EPDM VOC content

Waterproofing membrane is not necessarily on the roof. Don't believe the VOC requirement applies to EPDMs, except for any adhesive used.

VOC content is only applicable to on-site wet applied materials. So VOC content is not applicable to an EPDM membrane; however, the adhesive and sealant would need to be compliant for Healthcare, or School projects.  I think it would fall under - "Single ply roof membrane adhesives" - 250g/L.  

Jack, wouldn't the emissions and VOC content requirement generally apply to all projects, not just schools and health care, since the adhesive or primer is applied inboard of the membrane? 

My understanding: That the adhesive and primer would be considered inclusive to the weatherproofing system, as they are an essentail component for the integrity of the system as a whole. They are also located between the primary and secondary weatherproofing membranes.   Low-Emitting Materials: "The building exterior is defined as everything outside and inclusive of the primary and secondary weatherproofing system, such as waterproofing membranes and air- and water-resistive barrier materials." - BD+C V4 Low-Emitting Materials. I have also attached a link to this topic in another forum. It is older, but has some great discussion on if adhesives for membranes are considered interior/ exterior. https://leeduser.buildinggreen.com/forum/single-ply-roof-membrane-adhesives