The Subgroup provided a means to
bring consistency to the reporting of the wide spectrum of materials developed during the
Carpet Policy Dialogue year.
The Subgroup included standing representation from EPA, other Government
agencies, labor, industry, and public interest groups. In addition, the Subgroup sought
assistance, as needed, from ad hoc consultants with special expertise in communications.
The composition of the Subgroup included expertise in public communications,
communications strategy, public education, environmental protection, consumer product
safety, indoor air quality, carpet and carpet floor covering product manufacture, carpet
installation, and carpet product testing. Members of the Public Communications Subgroup
are listed in Appendix A.
The Subgroup held six meetings. The themes of these meetings were:
Meeting #1 2/27/91 Introduction and Overview
Meeting #2 4/8/91 Message Development
Meeting #3 5/21/91 Implementing Outreach Communications
Meeting #4 6/27/91 Proposed Brochure Development
4-1
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Meeting #5 7/30/91 Compendium Report Assembly
Meeting #6 9/26/91 Compendium Report Review
4.2. SCOPE OF WORK
During the initial meetings, the Public Communications Subgroup set goals,
established operating procedures, developed criteria that would govern the nature of materials
developed during the Dialogue year, and identified discussion topics for consideration during
their deliberations. These discussions determined the scope of work and breadth of the
public communications activities for the Subgroup.
4.2.1. Setting Goals
The Subgroup identified two goals. The first goal was to satisfy the requirements of
the Efidfioi Register notices (55 FR 17404; 55 FR 31640). However, in referring to the
Federal Register, the Subgroup noted that the only requirement stated was for the Dialogue
to provide the interested public with comparative information on TVOC emissions based on
information developed from voluntary product testing program(s). One option for
communicating such information included the use of product labeling. The Federal Register
provided no further direction to the Subgroup about the extent of public communications
activities for the Carpet Policy Dialogue.
The Subgroup acknowledged that it would be difficult to follow the requirement set
by the Federal Register due to the lack of available information about TVOC emissions for
carpet floor covering products. It was apparent to the Subgroup that only preliminary data
about TVOC emissions from carpet floor covering materials might be available before the
conclusion of the Dialogue year. The Subgroup concluded that it was not prudent to
communicate such information as it could convey a false message or be misinterpreted. In
view of this dilemma, the Subgroup adopted the approach that the interested public be
provided with useful information about the Carpet Policy Dialogue, accomplishments that
occurred during the Dialogue year, and a description of follow-on activities.
The second goal set by the Subgroup was to review and recommend for approval by
the Carpet Policy Dialogue Plenary communication materials prepared by the Subgroup
during the Dialogue year. In relation to these goals the Subgroup identified a series of
communication products that could be developed to convey information to the interested
public. These included: 1) an interim progress report to the FJ»A, 2) an executive summary
suitable for release to the interested press, 3) a public information brochure or leaflet, and 4)
a compendium report summarizing information from the Carpet Policy Dialogue.
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4.2.2. Operating Procedures
The development of draft communication materials was a collaborative effort among
Subgroup participants. Finalizing communication products was an interactive process shared
between the Public Communications Subgroup with the Carpet Policy Dialogue Plenary.
EPA staff coordinated these activities.
As the Subgroup identified the need for a communication product, Dialogue
participants forwarded their initial thoughts to EPA staff who were responsible for compiling
these draft materials and assembling them in a logical flow. Wherever possible, draft
materials underwent a review cycle prior to discussion at scheduled meetings. Comments
received from these reviews were given consideration and incorporated into subsequent
drafts. Draft documents were further embellished during discussions at Subgroup meetings.
Documents endorsed by the Subgroup were forwarded to the Plenary for approval. Text
revisions developed during discussions at Plenary meetings were an essential component in
establishing consensus agreement for the public communications products developed during
the Dialogue year.
4.2.3. Principles Governing Dialogue Communication Activities
The Subgroup established principles to guide the development of Subgroup products.
Recognizing that most of the information developed during the Dialogue year would be of a
technical scientific nature, the Subgroup sought to include lay language that was
understandable to the general public wherever possible. Furthermore, the Subgroup accepted
the responsibility that clear reporting was needed to explain that the purpose of the Carpet
Policy Dialogue was to reduce exposure to volatile organic compounds, encourage pollution
prevention, develop a standard analytical test method, and encourage industry to test and
report TVOC measurements for carpet floor covering products. It was equally important to
communicate that the mission of the Carpet Policy Dialogue did not include an evaluation of
health concerns or fostering a correlation between TVOC measurements with potential impact
on public health.
Another governing principle adopted by the Subgroup was that reports and other
materials developed for the Carpet Policy Dialogue should focus on facts. The Subgroup
agreed that it was appropriate for these reports to identify information gaps since, in many
instances, Dialogue discussions addressed the frontier of analytical science. In conjunction
with this, the Subgroup acknowledged its responsibility that new concepts such as TVOC
should be fully explained and that there was a need to communicate the scientific rationale
for the use of TVOC measurements of consumer products in relation to indoor air quality
and consumer choice.
The Subgroup also developed guiding principles about the content and use of public
communication materials developed during the Dialogue year. The Subgroup expressed the
4-3
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desire that information about the Carpet Policy Dialogue should reflect the positive aspects of
a diverse group of concerned organizations that collaborated in a voluntary framework. As
such, the focus of public communications products would be on the many accomplishments
of the Carpet Policy Dialogue rather than a critique of the process. The Subgroup
understood the value in selecting appropriate wording to convey messages that would be clear
and specific. Furthermore, the Subgroup accepted the principle that preliminary data
submitted in confidence to the Carpet Policy Dialogue for deliberative discussions and draft
materials of reports and other document materials would not be released for public
distribution prior to the approval of the Carpet Policy Dialogue Plenary.
Finally, the Subgroup accepted the principle that participation in the Carpet Policy
Dialogue, Public Communications Subgroup would not preclude any group or organization
(governmental and nongovernmental) from activities which they deemed necessary and
important to carry out their organization's mission to communicate with their constituency or
the interested public. The Subgroup viewed the products to be developed for the Carpet
Policy Dialogue as a resource to assist other organizations in developing factual information
about the topics addressed during the Dialogue year.
4.2.4. Discussion Topics
As part of the scoping activities that took place during the initial Public
Communications Subgroup meetings, the Subgroup referred to materials prepared by the
Plenary during the convening meeting for the Carpet Policy Dialogue on August 21, 1990.
This consisted of a list of questions and discussion topics prepared by the Plenary for the
Public Communications Subgroup to consider in addressing its mission. The list included
general questions such as: what would be the best forum/form to communicate information;
how could information be communicated in a positive fashion; what is the public's need for
information about TVOCs; what communication channels already exist to disseminate
information; and what are the economic considerations related to communicating. Other
topics included scientific and technical issues such as: what is a VOC; what is the relevance
of VOC measurements; what is the role of odor and irritation; and what is the relevance of
ongoing research. The handout used by the Subgroup for this discussion is included as
Table 4.1.
The Subgroup reviewed items on this list and observed that many of the questions and
topics were relevant to the charge set in the Federal Register. They noted that the items
listed could be used to spur discussion at future meetings and guide in the preparation of the
various communications products developed during the Dialogue year.
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TABLE 4-1
TENTATIVE LIST OF DISCUSSION TOPICS FOR THE
PUBLIC COMMUNICATIONS SUBGROUP'
What information to convey?
Message options: brochure/booklet/label/ad campaign/nothing
What do the numbers mean?
What is the impact of environmental factors on VOC emissions (like ventilation)?
Identify the target audience(s).
What is the impact of installation technology?
What are the cost impacts?
What is the best forum/form to communicate this information?
Why has research been done?
How to communicate in a positive, nonprejudicial fashion?
What about aesthetic factors?
How/where to get more information?
Should there be an overall strategy for TVOC communication?
What is the nature of VOCs - What is a VOC?
Why do people need to know about VOCs?
Look to other communication models that provide the public with information
(e.g., fuel efficiency, construction industry).
Relate this information to something the public knows about.
List constituents in products.
Identify current information and communications materials already available (e.g.,
advertising).
This material was prepared for discussion by the Public Communications Subgroup at a meeting held
on February 27, 1991. It was developed from a list which was compiled by the Carpet Policy
Dialogue Plenary on August 21, 1990.
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4.3. COMMUNICATIONS PLANNING
Preparing a communication plan is a multifaceted process. The Public
Communications Subgroup identified 10 steps common to developing any communications
plan and addressed these steps in identifying a communications strategy for the Carpet Policy
Dialogue. These steps are depicted in Figure 4.1. The following discussion highlights the
deliberative considerations of the Public Communications Subgroup relevant to the
communications planning process.
4.3.1. Step 1: Situation Analysis
The Subgroup identified several factors that would influence the distinctive
characteristics and shape of the Carpet Policy Dialogue communications effort. These
included: a) the sparsity of available information about TVOC emissions from carpet and
carpet floor covering products; b) the nature of a voluntary communications effort; and c) the
ability of the general public to grasp scientific concepts about TVOCs.
As noted previously, the Subgroup acknowledged that data about TVOC emissions
from the voluntary product testing programs would not be available before the close of
Carpet Policy Dialogue activities. The Subgroup viewed that preliminary data would not
have sufficient merit to fill in this information gap. Therefore, development of public
information messages would, of necessity, be focused on the findings and outcomes from the
Product Testing and Process Engineering Subgroups.
The cost associated with development and distribution of communication products are
always a limiting determinant in measuring the extent of a communications plan. This is
most apparent in voluntary efforts. The Subgroup agreed to identify opportunities that
encouraged voluntary involvement among Dialogue participants. In doing so, the Subgroup
attempted to provide useful information developed from the Carpet Policy Dialogue to a wide
variety of audiences.
There was some concern expressed among the Subgroup that the general public would
have difficulty understanding the concept of, or information about TVOCs. It was
determined that a better understanding about volatile chemicals might be communicated if an
analogy was made with the concept of off-gassing. The point was made that even the term
"volatile organic compound" carried with it an explosive connotation which could cause
needless alarm in the minds of the uninformed public.
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Figure 4-1
Communications Planning Process
Step One
Conduct
Situation
Analysis
Step Three
Identify
Target
Audiences
Step Nine
Set Time-Table
and
Implement
Plan
The
Communication Plan
^^ ^ lueiiiuy
^V^ \ Issues ar
X^ V Values
Step Six
Establish
Strategy
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4.3.2. Step 2: Set Objectives
The objectives set by the Subgroup paralleled the governing principles for
communicating to the public. The Subgroup proposed that it communicate to the public:
A summary of the accomplishments of the Carpet Policy Dialogue;
An explanation of why the Carpet Policy Dialogue undertook its work;
Facts about carpet, carpet floor covering products, and VOC emissions;
A context for these facts and explanation without interpretation; and
How this information was relevant to and could be used by the interested public.
4.3.3. Step 3: Identify Target Audiences
It was difficult for the Subgroup to set boundaries for the target audiences that could
benefit from information developed during the Dialogue year. For example, it was clear that
the consumer of carpet floor covering products would include residential and commercial
consumers, and that professionals such as architects and interior designers should also be
viewed as consumers. Employees of manufacturers, retailers, and installers were included in
another category of individuals who could benefit from information. Still another category
included health care professionals and regulatory scientists. Finally, the Subgroup also
included people who inadvertently find themselves in carpeted areas. In conclusion, the
Subgroup identified the target audience to include:
The consumer of carpet floor covering for personal use;
The consultant who recommends selection of carpet floor covering to the
consumer;
People who occupy carpeted spaces;
People who advise the public relevant to carpet floor covering; and
People involved in the carpet floor covering trade.
The Subgroup recognized that the technical expertise to communicate with such a diverse
audience resided within various Government, trade, and public interest organizations.
Furthermore, any effort to reach such a broad spectrum target audience would require a
variety of communication products specifically focused to the training and interests of the
audience to be addressed.
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4.3.4. Step 4: Identify Issues and Concerns
The Subgroup acknowledged that although health concerns would be among the
subjects that would occupy public interest, the Federal Register specifically noted that the
Dialogue should "not further characterize the health effects of chemicals emitted from
carpeting." The Subgroup did recognize that a public communication message which did not
include factual information about the diversity of opinion on this subject would not be
acceptable at this time. The Subgroup addressed these concerns from the viewpoint of
improvements to indoor air quality, adequate ventilation, and public lifestyle choice, with the
understanding that an educated consumer would have a better opportunity to make an
informed choice.
4.3.5. Step 5: Develop Messages
Developing messages to inform the interested public about the Carpet Policy Dialogue
was a collaborative effort. The governing principle for this activity was to focus on
accomplishments. These were listed and incorporated into an Executive Summary. To
develop a common message about the findings of the Carpet Policy Dialogue, the Subgroup
took a broader view which included information about indoor air quality, carpet chemical
emissions, actions that could minimize exposure following installation of new carpet floor
covering, and identification of information resources. The Subgroup also acknowledged the
importance of developing messages that told the interested public about the variety of
voluntary product testing programs that would be set in place during the Dialogue year.
4.3.6. Step 6: Establish Strategy
The dynamic nature of the Carpet Policy Dialogue, the multitude of ongoing
activities, and the special interests brought into play necessitated that communications
products be multi-tiered and developed by a variety of mechanisms. The Subgroup
acknowledged that communication products would include materials developed directly by the
Subgroup, collaborative efforts of the Public Communications Subgroup in partnership with
participating organizations at the Dialogue, or as separate communications efforts within
Government, industry, and/or the public sector. The prime strategy adapted by the Subgroup
was to develop factual information that could be used as a source reference describing the
Carpet Policy Dialogue.
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4.3.7. Step 7: Select Media/Products
The written word became the media of choice for the Carpet Policy Dialogue. As
noted previously, four products were identified. These included: an Interim Progress Report,
an Executive Summary, a public information brochure, and a compendium report.
4.3.8. Step 8: Determine Budget
Resource issues were considered within the voluntary framework of the Carpet Policy
Dialogue. The Subgroup made every effort to prioritize activities and products on the basis
of how well they would fit into a voluntary process. Primary consideration was given to the
development of products such as the Compendium Report which could be distributed via the
EPA TSCA Hotline and the National Technical Information Service. The Public Information
Brochure was developed with the thought that it could be easily reproduced by the interested
public. Some industry representatives implied that limited resources might be available to
distribute the brochure to carpet retailers. The Subgroup concluded that in the end,
distribution of these products would be via standard mechanisms traditionally used by
Government, industry, and the public sector. Much of this would be dictated by the most
expeditious and cost efficient means for distributing the materials and the nature of voluntary
commitments.
4.3.9. Step 9: Set Time Table to Implement Plan
It became evident early in the public communications effort that there was an
immediate need for the Carpet Policy Dialogue to communicate about the nature of its
activities. This immediate need was met with the completion of the Interim Progress Report
in April. The time table for developing other Dialogue products was determined by the
schedule set by the Federal Register. The EPA provided resources and staff to finalize
Dialogue products after the September 27, 1991, meeting. A notice of availability of the
Compendium Report and the Public Information Brochure in the Federal Register marked the
conclusion of this activity.
4.3.10. Step 10: Evaluate Results
The Subgroup acknowledged that a communications effort, by necessity, is an
evolving process which can not always be confined to time constraints such as the Dialogue
year. An effective public communications effort on a subject such as this requires
assessment and reevaluation on an ongoing basis. Since the Public Communications
Subgroup would be discharged of their duties at the conclusion of the Dialogue, no provision
was made for follow-on activities by the Carpet Policy Dialogue. The Subgroup concluded
that communication activities would include reporting information developed during the
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Dialogue year only. The Public Communications Subgroup recommended to the Plenary that
the EPA review the need for providing the interested public with additional information after
it has had an opportunity to review data developed from the various testing programs.
4.4. PUBLIC COMMUNICATION OUTREACH PRODUCTS
Communication outreach products developed by the Subgroup were the result of
cooperative efforts on the part of all participants. A list of potential products was developed
during the initial meeting of the Subgroup (Table 4.2). The feasibility of developing various
communications products was evaluated, and the list was prioritized.
The Subgroup learned by experience. As work commenced on the initial
communications outreach products, the Subgroup identified additional opportunities for
communicating. The shape of some communication outreach products evolved as materials
were developed by the Subgroup. Preliminary draft documents initially conceived as fact
sheets, became resource models to guide other organizations. These products gradually
developed into a final format as an executive summary or a public information brochure.
Relations with the press were governed by the principles established by the Carpet
Policy Dialogue Plenary at the convening meeting held on August 21, 1991. As such, the
Subgroup chose not to prepare press announcements. The Subgroup acknowledged that
summary materials (i.e., Executive Summary) would be useful to those individuals and
organizations who bore the responsibility of communicating with the interested public.
Announcements in the Federal Register, prepared by the project sponsor (EPA), which
marked Carpet Policy Dialogue accomplishments were deemed appropriate.
The Subgroup determined that involvement in the preparation of a summary booklet(s)
about the voluntary industry testing programs set in place during the Carpet Policy Dialogue
year would not be an appropriate activity to pursue. Since the focus of such materials would
be the carpet trade, the Subgroup recognized that such products would be better left to the
various industries and representative organizations. Such organizations have full access to
their membership and have existing mechanisms to communicate with their constituency via
trade press and newsletters.
The Subgroup and the Carpet Policy Dialogue explored the feasibility of developing
an annotated bibliography on the subjects of carpet and carpet floor covering products,
indoor air quality, and related concerns about volatile organic compound emissions from
carpet floor covering materials, and carpet floor covering product VOC emissions testing.
While steps were initiated to compile such a bibliography, the Dialogue found itself ill
prepared to complete this activity by the close of the Dialogue year. Nevertheless, the
Dialogue Group agreed that such a bibliography would prove a useful resource for the
interested public. At a meeting held on September 27, 1991, the Dialogue recommended that
EPA continue this
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TABLE 4-2
POTENTIAL PUBLIC COMMUNICATIONS OUTREACH PRODUCTS'
Interim reports and/or memoranda to the project sponsor (EPA) that mark Carpet
Policy Dialogue progress in accomplishing the objectives described in the Federal
Register:
A compendium of information received during the Dialogue year with explanation
of findings, conclusions, and recommendations;
An Executive Summary of the compendium information written in layman
language for the general public;
Summary booklet(s) focused to the carpet trade describing the voluntary industry
testing programs set in place during the Carpet Policy Dialogue year;
Public booklet/guide/brochure to provide interested consumers with information
on VOC emissions and carpet products, indoor air quality, and information about
carpet installation; and
A series of press releases to mark Dialogue year milestones and highlight the
various voluntary actions proposed by industry.
This table was developed from materials prepared for discussion by the Public Communications
Subgroup at a meeting held on February 27, 1991.
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activity and use the draft materials developed by project staff as the basis for such a
bibliographic listing. They further suggested that this information could be made available
from the Carpet Emissions Administrative Record and/or the proposed indoor air
clearinghouse.
All products developed by the Subgroup were reviewed and approved for distribution
by the Carpet Policy Dialogue Plenary. There were four outreach products developed by the
Public Communications Subgroup. These included an interim progress report, an executive
summary of Carpet Policy Dialogue accomplishments, a public information brochure, and a
compendium of the Carpet Policy Dialogue. What follows is a description of these products
which includes explanation of the considerations and deliberative actions by the Subgroup.
4.4.1. Interim Progress Report
At a meeting held on February 27, 1991, the Subgroup agreed to prepare an Interim
Progress Report. In doing so, the Public Communications Subgroup acknowledged that it
was timely for the Carpet Policy Dialogue to inform the interested public about the initial
accomplishments taking place at the Carpet Policy Dialogue. Preparation of this report
would also provide an opportunity to begin drafting materials that could be inserted into the
Compendium Report at the conclusion of the Dialogue year. Furthermore, the Subgroup
determined that the Interim Progress Report would serve to communicate to the project
sponsor (EPA) on the progress achieved by the Carpet Policy Dialogue midway through the
Dialogue year and also inform the interested public and various media about the activities of
the Carpet Policy Dialogue.
The Subgroup provided guidance to the project staff in preparing the initial draft of
the report. The outline of the report was to include introductory materials describing the
background, implementation, structural organization, and working mechanisms of the Carpet
Policy Dialogue. It would also include a description of the accomplishments to date and an
overview of the activities of the Subgroups.
Participants of the Public Communications Subgroup were asked to provide project
staff with a list of accomplishments and materials which they thought should be included in
the Interim Progress Report. These materials were incorporated into a draft document and
made available to the Subgroup for discussions at the April meeting. Comments and
revisions made by the Subgroup were incorporated into a revised draft which was reviewed
at the Carpet Policy Dialogue Plenary meeting on April 11, 1991.
It was necessary for project staff to request that a cut-off date be established for the
inclusion of Dialogue accomplishments in the Interim Progress Report because activities of
the Carpet Policy Dialogue were moving at such a rapid pace. The Plenary concurred that
this was necessary in order to expedite this communications product. Therefore, it was
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determined that the report would be inclusive of the activities that took place between August
21, 1990, and April 10, 1991.
Comments and revisions made at the April Carpet Policy Dialogue Plenary meeting
were incorporated into a revised draft. Additional comments and revisions were made to the
document at the May meetings. The Interim Progress Report was approved by the Carpet
Policy Dialogue Plenary at the June meeting. The final document was ready for distribution
in July and the report was transmitted to the EPA. Availability of the report was announced
in the Federal Register on August 9, 1991 (FR 56 37912).
4.4.2. Executive Summary
Following the initial review of the Interim Progress Report, the Subgroup identified
the need for a general summary about the work of the Dialogue. The goal set by the
Subgroup was to develop a communication product that would be factually informative and
deliver a complete message about the Carpet Policy Dialogue to the reader in only a few
minutes time. Furthermore, the Subgroup agreed that this communication product would be
a concise document more in the form of a fact sheet and specified that it should not be longer
than two pages.
As such, the Subgroup agreed that it would be a useful means to inform the trade or
popular press and should, therefore, be written using layman terminology. The Subgroup
also identified this product as a potentially helpful document for participating organizations in
the Dialogue to use as a means to inform their constituencies about the work of the Dialogue.
In addition, they concurred that it might form the basis for press releases which could be
written by Dialogue participating organizations.
The initial draft of this communication product was made available to the Subgroup at
the May meeting. It was revised and submitted to the Carpet Policy Dialogue Plenary on
May 22, 1991. Further revisions were made at that time, and the Plenary agreed that the
final document would be incorporated into the Interim Progress Report as an Executive
Summary. EPA Project Staff noted that the Executive Summary proved a useful document
when responding to inquiries from trade press or the interested public who sought
information about the progress of the Carpet Policy Dialogue.
As part of the Compendium Report assembly, the materials prepared for the Interim
Progress Report were updated by the Carpet Policy Dialogue at meetings held on September
26 and 27, 1991. The revised Executive Summary is included at the beginning of this
Compendium Report.
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4.4.3 Public Information Brochure
At the April meeting, the Public Communication Subgroup explored the feasibility of
preparing brochure-type material for distribution to the general public. The Public
Communications Subgroup's initial concept for this outreach product was to develop a master
resource booklet of relevant information for the general public that could be used by
participating organizations of the Carpet Policy Dialogue or other groups as the basis for
developing communication products for their constituencies. This might include facts,
charts, diagrams, and sample text in layman language. A preliminary list of topics that
might be included in this outreach product was outlined. A Brochure Working Party,
consisting of a subset of Subgroup members, was formed to flesh-out the concept and
determine the need for such a product.
Project staff integrated comments and submitted materials related to the development
of this product for discussion at the May 21, 1991, Subgroup meeting. Information provided
to the Subgroup for the situation analysis revealed that there was an immediate need for such
a product. Furthermore, the Subgroup acknowledged that the absence of factual information
about carpet floor covering products, volatile organic compound emissions, and indoor air
quality was, by itself, a cause for potential concern and misunderstanding among the general
public. Based on these discussions, the Subgroup identified five (5) topics that could provide
useful information to the interested public. These included:
1. Pollution and indoor air quality;
2. Carpet floor covering products and indoor air quality;
3. What is being done to understand VOCs;
4. Steps that consumers can take; and
5. Where to get more information.
The Brochure Working Party was given charge to develop a "strawman" brochure product
for discussion at the June Subgroup meeting.
Based on comments received from a review of the "strawman" draft prior to the June
meeting and the discussions at that meeting, the Subgroup prepared a list of principles to
govern further development of the brochure. These included:
The level of understanding for the target audience should be set at the 6th-8th
grade reading level; however, certain technical concepts may raise the reading
level to the 10th grade level.
The brochure should contain only statements that are accurate and which can be
substantiated.
The brochure should address all elements of the carpet floor covering system.
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The brochure should make some comparison of TVOC emissions from carpet
floor covering products with emissions from other products.
There may be different information needs for residential and
commercial/institutional carpet consumers, and the brochure should differentiate
where appropriate.
Recommendations about ventilation and odor detection times should be consistent
within the brochure.
It was at this meeting that the Subgroup set the goal to gain the approval of the
Carpet Policy Dialogue Plenary and to seek "sign-on" to the brochure by participating
organizations to the Dialogue. This would signal that representatives from the organizations
participating in the Dialogue worked cooperatively to address indoor air quality issues and
participated in the development of the brochure. In addition, "signing-on" indicated that the
participating organizations reviewed the brochure and agreed to be listed as a participating
organization.
The Subgroup agreed that the Public Information Brochure offered a unique
opportunity for industry, labor, Government, and public interest to make a statement on this
subject. Furthermore, a joint "sign-on" by these organizations would demonstrate a level of
accomplishment that could only be attained by means of a voluntary cooperative effort. At
the same time, the subgroup reaffirmed that this Carpet Policy Dialogue, Public Information
Brochure would not preclude participating organizations from developing other materials
focused to their constituent audience.
The Public Information Brochure was further revised for discussion at the July
Subgroup meeting. Project staff subjected the document to analysis by various computer
readability programs. This analysis formed the basis for discussions and further revisions to
the document on July 30, 1991. It was at this meeting that the Subgroup refined terminology
and sought to clarify the message for the broadest possible target audience. Difficult
concepts, lengthy scientific phrasing, and complex words were simplified to focus the
reader's attention and to provide the reader with an understanding of the information that is
currently available on this subject. Sections from early drafts were completely deleted or
revised, and existing text was repositioned to improve flow through the document. When
this had been completed, the Subgroup recommended that the revised document be forwarded
to the Carpet Policy Dialogue Plenary.
The Public Information Brochure was reviewed by the Carpet Policy Dialogue
Plenary on July 31, 1991. The Plenary made further revisions to the document before it was
approved in "FINAL TEXT" form. This approval permitted project staff to issue a letter to
nineteen (19) organizations participating in the Dialogue seeking "sign-on" approval to be
listed on the brochure.
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Results from the "sign-on" process were reported at the September 26, 1991,
Subgroup meeting. The majority of participating organizations attained "sign-on" status.
Subsequent discussion focused on those organizations which did not attain "sign-on" approval
as this provided useful feedback to the Dialogue about how the brochure could be perceived.
In the true spirit of the consensus process, the Dialogue Group sought to understand barriers
that precluded some organizations from "signing-on."
In some cases, there was little that could be done to bring an organization to "sign-
on" status. For example, the Subgroup learned that the American Society for Testing and
Materials (ASTM) had no procedural mechanism to approve or disapprove of such a
document. Other organizations requested text changes because, in their opinion, some
important subjects needed further clarification or a different emphasis. To its credit, the
Dialogue group was able to resolve these points and, following some text revisions, sixteen
(16) organizations agreed to be listed on the brochure. These organizations are listed in
Table 4.3.
Brochure layout options were also discussed at the final meeting of the Public
Communications Subgroup on September 26, 1991. The Subgroup considered several
proposed options and set guiding principles for the final layout. These included:
1. Use of recycled paper should be encouraged;
2. Paper stock (8 1/2" x 11" preferred over 8 1/2" x 14") should be cover weight,
non-glossy, and may be colored to attract reader attention;
3. Two-color typeface could be used to emphasize text;
4. The section: "Steps To Take," should be border framed, and the shading grid
should attract reader attention but not interfere with user friendly duplication;
5. A 2-fold (6 panel) or 3-fold (8 panel) format should be used to allow user friendly
duplication;
6. The brochure should not contain graphics;
7. The cover should emphasize the title only without graphics, and
8. EPA's sponsorship of the Dialogue should be recognized by placing an EPA logo
on the cover page bottom.
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TABLE 4-3
LIST OF ORGANIZATIONS THAT AGREED TO
BE LISTED ON THE BROCHURE
AFSCME - American Federation of State, County, and Municipal Employees
AFMA American Fiber Manufacturers Association
ALA American Lung Association
ATMI American Textile Manufacturers Institute
CRI - Carpet and Rug Institute
CCC - Carpet Cushion Council
FCICA - Floor Covering Installation Contractors Association
FCAMC Floor Covering Adhesive Manufacturers Committee of the National
Association of Floor Covering Distributors
GTRI -- Georgia Tech Research Institute
NFFE - National Federation of Federal Employees, Local 2050
NIST ~ National Institute of Standards and Technology
SBLMC - Styrene Butadiene Latex Manufacturers Council
ASC The Adhesives and Sealants Council
CPSC -U.S. Consumer Product Safety Commission
EPA U.S. Environmental Protection Agency
GSA - U.S. General Services Administration
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The Subgroup also discussed potential brochure distribution. EPA noted that it
intends to distribute 5,000 copies of the brochure to each "sign-on" participant along with
camera ready copy to permit these organizations to duplicate the brochure to meet their
distribution needs. In addition, the EPA will announce the availability of the brochure in the
Federal Register, distribute copies to the Regional offices, and make copies available from
the TSCA Hotline and the Office of Air and Radiation, Indoor Air Division. The Consumer
Product Safety Commission noted that they envisioned that the brochure would be available
on request from the CPSC Office of Public Affairs, and distributed to CPSC Regional
Offices. CPSC would also send copies of the brochure to State Product Safety Coordinators
as well as State and local Consumer Product Protection Organizations. The Carpet and Rug
Institute explained that they would encourage all carpet manufacturers, distributors, retailers,
and installers to distribute the Carpet Policy Dialogue brochure. Similar distribution would
be encouraged by the Carpet Cushion Council. The American Lung Association envisions
distribution of the brochure to its 131 constituent and affiliate Lung Associations across the
country where it will be publically available on request. Other organizations indicated a
variety of distribution channels to meet the needs of their constituencies.
The text of the Carpet Policy Dialogue: Public Information Brochure entitled "Indoor
Air Quality and New Carpet, What You Should Know" is included as Appendix M of this
report. A copy of the brochure may be obtained by contacting the EPA.1
4.4.5. Compendium Report
On February 27, 1991, the Public Communications Subgroup determined that the
hallmark of its public communication efforts would be a comprehensive report describing the
accomplishments of the Carpet Policy Dialogue. This communication product would be a
compilation of the final documents produced as a result of the Carpet Policy Dialogue. A
Draft Table of Contents for this product was developed and discussed at a Subgroup meeting
on April 9, 1991. The revised Draft was distributed to the Plenary on April 10th and
approved.
The "Compendium Report" incorporates into one source document all materials
associated with the work of the Carpet Policy Dialogue. As such, it is an assembly which
includes: the consensus agreements for the industry testing programs (carpet, carpet cushion,
and carpet floor covering adhesives industries), the analytical test method for measuring
TVOC emissions, information about the process engineering and installation practices of
1 The EPA, the Carpet Policy Dialogue, and all participating organizations listed on the brochure encourage
reproduction and distribution of this brochure without alteration and without permission, except for use as
advertising material or product endorsement. Any such reproduction should credit those organizations listed
on the brochure. The use of all or any pan of the brochure in a deceptive manner or for purposes of endorsing
a particular product may be subject to appropriate legal action.
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carpet floor covering materials relevant to VOC emissions, and public communications
products. It also includes a record of other Carpet Policy Dialogue related materials such as
the Federal Register announcements, and various Memoranda of Understanding.
The Compendium Report also provides descriptive information to give perspective
about the structure and framework of the Carpet Policy Dialogue. The report gives context
about the scope of work for the Carpet Policy Dialogue Plenary and explains the
relationships and activities of the three working Subgroups (Product Testing, Process
Engineering, and Public Communications).
This report was prepared with the understanding that it would become a public
document that would be available on request. It was developed so that participating
organizations in the Carpet Policy Dialogue and their representatives would be able to use
materials in the Compendium to communicate with their respective constituencies and publics
as they choose. At the same time, the document provides an opportunity for these
organizations to inform the interested public about ongoing and proposed activities with
respect to carpet floor covering, TVOC emissions, and indoor air quality.
Preparation of the Compendium Report involved the coordination of several activities.
This included updating materials prepared for the Interim Progress Report; compiling
documents prepared during the Dialogue year; preparation of bridging materials to give
context to the findings, conclusions, recommendations, and products developed by the Carpet
Policy Dialogue; and finally review and assembly of the document. The modular nature of
the document made it possible to insert reports prepared during the Dialogue year. For
example, the introductory material (Chapter 1) was initially prepared for the Interim Progress
Report, while Chapters 2, 3, and 4 are reports submitted to the Carpet Policy Dialogue
which were prepared by the working Subgroups. However, because these modules
repetitively referenced Dialogue products, it became necessary to integrate the appendices
and their attachments within the Compendium Report. This assured a meaningful document
that would be easy to follow.
A draft of the Compendium Report was made available to the Carpet Policy Dialogue
for review in September 1991. Comments from this review cycle were considered during
discussions of the Public Communication Subgroup on September 26, 1991. The document
was also reviewed and discussed by the Carpet Policy Dialogue Plenary at a meeting held on
September 27, 1991. Comments and revisions to the draft document were incorporated by
project staff following these meetings. The final document was transmitted to EPA and
announced in the Federal Register. Copies of the Compendium Report's Executive Summary
are available from the TSCA Hotline, and the report will be available for purchase from the
NTIS (PB 92-115005). The report is also filed in the TSCA Carpet Emissions
Administrative Record which is available to the public for reviewing and copying.
4-20
-------
CHAPTERS
References
-------
5.0. REFERENCES
Arnott, R. (Styrene-Butadiene Latex Manufacturing Committee), May 21, 1991.
Presentation to Process Engineering Subgroup on Company-by-Company 4-Phenyl-
cyclohexene Data from May 1988 to February 1991.
Black, M.S., et al., 199la. "Volatile Organic Compound Emissions From Carpet and
Associated Products," Draft Report. Air Quality Sciences, Inc., Atlanta, Georgia.
Black M.S., WJ. Pearson, L.M. Work. 1991b. Indoor air quality evaluation of carpet for
the Carpet and Rug Institute. Air Quality Sciences, Inc., VOC Paper 012021-02. Available
as Appendix R to this report.
Chase, S. (Floor Covering Adhesives Manufacturers Committee), October 24, 1990.
Presentation to Process Engineering Subgroup on Carpet Adhesive Formulations,
Components That Make Up Adhesives, and Potential VOC Levels in Those Components.
Davidson, J. (U.S. Environmental Protection Agency), November 30, 1990. Presentation to
the Process Engineering Subgroup on the EPA Carpet Installation Study.
Demer, F.R. 1989. The impact of various cure parameters on the release of 4-phenyl-
cyclohexane from carboxylated styrene butadiene rubber latex. M.S. Thesis, Univ. of
Arizona, Dept. of Pharmacology and Toxicology.
Dipelesi, J. (Floor Covering Installation Contractors Association), September 26, 1990.
Presentation to the Process Engineering Subgroup on Installation Methods, Installation
Parameters, and Guidelines.
Ernst, B., March 25, 1991. Telephone conversation between Elbert Herrick of IT
Environmental Programs, Inc., and Bruce Ernst of APCI, Allentown, Pennsylvania, on
Prime Urethane Foam Carpet Cushion Components and Typical Raw Materials.
Girman, J. (U.S. Environmental Protection Agency), April 9, 1991. Presentation to the
Process Engineering Subgroup on General Concepts of Physical Processes Affecting VOC
Carpet Emissions.
Hawkins, N.C., A.E. Luedtke, C.R. Mitchell, J.A. LoMenzo, M.S. Black., (submitted for
publication to American Industrial Hygiene Association Journal). "Effects of Selected
Process Parameters on Emission Rates of Volatile Organic Chemicals From Carpet."
5-1
-------
Hirzy, J.W., November 29, 1990. "On the Need for Data." A presentation to the Carpet
Policy Dialogue Plenary.
Knudtzon, K. (Floor Covering Adhesives Manufacturers Committee), September 26, 1990.
Presentation to Process Engineering Subgroup on an Overview of Carpet Adhesive Market
and Formulations.
Levin, H. (Hal Levin Associates), April 9, 1991. Presentation to the Process Engineering
Subgroup on Defining the Relationship Between Building Ventilation Rates and Indoor Air
VOC Concentrations and Setting Forth Practical Control Strategies for Controlling Carpet
System VOC Emissions.
Luedtke, A., (Du Pont), October 24, 1990. Presentation to the Process Engineering
Subgroup on Data from an Industry Cooperative Plant-Scale Study (Du Pont, Shaw, Dow,
and Ciba-Geigy) on the Effect of Carpet Curing Oven Operating Parameters on VOC
Emissions.
March, J., 1977. Advanced Organic Chemistry: Reactions. Mechanisms, and Structure. 2nd
Edition. McGraw Hill Publishing Co. pp. 761-767.
Morrison, R. and Robert Boyd, 1973. Organic Chemistry. Third Edition. Allyn and Bacon,
Inc.
NFFE/USEPA. 1989 (Dec. 4). National Federation of Federal Employees/U.S.
Environmental Protection Agency. Office of Pesticides and Toxic Substances. Citizen's
Petition, Section 21: Control of risk associated with certain carpeting. Washington, DC:
USEPA, p. 10. OPTS-211027. Revised 1990 (Jan. 11).
Oler, W.H. (Carpet Cushion Council), September 26, 1990a. Presentation to the Process
Engineering Subgroup on an Overview of Carpet Cushion Market, Manufacturing Process of
Bonded Carpet Cushion and Prime Urethane Carpet Cushion.
Oler, W.H. (Carpet Cushion Council), November 30, 1990b. Presentation to the Process
Engineering Subgroup on Carpet Cushion Manufacturing Process.
Oler, W.H. (Carpet Cushion Council), April 9, 1991. Presentation to the Process
Engineering Subgroup on Carpet Cushion Market and Potential Methods of Reducing VOCs
from Carpet Cushion.
PEI Associates, Inc., 1984. Worker Exposure to 1.3-Butadiene in the Plastics and Rubber
Industry. Prepared for the U.S. Environmental Protection Agency.
5-2
-------
PEI Associates, Inc., 1990. Occupational Exposure And Environmental Release Data For
Chlorofluorocarbons (CFCs) And Their Substitutes. Prepared for the U.S. Environmental
Protection Agency.
Persily, A. (National Institute of Standards and Technology), April 9, 1991. Presentation to
the Process Engineering Subgroup Reporting the Results of an NIST Study Comparing Actual
Versus Design Ventilation Rates in Selected Federal Office Buildings.
Potts, T. (Reichhold Chemicals, Inc.) and Jessie Roeck (Dow Chemical USA), September
26, 1990. Presentation to Process Engineering Subgroup on Latex Manufacturing Process,
Quality Control, and 4-Phenylcyclohexene Reduction Achievements.
SCAQMD (Southern California Air Quality Management District). 1990. Proposed
Amended Rule 1168-Control of Volatile Organic Compound Emissions from Adhesive
Application.
Tichenor, B. (U.S. Environmental Protection Agency), August 25, 1988. Memorandum to
D. J. Weitzman (U.S. Environmental Protection Agency) on Evaluation of Organic
Emissions From Waterside Mall Carpets and Office Partitions.
Tichenor, B. (U.S. Environmental Protection Agency), April 9, 1991. Presentation to the
Process Engineering Subgroup on the Effects of Ventilation Rates and Conditioning Times on
Indoor Concentrations of 4-Phenylcyclohexene.
USEPA. 1990a. U.S. Environmental Protection Agency. Office of Pesticides and Toxic
Substances. Carpet response to citizen's petition. Federal Register 55:17404.
USEPA. 1990b. U.S. Environmental Protection Agency. Office of Pesticides and Toxic
Substances. Carpet emissions reduction; policy dialogue. Federal Register 55:31640.
USEPA. 1991. U.S. Environmental Protection Agency. Safety Health and Environmental
Management Division. Indoor air quality carpet installation, p.46.
USGSA. 1991a. U.S. General Services Administration. Notice Concerning Solicitation.
Solicitation No. 3FNH-92-F301-N-12-12-91 Federal Supply Schedule Contract for FSC
Group 7220, Part I, Section A: for period October 1, 1992 to September 30, 1993.
Available from: General Services Administration, Federal Supply Service, Furniture
Commodity Center, FCNHF, Room 1010, Washington, DC 20460.
USGSA. 1991b. U.S. General Services Administration. Technical requirements booklet for
FSC Group 7220, Part I, Section A: for period October 1, 1992 to September 30, 1993.
Available from: General Services Administration, Federal Supply Service, Furniture
Commodity Center, FCNHF, Room 1010, Washington, DC 20460.
5-3
-------
Van En, M. 1990. Investigating the impact of various cure parameters on the release of
4-phenylcyclohexene (4-PCH) from carpet backed with compounds based on carboxylated
SBR latex. Report to the Styrene Butadiene Latex Manufacturer's Council. Available as
Appendix N to this report.
VanGelderen, R., et al., (Carpet and Rug Institute), September 26, 1990. Presentation to the
Process Engineering Subgroup on Carpet Market and Carpet Manufacturing Process.
5-4
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APPENDIX A
List of Carpet Policy
Dialogue Participants
-------
APPENDIX A. List of Carpet Policy Dialogue Participants.
CARPET POLICY DIALOGUE PLENARY GROUP
Charles M. Auer
Project Director
Director, Existing Chemical
Assessment Division
Office of Toxic Substances TS-778
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
Randall A. Arnott, CHCM
Corporate Manager,
Regulatory Affairs Audits
Richhold Chemicals, Inc.
P.O. Box 13582
Research Triangle Park, NC 27709
Robert Axelrad
Director, Indoor Air Division
Office of Air and Radiation
U.S. Environmental Protection Agency
401 M Street, SW AN-445
Washington, DC 20460
Tom Bacon
Comodity Specialist
General Services Administration
Federal Supply Service - FCRE
Washington, DC 20406
Charlene Bayer, Ph.D.
Principal Research Scientist
Georgia Tech Research Institute
Emerson Building, Room A-112
Atlanta, GA 30332
Michael Berry, Ph.D.
Deputy Director, Environmental Criteria
and Assessment Office
Office of Research and Development
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Marilyn Black, Ph.D.
Chief Scientist
Air Quality Sciences, Inc.
1331 Capitol Circle, Suite D
Marietta, GA 30067
Sharon Booker
Comodity Specialist
General Services Administration
Federal Supply Service - 3FNE
Washington, DC 20406
Werner Braun
Regulatory and Government
Affairs Manager
Dow Chemical USA
100 Larkin Laboratory
1691 North Swede Road
Midland, MI 48674
Katherine Cox, M.P.H.
Health and Safety Specialist
American Federation of State,
County and Municipal Employees
1625 L Street, NW
Washington, DC 20036
Earon Davis, Ph.D.1
Environmental Health Consultant
2530 Crawford Avenue, Rm. 115
Evanston, IL 60201
1 Augurt 20, 1990 to February 27, 1991.
A-l
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James L. Dipelesi
Past Chairman, Floor Covering
Installation Contractors Association
502 Union Valley Rd.
Mahopac, NY 10541
William H. Doan, Ph.D.
Manager Consumer Quality and
Certification Program
E.I. DuPont DeNemours & Company
Walnut Run Building 102
Wilmington, DE 19880
Henry Fogle, M.S.
Chairman, American Fiber Manufacturers
Association Toxicology
Subcommittee
Allied Signal
P.O. Box 831
Hopewell, VA 23860
Roy Fortman, Ph.D.
Research Analytical Chemist
Research Triangle Institute
P.O. Box 12194
Research Triangle Park, NC 27709
JohnGirman
Chief, Analysis Branch,
Indoor Air Division
Office of Air and Radiation
U.S. Environmental Protection Agency
401 M Street, SW AN-445
Washington, DC 20460
Oscar Hernandez, Ph.D.
Branch Chief, Risk Analysis Branch
Existing Chemical Assessment Division
Office of Toxic Substances TS-778
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
Marion Herz
Associate, Environmental Health
American Lung Association
1726 M Street, NW Suite 902
Washington, DC 20036
J. William Hirzy, Ph.D.
President, National Federation of
Federal Employees, Local 2050
506 E Street, NE
Washington, DC 20002
KenKnudtzon
Chairman, Floor Covering Adhesive
Manufacturers Committee,
National Association of
Floorcovering Distributors
Dap Inc.
P.O. Box 277
Dayton, OH 45401
Richard W. Leukroth, Jr., M.S.
Toxicologist
Existing Chemicals Assessment
Division
Office of Toxic Substances TS-778
U.S. Environmental Protection
Agency
401 M Street, SW
Washington, DC 20460
Hal Levin
Research Architect Consultant
Hal Levin Associates
ASTM Subcommittee D22.05 on
Indoor Air
2548 Empire Grade
Santa Cruz, CA 95060
Ken Mclntosh
Technical Director
Carpet and Rug Institute
P.O. Box 2048
Dalton, GA 30722-2048
Margaret Neily1
Textile Engineer
Consumer Product Safety Commission
Engineering Sciences Directorate
Washington, DC 20207
William H. Oler
Executive Director
Carpet Cushion Council
P.O. Box 546
Riverside, CT 06878
1 Augurt 21, 1990 through April 10, 1991.
A-2
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Andrew Persily
Group Leader
Indoor Air Quality Group
National Institute of Standards
and Technology
Building 226, Room A313
Gaithersburg, MD 20899
Hardy Poole
Assistant Director, Product Services
American Textile Manufacturers
Institute
1801 K Street, NW Suite 900
Washington, DC 20006
Joe Smrekar, Ph.D.
Development Manager
Milliken and Company
Live Oak Plant
300 Industrial Drive
La Grange, GA 30240
Ron Swope
The Adhesive and Sealant Council, Inc.
Senior Technical Services
Representative
ALCO Chemical
P.O. Box 5401
Chattanooga, TN 37406
Ron VanGelderen
President
Carpet and Rug Institute
P.O. Box 2048
Dalton, GA 30722-2048
Kenneth M. Wallingford, M.S., CIH
Chief, Industrial Hygiene Section
National Institute for Occupational
Safety and Health
4676 Columbia Parkway
Cincinnati, OH 45226
Ira Wainless
Senior Industrial Hygienist,
Directorate of Technical Support
Occupational Safety and Health
Administration
200 Constitution Avenue, NW
Room N3653
Washington, DC 20210
Susan Womble1
Chemist
Consumer Product Safety Commission
Health Sciences Directorate
Washington, DC 20207
1 Beginning April 10, 1991.
A-3
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PRODUCT TESTING SUBGROUP
Margaret G. Conomos,1 M.P.H.
Subgroup Coordinator
Statistician, Exposure
Evaluation Division
Office of Toxic Substances TS-798
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
Sarah S. Shapley1
Subgroup Coordinator
Environmental Protection Specialist,
Exposure Evaluation Division
Office of Toxic Substances TS-798
U.S. Environmental Protection Agency
401 M St., SW
Washington, DC 20460
Charlene Bayer, Ph.D.
Principal Research Scientist
Georgia Tech Research Institute
Emerson Building, Room A-112
Atlanta, GA 30332
Lane Bishop, Ph.D.
Statistical Consultant
Center for Applied Mathematics
Research and Technology
Allied-Signal Inc.
20 Peabody Street
Buffalo, NY 14210
Marilyn Black, Ph.D.
Chief Scientist
Air Quality Sciences, Inc.
1331 Capitol Circle, Suite D
Marietta, GA 30067
John Ellicson
Floor Covering Adhesive Manufacturers
Committee, National Association of
Floorcovering Distributors
DAP Inc.
P.O. Box 277
Dayton, OH 45401
Roy Fortman, Ph.D.
Research Analytical Chemist
Research Triangle Institute
P.O. Box 12194
Research Triangle Park, NC 27709
John Girman, Ph.D.
Chief, Analysis Branch,
Indoor Air Division
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
J. William Hirzy, Ph.D.
Past President
National Federal of Federal
Employees
506 E Street NE
Washington, DC 20002
Barbara Leczynski
Senior Statistician
David C. Cox and Associates
1620 22nd Street, NW
Washington, DC 20008
1 Subgroup Coordinator beginning March 8, 1991.
3 Subgroup Coordinator August 21, 1990 through March 8, 1991.
A-4
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Hal Levin
Research Architect Consultant
Hal Levin Associates
ASTM Subcommittee D22.05 on
Indoor Air
2548 Empire Grade
Santa Cruz, CA 95060
Alan Luedtke, Ph.D.
Senior Chemist, Carpet Technology
Group
E.I. DuPont De Nemours
and Company, Inc.
Chestnut Run Plaza
P.O. Box 80702
Wilmington, DE 19880
William H. Oler
Executive Director
Carpet Cushion Council
P.O. Box 546
Riverside, CT 06878
Hardy Poole
Assistant Director, Product Services
American Textile Manufacturers
Institute
1801 K Street NW, Suite 900
Washington, DC 20006
Val H. Schaeffer, Ph.D.
Pharmacologist/Toxicologist,
Health Sciences Directorate
U.S. Consumer Product Safety
Commission
Washington, DC 20207
Joseph Smrekar, Ph.D.
Developmental Manager
Milliken and Company
Live Oak Plant
300 Industrial Drive
La Grange, GA 30240
Bruce A. Tichenor, Ph.D.
Environmental Engineer
Air and Energy Engineering
Research Laboratory
U.S. Environmental Protection
Agency
Research Triangle Park, NC 27711
Ron VanGelderen
President
Carpet and Rug Institute
P.O. Box 2048
Dalton, GA 30722-2048
Harold Webster
Floor Covering Adhesive Manufacturers
Committee, National Association of
Floorcovering Distributors
Roberts-Consolidated Industries
600 N. Baldwin Park Boulevard
City of Industry, CA 91749
A-5
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PROCESS ENGINEERING SUBGROUP
Randall G. Amott, CHCM
Corporate Manager,
Regulatory Affairs Audits
Richhold Chemicals, Inc.
P.O. Box 13582
Research Triangle Park, NC 27709
Wayne Braud1
Floor Covering Adhesive Manufacturers
Committee, National Association
of Floorcovering Distributors
XL Corporation
Rte. 3 and Hwy. 41 North
Calhoun, GA 30201
Werner Braun
Regulatory and Government
Affairs Manager
Dow Chemical USA
100 Larkin Laboratory
1691 North Swede Road
Midland, MI 48674
Steve Chase1
Floor Covering Adhesive Manufacturers
Committee, National Association
of Floorcovering Distributors
Para-Chem Southern, Inc.
P.O. Box 127
Simpsonville, SC 29681
Wardner G. Penberthy, P.E.
Subgroup Coordinator
Acting Branch Chief, Economics
and Technology Division
Office of Toxic Substances TS-779
U.S. Environmental Protection Agency
401 M St., SW
Washington, DC 20460
Charles D. Cline, Ph.D.
Technical Director
Para-Chem Southern
P.O. Box 127
Simpsonville, SC 29861
James L. Dipelesi
Past Chairman, Floor Covering
Installation Contractors
Association
502 Union Valley Rd.
Mahopack, New York 10541
Henry Fogle, M.S.
Chairman, American Fiber
Manufacturers Association,
Toxicology Subcommittee
Allied Signal
P.O. Box 831
Hopewell, VA 23860
John Girman
Chief, Analysis Branch,
Indoor Air Division
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
J. William Hirzy, Ph.D.
Past President
National Federal of Federal
Employees
506 E Street NE
Washington, DC 20002
1 Alternate representative for the Floor
Covering Adhesive Manufacturers Committee
attending meeting! through November 1990.
1 Alternate representative for the Floor
Governing Adhesive Manufacturers Committee
attending meetings through May 1991.
A-6
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Ken Knudtzon
Chairman, Floor Covering Adhesive
Manufacturers Committee,
National Association of
Floorcovering Distributors
Dap Inc.
P.O. Box 277
Dayton, OH 45401
Hal Levin
Research Architect Consultant
Hal Levin Associates
ASTM Subcommittee D22.05 on
Indoor Air
2548 Empire Grade
Santa Cruz, CA 95060
Ken Mclntosh
Technical Director
Carpet and Rug Institute
P.O. Box 2048
Dalton, GA 30722-2048
Margaret Neily1
Textile Engineer
Consumer Product Safety Commission
Engineering Sciences Directorate
Washington, DC 20207
William H. Oler
Executive Director
Carpet Cushion Council
P.O. Box 546
Riverside, CT 06878
Andrew Persily
Group Leader,
National Institute of Standards
and Technology
Indoor Air Quality Group
Building 226, Room A313
Gaithersburg, MD 20899
Hardy Poole
Assistant Director,
Product Services
American Textile Manufacturers
Institute
1801 K Street NW, Suite 900
Washington, DC 20006
Alan Rautio
Executive Director
Styrene-Butadiene Latex Manufacturers Council
1815 H Street, NW
Washington, DC 20006
Joseph Smrekar, Ph.D.
Developmental Manager
Milliken and Company
Live Oak Plant
300 Industrial Drive
La Grange, GA 30240
Ron Swope
The Adhesive and Sealant Council, Inc.
Senior Technical Services Representative
ALCO Chemical
P.O. Box 5401
Chattanooga, TN 37406
Ron VanGelderen
President
Carpet and Rug Institute
P.O. Box 2048
Dalton, GA 30722-2048
Kenneth M. Wallingford, M.S., CIH
Chief, Industrial Hygiene Section
National Institute for Occupational
Safety and Health
4676 Columbia Parkway (R14)
Cincinnati, OH 45226
1 August 21, 1990 through April 10, 1991.
A-7
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PUBLIC COMMUNICATIONS SUBGROUP
Richard W. Leukroth, Jr., M.S.
Subgroup Coordinator
lexicologist, Existing Chemicals
Assessment Division, TS-778
Office of Toxic Substances
U.S. Environmental Protection Agency
401 M Street SW
Washington, DC 20460
Robert Axelrad
Director, Indoor Air Division
Office of Air and Radiation
U.S. Environmental Protection
Agency
401 M Street, SW AN-445
Washington, DC 20460
Wendy Butler
Communications Strategist
Office of Public Affairs
U.S. Environmental Protection
Agency
401 M St., SW
Washington, DC 20460
Mark Collate
Director, Government Relations
The Adhesive and Sealant Council, Inc.
1627 K Street, NW, Suite 1000
Washington, DC 20006
Katherine Cox, M.P.H.
Health and Safety Specialist
American Federation of State,
County, and Municipal Employees
1625 L Street NW
Washington, DC 20036
Earon Davis, Ph.D.1
Environmental Health Consultant
2530 Crawford Avenue, Room 115
Evanston, IL 60201
James L. Dipelesi
Past Chairman, Floor Covering
Installation Contractors
Association
502 Union Valley Rd.
Mahopack, New York 10541
William H. Doan
Manager, Consumer Quality and
Certification Program
E.I. DuPont DeNemours & Company
Walnut Run Building 102
Wilmington, DE 19880
Henry Fogle, M.S.
Chairman, American Fiber
Manufacturers Association,
Toxicology Subcommittee
Allied Signal
P.O. Box 831
Hopewell, VA 23860
John Girman
Chief, Analysis Branch,
Indoor Air Division
U.S. Environmental Protection Agency
401 M Street S.W.
Washington, DC 20460
Marion Herz
Associate, Air Conservation
American Lung Association
1726 M Street NW, Suite 902
Washington, DC 20036
1 Augua 20, 1990 to February 27, 1991.
A-8
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Ken Knudtzon Joseph Smrekar, Ph.D.
Chairman, Floor Covering Adhesives Development Manager
Manufacturers Committees, Milliken and Company
National Association of Floor Covering Live Oak Plant
Distributors 300 Industrial Drive
Dap Inc. LaGrange, GA 30240
P.O. Box 277
Dayton, OH 45401 Ron VanGelderen,
President
Hal Levin Carpet and Rug Institute
Research Architect Consultant, P.O. Box 2048
Hal Levin Associates Dalton, GA 30722-2048
ASTM Subcommittee D22.0S
on Indoor Air
2548 Empire Grade
Santa Cruz, CA 95060
Ken Mclntosh
Technical Director
Carpet and Rug Institute
P.O. Box 2048
Dalton, GA 30722-2048
William H. Oler
Executive Director
Carpet Cushion Council
P.O. Box 546
Riverside, CT 06878
Susan E. Ridge
Public Relations Consultant
Fleishman Hillard, Inc.
1301 Connecticut Ave., N.W.
Washington, D.C. 20036
Lori Saltzman, M.S.
lexicologist, Health Sciences
Directorate
U.S. Consumer Product Safety
Commission
Washington, DC 20207
Jeffrey P. Shawd
Public Affairs Manager
E.I. DuPont DeNemours & Company
Chestnut Run
Wilmington, DE 19880
A-9
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STANDARD TEST METHOD
PEER REVIEW GROUP
Al Hodgson
Lawrence Berkeley Laboratory
1 Cyclotron Road (B-90-G)
Berkeley, CA 94720
Niren Nagda
Geomet Technologies
20251 Century blvd.
Germantown, MD 20874
Hustin Howell
BASF Corporation
Fibers Division, R&D Bldg.
Sand Hill Road
Enka, NC 28728
Robert Foster
Allied Signal Tech. Center
P.O. Box 31
Petersburg, VA 23804
David K. Slosberg
Executive Vice-President, R&D
Interface Research Corporation
100 Chastain Center Blvd., #165
Ketmesaw, GA 30144
Dr. Joachim Pleil
U.S. Environmental Protection Agency
ORD/AREAL (MD-44) - The Annex
79 T. W. Alexander Drive
Research Triangle Park, NC 27709
Prof. James Winefordner
Dept. of Chemistry
304 Leigh Hall
University of Florida
Gainesville, FL 32611
Lars Molhave
Institute of Environmental & Occupational Medicine
University of Arhus Bygning 180
Universitetsparken
DK-8000 Arhus C
DENMARK
Helmut Knoppel
ISPRA Establishment
Joint Research Center
21020 ISPRA/Varese
ITALY
David Jennings
Building & Energy Technology Program
Saskatchewan Research Council
15 Innovation Blvd.
Saskatoon, Saskatchewan S7N 2X8
CANADA
Hans Gustafsson
National Testing Institute
P.O. Box 857
S-501 15 Boras
SWEDEN
Peder Wolkoff
National Institute of Occupational Health
Lerso Parkalle 105
DK-2100 Copenhagen
DENMARK
A-10
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PROJECT STAFF
EPA Staff
401 M Street, SW
Washington, DC 20460
Charles M. Auer
Project Director
Oscar Hernandez, Ph.D.
Project Co-Director
Sarah S. Shapley1
Product Testing Subgroup
Coordinator
Gordon G. Cash, Ph.D.
Standard Method Working Party
Coordinator, Product Testing Subgroup
Wardner G. Penberthy, P.E.
Process Engineering
Subgroup Coordinator
Richard W. Leukroth, Jr., M.S.
Project Coordinator and
Public Communications Subgroup
Coordinator
Margaret G. Conomos,2, M.P.H.
Product Testing Subgroup
Coordinator
Christina A. Cinalli
Technical Support Chemist
Product Testing Subgroup
Nguyen Nhan, ChE.
Chemical Engineer
Process Engineering Subgroup
Chris Kirtz
Director
EPA Regulatory Negotiations Project
Debra Dalton
Project Officer
1 Subgroup Coordinator Augurt 21, 1990, through March 8, 1991.
1 Subgroup Coordinator beginning March 8, 1991.
A-ll
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The Conservation Foundation
1250 24th Street, NW
Washington, DC 20037
Suzanne Orenstein
Program Administrator
CDR Associates
100 Arapahoe Avenue
Suite 12
Boulder, CO 80302
Christopher W. Moore
Co-Facilitator
Louise E. Smart Margaret Shaw
Co-Facilitator Facilitator
Barbara McLaughlin Paula Lagana
Office Manager Business Manager
Cindy Gerardy Sat Sundri Kaur Khalsa
Administrative Assistant Administrative Assistant
Versar Inc.1
6800 Versar Center
P.O. Box 1549
Springfield, VA 22515
Greg Schweer Janeice Zeaman
Environmental Scientist Senior Technical Editor
Sunny Yung
Environmental Scientist
1 Anembly of the Compendium Report and related activities.
A-12
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David C. Cox and Associates1
1620 22nd Street, NW
Washington, DC 20008
Barbara Leczynski
Senior Statistician
IT Environmental Programs, Inc.9
1133 21st Street, NW
Washington, DC 20036
John Murphy James Poles
Deputy Office Manager Environmental Scientist
AScI Corporation4
1365 Beverly Road
McLean, VA 22101
Gayle Lacy Mike Guill
Editor Graphics Coordinator
1 Preparation of the Product Testing Subgroup Report and associated
activities.
9 Preparation of the Process Engineering Subgroup Report.
4 Layout of the Public Communications Brochure and related activities.
A-13
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APPENDIX B
Federal Register, Vol. 55.
No. 79; Part VII,
Environmental Protection Agency,
Carpet Response to Citizen's
Petition; Notice
-------
Tuesday
April 24, 1990
Part VII
Environmental
Protection Agency
Carpet Response to Citizens' Petition;
Notice
-------
17404
Federal Register / Vol. 55. No. 79 / Tuesday, April 24, 1990 / Notices
ENVIRONMENTAL PROTECTION
AGENCY
[OPTS-211027; FRL 373&-81
Carpet Response to Citizens' Petition
AOENcr: Environmental Protection
Agency (EPA).
ACTION: Response to Citizens' Petition.
SUMMARY: On January 11.1990. the
National Federation of Federal
Employees (NFFE). Local 2050,
petitioned EPA under section 21 of the
Toxic Substances Control Act (TSCA),
15 U.S.C. 2620, to initiate rulemaking
proceedings, under sections 4.8 and 8 of
TSCA, 15 U.S.C. 2603, 2605. and 2607, to
reduce emissions from new carpets. EPA
has decided not to initiate the specific
rulemaking proceedings requested by
NFFE because the Agency disagrees
with the specific assertions regarding
the health risk posed by carpeting and
with the remedies sought.
However, EPA is concerned that
volatile compounds from installation of
new carpeting may significantly
increase indoor air exposures to such
compounds. Therefore, this notice
describes the Agency's decision to
initiate a series of actions designed to
assess and, if necessary, reduce the
public's exposure to compounds which
may off-gas from carpeting.
FOR FURTHER INFORMATION CONTACT
Michael M. Stahl. Director.
Environmental Assistance Division (TS-
799), Office of Toxic Substances. Rm. E-
543B . 401 M St.. SW., Washington. DC
20460, (202) 554-1404.
UPPLIMCNTARV INFORMATION:
I. Summary of Response
EPA has found that there are
insufficient data to support the
conclusions and remedies requested by
NFFE. The Agency, however, believes
that an absence of scientific certainty
does not necessarily mean an absence
of risk and that efforts to better
characterize carpet emissions, and
potential health effects which may be
associated with carpeting, as well as
other indoor exposure sources, should
be continued and expanded.
In addition, the Agency recognizes
that new carpet may be a significant
source of human exposure to low levels
of volatile organic compounds (VOCs).
As a matter of policy, the Agency
believes it is prudent to minimize indoor
human exposure to these chemicals
where reasonable and that efforts on the
part of manufacturers to reduce product
emissions should be strongly
encouraged.
In light of these findings, the Agency
is taking three major initiatives. First,
the Agency is formally requesting that
the carpeting industry undertake a
voluntary program to conduct periodic
total VOC analyses on a company-by-
company and product-by-product basis
to provide the interested public with
comparative information on total VOC
emissions. Second, the Agency is
inviting all interested parties to
participate in a 1-year dialogue process
designed to work out the details of the
voluntary testing program mentioned
above and to explore and, where
possible, reach agreement on a variety
of issues including: the sampling and
analytical methods for the voluntary
testing, any additional information
needed, and cost-effective process
changes to reduce emissions. Further,
details on the dialogue process are
discussed in Unit IV of this notice.
Thirdly, the Agency will continue its on-
going exposure reduction and research
activities on indoor air quality issues
generally and on the potential health
effects of exposure to low level VOC
mixtures, in particular.
A concurrent effort will be initiated to
assess the feasibility of prospective
epidemiology studies to determine the
response characteristics of individuals
exposed to carpet emissions.
H. Background
A. Statutory Requirements
1. TSCA in general. Section 21 of
TSCA provides that any person may
petition EPA to initiate proceedings for
the issuance of rules under sections 4,6
and 8 of TSCA.
Under section 4 EPA may issue rules
to require chemical manufacturers and
processors to test their chemicals. To
issue a section 4 rule on a chemical EPA
must find either that activities involving
the chemical may present an
unreasonable risk of injury to health or
the environment or that the chemical
will be produced in amounts that may
cause significant or substantial human
exposure or substantial environmental
release. In addition, EPA must find that
existing data are insufficient to
determine or predict the effects of the
chemical and that testing is necessary to
develop that data.
Under section 6 EPA may promulgate
rules to control a chemical if the Agency
finds there is a reasonable basis to
conclude that activities involving the
chemical present or will present an
unreasonable risk of injury to health or
the environment.
Under section 8 EPA may issue rules
to require chemical manufacturers and
processors to gather, retain and report
existing information, as may be
reasonably required. This information
includes production and use
information, health and safety studies.
and allegations of adverse reactions.
2. TSCA section 21. A section 21
petition must set forth the facts which
establish the need for the rules
requested. EPA is required to grant or
deny the petition within 90 days. If EPA
grants the petition, the Agency must
promptly commence an appropriate
proceeding, if EPA denies the petition.
the Agency must publish its reasons in
the Federal Register.
Within 60 days of denial, the
petitioner may commence a civil action
in a U.S. district court to compel the
initiation of the rulemaking requested in
its petition. The court must, for a
petition for a new rule, provide the
opportunity for the petition to be
considered de novo.
After hearing the evidence, the court
can order EPA to initiate the action
requested if the petitioner has
demonstrated, by a preponderance of
the evidence, support for particular
conclusions described in section 21. The
petitioner must support different
conclusions for section 4 petitions than
for section 6 or 8 petitions.
In the case of a section 21 petition for
a section 4 rule, the petitioner must
demonstrate support for the conclusion
that (1) information is insufficient to
permit a reasoned evaluation of the
effects of a chemical and (2) the
chemical either may present an
unreasonable risk or will be produced in
substantial amounts and may result in
significant or substantial human
exposure or substantial environmental
release.
In the case of a section 21 petition for
a section 6 or 8 rule, the petitioner must
demonstrate support for the conclusion
that there is a reasonable basis that
rules are "necessary" to protect against
"unreasonable risk."
B. Assertions of Petitioner
NFFE petitioned EPA to initiate
proceedings for a number of
immediately effective rules to control
exposure to the chemical substance 4-
phenylcyclohexene (4-PC), an
inadvertent byproduct ef the
manufacture of sryrene-butadiene latex
(SB latex) used in carpet manufacturing.
as well as other chemicals emitted by
new carpeting.
NFFE asserts that immediately
effective rules are needed to protect
against alleged adverse health effects
described by NFFE as "multiple
chemical sensitivity" (MCS) and "acute
irritancy response" (AIR). NFFE claims
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17405
that MCS and AIR result from exposure
to 4-PC emitted from SB latex in "bad"
batches of carpets. The chemical 4-PC is
likely produced at the initial
polymerization stage of SB latex.
