State of California  
AIR RESOURCES BOARD  
 
 
PUBLIC HEARING TO CONSIDER THE PROPOSED AMENDMENTS TO 
THE CONSUMER PRODUCTS REGULATION AND METHOD 310  
   
STAFF REPORT: INITIAL STATEMENT OF REASONS  
  
 
DATE OF RELEASE:  APRIL 3, 2018  
SCHEDULED FOR CONSIDERATION:  MAY 25, 2018  
  
 
Location:  
 
Sacramento County Administration Building  
700 H Street  
Sacramento, California  95814  
 
 
 This report has been reviewed by the staff of the California Air Resources Board and approved for publication.  Approval does not signify that the contents necessarily reflect the views and policies of the California Air Resources Board, nor does mention o f trade 
names or commercial products constitute endorsement or recommendation for use.
 
   
  
 
  
 
 
 
 
 
 
 
 
   
 
 
  
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 i 
 TABLE OF CONTENTS  
EXECUTIVE SUMMARY .......................................................................................... ES-1 
I. INTRODUCTION AND BAC KGROUND  .................................................................  1 
A. INTRODUCTION  ....................................................................................................... 1 
B. BACKGROUND  ........................................................................................................ 1 
C. REGULATORY HISTORY  ........................................................................................... 5 
II. THE PROBLEM THAT THE  PROPOSAL IS INTENDE D TO ADDRESS  .............. 6 
A. DESCRIPTION OF PUBLIC PROBLEM PROPOSAL IS INTENDED TO ADDRESS  .................. 6 
III. SUMMARY OF THE SPECI FIC PURPOSE AND RATI ONALE FOR EACH 
ADOPTION, AMENDMENT, OR REPEAL  ............................................................. 8 
A. PROPOSED AMENDMENTS TO THE CONSUMER PRODUCTS REGULATION  ..................... 8 
B. PROPOSED AMENDMENTS TO  METHOD 310 ........................................................... 17 
IV. BENEFITS ANTICIPATED FROM THE REGULATORY  ACTION, INCLUDING 
THE BENEFITS OR GOAL S PROVIDED IN THE AUTHORIZING STATUTE  ..... 20 
V. AIR QUALITY  ....................................................................................................... 21 
VI. ENVIRONMENTAL ANALYS IS ............................................................................ 22 
A. INTRODUCTION  ..................................................................................................... 22 
B. ENVIRONMENTAL REVIEW PROCESS  ....................................................................... 23 
C. PRIOR ENVIRONMENTAL ANALYSIS  ........................................................................ 23 
D. PROPOSED  AMENDMENTS TO THE CONSUMER PRODUCTS REGULATION  ................... 24 
E. ENVIRONMENTAL IMPACTS ..................................................................................... 25 
VII. ENVIRONMENTAL JUSTICE  ............................................................................... 28 
VIII. ECONOMIC IMPACTS ASS ESSMENT  ................................................................ 28 
A. INTRODUCTION  ..................................................................................................... 28 
B. SUMMARY OF FINDINGS  ......................................................................................... 29 
C. ECONOMIC IMPACTS ANALYSIS ON CALIFORNIA BUSINESSES , CONSUMERS , AND 
EMPLOYMENT  ....................................................................................................... 31 
D. ANALYSIS OF POTENTIAL IMPACTS TO CALIFORNIA STATE OR LOCAL AGENCIES  ....... 34 
IX. EVALUATION OF REGULA TORY ALTERNATIVES  ........................................... 35 
X. JUSTIFICATION FOR AD OPTION OF REGULATION S DIFFERENT FROM 
FEDERAL REGULATIONS CONTAINED IN THE CODE OF FEDERAL 
REGULATIONS  .................................................................................................... 36 
A. NATIONAL CONSUMER PRODUCTS REGULATION  ..................................................... 36 
XI. PUBLIC PROCESS FOR DEVELOPMENT OF THE PR OPOSED ACTION (PRE-
REGULATORY INFORMATI ON) .......................................................................... 37 
XII. REFERENCES  ...................................................................................................... 38 
XIII. APPENDICES  ....................................................................................................... 41 ii 
 APPENDIX A:  PROPOSED AMENDMENTS TO THE REGULATION FOR REDUCING 
EMISSIONS FROM CONSU MER PRODUCTS  .................................................... 41 
APPENDIX B:  PROPOSED AMENDMENTS TO METHOD 310: DETERMINATION OF 
VOLATILE ORGANIC COM POUNDS (VOC) IN CONS UMER PRODUCTS AND 
REACTIVE ORGANIC COMPOUNDS (ROC) IN A EROSOL COATINGS  ........... 41 
APPENDIX C:  2016 TE CHNICAL ASSESSMENT F OR MULTI -PURPOSE 
LUBRICANTS  ....................................................................................................... 41 
 
LIST OF  ACRONYMS ………………………………………………………………………....iii  
 
LIST OF TABLES    
 
Table 1 : Summary of Technical Assessment  of Multi -purpose Lubricant Product s 
(Excluding Oils) …………………………………………………………………….. 8 
 
