California Proposed Limits on Caprolactam Would Negatively Affect State’s Economy: Carpet and Rug Institute (CRI) President Werner Braun Comments on TalkFloorTVIn a video interview titled CRI’s Werner Braun on the California EPA’s Caprolactam Emissions Decision that appeared on February 25, 2011 on TalkFloorTV, host Dave Foster spoke with Carpet and Rug Institute President Werner Braun about measures currently proposed in California that would dramatically reduce the permissible exposure limit of caprolactam, the primary building block of nylon 6, an important source of carpet fiber.
(See related blog post California’s Proposed Reductions in Caprolactam, Formaldehyde Emissions)
Mr. Braun points out that, at a time when regulatory agencies in Europe and the U.S. have either significantly raised their allowable limits (and in the case of the U.S. Environmental Protection Agency, altogether removed the compound from its list of hazardous air pollutants), California is set to slash its allowable levels from the current 100 micrograms emitted per cubic meter of air down to 2µg/m³. The recommendations are coming out of the state’s Office of Health Hazard Assessment (OEHHA), a division of California’s Environmental Protection Agency.
Mr. Braun had strong words concerning the proposed decreases, saying that, as a former toxicologist, he thought the proposed changes were ill-conceived and wrong-headed.
He also notes that OSHA, the U.S. Occupational Health and Safety Administration, has set a limit on caprolactam that is 500 times the amount proposed for California. In addition, OSHA’s limit is set to reflect a total exposure that even sensitive individuals could tolerate without negative health effects during eight-hour work days spanning a 40-year career. In contrast, Caprolactam emissions from carpet, already set at one-quarter of OSHA’s allowable levels, dissipate completely in a few months.
The OEHHA proposals are relevant to the carpet industry in that once OEHHA sets a level for a particular Volatile Organic Compound (VOC), California’s Department of Public Health uses one-half of that number to set emission limits in its 01350 Indoor Air Quality Standard Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions from Indoor Sources Using Environmental Chambers, Version 1.1 (2010). In turn, the 01350 standard, as it is commonly known, is what the CRI uses as the basis for establishing the emission levels in its Green Label Plus (GLP) IAQ Standard.
This is significant to the carpet industry, because, if the GLP standard discontinues its adherence to the requirements of CA 01350, it will no longer be eligible for credit under the U.S. Green Building Council’s LEED Green Building program.
As to the impact the proposed changes would have, Mr. Braun said they would cause significant deselection of nylon 6 carpet and have, “Dire consequences on jobs and revenue in the state of California.”
He said the timeline for the proposed change is mid-April, but that CRI was asking the state for additional time to respond to comments on the issue.
“It’s an incredible can of worms,” he said.