NFFE supports this contention by
citing a surge in illness complaints
among EPA employees following carpet
installation in 1987-88 at the EPA
headquarters building in Washington.
D.C. NFFE claims that 4-PC is the single
common emission product from these
carpets and that similar complaints have
been made by persons exposed to SB
latex and not carpets. In addition, NFFE
asserts that animal studies link 4-PC
with adverse health effects.
NFFE maintains that this evidence
provides a reasonable basis for the
initiation of action under 1SCA, arguing
that it is not necessary to show 4-PC is
the only came of injury or to know the
precise mechanism by which the
adverse health effects occur.
NFFE further asserts thai it might be
inexpensive to reduce 4-PC levels in the
initial production of SB latex or its
subsequent processing. NFFE concludes
that this remedy is justified on the basis
of its probable low economic
consequence compared to the severity of
the life-altering human health effects
asserted in the petition.
C. Remedies Sought
EPA is requested to initiate tfae
following specific regulatory actions:
L Section 4. NFFE requests fart EPA
promulgate rales to generate information
elucidating tfae mechanism of action for
4-PC and other chearicais emitted from
certain carpeting through specific testing
including; (l) A case control
epidemiology study. (2) in vitro studies
of the reactivity of 4-PC and ita_epoaude
derivative with cellular proteis* and
DNA aad like studies of the ability of 4-
PC to affect certain ear/me lereit at
living cells, aad (3) whole animal stadia
related to the in vitro studies oa 4-PC
and carpet off-gassing riheisineh (effects
on enzyme levels. iny»»»« system
marker ^h^micalt aid aewotraaamjttar
substances).
2. Section 6. NFFE requests that EPA
promulgate immediately effective rules
under section 6 to establish 4-PC indoor
air level standards of 5 parts per trillion
(ppt) to protect against MCS aad 17 pot
to protect against AfiL aad to require
manufacturers to buy back carpets
which would caase these levels to be
exceeded. NFFE also requests EPA to
issue aa immediately effective order
under section e(b) to require
manufactureis t& xafasa'y eaality control
procedures, notify the public of me
health risks, aad Tequtee the carpel buy-
backs discussed above.
NFFE requests that testing be
conducted to determine what levels of 4-
PC in carpets would cause these indoor
air level standards to be exceeded.
Although NFFE characterizes this
testing requirement as a rule under
TSCA section fl. EPA believes that such
requirement is more appropriately
characterized as a rule under TSCA
section 4.
3. Section 8. NFFE requests that EPA
promulgate immediately effective roles:
(1) Under section 6(a] to require
manufacturers, processors and
distributors to report amounts of SB
latex manufactured and its uses; (2j
under section 8(c) to require
manufacturers to maintain and present
for inspection records of allegations of
advene health effects related to
exposure to 4-PC or mixtures containing
4-PC: and (3) under section 8(d) to
require manufacturers to submit lists of
health and safety studies on 4-PC or
mixtures containing 4-PC and to submit
health and safety studies on 4-PC in
their possession.
4. Other remedy requested. NFFE
requests that EPA develop and issue a
"Chemical Advisory" directed to
building managers regarding exposure to
volatile chemicals in carpeting,
particularly 4-PC and the hazard to
those persons apparently experiencing
MCS. This remedy is not petitiottabie
under TSCA.
m. Evaluation of the Petition
A. Legal Standards
Section 21, itself, does not specifically
state the criteria under which EPA
should decide whether to grant or deny
a citizens' petition. Section 21 merely
states that EPA must grant or deny
within 90 days.
However, there are standards under
sections 4.6 and B for issuing
regulations, and there are standards
imposed on the court for deciding
whether to order EPA to initiate
rulemaking in the event of a lawsuit
filed by me petitioner after denial of a
section 21 petition. EPA has examined
these standards, summarized in Unit
II.A. of this notice, aa the beeie far
evaluating KFFE's petition. Following to
a discussioa of mow these standards
apply to evaluation of the NFFE petitioa.
1. Legal standard* regarding tatting
rulet. With respect to NFFEs request for
initiating testing rules wader aecuoa 4,
EPA considered the legal standards
found in both aectioa 4 aad sectina C.
Some standards nnntaiaed ia tfeeee
sections are eeeeatially the esaai For
example, uader section 4 KPA may
issue a nde to require teatiag tf it fiode
that data on i
to evaluate its effects, and that the
chemical may present an unreasonable
risk of injury or is produced in
substantial quantities, and either may
result in significant or substantial
human exposure, or may result in
substantial environmental release.
Section 21 allows a court to order EPA
to initiate rulemaking if it makes.
essentially, the same determination after
a de now review of the petition.
Three criteria are relevant to
evaluating these standards for this
petition: (1) Sufficiency of data. (2)
unreasonable risk and (3) significant or
substantial exposure. Decisionmaking
under each of these criteria depends on
the particular facts involved in any
particular case and involves significant
judgment on the part of the
decisionmakerEPA or a court. The
unreasonable risk criterion, however.
requires elaboration because it is a
general standard that applies to both
section 4 and section 6. This elaboration
appears later in this Unit.
EPA applied another standard to its
evaluation of NFFTTs request for testing
rules not found in section 21, but only
found in section 4. Under section 4. EPA
most find that testing is necessary to
develop the data needed for evaluating
a chemical before it may issue a testing
rule. Under this requirement. EPA needs
to consider such issues as whether there
is a testing method that can be expected
to develop useful data or whether there '
are other means of obtaining data
without resorting to testing.
2. Legal standards regarding control
rules. In evaluating NFFFs request feu-
rules under section 6 to control
chemicals. EPA assessed whether such
rules are necessary to protect against
unreasonable risk. This is the same test
the court would apply under section 21.
The test has two aspects. First there
must be an "unreasonable risk" of injury
against which protection is needed.
Second. TSCA rules must be
"necessary" to protect against that risk.
EPA interprets toe standard that rules
are "necessary" to require consideration
of whether TSCA rules are the
appropriate remedy to protect against
the risk described. For example,
regulations under other Federal statutes,
whether administered by EPA or other
agencies, may be more appropriate than
TSCA rates. Another consideration may
be whether State or local initiatives
coastkute the appropriate remedy
instead of Federal roles.
3. re*eaaaofc rial. Unreasonable
risk is the baste regale tory standard
under TSCA. A applies «e raies ander
both section <4 aad section 6. and to
judicial decMioas oa section 21
B-2
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petitions. The importance of the
treasonable risk standard to TSCA
ecisionmaking requires that the
standard be given special explanation.
The finding of unreasonable risk is a
judgment under which the
decisionmaker determines that the risk
of health or environmental injury from a
chemical outweighs the burden to
society of potential regulations. The
section 4 requirement that EPA must
find that a chemical "may" present an
unreasonable risk requires less
information on risk than the section 6
requirement to find that a chemical
"will" present an unreasonable risk.
This concept is discussed in the
legislative history of TSCA. The House
Report notes that risk is measured by
elements of probability of harm and
severity of harm that may vary in
relation to each other, and that the
regulatory effect will be of greater
significance in making an unreasonable
risk determination if greater restrictions
are imposed by regulation (H.R. Rep. 94-
1341.94th Cong.. 2d Sess., pages 14 and
IS). Thus, to impose regulations banning
a chemical, for example, and thereby
imposing a significant burden on
society, the decisionmaker would need
considerable information on toxicity
and exposure. On the other hand, the
decisionmaker would need less
information on risk if the regulation
were only a testing requirement that
would not. by itself, result in the loss of
benefits of the chemical to society.
In practical application, an
unreasonable risk decision cannot be
made considering risk alone. Rather, the
probability of harm must be considered
against the impacts of regulation. Thus,
if exposure to a chemical is low and
extremely high burdens would be
incurred to achieve small incremental
risk reduction, a decisionmaker might
not find the risk unreasonable. On the
other hand, an unreasonable risk may
be found if the evidence on the risk
asserted is marginal but the impact of
regulation is low. Thus, the identified
risk may justify the minimal coats of a
testing rule or a labelling requirement
but would not justify the costs of more
restrictive measures.
These considerations are especially
relevant in the case of the NFFE
petition.
B. Evaluation ofNFFE's Assertions
EPA disagrees with NFFE that the
health problems cited in the petition are
likely caused by 4-PC exposure, or even
that the petition identifies human
disease conditions (MCS) that the
medical community generally recognizes
or for which there are evaluation
techniques. Instead, NFFE's risk case is
entirely based on the presence of 4-PC
at the site of complaints about non-
specific health effects.
EPA recognizes that certain
individuals may have adverse reactions
from exposure to indoor air
contaminants. However. EPA's
evaluation of 4-PC shows no evidence of
such toxicity and. indeed, shows that it
is an unremarkable chemical. There are
no clinical studies or epidemiology data
for 4-PC. Animal studies at dose levels
well above those measured or expected
at the EPA Headquarters do not indicate
acute toxicity or skin sensitization. In
addition, no credible physiological or
biochemical causal mechanism has been
identified to link 4-PC to the effects
alleged in the petition. This evidence
does not. however, entirely rule out a
causal relation of 4-PC to effects on
hypersensitive individuals.
NFFE has shown no definitive
evidence that persons exposed to SB
latex but not to carpet suffer the same
complaints as people exposed only to
carpet. Furthermore, 4-PC is not the only
chemical found at the carpet complaint
sites at EPA. Other chemicals, such as
toluene, have been found at the same
sites. A number of the chemicals found
at these sites could produce the same
non-specific symptoms that the
petitioner attributes to 4-PC. It appears
that some persona, NFFE included, may
have alleged 4-PC as a cause of adverse
effects partly because the odor of the
chemical is so readily detectable. It has
an extremely low odor threshold.
approximately 0.5 parts per billion (ppb).
EPA does not rule out that complaints
associated with the installation of
carpets could be the result of the
complex mixture of off-gassing
chemicals, including the VOCs in
carpets, padding and installation
materials. The composition and
concentrations of off-gassing chemicals
vary between carpets. The large surface
area of carpet compared to the surface
areas of other room components might
also be responsible for capturing and
emitting of contaminants from many
other sources.
C. Evaluation ofNFFE's Remedies
EPA has determined that NFFE's
assertions concerning 4-PC do not
support its proposed remedies. The
Agency's analysis follows.
1. Section 4. EPA has determined that
the toxicity testing requested by NFFE is
not justified under the legal standards of
TSCA and the existing scientific
evidence. There are insufficient data to
reasonably determine or predict the
effects of low levels of 4-PC and other
chemicals that may be emitted from
carpets. However, the other
determinations under sections 4 and 21
cannot be made at this time.
First, EPA is not able to determine
that, in the absence of sufficient data. 4-
PC either may present an unreasonable
risk or is emitted at levels that may
cause significant exposure. EPA's
evaluation of the available toxicity data,
as summarized in Unit III.B. of this
notice and as described in more detail in
the administrative file prepared for this
petition response, shows no particular
concern for 4-PC. There is not even an
apparent theoretical basis (structure-
activity relationship or causal
mechanism) that would lead to a
significant concern for 4-PC. Thus.
exposure to 4-PC off-gassing from
carpeting does not appear to be
unreasonable or significant, since it is
present at such low levels. The low odor
threshold of 4-PC is the only apparent
reason for indicting the chemical. EPA
believes this is not an appropriate
reason to require special testing of this
chemical.
Second, different considerations apply
to the evaluation of exposure to total
VOCs emitted from carpeting. The large
amounts of new carpet distributed in the
U.S. and the large surface area in the
indoor environment lead to a concern
that there may be substantial exposure
to off-gassed chemicals. Thus, EPA
believes that it is appropriate that
companies test in order to characterize
VOC emissions from carpeting products.
and will require such testing under
section 4 if it cannot be accomplished
voluntarily. This testing will help
determine if any exposure reduction
measures are necessary, as more fully
explained below.
Testing might be done either by carpet
manufacturers or by raw material
suppliers. For example, the Styrene
Butadiene Latex Manufacturers Council
(SBLMC), a trade association of
companies that manufacture SB latex,
has told EPA that its member companies
have attempted 4-PC reduction over the
last 2 years. The SBLMC, however, has
not provided data on attempted
manufacturing process changes or on
levels of 4-PC in individual products.
The SBLMC has told EPA that the
present average level of 4-PC in SB latex
is 123 parts per million (ppm). In a
related matter, no information has been
collected regarding the 4-PC levels in a
related product styrene-butadiene
rubber latex, which is sometimes used
to glue down carpets. Also, the Carpet
and Rug Institute (CRI), a trade
association of carpet manufacturers, has
informed EPA of ongoing studies of
carpet emissions. Results are expected
in the next few months.
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17407
Finally, with respect to the potential
adverse health effects of total carpet
emissions, the studies requested by
NFFE are not likely to develop the data
needed. Accordingly. EPA has decided
to consider whether other studies can be
developed to evaluate the potential
effects. The rhechanistic case-control
epidemiological studies requested by
NFFE are not appropriate. Case-control
studies look at subjects with a well
defined disease compared to subjects
without the disease to examine the
possible similarities in exposures. If the
disease is not well-defined, as with the
conditions that the petitioner describes
as MCS or AIR, epidemiologic studies
will not clarify a disease mechanism or
etiology. Studies done after the fact of
disease cannot assign the presence or
levels of enzymes (as the petitioner
requested) to particular chemical
exposures. EPA believes that it would
be more useful to consider a prospective
study of several populations, such as
those who appear most sensitive to
carpets and those who work with
carpets directly.
EPA concludes that the animal studies
suggested by NFFE would not be useful
NFFE claims that there may be a
breakdown in the immune system, and
perhaps other systems, of certain
sensitive persons caused by exposure to
4-PC and other off-gassing chemicals.
However, there is no adequately defined
connection between the symptoms
reported in humans by NFFE and its
requested measurements of: (1) The
binding of a chemical to cellular
proteins and DNA. (2) enzyme levels. (3)
immune system marker chemicals, or (4)
neurotransmitter substances.
Changes in the immune system have
historically not been shown to be a
reliable predictor of the symptoms of
concern presented in NFFE's petition.
Exploratory research on broad classes
of indoor air pollutants is needed to
develop such predictive capability.
Thus, it is appropriate for the research
cost to be borne by a broader segment
of society rather than by the carpet
industry alone.
2. Section 0. Under unreasonable risk
standards. EPA does not believe that the
health effects evidence on 4-PC justifies
immediately effective rules.
requirements for indoor air levels in the
low part per trillion range (well below
current detection limits) or requiring
buying back of carpet already installed.
Such types of rules are too restrictive.
given the paucity of evidence on 4-PC
EPA believes that by focusing on these
types of rules for 4-PC, resources would
be diverted from potentially more
fruitful efforts to address Indoor air
pollution generally, including carpet
emissions. A major problem with NFFE's
requested remedies is that resources
would be spent on addressing chemicals
that may in fact cause no problem. In
addition. NFFE's remedies may unfairly
indict particular chemicals or a
particular industry and could lead to
undue public concern.
EPA is willing to consider, however.
whether it is possible under
unreasonable risk standards to develop
cost-effective control steps to reduce
levels of all VOCs that may be emitted
from carpet, including 4-PC. A good
understanding of the effects of complex
mixtures, particularly in the case of
sensitive individuals, may not be
available for a long time. Thus, at least
for the near term, further study of the
health effects of complex mixtures in
indoor air. should not delay efforts to
address immediate concerns. EPA.
therefore, believes that until more
definitive information is available, the
Agency should promote reductions of
chemicals emitted from carpets.
3. Section 8. The principal issue
regarding NFFE's section 8 request is
whether to institute ruiemaking or
obtain the information on a voluntary
basis. Much of the information
requested by NFFE (i.e. health and
safety studies) has already been
obtained from industry; industry has
also informed EPA of ongoing animal
studies. In addition, production data and
use information on SB latex have been
provided by industry.
The NFFE requested section 8(c)
remedy for records retention for SB
latex is already established at 40 CFR
part 717. The SB latex industry has
agreed to provide by May 1990 their
existing records regarding adverse
reactions allegation* associated with SB
latex as well as existing health and
safety studies on SB latex. There may be
little incremental benefit to issuing rules
to gather information that industry will
provide voluntarily and more quickly
than through ruiemaking. EPA will
consider rules as necessary to obtain
information about processing which can
help identify appropriate exposure
reduction measures.
4. Chemical advisory. EPA believes
that its present and proposed
information dissemination and technical
assistance activities already provide an
effective means to reach the public
regarding health effects information.
Furthermore, issuance of a Chemical
Advisory is not a petitionable item
under section 21.
IV. EPA's Response
The NFFE petition requested that EPA
publish a number of immediately
B-4
effective rules to protect the public from
exposure to the compound 4-PC and
mixtures containing 4-PC. EPA.
however, denies this Section 21 petitio
because the evidence on the risk from 4^
PC and other VOCs does not support the
remedies requested.
The Agency, however, recognizes
NFFE's concerns and would certainly
agree that an absence of scientific
certainty does not necessarily mean an
absence of risk. In addition, the Agency
recognizes that new carpeting can be a
source of widespread human exposure
to low levels of VOCs. As a matter of
policy, the Agency believes it is prudent
to minimize indoor human exposure to
VOCs and other indoor air
contaminants where reasonable and
that efforts on the part of manufacturers
to reduce product emissions should be
strongly encouraged.
In light of these findings, the Agency
is taking several steps. First, the Agency
is formally requesting that the carpeting
industry undertake a voluntary program
to conduct periodic total VOC analyses
on a company-by-company and product-
by-product basis to provide the
interested public with comparative
information on total VOC emissions.
Such a program, which may include
labeling of carpet products for total
VOC emission, would help to stimulate
efforts to lower overall VOC emissions.
Second, the Agency is inviting all
interested parties to participate in a 1-
year public dialogue process (discussed
below) to initiate this program. Third.
the Agency will also continue its risk
management activities and research to
identify possible health effects
associated with complex air mixtures
emitted by carpets and low level VOC
exposures. These ongoing activities and
planned research under the indoor air
program are summarized in Unit V of
this notice.
EPA's public dialogue process will
continue for approximately 1 year. The
Agency will invite interested members
of the public to participate. EPA will
seek participation by NFFE. the
carpeting products industry, consumer/
public interest groups, other Federal
agencies, and other interested parties.
The goal of this dialogue will be to
characterize emissions and identify low-
impact feasible VOC controls that could
be implemented in the near term, not to
further characterize the health effects of
chemicals emitted from carpeting.
The specific charges to the
participants in the dialogue will be to:
1. Develop standard methodologies for
testing carpet emissions and obtain
commitments to test carpeting. The
Agency will be requesting the carpet
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industry to voluntarily commence
appropnate periodic testing (probably
on a company-by-company. product-by
product basis) to quantify the total
emissions of VOCs from their products
to provide the interested public with
comparative information on total VOC
emissions from new carpets. Should an
acceptable voluntary agreement not be
obtained within a reasonable time, the
Agency intends to propose a test rule
under section 4 of TSCA to compel such
testing.
2. Identify information needs for
assessment of emission control
feasibility, including data on carpet
manufacture and installation technology
and commercial activities associated
with carpet installation. This data
development and/or collection could be
accomplished either by issuance of rules
under TSCA sections 4 or 8, or by
voluntary submissions.
3. Evaluate potential controls for
reducing emissions, including product
and/or emission standards, and labeling
of carpet for VOC emissions. These
could be accomplished either voluntarily
or through low impact TSCA rules.
Other appropriate statutes administered
by either EPA or other Federal agencies
will be considered, as required by
section 9 of TSCA. If EPA pursues
mandatory control options under TSCA.
EPA will be required to make an
unreasonable risk finding under section
6.
4. identify VOC exposures which are
associated with carpet installation but
not necessarily from a carpet source
(adhesives. floor preparation, etc.) and
recommend any appropriate action* to
reduce them.
A simultaneous effort will be made to
assess whether prospective
epidemiologic studies can be developed
to determine the response
characteristics of individuals exposed to
carpet emissions and assess whether
other health effects studies (e-g. human
chamber, in vitro, or animal studies)
should be performed as methodologies
are developed and become available. A
prospective epidemiology study would
require identification and definition of
symptoms of concern, with selection
criteria including expressions of
symptoms within a specified time after
an exposure event Workable test
methods to measure the relevant
symptoms would need to be identified.
It may take as long as l year to
determine whether appropriate
epidemiology protocols can be
developed. If a determination is made
that protocols are feasible, EPA will
require industry to develop specific test
protocols and carry them oot
The administrative actions to
establish the dialogueincluding
meetings, reports, and other pertinent
informationwill be described in a
separate Federal Register notice to be
issued by June 1,1990.
V. EPA Indoor Air Program
The issue of carpet emissions and
their contribution to adverse health
effects has been treated by the Agency
as part of the overall indoor air pollution
problem. Prior to and independently of
the petition. EPA has undertaken a risk
management and research program for
indoor air pollution as part of its
responsibilities under Title IV of the
Superfund Amendments and
Reautborization Act of 1966 (SARA).
Title IV of SARA mandates a
comprehensive indoor air quality
research and development program by
EPA to identify, characterize, and
monitor sources and levels of indoor air
pollutants, to develop instruments for
indoor air quality data collection, and to
identify high risk building types.
This program has two major elements.
risk management and research, which
are discussed below.
A. Risk Management
The indoor air pollution risk
management program undertaken by
EPA emphasizes nonregulatory
programs of information dissemination,
technical assistance, guidance and
training to build State and local
government and private sector
capabilities to address indoor air quality
problems. However, the Agency also
believes that for identified high priority
problems, regulation under available
statutes, including the Toxic Substances
Control Act the Federal Insecticide.
Fungicide, and Rodenticide Act and the
Safe Drinking Water Act may also be
appropriate.
In an effort to disseminate available
information on indoor air quality, EPA
has published a number of documents
on indoor air pollution and its
mitigation, including a major "Report to
Congress on Indoor Air Quality"
(August 1989), a series of fact sheets on
indoor air issues, including "Sick
Buildings" and "Ventilation and Air
Quality in Offices," a "Survey of Private
Sector Indoor Air Quality Diagnostic
and Mitigation Firms." and several
publications dealing with residential
indoor air issues.
EPA is currently developing guidance
documents directed to specific
audiences, such as architects and
engineers, building owners and
managers, and new home builders and
buyers, on the prevention, diagnosis and
mitigation of indoor air quality problems
in commercial and residential
structures. As an example, the guidance
document for building owners and
managers is designed to be used in
assessment programs to identify and
correct potential problems, and to
manage related indoor air quality
problems, through building
investigations, employee relations.
contracting and mitigation techniques.
EPA is also exploring, through a public
dialogue process, whether a consensus
based credentialing system for private
sector indoor air quality diagnosis and
mitigation firms is feasible and
desirable. In addition, a manual for
physicians on the recognition, diagnosis
and treatment of illnesses related to
indoor air quality will be developed.
EPA is developing a general indoor air
quality training program for State and
local governments to help them to
identify and mitigate indoor air quality
problems. In addition. EPA will be
developing model State programs for
indoor air quality assessment and
response.
B. Research
The objective of EPA's indoor air
pollution research program is to gain
information to reduce exposure to
indoor air pollutants known to cause
health risks. The first step in achieving
this objective is the identification and
characterization of the health risks
posed by indoor exposures. Once the
risks have been adequately
characterized, exposure reduction
techniques can then be evaluated on the
basis of their practicality, cost, and
effectiveness.
To characterize pollutants from off-
gassing or volatilization that might occur
from carpets, wall coverings, paints, and
other products. EPA is conducting small
chamber testing of the indoor air
contribution of construction products.
Levels of chemicals that would be
expected indoors can then be estimated
based on such emissions data, using
indoor air models developed by EPA.
EPA is encouraging emissions testing
by industry using consensus, verified
methods. The American Society for
Testing and Materials (ASTM) is
currently reviewing an EPA-developed
standard small-chamber test method to
characterize the complex emissions
from products used indoors, such as
carpeting. EPA is conducting monitoring
and analytical methods research that
includes the development and
evaluation of personal and micro-
environmental monitors to measure
pollutants in indoor air. including
monitors for semiVOCs and polar
organic compounds. This research
B-5
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Federal Register / Vol. 55. No. 79 / Tuesday. April 24. 1990 / Notices
17409
includes compiling these methods into a
compendium of monitoring and
analytical techniques for indoor
pollutants, including methods for semi-
VOCs and polar organic compounds.
EPA is developing exposure assessment
techniques for application to large
buildings.
EPA is conducting research on the
effects of VOC mixtures on
neurobehavioral and physiologic effects
on humans. EPA is developing a risk
assessment methodology to evaluate the
human health risks from exposure to
indoor air pollution for both cancer and
non-cancer endpoints.
To understand the national scope of
the indoor air problem. EPA is
developing baseline data. EPA is also
resolving specific indoor air pollution
inquiries and complaints from within
EPA. As part of this effort EPA has
been developing and implementing a
national Indoor Air Quality and Work
Environment Study to be implemented
at the EPA's Headquarters facilities.
where EPA staff have expressed
concerns about indoor air quality.
Actions to improve indoor air quality at
EPA's facilities are being taken in
response to the survey results, and other
information.
In addition. EPA is engaging
independent experts to assist the
Agency in the development of a long-
range research strategy relative to MCS
with the goal of producing the
information necessary for establishing
Federal policy on this issue.
EPA is continuing development of risk
assessment information and methods for
evaluating risks associated with specific
sources cf indoor air contamination. As
part of this process, EPA is co-
sponsoring a 3-day technical workshop
scheduled for April 17-19.1990. to
address risk assessment methods for
indoor air complex chemical mixtures.
including carpeting.
VI. Administrative Record
EPA has established a public record
of those documents the Agency
considered in denying NFFE's petition.
The record consists of documents
located in the file designated by Docket
Control Number. OPTS-211027. located
at the TSCA Public Docket Office. This
Docket is available for reviewing and
copying from 8 a.m. to 4 p.m.. Monday
through Friday, excluding legal holidays,
at the following address: Environmental
Protection Agency. Rm. NE-G004. 401 M
St.. SW.. Washington. DC 20460. The
public record consists of all documents
in the OPTS-211027 file and all
documents cited in the documents in
that file.
Dated: Apni 17.1990.
William K. Reilly,
Administrator.
[FR Doc. 90-9464 Filed 4-23-90; 8.45 am)
NJJNOCOOE «MO-M-D
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APPENDIX C
Federal Register, Vol. 55, No. 130;
Carpet Emissions Reduction;
Policy Dialogue
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Federal Register / Vol. 55. No. 150 / Friday, August 3. 1990 / Notices
31641
[OPTS-505; FRl-3816-5]
Carpet Emission* Reduction; Policy
Dialogue
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Notice of public meeting.
SUMMARY: EPA is initiating a policy
dialogue as part of its efforts to gather
data which will assist EPA in
determining what future activity is
necessary to assess total volatile
organic chemical emissions from carpet
and reduce the public's exposure to total
compounds which may off-gas from
carpeting.
DATES: The first meeting has been
scheduled for August 21,1990. The
meeting will start at 8:30 a.m. and end at
approximately 5 p.m.
ADDRESSES: The meeting will be held at
the Holiday Inn Crown Plaza. National
Airport 300 Army Navy Drive,
Arlington. VA 22202, Tel. (703) 892-4100.
FOR FURTHER INFORMATION CONTACT:
Oscar Hernandez. Existing Chemical
Assessment Division (TS-778), Office of
Toxic Substances, Environmental
Protection Agency, room E 409,401M
Street. SW., Washington, DC 20460.
Telephone: (202) 382-3560.
SUPPLEMENTARY INFORMATION:
I. Background
On January 11.1990, the National
Federation of Federal Employees
(NFFE). Local 2050, petitioned EPA
under section 21 of the Toxic
Substances Control Act (TSCA), 15
U.S.C. 2620 to initiate rulemaking
proceedings, under sections 4,8, and 8
of TSCA. 15 U.S.C 2603. 2605, and 2807.
to reduce emissions from new carpets.
EPA has decided (55 FR17404) not to
initiate the specific rulemaking
proceedings requested by NFFE because
the Agency disagreed with the specific
assertions regarding the health risk
posed by carpeting and with the
remedies sought
The Agency believes, however, that
an absence of scientific certainty does
not necessarily mean an absence of risk
and that efforts to better characterize
carpet emissions, and potential health
effects which may be associated with
carpeting, should be continued and
expanded. In addition, the Agency
recognizes that new carpeting may be a
significant source of human exposure to
low levels of volatile organic
compounds (VOCs). Ac a matter of
policy, the Agency believes it is prudent
to minimize indoor human exposure to
these chemicals where reasonable and
that efforts on the part of manufacturers
to reduce product emissions should be
strongly encouraged.
In light of these findings, the Agency
is taking three major initiatives. First
the Agency is formally requesting that
the carpeting industry undertake a
voluntary program to conduct periodic
total VOC analyses on a company-by-
company and product-by-product basis
to provide the interested public with
comparative information on total VOC
emissions. Second, the Agency is
inviting parties representing concerned
interest groups to participate in a 1-year
dialogue process designed to work out
the details of the voluntary testing
program mentioned above, and to
explore and, where possible, reach
agreement on a variety of issues
including: The sampling and analytical
methods for the voluntary testing, any
additional information needed, and cost-
effective process changes to reduce
emissions. Third, the Agency will
continue its ongoing exposure reduction
and research activities on indoor air
quality issues generally and on the
potential health effects of exposure to
low level VOC mixtures, in particular.
A separate, but concurrent effort, will
be initiated to assess the feasibility of
prospective epidemiology studies to
determine the response characteristics
of individuals exposed to carpet
emissions.
tt. Participants
The Agency has contracted with a
private consulting firm to identify key
individuals and groups who are
prospective participants in the dialogue.
For further information, contact the
Existing Chemical Assessment Division
as noted above.
Dated: July 30, 1990.
IoMphA.Cui*v
Acting Director,- Office of Toxic Substances.
[FR Doc. 90-18172 Filed 8-2-90; 8:45 am]
OM
-VMI
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APPENDIX D
Schedule of Carpet Policy
Dialogue Meeings
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8/21/90
9/6/90
9/25/90
9/26/90
10/17/90
10/24/90
10/25/90
11/29/90
11/30/90
1/15/91
2/27-28/91
2/28-3/1/91
4/8-9/91
4/9-10/91
5/20-21/91
5/22/91
6/27-28/91
7/29-31/91
9/26-27/91
APPENDIX D
Schedule of Carpet Policy Dialogue Meetings
MEETING SCHEDULE
Carpet Policy Dialogue Plenary meeting
Product Testing Subgroup meeting
Product Testing Subgroup meeting
Process Engineering Subgroup meeting
Product Testing Subgroup meeting
Process Engineering Subgroup, Product Testing Subgroup meeting
Carpet Policy Dialogue Plenary meeting
Carpet Policy Dialogue Plenary meeting
Process Engineering Subgroup, Product Testing Subgroup meeting
Carpet Policy Dialogue Plenary meeting
Subgroup meetings (Product Testing, Process Engineering, Public Communications)
Carpet Dialogue Plenary meeting
Subgroup meetings (Product Testing, Process Engineering, Public Communications)
Carpet Policy Dialogue Plenary meeting
Subgroup meetings (Product Testing, Process Engineering, Public Communications)
Carpet Policy Dialogue Plenary meeting
Subgroup meetings (Product Testing, Process Engineering, Public Communications)
Subgroup Meetings (Product Testing, Process Engineering, Public Communications)
and Carpet Policy Dialogue Plenary meeting
Public Communications Subgroup Meeting and Carpet Policy Dialogue Plenary
meeting
D-l
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APPENDIX E
Test Method for Determining Total
Volatile Organic Compound Emission Factors
from Carpet Under Defined Test Conditions
Using Small Environmental Chambers
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TEST METHOD FOR DETERMINING
TOTAL VOLATILE ORGANIC COMPOUND EMISSION FACTORS
FROM CARPET UNDER DEFINED TEST CONDITIONS
USING SMALL ENVIRONMENTAL CHAMBERS
1.0. SCOPE
1.1. The following method measures the total volatile organic compound (TVOC) emission factor from
flooring materials using test conditions designed to simulate product use in residential and commercial settings.
The method provides an estimate of TVOC that is based on the sampling and analysis procedures specified
herein. These procedures may not adequately collect and/or quantify all organic compounds emitted from the
carpet specimen being analyzed. The method will, however, provide data that can be used to compare
emissions between different carpet products. The level of total volatile organic chemical emissions is
determined by observing the TVOC concentration in a small environmental chamber under specified test
conditions. The observed concentration is then related by a mathematical calculation to an emission factor, a
product specific variable. The quantity of TVOC in the environmental chamber air is determined by gas
chromatography or gas chromatography/mass spectrometry. The methodology is generally applicable to
volatile organic compounds emanating from individual flooring materials including carpet, carpet cushions,
adhesives, and subfiooring. Applicability to adhesives may require procedural changes in sample preparation
and analytical measurement techniques.
1.2. The "generic" standard environmental chamber practices currently described by the U.S. EPA in its
document "INDOOR AIR SOURCES: USING SMALL ENVIRONMENTAL CHAMBERS TO
CHARACTERIZE ORGANIC EMISSIONS FROM INDOOR MATERIALS AND PRODUCTS," EPA
REPORT 600/8-89-074, and ASTM Guide D5116-90, "STANDARD GUIDE FOR SMALL-SCALE
ENVIRONMENTAL CHAMBER DETERMINATIONS OF ORGANIC EMISSIONS FROM INDOOR
MATERIALS/PRODUCTS," are coupled with "flooring specific" environmental chamber requirements and
analytical procedures. These requirements are necessary for the study of TVOC emission factors from carpet
and other flooring specific materials if acceptable accuracy and precision are to be achieved.
1.3. The methodology provides a standard means of reproducibly and accurately testing carpet and other
flooring materials under controlled laboratory conditions.
1.4. This methodology, as presented, is technologically complex and requires a high degree of analytical
capability and experience in environmental chamber operation, sorbent system use, and high-resolution gas
chromatographic and/or mass spectrometric/gas chromatographic analysis. Individual laboratories performing
this method will find it necessary to establish their own specific standard operating procedures to achieve the
specific methodology criteria.
2.0. REFERENCE DOCUMENTS
2,1. ASTM Guide D5116-90 for Small Scale Environmental Chamber Determinations of Organic Emissions
from Indoor Materials/Products.
2.2. ASTM Test Method 741 for Determining Air Leakage Rates by Tracer Dilution.
2.3. ASTM D3195 Recommended Practice for Rotameter Calibration.
2.4. ASTM D13S6 Definitions of Terms Related to Atmospheric Sampling and Analysis.
E-l
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2.5. ASTM E355 Recommended Practice for Gas Chromatography Terms and Relationships.
2.6. ASTM Committee E-ll on Quality and Statistics, "Manual on Presentation of a Data and Control Chart
Analysis, Sixth Edition.*
2.7. Tichenor, "Indoor Air Sources: Using Small Environmental Chambers to Characterize Organic
Emissions From Indoor Materials and Products," EPA report 600/8-89-074. This report is available to
the public through the National Technical Information Service, Springfield, VA 22161.
2.8. Matthews, 'Environmental Chamber Test Methodology for Organic Vapors from Solid Emission
Sources," ATMOS. Env., 21, p. 321, 1987.
2.9. Tichenor, "Organic Emissions from Consumer Product and Building Materials to the Indoor
Environment," J of APCA, 38, p. 264, 1988.
2.10. Black, "Environmental Chamber Methodology for the Study of VOCs Emitting from Manufactured
Products," Proceeding of Indoor Air '90, Toronto, August, 1990.
2.11. CRI, "Standard for Installation of Textile Floorcovering Materials," Publication 104, The Carpet and
Rug Institute, 310 Holiday Avenue, Dalton, GA 30720.
2. 12. U. S. EPA, "Compendium of Methods for Determination of Toxic Organic Compounds in Ambient
Air" EPA report 600/4-89/017. This report is available to the public through the National Technical
Information Service, Springfield, VA 22161; PB90- 116989.
2.13. Winberry et al., "Compendium of Methods for the Determination of Air Pollutants in Indoor Air" EPA
report 600/4-90/010. This report is available to the public through the National Technical Information
Service, Springfield, VA 22161; PB90-200288.
3.0. TERMINOLOGY
3.1. Definitions and Terms Specific to This Standard.
AIR CHANGE RATE (ACH). The ratio of the volume of air brought into the chamber hourly and the
chamber volume measured in identical units (typically expressed in air changes per hour (ACH) or hr .
EMISSION FACTOR (mg/m^far). A product specific factor describing the mass of chemical emitted
from a product per exposed area of the product per unit time.
ENVIRONMENTAL TEST CHAMBER. A test apparatus with highly controlled operational
parameters designed to provide accurate and reproducible emission factors for sources of indoor air pollutants.
LOADING RATIO (m*'*)' ^ne rat*° °^ ^P086^ surface area of the test product and the free
chamber volume, measured as mVm'.
4.0. SIGNIFICANCE AND USE
4.1 The minimization of VOC emissions from interior products and processes has been suggested as a
prudent step in reducing human exposures to chemical emissions.
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4.2 The results of this method can be used to assist those involved with the design of new construction and
building refurbishing in order to give consideration to emissions from products and interior activities.
4.3 This methodology provides a standard means of testing carpet and other flooring materials under
surrogate conditions, i. e., product loadings with operational parameters and environmental conditions
consistent with a product's end use.
4.4 TVOC data alone are inadequate to determine health effects. The method will, however, provide data
that can be used to compare emissions between different carpet products.
4.5 The method incorporates a small environmental chamber, approximately 0.05 m3 in size to evaluate the
level of TVOC in the flooring materials over a specified duration of time. Environmental chambers
larger or smaller in size may be used if acceptable correlation with the latter chamber is shown
(correlation coefficient greater than 0.90 at multiple points in time ranging from the lowest obtained
emission factor to the highest obtained emission factor). Conditions controlled in the method include:
4.5.1. Sample collection and packaging to preserve the product's manufactured chemical
integrity;
4.5.2. Sample preparation in a presentation for individual materials and "installed systems";
4.5.3. Conditioning of the product or system prior to obtaining the test value;
4.5.4. Exposed surface area of the product being tested;
4.5.5. Environmental test chamber construction and operation;
4.5.6. Environmental test chamber temperature and moisture content;
4.5.7. Environmental test chamber air changes per hour;
4.5.8. Air circulation within the test chamber;
4.5.9. Accuracy and precision control of the chamber system;
4.5.10. Accuracy and precision of the analytical methodology; and
4.5.11. Sample archiving.
4.6. The test procedure employs a single set of experimental parameters to assess the TVOC emissions of
certain carpet and associated flooring materials. Care must be exercised in the extension of the results
to actual TVOC emissions under different conditions. This method provides an accurate and precise
comparison of TVOC levels from different products intended for the same use.
4.7. The test method permits variance of experimental parameters to assess TVOC emissions of carpet and
associated flooring materials under different usage situations. Parameters which can be independently
controlled include air temperature, air moisture level and air exchange rate.
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5.0. THE ENVIRONMENTAL CHAMBER
5.1. The interior volume of the environmental chamber should be approximately O.OS m , unless data exist
to demonstrate the adequacy of a different size as described in section 4.4 above. Surfaces shall be
sufficiently chemically inert that recovery rates of a representative mixture of TVOCs including
hexanol, toluene, cyclohexane and decane is greater than 95% at a mixture concentration of 40 /ig/m'
(10 pg/m' of each). All joints of the chamber must be permanently sealed except those absolutely
necessary, e.g., the opening for loading and unloading the sample and environmental probes. These
ports must have a self-sealing capacity comprised of non-VOC emitting and non-VOC
adsorbing/absorbing materials.
5.2. The air within the chamber must be free of any obstructions or contamination such as fans, humidifiers
or coils. The internal air must only come in contact with the inert chamber walls, the air diffusion
system, which includes inlet and outlet ports and environmental measurement devices.
5.3. Internal chamber air must be well-mixed and must comply within 5% of the theoretical well-mixed
model. A discussion of this evaluation is given in reference document 2.1, ASTM Guide D5 116-90. It
is recommended that SF(, or an other inert gas, be used as a tracer gas to determine compliance with
the theoretical curve. Another useful reference here is Method IP-4B in reference document 2.13. A
known concentration and constant supply of SFf is introduced into the chamber, and the chamber
concentration of SF« versus time profile is measured. The time duration of the tracer gas experiment
should be comparable to that of the actual experiments with floor covering materials. Mathematically,
this experimental curve should comply within a 5% relative standard deviation (RSD) of the theoretical
curve. This can be accomplished by estimating the RSD of the mean of the deviation of the difference
between the observed and theoretical values. An estimate of the variance is:
* « - 1
where, o = observed value; t = theoretical value; n = number of observations. The mean of
the differences would be:
The RSD is then:
jesD - -
m
This mixing evaluation should be confirmed with the flooring mounting substrate in place. An
empty chamber may not give a realistic representation of the air mixing within the chamber
during actual testing.
5.4. Purified air must be provided as the chamber supply air. It is necessary that the supply air
backgrounds be sufficiently low to achieve statistically meaningful analytical measurements at the levels
anticipated. Purified air must not have a background contributing concentrations greater than 2.0
Mg/m*ofTVOC.
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Supply air must be accurately and reproducibly metered to the chamber, and maintained at a rate of
1.00 ± 0.05 (precision standard deviation) air changes per hour. The accuracy of this air exchange
rate must be confirmed using procedures similar to that presented in ASTM method 741 for tracer gas
applications, and found to have less than 10% relative error.
5.5. Other environmental conditions must be maintained reproducibly within the ETC environment
including:
Temperature at 23°C ± 1.0°C (precision standard deviation)
Relative Humidity at 50% ± 5% (precision standard deviation) (Initial variance in the chamber may be
observed after loading a product as a result of 1) outside air entrance of differing humidity, and of 2)
moisture contribution from the product being tested. These variances should be recorded.)
Acceptable accuracy levels are 5 % average relative standard deviation based on twelve measurements
over a 24 hour period as measured within the ETC supply air.
5.6. The chamber must be operated under slight positive pressure (less than 1 inch of water) relative to
atmospheric pressure.
5.7. Sample ports must be affixed to the outlet exhaust of chamber in a manner that does not adversely
affect the chamber flow. Experience has shown that acceptable results are obtained when the sampling
protocol does not pull more than 50% of the outlet air flow.
5.8. Appropriate instrumentation must be incorporated in the test system to control and monitor airflow
rates, temperature, and humidity. This instrumentation must have adequate accuracy, precision, and
sensitivity to control these parameters and to document that the specified data quality objectives are
met. Automated process control, monitoring, and data logging systems are recommended.
6.0. SAMPLE HANDLING
6.1. The primary intent of a well-defined sample handling procedure is to ensure preservation of the
sample's chemical integrity. This process involves defined and controlled procedures encompassing
sample collection, sample packaging, sample delivery to the testing facility and storage of the sample
prior to testing. All of these parameters are important once the sample has been collected and until it is
tested.
6.2. Sample Collection.
6.2.1. The collected sample must ensure accurate representation of the actual performance parameter
being evaluated. Since the measured performance factor, in this case, is TVOC, its
composition must be retained and uncontaminated during all the phases of the sample handling
process. Because of the low levels of TVOC associated with carpet products, it is
recommended that the carpet and associated materials be collected directly from the
manufacturer's production line, and packaged immediately. This is the only way to ensure that
original sample integrity is maintained.
6.2.2. In actual building usage applications, one may wish to more closely simulate the handling of
the product prior to its delivery to a job site. This may be attempted if the handling
procedures are known, but it may be very difficult to control. There will be no assurance that
the TVOC levels and composition of the product after this type of treatment would be product
E-5
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specific TVOCs. This approach is not recommended for product specific information.
Contamination of the carpet and its associated products may occur by atmospheric exposure,
activities and materials during this type of preparatory stage.
6.2.3 For rolled materials such as broadloom carpet and cushions, the sample should be collected as
a minimum size of 2 ft. by 2 ft. This will allow for rolling of the product so that there is an
internal layer from which a minimum of two samples can be collected from the internal
product roll. Other products such as carpet tile should be obtained and packaged so that one
internal piece is sandwiched between two outer pieces. Any other solid or liquid material,
such as adhesive, should be placed from the manufacturing facility into appropriately clean and
sealed metal containers, protecting it from the external atmosphere.
6.3. Sample Packaging.
It is essential to package the product with materials which will not contaminate the product nor allow
VOC permeability from either the interior or exterior. Aluminized packaging (shiny side out) lined
with polyethylene or Tedlar has given acceptable results with the present sampling procedure. The
sample background on the packaging material, as tested according to this protocol, must have a
consistent TVOC background emission factor less than 0.010 mg/nAr.
6.4. Product Delivery and Storage.
Once the sample is collected and packaged, it must arrive at the testing facility ASAP, with a maximum
allowable delivery time of 36 hours following collection. It should then be stored in its packaged state
in an environmentally controlled interior space for a maximum period of 48 hours prior to testing. The
sample is to remain sealed until it is to be tested. There should not be any preliminary observation of
the sample.
6.5. Product Storage.
Following testing, the product should be repackaged and stored for a 6 month time period by the testing
facility. This storage should be maintained in an environmentally conditioned interior environment.
The test specimen packaging must be air-tight and VOC free as required of the original packaging with
a VOC background emission factor less than 0.010 mg/m^hr.
7.0. PREPARATION OF THE PRODUCT TEST SYSTEM
7.1. A stainless steel plate may be used as the substrate for the carpet cushion material if it is tested alone.
The mounting must have the ability to seal the edges of the test specimen or entire mounting block. A
stainless steel tray is recommended for this. The installations and systems should be prepared
according to the manufacturer's instructions and the use of CRTs Installation Guide for Commercial
and Residential Structures, CRI Publications 104 and 105. The manufacturer's instructions should have
priority, if available.
Other substrates such as particleboard underlayment or plywood, the most common in residential
homes, or other materials, such as resilient flooring, may be used. However, these flooring systems
will contribute VOCs and complicate the studies, since they too will be emitters of VOCs. A back-
ground control of their VOC emissions must be obtained so that the product test results may take the
substrate contributions into account.
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7.2. The flooring material must be prepared to comply with a loading ratio of 0.41 mVm*. This loading is
based on a standard ceiling height of 2.4 m allowing complete floor coverage with the material being
tested. The flooring must be laid on the appropriate sub-flooring and tested as a complete package.
The edges of the flooring system, including the sub-flooring and carpet, must be sealed or considerable
error could be incurred in the analysis.
Once the appropriate system has been prepared, it should be immediately loaded into the test chamber
for testing.
7.3. Installation systems of specific products may be assembled and tested, but individual-product-specific
information will not be obtainable. It is simply a "whole" or complete system emission description. If
the total system as well as component contributions are required information, then each component and
the "whole" will have to be tested.
It is suggested that all component pieces be tested simultaneously in order to avoid aging effects on the
individual component contributions to the whole.
7.4. The standard assembly for component testing will be that component installed on the sub-flooring with
the edges sealed. The other floorings, as mentioned in 7.1, may be used if specified for special
applications.
8.0. ENVIRONMENTAL CHAMBER TESTING PROTOCOL
The testing should be conducted in environmental chambers. These chambers must be constructed and
designed to evaluate ultra-trace levels of organic compounds. Chamber test conditions must be
controlled if accurate and reproducible data is to be obtained.
8.1. Procedure.
8.1.1. The test chamber shall be purged with purified air prior to loading under normal
operating conditions, but without the test specimen. A chamber background test
conducted on the chamber must confirm a TVOC background level less than 2.0
jig/m3. Once that is ascertained, the chamber may be opened and loaded.
8.1.2. The test specimen is prepared immediately prior to loading, and is subsequently
loaded into the chamber so that it is centered and does not interfere with the flow of
the supply air.
8.1.3. The standard test chamber operating parameters are:
1.00 ± O.OS (standard deviation) Air Changes per Hour
50 ± 596 (standard deviation) Relative Humidity (Initial variance in the
chamber may be observed after loading a product as a result of 1) outside air
entrance of differing humidity, and 2) moisture contribution from the product
being tested. These variances should be recorded.)
23°C ± 1.0°C (standard deviation) Temperature
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8.1.4. The test specimen is loaded so that the square area of the exposed surface to chamber
volume ratio of 0.41 mVm' is achieved. All edges of the test specimen are carefully
cut, and the specimen is placed in a tray with edges equal in height to the carpet
thickness.
8.1.5. Samples are collected at points in time consistent with the study objectives (see
Section 10). Several points (e.g., greater than 5, taken before the system achieves
steady state) are required to define the emission profile of sources with a changing
emission factor. A measurement
at a single point in time may be appropriate to compare materials with similar decay
rates.
8.1.6. Prior to sample collection, the sampling lines are purged for a total of 5 times their
volume. The sampling line length should be minimized to reduce potential sample
loss. In addition, the sampling lines should be heated.
9.0. CHEMICAL ANALYSIS
9.1. Chamber Air Collection.
The low levels of VOCs associated with flooring materials require a significant pre-concentration
of the air prior to chemical analysis. A multi-bed sorbent trap containing Carbosieve Sin,
Carbotrap C, and Carbotrap (Supelco or equivalent) is recommended for this purpose. The
adsorbents should be sequentially packed in an appropriate sampling tube in approximately equal
amounts separated by glass wool plugs. The adsorbents selected must provide greater than 90%
collection and desorption efficiencies for the majority of the chemicals present in the product
emissions under the test conditions established for sample collection and analysis. Determinations
of efficiency must be supported by an independent quantitation of recovered compounds, such as
by interpolation of GC peak measurement into a standard curve obtained by direct injection. Any
other sorbent system meeting these requirements may be used.
Allowable maximum collection volumes (V_J and sample collection flow rates (Q_J must be
determined for each sorbent system, such that
VM = w X VJ1.5
where V_ = maximum total volume in L
Vb = breakthrough volume for the least retained compound of interest in L/g
w = weight of sorbent(s) in g
and Q^ = 1000 X VM/t
where Q_ = maximum flow rate in mL/minute
V_ = maximum total volume in L
t = desired sampling time in minutes
For the sorbent system recommended above, the tube should be
1. Purified under an ultra-pure gas flow for a minimum of 8 hours at 275° C.
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2. After purification, maintained under a constant ultra-pure gas flow until immediately
before use for sampling. Storage is not recommended.
3. After sampling, immediately analyze or seal with stainless steel caps and frozen at -
20°C until analysis.
4. Stored for no more than 5 days at -20°C.
Actual sorbent traps must be conditioned in the laboratory making sure that they are purified and
contain no greater than 36 ng of TVOC.
Generally, sampling for carpet TVOC can be conducted from 30 mL/minute to 200 mL/minute for
a total collection not recommended to exceed 20 liters. The collection volume should be optimized
with the sorbent tube preparation. The sampling manifolds must maintain a constant flow rate
during the entire sampling period.
Samples are introduced to the GC via a single tube thermal desorber. Samples are desorbed at
275°C for 10 minutes under a carrier gas flow of 40 mL/min. A transfer line heated to 150°C
connects the desorber to the head of the GC column. Other types of desorbers may be applicable
if they meet the method accuracy, precision, and detection limit as required in Section 9.5 of the
"Test Method." Desorption operating parameters may change for other desorbers.
9.2 Instrumentation.
Rotameters, or any other flow measuring devices used, are calibrated with tubes in line. Ten
percent of all tubes purified are used for QC.
The TVOC analysis must be conducted by capillary gas chromatography coupled with flame
ionization, mass-selective, or mass spectrometric detection. Sensitivity is comparable between
mass selective detectors and the flame ionization detectors, and the compounds associated with the
flooring materials respond well to both detector systems. If individual volatile compounds are to
be identified, a mass spectrometer or mass-selective detector must be used as the detector. The air
sample must be efficiently desorbed from the sample sorbent tube to the analytical instrumentation
via a well-controlled, reproducible thermal desorption system.
Tuning and mass standardization is performed according to the manufacturer's instructions,
generally using perfluorotributylamine (FC-43). This process may vary among instruments. The
FC-43 is introduced directly into the ion source through a molecular leak. Instrumental parameters
are automatically adjusted following the sequence below to give acceptable relative ion abundances
of:
% Relative
69 100
131 >35
219 >24
502 >1
The electron multiplier is adjusted to bring within range the abundances of m/z 69, 219, and 502.
The mass range scanned is 20 amu to 600 amu with an allowable scan every 0.5-1 second.
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The chromatographic system is comprised of a gas chromatograph equipped with capillary columns
and a flame ionization detector, mass-selective detector, or interfaced with a mass spectrometer.
The thermal desorption system is interfaced with the gas chromatographic injection system. A
description of chromatographic systems and their calibration and operating parameters is given in
EPA's "Compendium of Methods for Determination of Toxic Organic Compounds in Ambient Air"
(EPA/600/4-89/017) and 'Compendium of Methods for the Determination of Air Pollutants in
Indoor Air' (EPA/600/4-90/010).
Only high-resolution (capillary column) GC techniques are acceptable for application of this
method. The specific column and temperature program employed is dependent on the compounds
of interest. In general, a non-polar stationary phase column (e. g., SE-30, SE-S4, OV-1),
temperature programmed from -70°C to 250°C at 10 degrees/minute is suitable. A fused silica
column 50 m in length X 0.3 mm internal diameter is recommended with a helium carrier flow of
1-2 mL/minute.
Chromatographic efficiency should be checked with the TVOC calibration mixture or
perfluorotoluene to ensure an asymmetry factor between 0.5 and 2.0. The compound(s) are
introduced into the chromatographic system as a "sample." The width of each peak at 10% of its
height should not exceed 10 seconds for each of the compounds evaluated.
9.3. Standard Operating Procedures.
The laboratory must present Standard Operating Procedures (SOPs) for all aspects of the analytical
procedures with confirmation of their compliance with the detection capability and established QC
parameters. The SOP should address:
9.3.1. Assembly, calibration and operation of the sampling system;
9.3.2. Preparation, handling and storage of the sorbent collection media;
9.3.3. Description and operation of the instrumentation systems including the sampling
device, sample introduction system, separation chemistry, and data system;
9.3.4. All aspects of data recording and processing; and
9.3.5. The operating procedures should be specific and be readily available to those involved
in the analysis and testing. A copy of the method should be retained in the
laboratory.
9.4. Quantitation of the analytical system is with a TVOC mixture representative of the types of VOCs
present in the sample. The standard mixture contains equal parts by weight hexanol, toluene,
cyclohexane, and decane. Data from the calibration standards are used to calculate a response
factor for TVOC. Calibration levels of 200 ng, 400 ng, 600 ng, and 800 ng of each component
are used for determining calibration curves. The calibration data at the end of each week are
pooled to yield a response factor. A daily standard encompassing 400 ng of each component is
injected to determine day-to-day precision of response factors. Calibration standards may need to
be changed to cover the concentration range of the samples. The average mass response of this
mixture is used for quantitation. This mixture must be introduced as a gas into the analytical
system and be subjected to the same analytical processes, including sorbent collection, as the
sample. The mixture (i.e., liquid or gaseous standard) should be purged from a known source onto
the sorbent media. Internal usage of perfluorotoluene or bromofluorotoluene is recommended to
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check instrumental system performance of the mass spectrometer. A normal alkane, not present in
the sample emissions, is recommended for the flame ionization detector.
9.5. Method Accuracy and Precision.
The requirements for those representative compounds included in the TVOC mix are greater than
90% recovery (incorporating sample collection through analysis) and less than 10% relative
standard deviation. Any deviations beyond these are unacceptable. The minimal quantifiable limit
is 4.0 jtg/m* which is twice the required detection limit of 2.0 pg/m*.
9.6. Method Detection Limit.
The system detection limit is obtained from calibration standards and is defined as:
DL = A + 3.3 s
where DL = the calculated detection limit in nanograms,
A = the intercept from a least squares calibration
curve fit, and
s = the standard deviation of replicate
determinations of the lowest level standard.
Experience with this method has shown that the minimal quantifiable limit is twice the detection
limit or 4.0 /ig/m' which is twice the detection limit of 2.0 /xg/rrf or 36 ng TVOC. The minimal
quantifiable emission factor limit is 0.01 mg/m*hr emission rate. Obviously, an emission rate
represented by a single number is a time average for samples whose emission varies on a time
scale comparable to the sampling time.
9.7. All detected mass responses corresponding to the quantifiable limit should be summed and used in
the TVOC determination. Calibration is by TVOC-mixture response factor as determined from a
calibration curve.
10.0. EMISSION FACTOR CALCULATIONS
10.1. Dynamic chamber testing, as described in this method, provides for the calculation of emission
factors for vapor phase organic compounds. The calculation procedure depends on the behavior
over time of the source being tested. For the purposes of this method, it is assumed that sources
have either constant emission factors or emission factors that exhibit first-order decay over time.
10.2. For sources with constant emission rates, once the chamber concentration reached equilibrium, the
emission factor is calculated as:
EF = C(N/L) (1)
where EF = emission factor, mg/nrar
C = chamber concentration, mg/m
N = chamber air exchange rate, hr~*
L = product loading, m /m
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10.3 For sources with an emission factor having a first-order decay, the emission factor is:
EF = EFoe-kt (2)
where EF0 = initial emission factor, mg/nrhr
k = first-order decay constant, hr"1
t = time, hr
EF0 and k are determined by fitting the following equation to the chamber concentration vs. time
data:
C = L0EFo)(e-kt - e"Nt)/(N-k) (3)
where C = chamber concentration, mg/mr
EF0 = initial emission factor, mg/m^nr
e = natural log base
k = first order rate constant, h~*
t = time, hr (midpoint of the sampling
interval)
N = air change rate in hr~*
L = product loading, mVm3
10.4. If products within a given class of material exhibit similar decay characteristics, a chamber
measurement at a single point in time may be used to compare emissions between individual
products. The point in time (e.g., 24 hrs) should be determined by preliminary decay rate studies.
Equation (1) would be used to calculate a surrogate emission factor that would be used to rank
individual products. This surrogate emission factor should not be used in IAQ models to calculate
indoor concentrations or to estimate exposures without recognition of the errors and uncertainty it
can produce.
11.0. QUALITY CONTROL AND QUALITY ASSURANCE
11.1. A quality control/assurance plan is designed to ensure the integrity of the measured and reported
data obtained during product evaluation studies. This program encompasses all facets of the
measurement program from sample receipt to final review and issuance of reports.
11.2. Project Description.
A brief description of the project should include identification of the materials to be tested; how the
testing is to be conducted; and, who is responsible for various project activities. The project
experimental design should be described including the test temperatures, air exchange rate, and
material loading; sample collection schedule, procedures, equipment, and materials; analytical
system procedures and equipment.
11.3. Data Quality Objectives/Acceptance Criteria.
The QA/QC plan must be based on established data quality objectives and acceptance criteria.
These will depend on the purpose of the testing and the capability of the laboratory (equipment and
personnel) to conduct the test procedures. Data quality objectives shall be established for the
following parameters prior to beginning the testing program:
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11.3.1. Test Sample Transfer Time and Environmental Conditions.
Establish tolerable limits for the elapsed time from sample acquisition to testing under an
acceptable range of specified environmental conditions.
11.3.2 Test Chamber Conditions and Test Results.
Precision and accuracy limits should be met for each of the following parameters:
PARAMETER PRECISION ACCURACY COMPLETENESS #
Temperature
Relative Humidity
Air flow rate
Substrate area
Sample weight
Organic
Concentration
Emission factor
±1.0°C
±5.0%RH
±5.0%
±1.0%
±1.0%
±20% RSD*
±20% RSD*
±0.5°C
±5.0%RH
±5.0%
-
"~
>90%
>90%
>90%
>90%
>90%
>90%
>90%
# Completeness characterizes the percentage of the planned measurements that are actually
conducted.
* RSD = Relative standard deviation = (s/m)100%
where s = estimate of the standard deviation and m = mean
A common method of estimating s for a variable calculated from several measured quantities,
such as EF is here is the root-mean-square approach:
Accuracy certifications are supplied by the manufacturers of the sensors who calibrate them
against NIST-traceable primary sources. Precision measurements are obtained within the
laboratory by continuous recording of the parameters. Non-compliance requires immediate
correction and/or replacement of sensors. Calibrated replacements should be kept in the
laboratory. Experience indicates that routine calibration and tracking of precision prevents non-
compliance. See Sections 11.4-11.8 below.
11.3.3. Record Keeping and Logs.
Various logging requirements should be implemented for all test parameters including chamber
and analytical performance. Many of these are identified in ASTM D5116-90. Additionally,
personnel conducting each procedure should be so noted. Records of the devices used, date and
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time of tests, and the test results should be part of the QA/QC recording process. The
completeness of records indicates the care and attention given the quality control process.
11.4. Calibration.
Calibration should be frequent enough to assure performance of the system within the specified
parameters. Frequency of calibration should be determined prior to the test and periodic
equipment checks should be used to verify the maintenance of acceptable performance.
Experience suggests that calibration of air flow, humidity, and temperature every two months
gives adequate results; in fact, the manufacturers recommend six-month intervals. All
calibration and verification measurements should be recorded including the time, equipment, and
measurement results.
11.5. Accuracy Determinations.
Accuracy determinations require measurement of a known emission source (e.g., permeation
tubes, spiked samples) or test gas. These measurements should be made prior to establishing
the project data quality objectives and should be consistent with the overall project objectives.
The procedures and materials used for establishing accuracy of the measurement system should
be recorded.
11.6. Precision.
Precision determinations require replications sufficient to establish the systematic variation
associated with a given measurement. Where multiple chambers are used as part of an
experiment, duplicate samples should be used for this determination. Variation in test results
from a single chamber and among chambers can be established by use of standardized sources
such as permeation tubes for determining organic concentrations and calculated emission rates.
11.7. Duplicate Analysis.
No less than 10% of the samples collected, both analytical and carpet samples, should be subject
to duplicate analysis. The results of such analyses should be recorded and assessed to determine
the adequacy of the total system performance relative to the project objectives.
11.8. Charting.
Charting quality control data will allow visual analysis of system performance and observation
of anomalistic or unacceptable deviations. This may be done by use of the Shewart Chart
(reference: Shewart, W.A., 1931, Economic Control of Quality of Manufactured Products, Bell
Telephone Laboratories). (Cf. "Manual on Presentation of a Data and Control Chart
Analysis", 6th ed., prepared by Committee E-ll on Quality and Statistics, ASTM, 1991.
11.9. Periodic audits should be conducted by external QA personnel, i. e., not by the same person
who is running the tests.
12.0. REPORT TEST RESULTS
The purpose of the test report is to provide the reader the ability to understand the conduct of
the tests and to assess and interpret the results. To meet these objectives, a complete
description of the test objectives, facilities and equipment, experimental design, sample
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descriptions, experimental procedures, data analysis, results, discussion, and conclusion, and
quality assurance/quality control program.
12.1. Test Report Contents.
The contents of the test report shall include all aspects of the test program relevant to
interpretation of results. The report shall be comprehensive and inclusive rather than omitting
detail, yet it should be presented as concisely as possible.
12.1.1. Testing Laboratory Identification.
Name, address, phone number, and contact person for the reported testing activity.
12.1.2. Test Objectives.
Purpose of the testing project and the intended use of the results.
12.1.3. Facilities and Equipment.
Describe the test chambers, clean air system, environmental measurement and control, sample
collection including sorbents, analytical instrumentation, and standards generation and
calibration.
12.1.4. Experimental Design.
Describe test conditions including temperature, humidity, air exchange rate, and test materials
loading. Include a test matrix listing the test condition and test sample variables and their
combinations in the experiment.
12.1.5. Sample Description.
Provide sample description and any given sample information, including , but not limited to,
type of material, product history, etc., and sample selection process (e.g., random). For wet
samples or samples applied to a substrate, describe the substrate and any measures taken to
attach the sample to the substrate or seal the sample edges. Provide information on sample
acquisition procedures, sample packaging, storage, transport, and handling upon arrival at the
laboratory. Describe environmental conditions and duration of each phase of the process from
acquisition until testing.
12.1.6. Experimental Procedures.
Describe the experimental procedures used during testing, including details of the sampling and
analysis techniques and references to published methods whenever used. For wet samples or
samples installed on a substrate, describe the materials used and the procedures. Describe the
timing of air sample collection in relation to the placement of the test specimen in the chamber
and operation of the environmental control system for the chamber. Provide the dates for
testing and the duration of exposure.
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12.1.7. Data Analysis.
Show or reference the methods including appropriate models or equations used to analyze the
chamber data to obtain emission factors or emission rates.
12.1.8. Results.
Provide emission factors for each type of sample tested and for each environmental condition
evaluated. The sampling time shall be reported as the mid-point of the sample collection.
Emission factors can be provided for individual organic compounds and/or total organics.
Where total organics are reported, include a description or reference of the method of
quantification. Where variable rates are measured, provide a rate constant and describe the
calculation method by which it is derived. Describe the accuracy and precision bounds of the
test results.
12.1.9. Discussion and Conclusion.
Present the requested results. If required, discuss the relevance of the findings and provide
conclusions. For example, describe the effect of temperature and/or air exchange rate on
emission factors. Note any anomalies and describe data treatment to address such data.
12.1.10. Quality Assurance/Quality Control.
Describe the QA/QC objectives (see Sec. 11.2) and discuss adherence to the acceptance criteria.
The discussion shall include both environmental variables and the results of chemical analyses.
Provide the results of duplicate and replicate sampling, and discuss the outcome of any audits.
Be both specific and concise. Describe the availability of the QA/QC plan and its storage
location.
12.1.11. Reporting Format.
A sample format is attached.
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ATTACHMENT
OUTLINE OF REPORT: MATERIALS EMISSIONS MEASUREMENTS
A. TESTING LABORATORY
1. Name
2. Phone
3. Address
4. Certifications
B. TEST SPECIMEN
1. Product Identification
a. Manufacturer
b. Product Name
c. Color or pattern
d. Model Name, Style, or Numerical Designation
e. Other Identifying Information
2. Acquisition and Handling
a. Date Received
b. Test Specimen Age or Date of Manufacture
c. Description of Packaging
d. Storage Conditions
3. Conditioning
4. Preparation of Test Specimen
C. CHAMBER TEST CONDITIONS
1. Temperature (chamber and sampling lines)
2. Humidity
3. Air velocity
4. Air exchange rate
5. Dates of testing
D. SAMPLE COLLECTION
1. Timing and Duration
2. Chamber Loading Ratio
3. Collection Media
4. Sampling Rate (i. e., sampling flow rate)
5. Chemical identification/quantification methods and procedures
E. RESULTS
1. Procedures Used for Identification of Compounds
2. Emission Factors: Basis of Calculation
3. Emission Factors for Specific Compounds
If absence of any substance is claimed, the relevant detection limits)
4. Emission Factors for Total measured organic compounds (in units of average mass response
of the four standards)
F. QUALITY ASSURANCE AND QUALITY CONTROL
1. Individual responsible for QA/QC plan preparation and oversight
2. Identification of data quality objectives
3. Performance of test system against data quality objectives
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ATTACHMENT E-l
Annex
-------
EPA Dialogue
Annex Draft 02
Date: 8-20-91
TEST METHOD FOR DETERMINING
TOTAL VOLATILE ORGANIC COMPOUND EMISSION FACTORS
FROM CARPET UNDER DEFINED TEST CONDITIONS
USING SMALL ENVIRONMENTAL CHAMBERS
ANNEX
Al. Modifications For Testing of Adhesives
Al.l SCOPE
Al. 1.1 The purpose of this annex is to provide guidance to interested parties on the use of small environmental
chambers for determining total volatile organic compound emission factors from adhesives that are used for the
installation of carpet or carpet cushions. The methodology provided in the standard method to which this section
is annexed provides the basis for measurements made for adhesives. However, some modifications of the
procedures outlined in the standard method for sample handling, preparation of the product system, the
environmental chamber testing protocol, chemical analysis, and emission factor calculations are required in
order to obtain data that can be used to compare emissions between different adhesives products.
