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Comment 1 for Consumer Products Test Method 310 (cpmthd310) - 45 Day.

First NameReinhard
Last NameOppl
Email AddressReinhardOppl@eurofins.com
Affiliation
SubjectLow VOC determination with method 310 not very reliable
Comment
Low VOC coatings, adhesives etc. are difficult to assess by present
method 310 using gravimetric determination of all volatiles (weight
loss during 1 hour of heating) and then subtraction of evaporated
water: 
1) With low VOC products, sensitivity and accuracy go down. 
2) With high water content and low VOC content, the limited
accuracy of water determination method will overrule any findings
of the low VOC content, resulting in very bad reliability. 
3) All this is even worse for cement based tile adhesives that are
almost impossible to determine with method 310. 
4) Modern water-based products then are punished relative to
solvent-based products due to weakness of test method, which cannot
be the meaning of method 310. 
The proposed change (direct gas chromatographic determination) is
basically excellent, but it should not refer to analytical methods
dealing with completely different issues (industrial emissions, or
solid waste), when a low VOC paint specific method is available:
ASTM D6886-03. Please use ASTM D6886-03 for low VOC products. 
Best regards, Reinhard Oppl, Eurofins Product Testing A/S,
Galten/Denmark and San Ramon/California

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Date and Time Comment Was Submitted 2009-08-17 09:38:44

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