TELEPHONE NOTES


Subject:    Testing of Reprocessed/consolidated Latex Paints
Date:       May 19, 1997
Contact:    Sue Drozdz, Army Corps of Engineers
By:         Dana Arnold, U.S. EPA, Office of Solid Waste (name changed to Office of Resource Conservation and Recovery on January 18, 2009)


- The Army Green Buildings Program provided funding to the   
  Army Corps to assist with identifying þgreenþ products     
  that can be used by the Army. The Army did not request     
  testing of paints.

- Ms. Drozdz chose to test reprocessed/consolidated latex    
  paints because she noticed that the requirements in the    
  GSA specification for "recycled" latex paints, TT-P-2846,  
  differed slightly from the requirements in the other GSA   
  specifications for interior and exterior latex paints. The 
  Army uses GSA specifications for building paints.

- Contrary to what is stated in the public comments from the
  National Paint & Coatings Association, neither the Army    
  nor the Army Corps has particular concerns about           
  reprocessed/consolidated latex paints.

- Paints were tested against GSA specification TT-P-2846 to
  determine if what GSA had on schedule met the              
  specification. The paints met this specification.

- Paints also were tested against the GSA specifications for
  virgin interior latex paints, TT-P-29 and exterior latex   
  paints, TT-P-1984(?). The paints performed satisfactorily  
  against the interior paint specification. Testing against  
  the exterior paint specification is not completed; a       
  weatherization test is about to begin and will take a      
  couple of months to complete. The paints performed         
  satisfactorily against the other exterior paint tests.

      - Ms. Drozdz indicated that she was pleasantly         
        surprised by the performance of the paints and would 
        not have any concerns about using them for interior  
        applications. 

- Ms. Drozdz cited two concerns. First, the Army uses        
  acrylic latex paints over primed metals. She is not        
  certain that reprocessed/consolidated latex paints are     
  available containing 100% acrylic. Second, all of the      
  Defense Department is moving away from government          
  specifications to commercial products, and there currently 
  is not a commercial item description (CID) for             
  reprocessed/consolidated latex paints. I pointed out that  
  if EPA designates reprocessed/consolidated latex paints,   
  the Army can either continue to use the GSA specification  
  or develop a CID.

- We also discussed narrowing the designation to reflect the
  applications listed in the GSA specification (i.e.,        
  interior and exterior wall and trim for wallboard,     
  masonry, etc.) Ms. Drozdz did not have an opinion.