Al.l.2 The annex provides recommendations for procedures that can be implemented to test adhesives. The
annex does not include mandatory methods for testing adhesives. Methods for testing adhesives are being
developed, but their performance has not been adequately documented for the purposes of a standard method.
Interested parties should develop testing protocols based on guidance provided in the standard method and this
annex.
Performance of any test program using protocols developed on the basis of recommendations in this annex must
be documented using appropriate test procedures. A quality control/quality assurance plan that specifies data
quality objectives and acceptance criteria consistent with this standard method should be established to document
the integrity of the measured and reported data obtained during testing.
Al.l.3 The user of the procedures recommended in this annex should be aware that the procedures for testing
adhesives are currently under development. This annex will be subject to revision based on the results the
research.
A1.2 THE ENVIRONMENTAL CHAMBER
A1.2.1 Specifications for the environmental chamber, as described in Section 5.0 of the Standard Method are
appropriate for testing of adhesives.
A1.3 SAMPLE HANDLING
Al.3.1 Samples for testing may be procured from manufacturers, distributors, building sites, or retail suppliers.
Samples procured for testing should be in an orginal, unopened manufacuturer's container not more than one
year old, based on information on the label. The container should be insected to ensure that it has not been
previously opened. If the container is suspected to be have been opened, it should be rejected for comparative
testing.
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Al.3.2 The user should record the following information from the container: manufacturer, product name,
product code, lot number, recommended application trowel(s) and rate(s). The user should record the date and
location of procurement of the product.
Al.3.3 The product should be stored in its original container at room temperature.
Al.3.4 Containers of adhesive* to be tested should not be opened until immediately prior to preparation of the
test specimen for placement in the chamber. If signs of physical separation of adhesives (indicated by an
oily/resinous layer on the surface) are observed, the container of adhesive should be discarded. However a small
amount of condensation of water on the surface does not indicate that the product cannot be tested. Adhesive
should be removed from the center of the container from below the surface using a suitable tool. Procedures for
removal of test specimens should ensure that the product remaining in the container does not become
contaminated. Containers should be immediately closed and sealed after adhesive has been removed for the
tests. Excess adhesive removed during specimen preparation should be discarded, not returned to the container.
The user should document each occasion when a sample is removed from the container.
A1.4 PREPARATION OF THE PRODUCT TEST SYSTEM
A1.4.1 Although manufacturers may recommend different types of trowels for different adhesives and different
product applications, a standardized method for preparation of the test system that uses one trowel size should
be implemented to determine compariability and to achieve uniformity on the test specimens. The tester should
record and report the mass of adhesive used and calculate and report the emission factor based on the mass of
adhesive, as well as based on surface area.
Al.4.2 A stainless steel plate should be used as the substrate for the adhesive if it is to be tested alone. The size
of the plate should comply with a loading ratio of 0.41 ml/lht
Al.4.3 The recommended trowel for application of the adhesive is a 1/8 X 1/8 X 3/32 Unnotched trowel held at
a 45 degree angle.
Al.4.4 The recommended procedure for application of the adhesive to the plate is as follows:
1) Weigh the clean stainless steel plate.
2) Place the stainless steel plate into a holder designed such that the top suface of the plate is flush with
the top surface of the sides of the holder. The surface of the sides of the holder should be smooth and should
extend out from the plate a few centimeters so that the holder provides excess surface area along the edges of
the plate to facilitate uniform application of adhesive onto the plate.
3) Remove sufficient adhesive from the container so that a uniform application can be made to the plate.
Do not use adhesive from the top surface of the container.
4) Holding the trowel at a 45 degree angle, make one pass across the plate to spread the adhesive. Rotate
the plate and holder 90 degrees and make a second pass across the plate with the trowel to insure uniform
application.
5) Visually inspect the application to determine If it is uniform. If any areas of the plate are not covered
with adhesive or the application is not homogenous, reject the specimen and prepare a new one.
6) Remove the plate from the holder and weigh the plate with adhesive. Record the mass of adhesive
applied to the plate.
7) Place the plate in the chamber and proceed with the test.
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A1.5 ENVIRONMENTAL CHAMBER TESTING PROTOCOL
Al.5.1 Standard test chamber operating pSrameters should be as specified in Section 8.1.3 of the standard method.
The relative humidity of the inlet air should be held constant at 50% +_5%. The humidity in the chamber should
be recorded, at a minimum, at each time a sample Is collected.
Al.5.2 Samples should be collected at points in time corgistent with the study objectives, as described in Sections
8 and 10 of the standard method.
A1.6 CHEMICAL ANALYSIS
Al.6.1 During testing, the concentration of VOCs in the air stream from the chamber may vary substantially
between inflation of the test and completion of the test. During the intial phase of tests of some adhesives, the
concentrations may be sufficiently high to allow direct sampling and analysis of the air stream. During later
phases of the tests, preconcentration of the VOCs in the air stream may be required prior to analysis. Sampling
methods need to be determined. The effects of water vapor emitted from adhesives will be considered in
developing the test method. Calculation of emission factors will be simplified by the use of a single method for
sample collection at all time points because complications associated with differences In collection efficiency are
precluded.
Al.6.2 Quantitation of the analytical system will be with a TVOC mixture representative of the types of VOCs
in the sample. The composition of the standard mixture needs to be determined in development of the test
method.
A1.7 EMISSION FACTOR CALCULATIONS
Al.7.1 As stated in the standard method, the procedure for calculation of emission factors of VOCs depends on
the behavior over time of the source being tested. If the adhesive has an emission factor having a first order
decay, procedures described in Section 10.0 of the method can be used. If the adhesive does not exhibit simple
exponential decay emissions over time, other emission models may be required.
Al.7.2 Emission factors should be reported in both surface area and mass of product units.
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APPENDIX F
Carpet and Rug Institute Consensus
Statement: Testing Program for
Carpet Products
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CARPET POLICY DIALOGUE
CARPET AND RUG INSTITUTE
CONSENSUS STATEMENT:
Testing Program for Carpet Products
February 28, 1991
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PREFACE
The Carpet Dialogue Group, convened by the U.S. Environmental Protection Agency, is engaged in a one-
year effort to develop consensus and voluntary commitments with respect to approaches for minimizing exposure
to volatile organic compounds (VOCs) emitted by carpet and associated products of carpet flooring systems (FR:
April 24, 1990 - "Carpet: Response to Citizens' Petition* p. 17404-17409; and, FR: August 3, 1990 - "Carpet
Emissions Reduction; Policy Dialogue" p.31640-34641).
This document conveys a consensus statement of the Carpet Dialogue Plenary Group regarding the
commitment by the carpet industry, as represented by the Carpet and Rug Institute (CRT), for the voluntary
development and communication of TVOC test data on carpet.
Additional statements and reports concerning other aspects of the Carpet Dialogue are anticipated.
F-i
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CARPET DIALOGUE
Consensus Statement
for the
Carpet and Rug Institute:
Testing Program for Garnet Products
1.0. BACKGROUND
1.1. Charter and Charge
1.2. CRI Statement of Commitment
2.0. DEFINITIONS
2.1. Total Volatile Organic Compounds (TVOC)
2.2. Boundary of Subject Matter
2.3. Voluntary Action
2.4. Analytical Test Method
3.0. CARPET PRODUCT TESTING PROGRAM
3.1. Rationale for a Carpet Product Variability Study
3.2. Study Objectives
3.3. Scope & Structure of Study
3.3.1. Carpet product type selection criteria
3.3.2. Sample collection & analytical test method
3.3.3. Study design sampling matrix for analytical testing
3.4. Data Reporting & Evaluation
3.4.1. Statistical analysis
3.4.2. Data presentation
3.4.3. Initial program evaluation
3.4.4. Public study report on industry profile
3.5. Independent Contractors & Data Quality Standards
4.0. FOLLOW-ON ACTIVITIES
4.1. Future Activities
4.1.1. Annual industry report
4.1.2. QA product certification
4.1.3. Public communication
4.2. Information Repository
4.3. Memorandum of Understanding
Attachment F-l Carpet Emissions Decay Study
Attachment F-2 Minority Report on Carpet Testing Agreement
F-ii
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CARPET AND RUG INSTITUTE
CONSENSUS STATEMENT:
Testing Program for Carpet Products
1.0. BACKGROUND
1.1. Charter and Charge
The charter for testing under the carpet dialogue process was given in the U.S. Environmental
Protection Agency's Federal Register notice of April 24, 1990 in responding to the petition by the National
Federation of Federal Employees (NFFE) for EPA to undertake certain actions with respect to reducing
emissions from carpet (FR: April 24, 1990 - "Carpet: Response to Citizens' Petition" p. 17404-17409; and FR:
August 3, 1990 - "Carpet Emissions Reduction; Policy Dialogue" p.31640-34641). The Carpet Dialogue
Group, convened under the auspices of the U.S. Environmental Protection Agency, is engaged in a one-year
effort to develop consensus and voluntary commitments for minimizing exposure to volatile organic compounds
emitted from carpet and associated products of a carpet flooring system.
This document conveys the Carpet Dialogue Group consensus statement regarding the commitment of
the carpet industry as represented by the Carpet and Rug Institute (CRT) to undertake voluntary testing for total
volatile organic compound (TVOC) emissions from new carpet products, establishment of a database for
reporting periodic TVOC analysis for new carpet products, and communication of useful information about
TVOC emissions from new carpet products. Specifically, it describes a testing program to develop data to
determine a profile of TVOC measurements among a representative sample of new carpet products. Its
acceptance was affirmed by the Carpet Dialogue Group meeting in plenary session on February 28, 1991.
1.2. CRI Statement of Commitment
Since there are no universally accepted air quality standards, guidelines, or regulations that are
applicable to carpet, the CRI regards the dialogue and this agreement as a vehicle to accelerate the exploration
and understanding of voluntary pollution prevention as one component in improving indoor air quality. CRI has
committed resources to this initiative in their belief that a voluntary program will promote industry-wide
improvements to improve product performance with respect to indoor air quality.
This voluntary testing program commitment by the CRI addresses issues discussed in the Federal
Register notice. It provides for a CRI sponsored industry-wide profile of carpet products which would serve as
a base for any future measurement of TVOC emissions from new carpet products, both with respect to
industry-wide trends or company-specific quality assurance. CRI and the Carpet Dialogue Group recognize that
this testing agreement is only one element in a continuing program of responsible product stewardship. The
Carpet and Rug Institute has formally committed itself to a voluntary initiative aimed at improvement of indoor
air quality through measures within the purview and resources of its members. The full breadth of the CRI
program consists of five main parts.
(1) To generate a TVOC data base for carpet products as described in this document,
(2) To present the U.S. Environmental Protection Agency with a profile of carpet emissions
derived from item (1),
(3) To generate a history of TVOC levels through ongoing, periodic monitoring, which would be
available for trend analysis and could be used for remedial action,
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(4) To motivate manufacturers to institute voluntarily quality assurance measures to reduce TVOC
emissions through a CRI-established certification program as their contribution to better indoor
air quality,
(5) To inform the general public and carpet customers of the carpet industry's quality assurance
program and its results on a periodic basis.
The focus of this statement is to detail the first two items listed above. Other components of the
comprehensive CRI program are mentioned briefly as future follow-on activities. It is anticipated that EPA and
CRI will enter into a memorandum of understanding (MOU) which will describe procedural arrangements for
implementation of the voluntary carpet testing program and follow-on activities.
2.0. DEFINITIONS
2.1. Total Volatile Organic Compounds
Total Volatile Organic Compounds (TVOC), as defined in this document, represents the sum of volatile
organic compounds (VOC) that can be analyzed and measured by the specified analytical method. TVOC, is
reported as an emission factor in mg/n^hr and is a single numerical expression for the sum of VOC emissions
from a test substance (carpet product). This numerical expression will be used to direct scientific efforts and to
communicate useful information to the interested public.
2.2. Boundary of Test Subject
Carpets are defined as a variety of fabric products used for floor covering that are manufactured from
various materials by tufting, weaving, knitting, needle punching, custom tufting, or fusion bonding. For the
purpose of this voluntary test agreement the test subject is restricted to carpet products as obtained at the end of
a manufacturer's carpet finishing line. Such products are referred to in this document as new carpet and the
terms carpet and new carpet are synonymous.
The compositional elements used in the manufacture of carpet includes: Face fiber, primary backing,
latex, secondary backing, dye/colorant, and topical treatment. There are numerous materials and/or processing
procedures that can be brought together to form the many combinations that comprise the full range of carpet
products currently available in the marketplace.
On behalf of the carpet industry, the CRI has determined that carpet product types can be resolved into
two general groupings: softback and hardback. The softback group is a broadloom carpet product comprising
94% of the total market share and produced at about 151 finishing lines. The haidback group is a tile product
with a thicker backing, comprising 6% of the market share and produced at about 20 finishing lines.
2.3. Voluntary Action
This voluntary agreement to conduct TVOC emissions testing for new carpet products is undertaken by
the carpet industry as part of a continuing commitment to product stewardship. The program is implemented
with respect to products as produced by the manufacturer and may include industry guidelines for proper
installation, maintenance and care of carpet products.
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point for on-going testing and evaluation which is one of the goals of the Federal Register charter. The
program will be implemented so as to preserve necessary proprietary information and establishes the basis for
appropriate inter-product comparison.
2.4. Analytical Test Method
The analytical test method selected to obtain TVOC measurements for carpet products is a small
chamber technique. The environmental chamber method was described by the U.S. EPA in its document
"Indoor Air Sources: Using Small Environmental Chambers to Characterize Organic Emissions from Indoor
Materials and Products," (EPA report 600/8-89-074). The method is an ASTM standard, "Standard Guide for
Small-Scale Environmental Chamber Determinations of Organic Emissions from Indoor Materials/ Products"
(ASTM D5116-90). The analytical techniques described in these documents have been further refined to
measure TVOC emissions from carpet products (Appendix E: "Standard Test Method for Determining Total
Volatile Organic Compound Emission Factors from Carpet Under Defined Test Conditions Using Small
Environmental Chambers"). TVOC data for carpet products obtained from this standardized small chamber
testing procedure may be used to compare and evaluate carpet's relative contribution to indoor air quality with
TVOC data from other products.
The standard analytical method, as described in Appendix E, provides accurate TVOC measurements.
The minimal quantifiable limit is 4.0 ug/m' which is twice the detection limit of 2.0 ug/m' or 36 ng TVOC.
The TVOC concentration measured in the environmental chamber is used to calculate an emissions factor
expressed as mg/mMir.
The emissions factor is a product-specific factor describing the mass of chemical emitted from the
product per exposed area of the product per unit time. The quantifiable limit expressed as an emission rate is
0.01 mg/mlhr. The emission rate is projected by multiplying the emissions factor by the area of carpet in a
particular installation.
Emission factor data may be generated at various time intervals. At this time, based on decay curve
characteristics for SBR latex carpet products, the study design calls for a single time-point measurement.
Although it may be possible to project a decay curve for all types of carpets from a single point using standard
modelling procedures, further information is needed regarding the decay curve characteristics for non-SBR
carpet products to resolve the question of whether a single point and which single point will be most
representative of product performance. This question will be evaluated by the Phase I testing component of the
Carpet Testing Program through the evaluation of existing decay curve data for SBR latex-backed carpet types
and the development of additional decay curve data on non-SBR latex-backed carpet types. The resolution of
this question will be integrated into the finalized analytical method which is attached as Appendix E.
The analytical test method has been documented by an expert working party of the dialogue's
Design/Testing Subgroup and a draft is being circulated for peer-review. The method, with peer-review
revisions incorporated, will be available and has been judged by the Carpet Dialogue Group on November 29,
1990 to be an acceptable analytic tool for any industry study undertaken in 1991 under the aegis of this carpet
dialogue process. This test method will be submitted to ASTM by its principal originator as the basis for a first
draft proposal for ASTM balloting procedures for new techniques. Further validation by interested laboratories
is expected in the course of the next two years.
3.0. Carpet Product Testing Program
The Carpet Testing Program will be organized into two distinct studies. The first will be to develop
decay curve emission data on six (6) hardback carpet product types. The product types to be studied and decay
F-3
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curve test details are outlined in Attachment F-l. The decay curve data established on the hardback products
will be compared with the decay curve characteristics for the previous nineteen (19) SBR latex-backed carpet
products evaluated by Air Quality Sciences, Inc. (AQS). A comprehensive decay curve analysis will be
conducted to determine the appropriate air sampling time point, or points, to use in measuring TVOC emissions
in the larger industry profile study. The second will build a data base/profile of TVOC emissions from a
representative sample of carpet product types. Data from the decay curve study and the SBR latex-backed
carpet profile study can be used to show an industry-wide profile of TVOC emissions for carpet products
currently available in commerce.
3.1. Rationale for Carpet Product Testing
Exploratory data developed in 1990 for the CRI by the AQS led to a preliminary CRI hypothesis that
there may not be significant variability across carpet products made with SBR latex. This preliminary data set
did not include information about non-SBR latex carpet types. Testing under the profile study will evaluate the
preliminary CRI hypothesis and further characterize the range of industry-wide product performance with
respect to TVOC emission rates. The decay curve characteristics from non-SBR latex carpet product types
when compared with the SBR latex-backed carpet product decay curve data will provide a basis for selecting a
sampling time point(s) for use in any follow-on testing.
The data developed from these carpet product testing studies will provide the Carpet Dialogue Group,
industry, regulatory agencies, and the interested public with additional information to assess whether there is
sufficient variability of TVOC emissions across carpet products to warrant communication of TVOC information
on individual carpet products to the interested consumer.
3.2. Study Objectives
The overall Carpet Testing Program objective is to characterize quantitatively the distribution of TVOC
emissions factor performance of carpet product types currently in commerce as defined by the selected study
sampling of available products. These data will also address the question of TVOC emission variability, or the
lack thereof, across carpet product types.
3.3. Scope and Structure of Study
3.3.1. Carpet product type selection criteria
Three materials factors will be used to define carpet product types in commerce: face fiber, topical
treatment, and backing. The latter were selected as being the most prominent materials in the construction of
carpet and also having some possible relevance to product VOC emission performance. By using these
materials factors as the organizing constituents in a sampling roster, the full range of carpet product types
currently available in commerce can be identified for study. Inclusiveness is essential to profile the industry and
permit a factorial analysis to address the question of variability across product types.
A canvas of current products shows that there are twenty-five (25) carpet product types in commerce
with eight (8) SBR latex-backed carpet product types accounting for roughly 94% of the market and seventeen
(17) non-SBR latex-backed carpet product types accounting for roughly 6 % of the market. A few of the non-
SBR backed carpet product types may be produced by only one or two mills and may, therefore, be deleted
F-4
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from the final draw for reasons of low market share. It is judged that this roster comprises over 98 % of carpet
types produced for general and commercial commerce.
The roster of currently produced commercial products and their market shares, as determined by CRI,
is summarized in Table 1. It shows the 25 product types that could be sampled.
3.3.2. Sample collection & anftiyftyyl test method
The method for sample collection at the carpet mill, sample transport to the laboratory, and TVOC
analysis is described in Appendix E. This method will be used throughout the Carpet Testing Program. Details
of the decay curve testing study of non-SBR latex-backed carpet are described in Attachment F-l.
3.3.3. Study design sampling matrix for flrcfllyfiptl testing
Table 2 (SBR latex-backed carpet product types) and Table 3 (non-SBR latex-backed carpet product
types) show the product combinations to be sampled and the number of carpet samples from each carpet product
type to be collected and analyzed by the methods described in section 3.3.2. When all data are available from
both studies, the TVOC emissions factors measured at the appropriate time point(s) obtained from these samples
will be analyzed as a single combined data set. Thus, a total of seventy-eight (78) samples will be statistically
analyzed in the combined carpet product profile study. Specifically, fifty-four (54) samples are SBR latex-
backed carpet product types and twenty-four (24) are non-SBR latex-backed carpet product types. Eighteen (18)
of the non-SBR latex-backed carpet product type combinations will be initially collected for the Decay Curve
Study. The appropriate air sampling time point(s) (e.g., 24 hrs) corresponding to these samples will be used in
the Profile Study. The remaining six (6) samples will be collected and analyzed after the SBR latex-backed
carpet samples are analyzed using the appropriate air sampling time point(s) as determined from the decay curve
data set. The samples and repeat samples (i.e., samples collected on different days from the same finishing
line) will be selected from the manufacturing finishing lines (about 151 for the SBR latex profile study and
about 20 for the decay curve study) to permit an evaluation of line to line and day to day variability of TVOC
emissions factor. In addition, this combined data set will also permit evaluation of the effects on TVOC
emissions factor for fiber type, topical treatment, and backing material.
For each row (product combination) in Tables 2 and 3, the number of finishing lines indicated in the
column labeled "lines" will be drawn randomly from all lines making that product combination at the time the
samples for that combination are to be collected. In addition, some of these lines, chosen at random from the
selected lines, will have a repeat or second sample taken on a different day. The number of lines contributing a
repeat sample is given in the "repeat samples" column. For example, for the first combination in table 2 (i.e. ,
nylon/no treatment/SBR latex), six lines will be chosen at random from all lines making this carpet product type
and three of these lines, chosen at random from the six, will be sampled a second time on a different day.
Since the product combinations listed in Table 3 are not widely manufactured, it may occur that only one
finishing line is the sole source for a specified product combination. In this case, a second sample from the
same line will be taken on a different day.
Additional quality assurance (QA7QC) samples (about 10% of the total samples tested) will be taken in
accordance with standard data quality procedures of the U.S. EPA.
3.4. Data Reporting and Evaluation
The data analysis will follow the lines of the objectives defined in section 3.2.
F-5
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TABLE 1.
ROSTER OF CARPET PRODUCT TYPES.1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Carpet
Fiber
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Olefin
Olefin
Olefin
Olefin
Olefin
Olefin
Polyester
Polyester
Wool
Product Tvoes
Topical Treatment
no treatment
soil release
soil/stain resist.
no treatment
soil release
no treatment
soil release
soil/stain resist.
no treatment
soil release
no treatment
soil release
no treatment
soil release
no treatment
soil release
no treatment
soil release
no treatment
soil release
no treatment
soil release
no treatment
soil release
insect resist.
Backing
SBR1 latex
SBR latex
SBR latex
AR' hardback
AR hardback
Urethane foam
Uretfaane foam
Urethane fn»m
PVC hardback
PVC hardback
EVA5 hardback
EVA hardback
Urethane hardback
Urethane hardback
Bitumen hardback
Bitumen hardback
SBR latex
SBR latex
Urethane foam
Urethane foam
Urethane hardback
Urethane hardback
SBR latex
SBR latex
SBR latex
Total
%
Market
Share
70.20
0.73
1.70
1.30
0.57
0.20
0.10
14.90
0.88
0.02
8.70
0.70
100.00
1 The CRI bat determined that ptoducti with EVA latex-backing ire no longer manufactured.
2 Stymie butadiene rubber
3 Amorphoua Resin
4 Polyvinyl chloride
S Ethylene vinyl acetate
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TABLE 2.
DATA BASE/PROFILE STUDY SAMPLING MATRIX OF
SBR LATEX PRODUCT TYPES.
Garnet Product Tvues
Fiber
Nylon
Nylon
Nylon
Olefin
Olefin
Polyester
Polyester
Topical
Treatment
no treatment
soil release
soil/stain res.
no treatment
soil release
no treatment
soil release
Backing
SBR latex
SBR latex
SBR latex
SBR latex
SBR latex
SBR latex
SBR latex
No. of
Sampled
Lines
6
6
6
4
4
4
4
No. of Market
Repeat Share
Samples %
3
3
3 70.2
2
2 14.9
2
2 8.7
Total
Samples
27
12
12
Wool
insect resist
Total
SBR latex
_2
36
0.7
18
_3
54
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TABLES.
DECAY CURVE STUDY AND ADDITIONAL PROFILE SAMPLES SAMPLING
MATRIX OF NON-SBR LATEX PRODUCT TYPES.
No. of samoles
Garnet Product Tvues
Fiber
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Nylon
Topical Treatment
no treatment
soil release
no treatment
soil release
no treatment
soil release
no treatment
soil release
no treatment
soil release
soil/stain res.
no treatment
soil release
Backing
AR hardback
AR hardback
PVC hardback
PVC hardback
EVA hardback
EVA hardback
Urethane hrdbk
Urethane hrdbk
Urethane foam
Urethane foam
Urethane foam
Bitumen hrdbk
Bitumen hrdbk
Decay
Curve
2
1
1
2
1
2
2
1
1
1
1
1
_2
Add'l
Profile
0
1
1
0
1
0
0
1
0
1
0
1
_Q
Market Total
Share No. of
% Samples
0.73 4
1.3 4
0.57 4
0.2 4
1.7 4
0.1 _4
Total
18
24
F-8
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3.4.1. Statistical analysis
A factorial analysis of the "78 point" profile study data will be performed using a standard statistical
technique known as analysis of variance. This method will be used to determine the effects on TVOC of five
factors: fiber type, topical treatment, backing, line to line variation, and temporal (day to day) variation within a
single finishing line. The first three factors are known as "fixed" effects and analysis of these data will be used
to determine the effects on TVOC emissions of different fiber types, topical treatments, and backings. The last
two factors are considered "random" effects. These analyses will produce estimates of the variability in TVOC
emissions due to line to line differences among manufacturing lines producing the same carpet product type, and
day to day differences in the operation of a single manufacturing line. All results will be accompanied by an
estimate of the statistical uncertainty (95 percent confidence limits) associated with them. These uncertainties
are due to sampling or product variability, as well as measurement error.
As part of the statistical investigation of the three fixed effects, the presence of two-way interactions
will be tested. An interaction between two factors means that the effects of one of the factors on TVOC
emissions depends on the particular setting of the other. For example, if the effect of soil release treatment
(versus no treatment) depends on the fiber type, it is stated that there is a fiber type/topical treatment
interaction. If statistically significant interactions are identified in the profile data, they will be presented and
discussed in the final report.
Upon receipt of the data from the testing laboratory, the data will be examined to determine the need
for data transformation. Traditionally, data sets of the type anticipated from these studies often exhibit a large
dynamic range (e.g., factor of 5 or more) and tend to be highly skewed. Data sets of this sort are frequently
transformed to a lognormal scale for analysis purposes. This is because the effects of factors and variance of
the measurements tend to be multiplicative rather than additive when the dynamic range is large. This means
that the geometric means, rather than the arithmetic averages, will be estimated in the statistical modeling
analysis. Regardless of any transformation of the data, the findings from the statistical analysis will be reported
in the original measurement scale (TVOC emissions factor).
The analysis will include examination of the data for outliers or atypical TVOC levels. This
investigation, to be conducted by CRI, will seek to determine whether the product sample was handled
according to good laboratory practices or whether any abnormalities occurred during the conduct of the
chemical analysis procedures. Product types which are atypical in the sense that the combination yields
repeatable tvoc emissions levels which are unexpected (high or low relative to other product types) will also be
investigated. The results of these investigations will be reported in the results section of the final report.
3.4.2. Data presentation
Data from the decay curve study (non-SBR latex-backed carpet product types) will be depicted
graphically to show the TVOC decay curve for sample tested across the six (6) measured time points. Data will
be compared with the available ninteen (19) point data set previously determined by AQS for the decay curve
characteristics of SBR latex-backed carpets. An evaluation of the applicability of standard time point(s) for
TVOC measurement will be made from this data presentation. Given the small market share of many of the
non-SBR latex-backed carpet products and the small number of finishing lines, all hardback carpet product types
will be coded to facilitate a mil assessment of the data collected without identifying individual carpet product
types. Sample collection will be arranged in order to allow for an assessment of the production variability
within a product type.
The industry-wide profile will consist, in the first data display, of the "78" data points showing TVOC
emissions factor values for each product type studied in the Carpet Testing Program (both SBR and non-SBR
latex-backed product types). In the second data display, fourteen (14) data points will represent the average
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value for each carpet product type studied in the Carpet Testing Program. The averaged data display will
exhibit a high end, a low end, and a median for TVOC emissions from SBR latex-backed carpet products.
The distribution of data from the profile study will characterize a typical industry-wide profile of carpet
product type performance: industry-wide with respect to product types in commerce and also to manufacturer
sources. The distribution would be statistically analyzed to identify outliers and allow the industry to pursue
them for remedial action (high emitters) or for clues to reducing emissions industry-wide (low emitters). This
use of test data could provide a basis for developing further programs to meet the Carpet Dialogue's goal of
creating market pressure to drive down VOC exposures from carpet systems.
Individual data from the carpet testing program will be blinded to protect the identity of individual
manufacturers. This approach allows the full import of the factorial analysis to be evaluated, including the
identification of "outlier" phenomena.
3.4.3. Initial program evaluation
EPA will evaluate the results of the Carpet Testing Program in terms of analytical results and
conclusions, and will determine the variability and appropriate characterization of carpet product emissions
factors. EPA will use this technical evaluation to determine the need for follow-on testing. This evaluation will
also judge the extent to which the decay curve study, carpet profile study, and appropriate follow-on measures,
if required, have met the goals and concepts of the Federal Register notice. These evaluations and
assessments will be pivot points in the transition from the initial data gathering stages of the CRI five-point
program (see 1.2, items 1 and 2) and the application objectives/follow-on activities of the CRI program (items
3,4, and 5). Details of the follow-on activities are described in section 4.1 through 4.3. The specific features
of the follow-on program will be determined by EPA and CRI in consultation with the Carpet Dialogue Group.
Among the issues to be considered at this pivot point is whether further experimental data are necessary to
address the objectives of the Federal Register notice.
3.4.4. Public study report on industry profile
CRI will provide a full report on the Carpet Testing Program including the profile monitoring study
and the decay curve study to the U.S. EPA. The document will include: TVOC data for each SBR latex-backed
carpet product type tested (identified by carpet product type) and non-SBR latex-backed carpet product type
tested (reported as a data set unidentified by carpet product type), comparision data of carpet product decay
curve characteristics with assessment of a standard TVOC measurement time point(s), uniform latex loading for
SBR-containing products, statistical/ variability analysis and graphic presentation(s) of the data, discussion of the
study findings, and a laboratory report on field/laboratory quality assurance aspects of the study. The report
may also contain a perspective about the relative contribution from various new carpet product types to the total
VOC loading in the indoor environment. The EPA will make this information available to the interested public
through various mechanisms including a notice of availability in the Federal Register.
3.5. Independent Contractors and Data Quality Standards
As CRI membership comprises over 95% of U.S. carpet manufacturers, it is appropriate that CRI
sponsor the study and bear full responsibility for rigid scientific constructs. CRI will obtain the necessary
permission and legal clearances to permit collection of samples at its member mills in accordance with the study
protocol. To assure accuracy of test results and to minimize conflict of interest, an independent laboratory will
be retained to conduct product testing. The laboratory will be selected on the basis of its ability to fulfill the
proposed protocol for sampling and analysis and documented assurance that testing will be conducted in
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accordance with good laboratory practices and standard U.S. EPA guidance for QA/QC. The protocol will
include provision for using only appropriately trained personnel hired by the laboratory to perform sample
collection and transport. In addition to an experimental study protocol, there will be prepared a quality
assurance project plan specific to this Carpet Testing Program which would follow OTS/EPA guidance. All
QA/QC evaluation will be included in the study report as will the extent to which the results met the defined
data quality objectives.
CRI intends to initiate product testing in the Spring of 1991 with a view to generating preliminary
results in the Fall of 1991. The U.S. EPA would provide technical counsel as it does on other voluntary testing
agreements to ensure that data quality objectives are met in the Carpet Testing Program.
It is understood by all parties to this agreement that CRI will fulfill the voluntary program commitment
described herein on a cost-effective basis. CRI believes that it has committed sufficient budgetary resources to
support the five-point program. However, as detailed implementation plans are developed it should be
understood that modifications may be made not only on technical grounds but also to meet evolving cost
estimates.
4.0. FOLLOW-ON ACTIVITIES
During the balance of the dialogue year it is the intent of CRI to work with the U.S. EPA, other
experts, and the Carpet Dialogue Group along with its various working subgroups, to expedite implementation
of the five point program outlined in section 1.2. CRI will continue to report to the plenary on their progress to
reach these objectives.
4.1. Future Activities
To the extent that further development of subsequent phases of the CRI five-point program are
dependant upon information obtained from the data base study, follow-on activities are not fully detailed in this
consensus statement. They are mentioned here to describe the comprehensive nature of the CRI commitment to
respond to the Federal Register notice. The selections, specific direction and features of follow-on activities
will be developed in consultation between EPA and CRI.
4.1.1. A""lffl* industry report
CRI will generate an annual, aggregate history of carpet industry TVOC product performance for at
least three years. The data will be derived from company submissions under the QA product certification
program described below (see 4.1.2). These data will be used to reveal trends over time relative to the overall
industry-wide profile and, in future, to product types. The trend analysis will be a means to pursue
problematic, "outlier product* instances and to evaluate the success of the carpet industry in reducing TVOC
levels.
4.1.2. OA product certification
CRI, in consultation with EPA, will devise a program to motivate producers to institute voluntary
indoor air quality assurance measures with respect to their carpet products. This program would have
prescribed procedures documented in an operational manual to be developed by CRI for its members. It would,
at a minimum, include the development and submission to CRI of TVOC emission rate data on product types by
companies.
F-ll
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This information would enable the CRI to pursue the trend analysis for typical carpet products as
described above and to take voluntary actions for improvement or remedy of "outlier products" with member
manufacturers. CRI is prepared to publish a roster of companies which have received TVOC performance
certification within a given year.
4.1.3. Public communication
CRI, in cooperation with EPA and the Carpet Dialogue Public Communications Group, will conduct a
consumer information program to provide their customers with appropriate information on TVOC emissions
from carpet. Depending on the conclusions to be drawn from the testing described in Section 3, this
information program may include either product-by-product/company-by-company numeric information on
TVOC levels or, if appropriate, more generic information from industry-sponsored product certification and
annual aggregate
analyses. The consumer information program will ensure that carpet TVOC emissions are placed in an
appropriate context with other indoor air pollution sources.
4.2. Information Repository
Reports on studies undertaken under the aegis of the carpet dialogue will be provided to the U.S. EPA
which would maintain an on-going public file of this information in its public data docket facility. This
permanent repository of information would be readily available to the interested public and serve as the
reporting place for the proposed annual aggregate/trend analysis, QA product certification, and public
communication products.
4.3. Memorandum of Understanding
To give shape and substance to the on-going testing program and the EPA objective to attain
commitments to conduct voluntary product testing for TVOC, the CRI and the U.S. EPA, will enter into a
memorandum of understanding at or before the close of the dialogue process. This MOU will incorporate basic
elements of this consensus statement and other procedural arrangements common for voluntary testing
agreements in OTS. The MOU will be made public through a Federal Register notice.
F-12
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ATTACHMENT F-l
THE CARPET AND RUG INSTITUTE
CONSENSUS STATEMENT:
Carnet Emissions Decay Study
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ATTACHMENT F-l
THE CARPET AND RUG INSTITUTE
CONSENSUS STATEMENT:
Caroet Emissions Decay Studv
To determine the appropriate point in time to sample carpet emissions, a study in addition to the study
conducted on 19 SBR latex carpet samples will be undertaken. In this study, the data on emissions factors and
their decays will be determined over a period of sufficient duration to ensure that a carpet with higher emissions
at an early point in time maintains its relative ranking with respect to other carpets at later points in time.
To do mis, the following elements of a study will be supplied by the Carpet and Rug Institute via a test
program conducted by Air Quality Sciences. This study will be Phase I of the larger study to establish a carpet
emissions profile for the industry as defined in the Consensus Statement.
1. The emissions factor data provided by Air Quality Sciences on the 19 styrene-butadiene rubber
(SBR) backed carpets are provisionally accepted as having demonstrated that 24 hours may be an appropriate
sampling time for determining total volatile organic compound (TVOC) emissions from this type of carpet.
2. To confirm that the relative ratings do not change among SBR backed carpet after 24 hours, Air
Quality Sciences will provide TVOC data over time for each of the tests of the 19 carpets as well as data on the
chamber air exchange rate and product loading (mVm5).
3. To determine whether 24 hours is an appropriate sampling time for non-SBR backed carpet,
additional tests of emissions factors over time will be conducted. The carpet samples selected for this additional
TVOC emission testing will include six types of non-SBR backed carpet:
a. Nylon, Foam Urethane
b. Nylon, Urethane Hardback
c. Nylon, AR Hardback
d. Nylon, PVC Hardback
e. Nylon, EVA Hardback
f. Nylon, Bitumen Hardback
4. Carpet samples will be selected by the predominant topical treatment and collected by a mutually
agreed upon neutral individual (neither CRI nor EPA). There will be three samples from each type of carpet.
In those cases where there is more than one mill producing a carpet type, two samples from one mill and one
sample from another mill will be collected. In the case of a single source product type, three samples will be
collected on three separate days from the single source mill. Thus, TVOC emissions and their decays will be
determined from a total of 18 non-SBR backed carpets. A complete replicate set of the 18 carpet samples will
be retained and stored by AQS.
5. The test method employed by Air Quality Sciences will be as per Appendix 1 of the Air Quality
Sciences draft report 'Indoor Air Quality Evaluation of Carpet for the Carpet and Rug Institute, January 8,
1991." except as noted below:
Chamber air samples for the measurement of TVOC concentrations will be taken by Air Quality
Sciences at 6 points in time: 4 hrs; 8 hrs; 24 hrs; 48 hrs; 72 hrs; and 96 hrs. These TVOC
concentrations will be reported as well as data on the chamber air exchange rate and temperature and
product loading (mVm').
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Limited to this decay curve study, concentrations will be determined by both the flame ionization detection
and mass spectrometric detection methods in order to determine a correlation (if any) between them. TVOC
data for both methods will be reported to the EPA. The mass spectrometric speciation data for each carpet
sample tested in the decay curve study will be retained by Air Quality Sciences.
6. At the completion of the Phase I study, Air Quality Sciences will prepare a comprehensive report
of the TVOC data. Since most of the 6 non-SBR latex-backed carpets for this study are proprietary in nature
and supplied by a single source, product types will be coded to facilitate a full assessment of the data collected
without identifying individual producers. Sample collection will be arranged in an order to allow for an
assessment of the production variability within a production unit.
7. Bruce Tichenor will provide technical oversight to Air Quality Sciences.
8. The Carpet and Rug Institute is prepared to commence immediately with the collection and testing
of these six carpet products (18 samples) as Phase I of the overall test plan referenced in the Conensus
Statement for submittal to the U.S. EPA.
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ATTACHMENT F-2
Minority Report on Carpet Testing Agreement
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ATTACHMENT F-2
MINORITY REPORT ON CARPET TESTING AGREEMENT
This report reflects concerns of the undersigned that the testing program, as it deals with SBR-backed
carpets as outlined in Draft 7 (of 2/28/91), tails to provide all the information it should to the Dialogue. By this
failure, the testing program ignores Charges 2 and 3 to the Dialogue regarding information needs and
assessment of possible control methods for reducing emissions from carpet. Charge 2 reads, in part:
"Identify information needs for assessment of emission control feasibility, including data on carpet
manufacture....
Charge 3 reads, in part:
"Evaluate potential controls for reducing emissions
Volatile organic compounds enter the carpet installation system at many points, including several points
during carpet manufacture, e.g. as spinning oils for fiber manufacture, as dye solvents/carriers, as soil- and stain
resistance aids, and as components of the backing.
Clearly, if the dialogue is to take seriously its charge to evaluate potential engineering- and/or process
controls for reducing emissions it must generate knowledge as to the sources of those emissions. Unless it can be
shown that emissions arising from spinning oils, dye-related chemicals, soil- and stain resistance treatments and
backing materials are analytically indistinguishable from one another, one must conclude that obtaining the identities
of the compounds in the emissions "package" is vital for an understanding of the sources. Without an understanding
of the quantitative contribution of the various sources we cannot discharge our duty to evaluate potential controls
that would involve changes in the above-named elements of the carpet manufacturing process.
The analyses will be conducted under the proposed agreement using both GC/MS and FID instrumentation,
so identification of the emission constituents would merely involve reference to standard libraries of eluants, and
would not involve doing completely separate analytical work.
Although the test program is voluntary, the dialogue group faces a charge to evaluate potential controls.
Therefore, does it make sense to consider a completely new testing program some unspecified time in the future
in order to meet the evaluation charge simply because industry has declined to identify the emissions' constituents?
Further, the dialogue group's unwillingness to require speciation has not been adequately justified. While
charge number 1 to the dialogue does speak to total volatile organic compound
(VoC) emissions, there is no prohibition in that charge against identifying what the constituents of that total VOC
package are. one argument raised against identifying the VOCs at the plenary on March 1, viz. that identification
of compounds will automatically and inevitably require the dialogue to do health risk assessment is without merit.
The proponents of that argument provide no basis for that assertion.
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In summary, the agreement to which this minority report is appended fails to generate data that it easily I
could, data that are vital to the other charges before the dialogue, data that could be obtained most cost-effectively
by speciation of the emissions to be measured under the agreement, data whose gathering is not prohibited by the
Federal Register notice, data that do not inevitably require the dialogue to do health risk assessment.
signed1: J. William Hirzy, NFFE
Katherine Cox, AFSCME
Hal Levin
Signatures as of May 22, 1991
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APPENDIX G
Carpet Cushion Council Consensus
Statement: Testing Program for
Carpet Cushions
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CARPET POLICY DIALOGUE
CARPET CUSHION COUNCIL
CONSENSUS STATEMENT:
Testing Proeram for Carpet Cushions
June 28, 1991
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PREFACE
The Carpet Policy Dialogue Group, convened by die U.S. Environmental Protection Agency, is
engaged in a one-year effort to develop consensus and voluntary commitments with respect to approaches for
minimising exposure to volatile organic compounds (VOCs) emitted by carpet and associated products of carpet
flooring systems (FR: April 24, 1990 - 'Carpet: Response to Citizens' Petition" p. 17404-17409; and, FR:
August 3, 1990 - "Carpet Emissions Reduction; Policy Dialogue" p. 31640-34641).
This document conveys a consensus statement of the Carpet Policy Dialogue Plenary Group regarding
the commitment by the carpet cushion industry, as represented by the Carpet Cushion Council, for the voluntary
development and communication of Total Volatile Organic Compound (TVOC) emission test data on carpet
cushions.
Additional statements and reports concerning other aspects of the Carpet Policy Dialogue are
anticipated.
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Carpet Policy Dialogue
Consensus Statement
for the
Carpet Cushion Council:
Testing Program for Garnet Cushions
Preface G-i
1.0. BACKGROUND G-l
1.1. Charter and Charge G-l
1.2. Carpet Cushion Council Statement of Commitment G-l
2.0. DEFINITIONS G-2
2.1. Total Volatile Organic Compounds (TVOC) G-2
2.2. Boundary of Test Subject G-2
2.3. Voluntary Action G-2
2.4. Test Method G-3
3.0. CARPET CUSHION TESTING PROGRAM G-4
3.1. Rationale for Carpet Cushion Product Testing G-4
3.2. Study Objectives G-4
3.3. Scope and Structure of Study G-5
3.3.1. Carpet cushion product type selection criteria G-5
3.3.2. Sample collection and test method G-S
3.3.3. Study design sampling matrix for analytical testing G-5
3.4. Data Reporting and Evaluation G-6
3.4.1. Statistical analysis G-6
3.4.2. Data presentation G-7
3.4.3. Initial program evaluation G-7
3.4.4. Public study report G-7
3.5. Independent Contractors and Data Quality Standards G-8
4.0. FOLLOW-ON ACTTvTnES G-8
4.1. Future Activities G-9
4.1.1. Industry-wide study G-9
4.1.2. Annual industry report G-9
4.1.3. QA product certification G-9
4.1.4. Public communication G-9
4.2. Information Repository G-10
4.3. Memorandum of Understanding G-10
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CARPET CUSHION COUNCIL
CONSENSUS STATEMENT:
Testine Program for Garnet Cushions
1.0. BACKGROUND
1.1. Charter and Charge
The charter for testing under the Carpet Policy Dialogue process was given in the U.S. Environmental
Protection Agency's (EPA) Federal Register notice of April 24, 1990 in responding to the petition by the
National Federation of Federal Employees (NFFE) for EPA to undertake certain actions with respect to
reducing emissions from carpet (FR: April 24, 1990 - 'Carpet: Response to Citizens' Petition' p. 17404-17409;
and FR: August 3, 1990 - 'Carpet Emissions Reduction; Policy Dialogue' p. 31640-34641). The Carpet Policy
Dialogue Group, convened under the auspices of the U.S. Environmental Protection Agency, is engaged in a
one-year effort to develop consensus and voluntary commitments for minimising exposure to volatile organic
compounds emitted from carpet and associated products of a carpet flooring system.
This document conveys the Carpet Policy Dialogue Group consensus statement regarding the
commitment of the carpet cushion industry, as represented by the Carpet Cushion Council, to undertake
voluntary testing for total volatile organic compound (TVOC) emissions from new carpet cushions, to establish a
data base for reporting periodic TVOC analysis for new carpet cushion products, and to communicate useful
information about TVOC emissions from new carpet cushions. Specifically, it describes a testing program to
develop decay curve data on five carpet cushion product types. These data will be used to determine a testing
point(s) at which TVOC measurements will be compiled among a representative sample of new carpet cushions
(study to be conducted as a follow-on activity to the Dialogue process). Its acceptance was affirmed by the
Carpet Policy Dialogue Group meeting in plenary session on April 10, 1991.
1.2. Carpet Cushion Council Statement of Commitment
There are no universally accepted indoor air quality standards, guidelines, or regulations that are
applicable to carpet cushions. The Carpet Cushion Council regards the dialogue and this agreement as
a vehicle to accelerate the exploration and understanding of voluntary pollution prevention as one component in
improving indoor air quality. The Carpet Cushion Council has committed resources to this initiative in their
belief that a voluntary program will promote the use of industry-wide process controls to improve product
performance with respect to indoor air quality.
This voluntary testing program commitment by the Carpet Cushion Council addresses issues discussed
in the Federal Register notice. It provides for a Carpet Cushion Council sponsored decay curve study of five
carpet cushion product types. This study would serve as a base for any future measurement of TVOC emissions
from new carpet cushions. It is anticipated that, through follow-on activities, a TVOC data base for a
representative sample of carpet cushions will be generated. It is intended to provide these data to the consumer
to demonstrate the carpet cushion industry's commitment to the policy of pollution prevention and improvement
of indoor air quality. It is anticipated that EPA and the Carpet Cushion Council will enter into a memorandum
of understanding (MOU) which will describe procedural arrangements for implementation of the voluntary
Carpet Cushion Testing Program and follow-on activities.
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2.0. DEFINITIONS
2.1. Total Volatile Organic Compounds (TVOC)
Total Volatile Organic Compounds (TVOC), as defined in this document, represents the sum of volatile
organic compounds (VOC) that can be analyzed and measured by the specified analytical method. TVOC is
reported as an emission factor in mg/m^-hr and is a single numerical expression for the sum of VOC emissions
from a test substance (carpet cushion). This numerical expression will be used to direct scientific efforts and to
communicate useful information to the interested public.
2.2. Boundary of Test Subject
Carpet cushions are composed of various raw materials, to a large extent, scrap materials from the
manufacture of products used in other industries. The scrap materials are obtained from numerous worldwide
sources and recycled for use in the manufacture of carpet cushions. As such, the chemical makeup of an
individual cushion, in particular bonded and jute cushions, can vary and may be dependent on the time of the
year and location of the purchase of its raw materials.
Carpet cushions are placed underneath carpet on a wall-to-wall type of installation that completely
covers the surface and sides of the carpet cushion when installed. It is estimated that new carpet cushion is
placed under approximately 50 percent of all new broadloom carpet sold. Vinyl non-skid rug pads and other
non-skid rug pads weighing less than 14 ounces per square yard, for placement underneath area rugs, are
beyond the scope of this agreement. For the purpose of this voluntary test agreement, the test subject is
restricted to carpet cushions as obtained at the end of a manufacturer's finishing line. The term carpet cushion
as used in this document refers to new carpet cushion as it leaves the finishing line.
On behalf of the carpet cushion industry, the Carpet Cushion Council has determined that carpet
cushions can be classified into five product types: bonded, prime, rubber, synthetic and rubberized jute. These
products are manufactured at a total of 75 finishing lines, representing approximately 34 companies. Bonded
cushions comprise 56 % of the total market share (based on square yards shipped); prime cushions constitute
33 % of the market. Rubber cushions constitute 6 % of the total market, while synthetic cushions represent 3 %
of the market. Rubberized jute cushions comprise 2% of the market. The number of finishing lines at which
these five carpet cushion product types are produced will be determined by the Carpet Cushion Council and
provided in the final report.
2.3. Voluntary Action
This voluntary agreement to conduct TVOC emissions testing for new carpet cushions is undertaken by
the carpet cushion industry as part of a continuing commitment to product stewardship. The program is
implemented with respect to products as produced by the manufacturer and may include industry guidelines for
proper installation, maintenance and care.
It is understood that the agreement is not open-ended and that the commitment of the Carpet Cushion
Council is the conduct of a reasonable and appropriate testing program, giving regard to cost, cost-effectiveness
and other feasibility considerations. As test data are generated, this information will serve as the reference
point for determining the need for additional testing and the possible need for an on-going testing program,
which is one of the goals of the Federal Register charter. The program will be implemented so as to preserve
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necessary proprietary information and, with future testing, establishes a base for appropriate inter-product type
comparisons.
2.4. Test Method
The test method selected to obtain TVOC measurements for carpet cushions is a small chamber test.
The environmental chamber method was described by the U.S. EPA in its document, 'Indoor Air Sources:
Using Small Environmental Chambers to Characterize Organic Emissions from Indoor Materials and Products"
(EPA report 600/8-89-074). The method is based on an ASTM standard, "Standard Guide for Small-Scale
Environmental Chamber Determinations of Organic Emissions from Indoor Materials/ Products" (ASTM
D5116-90). The techniques described in these documents have been further refined to measure TVOC
emissions from carpet flooring products (Attachment A: "Standard Test Method for Determining Total Volatile
Organic Compound Emission Factors from Carpet Under Defined Test Conditions Using Small Environmental
Chambers"). TVOC emissions data for carpet flooring products obtained from this standardized small chamber
testing procedure may be used to compare and evaluate carpet cushion's relative contribution to indoor air
quality with TVOC data from other products.
The standard method, as described in Appendix E, provides accurate TVOC measurements. The
minimal quantifiable limit is 4.0 ug/m3, which is twice the detection limit of 2.0 ug/nf or 36 ng TVOC. The
TVOC concentration measured in the environmental chamber is used to calculate an emissions factor expressed
as mg/mlhr. The emissions factor is a product-specific factor describing the mass of chemical emitted from the
product per exposed area of the product per unit time. The quantifiable limit for carpet cushion, expressed as
an emission rate, is 0.01 mg/m^hr. The emission rate is projected by multiplying the emissions factor by the
area of carpet cushion in a particular installation.
Emission factor data may be generated at various tune intervals. At this time, limited decay curve data
exist for carpet cushions. Since it has not been determined whether the use of a single point on the decay curve
is sufficient to characterize total VOC emissions from carpet cushions and whether all carpet cushion types
respond similarly with respect to their decay curve characteristics, additional information regarding these
properties is needed for each of the five carpet cushion types. If a single point for TVOC measurement is
reasonable, then the appropriate point must also be determined. The resolution of these issues will be integrated
into the finalized analytical method, which is included as Attachment A (currently in "draft" form).
The test method has been documented by an expert working party of the Dialogue's Product Testing
Subgroup. A draft protocol is currently being circulated for peer review. The method, with peer review
revisions incorporated, will be available directly. It has been judged by the Carpet Policy Dialogue Group on
November 29, 1990 to be an acceptable analytic tool for any industry study undertaken in 1991 under the aegis
of the Carpet Policy Dialogue process. This test method will be submitted to ASTM by its principal originator
for ASTM balloting procedures as a new "Standard Test Method." Further validation by interested laboratories
is expected over the next two years.
3.0. CARPET CUSHION TESTING PROGRAM
The Carpet Cushion Testing Program will be conducted in two phases. Fifteen samples will be
collected in the combined testing program. The first phase will develop decay curve emission data on bonded
and prime carpet cushion product types, representing 89% of the entire market. Three samples from each
product type, or a total of six samples, will be tested. Phase II will collect corresponding information on
rubber, synthetic and rubberized jute carpet cushions. A total of nine samples will be collected in Phase II.
The decay curve data established for these five product types will be compared with existing data on carpet
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cushion TVOC emissions, previously commissioned by the Carpet Cushion Council and the Carpet and Rug
Institute. They will also be used to determine the appropriate air sampling time point, or points, to use in
measuring TVOC emissions. TVOC measurements will be collected at six time points (4, 8, 24, 48, 72 and 96
hours) after placement of the carpet cushion in the small chamber. This single point(s) will be used to
characterize carpet cushion TVOC emissions in a larger industry-wide study, to be conducted as a follow-on
activity to the Carpet Policy Dialogue. The industry study will build a data base/profile of TVOC emissions,
collected from a representative sample of carpet cushion products over time.
3.1. Rationale for Carpet Cushion Product Testing
Exploratory data on generic types of carpet cushion developed in 1990 for the Carpet Cushion Council
demonstrate that TVOC emissions from carpet cushions, while different among classes, will nevertheless
approximate that of carpet. It has also been shown in testing done both by the Carpet Cushion Council and by
the Carpet and Rug Institute that carpet forms a barrier to emissions from carpet cushion that significantly slows
down the permeation of TVOCs into an indoor area. These preliminary data sets include limited information
about the characteristics of the decay curve for the various carpet cushion product types. They do not provide
data on the variability of TVOC emissions from cushions of the same product type (manufactured at different
finishing lines) or on the differences between average TVOC emission rates for the five carpet cushion product
types. The decay curve characteristics from the five carpet cushion types will provide a basis for selecting a
sampling time point(s) for use in any follow-on testing. This additional testing will characterize the range of
industry-wide product performance with respect to TVOC emission rates.
The data developed from the Carpet Cushion Testing Program will provide the Carpet Policy Dialogue
Group, industry, regulatory agencies, and the interested public with additional information to assess whether
there is sufficient variability of TVOC emissions across carpet cushions to warrant communication of TVOC
information on individual carpet cushion types to the interested consumer.
3.2. Study Objectives
The overall Carpet Cushion Testing Program objectives are to characterize the TVOC decay curve
characteristics for samples from each of the five carpet cushion product types currently in commerce, and to
determine the appropriate air sampling time points) to use in measuring TVOC emissions in future studies. At
this time, the program will not provide data on the distribution of TVOC emissions across the universe of carpet
cushion types.
3.3. Scope and Structure of Study
3.3,1. Carpet cushion product type selection criteria
Five carpet cushion product types (with approximate market shares based on square yards snipped in
parentheses) are currently in commerce: bonded (56%), prime (33%), rubber (6%), synthetic (3%) and
rubberized jute (2%).
3.3.2. Sample collection and test method
The method for sample collection at the carpet cushion mill, sample transport to the laboratory, and
TVOC analysis is described in Attachment A. This method will be used throughout the Carpet Cushion Testing
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Program. Samples of each product type will be randomly selected from a list of manufacturers' finishing lines,
to be compiled by the Carpet Cushion Council.
3.3.3. Study design sampling matrix for analytical testing
Table 1 shows the five product types to be sampled and the number of carpet cushion samples from
each carpet cushion product type to be collected and analyzed by the methods described in section 3.3.2. When
all data are available from both phases, the TVOC emissions rate measured at the appropriate time point(s)
obtained from these samples will be analyzed as a single data set. A total of fifteen samples (including five
replicate samples) will be analyzed in the combined study. Specifically, three samples from each product type
will be collected, where one sample will be collected from one finishing line and two samples will be collected
from a second finishing line at different times. The samples and replicate samples (i.e., samples collected on
different days from the same finishing line) will permit an evaluation of line to line and day to day variability of
TVOC emission factors. In addition, this combined data set will also permit evaluation of the effects on TVOC
emission factor for the five product types.
For each row (carpet cushion product type) in Table 1, the number of finishing lines will be drawn
randomly from all lines making that product type at the time the samples for that type are to be collected. In
addition, one of these lines, chosen at random
from the two selected lines, will have a replicate or second sample taken on a different day.
Additional quality assurance (QA/QC) samples (e.g., laboratory duplicate samples) numbering about
10% of the study samples tested will be taken in accordance with standard data quality procedures of the U.S.
EPA.
Table 1. Sampling Matrix of Carpet Cushion Product Types
No. of No. of % Total
Sampled Replicate Market No. of
Carpet Cushion Product Types Lines Samples Share Samples
Phase I
Bonded 2 1 56 3
Prime _2 _1 _33 _3
Total 4 2 89 6
Rubber 2163
Synthetic 2 1 33
Rubberized Jute _2 _1 _2 _3
Total 6 3 11 9
Grand Total 10 5 100 15
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3.4. Data Reporting and Evaluation
The data analysis will follow the lines of the objectives defined in section 3.2.
3.4.1. Statistical analysis
A statistical analysis of the combined study data will be performed using a technique known as analysis
of variance. This method will be used to determine the effects on TVOC emissions of carpet cushion product
type. Information will also be obtained on line to line variation among finishing lines producing the same carpet
cushion product type and temporal (day to day) variation within a single finishing line. All results will be
accompanied by an estimate of the statistical uncertainty (i.e., coefficient of variation or, if appropriate, 95
percent confidence limits) associated with them. These uncertainties are due to sampling or product variability,
as well as measurement error.
Upon receipt of the data from the testing laboratory, the chemical analysis results will be examined to
determine the need for data transformation. In addition to examining if a transformation is necessary, an
evaluation of which type of transformation is most appropriate will be conducted. Traditionally, data sets of the
type anticipated from this study often exhibit a large dynamic range (e.g., factor of 5 or more) and tend to be
highly skewed. Data sets of this sort are frequently transformed to a lognormal scale for analysis purposes.
This is because the effects of factors and variance of measurements tend to be multiplicative rather than additive
when the dynamic range is large. This means that the geometric means, rather than the arithmetic averages,
will be estimated in the statistical modeling analysis. Regardless of whether the data are transformed or not, the
results of the statistical analysis will be reported in the original measurement scale (TVOC emissions factor).
The analysis will include examination of the data for outliers or atypical TVOC levels. This
investigation, to be conducted by the Carpet Cushion Council, will seek to determine whether the product
sample was handled according to good laboratory practices or whether any abnormalities occurred during the
conduct of the manufacturing process or chemical analysis procedures. Product types which are atypical in the
sense that die TVOC emission rates are repeatable but that the type yields levels which are unexpected (high or
low relative to other product types) will also be investigated. The results of these investigations will be reported
in the results section of the final report.
3.4.2. Data presentation
Data from the testing program will be depicted graphically to show the TVOC decay curve for each
product type across the six (6) measured time points. These data will be compared with existing data sets,
previously commissioned by the Carpet Cushion Council and the Carpet and Rug Institute. An evaluation of the
applicability of standard time point(s) for TVOC measurement will be made from this data presentation.
In a second data display, five data points will represent the average value for each carpet cushion
product type studied in the Carpet Cushion Testing Program. Individual data will be reported in an appendix to
the final report. Company names will be blinded to protect the identity of individual manufacturers.
3.4.3. Initial program evaluation
The data collected in each phase of the testing program will be submitted to EPA for review as soon as
each data set becomes available. Two initial evaluations of Phase I and Phase II data and an overall evaluation
of the combined results will be conducted. EPA will evaluate the results of the Carpet Cushion Testing
Program in terms of analytical results and conclusions, and will determine the variability and appropriate
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characterization of carpet cushion product type emissions factors. EPA will use this technical evaluation to
determine whether, in its view, there is a need for follow-on testing or other follow-on measures. This
evaluation will also judge the extent to which the decay curve and testing data and appropriate follow-on
measures, if required, have met the Federal Register charter. Among the issues to be considered is whether
further experimental data are necessary to address the objectives of the Federal Register notice. Details of other
follow-on activities are described in sections 4.1 through 4.3.
3.4.4. Public study report
The Carpet Cushion Council will provide a full report on the Carpet Cushion Testing Program to the
U.S. EPA. The document will include: TVOC data for each carpet cushion product type tested, including the
decay curve characteristics and an assessment of a standard TVOC measurement time point(s) associated with
each cushion type, a description and results of the statistical/variability analysis and graphic presentation(s) of
the data, discussion of the study findings, and a laboratory report on field/laboratory quality assurance aspects
of the study. The report may also contain a perspective about the relative contribution from various carpet
cushion types to the total VOC loading in the indoor environment. The EPA will make this information
available to the interested public through various mechanisms, including a notice of availability in the Federal
Register.
3.5. Independent Contractors and Data Quality Standards
The Carpet Cushion Council represents 16 carpet cushion manufacturers. It is estimated that these
companies manufacture approximately 75% of all carpet cushions sold in the United States. With respect to the
Carpet Cushion Testing Program, the Carpet Cushion Council will solicit the participation of all its members, as
well as those carpet cushion manufacturers who are not members of the Council. The Carpet Cushion Council's
goal is to achieve 95% participation of all carpet cushion manufacturers in the testing program. The Carpet
Cushion Council will sponsor the testing program and will make a good faith effort to ensure that EPA
guidelines for QA/QC are employed. The Carpet Cushion Council will obtain the necessary permission and
legal clearances to permit collection of samples at the participating mills in accordance with the study protocol.
To assure accuracy of test results and to minimize conflict of interest, an independent laboratory will
be retained to conduct product testing. The laboratory will be selected on the basis of its ability to fulfill the
proposed protocol for sampling and analysis and documented assurance that testing will be conducted in
accordance with good laboratory practices and standard U.S. EPA guidance for QA/QC. The protocol will
include provisions for using only appropriately trained personnel hired by the laboratory to perform sample
collection and transport.
In addition to an experimental study protocol, a Quality Assurance Project Plan specific to this Carpet
Cushion Testing Program will be prepared following EPA Office of Toxic Substances (EPA/OTS) guidance.
All QA/QC evaluations will be documented in this plan, which must be signed by representatives of the Carpet
Cushion Council and EPA prior to the commencement of testing. All QA/QC results will be included in the
study final report. The extent to which the results meet the defined data quality objectives of the testing
program will also be addressed in the report.
The Carpet Cushion Council intends to initiate product testing in the late Summer of 1991, with a view
to generating preliminary results in the Fall of 1991. Phase II will be conducted as resources can be made
available, but within a one year period. The U.S. EPA will provide technical counsel, as it does on other
voluntary testing agreements, to ensure that data quality objectives are met in the Carpet Cushion Testing
Program.
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It is understood by all patties to this agreement that the Carpet Cushion Council commitment is to
conduct a cost-effective voluntary testing program. The Carpet Cushion Council believes that it has committed
sufficient budgetary resources to support the two-phased program described herein. However, as detailed
implementation plans are developed, it should be understood that modifications may be made not only on
technical grounds, but also to reflect the limits of the Council's undertaking to conduct a cost-effective program.
4.0. FOLLOW-ON ACTIVITIES
During the balance of the dialogue year, it is the intent of the Carpet Cushion Council to work with the
U.S. EPA, other experts, and the Carpet Policy Dialogue Group, along with its various working subgroups, to
expedite implementation of the two-phased program outlined in section 1.2. The Carpet Cushion Council will
continue to report to the Plenary on their progress to reach these objectives.
4.1. Future Activities
To the extent that further development of subsequent phases of the Carpet Cushion Council Testing
Program is dependent upon information obtained from the study described in this document, follow-on activities
are not fully detailed in this consensus statement. They are mentioned here to describe the comprehensive
nature of the Carpet Cushion Council's commitment to respond to the Federal Register notice. The selections,
specific direction and features of follow-on activities will be developed in consultation between EPA and the
Carpet Cushion Council.
4.1.1. Industry-wide study
The decay curve characteristics obtained in the Carpet Cushion Testing Program will serve to identify
the appropriate sampling point for TVOC measurement for the five carpet cushion types in commerce. This
sampling point will be used in an industry-wide study of a representative sample of carpet cushions. This larger
study will characterize a typical industry-wide profile of carpet cushion types: industry-wide with respect to
product types in commerce and also to manufacturer sources. The distribution will be statistically analyzed to
identify outliers and allow the industry to pursue them for remedial action or for clues to reducing TVOC
emissions on an industry-wide basis. This use of test data could provide a base for developing further programs
to meet the Carpet Policy Dialogue's goal of creating market pressure to drive down VOC exposures from
carpet systems.
4.1.2. Annual industry report
The Carpet Cushion Council will generate an annual, aggregate history of carpet cushion industry
TVOC emission product performance for at least three years. The data will be derived from the industry-wide
study described in section 4.1.1. These data will be used to reveal trends over time relative to the overall
industry-wide profile and, in future, to product types. The trend analysis will be a means to pursue
problematic, "outlier product" instances and to evaluate the success of the carpet cushion industry in reducing
TVOC levels.
4.1.3. QA product certification
The Carpet Cushion Council, in consultation with EPA, will devise a program to motivate producers to
institute voluntary indoor air quality assurance measures with respect to their carpet cushion products. This
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program will have prescribed procedures documented in an operational manual to be developed by the Carpet
Cushion Council for its members. It will, at a minimum, include the development and submission to the Carpet
Cushion Council of TVOC emission factor data on product types by companies.
This information would enable the Carpet Cushion Council to pursue the trend analysis for typical
carpet cushions as described above and to take voluntary actions for improvement or remedy of "outlier
products" with member manufacturers. The Carpet Cushion Council is prepared to publish a roster of
companies which have received TVOC performance certification within a given year.
4.1.4. Public communication
The Carpet Cushion Council, in cooperation with EPA, will conduct a consumer information program
to provide their customers with appropriate information on TVOC emissions from carpet cushions. Depending
on the conclusions to be drawn from the testing described in section 3, this information program may include
either product-by-product/company-by-company numeric information on TVOC levels or, if appropriate, more
generic information from industry-sponsored product certification and annual aggregate analyses. The consumer
information program will ensure that carpet cushion TVOC emissions are placed in an appropriate context with
other indoor air pollution sources.
4.2. Information Repository
Reports on studies undertaken under the aegis of the Carpet Policy Dialogue will be provided to the
U.S. EPA, which will maintain an on-going public file of this information in its public data docket facility.
This permanent repository of information will be readily available to the interested public and will serve as the
reporting place for the proposed annual aggregate/trend analysis and public communication products.
4.3. Memorandum of Understanding
To give shape and substance to the on-going testing program and the EPA objective to attain
commitments to conduct voluntary product testing for TVOC emissions, the Carpet Cushion Council and the
U.S. EPA will enter into a memorandum of understanding at or before the close of the dialogue process. This
MOU will incorporate basic elements of this consensus statement and other procedural arrangements common
for voluntary testing agreements in the Office of Toxic Substances. The MOU will be made public through a
Federal Register notice. The document will be submitted for signature by the EPA and all participants in the
Carpet Cushion Council Testing Program.
