LTTR has been a topic of discussion within the C578 task group for over 5 years. Section 7 contains the Physical Property requirements for materials that fall under the jurisdiction of this standard. Section 7.3 requires LTTR to be evaluated for polystyrene materials that have a captive blowing agent, generally extruded polystyrene. Section 7.3 contains the words “determine and report” and there have been multiple ballots over the years addressing the reporting of LTTR.
When a physical property is determined according to the prescribed test method, a test report is generated. So, the words “and report” are redundant in Section 7.3. However, some stakeholders of the standard believe the words “and report” is a requirement to disclose the LTTR physical property.
ASTM Form and Style contains recommendations for the creation of standard specifications. Form and Style describes the physical property section as the location of performance requirements of materials. Section B22 Product Marking and section B23 Packaging and Package Marking contains instructions for how standard specifications include packaging/product marking requirements. It is the technical contact’s opinion, that the confusion around whether C578 requires the disclosure of LTTR or not is because the words “and report” in Section 7.3 of the physical property portion of the standard is inappropriate and incomplete. Product marking is not a physical property. Furthermore, C578 Section 15 Product Marking contains explicit requirements for how products are to be marked. I understand that members who have been involved with the development of C578 for a long time believe the intention of the task group when LTTR was included in the standard was to require the disclosure of the property. However, since the product marking section of the standard was not revised accordingly, there is no disclosure requirement within the standard as written.
This work item is an effort to draw this effort to a conclusion.
Developed by Subcommittee: C16.22
Staff Manager: Mary Mikolajewski
Date Initiated: 02-10-2022
Technical Contact: Michael Joyce