Perhaps it’s a sign of increasing globalization, but ACMA’s recent regulatory work has taken a distinct international flavor.
Our first globally sourced opportunity came by way of our boatbuilding colleagues, who called to tell us the Environmental Protection Agency (EPA) was planning to prohibit the use of HFC-134a, widely used as a propellant for polyurethane foam floatation systems in boats and for insulated panels in refrigerated trailers.
The EPA’s planned action is part of its program under the Montreal Protocol, a 1987 treaty designed to phase out the production of HFC-134a and other hydrofluorocarbons (HFCs) that contribute to the destruction of the stratospheric ozone layer that shields the earth’s surface from harmful ultraviolet radiation.
HFCs are also potent heat trapping gases, and the EPA wants to prohibit or strictly limit the use of these compounds both to protect stratospheric ozone and to reduce climate change. But the agency recently proposed to eliminate use of HFC-134a by Jan. 1, 2017, much too soon to allow composites manufacturers to identify and fully qualify workable replacements.
In comments recently submitted to the EPA, ACMA argued our industry’s use of HFC-134a has the net effect of reducing the emission of climate warming gases because of the fuel savings accrued from the use of lighter and better insulated trailers. The association asked the agency to delay phase-out of this important substance until 2020.
Another call reached ACMA’s international switchboard from the U.N.’s Persistent Organic Pollutant Review Committee (POPRC). Convened under the 2001 Stockholm Convention, another international treaty, the POPRC identifies toxic substances that may accumulate in the environment, evaluates the availability of feasible alternatives, and then for each substance recommends either a complete phase-out, a limited ban, or, if there are no alternatives, no action.
The POPRC’s July 2014 risk assessment report for pentachlorophenol (PCP), a toxic and environmentally persistent substance widely used in the U.S. and Canada for the preservation of wood utility poles and railroad ties, included a lengthy evaluation of materials that may serve as useful replacement for treated wood in these applications. Unfortunately, the POPRC’s discussion on composite utility poles contained several critical misstatements.
In response, ACMA sent the POPRC information and references supporting the proven benefits and performance of composite utility poles and argued they are a feasible replacement for treated wood poles. A PCP phase-out recommended by the U.N. group may tip the large U.S. utility pole market in the direction of composites.