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APPENDIX H
Floor Covering Adhesive Manufacturers
Committee Consensus Statement:
Testing Program for Carpet
Installation Adhesives
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CARPET POLICY DIALOGUE
FLOOR COVERING ADHESIVE MANUFACTURERS COMMITTEE
CONSENSUS STATEMENT:
Testing Program for Garnet Installation Adhesives
June 28, 1991
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PREFACE
The Carpet Policy Dialogue Group, convened by the U.S. Environmental Protection Agency, is
engaged in a one-year effort to develop consensus and voluntary commitments with respect to approaches for
minimizing exposure to volatile organic compounds (VOCs) emitted by carpet and associated products of carpet
flooring systems (FR: April 24, 1990 - 'Carpet: Response to Citizens' Petition" p. 17404-17409; and FR:
August 3, 1990 - 'Carpet Emissions Reduction; Policy Dialogue" p. 31640-34641).
This document conveys a consensus statement of the Carpet Policy Dialogue Plenary Group regarding
the commitment by the carpet installation adhesives industry, as represented by the Floor Covering Adhesive
Manufacturers Committee of the National Association of Floor Covering Distributors, in concert with the
Adhesive and Sealant Council, Inc., for the voluntary development and communication of Total Volatile Organic
Compound (TVOC) emission test data on carpet installation adhesives.
anticipated.
Additional statements and reports concerning other aspects of the Carpet Policy Dialogue are
ed.
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Carpet Policy Dialogue
Consensus Statement
for the
Floor Covering Adhesive Manufacturers Committee:
Testing Procram for Carpet Installation Adhesives
1.0. BACKGROUND
1.1. Charter and Charge
1.2. Floor Covering Adhesive Manufacturers Committee Statement of Commitment
2.0. DEFINITIONS
2.1. Total Volatile Organic Compounds (TVOC)
2.2. Boundary of Test Subject
2.3. Voluntary Action
2.4. Test Method
3.0. CARPET INSTALLATION ADHESIVE TESTING PROGRAM
3.1. Rationale for Carpet Installation Adhesive Product Testing
3.2. Study Objectives
3.3. Scope and Structure of Study
3.3.1. Carpet installation adhesive product type selection criteria
3.3.2. Sample collection and test method
3.3.3. Study design sampling matrix for methodology development
3.4. Data Reporting and Evaluation
3.4.1. Statistical analysis
3.4.2. Data presentation
3.4.3. Initial program evaluation
3.4.4. Public study report
3.5. Independent Contractors and Data Quality Standards
4.0. FOLLOW-ON ACnvnTES
4.1. Future Activities
4.1.1. Annual industry report
4.1.2. Testing follow-up activities
4.1.3. Public communication
4.2. Information Repository
4.3. Memorandum of Understanding
Attachment H-l Test Method
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FLOOR COVERING ADHESIVE MANUFACTURERS COMMITTEE
CONSENSUS STATEMENT:
Testine Program for Camel Installation Adhesives
1.0. BACKGROUND
1.1. Charter and Charge
The charter for testing under the Carpet Policy Dialogue process was given in the U.S. Environmental
Protection Agency's (EPA) Federal Register notice of April 24, 1990 in responding to the petition by the
National Federation of Federal Employees (NFFE) for EPA to undertake certain actions with respect to
reducing emissions from carpet (FR: April 24, 1990 - "Carpet: Response to Citizens' Petition" p. 17404-17409;
and FR: August 3, 1990 - "Carpet Emissions Reduction; Policy Dialogue" p. 31640-34641). The Carpet Policy
Dialogue Group, convened under the auspices of the U.S. Environmental Protection Agency, is engaged in a
one-year effort to develop consensus and voluntary commitments for minimizing exposure to volatile organic
compounds emitted from carpet and associated products of a carpet flooring system.
This document conveys the Carpet Policy Dialogue Group consensus statement regarding the
commitment of the carpet installation adhesives industry, as represented by the Floor Covering Adhesive
Manufacturers Committee, to undertake voluntary testing for total volatile organic compound (TVOC) emissions
from recently manufactured carpet installation adhesives, to establish a data base for reporting decay curve
characteristics for carpet installation adhesive products, to provide periodic reporting of growth in usage of low
VOC emission products, to encourage adhesive manufacturers to exercise due diligence in the testing of
products before shipment to assure that carpet installation adhesive products meet VOC statements described on
labels and to communicate useful information about TVOC emissions from carpet installation adhesives.
Specifically, it describes a testing program to develop multi-time-point decay curve data on five carpet
installation adhesive product classifications. The data will be used to determine a testing point(s) at which
TVOC measurements could be compiled among a sample of recently manufactured carpet installation adhesives.
Its acceptance, in principle, was affirmed by the Carpet Policy Dialogue Group meeting in plenary session on
March 1, 1991.
1.2. Floor Covering Adhesive Manufacturers Committee Statement of Commitment
There are no universally accepted indoor air quality standards, guidelines, or regulations that are
applicable to carpet installation adhesives. The Floor Covering Adhesive Manufacturers Committee regards the
dialogue and this agreement as a vehicle to accelerate the exploration and understanding of voluntary pollution
prevention as one component in improving indoor air quality. The Floor Covering Adhesive Manufacturers
Committee has obtained commitment from 16 member companies to support this initiative in the belief that a
voluntary program will promote the use of industry-wide process controls to improve product performance with
respect to indoor air quality.
This voluntary testing program commitment by the Floor Covering Adhesive Manufacturers Committee
addresses issues discussed in the Federal Register notice. It provides for a Floor Covering Adhesive
Manufacturers Committee sponsored multi-time-point decay curve study of five carpet installation adhesive
product types. This study will serve as a base for any future measurement of TVOC emissions from recently
manufactured carpet installation adhesives. It is anticipated that, through annual reporting on percentage of
sales by VOC classification by committee members, a data base for carpet installation adhesives will be
generated. It is intended to provide these data to the consumer to demonstrate the carpet installation adhesive
industry's commitment to the policy of pollution prevention and improvement of indoor air quality. It is
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anticipated that EPA and the Floor Covering Adhesive Manufacturers Committee will enter into a memorandum
of understanding (MOU) which will describe procedural arrangements for implementation of the voluntary
Carpet Installation Adhesives Testing Program and follow-on activities.
2.0. DEFINITIONS
2.1. Total Volatile Organic Compounds (TVOC)
Total Volatile Organic Compounds (TVOC), as defined in this document, represents the sum of volatile
organic compounds (VOC) that can be analyzed and measured by the specified analytical method. TVOC is
reported as an emission factor in mg/mMir and is a single numerical expression for the sum of VOC emissions
from a test substance (carpet installation adhesive). This numerical expression will be used to direct scientific
efforts and to communicate useful information to the interested public.
2.2. Boundary of Test Subject
Carpet installation adhesives are formulated through a composition of several basic ingredients,
combined in varying proportions depending upon the functions of the adhesive. Adhesive formulating and the
choice of raw materials used is based on price, performance and environmental issues. Six functional
components are generally used: vehicle (e.g., water, solvents or a combination of both), binder (e.g., latex
(Styrene-Butadiene (SBR) is the major latex used) or resins (sometimes referred to as tackifiers), fillers
(limestone, gypsum, sand or clay), viscosity control agents, preservatives and freeze-thaw stability agents (e.g.,
methanol or ethylene glycol). These raw materials are obtained from numerous sources and added to the final
mixture in amounts determined by the manufacturer. Adhesive manufacturers typically offer a range of carpet
installation adhesives, with good (economy), better, best (premium) and specialty products. Further, variations
of adhesive formulas are needed in different geographical markets, due to variable temperature and humidity
conditions.
For the purpose of this voluntary test agreement, the test subject is restricted to carpet installation
adhesives as obtained directly from the distributor. The Floor Covering Adhesive Manufacturers Committee has
identified that these products have a rapid turnover at the distributor. This assures a uniform test sample of
recently manufactured adhesive products available to installers. Thus, the distributor represents the most
appropriate site to provide test sample materials. Such products are referred to in this document as new carpet
installation adhesives. The terms carpet installation adhesive, new or recently manufactured carpet installation
adhesive and floor covering adhesive are synonymous.
On behalf of the carpet installation adhesives industry, the Floor Covering Adhesive Manufacturers
Committee has determined that carpet installation adhesives can be classified into five product classifications:
multipurpose, pressure sensitive, vinyl backed, pad cement and seam sealer. These products are manufactured
by 16 member companies. Multi-purpose adhesives comprise 75% of the total carpet installation adhesive
market and are produced by 16 companies at 32 plants. Pressure sensitive adhesives constitute 17 % of the
market and are produced at about 26 plants, representing 16 companies. Vinyl backed adhesives constitute 5 %
of the total market and are produced at 28 plants (17 companies). Pad cement (2% of the market) is produced
at 17 plants by 12 companies. Seam sealers are produced at IS plants (12 companies) and comprise 1 % of the
carpet installation adhesive market.
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2.3. Voluntary Action
This voluntary agreement to conduct TVOC emissions testing for recently manufactured carpet
installation adhesives is undertaken by the carpet installation adhesive industry as part of a continuing
commitment to product stewardship. The program is implemented with respect to products as produced by the
manufacturer and sampled at the distributor. It may include guidelines for storage and use during installation.
It is understood that the agreement will operate where reasonable and appropriate as governed by the
economics of the designed testing program. As test data are generated, this information serves as the reference
point for on-going testing and evaluation, which is one of the goals of the Federal Register charter. The
program will be implemented so as to preserve necessary proprietary information and, with future testing,
establishes a base for appropriate inter-product type comparisons.
2.4. Test Method
The test method selected to obtain TVOC measurements for carpet installation adhesives is a small
chamber test. The environmental chamber method was described by the U.S. EPA in its document, "Indoor Air
Sources: Using Small Environmental Chambers to Characterize Organic Emissions from Indoor Materials and
Products* (EPA report 600/8-89-074). The method follows an ASTM standard, 'Standard Guide for Small-
Scale Environmental Chamber Determinations of Organic Emissions from Indoor Materials/ Products" (ASTM
DS116-90). The techniques described in these documents have been further refined to measure TVOC
emissions from carpet flooring products (Attachment A: "Standard Test Method for Determining Total Volatile
Organic Compound Emission Factors from Carpet Under Defined Test Conditions Using Small Environmental
Chambers"). Based on the evaluation of the results of preliminary testing, the testing procedure will be
modified in an addendum to incorporate the specifics of testing carpet installation adhesives. TVOC emissions
data for carpet flooring products obtained from this standardized small chamber testing procedure may be used
to compare and evaluate carpet installation adhesives's relative contribution to indoor air quality with TVOC
data from other products.
The standard method, which will be adapted for adhesives testing, is expected to provide accurate
TVOC measurements. The minimal quantifiable limit, which is twice the detection limit, will be determined in
preliminary testing. The TVOC concentration measured in the environmental chamber is used to calculate an
emissions factor expressed as mg/mrhr. The emissions factor is a product-specific factor describing the mass of
chemical emitted from the product per exposed area of the product per unit time. The quantifiable limit for
carpet installation adhesive, expressed as an emission rate, will also be determined in preliminary testing. The
emission rate is projected by multiplying the emissions factor by the area of carpet installation adhesive in a
particular installation.
Emission factor data may be generated at various time intervals. Adhesives, by their nature, emit
VOCs over time as part of a setting up process. As such, TVOC emissions vary during and following carpet
installation. At this time, there is limited understanding about the decay curve characteristics for carpet
installation adhesives. Since it has not been determined whether the use of a single point on the curve is
sufficient to characterize total VOC emissions from carpet installation adhesives and whether all carpet
installation adhesive product types respond similarly with respect to their decay curve characteristics, additional
information regarding these properties is needed for each of the five carpet installation adhesive product types.
If a single point for TVOC measurement is reasonable, then the appropriate point must also be determined.
Further, questions concerning the applicability of the standard test method described above (e.g., application
rate and method of application, substrate material, frequency and duration of air sampling) were raised during
technical discussions on the design of a testing program to characterize the decay curve of the various carpet
installation adhesive product types. The applicability of the test method will be addressed as a preliminary
component of the Carpet Installation Adhesive Testing Program. The resolution of all above described issues
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will be integrated into the finalized analytical method, which is included as Attachment H-l (currently in "draft"
form).
The test method has been documented by an expert working party of the Dialogue's Product Testing
Subgroup. A draft protocol is currently being circulated for peer review. The method, with peer review
revisions incorporated, will be available directly. It has been judged by the Carpet Policy Dialogue Group on
November 29, 1990 to be an acceptable analytic tool for any industry study undertaken in 1991 under the aegis
of the Carpet Policy Dialogue process. This test method will be submitted to the ASTM by its principal
originator for ASTM balloting procedures as a new "Standard Test Method." Further validation by interested
laboratories is expected over the next two years.
3.0. CARPET INSTALLATION ADHESIVE TESTING PROGRAM
The Carpet Installation Adhesive Testing Program will be conducted in two phases. As described in
section 2.4, a preliminary study will be conducted to establish specific testing parameters for carpet installation
adhesives. The Preliminary Study will provide data to refine the test protocol for use in characterizing TVOC
emissions from the multipurpose and pressure sensitive carpet installation adhesive product classifications. It
will create and evaluate alternative test protocols to determine which procedures are most appropriate for use in
characterizing TVOC emissions from carpet installation adhesive products. Four samples will be tested.
Following preliminary testing, Phase I will determine the TVOC decay curve characteristics for
multipurpose and pressure sensitive adhesives. These adhesives represent approximately 92% of the carpet
installation adhesive market. TVOC decay curves will be analytically determined on a samples) of each of the
product classifications. A total of fifteen study samples (including five samples of the same product type
manufactured by a different company) will be tested. Measurements will be taken at the number of time points
determined in the Preliminary Study. This information could be used by the industry to determine the
appropriate air sampling time point, or points, for follow-on activities. This single point(s) could also be used
to characterize carpet installation adhesive TVOC emissions by individual companies as they test their products
in a follow-on activity to the Carpet Policy Dialogue.
Phase n will include decay curve testing on vinyl backed adhesives, pad cement and seam sealers.
This testing will be conducted as resources can be made available, but within a one-year period. Preliminary
test method development may also be needed prior to initiating testing of these three product classifications.
3.1. Rationale for Carpet Installation Adhesive Product Testing
Most carpet installation adhesive manufacturers have been calculating VOC content using standards set
by the South Coast Air Quality Management District (ASTM D3960-81 and/or ASTM D2369-87). Prior to
1990, the majority of carpet installation adhesives were at a calculated VOC of 150 g/1 or higher. With the
pressure of South Coast's Rule 1168, all manufacturers reformulated their products to a calculated VOC at or
below the required ISO g/1 limit ("Rule 1168 - Control of Volatile Organic Compound Emissions from Adhesive
Application," Amended February, 1991). As of September, 1990, one manufacturer introduced a new
generation carpet installation adhesive with a calculated VOC of 0 g/1. By the end of February, 1991, eight
manufacturers reported they had developed solvent free low VOC emission carpet installation adhesives. At the
National Association of Floor Covering Distributors Convention, held May 5-8, 1991, fourteen of the fifteen
carpet installation adhesive manufacturers who had booths displayed a low VOC emission carpet installation
adhesive or a line of low VOC emission products. A survey was taken in February, 1991, asking
manufacturers to report on the range of calculated VOCs in the products they were making by product type -
current formulas versus new generation formulas. The responses ranged from 40 g/1 to 150 g/1 on current
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formula lines and from 0 gA to 20 gA on new generation lines. However, no data on the relationship between
these calculated values to TVOC emission rates from carpet installation adhesives have been established.
The data developed from the Carpet Installation Adhesive Testing Program will provide the Carpet
Policy Dialogue Group, industry, regulatory agencies, and the interested public with additional information to
assess TVOC decay curve emission characteristics of carpet installation adhesives. With future testing, it could
be determined whether there is sufficient variability of TVOC emissions across carpet installation adhesives to
warrant communication of TVOC information on individual carpet installation adhesives product classifications
and grades to the interested consumer.
3.2. Study Objectives
The overall objective of the Carpet Installation Adhesive Testing Program is to characterize
quantitatively die decay curve characteristics of a sample or samples from each of the five carpet installation
adhesive product classifications currently in commerce. The program will indicate TVOC emissions of the five
carpet installation adhesive product types currently in commerce. The program will not provide data on the
distribution of TVOC emissions across the universe of carpet installation adhesive product types.
3.3. Scope and Structure of Study
3.3.1. Carpet inytpllflfton adhesive product type selection criteria
Five carpet installation adhesive product classifications (approximate carpet installation adhesive market
percentages are provided in parentheses) are currently in commerce: multipurpose (75%), pressure sensitive
(17%), vinyl backed (5%), pad cement (2%) and seam sealer (1%).
Multipurpose carpet installation adhesives are formulated through a combination of one of two mineral
spirits and VM&P (Varnish Makers and Painters) Naptha, which are used to dissolve tackifing resins. In
addition, methanol and ethylene glycol are used for freeze-thaw stability, a required performance property.
Because of the cost, methanol is the more commonly used anti-freeze and it is very unlikely that the two
ingredients would be used in conjunction with each other. These solvents contribute 95-99% of the calculated
VOCs in multipurpose carpet installation adhesives. The base solvent used in formulating multipurpose carpet
installation adhesives will serve as a grouping variable for Phase I sample selection and testing. In other words,
testing for multipurpose carpet installation adhesives will be based on the type of solvent and freeze-thaw
additive used. Further, two grades of mineral spirits, Regular and Rule 66 (differentiated by aromatic content),
are used in the industry. Samples will be collected from products manufactured with each of these mineral
spirit grades. Since solvent free multipurpose carpet installation adhesives have recently been introduced to the
market, these products will also be included in Phase I of the testing program.
3.3.2. Sample collection and test method
A list of all products made by each of the manufacturers participating in the testing program will be
compiled by the Adhesive and Sealant Council, Inc. Random selection of samples within each product type will
be made by representatives of the National Association of Floor Covering Distributors and/or The Adhesive and
Sealant Council, Inc. Adhesives will be purchased directly from distributors by an independent contractor. The
method of sample transport to the laboratory, and TVOC analysis is described in Attachment H-l. This method
will be used throughout the Carpet Installation Adhesive Testing Program.
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3.3.3. Study design sampling mfl{rre ffrr methodology development
Table 1 shows the five product classifications to be sampled and the number of carpet installation
adhesive samples from each carpet installation adhesive product classification to be collected and analyzed by
the methods described in section 3.3.2. Four samples will be used in the Preliminary Study for establishing
methodology for future testing. Fifteen samples will be analyzed in the Phase I study. For five of the eight
products studied in Phase I, an additional sample(s) of the similar product type manufactured by a different
company will also be collected to obtain data on product variability. Selection of the five products to be
additionally sampled will be determined upon evaluation of the results of preliminary testing. These additional
samples are included in the fifteen samples. The number of samples to be collected in Phase II testing will be
determined upon the completion and evaluation of Phase I testing.
Additional quality assurance (QA/QC) samples (e.g., laboratory duplicate samples) numbering about
10% of the samples tested will be taken in accordance with standard data quality procedures of the U.S. EPA.
3.4. Data Reporting and Evaluation
The data analysis will follow the lines of the objectives defined in section 3.2.
3.4.1. Statistical analysis
Four samples will be evaluated in the Preliminary Study to establish a sample application technique and
to determine the appropriate sampling time points for use in Phase I testing. The testing laboratory will
establish the reproducibility of the test protocol in accordance with accepted good analytical laboratory
procedures as an inherent part of their method development.
Using the protocol established by the Preliminary Study, fifteen samples will be evaluated in Phase I
(Table 1). Statistical analysis of the Phase I data will be achieved by evaluating the results of the laboratory QC
samples and the additional samples collected from five of the eight product groupings. These additional samples
will provide information to assess production variability within a product classification.
The analysis will include evaluation of the decay curve for each sample and the degree of correlation of
each respective additional/laboratory QC sample. This analysis scheme provides the minimum data necessary
for statistical evaluation.
3.4.2. Data presentation
Data from the testing program will be depicted graphically to show the TVOC decay curve for each
product classification across the appropriate number (determined in the Preliminary Study) of measured time
points. An evaluation of the applicability of a standard time point(s) for TVOC measurement will be made from
this data presentation.
In a second data display, five data points will represent the average value for each carpet installation
adhesive product classification studied in the Carpet Installation Adhesive Testing Program. Individual data will
be reported in an appendix to the final report. Company names will be blinded to protect the identity of
individual manufacturers.
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TABLE 1.
SAMPLING MATRIX OF CARPET INSTALLATION ADHESIVE
PRODUCT CLASSIFICATIONS
Carpet Installation
Adhesive Product Types
No. of
Sampled
Products
No. of
Additional
Samples
Total
No.of
Samples
Preliminary Study
Mineral spirits multipurpose
VM&P Naptha multipurpose
Solvent free multipurpose
Pressure sensitive
Total
0
0
0
Q
Multipurpose:
Methanol/Mineral Spirits Regular
Methanol/Mineral Spirits Rule 66
MethanoI/VM&P Naptha
Ethylene Glycol/Mineral Spirits Regular
Ethylene Glycol/Mineral Spirits Rule 66
Ethylene Glycol/VM&P Naptha
Solvent Free
Pressure Sensitive
Total
1
1
1
1
1
1
2
2
10
15
Phase II (Number of Samples to be Determined)
Vinyl Backed
Pad Cement
Seam Sealer
Selection of the five additional samples to be collected in Phase 1 testing will be determined upon evaluation of the
results of the Preliminary Study.
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3.4.3. Initial program evaluation
The data collected in each phase of the testing program will be submitted to EPA for review as soon as
each data set becomes available. Thus, an initial evaluation of preliminary data, two independent evaluations of
the results of Phase I and Phase n testing, and an overall evaluation on the combined results will be conducted.
EPA will evaluate the results of the Carpet Installation Adhesive Testing Program in terms of analytical results
and conclusions, and will determine the appropriate characterization of carpet installation adhesive product
classification emissions factors. EPA will use this technical evaluation to determine the need for possible
follow-on activities. This evaluation will also judge the extent to which the decay curve data collected in this
testing program and appropriate follow-on measures, if required, have met the Federal Register charter.
Among the issues to be considered is whether further experimental data are necessary to address the objectives
of the Federal Register notice. Details of other follow-on activities are described in sections 4. 1 through 4.3.
3.4.4. Public study report
The Floor Covering Adhesive Manufacturers Committee will provide a full report on the Carpet
Installation Adhesive Testing Program to the U.S. EPA. The document will include: TVOC data for each
carpet installation adhesive product classification tested, including the decay curve characteristics and an
assessment of a standard TVOC measurement time point(s) associated with each adhesive type, a description and
results of the statistical analysis and graphical presentation(s) of the data, discussion of the study findings, and a
laboratory report on field/laboratory quality assurance aspects of the study. The report may also contain a
perspective about the relative contribution from various carpet installation adhesive types to the total VOC
loading in the indoor environment. The EPA will make this information available to the interested public
through various mechanisms, including a notice of availability in the Federal Register.
3.5. Independent Contractors and Data Quality Standards
The Floor Covering Adhesive Manufacturers Committee represents 16 carpet installation adhesive
manufacturers. It is estimated that these companies manufacture approximately 95% of all carpet installation
adhesives sold in the United States. The Floor Covering Adhesive Manufacturers Committee will sponsor the
testing program and bears full responsibility for rigid scientific constructs. The Floor Covering Adhesive
Manufacturers Committee will obtain the necessary permission and legal clearances to permit collection of
samples at its member's distributors, in accordance with the study protocol.
To assure accuracy of test results and to minimim conflict of interest, an independent laboratory will be
retained to conduct product testing. The laboratory will be selected on the basis of its ability to fulfill the
proposed protocol for sampling and analysis and documented assurance that testing will be conducted in
accordance with good laboratory practices and standard U.S. EPA guidance for QA/QC. The protocol will
include provisions for using only appropriately trained personnel hired by the laboratory to perform sample
collection and transport.
In addition to an experimental study protocol, a Quality Assurance Project Plan specific to this Carpet
Installation Adhesive Testing Program will be prepared following EPA Office of Toxic Substances (EPA/OTS)
guidance. All QA/QC evaluations will be documented in this plan, which must be signed by representatives of
the Floor Covering Adhesives Manufacturers Committee and EPA prior to the commencement of testing. All
QA/QC results will be included in the study final report. The extent to which the results meet the defined data
quality objectives of the testing program will also be addressed in the report.
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The Floor Covering Adhesive Manufacturers Committee intends to initiate product testing in July,
1991, with a view to generating a report on Phase I in the Fall of 1991. The U.S. EPA will provide technical
counsel, as it does on other voluntary testing agreements, to ensure that data quality objectives are met in the
Carpet Installation Adhesive Testing Program.
It is understood by all parties to this agreement that the Floor Covering Adhesive Manufacturers
Committee will fulfill the voluntary program commitment described herein on a cost-effective basis. The Floor
Covering Adhesive Manufacturers Committee has sufficient budgetary resources to support the Preliminary
Study. Funds to support Phase I and Phase n of the testing program will be solicited upon the completion and
evaluation of preliminary testing. However, as detailed implementation plans are developed, it should be
understood that modifications may be made not only on technical grounds, but also to meet evolving cost
estimates.
4.0. FOLLOW-ON ACTIVITIES
During the balance of the dialogue year, it is the intent of the Floor Covering Adhesive Manufacturers
Committee to work with the U.S. EPA, other experts, and the Carpet Policy Dialogue Group, along with its
various working subgroups, to expedite implementation of the two-phased program outlined in section 1.2. The
Floor Covering Adhesive Manufacturers Committee will continue to report to the Plenary on their progress to
reach these objectives.
4.1. Future Activities
To the extent that further development of subsequent phases of the Floor Covering Adhesive
Manufacturers Committee Testing Program is dependent upon information obtained from the study described in
this document, follow-on activities are not fully detailed in this consensus statement. They are mentioned here
to describe the Floor Covering Adhesive Manufacturers Committee's commitment to respond to the Federal
Register notice. The selections, specific direction and features of follow-on activities will be developed in
consultation between EPA and the Floor Covering Adhesive Manufacturers Committee.
4.1.1. Annual industry report
The Floor Covering Adhesive Manufacturers Committee will generate an annual, aggregate history of
carpet installation adhesive industry product type sales performance for at least three years. The data will be
derived from annual reporting on percentage of sales by product classification. These data will be used to
reveal trends over time relative to the overall industry-wide profile and, in future, to product types. The trend
analysis will evaluate the success of the carpet installation adhesive industry in reducing TVOC levels by
documenting increasing sales of lower emission products.
4.1.2. Testing follow-up activities
The Floor Covering Adhesive Manufacturers Committee, in consultation with EPA, will devise a
program to motivate producers to institute voluntary indoor air quality assurance measures with respect to their
carpet installation adhesive products. It will, at a minimum, include the development and submission to the
Floor Covering Adhesive Manufacturers Committee of TVOC emission rate data on product types by
companies. This information would enable the Floor Covering Adhesive Manufacturers Committee to pursue
H-9
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the trend analysis for typical carpet installation adhesives as described above and to take voluntary actions for
improvement or remedy of "outlier products" with member manufacturers.
The Floor Covering Adhesive Manufacturers Committee will also conduct a study to determine if a
correlation can be achieved between calculated VOCs and emission testing measurements.
4.1.3.
The Floor Covering Adhesive Manufacturers Committee, in cooperation with EPA, will conduct a
consumer information program to provide their customers with appropriate information on TVOC emissions
from carpet installation adhesives. Depending on the conclusions to be drawn from the testing described in
section 3, this information program may include product-by-product numeric information on TVOC levels or, if
appropriate, more generic information from the annual aggregate analyses. The consumer information program
will ensure that carpet installation adhesive TVOC emissions are placed in an appropriate context with other
indoor air pollution sources.
4.2. Information Repository
Reports on studies undertaken under the aegis of the Carpet Policy Dialogue will be provided to the
U.S. EPA, which will maintain an on-going public file of this information in its public data docket facility.
This permanent repository of information will be readily available to the interested public and will serve as the
reporting place for the proposed annual aggregate/trend analysis and public communication products.
4.3. Memorandum of Understanding
To give shape and substance to the testing program and the EPA objective to attain commitments to
conduct voluntary product testing for TVOC emissions, the Floor Covering Adhesive Manufacturers Committee
and the U.S. EPA will enter into a memorandum of understanding at or before the close of the dialogue
process. This MOU will incorporate basic elements of this consensus statement and other procedural
arrangements common for voluntary testing agreements in the Office of Toxic Substances. The MOU will be
made public through a Federal Register notice. The document will be submitted for signature by the EPA and
all members of the Committee.
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APPENDIX I
Memorandum of Understanding Between
the Carpet and Rug Institute and
the U.S. Environmental Protection Agency
-------
MEMORANDUM OF UNDERSTATING
between the
Carpet and Rug Institute
and the
U.S. Environmental Protection Agency
May 22, 1991
-------
MEMORANDUM OF UNDERSTANDING
A. BACKGROUND
The EPA initiated a dialogue process in April, 1990, to
undertake certain actions with respect to reducing emissions
from carpet. One aspect is to develop a program for the
voluntary testing of, and collection of data on, total volatile
organic compound (TVOC) emissions from carpet. See "Carpet:
Response to Citizens' Petition," 55 FR 17,404 (April 24, 1990)
and "Carpet Emissions Reduction; Policy Dialogue," 55 FR 31,640
(August 3, 1990).
As part of the dialogue process, the Carpet Policy
Dialogue Group reached a consensus agreement (February 28,
1991) on the Carpet and Rug Institute Consensus Statement:
Testing Program for Carpet Products. In reaching this
agreement the Carpet Dialogue Group indicated to its sponsor
(EPA) that the testing program described in the Consensus
Statement could provide the basis for a Memorandum of
Understanding to initiate voluntary action(s) by industry in
response to the charter set by EPA in the Federal Register
notices. This Consensus Statement describing the testing
program for carpet products with Attachments A and B is affixed
(Exhibit I).
B. PURPOSE
The CRI and EPA are entering into this Memorandum of
Understanding for the purpose of initiating the provisions and
follow-up expectations as stated within the context of the
above mentioned Carpet Dialogue Consensus Statement and for
providing for the product testing and reporting of data
developed from the Carpet Testing Program as outlined therein.
C. SUBSTANCE OF THE AGREEMENT
This Memorandum of Understanding formally establishes a
framework in which a voluntary program response for actions
described in the Federal Register notices noted above can be
fulfilled. Therefore, CRI and EPA enter into the following
understandings:
M
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1. Testing and Data Development
The CRI shall take responsibility for and coordinate
the testing and data development provided for in the
Consensus Statement, in accordance with the procedures
described within and the attachments affixed thereto, and
with due consideration for the following provisions:
a. Quality Assurance
The U.S. EPA order 5360.I1 mandates that
"quality assurance is embedded in all data
collection undertaken by or for the Agency." In
meeting this requirement, the Office of Toxic
Substances (OTS) requires the preparation of a
Quality Assurance Project Plan (QAPjP) which must be
submitted to and approved by EPA for use during the
testing project operations outlined in the Consensus
Statement. Detailed guidance is provided on the
preparation of the QAPjP in the affixed document:
"Office of Toxic Substances Guidance Document for
the Preparation of Quality Assurance Project Plans
for Industry Studies" (Exhibit II).
b. Protocol Changes
Any changes, modifications, or amendments to
the testing program described within the Consensus
Statement and its attachments shall be brought to
the attention of EPA by CRI and documented in the
record. Upon notification, both parties to this
agreement shall develop an alternate approach to
fulfill the needs and requirements of the Carpet
Testing Program. The parties shall jointly agree on
the alternate approach and a statement of such
agreement shall be entered into the record.
c. Data Development
The test results will be developed into a
report(s) and submitted to EPA as described in the
Consensus Statement and in accordance with the
provisions described below (see Data Submission).
1 USEPA. 1984. U.S. Environmental Protection Agency. Policy and program requirements to implement the
mandatory quality assurance program. Washington, DC: Office of Administration and Resource Management, USEPA.
EPA Order 5360.1.
1-2
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2. Confidentiality
The testing, data development, and data reporting
shall be conducted in accordance with the confidentiality
provisions of the Corsensus Statement and EPA shall
maintain the protections afforded in such confidentiality
provisions.
a. Confidential Business Information (CBI)
Information submitted to EPA under provisions
of the Toxic Substances Control Act (TSCA), in
support of TSCA, or as FYI under the terms of a
voluntary testing agreement is subject to the
provisions of Section 14 of TSCA and to EPA's
Regulations on the Confidentiality of Business
Information. All responses/correspondence will be
placed in the OTS public files unless confident-
iality is claimed in accordance with the procedures
outlined in Exhibit III, entitled: "Support
Information for Confidentiality Claims." Additional
information about confidentiality claims can be
found in 40 CFR Chapter 1, Section 2.203 et seq, and
41 FR 36902, September 1, 1976 as amended at 43 FR
40000, September 8, 1978 and 50 FR 51661, December
8, 1985. In the event that a claim for
confidentiality is made on all or part of the
provided information, said information will only be
released by the EPA to the extent, and by means of
the procedures, set forth in the cited regulations.
Requests for confidentiality should be addressed to
U.S. Environmental Protection Agency, Office of
Toxic Substances, Document Processing Center (TS-
790), 401 M Street S.W., Washington DC, 20460 (Attn:
Frank Caesar, Carpet Emissions Administrative
Record).
b. Data Submission
The CRI shall submit a final report on the
Carpet Testing Program as described in section 3.4.4
of the Consensus Statement and in accordance with
the QAPjAP. A cover letter along with two (2)
copies shall be submitted for public access to the
U.S. Environmental Protection Agency, Office of
Toxic Substances, Information Management Office (TS-
793), 401 M Street S.W., Washington DC, 20460, Attn:
Lynn Marcus, Carpet Emissions Administrative Record.
If the test results contain Confidential Business
Information (CBI) the package must contain the cover
letter, the original submitted in accordance with
the Consensus Statement and two (2) copies of the
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CBI study results, and three copies of a sanitized
version appropriate for public access. CBI
submittals shall be sent to the U.S. Environmental
Protection Agency, Office of Toxic Substances,
Document Control Office (TS-790), 401 M Street S.W.,
Washington DC, 20460, Attn: Lynn Marcus, Carpet
Emissions Administrative Record.
3. Consultation and Follow-on Activities
The parties to this Memorandum of Understanding
recognize that Section 3,4.3 of the Consensus Statement
calls for a technical evaluation by EPA for the purpose of
determining the need for follow-on testing, if required.
The EPA reserves the right to assess the suitability of
the test program results submitted for this evaluation to
assure that EPA has met the goals and concepts of the
Federal Register notice. Issues identified by EPA will be
discussed as follow-on activities in joint consultation by
the parties named below. Details of these matters will be
worked out by consent of both parties and could be the
subject of additional Memoranda of Understanding.
Elements described in Section 4 of the Consensus
Statement identify certain follow-on activities proposed
by CRI which would benefit by collaborative efforts
undertaken by both parties to this agreement. Therefore,
activities such as: 1) annual industry report, 2) quality
assurance product certification, and 3) public
communication, and 4) database information repository are
considered useful follow-on activities. To this extent
the CRI intends to pursue and report to EPA on progress in
these areas.
Should CRI have technical questions about provisions
of this Memorandum of Understanding, please contact
Charles M. Auer, Dir. Existing Chemicals Assessment
Division at (202)382-3442.
D. PLACEMENT OF RESPONSIBILITIES
Responsibility for completion of the CRI Carpet Testing
Program, CRI reporting activities, EPA technical evaluation of
the testing results, and inclusion of the final report into the
EPA Administrative Record as described in this Memorandum of
Understanding is placed with the President, Carpet and Rug
Institute, and the Director, Office of Toxic Substances, EPA.
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E. OTHER AGREEMENTS
Nothing in this Memorandum of Understanding precludes EPA
from any other steps it deems necessary to carry out any
applicable laws, regulations, or policies. These include
activities listed in the U.S. Code of Federal Regulations, and
the reduction of carpet emissions described in the Federal
Register notices cited above. Furthermore, this Memorandum of
Understanding does not preclude EPA from entering into separate
agreements with individual carpet manufacturers that are
presently not constituent members of the Carpet and Rug
Institute. It is understood that any such separate agreements
pertaining to the subject matter of this MOU will not contain
provisions less stringent or contrary to those terms and
conditions stipulated herein. Similarly, nothing precludes CRI
from entering into similar agreements with their contractors,
or constituent members for the purposes of conducting and
reporting testing, or similar agreements with other regulatory
Agencies.
F. NAME AND ADDRESS OF PARTIES
1. Carpet and Rug Institute
Box 2048, Holiday Avenue
Dalton, Georgia 30720
2. U.S. Environmental Protection Agency
Office of Toxic Substances
401 M Street, SW
Washington, DC 20460
1-5
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G. PERIOD OF AGREEMENT
This Memorandum of Understanding is entered into by the
Carpet and Rug Institute (CRI) and the U.S. Environmental
Protection Agency (EPA) as of this twenty-second da> of May,
1991.
For the Carpet and Rug Institute:
Ronald E. VanGelde^en
President
Carpet and Rug Institute
For the Environmental Protection Agency:
"M-jmuf*]
Martf. Greenwood
Director
Office of Toxic Substances
1-6
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ATTACHMENT 1-1
Federal Register: Carpet Policy Dialogue;
Memorandum of Understanding: Testing Program
for Carpet Products and Receipt of the Carpet
Policy Dialogue Interim Progress Report
-------
Federal Renter /Vol. 56. No. 154 / Friday. August 9, 1991 / Notices
IOPTS-001M; FRt-3933-1]
Carpet Policy Dialogue; Memorandum
of Understanding: Testing Program for
Carpet Products and Receipt of the
Carpet Policy Dialogue Interim
Progress Report
AGENCY: Environmental Protection
Agency (EPA).
ACTION; Notice of availability.
SUMMARY: EPA has entered into a
Memorandum of Understanding (MOU)
with the Carpet and Rug Institute (CRI)
for the purpose of initiating the
provisions stated within the context of
the Carpet Policy DialogueConsensus
Statement: Testing Program for Carpet
Products. The MOU provides for carpet
product testing for total volatile organic
compound emissions (TVOC) and
reporting of data as outlined- in the
testing program. EPA has received an
Interim Progress Report from the Carpet
Policy Dialogue describing activities
from August 21.1990 through April 10,
1991.
DATES: The MOU was entered into on
May 22,1991.
FOR FURTHER INFORMATION CONTACT.
The MOU and the Interim Progress
Report are available to the public in the
Carpet Emissions Administrative Record
located at the TSCA Public Docket
Office. This Administrative Record is
available for reviewing and copying
from 8 a.m. to noon and 1 p.m. to 4 p.m..
Monday through Friday, excluding legal
holidays al the foJburing address
Environmental Protection Agency, rm.
NE-G804.401M SU SV\L Washington.
DC 20460. Copies may be obtained from
the following address: Dave Kling,
Acting Director. Environmental
Assistance Division (TS-799). Office cf
Toxic Substances. Environmental
Protection Agency, 401 M St. SW.,
Washington. DC 20460. Telephone:
(202)554-1404, TDD: (202)554-0557, or
FAX {202)554-5603 (document requests
only). For further information on the
Carpet Policy Dialogue Project contact
Richard W. Leukroth, Jr., Carpet Policy
Dialogue Coordinator, Telephone:
(202)382-3832.
SUPPLEMENTARY INFORMATION:
On January 11, 1990, EPA received a
petition under section 21 of the Toxic
Substances Control Act fTSCA) seeking
regulatory action to address carpet
emission!. EPA denied the petition (55
FR 17404. April 24. 1990). In lien of the
section 21 proceedings, ERA convened
the Carpet Policy Dialogue on August 21.
1991, and set a different mission for the
group. EPA charged the dialogue to
work out the -details of voluntary
product testing program! mat report
TVOC emissions that off-gas from
carpet, carpet installation adhesives,
and carpet cushion products. In
addition, the Carpet Policy Dialogue was
asked to explore and, where possible.
reach agreement on a variety of issues
including: The sampling and analytical
methods for the voluntary product
testing for TVOCs, any additional
information needed, identification of
cost-effective process changes to reduce
TVOC emissions, information about
carpet installation practices, urtd to
provide the interested public with
information on TVOC emissions.
The Carpet Policy Dialogue formed
three working Subgroup* (Product
Testing, Process Engineering, and Public
Communications) to respond to the EPA
charter. The Carpet Policy Dialogue on
TVOC emissions is a nonregulatory
approach focusing on responsible care/
product stewardship through voluntary
actions on the part of industry. It
emphasizes pollution prevention,
exposure reduction, and addresses the
public desire for information that could
lead to consumer choice. The Carpel
Policy Dialogue is an example of how
government industry, public interest
groups, and the scientific community
can work together to resolve exposure
reduction and pollution prevention
issues, including those related to indoor
air exposures. Proposed testing
programs are developed during
Subgroup wcniskinam*' submitted to
the Carpet Policy Dialogue for the
benefit of a consensus process of review
and comment In reaching consensus
and accepting the carpet testing
program, the Carpet Policy Dialogue
indicates to its sponsor (EPA) that such
a statement can provide the basis for a
MOU to initiate voluntary action^ in
response to the charter set by EPA in the
Federal Register notices (55 FR 17404
and 55 FR 31640).
1-1-1
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Federal Kagistar / VoL Sfl. JUo. 154 / Friday. August fl. 13M / Notices
3gL3
II. Memorandum of Understanding
The EPAand CRI entered into the
MOU on May 22,1991. The MOU rigaed
by EPA and CKlfanaabV-establishes
framework a -which a voluntary
program response Cor Actions described
in the Federal Register natiaes noted
above can be fulfilled. It contains
provisions initiating the Carpet Testing
Program on TVOC emissions and
certain follow-on activities.
A. Carpet Testing Program
Under the terms and conditions of the
MOU. the CRI has voluntarily.agreed to
conduct product testing to determine
TVOC emissions factors from samples
of 25 representative carpet product
types. The objectives of the Carpet
Testing Program are to: (1) Study carpet
emissions decay curve data, {2J
characterize quantitatively the profile .of
TVOC emissions of carpet product types
currently in commerce, and (3) address
the question of TVOC emission
variability, or tiie lade thereof, across
carpet product types.
B. Participants
Placement of responsibilities lor the
actions described IB the MOU 1s with
the President .of (he Carpet and Rug
Institute and the Director of EPA's
Office ofToxic Substances.
m. Carpet Policy Dialogue - Interkn
Progress Report
In conjunction with the public
outreach activities of the Carpet Policy
Dialogue an Interim Progress Report was
submitted to EPA. This report reviews
activities and accomplishments of the
Carpet Policy Dialogue from August 21.
1990 through April 10,1991. The report is
a product of
-------
APPENDIX J
Memorandum of Understanding Between
the Carpet Cushion Council and the
U.S. Environmental Protection Agency
-------
MEMORANDUM OF UNDERSTANDING
between the
Carpet Cushion Council
and the
U.S. Environmental Protection Agency
September 26, 1991
-------
MEMORANDUM OF UNDERSTANDING
I. BACKGROUND
The Environmental Protection Agency (EPA) initiated a
dialogue process in April, 1990, to undertake certain actions
with respect to reducing emissions from carpet and associated
products of carpet flooring systems. One part of the dialogue
process is to develop a program for the voluntary testing of
and collection of data on total volatile organic compound
(TVOC) emissions from carpet cushions. See "Carpet: Response
to Citizens' Petition," 55 FR 17,404 (April 24, 1990) and
"Carpet Emissions Reduction; Policy Dialogue," 55 FR 31,640
(August 3, 1990). The objective of data collection is to
provide basic information of TVOC emissions and to provide
information to assess emission control feasibility.
On June 28, 1991, the Carpet Policy Dialogue Group, a
group of industry, public and governmental representatives,
agreed in principal to "The Carpet Cushion Council consensus
Statement: Testing Program for Carpet Cushions". In this
agreement the Carpet Policy Dialogue Group indicated to its
sponsor, the EPA, that the testing program described in the
Carpet Cushion Consensus Statement could provide the basis for
a Memorandum of Understanding to initiate voluntary action(s)
by industry in response to the charter set by EPA in the above-
mentioned Federal Register notices. The Carpet Cushion Council
Consensus Statement describing the testing program for carpet
cushion products is attached (Exhibit I).
The Carpet Policy Dialogue Group also endorsed by
consensus the recommendations of the Process Engineering
Subgroup to define post-dialogue Carpet Cushion Council
sponsored activities that would be undertaken to understand the
sources of TVOC in carpet cushion and how to reduce the
magnitude of these sources. These activities are described in
more detail below.
II. PURPOSE
The Carpet Cushion Council (CCC), acting on behalf of the
carpet cushion industry, and EPA are entering into this
Memorandum of Understanding for the purpose of initiating the
provisions and follow-up expectations as stated within the
context of the above mentioned {Carpet Policy Dialogue) Carpet
Cushion Council Consensus Statement and for providing for the
product testing and reporting of data developed from the Carpet
Cushion Testing Program as outlined therein. This Memorandum
of Understanding is also intended to formalize the consensus
J-i
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decisions of the Carpet Policy Dialogue related to recommended
post-dialogue studies intended to identify carpet cushion TVOC
sources and methods of reducing their magnitude.
III. SUBSTANCE OF THE AGREEMENT
This Memorandum of Understanding (MOU) formally
establishes a framework for a voluntary program to respond to
actions described in the Federal Register notices mentioned
above. Thus, CCC, on behalf of the carpet cushion industry,
and EPA enter into the following understandings:
A. Testing and Data Development
The CCC shall take responsibility for and coordinate
the testing and data development of Phase I and Phase II
as provided for in the Consensus Statement, in accordance
with the procedures described within and the attachments
affixed thereto, and with due consideration for the
following provisions:
1. Quality Assurance
The U.S. EPA order 5360.I1 mandates that
"quality assurance is embedded in all data
collection undertaken by or for the Agency". In
meeting this requirement, the Office of Toxic
Substances (OTS) requires the preparation of a
Quality Assurance Project Plan (QAPjP) which must be
submitted to and approved by EPA for use during the
testing project operations outlined in the Consensus
Statement. Detailed guidance is provided on the
preparation of the QAPjP in the attached document:
"Office of Toxic Substances Guidance Document for
the Preparation of Quality Assurance Project Plans
for industry Studies" (Exhibit II).
2. Protocol Changes
Any changes, modifications, or amendments to
the testing program described within the Consensus
Statement and its attachments shall be brought to
the attention of EPA by CCC and documented in the
record. Upon notification, both parties to this
1 USEPA. 1984. U.S. Environmental Protection Agency. Policy
and program requirements to implement the mandatory quality
assurance program. Washington, DC: Office of Administration and
Resource Management, USEPA. EPA Order 5360.1.
J-2
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agreement shall develop an alternate approach to
fulfill the needs and requirements of the Carpet
Cushion Testing Program. The parties shall jointly
agree on the alternate approach and a statement of
such agreement shall be entered into the record.
3. Data Development
The test results will be developed into
report(s) and submitted to EPA as described in the
Consensus Statement and in accordance with the
provisions described below (see Data Submission) .
The CCC has committed to initiating product testing
in the late Summer 1991, with a view to generating
preliminary results in the Fall of 1991. Phase II
will be conducted as resources can be made
available, but within a one year period.
4. Testing Study Results
The CCC shall submit a final report on Phase I
and Phase II testing as they become available but
not longer than one year from the date of signature
of this Memorandum of Understanding.
The testing, data development, and data
reporting may be conducted in accordance with the
confidentiality provisions of the Consensus
Statement and EPA shall maintain the protections
afforded in such confidentiality provisions.
a. Confidential Business Information (CBI)
Information submitted to EPA under
provisions of the Toxic Substances Control Act
(TSCA), in support of TSCA, or as FYI under the
terms of a voluntary testing agreement is
subject to the provisions of Section 14 of TSCA
and to EPA's Regulations on the Confidentiality
of Business Information. All responses and
correspondence will be placed in the OTS public
files unless confidentiality is claimed in
accordance with the procedures outlined in
Exhibit III, entitled: "Support Information
for Confidentiality Claims." Additional
information about confidentiality claims can be
found in 40 CFR Chapter 1, Section 2.203 et
seq. and 41 FR 36902, September 1, 1976 as
amended at 43 FR 40000, September 8, 1978 and
50 FR 51661, December 8, 1985. In the event
that a claim for confidentiality is made on all
or part of the provided information, said
information will only be released by the EPA to
J-3
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the extent, and by means of the procedures, set
forth in the cited regulations. Requests for
confidentiality should be addressed to U.S.
Environmental Protection Agency, Office of
Toxic Substances, Document Processing Center
(TS-790), 401 M Street S.W., Washington DC,
20460 (Attn: Frank Caesar, Carpet Emissions
Administrative Record).
b. Data Submission
The CCC shall submit a final report on
Phase I and Phase II of the Carpet Cushion
Testing Program as described in section 3.4.4
of the Consensus Statement and in accordance
with the QAPjP. A cover letter along with two
(2) copies shall be submitted for public access
to the U.S. Environmental Protection Agency,
Office of Toxic Substances, Information
Management Office (TS-793), 401 M Street S.W.,
Washington DC, 20460, Attn: Lynn Marcus, Carpet
Emissions Administrative Record. If the test
results contain Confidential Business
Information (CBI) the package must contain the
cover letter, the original submitted in
accordance with the Consensus Statement, and
two (2) copies of the CBI study results, and
three copies of a sanitized version appropriate
for public access. CBI submittals shall be
sent to the U.S. Environmental Protection
Agency, Office of Toxic Substances, Document
Control Office (TS-790), 401 M Street S.W.,
Washington DC, 20460, Attn: Lynn Marcus, Carpet
Emissions Administrative Record.
B. Carpet Cushion TVOC Source Reduction Study
1. Study Definition
The CCC shall take responsibility for and
coordinate the completion of a comprehensive study
which examines the manufacturing processes of each
of the five types of carpet cushions. These
manufacturing processes will be evaluated by task
forces of carpet cushion industry technical and
manufacturing personnel. Sources of carpet cushion
TVOCs will be identified in the comprehensive study.
Particular emphasis will be placed on summarizing
information on the contributions of raw materials to
carpet cushion TVOCs. Potential means by which
carpet cushion TVOCs can be reduced will be
J-4
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identified. The study will include, but is not
limited to, an evaluation of the extent to which the
following potential actions may reduce carpet
cushion TVOCs in terms of TVOC reductions and cost
effectiveness for each of the five carpet cushion
manufacturing processes:
(1) Replacement of TVOC generating chemicals
and raw materials with lower TVOC
substitutes;
(2) Changes in the operating conditions,
procedures and equipment of the
manufacturing process;
(3) Changes in management practices related to
the manufacturing processes (eg. monitoring
of raw material TVOC levels);
(4) Enhancement or initiation of recycle or
reuse programs which reduce TVOC sources;
(5) Improved control/treatment technologies
which could lower carpet cushion TVOCs at
the manufacturing site (eg. air stripping
of cushions).
A listing of past actions taken by carpet cushion
manufacturers that have reduced TVOC emissions from
carpet cushion products can be included in the study
to provide an historical perspective on this subject
for this industry.
2. Study Results
The CCC shall submit a final report on the
Carpet Cushion TVOC Source Reduction Study within
one year of the date of signature of this Memorandum
of Understanding.
a. Confidential Business Information (CBI)
Information submitted to EPA under
provisions of the Toxic Substances Control Act
(TSCA), in support of TSCA, or as FYI under the
terms of a voluntary agreement is subject to
the provisions of Section 14 of TSCA and to
EPA's Regulations on the Confidentiality of
Business Information. All responses and
correspondences will be placed in the OTS
public files unless confidentiality is claimed
in accordance with the procedures outlined in
Exhibit III, entitled: "Support Information
for Confidentiality Claims." Additional
information about confidentiality claims can be
J-5
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found in 40 CFR Chapter 1, Section 2.203 et
seq. and 41 FR 36902, September 1, 1976 as
amended at 43 FR 40000, September 8, 1978 and
50 FR 51661, December 8, 1985, In the event
that a claim for confidentiality is made on all
or part of the provided information, said
information will only be released by the EPA to
the extent, and by means of the procedures, set
forth in the cited regulations. Requests for
confidentiality should be addressed to U.S.
Environmental Protection Agency, Office of
Toxic Substances, Document Processing Center
(TS-790), 401 M Street S.W., Washington DC,
20460 (Attn: Frank Caesar, Carpet Emissions
Administrative Record).
b. Study Submission
A cover letter along with two (2) copies
shall be submitted for public access to the
U.S. Environmental Protection Agency, Office of
Toxic Substances, Information Management Office
(TS-793), 401 M Street S.W., Washington DC,
20460, Attn: Lynn Marcus, Carpet Emissions
Administrative Record. If the study contains
Confidential Business Information (CBI) the
package must contain the cover letter, the
original and two (2) copies of the CBI study
results, and three copies of a sanitized
version appropriate for public access. CBI
submittals shall be sent to the U.S.
Environmental Protection Agency, Office of
Toxic Substances, Document Control Office (TS-
790), 401 M Street S.W., Washington DC, 20460,
Attn: Lynn Marcus, Carpet Emissions
Administrative Record.
C. Consultation and Follow-on Activities
1) Carpet Cushion Testing Program
The parties to this Memorandum of Understanding
recognize that Section 3.4.3 of the Carpet Cushion Council
Consensus Statement calls for a technical evaluation of
Phase I and Phase II data by EPA for the purpose of
determining the need for follow-on testing, if required.
The EPA reserves the right to assess the suitability of
the test program results submitted for this evaluation to
assure that EPA has net the goals and concepts of the
Federal Register notice. Issues identified by EPA will be
discussed as follow-on activities in joint consultation by
J-6
-------
the parties named below or their representatives. Details
of these matters will be worked out by consent of both
parties and could be the subject of additional Memoranda
of Understanding.
Elements described in Section 4 of the Consensus
Statement identify follow-on activities proposed by ccc
that would benefit by collaborative efforts undertaken by
both parties to this agreement. Therefore, activities
such as: 1) the industry-wide study, 2) the annual
industry report, 3) the quality assurance product
certification program, 4) public communication, and 5) the
database information repository are considered useful
follow-on activities. To this extent the CCC intends to
pursue and report to EPA on progress in these areas.
2) Carpet Cushion TVOC Source Reduction Study
In order to insure efficient consultation and
cooperation of the organizations' participating in this
MOU, the Carpet Cushion Council will within two months of
signing the MOU, submit to EPA a workplan describing how
the Carpet Cushions TVOC Source Reduction Study will be
developed. The workplan will identify:
(1) the individuals developing the study and
their qualifications;
(2) What issues the study will address;
(3) A draft table of contents of the study; and
(4) A schedule for completing the study.
EPA will respond to CCC with comments on the workplan. If
needed, the workplan will be revised accordingly to
accommodate the interests of CCC and EPA.
Should CCC have technical questions about provisions
of this Memorandum of Understanding, please contact the
Director of the Existing Chemicals Assessment Division,
Charles M. Auer, at (202)382-3442.
IV. PLACEMENT OF RESPONSIBILITIES
Responsibility for completion of the CCC carpet Cushion
Testing Program, CCC reporting activities, EPA technical
evaluation of the testing results, Carpet Cushion TVOC Source
Reduction Study, and inclusion of the final reports into the
EPA Administrative Record as described in this Memorandum of
Understanding is placed with the Executive Director, Carpet
Cushion Council, and the Director, Office of Toxic Substances,
EPA.
J-7
-------
V. OTHER AGREEMENTS
Nothing in this Memorandum of Understanding precludes EPA
from any other steps it deems necessary to carry out any
applicable laws, regulations, or policies. These include
activities listed in the U.S. Code of Federal Regulations, and
the reduction of carpet emissions described in the Federal
Register notices cited above. Furthermore, this Memorandum of
Understanding does not preclude EPA from entering into separate
agreements with individual carpet cushion manufacturers that
are not participating in the Carpet Cushion Council TVOC
Testing Program referenced in III. C. above and are not
cosignatories to this MOU. It is understood that any such
separate agreements pertaining to the subject matter of this
MOU will not contain provisions less stringent or contrary to
those terms and conditions stipulated herein. Similarly,
nothing precludes CCC from entering into similar agreements
with their contractors, or constituent members for the purposes
of conducting and reporting testing, or similar agreements with
other regulatory Agencies.
VI. NAME AND ADDRESS OF PARTIES
A. Carpet Cushion Council
P.O. Box 546
Riverside, CT 06878
B. U.S. Environmental Protection Agency
Office of Toxic Substances
401 M Street, SW
Washington, DC 20460
VII. PERIOD OF AGREEMENT
This Memorandum of Understanding is entered into by the
Carpet Cushion Council (CCC) and the U.S. Environmental
Protection Agency (EPA) as of this twenty-sixth day of
September, 1991.
J-8
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Carpet Cushion Industry Manufacturing Companies:
Bonda Foam .Company
Water >/)alleyO MS 38965
Steal:
(r/us CTaft Industrial Products, Inc,
Yatferford, NY 12188t-/
John Uchmanovicz
Grain Industries
Fort- Smith* AR 72906
Michael A. Ricciardi
Custom Coating, Inc.
Unlfcon, OA 30720
ponjUd
win , Sr .
Dlxle\ Manufacturing Company
Notfolk, VA 23510
JoNR>S.;,14itchell
Dur-a 'uridercushions, Ltd
Montreal/\puebec CANADA H4T 1M1
David/jBeal
E.R. Carpenter Co.
Richmond, VA 23261
Ronald A'. Hingst
no.
Fairmont Corporation^
Chicago, IL 60609
Gerald A. Bader. .
Flexible Foam Products Co.
Spencerville, OH 45887
Richard. Whit ling
Foamex, L.P.
Eddystone, PA 19022
Robert J. Hay
FOBS Manufacturing'1, Inc.
Hampton, NH
Future Foam, Inc.
Council Bluffs, IA 51503
Robert A. Heller.
«>
General Folt Industries, Inc.
Philadelphia, PA 19137
Michel V. llivera
General Foam Corporation
Paramus, NJ 07652
Jack Meyerhardt
Great Western Carpet Cushion Co.
Orange, CA 92665
iddio
G.S. Industries, me,
Newton, NC 28658
G.J
Hi Life Products Inc.
Chino, CA 91708
»11
lory Springs Mfg.
Hickory, NC 28603
fist
Company
HoDDa/Donded Fibers
Lynchburg, VA 24503
Hooten s
f<=?£y,
MP/7a Ifcggett & Plafvt Company
Fort Worth, TX 76113
Larry R. Heppe
J-9
-------
Milliken-Sonuner x ~
Simpsonville. SC 29681
Shn
Jam Cushion Mfg. Co.
landfills, TX 76182
No-Mu>7fi&Qrporatlon, Inc.
Jacksonville, FL 32216
Charles Mussallem
N4>rth Carolina Foam
\irv, NC 27030
J.d/ Earnhardt
r.
Ol^Vnplc Products
Greensboro, NC 27406
R. Bacaes
PermaFirra Pad Company
Los Angeles, CA 90013
Burton Sunkin
Reliance Upholstery Supply Co. Inc.
Qardena, CA 90248
Frank.H. Huttner
For the Carpet Cushion Council:
Scottdel, Inc.
Swanton, OH 43558
Schor$£h
*~ f -, ^^j-~»-»
Shaw IndUitries,
Dalton, GA 30722-212B
Jr.
Carpet Pad C
Carson, CA 90746
Charles ~W. Morgan
-*-t^_-^
t fl 14^/fc^«A&4yM
i^JC- A - \(j^^-^
ponge CushionV Inc.
Morris, IL 60450
Frank
s~ y?V,
/ Wat^rville TG Inc.
V-MiTsslssauga, Ontario L4W 1P1 CAM
Jean A. Aubii
Woodbridge Foam Fabricating, Inc
Chattanooga, TN 37401
Ronald A. Lessa
William'H. Oler
Executive Director
For the Environmental Protection Agency:
Mark A. Greenwood
Director
office of Toxic Substances
MO
-------
ATTACHMENT J-l
Federal Register: Carpet Policy Dialogue:
Memorandum of Understanding: Testing Program for
Carpet Cushion Products
-------
Federal Register / Vol. 56. No. 231 / Monday. December 2. 19B1 / Notices
61245
IOPTS-00114, FRL-4004-a)
Carpet Policy Dialogue; Memorandum
of Understanding: Testing Program for
Carpet Cushion Products
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Notice of availability.
SUMMAMrr EPA has entered into n
Memorandum of Understanding (MOU)
with the Carpet Cushion Council (CCC)
acting on behalf of the carpet cushion
industry for the purpose of initiating the
provisions stated within the context of
the Carpet Policy Dialogue - Consensus
Statement: Testing Program for Carpet
Cushion Products. The MOU provides
for carpet cushion product testing for
total volatile organic compound
emissions (TVOCJ and reporting of data
as outlined in the testing, program.
DATE& The MOU was catered into on
September 28,1981.
Km FURTHER INFORMATION CONTACT:
Dave Kling, Acting Director.
Environmental Assistance Division fTS-
799). Office of Toxic Substances.
Environmental Protection Agency. 401M
St.. SW.. Washington. DC 20480.
Telephone: (202) 554-1404, TDD: (202)
554-0557. or FAX (202) 554-5603
(document reoueste onM. For
{['formation on the Carpet Policy
Dialogue Project contact Richard W.
L'iukroth. ]r.. Carpet Policy Dialogue
Coordinator. Telephone: (202) 260-3632.
Copies of the MOU may be obtained
from the Environmental Assistance
Division at the address listed above.
SUPPLEMENTARY INFORMATION:
I. Background
The Carpet Policy Dialogue (August
21.1990 to September 27,1991) was part
of the Agency's response to a petition
under section 21 of TSCA (55 FR17404;
53 FR 31640). EPA charged the dialogue
to work out the details of voluntary
product testing programs that report
1 VOC's that emit from carpet, carpet
installation adhesives. and carpet
cushion products. In addition, the Carpet
Policy Dialogue was asked to explore
nnd. where possible, reach agreement on
a variety of issues including: the
sampling and analytical methods for the
voluntary product testing for TVOC's.
any additional information needed.
identification of cost-effective process
i nanges to :educe TVOC emissions.
.-".formation about carpet installation
practices, and to provide the interested
f ublic with information on TVOC
emissions. The Carpet Policy Dialogue
formed three working Subgroups
I Product Testing. Process Engineering.
and Public Communications) to respond
to the EPA charter.
The Carpet Policy Dialogue on TVOC
emissions was a nonregulatory
approach focusing on product
stewardship through voluntary actions
on the part of industry. It emphasized
exposure reduction (pollution
prevention), and addressed the public
tiesire for information that could lead to
consumer choice. The Carpet Policy
Dialogue exemplified how government,
industry, public interest groups, and the
scientific community can work together
to resolve exposure reduction and
pollution prevention issues, including
those related to indoor air exposures.
Proposed testing programs were
developed during Subgroup discussion
and submitted to the Carpet Policy
Dialogue for the benefit of a consensus
process of review and comment. In
reaching consensus and accepting the
carpet cushion testing program, the
Carpet Policy Dialogue indicated to its
sponsor (EPA) that such a statement can
provide the basis for a memorandum of
understanding to initiate voluntary
action(s) in response to the charter set
by EPA in the Federal Register notices
(55 FR 17404 and 55 FR 31640).
II. Memorandum of Understanding
The EPA and CCC entered into the
MOU on September 26,1991. The MOU
signed by EPA and CCC formally
establishes a framework in which a
voluntary program response for actions
described in the Federal Register notices
noted above can be fulfilled. It contains
provisions initiating the Carpet Cushion
Testing Program on TVOC emissions
and certain follow-on activities.
A. Carpet Cushion Testing Program
Under the terms and conditions of the
MOU. the CCC has voluntarily agreed to
conduct product testing to determine
TVOC emissions factors for the five
product types currently available in
commerce over the next 3 years. The
objectives of the Carpet Cushion Testing
Program are to: (1) Study carpet cushion
emissions decay characteristics. (2)
address the question of TVOC emission
variability, or the lack thereof, across
J-l
-------
G1246 Federal Register / Vol. 56. No. 231 / Monday, December 2. 1991 / Notices
carpet cushion product types, and (3)
Determine the ume point(s) for
neasur.ng TVOC emissions from the
five product types. Results from this
testing will be used in finalizing the
design of a follow-on industry-wide
study of a representative sample of
carpet cushion products.
B. Participants
Placement of responsibilities for the
actions described in the MOU is with
the Executive Director. Carpet Cushion
Council and the Director. Office of Toxic
Substances, EPA.
III. Administrative Record
The MOU is available to the public in
the Carpet Emissions Administrative
Record. This Administrative Record is
available for reviewing and copying in
the TSCA Public Ducket Office from 8
a.m. to noon and 1 p.m. to 4 p.m..
Monday through Friday, excluding legal
holidays. The TSCA Public Docket
Office is located at EPA Headquarters.
Rm. NE-G004. 401 M St.. SW..
Washington. DC 20460.
Dated: November 25.1991.
Mark A. Greenwood
Director. Office of Toxic Substances.
(FR Doc. 91-28825 Filed 11-29-41; 8:45 am]
mum COM MM-M-F
J-2
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APPENDIX K
Memorandum of Understanding Between the
Floor Covering Adhesive Manufacturers Committee
and the U.S. Environmental Protection Agency
-------
MEMORANDUM OF UNDERSTANDING
between the
Floor Covering Adhesive Manufacturers Committee
and the
U.S. Environmental Protection Agency
September 26, 1991
-------
MEMORANDUM OF UNDERSTANDING
A. BACKGROUND
The Environmental Protection Agency (EPA) initiated a
dialogue process in April, 1990, to undertake certain actions
with respect to reducing emissions from carpet and associated
products of carpet flooring systems. One aspect is to develop
a program for the voluntary testing of, and collection of data
on, total volatile organic compound (TVOC) emissions from
carpet installation adhesives. See "Carpet: Response to
Citizens' Petition," 55 FR 17,404 (April 24, 1990) and "Carpet
Emissions Reduction; Policy Dialogue,11 55 FR 31,640 (August 3,
1990).
As part of the dialogue process, the Carpet Policy
Dialogue Group reached a consensus agreement (June 28, 1991) on
the Floor Covering Adhesive Manufacturers Committee Consensus
Statement: Testing Program for Floor Covering Adhesives. In
reaching this agreement the Carpet Policy Dialogue Group
indicated to its sponsor (EPA) that the testing program
described in the Consensus statement could provide the basis
for a Memorandum of Understanding to initiate voluntary
action(s) by industry in response to the charter set by EPA in
the Federal Register notices. This Consensus Statement
describing the testing program for carpet installation
adhesives is affixed (Exhibit I).
B. PURPOSE
The Floor Covering Adhesive Manufacturers (FCAMC) and EPA
are entering into this Memorandum of Understanding for the
purpose of initiating the provisions and follow-up expectations
as stated within the context of the above mentioned Carpet
Policy Dialogue Consensus Statement and for providing for the
product testing and reporting of data developed from the Carpet
Installation Adhesive Testing Program as outlined therein.
C. SUBSTANCE OF THE AGREEMENT
This Memorandum of Understanding formally establishes a
framework in which a voluntary program response for actions
described in the Federal Register notices noted above can be
fulfilled. Therefore, FCAMC and EPA enter into the following
understandings:
K-l
-------
1. Preliminary Studies/Testing and Data Development
The FCAMC shall take responsibility for and
coordinate the testing and data development provided for
in the Consensus Statement, i.i accordance with the
procedures described within and the attachments affixed
thereto, and with due consideration for the following
provisions:
a. Quality Assurance
The U.S. EPA order 5360,I1 mandates that
"quality assurance is embedded in all data
collection undertaken by or for the Agency." In
meeting this requirement, the Office of Toxic
Substances (OTS) requires the preparation of a
Quality Assurance Project Plan (QAPjP) which must be
submitted to and approved by EPA for use during the
testing project operations outlined in the Consensus
Statement. Detailed guidance is provided on the
preparation of the QAPjP in the affixed document:
"Office of Toxic Substances Guidance Document for
the Preparation of Quality Assurance Project Plans
for Industry Studies" (Exhibit II).
b. Protocol Changes
Any changes, modifications, or amendments to
the testing program described within the Consensus
Statement and its attachments shall be brought to
the attention of EPA by FCAMC and documented in the
record. Upon notification, both parties to this
agreement shall develop an alternate approach to
fulfill the needs and requirements of the Floor
Covering Adhesives Testing Program. The parties
shall jointly agree on the alternate approach and a
statement of such agreement shall be entered into
the record.
c. Data Development
The test results will be developed into a
report(s) and submitted to EPA as described in the
Consensus Statement and in accordance with the
provisions described below (see Data Submission).
The FCAMC has committed to initiating product
1 USEPA. 1984. U.S. Environmental Protection Agency. Policy
and program requirements to implement the mandatory quality
assurance program. Washington, DC: Office of Administration and
Resource Management, USEPA. EPA Order 5360.1.
K-2
-------
testing in July, 1991, with a view to generating a
report on Phase I in the fall of 1991. Phase II
will be conducted as resources can be made
available, but within a year period from the date of
this MOU. Upon completion of EPA's review of Phase
I test results, EPA and FCMAC will jointly determine
the number and allocation of samples to be included
in Phase II testing. The agreed upon procedures
for Phase II testing shall be documented as an
addendum to this MOU and be placed in the Carpet
Admissions Administrative Record.
2. Confidentiality
The testing, data development, and data reporting
shall be conducted in accordance with the confidentiality
provisions of the Consensus Statement and EPA shall
maintain the protections afforded in such confidentiality
provisions.
a. Confidential Business Information (CBI)
Information submitted to EPA under provisions
of the Toxic Substances Control Act (TSCA), in
support of TSCA, or as FYI under the terms of a
voluntary testing agreement is subject to the
provisions of Section 14 of TSCA and to EPA's
Regulations on the Confidentiality of Business
Information. All responses/correspondence will be
placed in the OTS public files unless confident-
iality is claimed in accordance with the procedures
outlined in Exhibit III, entitled: "Support
Information for Confidentiality Claims." Additional
information about confidentiality claims can be
found in 40 CFR Chapter 1, Section 2.203 et sea, and
41 FR 36902, September 1, 1976 as amended at 43 FR
40000, September 8, 1978 and 50 FR 51661, December
8, 1985. In the event that a claim for
confidentiality is made on all or part of the
provided information, said information will only be
released by the EPA to the extent, and by means of
the procedures, set forth in the cited regulations.
Requests for confidentiality should be addressed to
U.S. Environmental Protection Agency, Office of
Toxic Substances, Document Processing Center (TS-
790), 401 M Street S.W., Washington DC, 20460 (Attn:
Frank Caesar, Carpet Emissions Administrative
Record).
b. Data Submission
The data collected in each phase of the testing
K-3
-------
program will be submitted to EPA for review as soon
as each data set becomes available. Thus, an
initial evaluation of preliminary data, two detailed
evaluations of the results of Phase I and Phase II
testing, and an overall evaluation on the combined
results will be conducted.
The FCAMC shall submit a final report on the
Carpet Installation Adhesives Testing Program as
described in section 3.4.4 of the Consensus
Statement and in accordance with the QAPjP. A cover
letter along with two (2) copies shall be submitted
for public access to the U.S. Environmental
Protection Agency, Office of Toxic Substances,
Information Management Office (TS-793), 401 M Street
S.W., Washington DC, 20460, Attn: Lynn Marcus,
Carpet Emissions Administrative Record. If the test
results contain Confidential Business Information
(CBI) the package must contain the cover letter, the
original submitted in accordance with the Consensus
Statement and two (2) copies of the CBI study
results, and three copies of a sanitized version
appropriate for public access. CBI submittals shall
be sent to the U.S. Environmental Protection Agency,
Office of Toxic Substances, Document Control Office
(TS-790), 401 M Street S.W., Washington DC, 20460,
Attn: Lynn Marcus, Carpet Emissions Administrative
Record.
3. Consultation and Follow-on Activities
The parties to this Memorandum of Understanding
recognize that Section 3.4.3 of the Consensus Statement
calls for technical evaluations by EPA of the results of
the preliminary testing, Phase I and Phase II, and
ultimately an overall evaluation for the purpose of
determining the need for follow-on testing, if required.
The EPA reserves the right to assess the suitability of
the test program results submitted for each of these
evaluations to assure that EPA has met the goals and
concepts of the Federal Register notice. Issues
identified by EPA will be discussed as follow-on
activities in joint consultation by the parties named
below. Details of these matters will be worked out by
consent of both parties and could be the subject of
additional Memoranda of Understanding.
Elements described in Section 4 of the Consensus
Statement identify certain follow-on activities proposed
by FCAMC which would benefit by collaborative efforts
undertaken by both parties to this agreement. Therefore,
activities such as: 1) annual industry report, 2) testing
K-4
-------
follow-up activities including development of TVOC
emission rate data on product types by company and study
to determine if a correlation can be achieved between
calculated VOCs and emissions testing measurements, 3)
public communication, and 4) database information
repository are considered useful follow-on activities
including development of TVOC emission rate data on
product types by company and study to determine if a
correlation can be achieved between calculated VOCs and
emission testing measurements. To this extent the FCAMC
intends to pursue and report to EPA on progress in these
areas.
Should FCAMC have technical questions about
provisions of this Memorandum of Understanding, please
contact the Director of the Existing Chemicals Assessment
Division, Charles M. Auer, at (202)382-3442.
D. PLACEMENT OF RESPONSIBILITIES
Responsibility for completion of the FCAMC Floor Covering
Adhesives Testing Program, FCAMC reporting activities, EPA
technical evaluation of the testing results, and inclusion of
the final report into the EPA Administrative Record as
described in this Memorandum of Understanding is placed with
the Chairperson, Floor Covering Adhesive Manufacturers
Committee, and the Director, Office of Toxic Substances, EPA.
E. OTHER AGREEMENTS
Nothing in this Memorandum of Understanding precludes EPA
from any other steps it deems necessary to carry out any
applicable laws, regulations, or policies. These include
activities listed in the U.S. Code of Federal Regulations, and
the reduction of carpet emissions described in the Federal
Register notices cited above. Furthermore, this Memorandum of
Understanding does not preclude EPA from entering into separate
agreements with individual floor covering adhesives
manufacturers that are presently not constituent members of the
Floor Covering Adhesive Manufacturers Committee. It is
understood that any such separate agreements pertaining to the
subject matter of this MOU will not contain provisions less
stringent or contrary to those terms and conditions stipulated
herein. Similarly, nothing precludes FCAMC from entering into
similar agreements with their contractors, or constituent
members for the purposes of conducting and reporting testing,
or similar agreements with other regulatory Agencies.
K-5
-------
NAME AND ADDRESS OF PARTIES
Floor Covering Adhesive Manufacturers Committee
National Association of Floor Covering Distributors
85 W. Algonquin Road, Suite 375
Arlington Heights, Illinois 60005
U.S. Environmental Protection Agency
Office of Toxic Substances
401 M Street, sw
Washington, DC 20460
PERIOD OF AGREEMENT
This Memorandum of Understanding is entered into by the
Floor Covering Adhesive Manufacturers Committee (FCAMC) and the
U.S. Environmental Protection Agency (EPA) as of this twenty-
sixth day of September, 1991.
Floor Covering Adhesive Manufacturers Committee Producer Member
Comcanies:
**^*-
Adh. Ind. Mfgr. Co.
Cerritos, CA 90702
Advanced Adh. Tech.
Dalton, GA 30711-1887
ito I/ Adh. Inc. __)
Dalton.- GA 30722
CMidag/i Adh.
Chicajgo, IL 60
^TUrM t^
Inc.
Dayton, Ohio 45401-0277
;TclanJ3Urg-pun
Lahoma^City,
Mac
Oklahoma
I can
OK 73125
Para-Chen
Simpsonville, SC 29681
Roberts Consolidated Ind.
City of Industry, CA 91749
Supwrbond, Inc
Philadelphia,
W.F.^«aylor Co. Ihc.
Santa7 Fe springs, CA
670
K-6
-------
Elk Grove Village, IL 60007.
W.'W. Henry Company //
Huntingdon Park, CA 90255
TEC, Inc.
Palatine, IL 60867
: & Chem.
r Juliet, TN 37122
XL Corporation
Calhoun, GA 30701
Baltimore, HD 11137
For the Floor Covering Adhesive Manufacturers Committee:
Kenneth E. Knudtzcfn (j
Chairperson
For the Environmental Protection Agency:
/
dfajj^-H-a
Mark A. Greenwood
Director
Office of Toxic Substances
K-7
-------
ATTACHMENT K-l
Federal Register: Carpet Policy Dialogue;
Memorandum of Understanding: Testing Program
for Carpet Installation Adhesives
-------
61246
Federal Register / Vol. 56. No. 231 / Monday. December 2. 19TO / Notices
OPTS-00115; FRL-4004-4]
Carpet Policy Dialogue; Memorandum
of Understanding: Testing Program for
Carpet Installation Adhesive*
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Notice of availability.
SUMMARY: EPA has entered into a
Memorandum of Understanding (MOU)
with the Floor Covering Adhesive
Manufacturers Committee (FCAMC). of
the National Association of Floor
Covering Distributors for the purpose of
initiating the provisions stated within
the context of the Carpet Policy
Dialogue - Consensus Statement: Testing
Program for Carpet Installation
Adhesives. The MOU provides for test
method development decay curve
testing, carpet installation adhesive
product testing for total volatile organic
compound emissions (TVOC), and
reporting of data as outlined in the
testing program.
DATES: The MOU was entered into on
September 26,1991.
FOB FURTHER INFORMATION CONTACT:
Dave Kling. Acting Director.
Environmental Assistance Division (TS-
799). Office of Toxic Substances, U.S.
Environmental Protection Agency, 401 M
St.. SW.. Washington, DC 20460.
Telephone: (202) 554-1404. TDD: (202)
554-0557. or FAX (202) 554-5603
(document requests only). For
information on the Carpet Policy
Dialogue Project contact Richard W.
Leukroth. Jr.. Carpet Policy Dialogue
Coordinator, Telephone: (202) 280-3832.
Copies of the MOU may be obtained
from the Environmental Assistance
Division listed at the address above.
SUPPLEMENTARY INFORMATION:
I. Background
The Carpet Policy Dialogue (August
21.1990 to September 27,1991) was part
of the Agency's response to a petition
under section 21 of TSCA (55 FR17404;
55 FR 31640). EPA charged the dialogue
to work out the details of voluntary
product testing programs that report
TVOC's that emit from carpet carpet
installation adhesive*, and carpet
cushion products. In addition, the Carpet
Policy Dialogue was asked to explore
and. where possible, reach agreement on
u variety of issues including: the
sampling and analytical methods for the
voluntary product testing for TVOC's.
any additional information needed.
identification of cost-effective process
changes to reduce TVOC emissions,
information about carpet installation
practices, and to provide the interested
public with information on TVOC
emissions. The Carpet Policy Dialogue
formed three working Subgroups
(Product Testing, Process Engineering.
and Public Communications) to respond
to the EPA charter.
The Carpet Policy Dialogue on TVOC
emissions was a nonregulatory
approach focusing on product
stewardship through voluntary actions
on the part of industry. It emphasized
exposure reduction (pollution
prevention), and addressed the pobhc
desire for information that could lead to
consumer choice. The Carpet Pottey
Dialogue exemplified how government.
industry, public interest groups, and the
scientific commnntty can work together
to resolve exposure reduction and
pollution preveoBoa issues, including
those related to indoor air exposure*.
Proposed t£4till|j' pfugi amo WC1C
developed daring Safagrasp disarssuM
and submitted ID (he Carpet Policy
Dialogue for the benefit of a consensus
process ef review and comment In
reaching cemoosus and accepting the
carpel installation adhesive testing
program, tke Carpet Policy Dialogue
indicated to Us sponsor (EPA) that such
a statement can provide the basis for a
memorandum of '""JT*an'i'ng to
initiate voluntary actionfa] in response
to tke charter set by EPA in the Federal
Register notices (55 PR 17404 and 55 FR
31640V
H. MiinsiiniirtisM ef Uadnrstanriag
The BPA M* FCAMC entered ia*o tbe
MOU on Scptuabcr 2n.lfl91.Tht MOU
signed by EPA an! PCAMC formally
establishes a framework, in which a
voluntary program response fee action*
described ia the Fedacai Register notice*
noted above can be fulfil led. U coaiaias
provisions initiating tke Carpet
Adhesive Testing Program on TVOC
emissions and certain follow-on
activities.
K-l
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Federal Register / Vol. 56. No. 231 / Monday. December 2. MSI / Notices 61247
*. Carpet Adhesive Testing Program
Under the terms and condition* of the
MOU, the FCAMC has voluntarily
agreed to develop an analytical test
method for mewtving TVOC emissions
front adhesive products, conduct decay
curve testing to determine Ike time
point(s) for mum ui ing TVOC encssiom
from the elected tart procedure, and
conduct product testing to determine
TVOC eBriasiew factor* for five
adhesive product typt* currently
available in commerce over the next 2
yean. The objectives of tfce Carpet
Adhesive Teatiag Program are to: (I)
Study carpet adhesive emissions decay
chacattenstka. and (2) characterize
quantitatively the distribution, of. TVOC
emissions factor performance of the
carpet adhesive product types currently
in commerce.
B. Participants
Placement of responsibilities for the
actions described in the MOU is with
the Chairperson. Floor Covering
Adhesive Manufacturers Committee of
the National Association of Floor
Covering Distributors and the Director.
Office of Toxic Substances. EPA.
III. Administrative Record
The MOU is available to the public in
the Carpel Emissions Administrative
Record. This Administrative Record is
available for reviewing and copying in
the TSCA Public Docket Office front B
a.m. to noon and 1 p.m. to 4 p.m..
Monday through Friday, excluding legt*
holidays. The TSCA Public Docket
Office is located at EPA HeaOuiaitw*
Rm. NE-G004. 401 M St., SW..
Washington. DC 28460.
Dated: Nvmber 25.19U.
Mark A.
Director.
(FR Dtoe. K-2MM FBed iva-*u MS
MJJNO CODE MtO-*0-F
K-2
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APPENDIX L
Memorandum of Understanding Between
the Styrene Butadiene Latex Manufacturers'
Council and the U.S. Environmental Protection Agency
-------
MEMORANDUM OF UNDERSTANDING
BETWEEN THE
STYRENE BUTADIENE LATEX MANUFACTURERS COUNCIL
AND THE
U. S. ENVIRONMENTAL PROTECTION AGENCY
SEPTEMBER 26, 1991
-------
MEMORANDUM OP UNDERSTANDING
A. BACKGROUND
The EPA initiated a dialogue process in April 1990, to
undertake certain actions with respect to reducing emissions from
carpet. One aspect is to develop a program for the voluntary
collection of data on emissions from carpet. See "Carpet:
Response to Citizens' Petition, "55 Fed. Reg. 17,404 (April 24,
1990) and "Carpet Emissions Reduction; Policy Dialogue, "55 Fed.
Reg. 31,640 (August 3, 1990). As part of the dialogue process,
the Carpet Policy Dialogue Group reached a consensus agreement on
May 23, 1991, concerning the Styrene Butadiene Latex Manufac-
turers Council's (SBLMC) voluntary offer to provide data on the
levels of 4-phenylcyclohexene (4-PC) in styrene butadiene latex
sold for carpet backing applications.
This Memorandum of Understanding will record voluntary
actions by SBLMC in response to the charter set by EPA in the
Federal Register notices.
B. PURPOSE
The SBLMC and EPA are entering into this Memorandum of
Understanding for the purpose of stating the provisions of the
voluntary agreement within the context of the above mentioned
Carpet Policy Dialogue and for providing for the public reporting
of company quality assurance data.
C. SUBSTANCES OF THE AGREEMENT
This Memorandum of Understanding formally establishes a
framework in which a voluntary program response to the Federal
L-l
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Page 2
Register notices noted above can be undertaken. Therefore, SBLMC
and EPA enter into the following understandings:
1. 4-PC Reporting
a. SBLMC members, acting through SBLMC, will provide
data from their ongoing quality analysis programs that will
report the company-by-company weighted average of 4-PC in styrene
butadiene latex sold for carpet backing applications for the last
quarter of 1991 and the last quarter of 1992. Individual company
average 4-PC measurements used as input to the weighting
calculation as well as the weighting calculation methodology will
be reported. All 4-PC measurements will be made, as has been
the case in the past SBLMC-sponsored 4-PC survey, by the
analytical method, "Quantitation of 4-Phenylcyclohexene in
Styrene-Butadiene Latex by Capillary Gas Chromatography"
described in Attachment I; or equivalent method.
b. SBLMC will provide information regarding the quality
control practices applied to generate 4-PC data. General
comparisons will be made between actual laboratory practices used
and provisions of TSCA Good Laboratory Practice Standards as
stated in 40 CFR Part 792, FR Vol. 54, No. 158, August 17, 1989).
4-PC data will be reported to EPA through SBLMC in non-confi-
dential form but with individual company identifiers blinded to
protect confidentiality. The data will be reported, as it
becomes available, for a total number of two reports submitted
under the terms of this Memorandum of Understanding. Newly
L-2
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Page 3
reported data will be compared to data previously submitted to
EPA and the Carpet Policy Dialogue. The reported data will also
be displayed by updating the graph titled, " 4-PCH Reduction
History" shown in Attachment II.
c. SBLMC will assess the styrene butadiene latex 4-PC
data developed in the ongoing quality analysis programs noted
above to determine the feasibility of utilizing the information
to develop future quality control activities. This activity is
voluntarily undertaken in the absence of scientific evidence
linking adverse health effects and the levels emitted by new
carpet. SBLMC will provide its assessment to EPA on or before
the aypi cation of thio -Homei-andum L£ UiuayiyLduaiuu.
d. EPA shall make the reports publicly available via
the Carpet Emissions Administrative Record.
2. Reporting Requirements
The SBLMC shall submit the data reports and other
communications noted above as described in this paragraph. A
cover letter along with two- (2) copies of each report shall be
submitted for public access to the U. S. Environmental Protection
Agency, Office of Toxic Substances, Information Management Office
(TS-793), 401 M Street, S. W. , Washington, D. C. 20460, Attn: Lynn
Marcus, Carpet Emissions Administrative Record.
L-3
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Page 4
D. PLACEMENT OF RESPONSIBILITIES
Responsibility for completion of the SBLMC 4-PC data
submission activity, as described in this Memorandum of
Understanding, is placed with the Chairman of SBLMC, and the
Director, Office of Toxic Substances, EPA.
E. OTHER AGREEMENTS
Nothing in this Memorandum of Understanding precludes EPA
from any other steps it deems necessary to carry out any
applicable laws, regulations, or policies. These include
activities listed in the U.S. Code of Federal Regulations, and
the reduction of carpet emissions described in the Federal
Register notices cited above. Furthermore, this Memorandum of
Understanding does not preclude EPA from entering into separate
agreements with individual latex manufacturers that are presently
not constituent members of the SBLMC. It is understood that any
such separate agreements pertaining to the subject matter of this
Memorandum of Understanding will not contain provisions less
stringent or contrary to those terms and conditions, stipulated
herein. Similarly, nothing precludes SBLMC from entering into
similar agreements with any contractors, or constituent members
for the purposes of conducting and reporting testing, or similar
agreements with other regulatory agencies.
F. NAME AND ADDRESS OF PARTIES
Styrene Butadiene Latex Manufacturers Council
1815 H Street, N. W.
Washington, D. C. 20006-3604
U. S. Environmental Protection Agency
Office of Toxic Substances
401 M Street, S. W.
Washington, D. C. 20460
L-4
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Page 5
G. PERIOD OF AGREEMENT
This Memorandum of Understanding is entered into by the SBLMC
and the U. S. Environmental Protection Agency (EPA) as of this
£6/* PA\/ of September, 1991 and shall expire upon
/
completion of reporting as described in paragraph C.1 above.
For the Styrene Butadiene latex Manufacturers Council:
Randall G. Arnbtt
Styrene Butadiene Latex
Manufacturers Council
For the Environmental Protection Agency:
Marx's.Greenwood /
Director '
Office of Toxic Substances
L-5
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Attachment L-l
Quantitation of 4-Phenylcyclohexene in
Styrene-Butadiene Latex
-------
SBLMC
Styr«n« Butadtorn Latex Manufacturer* Council
1330 Connecticut Av»nu«. N.W., WOO, Wmihrgton. O.C. 20036-1702
(202) $5*0060 TELECOPIER (202) 669-16W
ANALYTICAL METHOD
QUANTITATION OF 4-PHENYLCYCLOHEXENE IN STYRENE-BUTADIENE LATEX
BY CAPILLARY GAS CHROMATOGRAPHY
This method has been developed by the Analytical Committee of the
Styrene Butadiene Latex Manufacturers Council (SBLMC) to provide a
standard reference method for the detection of 4-phenylcyclohexene in
carboxylated styrene-butadiene latices. The method has been validated
and is available to any interested person. Further information on the
method or on the validation can be obtained from the Styrene Butadiene
Latex Manufacturers Council, Suite 300, 1330 Connecticut Avenue, N.W.,
Washington, D.C. 20036 (202/659-0060).
INTRODUCTION
4-Phenylcyclohexene (4-PCH), a co-dimer of 1,3-butadiene and
styrene, has been associated with the odor in some styrene-
butadiene (SB) based backings in carpets. The Analytical
Committee of SBLMC developed this method in order to provide
uniformly acceptable data for the level of 4-PCH in
carboxylated styrene-butadiene (XSB) latices. The
concentration of 4-PCH is reported on the basis of the total
latex with a normalized solids content of 50%.
1.
This method is applicable for the determination of 4-PCH in
XSB latex produced for carpet backing applications.
1.2 This method was validated over a range of 94-2830 ppm 4-PCH
(wt/wt latex solids).
L-l-l
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REFERENCED DOCUMENTS
2.1 ASTM Standards:
D4483 Practice for Rubber-Determining Precision for Test
Method Standards, Annual Book of ASTM Standards, vol. 09.01
and 09.02
D1417 Standard Methods of Testing-Rubber LaticesSynthetic,
Annual Book of ASTM Standards, Vol. 09.01
SUMMARY OF METHOD
3.1 4-Phenylcyclohexene is preferentially extracted from the XSB
latex into an organic phase using a n-heptane/0.5M ammonium
sulfate liquid-liquid extraction system.
3.2 An aliquout of the organic phase is analyzed using capillary
gas chromatography.
3.3 An internal standard methodology is employed for making the
quantitative calculations.
SIGNIFICANCE AND USE
4.1 Quantitation of 4-PCH in the XSB latex will help in further
studies.
4.2 This method allows for the quantitation of 4-PCH with a
relative standard deviation (r/x) of 1.4% determined at a leve
of 960 ppm (wt/wt latex solids).
APPARATUS
5.1 Gas Chromatograph - This instrument should be equipped with a
flame ionization detector and have the capability to accept a
wide-bore fused silica capillary column. A detector make-up
gas is required.
5.2 Fused Silica Capillary Column, DB-5 (95% Dimethyl-(5%)-diphenyl-
polysiloxane), 30M x 0.53mm ID with 1.5 micron film thickness,
J&w Scientific, cat. no. 125-5032
5.3 Data Recording Device - A strip chart recorder, recording
integrator, or computer based data system is suitable.
5.4 Mechanical shaker, (Eberbach shaker at high speed,
280 excursions per minute, or equivalent to provide for a
minimum 92% (4-PCH) recovery in spiked latex samples)
5.5 Centrifuge, capable of 2000 rpm
L-l-2
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APPARATUS (cont'd)
5.6 Balance, analytical, 0.1 mg readability, Mettler AE163, or
equivalent
5.7 Aluminum weighing dish, diameter, 2 3/8"; depth, 5/8". These
dishes should be pre-cleaned with suitable organic solvent, to
eliminate processing oils, and dried in a vacumm oven before
their use in the procedure.
5.8 Volumetric Flasks, 25, 250 mL
5.9 Vials, screw cap, size No.2, 2 3/4 (25 mL capacity)
REAGENTS AND MATERIALS
6.1 Purity of Reagents - Use solvents especially purified for high-
pressure liquid chromatography work in this procedure. Use
other grades only after ascertaining that the reagent is free
of interferences.
6.2 Observe all health and safety recommendations of the chemical
manufacturers when using their products.
6.3 Dodecane, 99.7%, Wiley Organlcs cat. no. 2269.55, or equivalent
6.4 4-Phenylcyclohexene, 98%, Wiley Organics cat. no. 7803.00, or
equivalent
6.5 n-Heptane, B&J Brand, American Scientific Products
cat. no. 210-4*DK, or equivalent
6.6 Ammonium Sulfate ((NH4)2S04), American Scientific Products
cat. no. 3512-500*NY, or equivalent
6.7 Water, triple distilled, Distillata, or equivalent
6.8 Ammonium Sulfate Solution (66 g/L) - Dissolve 66 g of
ammonium sulfate ((NH4)2S04) in water and dilute to 1 L.
PROCEDURE
7.1 Calibration:
7.1.1 Tare (to the nearest 0.1 mg) a 25 mL volumetric flask
containing 10 mL n-heptane.
7.1.2 Weigh (to the nearest 0.1 mg) into the 25 mL volumetric flask
8 +/- 2 mg dodecane and 10 +/- 2 mg 4-phenylcyclohexene.
Dilute to mark with n-heptane. Denote this solution as the
'Master Calibration1.
L-l-3
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7. PROCEDURE (cont'd)
7.1.3 Pipet a l mL aliguout of the 'Master Calibration1 into a
clean 25 mL volumetric flask and dilute to mark with
n-heptane. Denote this solution as the 'working
Calibration1.
7.1.4 Chromatograph a 1 microliter aliquot of the 'Working Calibra-
tion' under the conditions as outlined in TABLE 1. Analyze
in triplicate or until a stable response factor is obtained.
7.1.5 Calculate an internal response factor for 4-PCH as per 8.1.1.
7.2 Preparation of Internal Standard Solution:
7.2.1 Tare (to the nearest 0.1 mg) a 25 mL volumetric flask
containing 10 mL n-heptane.
7.2.2 Weigh (to the nearest 0.1 mg) into the 25 mL volumetric flask
8 +/- 1 mg dodecane. Dilute to mark with n-heptane. Denote
this solution as the 'Internal Standard Solution1.
7.3 Sample Preparation and Analysis:
7.3.1 Tare (to the nearest 0.1 mg) a clean vial.
7.3.2 Weigh (to the nearest 0.1 mg) into the clean tared vial,
500 +/- 20 mg of the XSB latex sample.
7.3.3 Add 10 mL of the 0.5M ammonium sulfate solution.
7.3.4 Pipet 1 mL of the Internal Standard Solution into the sample
vial.
7.3.5 Add 9 mL of n-heptane to the vial.
7.3.6 Cap vial and place on a mechanical shaker set at high speed
(280 excursions per minute) for 30 minutes.
7.3.7 Remove vial from shaker, placing it in a centrifuge for
15 minutes at 2000 rpm.
7.3.8 Remove the vial from the centrifuge taking care not to
intermix the separated layers.
7.3.9 Quantitatively remove the n-heptane layer (top) from the
solution and place in a clean vial.
7.3.10 Add 10 mL of n-heptane to the original sample vial (aqueous
phase) and repeat for a second time the procedure from 7.3.6
eventually combining the second n-heptane extraction layer
with the first.
L-l-4
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7. PROCEDURE (cont'd)
7.3.11 Chromatograph a 1 microliter aliquot of the combined
n-heptane layers under the conditions outlined in TABLE 1.
7.3.12 Perform calculations as per 8.2.1.
7.4 Total Solids Determination:
7.4.1 Allow latex to cool to room temperature, if at an elevated
temperature. Weigh two samples of latex of approximately 1 g
each to the nearest 0.1 mg in tared, aluminum weighing
dishes.
7.4.2 Add l mL of distilled water as a drying aid to each dish.
Mix the latex and drying aid together by gently swirling the
dish.
7.4.3 Dry the samples for 45 minutes in a vacumm oven at a
temperature of 125*C, maintaining the pressure at less than
20.5 kPa (6 in. Hg). Drying time begins when door is closed.
vacumm shall be pulled over a 5 minute minimum period to
prevent splattering or loss of sample.
7.4,4 Remove the samples from the oven, cool the dish and contents
to room temperature in a desiccator, and weigh them to the
nearest 0.1 mg.
7.4.5 Calculation - Calculate the percentage of total solids in the
latex as follows:
Total Latex Solids, % - (C-A) x 100
(B-A)
where A * Weight of the weighing dish, g
B - weight of the dish plus the original sample, g
C - weight of the dish plus the dried sample, g
L-l-5
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8. CALCULATIONS
8.1 Calibration:
8.1.1 Calculate an internal response factor (versus dodecane) for
4-phenylcyclohexene:
RF = A(std) x W(c)
A(C) X W(Std)
where RP - Internal response factor for 4-PCH
W(c) - Weight (milligrams) of 4-PCH corrected
for purity
A(c) » Peak area for 4-PCH
W(std) « Weight (milligrams) of dodecane (internal
standard) corrected for purity
A(std) = Peak area for dodecane
8.2 Sample:
8.2.1 Calculate the parts per million (mg/kg) level of 4-PCH based
on the total latex normalized to a 50% solids content:
4-PCH, ppm = A(sp) x RF x W(std) x 1000 x 0.5
A(std) x W(sp) x 0.919 x TS
where RF - Internal response factor for 4-PCH
W(std) » Weight (milligrams) of dodecane (internal
standard) corrected for purity
A(std) - Peak area for dodecane
W(sp) - Weight (grams) of XSB latex (sample)
A(sp) - Peak area for 4-PCH
TS - Total Solids determination obtained from
7.4.5, expressed as a fraction
0.919 - Experimentally determined recovery {4-PCH)
0.5 « Factor used to normalize the total latex
to a 50% solids content
L-l-6
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9. REPORT
9.1 Parts per million (mg/kg) 4-phenylcyclohexene based on the
total latex normalized to a 50% solids content.
10. PRECISION AND BIAS
10.1 Precision statements have been prepared in accordance with
Practice D4483. Refer to Practice D4483 for definitions of
terminology and other statistical calculation details.
10.2 A Type I (interlaboratory) precision was evaluated. Two
materials of identical matrix containing different levels of
the test component were used in the interlaboratory program.
Testing was conducted in five laboratories. A test result is
the average value, as specified by this test method, obtained
from two or more determinations of the component level in
question.
10.3 The results of the precision calculations for repeatability
and reproducibility are given in TABLE 2, in ascending order
of the material level, for each of the materials evaluated.
10.4 BIAS - By definition, bias is a measure of the systematic
error that contributes to the difference between the mean
value of the test result population and an accepted reference
or true value. There may be one or more bias elements that
contribute to the systematic error.
10.5 A recovery study is a measure of one bias element associated
with the efficiency of the sample preparation procedure
(extraction, dilutions, etc.).
10.6 Material 2 was a test unit prepared by doping Material l with
460 mg/kg 4-phenylcyclohexene. Mean values for 4-phenylcyclo-
hexene were determined for the two test units. The bias
element is calculated from the equation:
(reference value) - (difference of the means)
BIAS -
reference value
where the reference value is the amount of 4-phenylcyclohexene
used to dope Material 2. Expressed in percent terms, the bias
associated with sample preparation in this method is 8.1%.
L-l-7
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TABLE I
Gas Chromatographic Parameters
COLUMN:
Column type:
Dimensions:
Liquid phase:
Film thickness:
fused silica capillary
30 m x 0.53 mm I.D.
DB-5 (95% Dimethyl-(5%)-diphenyl-
polysiloxane)
1.5 micron
INSTRUMENT CONDITIONS;
Injection mode:
Carrier Gas:
Linear flow velocity:
Make-up gas:
Oven temperature profile:
Initial temperature:
Intial time:
Program rate:
Final temperature:
Final time:
Injection temperature:
FID temperature:
direct injection
helium
38 cm/sec (@ 75*C)
helium, @ 26 mL/min
programmed
75 "C
1 min
12'C/min
200 *C
5 min
275 *C
275 *C
L-l-8
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TABLE II
TYPE I - Precision
(4-Phenylcyclohexene, wt/wt latex solids)
NOTE:
sr * within laboratory standard deviation
r repeatability (in measurement units)
(r) repeatability (in percent)
sR between laboratory standard deviation
R reproducibility (in measurement units)
(R) reproducibility (in percent)
within Laboratories
Mean value.
Material mg/Jcg
sr r
1 165 2.6 7.4
2 963 13.6 38,6
(r)
4.5
4.0
Between Laboratories
SR
12.5
45.9
R
35.3
130.0
(R)
21.4
13.5
L-l-9
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ATTACHMENT II
4-PCH Reduction History
260
200-
150-
100-
50
4-PCH, ppm
(by weight)
industry Avaraga
+ Individual Company
Avaragaa
May '88 May '90 Jan-Feb '91
Butadlana Latax
Manufacturers Council
May 1991
*Companybycompany weighted average data
include 320 individual measurements representing
approximately 94% of Jon.-Feb. 1991 shipments
to the carpet trade. This represents an average
50% reduction since 1988.
L-l-10
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ATTACHMENT L-2
Federal Register: Carpet Policy Dialogue;
Memorandum of Understanding: SBLMC Reporting
Program for 4-PC
-------
6124T
Federal Register / Vol. 56. No. 231 / Monday. December 2, 1991 / Notices
:OPTS-OOtt3; FRL-4004-2]
Carpet Policy Dialogue; Memorandum
of Understanding: SBLMC Reporting
Program for 4-PC
AGENCY: Environmental Protection
Agency
SUMMARY: EPA has entered iuta a
Memorandum of Understanding (MOU)
with the Stymie Butadiene Latex
ManufactumtCmnattSBLMQfartae
pwrpoae of initiating the pjoviaioiM
stated within the context of
recommendation* from the Carpet
Policy Dialogue. The MOU provides for
the public reporting of company quality
assurance data on 4-phenylcydohexene
(4-PQ, and a feasibility assessment for
future quality control activities-.
DATE*: The MOU was entered late on
September 2». JSW.
POM FURTHER MTCMIATION' CONTACT:
Dave Kfing, Acting Director,
Environmental Assistance Division (TS-
791% Office of Toxic Bobataace*.
aratoaameBtai ProtectM* Agency. 4M U
St. SW., Washingtoa DC 20460.
TelefkoKt: |202) 55+-1404, TDD; (202)
554-0557, or PAX (202} 5546803
(document requests only). Foe
information on the Carpet Policy
Dialogue Project contact Richard W.
Leukroth, Jr., Carpet Policy DialflgMe
Coordinator. Telephone: (202) MQ-ggig
Copies e£ the MOU may be obtained
from the Environmental Assistance
Division at the address listed above.
SUPMJEMENTAIIY INFORMATION:
I. Background
The Carpet Policy Dialogue (August
21. 1990 to September 27, 1991) was part
of the Agency's response to a petition
under section 21 of TSCA (55 FR 17404;
55 FR 31640). EPA charged the dialogue
to work out the details of voluntary
product testing piapaan thai report
TVOCa that eatt ins* carpet carpel
installation adhearv ec. sad carpet
cushion ptudaUi. in-addttieac. the Carpet
Policy Dialog** was asked to explore
and. where poaasble. reach aareetnea) 0*1
a variety of K««e» Mchkd«B*t the
sampling sod astttytkal awtaede tot the
voluntary prated tastiasj fax TV OCs,
any aditrtimsil JalntnuHon needed.
identification of cost-effective process
change* to reduce TVOC emiasionSk.
infbrwtkm about caipei iamtall«fian
practices; awi ls> afuvide tke inlexested
public with BEfonnatton onTVOC
pTTDHioos. The Carpet Policy
formed tbtee workioa, Svbgroups
(Product Testing. Process Engineering.
and Pbbhc Coaumsucatioas) to rapeed
to the EPA charter.
TW Carpel Policy Dialogue OK TVOC
emissions wa» a aonegtriatory
approach focusing oa product
stewardship through voluntary actions
on the part of industry. It emphasized
exposure reduction (poDution
prevention), and addressed the pabtk:
desire for information that eouW lead to
consumer choice. The Carpet Policy
Dialogue exemplified how government.
industry, public interest groups, and the
scientific community can woik together
to resolve exposure reduction and
pollution prevention issues, indoding
those reteted to indoor air exposures.
Recommendations developed during
Subgroup discussion were submitted to
the Carpet Poh'cy Dfafogne-fbr the
benefit of a consensus process of review
and comment. In reaching consensns
and accepting the SBLMC 4-PC company
quaKty assiuance reporting program, the
Carpet Policy Diafogoe indicated11<7 its
sponsor (EPA) that rach a
recommendation can provide the basis.
for a memorandum of undetslaodus&ie
initiate volualacy aciion(s) in response
to the chutes set by EPA in the Federal
Register notices (55 FR 17404 and 55 FR
31640).
D. Memorandum of Understanding
The EPA and SBLMC entered into the
MOU im September 2*. IMl.TkeHOU
signed by EPAaarf SBLWC Jsneatty
establishes a framework in whicb a
voluntary program response for actions
described hi lite Federal Register notices
noted above can be fulfilled. It coRtamv
provisions describing the 4-PC company
quality assurance reporting program and
certain follow-on activities.
A. SBLMC Quality Assurance Reporting
Program for 4-PC
Under the terms and conditions of the
. MOU .the SBLMC has voluntarily
agreed to report data from their ongoing
quality analysis programs. The SBLMC
will report the company-by-company
weighted average of 4-PC in styrene
butadiene latex sold for carpet backing
applications for the last quarter of 1991
and the last quarter of 1992. The
individual company average 4-PC
measurements used as input to the
weighting calculations as well as the
weighting calculation methodology will
be reported.
L-2-1
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Federal Register / Vol. 56. No. 231 / Monjay. December I, 1991 / Novices 612-18
In addition, the SBLMC has agreed to
assess the styrene butadiene latex 4-PC
data developed from ongoing quality
analysis programs noted above to
determine the feasibility of utilizing the
information to develop future quality
control activities. SBLMC will provide a
report to EPA on its assessment of the
feasibility on or before July 1,1993. The
report will be submitted to the EPA and
entered into the Carpet Emissions
Administrative Record.
B. Participants
Placement of responsibilities for the
actions described in the MOU is with
the Chairperson. Styrene Butadiene
Latex Manufacturers Council and the
Director. Office of Toxic Substances.
EPA.
m. Administrative Record
The MOU is available to the public in
the Carpet Emissions Administrative
Record. This Administrative Record is
available for reviewing and copying in
the TSCA Public Docket Office from 8
a.m. to noon and l p.m. to 4 p.m..
Monday through Friday, excluding legal
holidays. The TSCA Public Docket
Office is located at EPA Headquarters.
Rm. NE-C004.401 M St.. SW.,
Washington. DC 20460.
Dated; November 25.1991.
MukA-GnMBwood,
Director. Office of Toxic Substances.
IFR Doc. 91-28826 Filed 11-29-01: 8:45 am)
L-2-2
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APPENDIX M
FINAL TEXT DRAFT1
of
Public Information Brochure:
"Indoor Air Quality and New Carpet, What You Should Know"
1 This material was approved by the Carpet Policy Dialogue on September 27, 1991. Further changes to mil text may be needed to
accomodate brochure layout considerations, conform with government policy regarding disclaimer statements, or for other similar reasons.
The views of the sixteen "sign-on" organizations listed in the last section of the brochure will be considered in completing the final product.
Not all changes were available at the time when this report went to press. A copy of the final brochure product will be available from:
TSCA Assistance Information Service (TS-799), United States Environmental Protection Agency 401 M St., S.W., Washington, DC 20460.
Telephone (202)554-1404.
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FINAL TEXT DRAFT
PUBLIC INFORMATION BROCHURE:
"INDOOR Affi QUALITY AND NEW CARPET,
WHAT YOU SHOULD KNOW"
Past efforts to clean the air focused on pollution outdoors rather than indoors. Since many
Americans spend most of their time inside buildings, there has been a growing concern about
indoor air quality.
Sources of indoor air pollution range from dust, mold, and mildew to chemical emissions from
common household products, appliances, furnishings, and building materials. Poor ventilation
(lack of fresh air) allows pollutants to build up indoors. Polluted indoor air may cause some
people to become ill.
Indoor air pollution at low levels is difficult to study. For most chemicals, research has not yet
found whether low levels are likely to cause health problems. It is impossible to keep homes and
other buildings free of all pollutants. However, it makes good sense to try to reduce exposure to
pollutants, while enjoying the benefits of the many products that add to the overall quality of life.
As concern over indoor air pollution has grown, some questions have been raised about the
relationship between carpet products and indoor air quality. The following are answers to some
of the most frequently asked questions:
What is new carpet's role in indoor air quality?
Like many other household products, new carpet can be a low-level source of chemicals that are
emitted into the air. These chemical emissions, also called volatile organic compounds (VOCs),
contribute to the total level of pollutants in a building.
It is important to remember that carpet is part of a total floor covering system that may include
the cushion and installation adhesives. The cushion and adhesives are also sources of emissions.
Manufacturers of floor covering products are working to reduce emissions from their products.
How do the emissions from carpet compare to
Emissions from new carpet and cushions tend to be lower than emissions from many other
construction and renovation materials. The emissions from adhesives used to install carpets can
vary. New low-emitting adhesives are available that can greatly reduce emissions from new carpet
installations.
New carpet is usually installed during home or office decoration, building construction, or
renovation. Interior decorating usually includes the use of new materials such as wall treatments
(painting, wallpapering, paneling), floor covering (carpet, vinyl, wood, ceramic), window
covering (fabric, wood, plastic), and furniture. Any or all of these materials may produce
chemical emissions and odors.
M-l
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FINAL TEXT DRAFT
Should I be concerned about chemical emissions from new carpet?
Limited research to date has found no link between adverse health effects and the levels of
chemicals emitted by new carpet.
Some people report allergy- or flu-like symptoms that they believe are caused by newly installed
carpet, however, such symptoms could be attributed to other sources.
When new carpet is installed, it may produce an odor. All odors are caused by chemicals - even
food or flower odors. However, some people are more sensitive to odors than others. The
presence of an odor following installation of new carpet does not mean there is a problem. While
it may be unpleasant to some individuals, most people are not bothered by new carpet odor.
What can I do to reduce mv exposure?
The presence of some pollutants in buildings is unavoidable. However, increasing the amount of
fresh air in the home or office may reduce exposure to pollutants. The Carpet and Rug Institute
(CRT), a trade association, recommends that the ventilation system in public and commercial
buildings be operated at maximum outdoor air flow before, during, and for 48-72 hours after the
new carpet installation. In homes, leave doors and windows open, if possible, and use fans to
increase the flow of outdoor air. It is important to provide adequate ventilation to maintain good
indoor air quality.
To reduce exposure in homes, residents may wish to leave during the installation of new carpet.
In the office, ask building managers to consider installing new carpet when the area is not in use.
M-2
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FINAL TEXT DRAFT
STEPS TO TAKE
You should:
Plan ahead.
Ask your carpet retailer for information on
emissions from carpet.
Ask for low-emitting adhesives, if
adhesives are needed.
Be sure the retailer requires the installer to
follow Carpet and Rug Institute installation
guidelines.
Be sure the ventilation system is in proper
working order before installation begins.
Open doors and windows, if possible,
during and after installation. Consider
using window fans, room air conditioning
units, or other means to exhaust emissions
outdoors.
Operate the ventilation system with
maximum outdoor air during and after
installation for 48 to 72 hours.
Consider leaving the premises during and
immediately after carpet installation. You
may wish to schedule the installation when
most family members will be out of the
house.
Contact your carpet retailer if
objectionable odors persist.
Follow the manufacturer's instructions for
proper carpet maintenance.
These key points, listed above, apply to carpet installations in all types of buildings. If you have questions
about carpet, contact your retailer, building manager, or other responsible person.
M-3
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FINAL TEXT DRAFT
AVhere
I get more nfratn
Individual manufacturers often provide brochures and other materials to help consumers better understand and
take care of their new purchases. Government agencies, industry associations, and consumer groups are useful
resources for more information on indoor air quality. You may wish to write or call these organizations for
more information:
U.S. Environmental Protection Agency
TSCA Assistance Information Service (TS-799)
401 M Street, S.W.
Washington, DC 20460
(202)554-1404
U.S. Consumer Product Safety Commission
Washington, DC 20207
1-800-638-2772
American Lung Association
1726 M Street, N.W., Suite 902
Washington, DC 20036
(202)785-3355
Carpet and Rug Institute
Box 2048, 310 Holiday Avenue
Dalton, GA 30720
(404)278-3176
Carpet Cushion Council
P.O. Box 546
Riverside, CT 06878
(203)637-1312
Floor Covering Adhesive
Manufacturers Committee of
the National Association of Floor Covering
Distributors
401 North Michigan Avenue
Chicago, IL 60611
(312)644-6610
Floor Covering Installation
Contractors Association
P.O. Box 948
Dalton, GA 30722
(404)226-5488
National Federation of
Federal Employees, Local 2050
P.O. Box 76082
Washington, DC 20012
(202)862-4400
Your local carpet retailer:
[Place for retailer/distributor to
stamp address and telephone number]
Note: The organizations listed above have not reviewed or approved all the information and
documents that may be provided by other organizations. The views or opinions expressed by
organizations listed on this brochure may not necessarily reflect the opinions of EPA, other
Federal agencies, or other organizations that collaborated in preparing this brochure. Listing
an organization (Federal or non-federal) should not be construed as any endorsement by any
organization.
This document may be reproduced without alteration and without permission, except for use as
advertising material or product endorsement. Any such reproduction should credit the
organizations listed. The use of all or any pan of this document in a deceptive manner or for
purposes of endorsing a particular product may be subject to appropriate legal action.
M-4
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FINAL TEXT DRAFT
Representatives from the following organizations have been working cooperatively to address indoor air quality
issues and have participated in the development of this brochure.
American Federation of State, County, and Municipal Employees
American Fiber Manufacturers Association
American Lung Association
American Textile Manufacturers Institute
Carpet and Rug Institute
Carpet Cushion Council
Floor Covering Installation Contractors Association
Floor Covering Adhesive Manufacturers Committee of the
National Association of Floor Covering Distributors
Georgia Tech Research Institute
National Federation of Federal Employees, Local 2050
National Institute of Standards and Technology
Styrene Butadiene Latex Manufacturers Council
The Adhesive and Sealants Council, Inc.
U.S. Consumer Product Safety Commission
U.S. Environmental Protection Agency
U.S. General Services Administration
M-5
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APPENDIX N
FINAL REPORT
Investigating the Impact of Various Cure Parameters on the
Release of 4-Phenylcyclohexene (4-PCH) from Carpet
Backed with Compounds Based on Carboxylated SBR Latex
-------
FINAL REPORT
INVESTIGATING THE IMPACT OF VARIOUS CURE PARAMETERS ON THE
RELEASE OF 4-PHENYLCYCLOHEXENE (4-PCH) FROM CARPET
BACKED WITH COMPOUNDS BASED ON CARBOXYLATED SBR LATEX
January 17, 1990
Submitted to:
Mr. Alan Rautio
Styrene Butadiene Latex
Manufacturer's Council
Prepared by:
Dr. Mark Van Ert
Director: Occupational
Safety & Health Program
-------
ACKNOWLEDGMENTS
This University of Arizona research project was
supported in its entirety by funding from the Styrene
Butadiene Latex Manufacturer's Council (SBLMC). Special
thanks go to Mr. Charles Oxley of BASF Corporation for his
participation as project chairman and for his professional
assistance during the course of this study, to Mr. John
Bogdany and his staff at GENCORP Polymer Products for
assisting our research team in the development of skills
essential to the preparation of carboxylated SBR latex-backed
carpet, to Mr. Dennis Moldovan and Dr. Anoop Krishen of
Goodyear Tire and Rubber Company, Mr. Kerwin Kolinek of
GENCORP Polymer Products and, certainly, to the other members
of the Council for their professional insights during the
design and implementation of the project. The administrative
assistance of Mr. Alan Rautio, Executive Director of the
SBLMC, in expediting the development of the project is also
greatly appreciated.
Dr. David Stumpf, Research Associate for the project,
and Ms. Mary Flynt, Graduate Research Student, deserve
special mention for their very able assistance in the
completion of this research endeavor.
N-i
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FINAL REPORT
FOR
INVESTIGATING THE IMPACT OF VARIOUS CURE PARAMETERS ON THE
RELEASE OF 4-PHENYLCY.CLOHEXENE (4-PCH) FROM CARPET
BACKED WITH COMPOUNDS BASED ON CARBOXYLATED SBR LATEX
INTRODUCTION
Previous research at the University of Arizona has
demonstrated 4-phenylcyclohexene I4-PCH) to be an odorous
emission from certain batches of carpet.1 The source of this
chemical was determined to be the SBR latex employed in the
backing of the carpet. Recent work by Demer,a revealed a
trend in the reduction of 4-PCH in SBR latex as a function of
cure time. The actual relationship between 4-PCH emissions
from a representative compounded latex similar to that
employed in the manufacture of carpet was not examined in
that study. As a result, a comprehensive study was initiated
to investigate the relationship between 4-PCH release from
latex-backed carpet and specific cure parameters.
The following set of variables was controlled during
test trials to objectively characterize the parameters
affecting the release of 4-PCH from carpet samples freshly
coated with SBR latex formulations:
1. Cure time
2. Cure temperature
3. Air exchange rate
Other dependent factors that were considered during the
course of the curing procedure to determine their
N-l
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relationship to 4-PCH release from the carpet samples
included:
1. Humidity within the cure oven, and
2. Moisture content of carpet samples
METHODS AND MATERIALS
Preparation of Carpet Test Samples
The effect of specific cure parameters on the level of
4-PCH in carpet samples containing SBR latex required special
considerations in experimental design. A primary
consideration was evaluating the release or decay of 4-PCH in
the actual carpet matrix. Consistent with recommendations
provided by SBLMC advisors, both carpet type and backing were
standardized prior to evaluating 4-PCH release. The
representative carpet standard was a 26 oz. nylon 6:6 pile
Saxony with a 3.2 02. polypropylene backing. The carpet and
secondary backing samples were provided by member companies
of the Carpet and Rug Institute (CRI) Committee. Blended
latexes representing two levels of 4-PCH content, were
compounded as described below and employed to adhere the
secondary backing to the carpet samples.
A member (SBLMC) laboratory developed the two latex
composites by blending latexes from six producers. These
two latex blends (i.e. latex A or B) were then compounded by
the University of Arizona research team to contain 450 parts
N-2
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Georgia Marble filler. Other ingredients added included a
thickener and froth aid. The final carboxylated latex
compound was frothed to approximately 800 grams per quart and
applied at 26 oz./sq. yd. application weight. A SBLMC member
assisted the University of Arizona research group in
reviewing carpet samples prepared during preliminary
compounding and coating tests specified in appropriate test
methods (i.e. DTSC-TM 1000, 1003, and 1004). Data sheets
detailing the preparation of carpet latex were compiled for
each run to insure conformance with quality control
parameters. A standard operating procedure describing latex
preparation and application is presented in Appendix I.
A ten square inch carpet area on a 12 square inch piece
of carpet was coated with a carboxylated SBR latex compound
and then divided into four 5 square inch carpet pieces.
These square carpet swatches were then introduced into a
Fisher, Model 496, atmosphere controlled forced air curing
oven set at one of three cure temperatures (225, 250, or 275°
F) . One of the four carpet sample swatches was removed at a
designated cure time interval (10, 20, 40, or 60 min.). Five
0.5 square inch carpet pieces were cut along a diagonal from
each test swatch to evaluate remaining 4-PCH and variation in
latex applications. All test runs were duplicated to obtain
an appreciation of the variation in each test parameter.
Two air exchange rates, zero and three air exchanges per
minute, were also selected to assess the influence of this
test parameter on 4-PCH release from the carpet. An air
N-3
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exchange rate of three (3) per minute accounted for a 45 + 5
linear foot per minute (Ifm) velocity over the surface of the
carpet.
To evaluate the release of moisture from the carpet
swatches during specific cure cycles (cure temperature vs.
cure time), carpet swatches were weighed with a Mettler Model
H31AR Precision Balance prior to and following a cure cycle.
Five-0.5 square inch samples were then prepared for 4-PCH
analysis.
Analytical Equipment
Samples were analyzed using a HP 5890A gas chromatograph
using a flame ionization detector. The analytical column wa
an HP-17 (OV-17), 10 meter, megabore column. Nitrogen
carrier gas flow was 10 ml/min. (65 kPa) at 140 C column
temperature. Injector temperature was 190 C, detector
temperature was 250 C.
Detector output was connected to a Jones Chromatography
Limited, JCL 6000 Chromatography data system and collected
and stored as individual files.
Sample Preparation
The carpet sample size selected for analysis was
approximately 0.5 square inch with sample weight being
recorded as the parameter for comparison. The carpet sample
N-4
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was placed in a 16 ml screw top vial, 4-6 mis of carbon
disulfide containing a 1-PCH internal standard added, capped
with a teflon-faced septa cap and left to equilibrate for 15
minutes. Previous experiments demonstrated that this was
sufficient equilibration time for over 95% of the 4-PCH to
equilibrate with the solution. Carbon disulfide was chosen
for its relatively low background FID signal as well as the
high solubility of 4-PCH.
One microliter sample volumes were injected into the gas
chromatograph. If the 4-PCH content was above 24 nmoles/ml,
the sample had additional carbon disulfide added to bring the
concentration below 24 nmoles/ml. This was due to the
earlier observation that above 31 nmoles/ml concentration,
dissolution of the 4-PCH was not complete.
Standard Curve
The 4-PCH standard curve was prepared using authentic 4-
PCH in carbon disulfide. The curve was made so that
microliter injections of the standard represented 0.64, 1.35,
3.16, 6.32, 12.6 and 25.2 picomoles per microliter (nanomoles
per ml). Our lower level of detection was thus 101 ng/ml
carbon disulfide.
N-5
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Carpet and Oven Temperature Measurement
Carpet and oven temperatures were measured using two
Omega TAG-80 T Thermocouple to Millivolt Converters attached
to a Type T thermocouple and measured using a Micronta
Digital Voltmeter.
RESULTS AND DISCUSSION
4-PCH _Content of Composite Latexes
The raw latex composites employed in the study, namely A
and B, were found to contain approximately "700 ppm (w/w)" and
250 ppm (w/w) 4-PCH, respectively. The 0.5 square inch
carpet samples coated with compounded latex contained
approximately 60 ppm* or 20 ppm 4-PCH, depending on the latex
employed, that is, latex A or B. Due to the slight variation
in the 4-PCH content noted during the preparation of
individual batches of compounded latex, all data reflecting
the impact of various cure parameters on the release of 4-PCH
are reported as a percentage of the absolute amount of 4-PCH
remaining in a latex coated carpet sample for the individual
test run.
* w/w means weight 4-PCH/dry weight of latex
+ weight of 4-PCH/dry weight of 0.5 sq. in. carpet sample
N-6
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Effect of Oven Temperature on 4-PCH Release
The impact of oven temperature on 4-PCH release was
evaluated at three temperatures, 225°F, 250°F, and 275°F for
carpet backings coated with either compounded latex A or B.
The data presented in Table I and Figure 1 illustrates
the temperature dependent decay of 4-PCH over time for carpet
treated with latex A. The decay of 4-PCH is presented as
percent 4-PCH remaining as a function of time at designated
oven temperature settings. Following an initial lag in 4-PCH
release during the first five minutes of the cure cycle, the
rate of decay of 4-PCH is enhanced as the oven temperature
settings were increased from 225°F to 275°F. The decay rate
is greatest over the first twenty minutes of cure, with the
exception of the 225°F cure study, and then, decreases to a
minimum at 40 minutes.
A review of the 4-PCH decay profile for carpet coated
with latex B revealed an almost identical pattern to that
seen for latex A (see Table II, Figure 2). An initial lag on
4-PCH release is again noted over the first five minutes of
cure followed by a temperature dependent release of 4-PCH.
At 275°F over 50% of the 4-PCH in latex A & B coated
carpets is released within ten minutes, whereas only 10% is
released at 225°F over the same time period. Although these
experimental data cannot be directly extrapolated to actual
cure conditions in industrial situations, the data are quite
suggestive that higher cure temperatures would have a
N-7
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significant impact on the release of 4-PCH from carpet
backings comprised of carboxylated SBR latex. The data would
also suggest that higher temperatures could be critical when
circumstances dictate shorter oven cure times.
A review of Figures 1 and 2 also indicate that the
percent removal of 4-PCH from carpet backed with both
composite latexes (A & B) is nearly identical. This
observation suggests that a partitioning process is occurring
between the carpet matrix and oven air. If this partitioning
phenomenon is correct, other factors such as air velocity may
well influence the rate at which 4-PCH is released from
carboxylated SBR latex.
The data presented in Figures 1 and 2 were collected at
an air exchange rate of three air exchanges per minute. Th
rate was selected on the basis of preliminary studies which
demonstrated no difference between 100% recirculated air (no
air exchange) and a relatively high exchange rate of three
per minute. Further, the latter air exchange rate did not
adversely influence the maintenance of oven temperature.
Actual Carpet Temperatures vs 4-PCH Release
In addition to oven temperature measurements, an Omega
TAC-80T thermocouple was inserted into the carpet tuft next
to the backing to monitor the change in carpet temperature
over the course of the sixty minute cure cycle. The data
detailed in Tables Ilia, Illb, and Hie and plotted in
N-8
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Figures 3a, 3b, and 3c describe the change in carpet
temperature and 4-PCH decay following placement of carpet
swatches in the curing oven at a preset oven temperature.
Initial studies of carpet coated with latex A revealed that
the carpet reached final oven temperatures, 225°F, 250°F, or
275°F, after approximately 20 minutes. At all preset oven v
temperatures, the rate of 4-PCH release demonstrated an
increase at a carpet temperature of approximately 175°F,
suggesting that this temperature level may be required to
induce a relatively constant initial rate of decay. As
described previously, however, higher 4-PCH decay rates were
noted at higher oven temperatures.
Since carpet temperature was not expected to be
influenced by the type of latex employed to coat the carpet
backing, the aforementioned set of experiments was not
repeated in its entirety for latex B. Rather, carpet
temperature change was evaluated only at 225°F. As shown in
Table Hid (Figure 3d), the rise in carpet temperature oven
time for latex B was essentially identical to that obtained
using latex A.
Relationship Between Carpet Moisture Loss and 4-PCH Release
The loss of moisture from carpet samples treated with
latexes A and B was essentially the same at all oven
temperatures tested (see Tables IVa-IVd and Figures 4a-4d).
Latex A treated carpet was evaluated at all three oven cure
N-9
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temperatures (225°F, 250°F, and 275°F). Latex B treated
carpet was tested at 225°F to validate an expected moisture
loss pattern. Interestingly, at all oven temperatures
tested, the maximum moisture loss occurred at 10 minutes,
reflecting a total loss of approximately 10% of the initial
carpet weight. Although the data in Figure 4a indicates an ^
increased decay rate of 4-PCH beginning at the same time
carpet moisture has been eliminated (that is, after 10
minutes), the data in the remaining figures (4b-4d) suggest
that an increased 4-PCH decay rate begins earlier, at
approximately five minutes, when approximately 50% of the
available carpet moisture has dissipated. It is difficult to
state then that moisture directly influences the rate of 4-
PCH release. Rather, the preponderance of the data (Figures
4b-4d) indicate that both moisture and 4-PCH are evolved as
temperature increases. As described earlier, a temperature
of 175°F may be required to initiate a relatively significant
and constant rate of 4-PCH decay.
Effect of Increased Air Velocity on the Release of 4-PCH
Although not part of the original experimental design, a
preliminary study to investigate the effect of high velocity
air lea. 1500 linear feet per minute, Ifm) on the release of
4-PCH from carpet coated with freshly compounded latex (that
is, latex A) was conducted at 225°F. During the cure cycle,
a relatively uniform air stream of 1500 Ifm was focused
N-10
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perpendicularly onto the tufted surface of a 5 inch square
piece of carpet. In previous experiments, the highest air
velocity over the surface of the carpet was approximately 45
Ifm which occurred automatically at 3 air exchanges per
minute.
The results of this study (see Figure 5) demonstrated $.
4-PCH decay rate significantly greater than that determined
for the control carpet sample which was not exposed to forced
air. The carpet sample exposed to the 1500 Ifm released
approximately 90% of the available 4-PCH in 10 minutes,
whereas the unexposed sample released less than 30% over the
same time period. It is also noteworthy that after only five
minutes, which represented the initial lag period in 4-PCH
release in this and previous experimental runs at 225°F to
275°F, that approximately 50% of the 4-PCH had already been
released from the carpet sample exposed to the 1500 Ifm air
velocity. This data is further suggestive that a
partitioning process is critical to the release of 4-PCH from
carpet and that this process is also enhanced by increased
air velocity over the carpet.
SUMMARY
The impact of various cure parameters including cure
temperature, cure time, carpet moisture, and air exchange
rate on the release of 4-phenylcyclohexene (4-PCH) was
evaluated with carpet backed with carboxylated SBR latex .
N-ll
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Higher oven cure temperatures were clearly demonstrated to be
a strong driving force in the removal of 4-PCH from carpet
backed with two representative composite latexes containing a
low and high 4-PCH level. Observations that the percent
removal of 4-PCH remains relatively uniform with both latex
composites (high and low) suggests that a partitioning
process takes place between the latex-carpet source and oven
air.
Initial studies to evaluate the impact of high velocity
air on the release of 4-PCH indicate that this parameter may
have a pronounced effect in reducing 4-PCH in carpet and,
therefore, deserves further study.
Since all data represent laboratory findings, any
correlation with commercial practice remains to be
established.
N-12
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Table I
Effect of Oven Temperature on 4-PCH Release
(Latex A, 3 air exchanges/minute)*
Time (minutes)
0
5
10
20
40
60
% 4-PCH
22LL
100
98
84
57
7
0
Remaining
250 F
100
96
71
22
1.4
0
-
221£
100
94
41
16
0.2
0
n « 6, standard deviation less then 15%
N-13
-------
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Table II
Effect of Oven Temperature on 4-PCH Release
(Latex B, 3 air exchanges/minute)*
Time (minutes)
0
5
10
20
40
60
22LL
100
95
80
58
13
0
250 F
100
100
70
25
1
0
Z22E
100
96
45
19
0
0
n - 6, standard deviation less then 15%
N-15
-------
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Table Ilia
Effect of 225 F Carpet Temperature on 4-PCH Release
(Latex A, 3 air exchanges/minute)*
Time (minutes)
0
5
10
20
40
60
Carpet TemDerWFC F
91
137
173
225
225
225
% 4-PCH Remaining
100
97
96
60
9
0
n - 6, standard deviation less then 15%
N-17
-------
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N-18
-------
Table Illb
Effect of 250 F Carpet Temperature on 4-PCH Release
(Latex A, 3 air exchanges/minute)*
Time (minutest
0
5
10
20
40
60
Caroet Temperature F
90
178
208
246
250
250
% 4-PCH Remaining
100
98
74
22
1
0
' n 6, standard deviation less then 15%
N-19
-------
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N-20
-------
Table IIIc
Effect of 275 F Carpet Temperature on 4-PCH Release
(Latex A, 3 air exchanges/minute)
Time (minutes)
0
5
10
20
40
60
Carpet Temperature f
90
168
179
254
267
267
% 4-PCH Remaining
100
86
40
17
0
0
n » 6, standard deviation is less then 15%
N-21
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N-22
-------
Table Hid
Effect of 225 F Carpet Temperature on 4-PCH Release
(Latex B, 3 air exchanges/minute}*
Time (minutes)
0
5
10
20
40
60
Carpet Temperature F
100
139
190
225
225
225
%4-PCH Remaining
100
98
96
62
15
1
n » 6, standard deviation less than 15%
N-23
-------
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N-24
-------
Table IVa
Relationship Between Carpet Moisture Loss and 4-PCH Release, 225 F
(Latex A, 3 air exchanges/minute)*
Time (minutes)
0
5
10
20
40
60
% Starting Weight
100
94
91
90
90
90
% 4-PCH Remaining
100
97
94
60
9
1
* n 6, standard deviation less than 15%
N-25
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N-26
-------
Table IVb
Relationship Between Carpet Moisture Loss and 4-PCH Release, 250 F
(Latex A, 3 air exchanges/minute)
Time (minutes)
0
5
10
20
40
60
% Starting Weight
100
94
90
90
90
90
% 4-PCH Remaining
100
98
74
22
1
0
* n « 6, standard deviation less than 15%
N-27
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N-28
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Table IVc
Relationship Between Carpet Moisture Loss and 4-PCH Release, 275 F
(Latex A, 3 air exchanges/minute)
Time (minutes)
0
5
10
20
40
60
% Starting Weight
100
94
90
90
90
90
% 4-PCH Remaining
100
86
40
17
0.2
0
* n « 6, standard deviation less than 15%
N-29
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N-30
-------
Table IVd
Relationship Between Carpet Moisture Loss and 4-PCH Release, 225 F
(Latex B, 3 air exchanges/minute)
Time (minutest
0
5
10
20
40
60
% Starting Weight
100
98
91
90
90
90
% 4-PCH Remaining
100
98
81
61
11
1
* n * 6, standard deviation less than 15%
&
N-31
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N-32
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N-33
-------
REFERENCES
1. Van Ert MD, Clayton JW, Crabb CL, Walsh DW:
Identification and Characterization of 4-
Phenylcyclohexene - An Emission Product from New
Carpeting. Presented at the 1987 Am Ind Hyg Conference,
Montreal, Canada, June 1, 1987.
2. Demer, Frank R: The Impact of Various Cure Parameters on
the Release of 4-Phenylcyclohexene From Carboxylated
Styrene Butadiene Rubber Latex. M.S. Thesis, Univ. of
Arizona, Dept. of Pharm. & Tox. 1989.
N-34
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APPENDIX I
N-35
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PREPARATION OF CARPET BACKED WlT^f
STYPfiNE-BUTADIENE RUBBER lA^EX
10/30/89
1.0 INTRODUCTION
1.1 Purpose of the Standard Operating Procedure
The purpose of this SOP is to define the methodology for the preparation of
styrene-butadiene rubber latex backed carpet.
1.2 Sources of the Method
1.2.1 VCR tape recorded at GENCORP laboratory.
1.2.2 Research Proposal for Investigating the Impact of Various Cure
Parameters on the Release of 4-Phenylcyclohexene from Styrene-
Butadiene Rubber Latex by Frank R. Demer.
1.3 References
1.3.1 VCR tape recorded at GENCORP laboratory.
1.3.2 Research Proposal for Investigating the Impact of Various Cure
Parameters on the Release of 4-Phenylcyclohexene from Styrene-
Butadiene Rubber Latex by Frank R. Demer.
1.4 Principles of the Method
1.4.1 Carpet made by standard procedures applicable to industry.
1.4.2 Samples prepared for gas chromatography analysis for 4-PCH content.
2.0 APPLICABILITY
This method shall be used for the preparation of standardized carpet samples for
use in further research.
3.0 DEFINITIONS
(a) 4-PCH * 4-phenylcyclohexene
(b) 1-PCH » 1-phenylcyclohexene
(c) SBR - styrene-butadiene rubber
(d) SBLMC » Styrene Butadiene Latex Manufacturer's Council
(e) Filler - Whiting 200D, calcium carbonate (Georgia Marble)
(f) Frothing agent - Southern Chemical 391
(g) Thickener Paragum 165
(h) Carpet - 26 oz. nylon 6:6 pile Saxony
(i) Secondary backing Amoco 3.2 oz. polypropylene
(j) GC « gas chromatography
N-36
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4.0 RESPONSIBILITIES
4.1 The Project Director will be responsible for the determination and implementation
of appropriate laboratory procedures.
4.2 The Internal Quality Assurance Officer will be responsible for insuring the
proper conduct of these procedures, and for periodically reviewing their
performance.
4.3 The Laboratory Technician will be responsible for the preparation of carpet
samples and the analyses of those samples according to the procedures specified
in this SOP.
5.0 EQUIPMENT
5.1 Materials
(a) 26 02. nylon 6:6 pile Saxony
(b) Secondary backing
(c) 10" x 10" carpet frames
(d) 3/4" metal latex roller
(e) 1 1/2" metal carpet roller
(f) Pyrex Desiccator
(g) Desiccant
(h) 16 ml. reaction vessels
(i) Reaction vessel septa, caps
(j) Hamilton Series 700 lOul syringes
(k) 32 oz. plastic cups with lids
(1) 20 oz. plastic cups
(m) 10 oz. plastic cups
(n) 3.2 oz. plastic cups
(o) Oxford repipettor
(p) rubber spatula
(q) 10" by 10" plexiglass square pattern
5.2 Instrumentation
(a) Brookfield Portable Viscosity Meter; Model RVT
(b) Sartorius Series U Balance; Model U6100D or equivalent
(c) Fisher Isotemp Oven; Model 496
(d) Lightning Variable Speed Mixer; Model DS3004 or equivalent
(e) Kitchen Aid 10 Speed Commercial Mixer; Model Ultra Power, 10 speed
(f) Computing Integrator (JCL6000 or equivalent)
(g) Hewlett Packard Gas Chromatograph 5890A
(h) Hewlett Packard Integrator 3390A
(i) T Thermocouple and Millivolt Converter, OMEGA Engineering, Inc.
(j) Millivolt Voltmeter (digital)
5.3 Reagents
(a) Carbon Disulfide, reagent grade
(b) Gas Cylinders for GC
(c) Latexes A & B
(d) DD Water
(e) Whiting 200D Georgia Marble filler
(f) SCT 391 Froth Aid
(g) Paragum 165 thickener
(h) 4-PCH standard, 1-PCH standard
N-37
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6.0 STANDARD OPERATING PROCEDURE
6.1 Prior preparations
6.1.1 Glassware
(a) Prior to analysis, clean all glassware used to prepare
standards, and all reaction vessels, caps, and septa with an
approved laboratory cleaning solution.
(b) Rinse all cleaned glassware 3 times with double-distilled
water.
6.1.2 1 -PCH Internal Standard
(a) Low Sensitivity Standard - add 7.5 ul of 1-PCH standard to 500
ml of carbon disulfide, to give a 1-PCH concentration of 94.13
nmol/ml. Store refrigerated in brown bottle.
(b) High Sensitivity Standard - add 1.8 ul of 1-PCH standard to 500
ml of carbon disulfide, to give a 1-PCH concentration of 22.6
nmol/ml. Store refrigerated in brown bottle.
6,1.3 4-PCH Standard Solutions
6.1.3.1 Prepare stock 4-PCH standard solution by adding 4 ul of
pure 4-PCH to 4 ml carbon disulfide to make a stock
standard solution of 6351 nmols/ml.
6.1.3.2 Use the 1-PCH internal standard solution and the 4-PCH
stock standard solution to prepare working 4-PCH
standard solutions.
(a) 1.57 nmoles 4-PCH/ml working standard solution
prepared by mixing 0.50 ul of stock standard 4-
PCH to 2 ml internal standard solution (6.1
(b) 3.15 nmoles 4-PCH/ml standard solution prepared
by mixing 1.00 ul of 4-PCH to 2 ml internal
standard solution.
(c) 9.45 nmoles 4-PCH/ml standard solution prepared
by mixing 3.00 ul of 4-PCH to 2 ml internal
standard solution.
(d) 15.75 nmoles 4-PCH/ml standard solution prepared
by mixing 5.00 ul of 4-PCH to 2 ml internal
standard solution.
(e) 22.05 nmoles 4-PCH/ml standard solution prepared
by mixing 7.00 ul of 4-PCH to 2 ml internal
standard solution.
(f) 31.50 nmoles 4-PCH/ml standard solution prepared
by mixing 10.00 ul of 4-PCH to 2 ml internal
standard solution.
N-38
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6.2 Preparation of SBR Latex
6.2.1 Mix latex thoroughly and weigh out appropriate amount into tared 32
oz. cup (See Appendix A).
6.2.2 Add appropriate amount of DD water (See Appendix A).
6.2.3 Mix thoroughly with the Lightning Mixer at 500 rpm for 2 minutes.
6.2.4 Add appropriate amount of calcium carbonate filler slowly while
mixing at 700 rpm (See Appendix A). Continue mixing for 5 more
minutes to completely wet filler.
6.2.5 Tare 32 oz. cup again and add appropriate amount of froth aid (See
Appendix A).
6.2.6 Mix at 900 rpm for 30 seconds.
6.2.7 Tare 32 oz. cup again and add appropriate amount of thickener (See
Appendix A).
6.2.8 Mix at 900 rpm for 5 minutes.
6.2.9 Check viscosity with the Brookfield Viscosity Meter.
6.2.9.1 Attach *5 spindle to viscosity meter and set speed on
20 rpm.
6.2.9.2 Fill 10 oz. tared cup about half full with latex
mixture.
6.2.9.3 Place cup under meter and lower spindle until the top
of the latex mixture just reached the notch around the
spindle.
6.2.9.4 Turn viscosity meter on and allow to run for 1 minute,
or until reading stabilizes. If longer than 2 minutes,
check setting.
6.2.9.5 Record number on viscosity dial and multiply by factor
from conversion table supplied by Brookfield (200) to
get viscosity reading in centipoises.
6.2.10 Add latex mixture to 10 oz. tared cup until the weight in the cup is
500 grams.
6.2.11 Scrape latex mixture out of cup and into stainless steel bowl of
Kitchen Aid mixer.
6.2.12 Whip mixture with wire whip at highest speed for appropriate time,
then at lowest speed for 1 minute (See Appendix A).
6.2.13 Fill 3.2 oz tared cup with frothed latex mixture, tapping cup gently
to remove air bubbles.
6.2.13.1 Weigh the latex mixture in the tared cup.
N-39
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6.2.13 (continued)
6.2.13.2 Multiply amount by 9.7 (in the case of this 3.2 02. cup)
to get weight of frothed latex mixture per quart.
6.2.14 If the mixture weighs 800 grams/quart (+ 25 grams), continue ro
6.2.15.
6.2.14.1 If the mixture weighs less than 775 grams, continue to
6.2.15, check viscosity. If within range continue.
6.2.14.2 If the mixture weighs more than 825 grams, froth for 5
seconds more at high speed, then 1 minute more at lowest
speed.
6.2.14.3 Repeat step 6.2.13.
6.2.14.4 If the mixture weighs 800 grams/quart (± 25 grams),
continue to 6.2.15.
6.2.14.5 If the mixture still weighs more than 825 grams, keep
repeating step 6.2.14.1 and 6.2.14.2 until it reaches
800 grams/quart (+ 25 grams).
6.2.14.6 If the mixture now weighs less than 775 grams/quart,
continue to 6.2.15.
6.2.15 Check the viscosity of the latex mixture.
6.2.15.1 Attach the *6 spindle to the viscosity meter.
6.2.15.2 Place the 3.2 02 cup filled with the frothed latex
mixture under the meter and lower spindle until the
notch just meets the top of the latex mixture.
6.2.15.3 Allow the meter to run at 20 rpm for 30 seconds.
6.2.15.4 Record the number from the meter dial and multiply by
number from chart (500) to get viscosity in
centipoises.
6.2.15.5 If the viscosity is between 20,000 and 27,000
centipoises, the procedure may be continued and latex
used in the preparation of the carpet. If the viscosity
is not between these limits, the latex mixture must be
discarded and a new batch prepared, starting from 6.2.
N-40
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6.3 Applying the latex mixture to the carpet
6.3.1 Mark a 10" by 10" square in black indelible Sharpie marker on the back
of a 12" by 12" piece of carpet, using the plexiglass pattern.
6.3.2 Attach carpet to carpet frame by stretching and impaling the marked
carpet on top of the nails, tuft side down, aligning the nails along
the top and bottom of the square marked on the carpet back, and
centering the marked sides so they are equidistant on each side of
the nails. (The extra piece of wood that makes up the carpet frame
should be in place between the two rows of nails, underneath the
carpet sample.)
6.3.3 Place the 1/2" roller on top of the carpet, between the two rows of
nails, flush against the top nails.
6.3.4 Weigh the tared 3.2 oz. cup filled with the frothed latex mixture,
and remove latex until the cup contains 71 grams of latex mixture.
Record exact amount of latex mixture in cup.
6.3.5 Spread the latex mixture evenly along the bar, on the carpet, on the
side of the bar opposite to the nails. Record weight of latex mixture
left in cup, and determine exact amount applied to carpet.
6.3.6 Grasp bar, placing thumbnails just below bar, thumbs touching
carpet, on vertical black lines.
6.3.7 Drag bar toward you, applying no pressure to the bar other than its
own weight, keeping thumbnails along black line, so that the latex
mixture does not go outside of the black lines, and is applied onto
the carpet.
6.3.8 When bar is within 1" of nails at bottom, spin bar such that latex
mixture is carried upward and around until it is on side of bar
opposite to nails, and bar is flush against bottom nails. Spread
excess latex mixture evenly along bar.
6.3.9 Push bar away from you, toward top nails, using index fingernails to
keep latex mixture within black vertical lines, and again applying
no pressure to the bar other than its own weight.
6.3.10 When bar reaches within 1" of top nails, spin bar again, carrying
latex mixture upward and around until it is on side of bar opposite
to nails, and bar is flush against top nails. Spread excess latex
mixture evenly along bar.
6.3.11 Continue until no excess latex mixture remains on bar (1 or 2 times
more if necessary).
6.3.12 Place 12" by 12" piece of carpet backing, fuzzy side down, so that one
side is just below top set of nails, and sides are even with sides of
carpet.
6.3.13 Gently press down carpet backing and attach evenly to bottom nails.
6.3.14 Using heavy, 1 1/2" bar, roll the 10" by 10" square from the bottom
nails up to top nails.
N-41
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6.3.14 (continued)
6.3.14.1 The first roll should have no pressure applied, other
than weight of bar.
6.3.14.2 The second roll should have slight pressure applied to
the bar.
6.3.14.3 The third roll should have no pressure applied, other
than weight of bar.
6.3.15 Carefully remove the completed carpet piece from the frame. Trim
along the black lines, producing a 10" by 10" piece.
6.3.16 The standardized piece of carpet has been now been prepared, and may
be used as desired in the experiment.
7.0 RECORDS
7.1 Data Collected by this Procedure
7.1.1 Datasheets
7.1.1.1 Data Sheets are prepared for both Latex A and Latex B,
with the recipe (appropriate amounts) for each type of
latex written on the appropriate sheet (see Appendix
A).
i
7.1.1.2 Each sheet also has blank spaces so that the actual
amount used can be recorded. There are also spaces to
record viscosity data, and weights determined
throughout the process.
7.1.1.3 All information pertaining to the preparation of this
batch of latex should be recorded on this sheet, and
the sheet dated.
7.2 Location/Placement of Record Forms
7.2.1 Each day's data sheet should be placed in a manila folder, marked
with the name of the experiment and the date, and kept in the file
cabinet. The gas chromatograph data and all computer data using this
batch of carpet will also be kept in this same file.
N-42
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ATTACHMENT N-l
Preparation of Carpet Backed with
Styrene-Butadiene Rubber Latex
-------
Appendix A
Note that the two data forms are different, one is for Latex A and one is for Latex B.
N-l-l
-------
Date
Latex A
Latex
Water
Whiting 200D
SCT 391 Frothaid
Paragum 165
Compound Solids
Initial Viscosity
Latex Compounding Data Sheet*
Froth
time (sec)
cup weight
(per quart)
Viscosity
Drv
100.00
450.00
2.00
1.21
82%
Wet
187.00
20.00
450.00
5.71
9.3
Factor/Batch
Total Weight
Adapted from GENCORP Potymtr Product*. 0«Uon, GA
N-l-2
-------
Date
Latex B
Latex
Water
Whiting 200D
SCT 391 Frothaid
Paragum 165
Compound Solids
Initial Viscosity
Latex Compounding Data Sheet*
Froth
time (sec)
cup weight
(per quart)
Viscosity
Drv
100.00
450.00
2.00
0.75
82%
Wet
185.00
26.00
450.00
5.71
5.80
Factor/Batch
Total Weight
Adapt td from GENCOftP Polymr Products, Oil ton, GA
N-l-3
-------
APPENDIX O
Effects of Selected Process Parameters
On Emission Rates of TVOC From Carpet
-------
Effects of Selected Process Parameters
On Emission Rates of TVOC From Carpet
N. C. Hawkins (The DOW Chemical Company)
J. A. LoMenzo (Ciba-Geigy Corporation)
A. E. Luedtke (E.I. Du Pont De Nemours & Co., Inc.)
C. R. Mitchell (Shaw Industries, Inc.)
ABSTRACT
A study with the objective of evaluating VOC as a function of process variables has been completed.
The focus was on four factors associated with application of the secondary backing to the carpet (finishing). A
statistically designed experiment provided derivation of reasonable models relating TVOC to these process
variables. It was noted that the actual range of TVOC encountered at 24 hours was not particularly wide
considering the test design. In addition, the emission rates for all samples dropped to relatively low levels in 24
hours. This is consistent with data obtained in other studies. Finally, the results of the study do not indicate
much opportunity for major reductions in TVOC levels via these process variables.
January 1991
O-i
-------
Effects of Selected Process Parameters
on Emission Rates of TVOC From Carpet
This study was undertaken in an effort to develop an understanding of the effects of manufacturing
process variables on VOC emission rates from carpet. The project was sponsored by four companies - Shaw
Industries, Ciba-Geigy, Dow Chemical, and Du Pont. The significant feature of this particular group is that it
consists of a carpet mill and three suppliers of many of the raw materials needed for making a carpet; i.e., a
dye manufacturer, latex producer, and a fiber producer.
The study employed an experimental design methodology which required the controlled manufacture of
test items (carpets). The items were defined around a few key process variables and fit into a statistical design
framework.
The first step toward the design of the experiment involved discussion of all the conceivable variations
possible in the manufacture of a carpet. These ranged from fiber type to dyeing processes to finishing steps.
Over 100 variables were identified.
In order to have a manageable test design, it was necessary to reduce the number of variables. This
was accomplished by applying the collective understanding of the study participants to their respective products
and processes. The net result was the identification of four process variables around the finishing line - the last
processing steps the carpet undergoes before wrapping.
The four variables studied were latex type, latex loading (coating weight per unit area of carpet), oven
make up air, and oven residence time. Latex types were selected due to known composition differences. Oven
make up air and oven residence time were studied because of their anticipated impact on the curing of the latex.
The actual experiment was based upon a two level factorial design (Figure 1). The process conditions
(levels) were selected at high and low extremes. Center points were also included in this study and were chosen
at or near normal operating conditions - these were replicated. The design, therefore, called for a total of 20
test items.
In this study the extremes were chosen as near the edge of manufacturing operability as possible
without producing defective carpet. The extremes for residence time were set at +1-25% of normal operating
conditions - at shorter times not all of the items could be cured and at longer times the risk of affecting the
coloration of the carpet was increased. The low for make up air was near the minimum necessary to adequately
remove water vapor from the oven, while the high was just below the point of blowing out the natural gas
burners. The latex loading varied from +M0% of the normal coating weight used for a carpet. This variation
was selected because the lower weights did not provide a viable carpet (i.e., inadequate adhesion of the
secondary backing). At higher latex loadings, some of the test items could not be cured at the extremes of other
process variables.
There is one additional note relative to the test carpets representing center points. It was opted to run
these items at the "high* for make-up air. The normal setting used in day to day operations was found to be
fairly close to the high extreme used in the test.
The test carpet and process line used in the study are characterized as typical. The substrate for this
experiment represents a commonly used carpet design and construction - Nylon-66 fiber, beige color, cut pile,
treated with stain and soil resist agents, and polypropylene primary and secondary backings. The process line is
O-l
-------
an older line; ca. 20 years old. It has been upgraded over the years with current technology, so the
performance should be similar to the majority of finishing lines in use.
The actual manufacture of the items was in a random fashion, with the exception of latex type (see
Table 1). It was necessary to block the items on latex type due to the practical limitations of trying to make
rapid latex batch changes on a commercial carpet line. The experiment was conducted on two separate days.
Each sample set was manufactured from a single batch of latex.
Careful consideration was given to when and how the samples for emissions testing were collected.
After each process change required in the design, 1,000 linear feet of carpet were run through the finishing line
to allow adequate time for the system to stabilize. At the end of the 1,000 ft, two 2' by 12' samples,
representing the full width of the carpet, were immediately collected. These were wrapped in layers of
polyethylene, aluminum foil, and polyethylene. One test sample was retained by the carpet mill, and the other
was delivered to Air Quality Sciences, Inc. (AQS) for analysis.
The actual emission rate data was obtained via small environmental chambers. The conditions of the
acquisition are typical of those currently used for carpet - 0.42 mVm1 loading factor, 25 deg. C., 50% RH, and
1 ACH. VOC were trapped on an adsorbent over two hour intervals starting at 1 hour and at 24 hours after
introduction into the chamber. The qualitative and quantitative analysis was via GC/MS using the protocol
developed by AQS. The raw TVOC rate data is reported in Table 2 at 1 hour and 24 hours in mg/rrfh.
Noted in the raw data was that sample #5 and sample )W> have considerably higher one hour emission
rates than the rest of the samples. Recall that #6 is one of the center points and has a replicate #10. AQS
performed a duplicate analysis of sample #6 and obtained a TVOC emission rate more consistent with the other
samples. A third analysis was conducted on the sample of #6 retained by the carpet mill - this also provided a
TVOC value which was more consistent with the rest of the data. The high values for #5 and #6 were found to
be the result of an unusually high 2-butoxyethanol contribution to TVOC.
It is not clear why 2-butoxyethanol was so prevalent in these two samples. Subsequent analysis did
determine that 2-butoxyethanol was in one of the products used by the carpet mill to formulate the latexes
before application. Nonetheless, it is difficult to argue that the high levels observed in samples #5 and #6 were
a result of the manufacturing process. For example, 1) both H5 and #6 were a result of the manufacturing
process. For example, 1) both #5 and #6 were manufactured from the same latex batch as the other eight items
in this set; 2) 2-butoxyethanol was not seen in anywhere near the same levels in the one hour emission rates for
the other samples; 3) replicate analysis of #6 did not reveal high levels of 2-butoxyethanol; 4) the 24 hour
emission rates for #5 & #6 are reasonable (2-butoxyethanol is a very minor component); 5) the boiling point of
2-butoxyethanol is 171 "C, so it seems unlikely that the levels seen in #5 & )K6 could drop to comparable levels
to the rest of the samples in only 24 hours; and 6) the precautions taken in handling and storage of these
samples make it unlikely that large quantities of 2-butoxyethanol could have been lost on standing.
Two key observations can be made from the raw data. The first is the significant drop in emission rate
from one hour to 24 hours - 0.779 mg/irfh to 0.071 mg/m^h (averages) or about 90%. The 24 hour mark may
be closer to the emission rate most consumers will first encounter after installation of a carpet. Also, the
collection process - tightly enclosed samples taken immediately off the finishing range - is anticipated to provide
a worst case emission profile. The second observation is relative to the narrow range of the 24 hour rates. In
this particular experiment the difference between high and low 24 hour emission rates was 0.175 mg/nrfi,
despite running the manufacturing processes as near to the limits of operability as feasible.
Although some simple observations can be made from the raw data, the primary value of an
experimental design comes from statistical analysis. The modeling for this study was via multiple regression
analysis, which treated TVOC as the outcome variable. The predictor variables were oven residence time, oven
make up air, latex 'coating weight", and latex type. This approach also provides the opportunity to evaluate
0-2
-------
interactions between the variables (cross terms); i.e., whether they may be interacting synergistically or
antagonistically.
The models shown in Table 3 illustrate the outcome of the regression analysis. TVOC is shown as a
function of the significant (alpha = 0.05) process variables and cross terms. Reported with the models are R1
values. R1 is a reflection of the goodness of fit of the data to the model. An R1 of 1.0 signifies a perfect fit
and an R1 of 0.0 reflects no relationship between the chosen variables.
The R1 values for the one hour and 24 hour models were 0.58 and 0.77 respectively. This indicates
that the models account for a fair amount of the variance in the data set. The important predictor variables are
make up air and oven residence time. Cross terms with make up air and oven residence time also stand out as
important. [Note, the one hour data for sample #6 was treated as an outlier and not used in the one hour
model.]
Another way of representing relationships is through the use of contour plots. Figure 2 illustrates the
response of TVOC to make up air and oven residence time. Note, that the normal operating range for residence
time and make-up air for this process line lies in the upper half of center on the plot. Also recall, the extremes
on the plot are approaching the limits of operability. Thus, the data indicates there is relatively little
opportunity to significantly reduce TVOC on this finishing line with these process variables without increasing
the risk to final product attributes.
The broader application of the previous statement to other process lines would, of course, be
speculative. Nonetheless, it is important to consider three points: 1) the process line employed in the study is
typical of equipment available to the trade; 2) carpet manufacturers are using products from a relatively small
number of suppliers; and 3) despite the physical differences in various process lines, they are set up to take the
carpet to a similar endpoint - ie., a cured latex (primarily removal of water). Hence, product TVOC
differences between finishing lines would not be predicted to be great.
In summary, a study has been completed with the objective of evaluating VOC as a function of process
variables. The focus was on four factors, all associated with the finishing line. A statistically designed format
provided derivation of reasonable models relating TVOC to these process factors. It was noted that the actual
range of TVOC encountered at 24 hours was not particularly wide considering the test design. In addition, the
emission rates for all samples dropped to relatively low levels in 24 hours. This is consistent with data obtained
in other studies. Finally, the results of the study do not indicate much opportunity for major reductions in
TVOC levels via these process variables.
O-3
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FIGURE 1
Experimental Design
Latex A
Latex B
Coating Wt. |»3 E3 ' Coating Wt.
Residence Time Residence Time
O-4
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TABLE 1
ACTUAL STUDY DESIGN USED IN EXPERIMENT
Sample
Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Res.
Time
Low
High
Low
Low
Low
Middle
High
High
High
Middle
High
Low
Middle
Low
High
High
Middle
Low
Low
High
Latex
Level
Low
Low
Low
High
High
Middle
High
High
Low
Middle
High
Low
Middle
High
Low
High
Middle
Low
High
Low
MakeUp
Air
Low
High
High
High
Low
High
Low
High
Low
High
High
High
High
High
Low
Low
High
Low
Low
High
Latex
Type
A
A
A
A
A
A
A
A
A
A
B
B
B
B
B
B
B
B
B
B
O-5
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TABLE 2
RAW EMISSION RATE DATA
mg/m2 h
SAMPLE 1 HOUR 24 HOUR % REDUCTION
1 0.804 0.070 91
2 0.236 0.014 94
3 0.500 0.093 81
4 0.481 0.063 87
5 1.980 0.188 91
6 3.040* 0.071 97
7 0.302 0.056 81
8 0.350 0.063 82
9 0.288 0.061 79
10 0.156 0.027 83
11 0.343 0.053 85
12 0.693 0.111 84
13 0.397 0.067 83
14 0.386 0.069 82
15 0.693 0.085 88
16 0.881 0.088 90
17 0.973 0.088 91
18 1.200 0.168 86
19 1.190 0.162 86
20 0.690 0.050 93
Ave. 0.779 0.071
Std. Dev. 0.687 0.042
"Replicate analyses of #6 provided TVOC values of 0.638 & 0.227 mg/nfli
O-6
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TABLE 3
FITTED REGRESSION MODELS
ONE HOUR RATES
TVOC = 0.695 - 0.222(AIR) - 0.215(RES. TIME) + 0.161(AIR)(RES.TIME)-
R2 = 0.58
24 HOUR RATES
TVOC = 0.087 - 0.023(AIR) - 0.028 (RES. TIME) - 0.012(LATEX) + 0.015(AIR)(LEVEL)(RES. TIME)
R2 « 0.77
* Cross term was close to Alpha = 0.05 significance level
O-7
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FIGURE 2
TVOC RESPONSE TO OVEN RESIDENCE TIME & "AIR" AT 24 HOURS
1 .0
-l.Q
-1.0
RESIDENCE TZHE
UNITS - ag/a2h? STD OEV. OF REGRESSION 0.030
i .0
0-8
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APPENDIX P
CRI Commercial Carpet Installation Standard
-------
COMMERCIAL '
A **y ^v » ^KB m ^^ v m~ «i^v r Z^ J
CARPET INSTALLATION STANDARD
THE CARPET AND RUG INSTITUTE
STANDARD
for INSTALLATION of
COMMERCIAL
TEXTILE FLOORCOVERING
MATERIALS
CRI 104 - 1991
-------
COMMERCIAL
CARPET INSTALLATION
STANDARD
CRI 104 1991
STANDARD FOR
INSTALLATION OF COMMERCIAL TEXTILE FLOORCOVERINQ MATERIALS
1991
ISBN * 0-89275-010-3
Copyright© 1991
Th« Carptt tnd Rug Inttttutt
P. O. Box 204«
Dtlton, Georgia 30722-204*
(404) 27S-3176
-------
Commercial Carpet Installation Standard
Table of Contents
age
Notice P-ii
Forward P-iii
Section
1. Scope P-l
2. Applicable Documents P-l
3. Definitions of Terms P-l
4. Tools and Materials P-4
5. Storage and Handling P-4
6. Site Conditions P-5
7. Planning and Layout P-7
8. Direct Glue-Down P-8
9. Double Glue-Down P-10
10. Attached Cushion P-12
11. Stretch-in Utilizing Tackless Strip P-13
12. Carpet on Stairs P-16
13. Carpet Modules (Tiles) P-17
14. Installation of Outdoor Carpet and Synthetic Turf P-18
15. Protection of Installation P-20
Tables
I. Tools P-21
H. Materials P-22
HI. Adhesives P-23
IV. Trowel Size P-24
V. Tackless Strip P-25
Figure
1. Tufted, Stretch Diagram P-27
2. Wilton or Velvet, Stretch Diagram P-28
3. Axminster, Stretch Diagram P-29
CRI Publications P-30
P-i
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NOTICE
The Carpet and Rug Institute assumes no responsibility and accepts no liability for
the application of the principles or techniques contained in this standard. Specifying
authorities have the responsibility of reviewing ail applicable federal, state and local
statutes, ordinances, and regulations.
P-ii
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FOREWORD
This oubfication. a voluntary minimum standard for the installation of commercial
textile fioorcovenngs. is based on reliable installation principles and procedures developed
through practical experience, research, and information obtained from carpet manufac-
turers, retailers, installers, end users, testing laboratories, and others with specialized
experience in the field.
This publication does not include carpet performance characteristics. Users are urged
to review appropriate publications developed by the Carpet and Rug Institute for guidance
m selecting and specifying carpet.
For standards applicable to the installation of residential carpet, please refer to the
Carpet and Rug Institute publication CRI 105. "Standard Reference Guide for Installa-
tion of Residential Textile Floorcovenng Materials."
P-iii
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CRI STANDARD 104
STANDARD PRACTICE FOR
INSTALLATION OF COMMERCIAL TEXTILE PLOORCOVERING MATERIALS
1. SCOPE
1.1 This standard covers the installation of textile floorcovermg materials over subfloor
and the preparation of the subfloor prior to installation.
1.2 This standard covers the installation of all textile floorcovermg materials for all methods
of manufacture including carpet modules.
1.3 This standard establishes industry minimum installation procedures. These procedures
shall not be decreased.
1.4 This standard may be changed only by specific recommendations from the manufac-
turer of the products to be installed.
2. APPLICABLE DOCUMENTS
2.1 Standard for Installation of Residential Textile Floorcovering Materials - CRI 105
The Carpet and Rug Institute
2.2 Carpet Specifier's Handbook The Carpet and Rug Institute
2.3 How to Specify Commercial Carpet Installation - The Carpet and Rug Institute
2.4 Areas of Responsibility The Carpet and Rug Institute
3. DEFINITIONS OF TERMS
Adhesive, n. A substance which dries to a film capable of holding materials together
by surface attachment.
Alkali, n. - A soluble substance with basic properties and having a pH of more than 7
Attached Cushion, n. Cushion material permanently bonded to the back of carpet and
rugs by the manufacturer. Often made of synthetic rubber foam or polyurethane foam.
Axminsttr Carpet, n. Carpet woven on Axminster loom by which pile tufts are individually
inserted from varied colored yarns arranged on wide spools. This process makes
it possible to produce carpet and rugs of complex designs with many colors, such
as Oriental design rugs.
p-i
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Baseboard, n. - A board skirting the lower edge of a wall, covering the joint of the A
and the adjoining floor.
Birdcage, n. - Common term used to describe the end of a stair rail where the Danis;
are curved in a spiral to form a newel post.
Bullnose, n. - Common term used for step return.
Carpet Cushion, n. - A term used to describe any kind of material placed under carpet
to provide resiliency, support and noise absorption when walked upon Aiso
referred to as carpet lining, padding or underlay, although "carpet cushion" >s the
preferred industry term.
Carpet Modules, n. Carpet packaged as squares, generally 18 inches by 18 inches
(457 x 457 mm) with or without attached cushion backing. Also referred to as
"carpet tiles."
Custom Carpet, n. - A carpet or rug manufactured in a special size, shape, color, design
or width through a number of tufted or woven manufacturing processes.
Double Glue-Down, n. An installation method whereby the carpet cushion is first adhered
to the floor with an adhesive, and the carpet is then adhered to the cushion by an
adhesive.
Glue-Down, n. An installation method whereby the carpet is adhered to the floor with
an adhesive.
Gully, n. - The distance between tackless strip and the wall. It should always be slightly
less than the thickness of the carpet.
Knee-Kicker, n. - An installation tool designed to position loose carpet and move it onto
the tackless strip. The leading edge of the kicker should be on the surface of
carpet and on the tackless strip to hook and force carpet backing onto the p
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and floors.
Rcstretch, v. - Term used to describe stretching carpet after original tackiess mstaiia-
fon to remove wrinkles, bubbles, or to correct loose fit.
Riser, n. - The upright part of a step between two stair treads.
Seam. n. : In a carpet installation, the line formed by joining the edge of two pieces of
carpet by the use of various seaming tapes, hand sewing or other techniques
Seam Adhesive, n. - A specifically formulated adhesive for securing cut edges of carpet
to be seamed. Specialized products are necessary for either direct glue-down
attached cushion, or stretch-m over a cushion installation. Its use will help prevent
raveling and delamination at seam edges.
Seaming Tape, n. Fabric tape used for joining two sections of carpet. "Hot melt taoe
is precoated with a thermoplastic adhesive. For other tapes, the adhesives are ap-
plied separately.
Secondary Backing, n. Woven or nonwoven fabric reinforcement laminated to the back
of tufted carpet usually with an adhesive to enhance dimensional stability, strength
stretch resistance, and ease of handling.
Selvage (Selvedge), n. The factory-finished edge of a carpet.
Set-Up Time, n. The required drying time whereby adhesive will no longer transfer
whenever pressure sensitive or contact cements are used.
Shoe Molding, n. Wood or plastic strip with one corner edge rounded slightly It is
used to conceal joints between walls and floors, or between larger moldings and
floors.
Stretch-In, n. - Installation procedure for installing carpet over separate cushion using
a tackiess strip.
Tackiess Strip, n. Wood or metal strips fastened to the floor near the walls of a room
containing either two or three rows of pins angled toward the walls on which the
carpet backing is stretched onto and secured in a stretch-in installation.
Textile Floorcoverlng Material, n. General description used for carpet, rugs, etc
Threshold, n. The raised board beneath a door, also known as a "door sill" or "saddle
100% Transfer, n. The full coverage/transfer of the carpet floor adhesive into the
carpet backing, including the recesses of the carpet back, while maintaining full
coverage of the floor.
Tread, n. « The horizontal part of a stair and that part which is walked on.
Tufted Carpet, n. Carpet manufactured by the tufting process, a method by which pile
yams are inserted into a primary backing fabric by a row of eyed needles.
Unitary Carpet, n. - Carpet used for glue-down installations which has an application
of high quality backcoating latex to increase tuft bind performance properties
without the addition of a secondary backing.
Velvet Carpet, n. - Carpet woven on a velvet loom. Velvet carpet is typically cut pile or
level loop in solid or tweed colorings, though textured and patterned effects are
possible.
Vinyl Plastteizer, n. - A substance incorporated into vinyl to increase its flexibility, workabili-
P-3
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ty. or extensibility (capable of being extended).
Wilton Carpet, n. - Carpet woven on a loom with a Jacquard mechanism which
a series of punched cards to select pile height and yarn color. The Wilton
produce carpet with complex multicolor patterns and highly textured pile surfaces
of multilevel cut and looped yarns.
Woven Carpet, n. - Carpet produced on a loom through a weaving process by «h:cr>
the lengthwise (warp) yarns and widthwise (weft or filling) yarns are interlaced to for-n
the fabric. Carpet weaves such as Wilton, Axmmster and velvet are complex.
often involving several sets of warp and filling yarns for the pile and backing
4. TOOLS AND MATERIALS
4.1 Carpet shall be installed using the tools and accessories listed m Table I
4.2 Materials shall be selected from the list in Table II.
4.3 Adhesive shall be used as recommended by the carpet manufacturer or adhesive
manufacturer. Common types are listed in Table III.
4.4 General guidelines for trowel notch selection are listed in Table IV.
4.5 When specified, the tackless strip shall be selected from the list in Table V
5. STORAGE AND HANDLING
Environmental conditions prior to and immediately after installation shall meet the following
criteria to assure a "relaxed" carpet, preventing glue-down or stretch-in problems.
5.1 Storage Carpet shall be stored in flat bins to prevent pile crush. Temporary storage
shall be in flat bins with a maximum height not to exceed three rolls.
5.2 Handling Carpet shall be transported on flat dollies equipped with carpet cradles
Fork lifts shall be equipped with booms. Bending or folding of individual carpet
rolls is not recommended. However, if it is absolutely necessary for delivery pur-
poses, under no circumstances should the carpet be left bent or folded for longer
than 4 hours.
5.3 Conditions The carpet and adhesive shall be conditioned on site in a heated dry
space at a minimum temperature of 65° F (18° C) and a relative humidity between
10% and 65% for at least 48 hours before installation. These conditions shall be
maintained night and day during installation and for at least 72 hours after completion
P-4
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6. SITE CONDITIONS
6.1 Floor Preparation Each subfloor shall be inspected to determine the special care
ecuired to make it a suitable foundation for carpet,
6.l.t Concrete - New concrete shall be cured, clean and dry. It shall be free of
curing or parting agents that interfere with the bonding of the adhesive The
owner or general contractor must submit to the flooring contractor a report on
the percentage of moisture in the slab. The moisture content shall not exceed
a hygrometer reading of 65%.1
Whenever a powdery surface is encountered, a sealer compatible with the
adhesive shall be used to provide a suitable surface for the glue-down installa-
tion when specified.
Patching of cracks and depressions shall be made with a compatible latex
patching compound. Do not exceed manufacturer's recommendation for patch
thickness. Large patched areas must be sealed.
Old concrete must be clean, dry, and free of paint, dirt, adhesive, oils and
other contaminants.
6.1.2 Wood Wood subfloors should have a minimum 18-inch (457 mm) air space
underneath with cross ventilation. Plywood, hardwood, and particleboard used
as subfloonng must be a flooring grade installed to the manufacturer's specifi-
cations. Joints shall be filled and rough areas sanded smooth. Old wood shall
be checked for soundness, and any loose boards shall be renailed. Rough and
uneven areas shall be sanded smooth and sealed.
Oil contaminated floors must be covered with a suitable underlayment such
as hardboard, plywood, or particle board installed according to the Hardwood
Plywood Manufacturers Association or the Particleboard Manufacturers
Association recommendations.
The suitability of a painted wood surface can be checked by gluing down a
two-foot square of carpet. If the adhesion bond is strong, and the paint does
not pull up with the carpet after 72 hours, the carpet can be installed. Glossy
surfaces are to be roughened prior to installation.
Sanded and new floors shall be coated with a compatible sealer to provide
a good surface for glue-down.
7 To determine the presence of excessive moisture on-site, place a hygrometer on the floor
near an inside wall, cover with a sheet of clear plastic film about two feet (610 mm) square, and seat
with duct tape. A rough estimate may be obtained in 15 to 30 minutes; 24 hours is needed for an
accurate check. Vanous locations in the area should be tested.
Moisture test on stabs below S5°F (13°C) are inaccurate because moisture migration is retarded by
low temperatures.
P-5
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6.1.3 Metal Metal floors must be level and cleaned of grease, oil. din. ana -us;
6.1.4 Vinyl and Linoleum - Carpet must not be glued down directly over ex:st
sheet vinyl
Direct glue-down over tiles and other types of previously installed resilient floor-
mg is feasible under certain conditions; however, tests must oe performed
to determine if the vinyl plasticizers will migrate into the carpet adhesive
and loosen the bond.
6.1.5 Terrazzo, Ceramic, Marble, Epoxy and Slate All of these materials repre-
sent nonporous surfaces. If a nonporous backed carpet is glued down ever
these surfaces, strict attention must be given to the 'open time
recommendations.
6.1.6 Radiant Heat Heat must be lowered before the installation to prevent floor
adhesive from "setting" too fast. When affixing tackless strips in stretch-in
installations, care must be taken not to nail into the pipe or conduit.
6.1.7 Sealers The use of sealers on floor surfaces is generally not necessary
except for sanded, dusty, porous, and acoustical surfaces. Sealing cannot
overcome moisture conditions and must not be used for that purpose. When
used, sealers must be thin and fast drying. They should be compatible with
adhesives, which should be applied only after sealer is dry.
6.2 Moisture in Concrete Subfloors At least 90-120 days are to be allowed
concrete slab to cure and reach an acceptable dryness. Appearance alone is not
a reliable test. In order to prevent glue-down and adhesive breakdown problems due
to moisture and alkali, the general contractor or owner shall be responsible for pro-
viding written moisture and alkali test results relating to the concrete slab prior to
the installation. A pH range of 5-9 is satisfactory; however, 10 or greater requires
corrective measures.2 This can be accomplished by applying an acid etch con-
sisting of 10 parts water to 1 part of muriatic acid, and rinsing twice with clear water
In some cases, a 30% mixture of vinegar and water may be used to reduce alkalinity
In case "gypcrete," lightweight, or acoustical concrete is used, check the manufac-
turer's recommendations for the proper sealer to be used before carpet is installed
6.3 Temperature and Humidity Ideally, carpet shall be installed when the temperature
is between 65° F and 95° F (18° C and 35° C) and the relative humidity is between
10% and 65% and, if installing over concrete, the slab temperature should not oe
less than 65° F (18° C).
2 The pH on the surface of the concrete can be determined by slightly wetting the floor and
applying pH test paper.
P-6
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6.4 Relax Carpet Whenever possible and conditions permit, all carpet snail oe
unrolled, relaxed, and allowed to ventilate witn the induction of fresh air
6.5 Environmental Conditions Fresh air ventilation during installation snail oe
-maintained by opening windows and doors, by utilizing exhaust fans, and by operating
the ventilation fan system at full capacity. When conditions warrant, fresh air ven-
tilation shall be maintained after installation for 48-72 hours at normal room
temperatures by operating the ventilation fan system at full capacity and by opening
windows and doors if possible. This will help eliminate the existence of any lingering
odors.
6.6 Carpet over Carpet Carpet shall not be installed over existing carpet.
7. PLANNING AND LAYOUT
All facets of the installation are to be coordinated. A scale drawing of the area to be
carpeted is required to determine yardages, yardage per dye lot, edge treatments.
cushions, adhesives, moldings, and other accessories and to identify proper location
of seams.
On new construction, architectural drawings shall be provided that define the entire
carpet area with space names or numbers and a finish schedule of styles, patterns.
colors, and installation methods. On existing structures, new measurements and shop
drawings shall be made.
7.1 Shop Drawings and Layout The carpet shop drawing shall contain the following
information:
7.1.1 Name of the job, owner, and installation company. On new construction, the
name of the general contractor and architectural firm shall be listed.
7.1.2 Building address
7.1.3 Date of drawing
7.1.4 Scale
7.1.5 Floor number and location in building
7.1.6 Compass direction on each sheet
7.1.7 Drawing for each area to be carpeted
7.1.8 Type of floor for each area
7.1.9 Type of installation for each area
P-7
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7.1.10 Quantities of carpet needed for each area, including roll length requirement
7.1.11 Notations where dye lot changes will occur
7.1.12 Excess material in each area and how it will be used
7.1.13 Seam layout of each area
7.1.14 Carpet pile direction for each area
7.1.15 Name of manufacturer, quality, and color of carpet for each area
7.1.16 Large scale drawings showing treatment of step areas or other detail
7.1.17 Location and type of all edge moldings
7.1.18 Type of base in each area
7.2 Seama Seams shall be kept to a minimum. The seams shall be positioned so that
where possible:
A. The seams run the length of the area.
B. Main traffic runs along rather than across the seam.
C. Incident light does not strike across the seam.
D. The seams are away from areas subject to pivoting traffic.
6. Seams are not perpendicular to doorway openings.
7.3 Pile Direction Where two or more pieces of the same carpet are adjacent, the p1
direction shall be the same as in other areas unless otherwise specified. Ideally. piL
direction shall be toward the entrance, but other factors such as pattern, aesthetics
and economic use of material may also be considered.
INSTALLATION
8. DIRECT GLUE-DOWN
Direct glue-down adheres carpet to subfloors.
8.1 Preparation The floor is to be dry and free from contaminants which will prevent
good adhesion. Surfaces shall be vacuumed and thoroughly cleaned before applica-
tion of the adhesive.
8.2 Layout - Cut the carpet to the proper length and spread out in the area where it
is to be installed. The carpet shall be cut three to four inches longer than the area
measurement. Where applicable, also allow for pattern repeat. Align all breadths.
or sections, of carpet in their proper position and trim the seams.
P-8
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Whenever possible, carpet should be spread in the room 24 hours prior to actual
installation, with room temperature between 65° F and 95° F (18° C and 35° Q Before
spreading adhesive, seam edges must be trimmed using the appropriate seam cut-
: ng tools according to the manufacturer's recommendations.
8.3 Trowel Notch Size and Adhesive
8.3.1 Select the appropriate adhesive and trowel notching recommended by the
carpet manufacturer and/or adhesive supplier, or refer to the list shown in Table
IV as a minimum. A 100% transfer of the floor adhesive into the carpet back-,
mg while maintaining full coverage of the floor must be obtained.
8.3.2 The floor adhesive shall be spread uniformly over the subfloor with the specified
trowel. After sufficient open time, the carpet should be pressed into the
adhesive and roiled with the appropriate roller.
WARNING Lack of adhesion caused either by a lower quali-
ty adhesive or wrong trowel selection is the number one cause
of installation failure. A 100% transfer of floor adhesive into
the carpet backing, including the recesses of the carpet back,
while maintaining full coverage of the floor must be attained.
8.4 Seaming To prevent fraying and raveling at the seams, a 1/8-inch (3.2 mm) con-
tinuous bead of seam adhesive should be applied to the base of the first edge where
the face yarn enters the backing. (See diagram below.) This will seal the first edge
as well as the second when the edges are butted together to form the seam.
8.4.1 Woven carpet - All cut seam edges on woven carpet must be secured with a
latex seam adhesive immediately following seam trimming.
8.4.2 Unprotected edges - All unprotected edges must be protected with an
appropriate seam adhesive.
8.5 Rolling - Rolling shall be performed with the lightest roller which will achieve 100%
P-9
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transfer of the floor adhesive into the carpet back. Refer to manufacturer $ 'e<
mendation for roller weight. Normally, do not exceed 75 pounds (34 kg)
8.5.1 Jute or Synthetic Secondary Backing Tufted carpet with jute or synti
secondary backing should be pressed down into the adhesive oed us.rg a
section of carpet core or a roller Roll m both directions but do not over -cr
8.5.2 Unitary and Woven - Unitary (single back) carpet and woven carpet T^US; oe
rolled a second time about 3-12 hours after initial rolling to make sure a
strong bond is established.
8.6 Trimming - The wall trimmer shall be ad|usted to trim the excess carpet
the wall.
9. DOUBLE GLUE-DOWN
Site and environmental conditions for double glue-down should be the same as 'or
direct glue-down. In this type of installation, a separate cushion is adhered to the floor
and the carpet is glued to the cushion using the same methods utilized for direct giue-
down. NOTE. As significant differences exist in various carpet cushions, consult with the
manufacturers of the cushion, carpet, and adhesives for their recommendations m this
type of installation.
9.1 Preparation The floor is to be dry and free from contaminants which win
good adhesion. Surfaces shall be vacuumed and thoroughly cleaned before ao
mg the adhesive.
9.2 Adhesives and Trowel Notch Sizes - Select the appropriate adhesive and trowei
notch size recommended by the manufacturers of the carpet, cushion, and adhesive
If recommendations are not available, refer to the general guidelines m Table iv
Roller or spray applications may be used upon recommendations of the carpet
manufacturer and/or adhesive supplier.
For application of cushion to floor, a pressure sensitive adhesive is recommended
to facilitate easy removal of cushion at end of use. Other premium adhesives may
be used, but removal of cushion from the floor will be more difficult.
For application of carpet to cushion, a consideration in the selection of the trowei
notch size is the coarseness of the carpet backing. It is important that the trowei
notch be large enough to apply a continuous thin film of adhesive for 100% transfer
into the backing while maintaining full coverage of the cushion. Woven and unitary
backed carpet require full penetration of the adhesive into the valleys or depressions
between tuft rows. A premium adhesive is recommended.
p-io
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9.3 Layout Cushion - After the floor is prepared, the layout and cutting of the cushion
snouid be completed. Cushion should be installed in the longest continuous lengths
oossiDie with consideration given to the traffic pattern and seam placement of the
ca'cet Cushion seams should not be directly under carpet seams, but located at
- gnt angles or offset at least 6 inches (152 mm) from the carpet seams.
Cusmcn searrs must be butted without compression leaving no gaps Place cushion
flush with all walls, trimming for net fit. Fold back the cushion and apply adhesive
to the floor
9.4 Layout Carpet - Cut the carpet to the proper length and spread out in the area
to be carpeted. The carpet should be cut 3-4 inches (76-101 mm) longer than
the area measurement. Where applicable, allow for pattern repeat. Carpet seams
should be at a right angle to cushion seams or offset at least 6 inches (152 mm)
to either side. Align all carpet breadths to their proper position and trim seams.
The adhesive shall be spread uniformly over the cushion surface with the specified
trowel. After sufficient open time, the carpet is to be pressed into the adhesive and
rolled with the appropriate roller.
9.5 Seaming - To prevent fraying and raveling at the seams, a 1/8-inch (3.2 mm) con-
tinuous bead of seam adhesive should be applied to the base of the first edge where
the face yarn enters the backing. This will seal the first edge as well as the second
when the edges are butted together to form the seam.
Sewn seams or hot melt seams may be used. If hot melt tape is used, it must
be non-silicone treated, and the edges of paper beyond the netting removed. The
carpet manufacturer's recommendations should be followed if available.
9.6 Rolling - Rolling shall be performed as follows:
9.6.1 Jute or Synthetic Secondary Backing - Tufted carpet with jute or synthetic
secondary backing should be pressed into the adhesive bed with a two-foot
section of carpet roll core, a stiff broom, or by using a roller weighing
35*50 pounds (16-23 kg). Roll in both directions, but do not over roll.
9.6.2 Woven Carpet - Woven carpet should be pressed into the adhesive using
a two-foot section of carpet roll core or a stiff broom, followed by rolling with
a roller weighing up to 50 pounds (23 kg) to press the carpet firmly into the
adhesive.
9.6.3 Unitary Back - To make certain a strong bond is established, tufted unitary
back must be rolled a second time about 3-12 hours after the initial rolling
with a roller weighing up to 75 pounds (34 kg).
P-II
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10. ATTACHED CUSHION
Carpet with cushion material permanently bonded to the back of the carpet by the
*.urer it is often made with attachment of synthetic rubber foam or poiyurethane
10.1 Conditions
10.1.1 For site, handling, and environmental conditions as well as floor preoarat'C"
refer to Sections 5 and 6.
10.2 Carpet Layout
10.2.1 Refer to Section 8.2 (Direct Glue-Down).
10.3 Adhesive!
10.3.1 Consult the carpet manufacturer for recommendations for floor and seam
adhesives.
10.3.2 When specific adhesive recommendations are not available, refer to Table ill
10.3.3 Trowel notch size refer to Table IV.
10.3.4 Open time of adhesive is required. Use tacky method of installation The
applied adhesive must develop legs or tack prior to laying the carpet into
the adhesive. Open time will vary dependent upon environmental conditions
10.3.5 IMPORTANT: Sufficient adhesive application must provide a 100% cover
of the floor and carpet back when installed.
10.4 Installation Dry lay the carpet area making sure the carpet lays flat and the pile
runs in the same direction. Rough cut the carpet in at walls and around columns
Using a cushion back cutter, trim seams according to the manufacturer s recom-
mendation. To eliminate possible height variation at the seam areas, a sufficient
amount of the factory or selvage edge must be trimmed. Check for any height
variation at the seam and adjust if necessary by shimming. Then carefully fold back
both breadths of carpet, being careful not to shift the carpet. Using recommended
adhes'ves and properly notched trowel, spread adhesive in a uniform manner Keep
trowel clean and properly notched. Check proper open time of the adhesive, allow-
ing the adhesive to develop legs or tack before installing carpet. Lay the first breadth
into the adhesive and smooth out using a section of the carpet core. Seal the seam
edge using a recommended seam adhesive by applying a 1/8-inch (3.2 mm) con-
tinuous bead at the point where the yarn enters the primary backing.
Lay the other side into the adhesive, butting the second carpet edge tightly against
the first edge. Do not allow the seams to peak. Eliminate any trapped air or buckles
by smoothing out the carpet with a section of the carpet core or a lightweight roller
P-12
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Clean any excessive seam adhesive from seam area using a recommended cleaner
and white cloth. Do not flood seam with cleaning solvent. Check the seam and clip
any loose tufts with nap shears For cut piles, make sure the yarn is not trapped
n me seam.
10.5 Carpet on Stairs
10.5.1 Stair nosing must be rounded 3/4 to 1 inch (19 to 25 mm) to allow carpet
contact with the nosing.
10.5.2 For straight stairs with a nosing, carpet should be installed with one piece
covering both tread and nosing and a separate piece covering the riser.
For straight stairs without a nosing, cut carpet to be installed m one piece
over the tread and riser.
10.5.3 Measure and cut carpet accordingly.
10.5.4 Apply a 3-inch (76 mm) band of contact cement to the nosing, under the
nosing, and on the stair tread. Apply contact adhesive to the correspond-
ing areas on the back of the pre-cut carpet for both the tread and riser.
10.5.5 Use carpet manufacturer's recommended floor adhesive and apply to
remaining areas of the tread and riser.
10.5.6 Allow adhesives to set properly before positioning carpet.
10.6 Protection of Installation
10.6.1 Refer to Section 15.
10.6.2 Maintain minimum traffic for a 24-hour period to allow adhesive to properly
cure.
10.6.3 Temporarily use plywood or hardboard to protect the installation if roller
traffic is required prior to 72 hours of cure time of the adhesive.
11. STRETCH-IN UTILIZING TACKLESS STRIP
This method requires fastening the carpet under tension on tackless strip around the
perimeter of the area to be carpeted. A separate cushion shall be used. (See Section 6
regarding site conditions.)
11.1 Selection of Separate Cushion - Contact the carpet manufacturer to obtain cushion
requirements in order to prevent problems resultant from improper cushion selec-
tion and the possible voiding of applicable warranties. Choice of cushion which is
P-13
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inappropriate for the end use application of the carpet may result in accelerated
loss of appearance retention, wrinkling, buckling, and the separation of the earner
backing or seams. Cushion thickness should not exceed 3/8-inch (9.5 mm).
11.2 Layout and Material - Carpet is to be laid out with consideration to traffic cat-
terns and seam placement. Where possible on large commercial installations, it
is recommended that carpet be spread and allowed to condition for 24 hours prior
to installation.
All materials shall be on the job site prior to the beginning of the installation to assure
uniformity of the application.
11.3 Tackless Strip Tackless strip applications are to be matched to each specific use
in accordance with Table V. NOTE: Standard and pre-nailed wood tackless strips
should be a minimum of one inch (25 mm) wide and 1/4-inch (6.4 mm) thick.
Commercial or architectural strip with three rows of pins is to be used when dimen-
sions exceed 30 feet (9.1 m).
11.3.1 Installation of Tackl«s« Strip
A. Full length pieces of tacktess strip shall be spread around the wall
perimeter with pins pointing toward the wait.
8. The proper gully shall be slightly less than thickness of the carpet, but
not to exceed 3/8-inch (9.5 mm).
C. The tackless strip shall be cut to proper lengths to maintain the same
gully, regardless of the shape of the wall.
D. The tackless strip shall be securely fastened to maintain the proper
stretch provided by power stretching. Two nails (fastening points) are
required for the smallest pieces of tackless strip.
E. Carpet shall NOT be stapled to the tackless strip.
F. Avoid placing tackless strip across door openings or door sills where
possible.
11.4 Installation of Separate Cushion Cushion is to be installed in the longest con-
tinuous lengths possible. The cushion seams should not be installed directly under
carpet seams. Generally, they should be placed at right angles to the carpet seams.
When this is not practical, shin the cushion so that seams are at least 6 inches
(152 mm) to one side of the carpet seams.
11.4.1 Cushion Installed Wall-to-Wall - Cushion shall be securely fastened to the
subfloor with staples or nonflammable cushion adhesive around the
perimeter of the installation. Seams shall be secured with staples or nonflam-
mable cushion adhesive. However, tape such as duct tape shall be
used for seams on rubber cushion. These procedures are required to pre-
P-14
-------
vent shitting of the cushion during and after the carpet installation
Foam or sponge cushion with a waffle design should be installed with the
smooth side up.
Foam cushion seams are to be covered with vinyl covered fabric tape, such
as auct tape, or secured with adhesives. Staples or adhesives are to oe
applied approximately 6 inches (152 mm) within the perimeter edges ail
around.
11.4.2 Cushion Installed Loose Felt cushion seams are to be sewn with
stitches not more than one inch (25 mm) apart and at least one inch from
the seam edges.
Foam cushion seams are to be covered with vinyl covered fabric tape or _
duct tape. Eight-inch to ten-inch (203 to 254 mm) strips of tape are to be
placed at right angles to the seam at 18-inch (457 mm) intervals. Tape is
to be applied to full length of seam.
11.5 Layout and Cutting Following the seaming diagram, cut sufficient length of carpet
that will cover the entire area. Where pattern matches are involved, an extra repeat
must be allowed on each cut for the match, plus an extra 3 inches (75 mm) on each
cut for trimming.
Trim all edges that are to be used for seaming at least one inch (25 mm) on each
side. NOTE: The selvage of some woven carpet must not be trimmed. The manu-
facturer's recommendations should be followed.
11.6 Edge Securing - Once the edges are trimmed, an appropriate seam adhesive must
be applied to both trimmed edges. Allow the seam adhesive to dry thoroughly before
seaming. Improperly sealed edges can lead to seam delammation or loss of face
yarns with unsightly results.
11.7 Seaming The choice of seaming method is dictated by the type of carpet backing
and carpet construction.
11.7.1 Hot Melt Tape - A fabric seaming tape precoated with a thermoplastic
adhesive is centered beneath the seam. Heat from an electric iron melts
the adhesive, laminating the carpet backing to the tape. A grooved iron is
recommended for better penetration of the adhesive. Proper iron temperature
is essential, with special care taken for carpet with synthetic backing or syn-
thetic pile yarns. Always run the iron in the smooth direction of the pile.
The maximum recommended heat setting is 2%. A heat shield tor the iron
it required. A metal surface should not be used to weight the seam behind
P-15
-------
the iron, as metal traps the heat. Wood should be used for this purpose.
Premium tape with high tensile strength and sufficient adhesive on the woven
scrim is recommended. NOTE: To minimize elevating and peaking, a 6-mcn
(152 mm) wide tape should be used.
Pre-stretch the carpet in the seam direction before making the seam.
11.7.2 Tape and Latex The seaming tape shall be centered directly under ;ne
seam. Latex seaming adhesive is applied to the tape. The seam shall be
allowed to dry at least 8 hours before stretching.
11.7.3 Hand Sewing - Hand sewing shall be an overcast stitch placea not more
than 1/2-mch(l3mm) apart and no less than V2-inch(l3mm) from the edge
of the carpet. It is recommended that a latex coating and tape be applied
over the stitching. Hand sewing is recommended for all Wilton and most
other woven carpet.
11.7.4 Electrical Tape For electrically conductive tapes, follow the manufacturer s
recommendations.
11.8 Power Stretching - Following seaming, carpet must be power stretched and firmly
hooked onto the tackless strip at the starting walls and on the tackless strips m
the surrounding area. The use of power stretchers is mandatory.
Before power stretching, make certain that hot melt tape seams are cool to the touch.
A four-way stretch is to be used (See Figures 1-3).
Follow the carpet manufacturer's recommendations for the method and amount of
stretch to be applied. When recommendations are not available, tufted carpet with
a jute secondary back should be stretched "drum tight." Tufted carpet with a syn-
thetic secondary back should be stretched 1%-1Vz% in width and length.
Refer to Figures 2 and 3 for woven carpets.
A wall trimmer shall be used to trim the carpet along walls and abutments. The
trimmer shall be adjusted to leave sufficient excess carpet to tuck into the gullies.
12. CARPET ON STAIRS
Stair carpet should be installed as follows:
12.1 Preparation - Stair nosing should be rounded 3/4-1 inch (19 to 25 mm) to prevent
sharp stair edges from cutting the carpet and/or cushion.
12.2 Stretch-In Installation - Tackless strip is to be installed on each tread and riser
P-16
-------
Pins on the step point toward the riser. Pins on the risers point down to the step
The gully between the stnps is slightly less than double the carpet thickness. Tackless
strips and cushion are about 1 1/2-inch (38 mm) less than the carpet width to allow
'or a turn under on each side of the stairs. Some stairs require tackless strip on
:ne sides to maintain the proper tension.
Using a knee-kicker, or "stair stretcher," stretch the carpet tightly over eacn step
The carpet should be secured to each tackless strip and driven into the gully with
a stair tool at the junction of the tread and riser. Curved or sloped areas shall have
the carpet tailored to fit the tread and riser without wrinkles and with the edges neat-
ly finished.
12.3 Glue-Down Installation on Stairs - Carpet is to be tightly secured to treads and
risers using a proper adhesive. A separate piece of carpet shall be used for each
step with riser, except on steps without nosing. Carpet should be installed with the
pile direction in the length of t!ie stair.
13. CARPET MODULES (TILES)
The carpet manufacturer's recommendations are to be followed. If not available, the follow-
ing procedure is to be used.
13.1 Measuring Determine the center of the room using standard tile layout methods
using grid lines where possible.
13.2 Method of Installation Determine the starting point. Srap a chalk line across the
room in both directions through the center to divide the room into four squared
sections. On both sides of each chalk line, apply a strip of adhesive at least nine
inches (228 mm) wide using a twist-textured paint roller or a 1/16-inch (1.6 mm)
V-notch trowel. When the adhesive is dry or tacky, begin installing each section
in a pyramid fashion starting from the center and working outward.
Additional modules within the quadrant are to be installed using the "stair step"
technique. In this technique, the tiled area grows »^adily away from the center of
the room. It does not grow along either of the chalk lines but, rather, along an im-
aginary diagonal line between them. The installation continues to grow from the
center to the comer of the room, finishing the entire quadrant t afore starting the
next quadrant.
13.3 Joints Modules in the completed installation must be snugly jointed together.
Continually check that modules are being placed together with correct firmness.
To check for correct snugness, measure the distance along ten installed modules.
P-17
-------
The gain in each 10 modules should be Vt-inch (6.4 mm). Example: Ten 18 inches
by 18 inches (457 x 457 mm) modules should measure 1801/4 inches (4578
when properly installed. When placing modules, brush the face pile back from
tile edge and "tip" the module into place in order to prevent pile yarns from becoming
entrapped in the joint.
13.4 Control Grid - Throughout the installation, a control grid should be installed at
regular 15-foot (4.57 m) intervals to keep the modules from shifting. A control grid
consists of a row of modules anchored in place with the same adhesive used to
align the center line adhesive. Adhesive must always be placed around the perimeter
of the area. All cut modules should be installed over adhesive.
NOTE: Where wheel traffic will be present, the entire area must be installed with
adhesive.
14. INSTALLATION OF OUTDOOR CARPET AND SYNTHETIC TURF
Outdoor carpet installations offer conditions quite different from those encountered in-
doors. Both carpet and adhesive are subjected to extremes of weather and traffic, and
installation surfaces will be much more varied and often uneven.
14.1 Carpet Selection The carpet to be installed outdoors should be of the construc-
tion and type of synthetic face yarns and backing recommended for outdoor u{
14.2 Site Conditions - All installation surfaces must be clean, dry, sound, cured, smooth
as possible, and with adequate drainage.
14.2.1 Concrete - Concrete surfaces must be clean, dry and free from alkali. They
must be cured for a minimum of 60 days, or longer, dependent upon
weather conditions. All wax must be removed, and painted surfaces
should be sanded thoroughly and cleaned before installation.
14.2.2 Wood Painted wood surfaces should be sanded and sealed with an
appropriate outdoor sealer. Stoned wood surfaces should be covered with
an outdoor grade plywood and sealed. Waxed or oiled wood surfaces
present special problems which will require resurfacing.
14.2.3 Metal Metal surfaces must be cleaned of grease, oil, dirt, and rust. Painted
metal surfaces must be rough-sanded with loose paint removed.
14.2.4 Terrazzo, Ceramic, Marble, Epoxy These surfaces must be clean and
dry with all wax finishes removed.
14.2.5 State and Brick - These surfaces may be too rough and uneven for most
outdoor installations and may require refinishing and leveling bef^a
P-18
-------
installation.
14.2.6 Asphalt - Asphalt must be clean, dry, free from excessive oil and grease.
and m good condition. New asphalt must be cured for at least 30 days, or
longer, dependent upon weather conditions. Old asphalt may require resur-
facing before installing carpet.
14.2.7 Swimming Pools Regardless of the surface encountered, indoor swim-
ming pools must be drained and dry before installing outdoor carpet. Out-
door pools must not be used during installation. Any fungus or algae must
be removed from the surfaces to be covered.
14.3 Backing Materials - The type of backing materials involved is very crucial m the
installation of outdoor carpet. Outdoor carpet backings can be classified into one
of the following types:
A. Fibers Polypropylene, woven and nonwoven.
B. Vinyl - Unitary or foam. (Requires special adhesive.)
C. Urethane Unitary or foam, smooth or patterned.
. 0. Latex Rubber - Smooth, foam waffle, or diamond shape.
CAUTION: Use of the correct adhesive will greatly determine the success
of an outdoor installation. Where the backing material is unknown, or if doubt
exists, contact the carpet manufacturer for a positive identification.
14.4 Adhesive* Adhesive selection is very important. Recommended adhesives for
outdoor installations are as follows:
A. Solvent Based Preferred for outdoor installations as they can be
applied over a wida range of weather conditions and are generally more
water resistant.
CAUTION: Some contain flammable solvents and should only be used
outdoors.
B. Latex (Water) Based Latex adhesive must be of premium quality.
Avoid application under damp, humid, or extreme cold or hot conditions.
Surface of substrata must be compatible with liquid adhesive.
CAUTION: Always follow tha manufacturer's installation procedures.
14.5 Layout - All outdoor carpet must be unrolled and allowed to relax at least one
hour before installation. Ideally, this should take place when the temperature is
between 55° F and 95° F (12.7° C and 35° C), and the relative humidity is between
and 65%.
The carpet should be pro-cut for the area to be covered, allowing for any
required trimming. Seams should be kept to a minimum and run with the traffic
pattern whenever possible. Knee-kickers may be used to position the carpet prop-
P-19
-------
erly, but should be used with caution.
Where seams are required, be certain that the pile lay runs m the same ejection
14.6 Edge Seaming A bead of seam adhesive must tie applied to all seam edges of
the outdoor carpet, as well as all exposed edges.
14.7 Rolling - Generally, outdoor carpet will require rolling after installation The size
and weight of the roller to be used should be specified by either the carpet or adhesive
manufacturer.
14.8 Rnithing All seams should be brushed, and protruding pile tufts should be trimmed
Excess adhesive must be removed with a suitable solvent recommended by the
adhesive manufacturer. The final installation must be cleaned and ready for use
NOTE: For indoor installation of outdoor carpet, follow the procedures outlined m
Section 8, except where outdoor conditions may also exist such as indoor swim-
ming pools, health spas, and indoor-outdoor patios.
NOTE: The installation of artificial turf on athletic fields is a highly specialized area
and is outside the scope of this standard. Consult the manufacturer for specific in-
stallation instructions.
15. PROTECTION OF INSTALLATION
If required to protect the finished floorcovering from dirt or paint, or if additional work
is to be done after the installation, cover it with a non-staining building material paper
Plastic sheeting should not ba uMd over glue-down or tackles* installations
as It may trap moiatura or retard curing of the adhesive
Ideally, temparaturas of indoor carpeted areas should never fall below 50° F
(10° C) regardless of the aga of the installation.
P-20
-------
TABLE
TOOLS
A Tape Measures
1 25-ft. (7 6 m) Retractable
2. 50-ft. (15.2 m) Metallic
3 100-n. (30.5 m) Metallic
B. Straight Edges
1 1-Rigid
2. 1-Flexible
C. Chalk Line and White
Chalk (Only)
D. Knives and Cutters
1. Utility Knife
2. Carpet Knife
3. Slotted Razor Blade
4. Loop Pile Cutter
5. Wall Trimmer Conventional
6. Wall Trimmer - Cushion Back
7, Carpet Shears
8. Nap Shears
9. Electric Rotary Knife
10. Hacksaw
11. Tin Snips
12. Tackless Strip Cutter
E. Hammers and Mallets
1. Carpenters
2. Tack
3. Rubber Mallet
4. Electric Stapler
5. Hammer Tacker
F. Screwdrivers
1. Phillips
2. Standard
G. Trowels
H. Files
1. Triangular
2. Flat
I. Rollers
1. 35 Ib. (16 kilograms)
2. 50 Ib. (23 kilograms)
3. 75 Ib. (34 kilograms)
J. Power Stretcher
K. Knee Kicker
L. Miscellaneous
1. Base Shoe Lifter
2. Drive Down Bar
3. Stair Tool
4. Awl
5. Nail Set
6. Sharpening Stone
7. Carpet Spreader
8. Pliers
9. 3-m. (76 mm) Hot Melt
Seaming Iron and Shield
10. 6-in. (152 mm) Hot Melt
Seaming Iron and Shield
11. Extension Cord and
Adapter
12. Plastic Squeeze Bottle
13. Hammer Drill
14. Metal Miter Box
15. Hygrometer
16. pH Paper
17. Carpet Tractor
16. Wood Weight to follow
Hot Melt Seaming Iron
19. Door Pin Remover
20. First Aid Supplies
21. Stay Nails
22. Carpenters Square
23. Pencil and Note Pad
24. Chalk Stick
25. Marking Pen
26. Thimbie, curved
27. Needle and Thread
28. Putty or Coloring
Sticks for touchup
of wood
29. Vacuum Cleaner
P-21
-------
TABLE II
MATERIALS
A. Metal and Vinyl Moldings
1. Binder Bars
2. Cap Molding
3. Stair Nosing
4. Accent Molding
5. Metal Clamp-Down Binder Bar
6. Access Panel Molding
7. Combo Metal
B. Seaming Tape
1. Latex
2. Hot Melt
C. Tackles* Strip
1. Standard no anchoring nails
2. Pre-nailed wood
3. Pre-nailed concrete
4. Acoustical
5. Commercial or Architectural
P-22
-------
TABLE III
ADHESIVES
1. Latex
2. Vinyl Back Carpet Adhesive
3. Carpet Seam Adhesive
4. Carpet Seaming Latex
5. Contact Cement
6. Urethane Carpet Cushion Adhesive
7. Seam Sealer
P-23
-------
TABLE IV
TROWEL SIZE - MINIMUM GUIDELINES
Direct Glue-Down
Carpet Backing
Jute
Rubber (foam & sponge)
Urethane Cushion
Jute/Vinyl
Vinyl-foam
Vinyl-slab
Vinyl-coated
Synthetic
Unitary
Woven
Hot Melt
Adhesive
Type
Latex
Latex
Latex
Vinyl
Vinyl
Vinyl
Vinyl
Latex
Latex
Latex
Latex
Double Glue-Down
Trowel Size
width x spacing x depth
in inches'
3/32 x 3/32 x 3/32
1/8 x 1/8 x 3/32
Notch
Shape
1/8
1/8
1/8
1/8
1/8
1/8
x
x
X
X
X
X
1/16
1/8
1/16
1/8
1/16
1/8
x
X
X
X
X
X
1/8
3/32
1/8
3/16
1/8
3/16
3/32 x 3/32 x 3/32
1/8 x 1/8 x 3/16
V or
U
V or
U
V or
U
V or
U
V or
U
Between floor & cushion
smooth floor
porous floor
Between cushion & carpet
smooth back carpet
- rough back carpet
Latex
Latex
Latex
Latex
1/16 x 1/32 x 1/32
1/16 x 1/16 x 1/16
1/8 x 1/8 x 3/32
1/8 x 1/16 x 1/8
1/8 x 1/8 x 3/16
U
U
U
U
U
Notes: The above guidelines should only be used when specific recommendations are not available from the carpet
manufacturer and/or the adhesive supplier. Rough, porous concrete surfaces and heavily textured carpet backs
may require a trowel with deeper notches than listed above. A100% transfer of floor adhesive to both floor and carpet
must be achieved.
To convert trowel dimensions to metric:
1/32"
1/16"
3/32"
1/8 "
3/16"
0.8mm
1.6mm
2.4mm
3.2mm
4.8mm
P-24
-------
TABLE V
TACKLESS STRIP
Type Tackless
Standard
Pre-nailed (wood)
Pre-naiied (concrete)
Acoustical
Commercial or
Architectural
Application
Use on wood, concrete and
other hard surface floors
Use on wood subfloors
Use on concrete
Use on lightweight aggregate
concrete flooring that has
been designed for absorbing sound
Use when dimensions exceed
30 feet (9.1 m)
P-25
-------
P-26
-------
FIGURE 1
TUFTED
Amount of Stretch n per the Carpet Manufacturer's Recommendation
In Absence of Carpet Manufacturer's Recommendation, Use Diagram Below
power stretch from wall A B & hook onto
tackless along the wall from C to 0
yc
power stretch
from wall A C
& hook onto tackless
along the wall
from B to 0
power stretch
from wall A B
& hook onto tackless at
comer C
power stretch from
wall A B & hook onto tackless
temporanly at comer 0 until
Step 7 has been completed
power stretch from
wall A C and
hook onto tackless
at comer B
stretcn & hoo*
onto tacKless
with knee Kicker
along the
wall from
AtoC
stretch & hook onto tackless with knee kicker N
along the wall from A to B
hook onto tackless
along comer A
STRETCH:
Jute Secondary Backing:
Synthetic Secondary Backing:
Length
"drum tight"
Width
"drum tight"
P-27
-------
FIGURE 2
WILTON OR VELVET
Amount of Stretch aa per the Carpet Manufacturer's Recommendation
In Absence of Carpet Manufacturer's Recommendation, Use Diagram Below
power stretch from wall A B & hook onto
tackless along the wall from C to 0 /
power stretch
from wall A C
& hook onto tackless
along the wall
from B to 0
power stretch
from wall A
& hook onto tackless at
corner C
power stretch from
wall A B & hook onto tackless
temporarily at corner 0 until
Step 7 has been completed
power stretch from
wall A C and
hook onto tackless
at comer B
stretch & hook onto tackless with knee kicker
along the wall from A to B
stretcn & hook
onto tacKiess
with knee kicker
along the
wall from
A to C
STRETCH: Length
Wilton: equal stretch in length and width
(drum tight)
Velvet: snug
hook onto tackless
along comer A
Width
equal stretch in length and width
(drum tight)
more stretch in width than length
P-28
-------
FIGURE 3
AXMINSTER
Amount of Stretch aa per the Carpet Manufacturer's Recommendation
In Absence of Carpet Manufacturer's Recommendation, Use Diagram Below
power stretch from wall A B & hook onto
tackless along the wall from C to D J
x/ C
power stretch
from wall A C
& hook onto tackless
along the wall
from 8 to D
power stretch
from watt A B
& hook onto tackless at
corner C
power stretch from
wall A B & hook onto tackless
temporarily at corner 0 until
Step 7 has been completed
power stretch from
wall A C and
hook onto tackless
at comer B
stretch & hook onto tackless with knee kicker
along the wall from A to B
stretch & HOOK
onto tackless
with knee kicker
along the
wall from
AtoC
hook onto tackless
along comer A
STRETCH:
Length
tight
Width
snug
P-29
-------
GDI Publications
INFORMATIVE PUBLICATIONS DESIGNED FOR:
DISTRIBUTORS
CONSUMERS
MANUFACTURERS
NSTALIERS
SPECIFIERS
CARPET CAPE AND CLEANING SHEET
-3! of So lac.e *c' -c^c "5 *>t" sacn saie
;.r-es acyu-"?, : 63"-5 sec* -9"-:vai
a-c r"e' je^erai n'crr-aticn T"e 5"99'rrrtea
:- ro:" s.ces
CARPET CLAIMS MANUAL
A ;uiae 'or ail inaiviouais involved n caroet
ansac: or>s ;ms BOOK 'Ociuaes C'aims ooncies
-cst comr-cntv encounterea ana avanaoie 'or
acootion ay comoanies on an n tne United States ana Canada, make*
».$ OOOK an enceilem cross reference of parent
comoanies ana mnis and a source ot address**.
eieonone numoers. and names of cnief ex-
ecutive officers. Commission tutters art
aentified
CARPET SPECIFIER'S HANOIOOK
~*is >s an excellent reference source tor anyone
*no manufactures, soecifiee. buys, sells, or in-
stans commercial or residential carpet. This
:aroet encvciooeoia aiseusse* type* of carpel.
rie economics ot caroet. wear characteristic*.
manufacturing tecnnique*. fiber type*, oacxmg
materials, and maintenance plan*.
CARPET SPOT REMOVAL GUIDE
An easy to use. consumer slide cnart outlining
cleaning procedure* and cleaning agents lor
carpets and rugs. A guide tor removing over 130
3ifferent spots from carpet
CHEMICAL SPOTS ANO STAINS ON CARPET
ANO RUGS
Aimeo at -esioentiai commerc'ai ana inaustnai
enrj users ana maintenance oersonnei :ru$
DOOKiet identifies common cnemicai suostances
ana aescnoes me typeot damage tnat tney can
cause to carpets and wnat mignt oe oone to cor-
ect a orooiem
COMMERCIAL CARPET MAINTENANCE
MANUAL
Written to assist facility managers maintenance
supervisors ana otners «no puy sen specify.
or are responsiote 'or commercial carpet
maintenance, mis OOOK is aesigned to Duiia
awareness of oerformanee cnaractansncs ot
carpet, it offers recommendations mat will assist
>n developing a maintenance plan mat is oooxie! "e'cv 52:.:
0 *ntmg soecidcat'Ons s;re'C" - -s'a = :-
selecting ;usn.on ana c-e- -; 3 :
necessary 'or a satisfac:or\ -s'a a-c-
tNDUSTRY REVIEW
This OOOK >s a statisi.cai -ecc- --y -- a ;e ?-
year summary of ncustry $r cr~e''3 - ;;_^
yard volume ana acnar vaiue rc -: ; _? :
woven ana otner tyces of carcei "c_:es : :
carpet and rug *ioer smomerts r-ucr e>:c" -
country of origin ana aestinat.on jnc c »' -
ponant aata
SQUARE FEET. SQUARE METERS. SQUARE
YARDS COMPUTATION TABLE
To help calculate tne amount 3f :aroet -eec?r
for a specific area, mis OOOK gives :i*e n*r~-4
ol sauare f»et yaras. or meters n a s;art3T
width inciuoeo are cnans tor e»ac: :cn-c, a
lions m 9 feet '2 feet, ana IS 'eet /viotrs
STANDARD FOR INSTALLATION OF
COMMERCIAL TEXTILE FLOORCOVERING
MATERIALS. CRI 104
A definitive industry minimum .nstaiiation 5'ar-
dard. this OOOK n a detauaa :u;>>ne 3' 'ec-
maue. procedure, ana terminology -sec -
specification writing, otannmg ayoul ire
installation information mciuaes topics sue- as
accepted toois and materials, ''oor sreoarat cr
installation in special areas 3s an ei-
ceilent guide for retailers.
VALUE THROUGH TECHNOLOGY
This is a sene* of tour video cassettes aesc- :
ing the carpet manufacturing process ana s
suitable for educational seminars inciuaea -
me) sene* are:
Tap* »i Carpel Fibers and Yarns
Tape *2 Carpet Construction and Textures
Tape »3 Carpet Dyeing ana Fmisnmg
Tape »« Overview
Prtee* avaHabto upon reouest.
For more mlormatxxi. contact CRI s Publication
Department at *04 278-0232
P-30
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APPENDIX Q
CRI Residential Carpet Installation Standard
-------
RESIDENTIAL
CARPET INSTALLATION STANDARD
THE CARPET AND RUG INSTITUTE
STANDARD
REFERENCE GUIDE
for INSTALLATION of
RESIDENTIAL
TEXTILE FLOORCOVERING
MATERIALS
CRI 105- 1990
^'^r'/^
-------
RESIDENTIAL
CARPET INSTALLATION
STANDARD
STANDARD REFERENCE GUIDE
FOR INSTALLATION OF RESIDENTIAL
TEXTILE FLOORCOVERING MATERIALS
Fir»t Edition
The Carpet and Rug Institute
ISBN #0-89275-030-8
Copyright© 1990 by The Carpet and Rug Institute. All rights reserv-
ed. Printed in the United States of America. No part of this publica-
tion may be reproduced m any form without permission in writing
from the publisher.
-------
Table of Contents
Page
Forward Q-iii
Introduction Q-iv
Consumer Check List for the Installation of Carpet Q-v
Good Consumer Relations Q-vii
Standard Reference Guide for Installation of Residential Carpet
1. Scope Q-l
2. Specific Reference Applicable to the Standard Reference Guide Q-l
3. Tools and Materials Q-l
4. Handling Q-l.
5. Site Conditions Q-l
6. Environmental Conditions Q-2
7. Measuring Q-2
8. Planning Q-2
9. Layout Q-2
10. Customer Sign-Off Q-2
11. Carpet Over Cushion Q-3
12. Carpet on Stairs Q-3
13. Direct Glue-Down of Carpet Q-4
14. Double Glue-Down of Carpet Q-4
15. Attached Cushion Carpet' Q-4
16. Outdoor Carpet and Synthetic Turf Q-4
17. Protection of the Installation Q-4
18. Customer Acceptance Q-5
Specific Reference Section in Support of the Standard Reference Guide
1. Scope Q-9
2. Applicable Documents Q-9
3. Tools and Materials Q-9
4. Handling Q-10
5. Site Conditions Q-10
6. Environmental Conditions Q-12
7. Measuring Q-12
8. Planning Q-12
9. Layout Q-13
10. Customer Sign-Off Q-15
11. Stretch-in Utilizing Tackless Strip Q-15
12. Carpet on Stairs Q-18
13. Direct Glue-Down of Carpet Q-19
14. Double Glue-Down of Carpet Q-20
15. Attached Cushion Carpet' Q-21
16. Installation of Outdoor Carpet and Synthetic Turf Q-22
17. Protection of the Installation Q-24
18. Customer Acceptance Q-24
19. Definitions of Terms Q-25
Q-i
-------
Table of Contents (Continued)
'age
Tables
I. Tools [[[ Q-28
H. Materials ................................................. Q-29
IE. Adhesives ................................................ Q-30
IV. Trowel Size ............................................... Q-31
V. Tackless Strip .............................................. Q-32
VI. Seaming ................................................. Q-33
VH. Stretch .................................................. Q-34
Vffl. Residential ................................................ Q-35
Figure
1 [[[ Q-36
2 [[[ Q-37
3. Tufted, Stretch Diagram ........................................ Q-38
4. Wilton or Velvet, Stretch Diagram ................................. Q-39
5. Axminster, Stretch Diagram ..................................... Q-40
-------
FOREWORD
Tn,s ouDiicatton, entitled . . . CRM05. STANDARD REFERENCE GUIDE FOR INSTALLA-
TION OF RESIDENTIAL TEXTILE FLOORCOVERING MATERIALS, is a voluntary stancaro
it is based on rehaoie installation principles and procedures developed through practical ex-
perience, research and information obtained from manufacturers, retailers, installers, end jsers
testing laboratories and others with applicable expertise.
Installation techniques, principles and workmanship requirements apply similarly to all types
of applications. However, this publication differs in emphasis and target audience. It is directed
toward the installation of carpet intended for residential or equal use such as homes, apart-
ments, condominiums, etc. As such, it stresses current products and installation methods com-
monly used in these locations.
The Standard Reference Guida is contained within the special yellow pages (11 - 17) of
this publication.
It provides the installer and retailer with a specific and practical set of standards. While these
are voluntary standards, they do represent a consensus as to the very minimum of accep-
table requirements for a satisfactory installation and cover residential applications normally
encountered. Anyone who chooses to represent or request conformity to the CRI installation
standards shall conform to each of these minimum standards.
A Specific Reference Section is provided to assist the installer and retailer with detailed
requirements in support of the minimum Standard Reference Guide pertaining to varying
conditions and applications.
CRI-105 does not include carpet performance characteristics. Users are urged to review
appropriate publications developed by The Carpet and Rug Institute for guidance in selecting
and specifying carpet.
NOTE: For standards applicable to the installation of commercial carpet and carpet modules.
please refer to CRM04, the Standard for Installation of Commercial Textile Roorcover-
ing Materiel*.
Q-iii
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INTRODUCTION
This ouDiication is unique m its content.
it contains tne CRN 105 Standard Reference Guide and a Specific Reference Section n
support of the Standard Reference Guide.
It also includes a section listing expectations from and by the consumer entitled "Consumer
Check List" and a section of expectations from and by the installer entitled "Good Customer
Relations."
Installers are urged to study and understand both sections. This will help the installer prepare
for questions from the customer and prevent being caught unaware.
It is recommended that retailers discuss the "Consumer Check List" with the consumer prior
to the job. This will help the customer understand what can be reasonably expected and which
services may incur additional costs.
These two sections are intended to provide a better understanding between the consumer
and the installer. Assumptions and false expectations can be avoided by creating a
understanding before the job begins, which will result in consumer satisfaction . the
objective.
Q-iv
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CONSUMER CHECK LIST
FOR THE INSTALLATION OF CARPET
The installation of carpet is the most important function to be performed once you
selected your carpet and its intended use. There are a number of things you can ao
and should know which can help you obtain an installation job to your satisfaction and
needs.
A sketch . . it would be helpful to make a rough sketch with approximate measure-
ments of the area(s) where carpet will be installed. Try to locate all windows, doors.
closets and unusual angles. However, you should ask the retailer or the installation
company to make accurate measurements for actual installation purposes.
Seams ... be sure there is agreement between you and the dealer as to the loca-
tion of all seams that may be required before the job starts. Usually, seams are best
laid toward the primary natural light source. Visibility of the seams will vary with the
type of carpet purchased. Please understand that most carpet seams cannot be
guaranteed to be invisible.
Carpet size . . . be sure there is an exact understanding of the total amount of carpet
required for each and every location. Most carpet is made in standard widths. Please
understand that there is a good chance for some small overages due to corners, room
sizing, etc. This is normal.
Cushion . . . be sure to have the appropriate type of cushion (underlayment or pad-
ding) laid to serve your specific needs. It may differ from room to room. There are many
different types of cushion available. Be sure to discuss those at the time you purchase
your carpet.
Moving furniture ... do you plan to move your own furniture out of the room, or
do you expect the installers to move the furniture for you? There may be an extra charge
involved. You may wish to move cherished or fragile items yourself.
Appliances . . . in the event appliances require a utility disconnect (water, gas, etc.),
local code requirements and disconnect/reconnect arrangements are to be determin-
ed in advance.
Removal of existing carpet . . . before any work commences, discuss who is ex-
pected to remove the existing carpet and cushion and if the cost of that task is includ-
ed. Be sure to advise the installers whether or not you wish to keep that carpet or
have it taken away.
Q-v
-------
Installation date . . . agree on an installation date and obtain a rough approxima-
tion of the amount of time required to complete the job. Have an alternate date m mmd
m case the carpet cannot be installed on your preferred date.
Stretching of the carpet . . . all carpet should be power stretched. Tautness of the
carpet is essential to assure a good, long lasting installation. It will also enhance the
performance of your carpet and prevent wrinkling or buckling.
Leftovers . . . advise the installers if you wish to keep smaller, leftover pieces of
carpet or if you wish to have the scraps taken away.
Vacuum . . . arrangements for the vacuuming of the newly installed carpet should
be made in advance. Vacuuming may involve an extra charge.
Guarantee/Warranty ... it is important that there is an understanding of the
guarantee/warranty; what is covered/not covered; and the procedure if a service call
is required. Find out what can be reasonably expected.
Ventilation ... as with most new products, new carpet may initially have a slight
odor. This is normal. Adhesives or hot melt seaming tapes used to install the carpet
may have a slight odor while they are curing. Existing carpet or cushion, while being
removed, may create an odor.
All removal or installation processes are best handled under optimum fresh air
ventilation conditions. During installation, be sure that windows and doors are open,
conditions permitting. Ideally, the heating/air conditioning/ventilation system should
be operating at normal room temperature with maximum fan speed.
If you, a member of your family, or other occupants are sensitive to certain odors, you
may wish to be absent during installation. After the installation has been completed,
you may wish to ventilate the premises with fresh air by opening windows and doors
and operating the ventilation system at normal room temperature with fan speed at
maximum capacity for at least 48-72 hours. This will help eliminate the existence of
any lingering odors.
Q-vi
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GOOD CUSTOMER RELATIONS
Customer satisfaction is the ultimate objective. Observing the following rules will enable
a carpet installer to avoid callbacks, avoid costly claims, and earn the respect and
goodwill of the customer. The carpet installer is the last person with whom the customer
has any cc act. The customer has the right to expect professionalism and a quality
retaliation. A good impression is a lasting impression.
Before the job... review the plans and installation requirements of the job and resolve
any questions before going to the job site. Make sure your tool box has everything
you might need for the installation. Be sure to have a sketch of the area(s) where the
carpet will be installed showing the location of all seams, edge molding, etc.
Double check before going to the job to see that you have the correct carpet, cushion
and supplies as ordered/purchased by the customer and that the quantity is sufficient
to complete the job.
Be on time .. .always be on time. If you are detained for any reason at all, be sure
to call the customer and determine if it is still convenient or if another day and time
should be scheduled.
Be neat . . . always have a neat appearance.
Respect the customer... always respect a customer's home. You are there to add
function and beauty to the environment. You are there because the customer has asked
for your services as a professional installer of carpet.
Be courteous ... be courteous and friendly to everyone. Maintain a professional
decorum. Do not talk about your personal problems with the customers.
If you smoke, first ask permission. Many people do not smoke. Please respect the
customer's wishes. A good indication is the availability or lack of ashtrays in a home.
Always ask permission to use the bathroom and be sure to leave it in the same condi-
tion you found it. If you have any trash, be sure to ask permission for its disposal and
where it should be placed.
Always obtain the customer's approval before using the phone.
Be professional . . . instruct your helpers and fellow workers not to argue in the
presence of the customer about the work and how it should be done.
Q-vii
-------
Do not try to be a "salesperson" on the job. Something you say could create a problem
Avoid answering the customer's questions about the quality of the carpet or cushion.
Do not volunteer information about any of the products. Instead, suggest that the
customer call the store for that kind of information.
Should you see or suspect a manufacturing defect, immediately contact the retailer
who sold the carpet for directions.
If you run into an unexpected installation problem on the job, talk it over with your
customer so that he/she will know beforehand what you plan to do to resolve it and
why you are doing it. If there are additional costs involved, be sure the customer is
asked to call the store.
If you should accidentally make a mistake in the installation, or damage the carpet.
repair it immediately.
If a change in the time schedule, or possibly other inconveniences, should be necessary,
be sure to discuss this with the customer.
Never discuss with the customer how difficult the carpet may be to install.
Make sure the job is done right and that you are proud of your workmanship and that
of your co-workers.
Things to do ... if you are asked to move furniture, do it carefully and make sure
the customer knows that you are being careful and can see your caution. If you are
asked to move appliances such as stoves and refrigerators connected to gas or water
lines, be sure to have the customer arrange the utility disconnect in advance.
The estimator/measurer should initially check and list existing damage; i.e., chipped
paint, scratched walls, chipped or scratched furniture, worn wallpaper, etc. Upon
arrival at the customer's home, the installer should recheck. Discuss their existence
before and after the job with the customer. If customer is not present, a list should
be kept.
If removal of existing shoe moldings has not been addressed by the store, then the
installer shall contact the dealer for direction.
Confirm with the customer the location of seams as indicated on the drawing agreed
to in advance by the customer and the dealer. If necessary, explain why they are located
there. Most locations require seaming toward the primary natural light source with some
Q-viii
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notable exceptions such as high traffic areas, doors, etc. if the initially agreed
seam locations appear to be unacceptable to the customer, call the store Customer
understanding and approval of seam locations are essential to customer satisfaction
F.nd out from the customer if you are expected to remove the existing carpet arc
cushion or if the customer wishes to keep them.
Ask the customer if they would like to keep the smaller pieces of carpet (if any)
If the carpet arrives at the customer's place rolled up or wrapped in plastic containers
be sure to unwrap these rolls outside, allowing them to breathe and relax Defore
taking them to the area where they are to be installed.
Be sure that the room is adequately ventilated while you are working. Windows and
doors should be opened. The ventilation system should operate at full fan speed. Utilize
plenty of fresh air.
Carpet, cushion and adhesives used for seaming and/or installation often have a slight
odor while they are curing. This is normal. However, if the customer expresses a
sensitivity to these odors, be sure to recommend that the windows be kept open and
that the ventilation system continue to operate at full fan speed for at least 48-72 hours
after the installation has been completed. Settings of the heating/air conditioning system
should be left at normal room temperature levels. This will help eliminate the existence
of any lingering odors.
Arrangements for the vacuuming of the newly installed carpet should be made in
advance. There may be an extra charge for this service. Leaving the carpet vacuum-
ed after the job has been completed leaves a good impression of the product and a
finished look to the job.
Upon completion ... do not leave the job until you have cleaned the work area. A
tidy area leaves a good impression and enhances the beauty and quality of your
installation.
Check over the completed job before leaving and ask yourself the questions: Would
you be proud and satisfied to have this in your home? Would you put your name on
this installation?
Finally, invite the customer to join you and inspect the completed installation.
-------
STANDARD REFERENCE GUIDE
FOR INSTALLATION OF RESIDENTIAL CARPET
-------
STANDARD REFERENCE GUIDE
FOR INSTALLATION OF RESIDENTIAL CARPET
1. Scope of this Standard Reference Guide (See Section 1, p. 21)
1 1 This guide covers the installation of residential carpet.
1 2 This guide covers the preparation of the subfloor.
1.3 This guide establishes minimum installation procedures. These procedures shall
not be decreased.
1.4 This guide may be changed only by specific recommendations from the manufac-
turer of the products to be installed.
2. Specific Reference applicable to this Standard Reference Guide (pp. 19-39)
2.1 The "Standard Reference Guide for the Installation of Residential Carpet Specific
Reference Section" is applicable to this minimum Standard Reference Guide if
more detail is desired or in the event of varying conditions and/or applications.
3. Tools and Materials (See Section 3, p. 21)
3.1 Carpet shall be installed using the tools listed in Table I.
3.2 Use of a power stretcher is mandatory on all wall-to-wall installations.
3.3 Materials shall be selected from the list in Table II.
3.4 Adhesives shall be used as recommended by the carpet manufacturer or adhesive
manufacturer but not less than in Table III.
3.5 Whenever possible, the carpet, cushion and adhesive* should be conditioned to
site conditions prior to installation.
4. Handling (See Section 4, p. 22)
4.1 Do not bend or fold rolls of carpet unless it is necessary for delivery purposes.
Carpet rolls shall be unfolded upon arrival at the job. Carpet shall not be left bent
or folded.
4.2 Storage at the job site shall be dry and secured.
5. Site Condition* (See Section 5, pp. 22 24)
5.1 Every subfloor shall be property prepared. Concrete, wood or other flooring each
has its own preparation requirements as per Specific Reference Section 5.
5.2 Check and correct subfloor ridges and other unevenness which could be reflected
by the finished installation.
5.3 Carpet shall not be installed over existing carpet.
5.4 Cushion shall not be installed over existing cushion.
5.5 Whenever possible and conditions permit, all carpet shall be unrolled, relaxed and
allowed to ventilate with the induction of fresh air.
Q-l
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6. Environmental Conditions (See Section 6. p. 24)
6.1 Fresh air ventilation during installation shall be maintained by opening windows
and doors, by utilizing exhaust fans and by operating the ventilation fan system
at full capacity.
6.2 When conditions warrant, fresh air ventilation shall be maintained after installa-
tion for 48-72 hours at normal room temperatures by operating the ventilation fan
system at full capacity and by opening windows and doors if possible. This will
help eliminate or minimize the existence of any lingering odors.
7. Measuring (See Section 7, p. 24)
7.1 Each room shall be measured before installation to ensure efficient use of carpet
and proper location of jogs, projections, openings, hearths, closets, stairs and door
swings.
8. Planning (See Section 8, pp. 24 - 25)
8.1 Determine responsibility for moving of furniture before and after installation.
8.2 Determine responsibility (customer or installer) for having door height adjusted (if
necessary) for proper clearance.
8.3 Determine disposition of excess carpet (keep or remove).
8.4 Determine disposal of scraps (customer or installer).
8.5 Obtain number of stair steps and size of the treads and risers (width, height, length).
8.6 Determine location and type of edge moldings and transitions.
8.7 Determine type of base.
8.8 Determine seam location and direction.
8.9 Determine correct seaming tape for application (See Table VI.)
9. Layout (See Section 9, pp. 25 27)
9.1 Seams should be placed toward the primary natural light source, whenever possi-
ble. If not possible, seams are to be kept out of heavy traffic areas or placed where
they can be covered by furniture.
9.2 Carpet pile shall run in the same direction and toward the entrance unless specified
otherwise.
9.3 Dye lots of carpet shall be matched or sequenced.
9.4 A 3-inch minimum overage is required for each cut of carpet unless the pattern
repeat demands otherwise.
10. Customer Sign-Off (See Section 10, p. 27)
10.1 Obtain customer agreement on seam locations prior to installation.
10.2 Obtain customer agreement on quarter turning of carpet prior to installation.
Q-2
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INSTALLATION
11. Carpet Over Cushion (See Section 11, pp. 27 30)
1 Separate cushion used shall be m accordance with the carpet manufacture1- s
recommendation. (See Table VIII)
' * 2 Seoarate cushion shall be securely fastened to the subfloor with smooth side JD
or m accordance with manufacturer's recommendation.
11.3 Separate cushion seams shall be perpendicular to carpet seams or offset Dy at
least 6 inches.
11.4 Tackless strips shall be not less than 1 inch wide and 1/4-mch thick. (See Table
V for correct application.)
11.5 Tackless strips are to be fastened around the perimeter of the room with a gutiy
slightly less than the thickness of the carpet from the wall but not to exceed 3/8-mcn
11.6 Do not place tackless strips across door openings or door sills except where there
is a threshold.
11.7 Carpet shall not be stapled to the tackless strip.
11.8 Before seaming, carpet should be power stretched at seam line. (Hot melt tape
does not stretch.)
11.9 Carpet must be fastened undtr tension on tackless strips around the perimeter
of the room over separate cushion.
11.10 Trim all edges used for seaming at least one inch on each side. NOTE: Selvage
of some woven carpet must not be trimmed.
11.11 Trimmed seam edges should be sealed with an appropriate seam sealer.
11.12 Seaming method is dictated by the type of carpet backing and carpet construc-
tion in accordance with Table VI.
11.13 After seaming, the carpet must be properly stretched with the edges hooked to
the tackless strips of the starting and surrounding walls with a power stretcher
(See Figures 3-6 for appropriate stretching diagrams). Use of a power stretcher
is mandatory.
11.14 Amount of stretch is per manufacturer's recommendation or Table VII.
1115 Wall trimmers shall be adjusted to leave sufficient excess carpet to tuck into gullies.
12. Carpet on Stain (See Section 12. pp. 30-31)
12.1 Stair nosing should be rounded at a radius of 3/4-inch - 1 inch.
12.2 Tackless strips shall be secured on each tread and riser. Pins on steps point toward
riser. Pins on risers point down toward tread.
12.3 Gullies between the tackless strips are to be slightly less than double the carpet
thickness.
12.4 Tackless strips and cushion shall be cut 1 1 /2-inch leas than the width of the carpet
to allow for turn under each side of the stairs. Some stairs require tackless strips
on the sides to maintain proper tension.
12.5 Carpet shall be secured to each tackless strip using a knee kicker or stair
Q-3
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stretcher and driven into the gully with a stair tool at the junction of the tread and
riser.
12.6 Curved or sloped areas shall have the carpet tailored to fit the tread and riser without
wrinkles and with the edges neatly finished.
13. Direct Glue-Down of Carpet (See Section 13, pp. 31 - 32)
13.1 This method is not widely used in residential applications but is an acceptable
method for installing carpet on concrete or plywood subfloors, stairs and basements.
13.2 Floor preparation, layout specifics, use of adhesives and tools, edging, seaming.
trimming and roiling require special techniques as per Specific Reference
Section 13 of the Standard Reference Guide.
13.3 Site conditions shall be met in accordance with Section 5 of the Standard Reference
Guide.
14. Double Glue-Down of Carpet (See Section 14, pp. 32 33)
14.1 This method is not widely used in residential applications but can be used as recom-
mended by the manufacturer with special minimum requirements as per Specific
Reference Section 14 of the Standard Reference Guide.
15. Attached Cushion Carpet (See Section 15, pp. 33 - 34)
15.1 Carpet with attached cushion shall be installed in strict accordance with the manu-
facturer's recommendation. Dye lot checks, floor preparations, layout specifics.
use of adhesives and tools, edging, seaming, trimming and rolling require special
techniques and cautions per Specific Reference Section 15 of the Standard
Reference Guide.
15.2 Site conditions shall be met in accordance with Specific Reference Section 5 of
the Standard Reference Guide.
16. Outdoor Carpet and Synthetic Turf (See Section 16, pp. 34 - 36)
16.1 Outdoor carpet installation conditions differ significantly from those encountered
indoors. Carpet and adhesives must meet extreme weather, temperature, surface,
traffic and differing use conditions.
16.2 Use only products specified by manufacturers for outdoor applications.
16.3 Surface preparation, layout, use of adhesives and tools, edging, seaming, rolling
and finishing require special techniques as per Specific Reference Section 16 of
the Standard Reference Guide.
17. Protection of the Installation (See Section 17, p. 36)
17.1 If protection of the carpet is required immediately after installation, cover the
affected area with a non-staining building paper. Caution: Do not use plastic
sheeting on any installation as it may trap moisture, retard curing of the adhesive
or prevent the ventilation orocess.
Q-4
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18. Customer Acceptance (See Section 18, p. 36)
18.1 Upon completion of the job. the customer shall be asked to sign a job completion
ticket.
Q-5
-------
Q-6
-------
SPECIFIC REFERENCE SECTION
in support of the
STANDARD REFERENCE GUIDE
FOR INSTALLATION OF RESIDENTIAL CARPET
Q-7
-------
STANDARD REFERENCE GUIDE
FOR INSTALLATION OF RESIDENTIAL CARPET
SPECIFIC REFERENCE SECTION
1. SCOPE
This standard covers the installation of residential carpet in a home, apartment, scat
trailer or other type residence and the preparation of the subfloor over which t AH
be installed.
This standard establishes minimum installation procedures. These procedures shall not
be decreased.
This standard may be changed only by specific recommendations from the manufacturer
of the products to be installed.
2. APPLICABLE DOCUMENTS
Standard for Installation of Commercial Textile Poorcovenng Materials CRI-104 Carpet
and Rug Institute
Carpet Specifier's Handbook Carpet and Rug Institute
How to Specify Commercial Carpet Installation Carpet and Rug Institute
Areas of Responsibility Carpet and Rug Institute
Carpet Installation Training Manual (Student's Guide) - Floor Covering installation
Training Council
Carpet Installation Training Manual (Instructor's Guide) Floor Covering Installation
Training Council
3. TOOLS AND MATERIALS
Carpet shall be installed using the tools listed in Table I.
Use of a power stretcher is mandatory on all wall-to-wall installations.
Materials shall be selected from the list in Table II.
Adhesive* shall be used as recommended by the carpet manufacturer or adhesive manu-
facturer but not less than in Table III.
Whenever possible, the carpet, cushion and adhesive should be stored in a heated and
dry place.
Whenever possible, the carpet should be stored under environmental conditions which
closely approximate ideal installation temperatures and conditions at the |Ob site. This
will allow the carpet to be "relaxed" and prevent problems in both stretch-m and glue-
down installations.
Carpet shall be stored in flat bins to help prevent pile crush. Temporary storage shall
be in flat bins with a height not to exceed three rolls.
Q-9
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4. HANDLING
r-99 W WWII v^M
It is preferable that carpet be transported on flat dollies equipped with carpet craaies
Fork lifts shall be equipped with booms. Bending and folding of individual carpet rcns
is not recommended unless absolutely necessary for delivery purposes. The earner
shall not be left bent or folded. The bottom side must have a protective covering
Storage at the job site shall be dry and secured.
5. SITE CONDITIONS
Temperature and Humidity Ideally, carpet shall be installed when the temperature s
between 65° and 95° F and the relative humidity is between 10% and 65°'o and f
installing over concrete, the slab's temperature should not be less than 65° F
Floor Preparation Every SuOfloor shall be inspected to determine what special care
may be required to make it a suitable foundation for carpet, as follows:
Carpet over Carpet - Carpet shall not be installed over existing carpet.
Cushion over Cushion Cushion shall not be installed over existing cushion
Radiant Heat Ducts - Heat must be lowered before installation to prevent adhesive
from "setting" too quickly. When affixing tackless strip in stretch-m installations.
take care not to drive nails into conduits or pipes.
Sealers The use of sealers on floor surfaces is generally not necessary except for
sanded, dusty, porous and acoustical surfaces. Sealing cannot overcome high
moisture conditions and must not be used for that purpose. When used, sealers
must be thin and fast-drying. They should be compatible with adhesives, which
should be applied only after sealer is dry.
Concrete New concrete shall be cured, cleaned and dry. It shall be free of curing
or parting agents that interfere with the bonding of the adhesive. The builder or
general contractor of the building should be asked by the installer for a report
on the slab's moisture percentage. The moisture content shall not exceed 65%.
To determine the existence of excessive moisture on-site, place a hygrometer m
several areas of the floor near an inside wall and cover with a sheet of clear plastic
film about 2 feet (61 cm) square and seal with duct tape. A rough estimate may
be obtained within 30 minutes, though 24 hours is needed for an accurate check.
(NOTE: Moisture test kits are available.)
Moisture tests on slabs below 55° F (13° C) are inaccurate as moisture migration
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'S retarded by low temperature
Wherever a powdery surface is encountered, a sealer snail be used, ccr-ca: - a
/v'th :*e adhesive, to provide a suitable surface for a glue-flown installation *-«-
5oec:f.'ed.
Moisture in Concrete Subfloors Whenever possible, at least 90-120 days are to
be allowed for a concrete slab subfloor to cure and reach acceptable aryress
Appearance alone is not a reliable test. The builder or general confac::'
involved shall be asked for moisture and alkali test results on the concrete 5 ac
prior to the installation. This is necessary to prevent adhesive breakdown prooier-s
due to moisture or alkali. A pH range of 5-9 is satisfactory But 10 or Tore
requires corrective measures. This can be accomplished by applying an acid rinse
consisting of 10 parts water to 1 part muriatic acid, and rinsing twice with dear
water. In some cases, a 30% mixture of vinegar and water may be used to reduce
alkalinity.
pH on the surface of the concrete can be determined by slightly wetting the floor
and applying pH test paper.
In case "Gypcrete" lightweight or acoustical concrete is used, check the manu-
facturer's recommendations for the proper sealer to be used before the carpet
is installed.
Wood Wood subfloors should have a minimum 18-inch air space underneath with
cross ventilation. Plywood, hardwood and particle board used as the subfloormg
must be of a flooring grade installed to the manufacturer's specifications. Old wood
shall be checked for soundness, and any loose boards shall be renailed. Joints
and rough and uneven areas shall be smoothed and sealed.
Oil contaminated floors must be covered with a suitable subfloor such as plywood
or particle board installed according to Hardwood Plywood Manufacturers Associa-
tion or Particle Board Manufacturers Association recommendations.
The suitability of a painted wood surface for a glue-down installation can be checked
by gluing down a 2-foot square of carpet. If the adhesive's bond is strong, and
the paint does not pull up with the carpet after 72 hours, the carpet can be
installed. Glossy surfaces are to be roughened prior to installation.
Sanded and new floors shall be coated with a compatible sealer to provide a good
surface for glue-down.
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Metal Metal floors must be cleaned of grease, oil. dirt and rust and the surface leveled
Terrazo, Ceramic, Marble, Epoxy and Slate All of these materials represent
nonporous surfaces. If a carpet with a nonporous back is glued down over these
surfaces, strict attention must be given to the "open time" recommendations
6. ENVIRONMENTAL CONDITIONS
Fresh air ventilation during installation shall be maintained by opening windows and doors.
by utilizing exhaust fans and by operating the ventilation fan system at full capacity
When conditions warrant, fresh air ventilation shall be maintained after installation 'or
48-72 hours at normal room temperatures by operating the ventilation fan system at
full capacity and by opening windows and doors if possible. This will help eliminate
the existence of any lingering odors.
7. MEASURING
All facets of the installation should be coordinated. A correct measurement is essential
before any carpet can be planned, estimated or completed.
Measuring Exact length and width measurements shall be made with a steel
tape of every area to be carpeted.
Measurements should include jogs, projections, openings, hearths, closets.
stairs and door swings.
Short measures should be checked to make certain they add up to the total
measures or dimensions.
Estimating Yardage - After measurements have been completed, yardage should
be estimated with a minimum of waste. Use the scaled plan to lay out cuts
and fillers and excess carpet from each area. For patterned carpet, allow
sufficient yardage for pattern match. Determine yardage and seams by width
of carpet available. For example, if carpet to be used is 12 feet wide, scale
12 feet on the plan for all areas to be carpeted, allowing 3-inch overage on
each net cut. (See Figures t and 2)
8. PLANNING
If agreed upon decisions are made by the consumer, carpet dealer and installer prior
to installation, many problems and customer dissatisfaction can be overcome. The
customer should be a part of the planning stage.
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Prior to the arrival of the installation crew, there should be agreement as :c .-. "
will move the furniture This agreement should take into consideration re ar-~
pieces of furniture, such as waterbeds. hutches, refrigerators, pianos, etc as .-.e
as small items, such as lamps, end tables, etc it is important to Know .v c .v
oe responsioie for moving breakable and valuable items from on and ~, e
'urnture
In the event appliances require a utility disconnect (water, gas. etc ) local coce
requirements and disconnect/reconnect arrangements are to be determirec "
advance by the customer.
If this is the first time carpet is installed or a higher pile is to be used, the doers
may not have sufficient clearance to swing freely over the carpet. Arrangements
need to be made as to who will be responsible for cutting the doors
Arrangements need to be made in advance as to who will remove and dispose
of the old carpet and cushion.
The customer should be allowed to have a choice of the type of metal or vmyi
molding to be used.
The customer should be shown the proposed layout which contains ail of the
seams. The location of the seams should be explained and an agreement
obtained before any work starts.
If a piece of carpet is to be given a quarter turn, the customer should be informed
and a written agreement obtained.
The customer should be made aware of carpet scraps and allowed to decide what
should be done with them.
LAYOUT
A scale drawing of the areas to be carpeted is required to determine yardages, yardage
per dye tot, edge treatments, cushions, adhesives. moldings, other accessories and
to identify proper location of seams.
For new homes and apartment buildings, architectural drawings shall be provided that
indicate the areas to be carpeted with room designations or apartment numbers plus
a finished schedule of carpet styles, patterns, colors and installation methods to be
used for each area. For existing buildings, new measurements and shop drawings
shall be made.
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Shop Drawings and Layout - The carpet shop drawing shall contain -re
following information:
Name of the owner of the home or apartment and the installation company
On new construction, the names, addresses and telephone numbers of the
general contractor, architect and interior designer shall also be listed
Address and telephone number of the customer (end-user).
For homes or apartments, the floor number and location in building. marKmg
room names - L.R., D.R.. M.B.R., Hall, Ent., etc.
Date of drawing.
Scale drawing of carpet layout to be approved by end user.
Scale drawing for each area to be carpeted.
Location, swing and clearances of all doors.
Type of floor for each area on which carpet is to be installed (with notation
as to what type of old carpet or floorcovering is currently installed and who
will be responsible for removal).
Type of installation to be used for each area.
Quantities of carpet needed for each area, including roll length requirements.
A cut list should accompany the diagram to avoid misunderstandings.
Notations where dye lot changes will occur.
Excess material in each area and now it will be used.
Seam layout of each area.
Carpet pile direction for each area.
Name of manufacturer, quantity and color of carpet for each area.
Location and type of all edge moldings.
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Type of base m each area.
Location of door openings requiring edging.
Stairs - Stairs should be shown on the plan in proper scale and location, indicating
the number of steps, dimensions of treads and risers and wioth of stecs
Seams Seams shall be kept to a minimum, positioned where possible so that
A. Mam traffic runs along, rather than across, the seam.
B. Incident light does not strike across the seam.
C. The seams are away from areas subject to pivoting traffic.
0. Seams are not perpendicular to doorway openings.
Pile Direction Where two or more pieces of the same carpet are adjacent, the
pile direction shall run the same as in other areas of the room, unless other-
wise specified. Ideally, pile direction shall be toward the entrance, but other
factors such as pattern, aesthetics and economic use of material may also
be considered. Pile direction on stairs should be illustrated.
10. CUSTOMER SIGN-OFF
The customer or end user should be shown a copy of the completed shop drawing,
signing off to indicate approval.
INSTALLATION
11. STRETCH-IN UTILIZING TACKLESS STRIP
Using this method require* fastening the carpet under tension on tackless strip around
the perimeter of the area to b« carpeted. A separate cushion shall be used. (See
Section 5 regarding Site Condition*.)
Layout and Material Carpet is to be laid out with considaration to traffic patterns
and taam placement. All materials shall be on the job site prior to the beginning
of the installation to aasura uniformity of the application.
Tackles* Strip Tackles* strip applications art to be matched to each specific use
in accordance with Tab** V. (NOTE: Standard and prt-nailad wood should b« a
minimum of 1 inch wida and 1/4-inch thick.) Architectural strip with three rows
of pins is to be usad for carptt with haavily-lataxad backs, most wovens and
certain "Berber" typa carpet with knobby backs, or rooms exceeding 30 feet.
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Installation of Tackles* Strip
A. Full length pieces of tackless strip shall be spread around the .vail
, trimeter with pins pointing toward the wall.
8. The proper gully shall be slightly less than thickness of the carpet, aut
not to exceed 3/8-inch.
C. The tackless strip shall be cut to proper lengths to maintain the same
gully regardless of the shape of the wall.
D. The tackless strip shall be securely fastened to maintain the proper stretch
provided by power stretching. Two nails or fastening points are required
for the smallest pieces of tackless strip.
E. Carpet shall NOT be stapled to the tackless strip.
F. Avoid placing tackless strip across door openings or door sills where
possible.
Installation of Separate Cushion The selection of separate cushion shall be m
accordance with the carpet manufacturer's recommendation.
Contact the carpet manufacturer to obtain his cushion requirements m order to
prevent problems resultant from improper cushion selection and the possible
voiding of applicable warranties. Choice of cushion which is inappropriate for the
end use application of the carpet may result in accelerated loss of appearance
retention, wrinkling, buckling, and the separation of the carpet backing or seams.
Cushion thickness should not exceed 7/16-inch.
Cushion is to be installed in the longest continuous lengths possible. The cushion
seams should not be installed directly under the carpet seams. Generally, they
should be placed at right angles to the carpet seams. When this is not practical,
shift the cushion so that seams are at least 6 inches to one side of the carpet seams.
Cushion Installed WalMo-WaH - Cushion shall be securely fastened to the
subfloor with staples or nonflammable cushion adhesive around the perimeter
of the installation. Seams shall be secured with staples or nonflammable
cushion adhesive. However, tape - such as duct tape - shall be used for seams
on rubber cushions. These procedures are required to prevent shifting of the
cushion during and after the installation.
Foam or sponge cushion with a waffle design should be installed with the
smooth side up.
Vinyl-covered fabric tape such as duct tape, or adhesives, shall be used for
seams on foam cushion. Staples or adhesives are to be applied 1 6 inches
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within the perimeter edges all around.
Layout and Cutting - Following the seaming diagram, cut sufficient length of caroet
that will cover the entire area. Where pattern matches are involved, an extra reoeat
must De allowed on each cut for the match, plus extra carpet (3 mcnesi on eaci
cot 'or trimming.
Trim all edges that are to be used for seaming at least 1 inch on each side :NOTE
The selvage of some woven carpet must not be trimmed The manufacturer 3
ecommendations should be followed.)
r
Edge Securing Trimmed seam edges should be sealed with an appropriate sean
sealer. Unsealed seams can lead to seam deiammation of tufted carpet or toss
of face yarns with unsightly results.
Seaming The choice of seaming method is dictated by the type of carpet backing
and carpet construction.
Hot Melt Tape A fabric seaming tape precoated with a thermoplastic adhesive is
centered beneath the seam. Heat from an electric iron melts the adhesive.
laminating the carpet backing to the tape. A grooved iron is recommended for
better penetration of the adhesive. Proper iron temperature is essential, with special
care taken for carpet with synthetic backing or synthetic pile yarns. Always
run the iron in the smooth direction of the pile. The maximum recommended heat
setting is "2 1/2". A heat shield for the iron is required. A metal surface should
not be used to weight the seam behind the iron, as metal traps the heat. Wood
should be used for this purpose.
A premium tape with high tensile strength and sufficient adhesive on the woven
scrim is recommended. NOTE: To minimize elevating and peaking, a 6-inch wide
tape should be used.
Pre-stretch the carpet in the seam areas before making the seam.
Tape and Latex The seaming tape shall be centered directly under the seam. Latex
seaming adhesive is applied to the tape. The seam shall be allowed to dry at least
8 hours before stretching.
Hand Sewing Hand sewing shall be an overcast stitch placed not more than 1/2-mch
apart and no lew than 1/2-inch from the edge of the carpet. It is recommended
that a latex coating and tape be applied over the stitching. Hand sewing is
recommended for all Wilton and most woven carpet.
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Electrical Tap* For electrically conductive tapes, follow the manufacturers
recommendations.
Power Stretching - Following seaming, carpet must be power stretched anc firm-/
hooked to the tackless strip at the starting walls and on the tackless strips m :*e
surrounding area. The use of power stretchers is mandatory.
Before power stretching, make certain that hot melt tape seams are cool to the
touch.
A four-way stretch is to be used (See Figures 3-6).
Follow the carpet manufacturer's recommendations for the method and amount
of stretch to be used. When recommendations are not available, tufted carpet with
jute secondary back should be stretched "drum-tight." Tufted carpet with
synthetic secondary back should be stretched 1% to 1-1/2% m width and length
Some woven carpet, such as velvet, does not stretch in the length, while other
woven carpet, such as an Axminster, has no stretch in the width. Where there
is no stretch, the carpet should be power stretched "snug" in these directions.
A wall trimmer shall be used to trim the carpet along walls and abutments. The
trimmer shall be adjusted to leave sufficient excess carpet to tuck into the gullies.
12. CARPET ON STAIRS
Stair carpet should be installed as follows:
Preparation Stair nosing should be rounded 3/4-inch to 1 inch to prevent sharp stair
edges from cutting the carpet and/or cushion.
Stretcher) Installation Tackless strip is to be installed on each tread and riser. Pins
on the step point toward the riser. Pins on the risers point down to the step. The
gully between the strips is slightly less than double the carpet thickness. Tackless
strips and cushion are about 1 1/2-inch less than the carpet width to allow for a
turn under on each side of the stairs. Some stairs require tackless strip on the
sides to maintain the proper tension.
Using a knee kicker, or "stair stretcher," stretch the carpet tightly over each step.
The carpet should be secured to each tackless strip and driven into the gully witn
a stair tool at the junction of the tread and riser. Curved or sloped areas shall
have the carpet tailored to fit the tread and riser without wrinkles and with the
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edges neatly finished.
Glut-Down Installation on Stairs Carpet is to be tigntly secured to treads anc <-sers
using a proper adhesive A separate piece of carpet snail be used ?or eacn steo
with nser. except on steps without nosing. Carpet should be installed with tre
pile direction m the length of the stair.
13. DIRECT GLUE-DOWN
Direct glue-down adheres carpet to subfloors by use of nonflammable adhesives The
edges of the carpet are butted together to form seams. Though direct glue-down
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backing.
Roiling - Rolling shall be performed as follows:
Jute or Synthetic Secondary Backing Tufted carpet with jute or synthet c
secondary backing should be pressed into the adhesive bed with a 2-foot section
of carpet core or by using a roller weighing not more than 50 pounds. Roll m ootn
directions thoroughly, but do not over roll.
Unitary Back Unitary (single back) carpet and woven carpet must be roiled a
second time with a 35 50 pound roller a minimum of 3-1/2 hours after initial
rolling to make certain a strong bond is established.
Trimming - The wail trimmer shall be adjusted to net trim the excess carpet to the wall.
14. DOUBLE GLUE-DOWN
Site and environmental conditions for double glue-down should be the same as for direct
glue-down (Refer to Sections 5 & 6). But, in this type of installation a separate cushion
is adhered to the floor, and the carpet is glued to the cushion using the same methods
utilized for direct glue-down. NOTE: As significant differences exist in various carpet
cushions, consult with the manufacturers of the cushion, carpet and adhesives for
their recommendations in this type of installation.
Preparation - The floor is to be dry and free from contaminants which will prevent
good adhesion. Surfaces shall be vacuumed and thoroughly cleaned before
applying the adhesive.
Trowel Notch Sizes and Adhesives for Double Glue-Down Installations Select
the appropriate adhesives and trowel notch sizes recommended by the manufac-
turers of the carpet, cushion and your adhesive suppliers. The trowel notch size
should be sufficient to apply a continuous thin film of adhesive to the floor for
glue-down of the cushion. It should also be of the proper size and shape to assure
full coverage of the adhesive into the carpet back for a proper glue-down of
the carpet to the cushion. A premium adhesive is recommended.
Woven and unitary backed carpet requires full penetration of the adhesive into
the "valley," between the tuft rows on the back.
Layout-Cushion - After the floor is prepared, the layout and cutting of the cushion
should be completed. Cushion should be installed in the longest continuous lengths
possible with consideration given to the traffic pattern and seam placement of
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the carpet. Cushion seams should not be directly under the carpet seams
located at right angles or offset at least 6 inches from the carpet seam
Cushion seams must be tightly butted, leaving no gaps Place cushion 'lush
wails, tnmmmg for net fit. Fold back the cushion and begin applying adhesive
to the floor
Layout-Carpet Cut the carpet to the proper length and spread out m the area to
be carpeted. The carpet shall be cut 3 inches longer than the area measurement
Where applicable, also allow for pattern repeat. Carpet seams should be at a ngnt
angle to the cushion seam or offset at least 6 inches to either side. Align ail carpet
breadths to their proper position and trim the seams. Select the appropriate
adhesive and trowel notching from the list shown in Tables III and IV
The adhesive shall be spread uniformly over the cushion surface with the specified
trowel. After sufficient open time, the carpet is to be pressed into the adhesive
and roiled with the appropriate roller. WARNING: Lack of adhesion caused either
by a low quality adhesive or wrong trowel selection is the number one cause of
failures in glue-down and double glue-down installations.
Edge Seaming Edges are to be butted to form seams. A bead of seam adhesive
is to be applied to the edges of the carpet to seal the seams and prevent fraying
and raveling. The seam adhesive should be applied along the trimmed edge where
the face yarn enters the backing. Sewn seams or hot melt seams may also be
used. If hot melt tape is used, it should be non-silicone treated, and the edges
of paper beyond the netting should be removed, or the manufacturer's recom-
mendation should be followed.
Rolling - Rolling shall be performed as follows:
Jute or Synthetic Secondary Backing Tuned carpet with jute or synthetic
secondary backing should be pressed down into the adhesive bed with a 2-foot
section of carpet core or by using a roller weighing 35 - 50 pounds. Roll m both
directions, but do not over roll.
Unitary Beck Unitary back or woven carpet must be rolled a second time with
a 35 - 50 pound roller about 3-1/2 hours after initial rolling to make certain a strong
bond is established.
15. ATTACHED CUSHION
Site Conditions arid ROOT Preparation See Section 5.
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Adhesives'-Use only adhesives recommended by the carpet or adhesive manufacturers
Use the tacky adhesive method for installing attached cushions. Caution: Vinyl
backed carpet requires special floor and seam adhesives.
Installation Check dye lots. If there is more than one dye lot, determine best breaking
point. DO NOT MIX DYE LOTS. Lay out carpet by overlapping the edges and making
sure the carpet with the attached cushion lays flat and the pile runs in the same direc-
tion. Rough cut carpet in at walls and columns. Cut seams according to manufac-
turer's recommendation. Check for height differences at the seam and correct if
necessary. Carefully fold back both breadths of carpet, being careful not to shin the
carpet. Using recommended adhesives and proper notched trowel, spread adhesive
in a uniform manner. Keep trowel clean and properly notched. Check proper open
time of the adhesive, allowing the adhesive to develop legs or tack before installing
carpet. Lay the first breadth into the adhesive and smooth out using back of broom
or section of carpet core. Attached cushion carpet shall be rolled as per the manufac-
turer's recommendation. Seal the seam edge using recommended seam adhesive
Lay the other side into the adhesive, butting the second edge tightly against the first
edge. DO NOT LET SEAMS PEAK. Press the second carpet into the adhesive pushing
away from the seam, working out any trapped air. Clean excess adhesive from seam
using recommended cleaner and white cloth. DO NOT FLOOD SEAM WITH CLEAN-
ING SOLVENT. Check the seam and clip any loose tufts with nap shears. For cut
piles, make sure the yam is not buried in the seam.
16. INSTALLATION OF OUTDOOR CARPET AND SYNTHETIC TURF
Outdoor carpet installations offer conditions quite different from those encountered
indoors. Both carpet and adhesive are subjected to extremes of weather and traffic.
and installation surfaces will be much more varied and often uneven.
Carpet Type - The carpet to be installed outdoors should be of the construction and
type of synthetic face and backing yams recommended for outdoor use.
Stte Conditions All installation surfaces must be clean, dry, sound, cured, smooth
as possible and with adequate drainage.
Concrete Concrete surfaces must be clean, dry and free from alkali. They must
be cured for a minimum of 60 days and longer, if necessary, according to weather
conditions. Ail wax must be removed, and painted surfaces should be sanded
thoroughly and cleaned before installation.
Wood - Painted wood surfaces should be sanded and sealed with an appropriate
outdoor sealer. Slotted wood surfaces should be covered with marine grade
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otywood and sealed. Waxed or oiled wood surfaces present special problems
will require resurfacing.
Metal - Metal surfaces must be cleaned of grease, oil. dirt and rust. Painted metal
surfaces must be rough-sanded with loose paint removed.
Terrazo, Ceramic, Marble, Epoxy These surfaces must be clean and dry witn
all wax finishes removed. *
State and Brick These surfaces may be too rough and uneven for most outdoor
installations and may require refimshmg and leveling before installation
Asphalt Asphalt must be clean, dry and free from excessive oil and grease and
m good condition. New asphalt must be cured for at least 30 days, or longer
dependent upon weather conditions. Old asphalt may require resurfacing before
installing carpet.
Swimming Pools Regardless of the surface encountered, indoor swimming pools
must be drained and dry before installing outdoor carpet. Outdoor pools must not
be used during installation. Any fungus or algae must be removed from the
surfaces to be covered.
Backing Materials The type of backing materials involved is very crucial m the
installation of outdoor carpet. Outdoor carpet backings can be classified into one
of the following types:
A. Fibers - Polypropylene, woven and nonwoven.
B. Vinyl Unitary or foam. (Requires special adhesive.)
C. Urethane Unitary or foam, smooth or patterned.
0. Latex Rubber Smooth, foam waffle and diamond shape.
CAUTION: Use of the correct adhesive will greatly determine the success of an
outdoor installation. Where the backing materiel is unknown, or if doubt exists.
contact the carpet manufacturer for a positive identification.
Adheeivee Adhesive selection is very important. Recommended adhesives for out-
door installations are as follows:
A. Solvent Based Preferred for outdoor installations as they can be applied over
a wide range of weather conditions and are generally more water-resistant.
CAUTION: Some contain flammable solvents and should only be used
outdoors.
B. Latex (Water) Based If used, must be of premium quality. Avoid using under
damp, humid or extreme cold or hot conditions. Surface of substrate must
be compatible with liquid adhesive.
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CAUTION: Always follow the manufacturer's recommended mstaiiarc"
procedures.
Layout - All outdoor carpet must be unrolled and allowed to relax at least one nc;-r
before installation. Ideally, this should take place when the temperature s
between 55° and 95° F. and the relative humidity is between 10% ana 65:3
The carpet should be pre-cut for the area to be covered, allowing for any requirec
trimming. Seams should be kept to a minimum and run with the traffic Datter-
whenever possible. Knee kickers may be used to position the carpet properly
but should be used with caution.
Where seams are required, be certain the pile lay runs in the same direction
Edge Seaming A bead of seam adhesive must be applied to all seam edges of the
outdoor carpet, as well as all exposed edges.
Rolling Generally, outdoor carpet will require rolling after installation. The size anc
weight of the roller to be used should be specified by either the carpet or adhesive
manufacturer.
Finishing All seams should be brushed, and protruding pile tufts should be
trimmed. Excess adhesive must be removed with a suitable solvent recommend-
ed by the adhesive manufacturer. The final installation must be cleaned and ready
for use.
NOTE: For indoor installation of outdoor carpet, follow the procedures outlined
in Section 11, except where outdoor conditions may also exist such as indoor
swimming pools, health spas and indoor-outdoor patios.
17. PROTECTION OP THE INSTALLATION
If required to protect the finished fioorcovenng from dirt or paint, or if additional wort-
is to be done after the installation, cover it with a non-staining building material paper
Plastic sheeting should not be used over glue-down or feckless installations as it
may trap moisture or retard curing of the adhesive.
Ideally, temperatures of indoor carpeted areas should never fall below 50° F (10° C)
regardless of the age of the installation.
18. CUSTOMER ACCEPTANCE
Upon completion of the job, the customer shall be asked to sign a job completion ticket
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19. DEFINITIONS OF TERMS
Alkali, n. A soluble substance with basic properties and having a pH of more than 7
Attached Cushion, n. Cushion material permanently bonded to the oack of carpet and
-gs oy the manufacturer. Often made of synthetic rubber foam or poiyurethane foam
Axmmster Carpet, n. Carpet woven on a special Axmmster loom by which pile tufts
are ncividuaiiy 'nserted from varied colored yarns arranged on wide spools This
process manes it possible to produce carpet and rugs of complex designs with many
colors, such as Oriental design rugs.
Baseboard, n. A board skirting the lower edge of a wall, covering the joint of the wail
and the adjoining floor.
Birdcage, n. - Common term used to describe the end of a stair rail where the banisters
are curved in a spiral to form a newel post.
Bullnose, n. Common term used for step return.
Carpet Cushion, n. A term used to describe any kind of material placed under carpet
to provide additional softness, support and noise absorption when walked upon. Also
referred to as carpet lining, padding or underlay, although "carpet cushion" is the
preferred industry term.
Custom Tufted Carpet, n. A carpet or rug manufactured in a special size, shape.
color, design or width through a number of manufacturing processes.
Double Qlue-Oown, n. - An installation method whereby the carpet cushion is first adhered
to a substrate, or a floor, with an adhesive, and the carpet is then adhered to the cushion
by an adhesive.
Qlue-Oown, n. An installation method whereby the carpet is adhered to a substrate.
or a floor, with an adhesive.
Gully, n. The distance between tackless strip and the wall. It should always be slightly
less than the thickness of the carpet.
Knee-Kicker, n. An installation tool designed to position loose carpet and move it onto
tackless strip. The leading edge of the kicker should be on the surface of the carpet
and on the tackiest strip to hook and force carpet backing onto the pins of the strip.
To absorb the pressure shock on the knee, the kicker's "bun pad" is made of sponge
rubber. (NOTE: Knee-kickers should only be used for the attachment of carpet to the
tackless strip and not for stretching carpet. A power- stretcher should always be used
for stretching carpet during installation; see below.)
Open-Time, n. Elapsed time during which an applied adhesive will still bond to the carpet.
Power Stretcher, n. A carpet installation tool used to stretch carpet for installation on
tackless strip. It consists of a pinned plate which grips the carpet, tubular extensions.
a padded end which is used to brace against an opposing wall or other structure, and
a lever system that multiplies the installer's applied stretching force.
Quarter-Round, n. Wooden or plastic molding with a cross section comprising a 90°
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arc of a circle. It is used as joints between walls and floors, or between larger moldings
and floors.
Restretch, v. - Term used to describe stretching carpet after original tackless .nstaiia-
tion to remove wrinkles or bubbles or to correct loose fit.
Riser, n. The upright part of a step between two stair treads.
Seam, n. In carpet installation, the line formed by the joining of the edges of two pieces
of carpet by use of various seaming tapes, hand sewing or other techniques.
Seam Adhesive, n. - A specifically formulated adhesive compound for securing cut edges
of carpet to be seamed. Its use will help prevent raveling and delammation at seam
edges.
Seaming Tapes, n. Fabric tapes used for joining two sections of carpet. Hot melt
tapes are precoated with a thermoplastic adhesive. For other tapes, the adhesives
are applied separately.
Secondary Backing, n. In tufted carpet, a second backing fabric is laminated to the
primary backing for body, dimensional stability and ease of handling. Most primary
backing fabrics today are made of synthetic fibers; secondary backings are made of
synthetic or jute fibers.
Selvage (Selvedge), n. The factory-finished edge of a carpet.
Set-Up Time, n. The elapsed time during which an applied adhesive will be fully "cured"
or dried.
Stretch-In, n. A term describing the procedure for installing carpet using tackless strip.
Tackles* Strip, n. - Wood or metal strips fastened to the floor near the walls of a room
containing either two or three rows of pins angled toward the walls on which the carpet
backing is secured in a "stretch-in" installation.
Textile Floorcovering Material, n. General description used for carpet, rugs. etc.
Threshold, n. - The raised board beneath a door, also known as a "door sill" or "saddle."
100% Transfer, v. - The full coverage/transfer of the carpet floor adhesive into the carpet
backing, including the recesses of the rough carpet back.
Tread, n. - The horizontal pan of a stair.
Tufted Carpet, n. - Carpet manufactured by the tufting process, a method by which the
pile yams are inserted into a primary backing fabric by a row of eyed needles. Tufting
accounts for a large percentage of the carpet produced in the U. S. today, especial-
ly those for residential use.
Unitary Carpal, n. - Type of carpet used for glue-down installations which has an
application of high quality latex to increase tuft bind performance properties without
the addition of a secondary scrim backing.
Velvet Carpet, n. - Carpet woven on a loom similar to a Wilton, but lacking the Jacquard
mechanism. Velvet carpet is typically cut pile or level loop in solid or tweed color-
ings, though textured and patterned effects are possible. ^^
Q-26
-------
Vinyl Pltsticizer, n. - A substance incorporated into vinyl to increase is
workability or extensibility (capable of being extended).
Wilton Carpet, n. - Carpet woven on a loom with a Jacquard mechanism which utilizes
a senes of punched cards to select pile height and yarn color The Wilton loom can
produce carpet with complex multicolor patterns and highly-textured pile surfaces
of multilevel cut and looped yarns.
Woven Carpet, n. Carpet produced on a loom through a weaving process Dy wrier-,
the lengthwise (warp) yarns and widthwise (weft or filling) yarns are interlaced to form
the fabric. Carpet weaves - such as Wilton. Axminster and velvet - are complex, often
involving several sets of warp and filling yarns for the pile and backing.
Q-27
-------
TABLE
TOOLS
A Tape Measure
1. 25-ft. Retractable
B Straight Edges
1. 1-Rigid
2. 1-Flexible
C Chalk Line and White
Chalk (Only)
0. Knives and Cutters
1. Utility Knife
2. Carpet Knife
3. Stoned Razor Blade
4. Loop Pile Cutter
5. Wall Trimmer Conventional
6. Wall Trimmer - Cushion Back
7. Carpet Shears
8. Nap Shears
9. Electric Rotary Knife
10. Hacksaw
11. Tin Snips
12. Tackless Strip Cutter
E. Hammers and Mallets
1. Carpenters
2. Tack
3. Rubber Mallet
4. Electric Stapler
5. Hammer Tacker
P. Screwdrivers
1. Phillips
2. Standard
G. Trowete
H. Rltt
1. Triangular
2. Rat
I Roller
1. 35 Ib. (16 kilograms)
2. 50 Ib. (23 kilograms)
J. Power Stretcher
K. Knee Kicker
L. Miscellaneous
1. Base Shoe Lifter
2. Drive Down Bar
3. Stair Tool
4. Awl
5. Nail Set
6. Sharpening Stone
7. Carpet Spreader
B. Pliers
9. 3-m. Hot Melt Seaming
Iron and Shield
10. 6-m. Hot Melt Seaming
Iron and Shield
11. Extension Cord and
Adapter
12. Plastic Squeeze Bottle
13. Hammer Drill
14. Metal Miter Box
15. Hygrometer
16. pH Paper
17. Carpet Tractor
18. Wood Weight to follow
Seaming Iron
19. Door Pin Remover
20. Bandaids
21. Stay Nails
22. Carpenters Square
23. Pencil and Note Pad
24. Chalk Stick
25. Marking Pen
26. Thimble, curved
27. Needle and Thread
28. Putty or Coloring
Sticks for touchup
of wood
29. Vacuum Cleaner
Q-28
-------
TABLE
MATERIALS
A Metal and Vinyl Moldings
1. Binder Bars
2. Cap Molding
3. Stair Nosing
4. Accent Molding
5. Metal Clamp-Down Binder Bar
6. Access Panel Molding
7. Combo Metal
B. Seaming Tape
1. Latex
2. Hot Melt
C. Tackle** Strip
1. Standard no anchoring nails
2. Pre-nailed wood
3. Pre-nailed concrete
4. Commercial or Architectural
5. Acoustical
Q-29
-------
TABLE III
ADHESIVES
1 Latex
2. Vinyl Back Carpet Adhesive
3. Carpet Seam Adhesive
4. Carpet Seaming Latex
5. Contact Cement
6. Urethane Carpet Cushion Adhesive
7. Seam Sealer
Q-30
-------
TABLE IV
TROWEL SIZE GENERAL GUIDELINES
Carpet Backing
Jute
Rubber (foam & sponge)
Urethane Cushion
Jute/Vinyl
Vinyl-foam
Vinyl-slab
Vinyl-coated
Synthetic
Unitary
Woven
Hot Melt
Between floor & cushion
smooth floor
- porous floor
Between cushion & csrpet
smooth back carpet
- rough back carpet
Direct Glue Down
Adhesive
Type
Latex ~~N
Latex /
Latex I
Vinyl S
Vinyl 1
Vinyl I
Vinyl J
Latex
Latex
Latex
Latex
Double Glue Down
Latex
Latex
Latex
Latex
Trowel Size
width x spacing x depth
in inches'
3/32 x 3/32 x 3/32
1/8 x 1/8 x 3/32
1/8 x 1/16 x 1/8
1/8 x 1/8 x 3/32
1/8 x 1/16 x 1/8
1/8 x 1/8 x 3/16
1/8 x 1/16 x 1/8
1/8 x 1/8 x 3/16
3/32 x 3/32 x 3/32
1/8 x 1/8 x 3/16
1/1 6 x 1/32 x 1/32
1/16 x 1/16 x 1/16
1/8 x 1/8 x 3/32
1/8 x 1/16 x 1/8
1/8 x 1/8 x 3/16
Notch
Shape
V Or
U
V Cr
U
V cr
U
V cr
U
V or
U
U
U
U or
U
U
Notes: The above guidelines should only be used when specific recommendations are not available from the
manufacturer and/or the adhesive supplier. Rough, porous concrete surfaces and heavily textured carpe
may require a trowel with deeper notches than listed above.
'To convert trowel dimensions to metric:
1/32" * 0.8mm
1/16" » 1.6mm
3/32"
1/8 "
* 2.4mm
m 3.2mm
3/16" » 4.8mm
Q-31
-------
TABLE V
TACKLESS STRIP
Type
Standard
Pre-nailed (wood)
Pre-nailed (concrete)
Acoustical
Architectural
Application
Use on wood, concrete and
other hard surface floors
Use on wood subfloors
Use on concrete
Use on light-weight aggregate
concrete flooring that has
been designed for absorbing sound
Use when dimensions exceed
30 feet (9m)
Q-32
-------
TABLE VI
SEAMING
Hot Melt Tape
Tape and Latex
Electric Tape
Hand Sewing
Pin Tape2
CARPET
TUFTED WOVEN
Recommended
Recommended
Recommended
Recommended'
Recommended Recommended
'Wilton's MUST be hand sewn.
2Check for manufacturer's recommendations.
Q-33
-------
TABLE VII
STRETCH
(Use if manufacturer's recommendations are not available)
Tufted'
Jute Secondary
Synthetic Secondary
Woven
Velvet2
Wilton2
Axminster3
Knitted4
Length
'drum tight"
snug
equal stretch in
length and width
(drum tight)
tight
Width
"drum tight"
1Vzo/0
more stretch
in width
than length
equal stretch in
length and width
(drum tight)
snug
more stretch in
width than length
approx.
' See Figure 3
2Se« Figure 4
3Se« Figure 5
4Se« Figure 6
Q-34
-------
TABLE VIII
RESIDENTIAL
CARPET CUSHION SELECTION
Contact the carpet manufacturer to obtain his
cushion requirements in order to prevent
problems resultant from improper cushion
selection and the possible voiding of applicable
warranties. Choice of cushion which is map*
propnate for the end use application of the carpet
may result in accelerated loss of appearance
retention, wrinkling, buckling, and the separation
of the carpet backing or seams.
Cushion thickness should not exceed 7/i6-
-------
Q-36
-------
FIGURE 2
el
N
UJ
i/i
-szi
It
7^*5'
LJ
o
2
il
a
551
$3
O
O
i ir.
uj £ 35 £r
a SJJ c 6
»gi'
|i|
i «
Q-37
-------
FIGURE 3
TUFTED
Amount of Stretch t» per the Carpet Manufacturer's Recommendation
In Absence of Carpet Manufacturer s Recommendation, Use Diagram Below
power stretch
from wall A C
& hook along the
wall from B to 0
power stretch from wall A B & nook along
the wail from C to 0
power stretch
from wall A B
& hook at corner C
power stretch from
wall A B & hook temporarily
at corner 0 until Step 7
has been completed
power stretch from
wall A C and
hook at comer B
I /7TT
stretch &
nook with
knee
along the
wall from
A to C
stretch & hook with knee kicker along the wall \
from A to B
hook along
comer A
STRETCH:
Jut* Secondary Backing:
Synthetic Secondary Backing:
Q-38
Length Width
"drum tight" "drum tight"
-------
FIGURE 4
WILTON OR VELVET
Amount of Stretch as per the Carpet Manufacturer's Recommendation
In Absence of Carpet Manufacturer's Recommendation, Use Diagram Below
power stretch from wall A B 4 hook along
the wall from C to 0 /
v C
f STEM
power stretch
from wall A C
& hook along the
wall from B to 0
power stretch
from wall A B
& hook at corner C
power stretch from
wall A B & hook temporarily
at corner 0 until Step 7
has been completed
power stretch from
wall A C and
hook at corner B
H.;
mi^mm^
stretch £ hook with knee kicker along the wall \
from A to B
STEP
3
stretcn 4
HOOK with
Knee
along :he
wail
-------
FIGURE 5
AXMINSTER
Amount of Stretch ae per the Carpet Manufacturer's Recommendation
In Absence of Carpet Manufacturer's Recommendation, Use Diagram Below
Dower stretch from wall A B & hooK along
'he vvaii from C to D
power stretch
from wall A C
& hook along the
wall from B to D
power stretch
from wall A B
& hook at corner C
power stretch from
wall A B & hook temporarily
at corner D until Step 7
has been completed
power stretch from
wall A C and
hook at comer B
stretch & hook with knee kicker along the wall \
from A to B
stretch &
hooK with
knee ktcxer
along the
wall from
A to C
hook along
comer A
STRETCH: Length Width
tight snug
Q-40
-------
FIGURE 6
KNITTED
Amount of Stretch u per the Carpet Manufacturer's Recommendation
In Absence of Carpet Manufacturer's Recommendation, Use Diagram Below
power stretch from wall A B & hook along
the wall from C to D
power stretch
from wall A C
& hook along the
wall from B to 0
power stretch
from wall A B
& hook at corner C
power stretch from
wall A B & hook temporarily
at corner 0 until Step 7
has been completed
stretch
hook with
knee
along the
wall from
A to C
power stretch from
wall A C and
hook at corner B
stretch & hook with knee kicker along the wall \
from A to B
STRETCH:
Length
hook along
corner A
Width
more stretch in width than length
approx. T/i%
In an exceptionally large room a reverse stretch from walls C 0 to A B. and from
walls B 0 to A C is recommended to assure a tight, satisfactory installation
Q-41
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SPECIAL ACKNOWLEDGEMENTS
Since :be oegmnmg of this oroject. more than 100 individuals generously donated their time.
effort, talent, and experience. These individuals represented all affected segments of the carpet
industry -nanufacturers of carpet, carpet cushion, and adhesives; retailers and installers
in the process of developing this document, almost all disagreements were resolved because
of the dedication and expressed commitment by the participants to provide guidelines m the
best interest of the ultimate carpet user. The following organizations generously expressed
their endorsement of this work:
"AFA supports the concept of CRI-105 for Residential Installation. AFA is pleased to have
been involved in the review and development process. The AFA Board of Directors will be
reviewing CRI-105 in detail."
moux cmsT INSTITUTE
CmOlER 3U
"The Canadian Carpet Institute and The National Floorcovering Association in Canada have
promoted programs to provide improved installer training and practice. The publication of
CRI-105 will provide a much needed standard guideline from which to work and we will
recommend that all carpet manufacturers, distributors and retailers who are members of our
organizations adopt its use."
MASV
T H 1 * i
' 'We have reviewed the 4th Draft received and again we want to compliment you and the Com-
mittee on the quality and the comprehensiveness of the Standard."
"We plan to reference CRI-105 in the revision of the CMAW Performance Guidelines . "
*
Q-42
-------
B
FLOOR COVERING
INSTALLATION CONTRACTORS ASSOCIATION
We support this effort to provide standards for the residential installation community arc
want :o be on record in our endorsement of this new standard."
we are hopeful that the present document will provide an appropriate guideline
NAFCD
Distributors
OOdVN
"The National Association of Floor Covering Distributors is pleased that a reference standard
for residential installation is now available and, through distributors, will encourage its use
with dealers and installers."
WESTERN FLOOR COVERING ASSOCIATION
*« -
"... WFCA accepts the standards as proposed... this... shows that the industry as a whole
is trying to improve our practices ..."
". . . there is no way the retailers, installers and manufacturers could agree on every phase
of a proposed standard ... but... it's a good starting point."
"... WFCA will encourage industry adherence to the standard ..."
QH3
-------
APPENDIX R
Indoor Air Quality Evalualtion of
Carpet for the Carpet and Rug Institute
-------
VOLATILE ORGANIC COMPOUND EMISSIONS FROM CARPET
AND ASSOCIATED PRODUCTS
Marilyn S. Black, William J. Pearson, Lydia M. Work
Air Quality Sciences, Inc.
1331 Capital Circle
Atlanta, Georgia 30067
INTRODUCTION
As public awareness of indoor air quality (IAQ) and its impact on
productivity, comfort and health continues to grow, pressure increases to
provide "quality indoor environments" for occupants of office buildings,
personal residences, and other indoor structures. The burden of providing
this environment impacts all those involved in the design, construction, and
operation of these structures as well as the actual occupants themselves.
Ventilation, construction materials, cleaning materials and procedures,
internal processes and activities are some of the many factors which may
affect IAQ.
Because indoor materials and internal processes are potential sources of
indoor air pollutants such as formaldehyde and other volatile organic
compounds (VOCs), ozone, particles, microbiologicals, carbon dioxide and other
inorganic oxides, mitigative control and proper selection of materials has
received recent attention. One practical approach to controlling indoor
pollutant exposures is to ensure that low emitting materials are used while
simultaneously providing adequate ventilation to the indoor spaces. Proper
ventilation has been recognized as an important issue in adequate IAQ and has
been addressed in a recent consensus standard (ASHRAE, 1989).
Although there are no current standards for acceptable indoor levels of
pollutants, there are guidelines for certain pollutants as established by some
various agencies and professional organizations (WHO, 1987; ASHRAE, 1989;
Canada, 1987). Since materials and certain processes are believed to be
significant contributors to the presence of pollutants in buildings,
technology has been developed to measure pollutant emission rates from known
sources and to predict resultant air concentrations within buildings.
Flooring materials, floor coatings, wall materials, wall coatings, office
furniture, and office machines have been recently listed as potential
contributors to VOCs within the indoor air, and suggested maximum emission
rates (sometimes referred to as "emission factors") have been proposed for
each (Tucker, 1990). The State of Washington has also proposed similar
guidelines with maximum acceptable levels of VOCs and other pollutants in the
buildings originating from interior finishes, furnishings, and processes
(State of Washington, East Campus Plus, 1990).
R-1
-------
ACS Report #: VOC Paper 02
AQS Project #: 01021
Date Prepared: January 8, 1991
Carpet materials have received recent attention as potential contributors of
VOCs. This interest was primarily generated by a "Citizens Petition" which
requested the Environmental Protection Agency (EPA) to regulate the emission
of 4-phenylcyclohexene (4-PC) under the Toxic Substances Control Act (TSCA).
This particular compound is an odiferous species known to be a manufacturing
by-product of carpet incorporating styrene/butadiene rubber.
The EPA rejected the petitioners' request to regulate 4-PC, on the basis that
toxicological data did not support the claim of adverse health effects
resulting from 4-PC exposure. However, the EPA has requested that the carpet
industry take voluntary action to reduce total VOC emissions from their
products, as a pollution prevention mitigative initiative (Federal Register,
1990).
To obtain an understanding of the magnitude of VOC emissions from carpet and
its associated products, a comprehensive study of VOC emissions was begun in
November, 1989 of SBR latex-backed carpets. An environmental chamber
technology and testing protocol was developed for accurately and reproducibly
assessing VOC emission rates. Using this technology, a study was conducted
of representative carpet products, carpet cushions, adhesives, and installed
systems. Emission rate changes over time were studied for each of the
products for both total volatile organic compound (TVOC) and 4-
phenylcyclohexene (4-PC) emissions. Comparative studies were also conducted
of other interior .products including particleboard, paint, adhesive, and wall
covering.
EXPERIMENTAL METHODOLOGY
A complete description of the methodology used in this study is attached as
Appendix 1. It describes the technique for determining TVOC emission rates
from flooring systems using test conditions defined to simulate product use in
realistic settings. Incorporated in this method are applicable terminology,
environmental chamber specifications, sample handling protocols, sample
collection techniques, sample packaging procedures, product delivery and
storage, preparation techniques for the test system, testing protocols,
chemical analysis descriptions, emission rate calculations, and quality
control and assurance procedures.
A summary of these techniques specific to this study follows.
R-2
-------
AQS Report #: VOC Paper 02
AQS Project #: 01021
Date Prepared: January 8, 1991
Environmental Chamber Technology.
An environmental chamber technology, in conjunction with a defined testing
protocol, has been designed to accurately assess the VOCs from new SBR latex
carpet. This methodology measures TVOC emission rates from flooring systems
using test conditions defined to simulate product usage in a realistic manner,
both residential and commercial.
The technology employs small stainless steel chambers with a precisely
maintained air supply. The controlled parameters include chemical purity of
the air supply, moisture content, temperature, amount of air flow measured in
air changes per hour, and velocity of the air movement through the chamber.
These parameters are precisely regulated with a computerized process control
system which provides immediate feedback, control and continuous data logging
of the parameters. All of the products were evaluated utilizing consistent,
standardized test conditions.
A schematic of the technology system is shown in Figure 1 and a photograph of
the five small chambers used in this study is presented in Figure 2. The
actual measurement specifications including the chamber system are given in
Table 1. The product loading factor of 0.41 m/m was chosen to simulate a
full coverage of carpet in a room with an 2.4 m ceiling height.
Quality control procedures on the chamber operation included continuous
monitoring of the operating parameters including air supply temperature,
humidity, and TVOC background; evaluation of mixing efficiency and calibration
of the air exchange rate; evaluation of VOC recovery within the chamber using
quantitative standards; and monitoring of chamber pressure relative to the
atmosphere.
Analytical Measurements.
Analytical measurement specifications are given in Table 2. The low levels of
VOCs associated with the carpet materials require a significant pre-
concentration of the air prior to chemical analysis. A multibed sorbent of
Carbosieve SHI/Carbotrap C/Carbotrap was used for TVOC collection and a water
solution was used for the formaldehyde collection. The actual sorbent traps
were prepared and purified in the laboratory.
R-3
-------
AQS Report #: VOC Paper 02
AQS Project #: 01021
Date Prepared: January 8, 1991
The TVOC analysis, including 4-PC, was conducted by capillary gas
chromatography coupled with mass spectrometric detection. The environmental
chamber air samples were thermally desorbed into the analytical
instrumentation for analysis via a well-controlled and reproducible thermal
desorption system.
Formaldehyde analysis was conducted with a double beam UV-visible
spectrophotometer following color development of the formaldehyde derivative.
Calibration was determined from standards using a least squares calibration
curve fit, and the minimal quantifiable limit was determined to be twice the
detection limit as measured from replicate determinations of the lowest level
standard.
PRODUCT DESCRIPTIONS
Carpet. Nineteen individual SBR latex-backed carpet products were evaluated
for TVOC and 4-PC emissions. The generic description of each is given in
Table 3 indicating the face fiber type identification, dye method, and whether
or not topical soil/stain resist treatments were applied. Each product was
obtained from the manufacturer's finishing line. Laboratory instructions were
that samples taken off the manufacturing line were to be immediately packaged
and delivered to the laboratory as soon as possible.
Each carpet sample was obtained from the manufacturing finish line in a 12
foot by 2 foot piece so that it incorporated the complete width of the
finished product. The material was rolled and packaged first in a 6 mil
polyethylene bag followed by an air tight wrap of 3 mil aluminum foil. Once
the materials were delivered to the laboratory, they were stored in a
conditioned room maintained at 68°C - 78°C and 40%-60% relative humidity. The
material remained in its packaging until immediately before chamber
evaluations.
The packaging was chosen prior to the start of the program to ensure that it
would not contaminate the product with additional VOCs and that it would not
allow permeation of the carpet VOCs to the outside air. The materials chosen
have TVOC emission rates less than 0.005 mg/m-hr.
R-4
-------
AQS Report #: VOC Paper 02
AQS Project #: 01021
Date Prepared: January 8. 1991
Associated Carpet Products. An initial VOC emissions survey of carpet cushions
and adhesives was also conducted. Three different types of cushions and four
adhesives, as generically identified in Table 4, were evaluated. The carpet
cushions were obtained and packaged as the carpet. The first three adhesives
were obtained in unopened 5 gallon containers from local suppliers. The
special "low VOC" adhesive was supplied as a small sample directly from the
specific manufacturer.
PREPARATION OF THE PRODUCT TEST SYSTEM
The products were evaluated in the chambers as realistically as possible. Each
was prepared as it would be during an actual building installation; the
loading was simulated within the chambers to be commensurate with a complete
floor coverage in a room with a 2.4 m ceiling height; and environmental
conditions were maintained at 50% relative humidity and 25°C. A complete
discussion of these standardized parameters is given in Appendix 1.
The universal subflooring was concrete although some studies were conducted
with particleboard underlayment as might be found in residential structures.
The sample mounting allowed only the surface of the prepared test specimen to
be exposed to the air flow within the chamber, and the edges were sealed with
a stainless steel band.
Each type of product, carpet, cushion and adhesive was studied individually as
well as in a complete system. Installation systems which were evaluated
included:
carpet on subflooring, no adhesive or cushion;
carpet on subflooring with adhesive (direct glue down);
carpet on subflooring with cushion, no adhesive; and
carpet on subflooring with cushion and adhesive (double glue down).
The installations were prepared according to the manufacturers' instructions
and the use of The Carpet and Rug Institute's (CRI) Installation Guide for
Commercial and Residential Structures, CRI Publications 104 and 105. The
manufacturers' instructions had priority, if available.
R-5
-------
AQS Report #; VOC Paper 02
AQS Project #: 01021
Date Prepared: January 8, 1991
DATA PRESENTATION
SBR LATEX CARPET PRODUCTS.
Formaldehyde Emissions.
There were no detectable formaldehyde emissions measured from any of the
nineteen SBR carpet products during this study. This indicated that the new
SBR latex carpets evaluated were not pollutant sources of formaldehyde.
TVOC and 4-PC Emission Rates.
Chemical emissions of each individual carpet product, evaluated for one-week
exposure periods, produced similar TVOC decay patterns with time. Typical
emission profile patterns for two independent carpet products are shown in
Figure 3. The level of TVOCs was highest at the first measurement point, one
hour after exposure in the environmental chamber, and exponentially decreased
with time. Initial studies were conducted by taking data points at
1,4,8,12,24,48,72,96,120, and 144 exposure hours. After these initial
studies, daily test measurements were made at 24-hour increments. A
representative chromatogram of the TVOCs is shown in Figure 4 for a carpet
sample. The chromatogram is relatively simple with only a few detectable peak
responses.
The emission profiles of 4-PC were obtained simultaneously and were found to
be similar to those of TVOC as shown in Figure 5. One primary observable
difference was noted; while the TVOCs decreased with time after initial
exposure to the atmosphere, the 4-PC emissions appeared to peak out sometime
within the first 24 hours before they began to decrease. Once 4-PC began to
decrease, however, it was continual. The peak response of 4-PC varied among
products between the 1st and 24th hour of exposure.
The percentage changes in TVOC and 4-PC levels are shown in Table 5 for
exposure time between immediate exposure and the 24th hour and the 144th hour.
Within 24 hours, the TVOC levels decreased rapidly by an average of 58%, and
by the end of one week, the TVOC levels had decreased by an average of 91%.
The 4-PC level showed a wide variation within the first 24-hour exposure
period. On an average, it increased 7.9% within the first 24 hours, but had
decreased by 63% at the end of a one-week exposure.
The 24th hour and 144th hour emission factors and "k" constants for the TVOC
and 4-PC decreases with time are summarized in Table 6 for each product. A
generic emission rate profile over time was generated using the mean of the
measured emission rates at each measurement point of all the SBR products.
R-6
-------
AQS Report #: VOC Paper 02
AQS Project #: 01021
Date Prepared: January 8, 1991
This graph, as presented in Figure 6, shows a pattern consistent with each of
the individual emission rate graphs and illustrates that the emission rates
are low and significantly below the 0.6 mg/m «hr guideline recently proposed
by EPA (Tucker, 1990). The same generic graph is presented in Figure 7
incorporating the 99% and 95% confidence levels around the mean of each
emission rate.
General trends observable in this data include:
1. The TVOC emission profiles among the SBR latex products are very similar
and predictable from a generic model generated from the mean
measurements.
2. TVOC and 4-PC emissions decrease with time.
3. TVOC emissions decrease more rapidly (half life of 1.8 days) than those
of 4-PC (half-life of 2.9 days).
4. 91% of the TVOC emissions decrease by the end of one week.
5. 63% of the 4-PC emissions decrease by the end of one week.
6. The variation in TVOC emissions among the SBR products decrease with
time. For example, there is 81% relative variation among the products
at the 24-hour exposure and 52% variation on the 7th day. This
variation, however, when considered in TVOC concentration, only
corresponds to ±50 u,g/m and ±2 u,g/m , respectively. This variation
level at the end of a one-week exposure is at the instrumental detection
limit.
4. The variation in 4-PC emissions among products increases in time with a
53% relative variation at 24 hours to 68% on the 7th day. This
corresponds, however, to only ±14 u,g/m (±2 ppb) and ±7 \ig/m (±1 ppb),
respectively.
5. The TVOC emissions from the 24th exposure hour are all below the 0.6
mg/m -hr guideline as presented by EPA (Tucker, 1990).
6. The mean TVOC profile indicates with 95% certainty that all similar SBR
latex products have emission rates less than 0.6 mg/m -hr within the
first hour of exposure, and with 99% certainty that all similar SBR
products have emission rates less than 0.6 mg/m -hr within 24 hours of
exposure.
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Date Prepared: January 8, 1991
Manufacturing/Product Variables.
This study was designed to present an overview of carpet emissions and was not
intended to be of statistical design. However, there were certain
observations relating TVOC emissions and known manufacturing parameters which
are noteworthy. These observations, as presented below, are generally based
on single measurements and should be considered strictly qualitatively.
Fiber Types.
The majority of products evaluated in this study consisted of face fiber
identified as type 1. When the emission data of this group of products were
considered as an aggregate, and the individual data of other fiber products
are compared to it, the following are observed:
1. The emission profiles of all follow similar TVOC decay patterns;
2. The TVOC levels of the two face fiber type 2 and one face fiber
type 4 products fall within 1 standard deviation of the face fiber
type 1 group variation, indicating similar magnitude; and
3. The TVOC level of the one face fiber type 3 material falls within
4 standard deviations of the type 1 variation (using the 24-hour
data as the comparative exposure point), indicating a potential
difference.
Hill Variability.
A generic type 1 fiber product was produced at four different manufacturing
locations, with each mill producing an independent sample. The TVOC data, C-9
through C-12, showed little variation (with the exception of C-10 at the 24-
hour point, which appears to be an outlier) among the TVOC emission data at
24- and 144-hour exposures. At the end of one week, the measured TVOC
variation was within the analytical measurement variability, basically
indicating no difference in magnitude.
Finishing Speed.
Two type 1 fiber products were manufactured identically with the exception of
residence time in the same drying oven. The product which remained in the
oven for a longer period of time indicated lower TVOC emissions than its
traditional counterpart.
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AQS Report #: VOC Paper 02
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Date Prepared: January 8, 1991
LARGE CHAMBER/SMALL CHAMBER CORRELATION.
TVOC emission evaluations in this study were primarily conducted in small
(0.05 m ) environmental chambers. An experiment was undertaken to confirm
that this small chamber data can be correlated to that obtained in an actual
room situation.
TVOC emission profiles for product C-3 were studied simultaneously in both a
large (26 m ) chamber and a small (0.05 ml chamber under identical operating
conditions with a loading factor of 0.41 m/m . The emission profiles were
monitored over a 6-week period, and the resultant correlations were quite
good. Linear regression analysis indicated an r of 0.92 for the TVOC
measurements, and an r of 0.97 for the 4-PC emissions. This excellent
correlation indicated good sample homogeneity with respect to the chemical
characteristics of this particular product.
The homogeneity of another SBR product was evaluated in a different manner.
Five independent samples were cut from one continuous manufacturing run of
product C-ll, and each sample was studied independently, but simultaneously in
five different small environmental chambers. The resultant TVOC data showed a
7.2% relative variation among the TVOC results and 7.0% relative variation
among the 4-PC measurements. Such variation is within the relative standard
deviation of the analytical measurement technique. This data was further
confirmation of good sample homogeneity within a specific SBR carpet product.
CARPET CUSHIONS, ADHESIVES AND SUBFLOORS.
Some representative carpet cushions and adhesives, as previously described in
Table 4 were evaluated for TVOC emissions. Carpet cushions were analytically
studied in the same manner and loading ratio as carpet, 0.41 m /m . The
adhesives were applied to a properly cured concrete subflooring using an
appropriate trowel at the spread rate recommended by the manufacturer or the
CRI Installation Guide. The adhesive loading based on surface exposure was
also 0.41 m /m.
A summary of the TVOC emission rates obtained from the cushions, adhesives,
and subflooring materials are shown in Table 7 for both the 24-hour and 144-
hour exposure points. Two cushions displayed TVOC profiles similar to carpet
and decreased with continual exposure time. The third cushion, in contrast,
had increasing TVOC values due primarily to the release of heavier molecular
weight compounds later in the exposure period.
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Date Prepared: January 8, 1991
The first three adhesives displayed similar TVOC patterns with time. However,
their emissions were significantly higher than those of the cushions and
carpets. A typical TVOC decay curve is presented in Figure 8 for one of the
latex adhesives; it required a 35-day exposure time to bring the level of
TVOCs down to the level which SBR latex carpet displays within the first 24
hours of exposure. A chromatographic scan of this particular adhesive is
shown in Figure 9. This organic compound pattern is significantly dense in
comparison to the carpet chromatogram previously shown in Figure 4.
Particleboard, a common subflooring material in residential and commercial
structures was evaluated as a TVOC source. As can be seen in Figure 10, it
has an elevated level of TVOC which appears to be generally constant over the
one-week exposure period. Primary TVOC contributions include formaldehyde and
other aldehydes and terpenes. The particleboard emission rate is
significantly greater than either the cushions or the carpet.
INSTALLATION SYSTEMS.
Various carpet systems were prepared for environmental chamber emission
studies. These systems included a variety of possibilities coupling
subflooring with cushions, adhesives, and carpet. The first set of systems,
which did not use adhesive, are summarized in Table,8 along with the 24-hour
emission rates and approximate resultant air concentrations. The
particleboard underlayment contributed significant TVOCs to the system.
The second set of data, as presented in Table 9, indicates the magnitude of
adhesive TVOCs. The general latex adhesives appear to contribute significant
TVOC loads to the carpet systems resulting in TVOC concentration approximately
1000 fold higher than a non-adhesive system. The carpet VOCs are analytically
masked by the adhesive VOCs. The decay time required to bring the adhesive
TVOC level down to below 0.6 mg/m -hr guideline (Tucker, 1990) ranges from 3
to 6 weeks dependent on the adhesive and type of application (single glue or
double glue). By the time the adhesive TVOCs have significantly decreased,
the carpet specific TVOCs have dissipated.
The "low VOC" adhesive, Ad-4 did have considerably lower TVOCs than the other
three adhesives. Decay profiles of this adhesive by itself and in a carpet
system are shown in Figure 11. Detectable VOCs present are from the adhesive
as well as the carpet.
TVOC emission rate comparisons between carpet systems and their individual
components are presented in Figure 12. The carpet (C) and pad or cushion (P)
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Date Prepared: January 8, 1991
are minor contributors in comparison to the adhesive (Ad). The TVOCs are
highest for the two systems, C/Ad (a single glue down with carpet and
adhesive) and C/Ad/P/Ad (a double glue down with carpet, cushion and two
applications of adhesive).
SUMMARY
The TVOC emission profiles of the SBR latex products were very similar and
predictable by a generic model generated from the mean measurements obtained.
The available data indicate with 95% certainty that all similar SBR latex
products would have emission rates less than 0.6 mg/m -hr (or simply will
result in <500 u-g/m of TVOC air concentrations) within their first hour of
exposure.
The TVOC emissions emanate rapidly from the SBR latex products, reducing an
average 58% within the first 24 hours and 91% by the end of one week. The
4-PC levels similarly decrease, but at a slightly slower rate. The TVOC
contributions from new SBR carpet are barely detectable at the end of one
exposure week.
Comparative data among other carpet system components including cushions, wood
subflooring, and adhesives indicate SBR carpet to be one of the lower TVOC
emitters. TVOCs from carpet installations appear to be primarily dominated by
the adhesive component, which can contribute 10 levels higher of TVOCs. In
addition, comparative data (Figure 13) among other interior products such as
pressed wood, wall covering, adhesive, and paint show carpet itself to be a
minor TVOC source.
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AQS Report #: VOC Paper 02
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Date Prepared: January 8, 1991
TABLE 1
ENVIRONMENTAL CHAMBER SPECIFICATIONS
Stainless steel with rounded, electropolished interior surfaces.
Internal volume of 0.05 m3.
Internal construction free of mixing fan, obstructions or contamination.
Internal velocity reproducible at 0.05 - 0.2 m/sec.
Internal mixing within 5% of theoretical well-mixed model.
Recovery rates >90% for representation compounds at 25 jig/m3.
Positive pressure chamber operation relative to atmosphere (1" H20).
Standard environmental controls include:
1.0 ACH ± 0.05 ACH
25.0°C ± 0.2°C
50.0% RH ± 2.0% RH
TVOC background < 2 u.g/m
Product loading ratio at 0.41 m2/m3 (square area of exposed carpet surface to
volume of chamber).
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Date Prepared: January 8, 1991
TABLE 2
ANALYTICAL MEASUREMENT SPECIFICATIONS
TVOC collection and analysis by so1id sorbent trapping/thermal
desorption/GC/MS analysis.
CHOH collection and analysis by modified pararosaniline spectrophotometric
technique (Miksch, 1984; Black, 1987.).
TVOC quantifiable limit: 2 jig/m3 (0.5 ppb)
CHOH quantifiable limit: 6 jig/m3 (5 ppb)
4-PC quantifiable limit: 2 ng/m3 (0.3 ppb)
TVOC quantisation by a representative gaseous TVOC mixture including decane,
toluene, and cyclohexane (methanol was incorporated for adhesive analysis).
TVOC quality control duplicates of carpet indicated an analysis variation of
7-11% relative standard deviation.
VOC identification made by customized mass spectral library and retention
time.
CHOH and 4-PC quantisation by specific gaseous standards.
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TABLE 3
PRODUCT DESCRIPTIONS OF CARPET MATERIALS
MANUFACTURED WITH STYRENE BUTADIENE
RUBBER (SBR) ADHESIVE
GENERIC DESCRIPTION
PRODUCT
DESIGNATION
C- 1
C- 2
C- 3
C- 4
C- 5
C- 6
C- 7
C- 8
C- 9
C-10
C-ll
C-12
C-13
C-14
C-15
C-16
C-17
C-18
C-19
FACE
FIBER TYPE
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
3
4
2
1
DYE
METHOD
Continuous
Continuous
Continuous
Continuous
Continuous
Beck
Solution
Solution
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Beck
Solution
Stock
Beck
Solution
SOIL/STAIN RESIST*
TREATMENT
No
Yes
Yes
Yes
No
No
No
No
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
*The exact treatment of each was not known.
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AQS Report #: VOC Paper 02
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Date Prepared: January 8, 1991
TABLE 4
PRODUCT DESCRIPTIONS OF CARPET CUSHIONS
AND FLOORING ADHESIVES
PRODUCT DESIGNATION GENERIC DESCRIPTION
P-l Flat
P-2 Fibrous
P-3 Flat
Ad-1 Multipurpose Latex
Ad-2 Multipurpose Latex
Ad-3 Multipurpose Latex
Ad-4 Synthetic, "Low VOC"
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TABLE 5
PERCENTAGE TVOC AND 4-PC EMISSION CHANGES
WITH ELAPSED EXPOSURE TIME
% REDUCTION OR INCREASE
PRODUCT
C- 1
C- 2
C- 3
C- 4
C- 5
C- 6
C- 7
C- 8
C- 9
C-10
C-ll
C-12
C-13
C-14
C-15
C-16
C-17
C-18
C-19
Mean
±Standard
Deviation ±18.8
24 HRa
-29.6
-40.0
-35.3
-67.6
-32.9
-35.5
-51.1
-44.0
-82.6
-77.0
-70.2
-79.1
-77.2
-64.4
-68.9
-40.0
-71.1
-83.8
-59.3
-58.4
TVOC
144 HRb
-93.0
-97.1
-86.9
-95.7
-82.6
-80.3
-86.6
-95.3
-96.5
-81.5
-94.4
-97.0
-87.6
-88.2
-96.1
-93.6
-88.0
-96.1
-93.1
-91.0
24 HRa
+82.8
+9.6
+10.1
-52.9
-3.85
+17.6
-24.3
+12.9
-5.56
-10.7
+83.3
-50.9
-10.0
+16.9
+113
+13.2
-6.82
-25.0
-17.9
+7.97
4-PC
144 HR*
-85.7
-94.0
-78.3
-94.1
-51.2
-62.2
-77.1
-67.7
-52.8
-53.6
-39.4
-74.5
-62.0
-60.4
-63.3
-23.7
-44.3
-69.6
-45.5
-63.1
±5.6
±43.2
±18.5
* Taken after a 24-hour equilibration period within the environmental chamber.
b Taken after a one-week (144 hours) exposure period within the environmental chamber.
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TABLE 6
TVOC AND 4-PHENYLCYCLOHEXENE (4-PC)
EMISSION RATES OF NEW CARPET
PRODUCT
C- 1
C- 2
C- 3
C- 4
C- 5
C- 6
C- 7
C- 8
C- 9
C-10
C-ll
C-12
C-13
C-14
C-15
C-16
C-17
C-18
C-19
Mean
±Standard
Deviation
TVOC
24 HRa
0.071
0.109
0.183
0.045
0.098
0.097
0.131
0.102
0.166
0.041
0.182
0.179
0.060
0.054
0.127
0.500
0.195
0.092
0.438
144 HRb
<0.005
<0.005
0.037
0.006
0.040
0.030
0.036
0.064
0.033
0.033
0.034
0.026
0.036
0.018
0.016
0.053
0.081
0.022
0.074
fcfHR'1)0
0.027
0.021
0.013
0.020
0.009
0.012
0.013
0.010
0.020
0.010
0.018
0.022
0.013
0.014
0.023
0.018
0.014
0.018
0.016
0.151
0.123
0.034
0.018
0.016
0.005
4-PC
24 HRa
0.064
0.091
0.152
0.040
0.075
0.087
0.106
0.035
0.034
0.025
0.033
0.025
0.045
0.062
0.064
0.043
0.082
0.042
0.110
144 HRb
<0.005
<0.005
0.030
0.005
0.038
0.028
0.032
0.010
0.017
0.013
0.020
0.013
0.019
0.021
0.011
0.029
0.049
0.017
0.073
MR'1)'
0.017
0.018
0.011
0.018
0.0065
0.0075
0.0093
0.0081
0.0058
0.0056
0.0034
0.0080
0.0075
0.0075
0.010
0.0052
0.0040
0.0079
0.0040
0.064
0.034
0.025
0.017
0.010
0.008
" Emission rate taken after a 24-hour equilibration period within the environmental chamber.
6 Emission rate taken after a one-week (144 hours) exposure period within the environmental chamber.
c The rate constant of TVOC decay.
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TABLE 7
SUMMARY OF TVOC EMISSION RATES FOR
CUSHIONS, ADHESIVES, AND SUBFLOORING
Product Designation TVOC Emission Rate (mg/ni2»hr)
Cushions 24 Hra 144 Hrb
P-l 0.123 0.059
P-2 0.240 0.012
P-3 3.36 8.11
Adhesives
Ad-1 90.0 11.9
Ad-2 76.6 3.95
Ad-3 99.0 17.2
Ad-4 0.698 0.076
Subfloorinq
Concrete <0.005 <0.005
Particleboard 0.952 0.837
a Emission rate taken after a 24-hour equilibration period within the environmental chamber.
b Emission rate taken after a one-week (144 hours) exposure period within the environmental chamber.
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Date Prepared: January 8, 1991
TABLE 8
SUMMARY OF TVOC DATA FOR CARPET SYSTEMS
(NO ADHESIVE USED)
SAMPLE 24 HR EMISSION RATES 24 HR CONCENTRATION3
IDENTIFICATION mQ/nf.hr mq/m3 ppb
Carpet + P-l
on concrete 0.136 0.056 15
Carpet + P-l
on wood underlayment 0.549 0.225 61
Carpet + P-3
on concrete 0.776 0.318 86
* Concentration estimations based on a simple model assuming:
1 ACH with a well-mixed atmosphere
50 ± 0.5% RH
25 ± 0.2°C
No additional sources of VOCs present
No sinks or re-emitting sources of VOCs present
36 m3 room volume with a 2.4 m ceiling height
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Date Prepared: January 8, 1991
TABLE 9
SUMMARY OF TVOC DATA FOR CARPET SYSTEMS
(WITH ADHESIVE USED)
SAMPLE
IDENTIFICATION
Carpet + Ad-1
on concrete
(single stick)
Carpet + Ad-1 + P-l
on concrete
(double stick)
Carpet + Ad-2
on concrete
(single stick)
Carpet + Ad-3
on concrete
(single stick)
Carpet + Ad-4
on concrete
(single stick)
24 HR EMISSION RATES
mq/m «hr
98.0
145
88.3
153
0.783
24 HR CONCENTRATION3
mq/m ppb
40.2
59.6
36.2
62.8
0.321
10,854
16,092
9,774
16,956
87
a Concentration estimations based on a simple model assuming:
1 ACH with a well-mixed atmosphere
50 ± 0.5% RH
25 ± 0.2°C
No additional sources of VOCs present
No sinks or re-emitting sources of VOCs present
36 m3 room volume with a 2.4 m ceiling height
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FIGURE 1
SCHEMATIC OF TECHNOLOGY SYSTEM
Dynamic Environmental Chamber System
Air Purification
and Humidiflcatlon
1
B^B
f~
I
Environmental
Chamber
n
Collection
Media
Process Control and
Monitoring System
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FIGURE 2
PHOTOGRAPH OF SMALL ENVIRONMENTAL CHAMBER
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FIGURE 3
TYPICAL TVOC EMISSION PROFILE WITH TIME
(SBR LATEX CARPET)
Oo
.2
t
0.18-
J0.16-
p>0.12i
a:
£ 3.38-
c
§ 0.06 -
_cn
£ 0.04-
0.02-
-1
C
k
f
A
\ \
\^
20
TVC
.
L
)C EMISSION RATE VS T
* '" A :
tO 60 SO 100
Eiaosed Hour
Carpet A ±- Carpet 3
ME
^^^
120
JL
UO 16
0
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Date Prepared: January 8, 1991
FIGURE 4
TYPICAL TVOC CHROMATOGRAM OF CARPET EMISSIONS
(1 HR EXPOSURE)
1000000 -
JOO'J'JO -
Tir.-.s .min.
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Date Prepared: January 8, 1991
FIGURE 5
TYPICAL 4-PC EMISSION PROFILE WITH TIME
(SBR LATEX CARPET)
0.07
0.06
0.05 -^ :
| 0.03
c
c
0.02i
0.0; J
0
4-PC EMISSION RATE VS TIME
0 20 40 60 80 100
Eidosed Hour
120 UO 150
Corset A -*.- Cornet B
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Date Prepared: January 8, 1991
FIGURE 6
"MEAN" TVOC EMISSION RATE PROFILE WITH TIME
(SBR PRODUCTS)
o.oo-
20 40 60 80 100 120 140 160
Elapsed Hours
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Date Prepared: January 8, 1991
FIGURE 7
CONFIDENCE LEVELS OF "MEAN" TVOC EMISSION RATE PROFILE
WITH TIME (SBR PRODUCTS)
0.70-
0.60-
0.10-
0.00-
EPA QudMne
99% Confidence 'ntetvai
About *e Wean
20 40 60 80 100 120 140 160
Elapsed Hours
0.70-
0.60-
f 0.50-
I :
O) I
- 0.30-
(0
§ 0.20-
UJ
0.10-
0.00
95% Confidencs "m«va
About Si« Mean
0 20 40 60 30 100 120 140 160
Eiacsed Hours
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FIGURE 8
TYPICAL TVOC EMISSION PROFILE
OF LATEX ADHESIVE
15 20 25
ELAPSED DAYS
30
40
Hingis Glue
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Date Prepared: January 8, 1991
FIGURE 9
TVOC CHROMATOGRAPHIC SCAN OF
LATEX ADHESIVE
Abuncancs
TiC or l02scCA'CS'-'2.a
! 1.40e»07 -
1.20e*07 -
! 3 OOe + 06 -
i i
: i
i
ii I
-
! i
i )!'.
j.Jue-'JlJ . > ~i ...*. l.i : : "»* "i ' -
4 S 8 !0 -2 !
| Time (nun.)
-I '5
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FIGURE 10
TVOC EMISSION PROFILE OF PARTICLEBOARD
UNDERLAYMENT COMPARED TO CARPET
0.37
20
4-0
60 80 100
Elapsed Exposure Hour
120
140
Partiaeooard Carpet
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FIGURE 11
TVOC EMISSION PROFILE OF "LOW VOC" ADHESIVE
WITH AND WITHOUT CARPET OVERLAY
50
100 150 200 250
Exposure Time (Hr)
300
350
Adhesive
G-- Adhesive/carpet
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FIGURE 12
TVOC EMISSION RATE COMPARISON OF
"CARPET SYSTEM" AND INDIVIDUAL CONTRIBUTORS
60
£50
*
(N
E
£30^
c
"in
E20-t
CJ
o
10-
0
pad(P) carpet(C) adhesive(Ad) C/Ad C/Ad/P/Ad
Carpet Systems and Components
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FIGURE 13
COMPARISON OF TVOC EMISSION RATES OF
DIFFERENT INTERIOR PRODUCTS
120
87
CM
I
tr
c
LLJ
TVOC Emission
Rates
Different Materials
1CK
9i
8-
7-
6-
5-
4-
3-
2-
Carpet P-Wood Wallcovering Adhesive
Paint
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Date Prepared: January 8, 1991
REFERENCES
[1.] ASHRAE, "Ventilation for Acceptable Indoor Air Quality," ASHRAE 62-
1989, ASHRAE, Atlanta, Georgia (1989).
[2.] Black, M., and J. Mason, "Correlation of Wood Product Formaldehyde
Emission Rates", GTRI, Atlanta, Georgia (1985).
[3.] Canada, "Exposure Guidelines for Residential Indoor Air Quality,"
Minister of National Health and Welfare, Ottawa, Canada (1987).
[4.] Federal Register, "EPA: Carpet Response to Citizen's Petition," Vol
55, No. 79, Washington, D.C. (1990).
[5.] Miksch, et.al., "Modified Pararosaniline, Method for the
Determination of Formaldehyde in Air", Anal. Chem. 53,2118 (1981).
[6.] State of Washington, East Campus Plus, "An IAQ Assessment Program,"
Olympia, Washington (1990).
[7.] Tucker, Gene, "Building with Low-Emitting Materials and Products:
Where Do We Stand?" Indoor Air '90 - the Fifth International
Conference on Air Quality and Climate, Toronto, Canada (1990).
[8.] WHO, Indoor Air Quality, Euro Reports, and Studies, Berlin (1987).
R-34
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APPENDIX 1
STANDARD TEST METHOD FOR DETERMINING
TOTAL VOLATILE ORGANIC COMPOUND EMISSION RATES
FROM FLOORING MATERIALS UNDER DEFINED TEST CONDITIONS
USING SMALL ENVIRONMENTAL CHAMBERS
1.0 SCOPE
1.1 The following methodology measures the total volatile organic compound
(TVOC) emission rates from flooring materials using test conditions defined
to simulate product use in realistic settings, residential and commercial
structures. The level of total volatile organic chemical emissions is
determined by observing the TVOC concentration in a small environmental
chamber under specified test conditions. The observed concentration is then
related by a mathematical calculation to an emission rate, a product
specific variable. The quantity of TVOC in the environmental chamber air is
determined by gas chromatography or gas chromatography/mass spectrometry.
The methodology is generally applicable to volatile organic compounds with
boiling points from less than 0 C to 290°C emanating from individual
flooring materials including carpet, carpet cushions, adhesives, subflooring
and associated "installed systems".
1.2 The "generic" standard environmental chamber practices currently described
by the U.S. EPA in its document "INDOOR AIR SOURCES: USING SMALL ENVIRON-
MENTAL CHAMBERS TO CHARACTERIZE ORGANIC EMISSIONS FROM INDOOR MATERIALS AND
PRODUCTS," EPA REPORT 600/8-89-074, and ASTM Guide 05116-90, "STANDARD GUIDE
FOR SMALL-SCALE ENVIRONMENTAL DETERMINATIONS OF ORGANIC EMISSIONS FROM
INDOOR MATERIALS/PRODUCTS," are coupled with "flooring specific" environ-
mental chamber requirements and analytical procedures. These requirements
are necessary for the study of TVOC emission rates from carpet and other
flooring specific materials if acceptable accuracy and precision are to be
achieved.
1.3 The methodology provides a standard means of reproducibly and accurately
testing carpet and other flooring materials under a realistic, yet highly
controlled, atmosphere.
2.0 REFERENCE DOCUMENTS
2.1 ASTM Guide D5116-90 for Small Scale Environmental Determinations of Organic
Emissions from Indoor Materials/Products.
2.2 ASTM Test Method 741 for Determining Air Leakage Rates by Tracer Dilution.
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2.3 ASTM D3195 Recommended Practice for Rotameter Calibration.
2.4 ASTM D1356 Definitions of Terms Related to Atmospheric Sampling and
Analysis.
2.5 ASTM E355 Recommended Practice for Gas Chromatography Terms and
Relationships.
2.6 ASTM D3609 Practices for Calibration Techniques Using Permeation Tubes.
2.7 Tichenor, "Indoor Air Sources: Using Small Environmental Chambers to
Characterize Organic Emissions From Indoor Materials and Products," EPA
report 600/8-89-074.
2.8 Matthews, "Environmental Chamber Test Methodology for Organic Vapors from
Solid Emission Sources," ATMOS. Env., 21, 1987.
2.9 Tichenor, "Organic Emissions from Consumer Product and Building Materials to
the Indoor Environment," J of APCA, 38, 1988.
2.10 Black, "Environmental Chamber Methodology for the Study of VOCs Emitting
from Manufactured Products," Proceeding of Indoor Air '90, Toronto, August,
1990.
3.0 TERMINOLOGY
3.1 Definitions and Terms Specific to This Standard
AIR CHANGE RATE (ACH). The ratio of the volume of purified and environ-
mentally controlled air brought into the chamber hourly and the chamber
volume measured in identical units (typically expressed in air changes per
hour (ACH) or hr .
EMISSION RATE (mg/mz-hr). A product specific factor describing the mass of
chemical emitted from a product per exposed area of the product per unit
time.
ENVIRONMENTAL TEST CHAMBER (ETC). A test apparatus with highly controlled
operational parameters designed to realistically provide accurate and repro-
ducible TVOC studies for flooring materials.
LOADING RATIO (m2/m3). The ratio of exposed surface area of the test
product and the free chamber volume, measured as m /m .
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4.0 SIGNIFICANCE AND USE
4.1 The minimization of VOC emissions from interior products and processes has
been suggested as a prudent step in reducing human exposures to chemical
emissions.
4.2 Architects, interior designers, indoor air consultants and those involved
with the design of new construction and building refurbishing are specifying
allowable VOC emissions from products and interior activities.
4.3 This methodology provides a standard means of testing carpet and other
flooring materials under realistic product loadings with operational
parameters and environmental conditions consistent with a product's end use.
4.4 The method incorporates a small environmental chamber, 0.05 m in size to
evaluate the level of TVOC in the flooring materials over a specified
duration of time. Environmental chambers larger in size may be used if
acceptable correlation with the latter chamber is shown (correlation
coefficient greater than 0.95). Conditions controlled in the method
include:
4.4.1 Sample collection and packaging to preserve the product's manu-
factured chemical integrity;
4.4.2 Sample preparation in a realistic presentation for individual
materials and "installed systems";
4.4.3 Conditioning of the product or system prior to obtaining the test
value;
4.4.4 Exposed surface area of the product being tested;
4.4.5 Environmental test chamber construction and operation;
4.4.6 Environmental test chamber temperature and moisture content;
4.4.7 Environmental test chamber air changes per hour;
4.4.8 Air circulation and velocity within the test chamber;
4.4.9 Accuracy and precision control of the chamber system; and
4.4.10 Accuracy and precision of the analytical measurements.
4.4.11 Sample archiving.
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4.5 The test procedure employs a single set of experimental parameters to assess
the TVOC emissions of certain carpet and associated flooring materials.
Care must be exercised in the extension of the results to actual TVOC
emissions under different conditions. This method provides an accurate and
precise comparison of TVOC levels from different products intended for the
same use.
4.6 The test method permits variance of experimental parameters to assess TVOC
emissions of carpet and associated flooring materials under different usage
situations. Parameters which can be independently controlled include air
temperature, air moisture level and air exchange rate.
5.0 THE ENVIRONMENTAL CHAMBER
5.1 The interior volume of the environmental chamber should be a minimum of 0.05
m . The interior must be constructed of inert smooth stainless steel and
must assure that a representative TVOC mixture is not irreversibly retained
on the interior surfaces. Recovery rates of a representative mixture of
TVOCs including methanol, toluene, cyclohexane and decane must be greater
than 95% at a mixture concentration of 40 jj-g/m . All joints of the chamber
must be permanently sealed except those absolutely necessary, i.e. the
opening for loading and unloading the sample and environmental probes.
These ports must have a self sealing capacity comprised of non-VOC emitting
and non-VOC adsorbing/absorbing materials.
5.2 The air within the chamber must be free of any obstructions or contamination
such as fans, humidifiers or coils. The internal air must only come in
contact with the inert chamber walls, the air diffusion system, which
includes inlet and outlet ports and environmental measurement devices.
5.3 Internal air velocity within the chamber must be reproducibly maintained in
the range of 0.1 m/sec which is typical of the occupied zone of interior
spaces. As discussed in ASTM Guide D5116-90, reference document 2.1, the
air velocity near the surface of the product being tested can affect the
mass transfer coefficients of the organic chemicals emitting from the
product. Control must be exercised to ensure that the air velocity at the
surface of the product being tested is maintained within the suggested range
of 0.1 m/sec. The air mixing mechanism must also be well controlled.
5.4 Internal chamber air must be well-mixed and must comply within 5% of the
theoretical well-mixed model. A discussion of this evaluation is given in
reference document 2.1, ASTM Guide 05116-90. It is recommended that SF6, or
an other inert gas, be used as a tracer gas to determine compliance with the
theoretical curve. A known concentration and constant supply of SF6 is ^^
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introduced into the chamber, and the chamber concentration of SF6 versus
time profile is measured. Mathematically, this experimental curve should
comply within a 5% relative standard deviation of the theoretical curve.
This mixing evaluation should be confirmed with the flooring mounting sub-
strate in place. An empty chamber may not give a realistic representation
of the air mixing within the chamber during actual testing.
5.5 Clean air must be generated as the chamber supply air. It is necessary that
the supply air backgrounds be sufficiently low to achieve statistically
meaningful analytical measurements at the levels anticipated. Purified air
must not have a background contributing concentrations greater than 2.0
jjig/m of TVOC with any individual VOC not contributing more than 2.0 u.g/m .
Supply air must be accurately and reproducibly metered to the chambers, and
maintained at a rate of 1.00 ± 0.05 (standard deviation) air changes per
hour. The accuracy of this air exchange rate must be confirmed using ASTM
method 741 for tracer gas applications, and found to have less than 10%
relative error.
5.6 Other environmental conditions must be maintained reproducibly within the
ETC environment including;
Temperature at 25°C ± 0.5°C (standard deviation)
Relative Humidity at 50% ± 2% (standard deviation)
Acceptable accuracy levels are 5% average relative error based on twelve
measurements over a 24 hour period as measured within the ETC supply air.
5.7 The chamber must be operated under slight positive pressure (1+ inches of
water) relative to atmospheric pressure.
5.8 Sample ports must be affixed to the outlet exhaust of chamber in a manner
that does not produce a backpressure effect on the chamber flow. The
sampling protocol must not pull over more than 50% of the outlet air flow.
5.9 A process control system must be used to maintain the exactness required of
the chamber control, and continuous monitoring and data logging of the
chamber operating parameters must be maintained and available at frequent
intervals.
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6.0 SAMPLE HANDLING
6.1 The primary intent of a well-defined sample handling procedure is to ensure
preservation of the sample's chemical integrity. This process involves
defined and controlled procedures encompassing sample collection, sample
packaging, sample delivery to the testing facility and storage of the sample
prior to testing. All of these parameters are important once the sample has
been collected and until it is tested.
6.2 Sample Collection.
6.2.1 The collected sample must ensure accurate representation of the
actual performance parameter being evaluated. Since the measured
performance factor, in this case, is TVOC, its composition must be
retained and uncontaminated during all the phases of the sample
handling process. Because of the very low levels of TVOC associ-
ated with carpet products, it is recommended that the carpet and
associated materials be collected directly from the manufacturer's
production line, and packaged immediately. This is the only way to
ensure that original sample integrity is maintained.
6.2.2 In actual building usage applications, one may wish to more closely
simulate the handling of the product prior to its delivery to a job
site. This may be attempted if the handling procedures are known,
but it may be very difficult to control. There would be no assur-
ance that the TVOC levels and composition of the product after this
type of treatment would be product specific TVOCs. This approach
is not recommended for product specific information. Contamination
of the carpet and its associated products may occur by atmospheric
exposure, activities and materials during this type of preparatory
stage.
6.2.3 For rolled materials such as broadloom carpet and cushions, the
sample should be collected as a minimum size of 2 ft. by 2 ft.
This will allow for rolling of the product so that there is an
internal layer from which a minimum of two samples can be collected
from the internal product roll. Other products such as carpet tile
should be obtained and packaged so that one internal piece is
sandwiched between two outer pieces. Any other solid or liquid
material, such as adhesive, should be placed from the manufacturing
facility into appropriately clean and sealed metal containers,
protecting it from the external atmosphere.
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6.3 Sample Packaging.
It is essential to package the product with materials which will not contam-
inate the product nor allow VOC permeability from either the interior or
exterior. An aluminized packaging (shiny side out) lined with polyethylene
or Tedlar is recommended. The sample background on the packaging material,
as tested according to this protocol, must have a consistent TVOC background
level less than 0.005 mg/nr-nr.
6.4. Product Delivery and Storage.
Once the sample is collected and packaged, it must arrive at the testing
facility ASAP, with a maximum allowable delivery time of 36 hours following
collection. It should then be stored in its packaged state in an environ-
mentally controlled interior space for a maximum period of 8 hours prior to
testing. The sample is to remain sealed until it is to be tested. There
should not be any preliminary observation of the sample.
6.5 Product Storage.
Following testing, the product should be repackaged and stored for a 6 month
time period by the testing facility. This storage should be maintained in
an environmentally conditioned interior environment. The test specimen
packaging must be air-tight and VOC free as required of the original
packaging with a VOC background less than 0.005 mg/m-hr.
7.0 PREPARATION OF THE PRODUCT TEST SYSTEM
7.1 The sample must be prepared in a realistic manner. The universal test mount
substrate should be concrete, the most universal in commercial and the most
inert substrate of all sub-flooring materials. If prepared and cured
properly, the concrete will be a non-TVOC source and will not present a
problem in the analysis. A stainless steel plate may be used for the carpet
cushion material or other solid material if it is tested alone. The stain-
less steel plate cannot be used for adhesive. The mounting must have the
ability to seal the edges of the test specimen or entire mounting block. A
stainless steel edge sealer is recommended for this.
Other substrates such as particleboard underlayment or plywood, the most
common in residential homes, or other materials, such as resilient flooring,
may be used. However, these flooring systems will contribute VOCs and
complicate the studies, since they too will be emitters of VOCs. A back-
ground control of their VOC emissions must be obtained so that the product
test results may take the substrate contributions into account.
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7.2 The flooring material must be prepared to comply with a loading ratio of
0.41 m /m . This loading is based on a standard ceiling height of 2.4 m
allowing complete floor coverage with the material being tested. The
flooring must be laid on the appropriate sub-flooring (concrete, the
standard) and tested as a complete package. The edges of the flooring
system, including the sub-flooring and carpet, must be sealed or consid-
erable error could be incurred in the analysis.
Once the appropriate system has been prepared, it should be immediately
loaded into the test chamber for conditioning and testing.
7.3 Each flooring material, i.e. carpet, cushion, adhesive, etc. must be
evaluated independently for accurate product-specific emission data to be
obtained.
Installation systems of specific products may be assembled and tested, but
individual product specific information will not be obtainable. It is
simply a "whole" or complete system emission description. If the total
system as well as component contributions are required information, then
each component and the "whole" will have to be tested.
It is suggested that all component pieces be tested simultaneously in order
to avoid aging effects on the individual component contributions to the
whole.
7.4 The standard assembly for component testing will be that component installed
on the concrete sub-flooring, i.e. carpeL on concrete, cushion on concrete,
adhesive on concrete, each with the edges sealed. The other floorings, as
mentioned in 7.1, may be used if specified for special applications.
7.5. If system installation studies are required, the following combinations are
standard:
carpet on sub-flooring, no adhesive or cushion;
carpet on sub-flooring with adhesive (direct glue down);
carpet on sub-flooring with cushion, no adhesive; and
carpet on subflooring with cushion and adhesive (double glue down).
These installations and systems should be prepared according to the manu-
facturer's instructions and the use of CRTs Installation Guide for
Commercial and Residential Structures, CRI Publications 104 and 105. The
manufacturer's instructions should have priority, if available.
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8.0 ENVIRONMENTAL CHAMBER TESTING PROTOCOL
The testing should be conducted in environmental chambers. These chambers must
be constructed and designed to evaluate ultra-trace levels of organic
compounds. Chamber test conditions must be controlled if accurate and
reproducible data is to be obtained.
8.1 Procedure
8.1.1 The test chamber shall be purged prior to loading under normal
operating conditions, but without the test specimen. A chamber
background test conducted on the chamber must confirm a TVOC
background level less than 2.0 ug/m with any individual VOC not
contributing more than 2.0 p,g/m . Once that is ascertained, the
chamber may be opened and loaded.
8.1.2. The test specimen is prepared immediately prior to loading, and is
subsequently loaded into the chamber so that it is centered and
does not interfere with the flow of the supply air.
8.1.3. The standard test chamber operating parameters are:
1.00 ± 0.05 (standard deviation) Air Changes per Hour
50 ± 2% (standard deviation) Relative Humidity
25°C ± 0.5°C (standard deviation) Temperature
8.1.4. The test specimen is loaded so that the sguare area of the exposed
surface to chamber volume ratio of 0.41 m /m is achieved. All
edges of the test specimen are sealed. The test specimen is
allowed to equilibrate within the chamber for a 24 hour period,
immediately after which the first test sample is taken. For one
point in time testing, the 24 hour point is used. In that case,
duplicate samples are collected.
8.1.5. For those tests requiring other exposure points such as the change
in emission profile over time, additional samples are taken.
Sample collection points for dry materials should include at a
minimum 6 data points for example, 4 hour, 8 hour, 24 hour, 48
hour, 120 hour, 168 hour. Wet materials may require additional
weekly test points after 168 hours until measured levels in the
desired range are achieved.
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8.1.6. Prior to sample collection, the sampling lines are purged for a
total of 5 times their volume. The sampling line length should be
minimized to reduce potential sample loss. In addition, the
sampling lines should be heated if high boiling compounds (>150°C)
are expected in the emissions.
9.0 CHEMICAL ANALYSIS
9.1 Chamber Air Col lee t ion.
The low levels of VOCs associated with flooring materials require a signifi-
cant pre-concentration of the air prior to chemical analysis. A multi-bed
sorbent trap containing Carbosieve SIII, Carbotrap C, and Carbotrap, is
recommended for this purpose. The adsorbents are selected based on the
actual compounds present in the air sample. The adsorbents selected must
provide greater than 90% collection and desorption efficiencies for the
majority of the chemicals present in the product emissions under the test
conditions established for sample collection and analysis. Any other sorbent
system meeting these requirements may be used.
Actual sorbent traps must be conditioned in the laboratory making sure that
they are purified and contain no greater than 9 ng of TVOC.
9.2 Organic Instrumentation.
The TVOC analysis must be conducted by capillary gas chromatography coupled
with flame ionization detection or mass spectrometric detection. Sensi-
tivity is comparable between mass selective detectors and the flame ioniza-
tion detectors, and the compounds associated with the flooring materials
respond well to both detector systems. If individual compounds are to
identified, a mass spectrometer must be used as the detector. The air
sample must be efficiently desorbed from the sample sorbent tube to the
analytical instrumentation via a well-controlled, reproducible thermal
desorption system.
9.3 Standard Operating Procedures.
The laboratory must present Standard Operating Procedures (SOPs) for all
aspects of the analytical procedures with confirmation of their compliance
with the detection capability and established QC parameters. The SOP should
address:
9.3.1 Assembly, calibration and operation of the sampling system;
9.3.2 Preparation, handling and storage of the sorbent collection media;
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9.3.3 Description and operation of the instrumentation systems including
the sampling device, sample introduction system, separation
chemistry, and data system;
9.3.4 All aspects of data recording and processing;
9.3.5 The operating procedures should be specific and be readily
available to those involved in the analysis and testing.
9.4 Quantitation of the analytical system is with a TVOC mixture representative
of the types of VOCs present in the sample. A standard mixture containing
hexanol, toluene, cyclohexane, and decane is recommended. The average mass
response of this mixture is used for quantisation. This mixture must be
introduced as a gas into the analytical system and be subjected to the same
processes as the sample. Internal usage of perfluorotoluene or bromofluoro-
toluene is recommended to trace instrumental system performance.
9.5 Method Accuracy and Precision.
The requirements for those representative compounds included in the TVOC mix
are greater than 90% recovery (incorporating sample collection through
analysis) and less than 10% relative standard deviation. Any deviations
beyond these are unacceptable. The minimal quantifiable limit is 4.0 (ig/m
which is twice the required detection limit of 2.0 ng/m (or an absolute
value of 36 ng with no individual compound exceeding 9 ng).
9.6 Method Detect ion Limit.
The system detection limit is obtained from calibration standards and is
defined as:
DL = A + 3.3 s
where DL = the calculated detection limit in nanograms,
A = the intercept from a least squares calibration curve fit, and
S = the standard deviation of replicate determinations of the
lowest level standard.
The minimal quantifiable limit is twice the detection limit or 4.0 ng/m3
which is twice the detection limit of 2.0 ng/m or 36 ng TVOC. The quanti-
fiable limit is 0.01 mg/m -hr emission rate.
9.7 All detected mass responses corresponding to the quantifiable limit should
be summed and used in the TVOC determination. Calibration is by TVOC
mixture response factors as determined from a calibration curve.
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10.0 EMISSION RATE CALCULATIONS
10.1 The 24 hr. One Point in Time Test.
This emission factor (ER24) should be calculated as:
10.2
ER24 = C(N/L) = mg/nf.hr
where
-i
N = chamber air exchange rate, hr
L = Product Loading, m /m
C = 24 hr. chamber concentration, mg/m
For those studies involving the change in emission levels over a defined
test period, determine the initial emission rate (ER0) and the rate
constant (k) by fitting the chamber concentration versus time date to the
equation:
C = A(ER0)(ekT-e-Nt)/(N-k)
where C = chamber concentration, mg/m3
A = product area, m
ER0= initial emission rate, mg/m -hr
e = natural log base
-i
k = first order rate constant, h
t = time, hr
N = Air change rate in hr
The total predicted emission over the lifetime of the product is:
ER0/k = |xg/m2
This assumes a decreasing emission rate with time. Any other type of
emission pattern will require a different calculation based on an
appropriate mathematical model.
11.0 QUALITY CONTROL AND ASSURANCE
11.1 A quality control/assurance plan is designed to ensure the integrity of
the measured and reported data obtained during its product evaluation
studies. This program encompasses all facets of the measurement program
from sample receipt to final review and issuance of reports.
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11.2 Various measures should be routinely implemented in a product evaluation
program including, but not limited to:
appropriate record keeping of sample identifications and tracking
throughout the study;
calibration of all instrumentation and equipment used in the
collection and analysis of samples;
tracking of all chamber and analytical performance parameters
including air purification, environmental controls, air change rate,
sample recovery, detection capability and background levels;
analysis of spiked samples for accuracy determinations;
duplicate analyses of 10% of all samples evaluated and analyzed;
linear regression of all standardization;
analysis of controls including chamber backgrounds, sampling media,
and instrumental systems;
quality control charting of operational and analysis parameters; and
periodic audits by appropriate QA personnel.
12.0 REPORT FORM AT
The report should contain all pertinent information including:
testing laboratory name, address and contact person;
testing objectives;
date of sample arrival;
sample identification and description;
sample handling procedures;
testing preparation procedures for the product;
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experimental protocol including conditioning and testing;
test date and exposure duration;
data analysis procedures;
test results as required by the objective;
accuracy and precision bounds of test results;
analytical instrumentation and analytical methodology;
operational parameters and performance specifications of chambers and
instrumentation;
quality control assurance procedures and data.
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