Table 2 :  Comparison of Ingredient s…………………………………………………….. 26 
 Table 3 :  Reformulation C osts for  Multi -purpose Lubricant  Products …………….. 30 
 Table 4 :  Wage Rate Range in California…………………………………. ……………..32  
 
  iii 
 LIST OF  ACRONYMS  
 
AB   Assembly Bill  
ACP   Alternative Control Plan 
ASTM    American Society for Testing and Materials International  
Board    California Air Resources Board  
CARB    California Air Resources Board  
CCAA or Act   California Clean Air Act  
CCR    California Code of Regul ations  
CEQA    California Environmental Quality Act  
CFR   Code of Federal Regulations  
CO2   Carbon Dioxide  
FSOR    Final Statement of Reasons  
GHG    Greenhouse Gas  
g O 3/g ROC    Grams of Ozone per gram of Reactive Organic Compound  
g O 3/g product  Grams of Ozon e per gram of product  
GWP    Global Warming Potential  
ISOR    Initial Statement of Reasons  
LVP- VOC   Low Vapor Pressure Volatile Organic Compound  
MIR   Maximum Incremental Reactivity  
NAAQS   National Ambient Air Quality Standards  
ppm   Parts per Million  
PWMI R  Product -weighted Maximum Incremental Reactivity  
ROC   Reactive Organic Compound  
ROE    Return on Owner’s Equity  
SB   Senate Bill  
SIP   State Implementation Plan  
TAC   Toxic Air Contaminant  
Method 310  Air Resources Board Method 310, Determination of Vol atile 
Organic Compounds (VOC) in Consumer Products and Reactive Organic Compounds (ROC) in Aerosol Coating Products  
VOC    Volatile Organic Compound  
U.S. EPA   United States Environmental Protection Agency  
     
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 ES-1 
 EXECUTIVE SUMMARY 
 
Background  
 
In this rulemaking, California Air Resources Board (CARB or Board) staff is proposing 
amendments to the Regulation for Reducing Emissions from Consumer Products 
(Consumer Products Regulation) and CARB Test Method 310: Determination of Volatile Organic Compounds (VOC) in Consumer Products and Reactive Organic Compounds (ROC) in Aerosol Coating Products  (Method 310).  The primary purpose of the proposed 
amendments is to provide flexibility in meeting the 10 percent by weight VOC limit for multi-
purpose lubric ant (MPL)  products , which under the existing regulation would apply for the 
first time on December 31, 2018.  
 The Board approved amendments to the Consumer Products Regulation in 2008, reducing the VOC limit for MPL products to 25 percent by weight effecti ve December 31, 2013, and 
10 percent by weight effective December 31, 2015 (CARB, 2008) .  A Technical Assessment 
to determine feasibility of the VOC limits prior to their implementation was required for these technology -forcing limit s.  In 2013, the Board approved a three- year extension for the  
10 percent by weight VOC limit to allow manufacturers additional time to reformulate products  (CARB, 2013) .  The regulation also required Responsible Parties to report their 
reformulation and research and development efforts to meet the 10 percent by weight VOC 
limit.  Staff used this information to conduct a Technical Assessment to determine the 
feasibility of the 10 percent by weight VOC limit.  
 Staff’s analysis of the Technical Assessment determined that the 10 percent by weight VOC  
limit continued to prove challenging.  The analysis indicated that the air quality benefits 
anticipated from t he 10 percent reformulation had largely been met by the previous 
reformulation effort.  Staff determined that additional reformulation flexibility should be given 
to manufacturers, while locking in the air quality benefits achieved by the 25 percent by 
weight VOC reformulation effort .  Staff analyzed the product weighted maximum 
incremental reactivity (PWMIR) of products reported and found that formulation flexibility 
could be provided without compromising the air quality benefits by incorporating a reactivity 
limit. 
 Reactivity limits are based on sound science and have been used by the Aerosol Coating 
Products Regulation since 2000 when the regulation was amended to establish Reactivity 
Limits based on the maximum incremental reactivity ( MIR) scale  (CARB, 2000) .  In 2008, 
the United States Environmental Protection Agency ( U.S. EPA) also promulgated a national 
reactivity -based regulation for aerosol coatings  (U.S. EPA, 2008) . 
 
This Executive Summary, together with the Staff Report, is the Initial Statement of Reasons 
for Proposed Rulemaking required by the California Administrative Procedure Act.  
Appendix A contains the proposed amendments to the Consumer Products Regulation.  
Appendix B contains the proposed amendments to Method 310.  The proposed regulatory 
changes provided in Appendices A and B are shown in underline and strikeout  format.  
 
  ES-2 
 Staff Proposal  
 
CARB staff has proposed amendments to the Consumer Products Regulation to include an 
alternate compliance option to provide flexibility for manufacturers in meeting the 
requirements of the 10 percent by weight VOC limit  for MPL products .  The alternate 
compliance option would allow manufacturers to comply by meeting a 25 percent by weight 
VOC limit and a PWMIR  limit of 0.45 grams of ozone per gram of product  (g O 3/g product) .  
Staff is also proposing to extend the effective date of the existing 10 percent by weight VOC 
limit from December 31, 2018, to July 1, 2019, to provide adequate time for manufacturers 
of MPL products to evaluate their products and decide whether to comply via the alternate 
compliance option or the 10 percent by weight VOC limit.  Additionally , staff is proposing to 
prohibit the use of compounds with high global warming potentials (GWP)  in MPL products .   
 
The sections proposed for amendment are codified in title 17, California Code of 
Regulations (CCR) , sections 9450 9, 94513, and 9451 5. 
 Amendments to the analytical method,  Method 310,  are also proposed.  The proposed 
amendments to Test Method 310 are intended to clarify and update dates of test 
procedures.   Specifically, staff is updating reference method citations and dates, correct ing 
grammar for consistency, and including several additional reference methods.  
 
Emission Reductions and Impacts 
 The flexibility that would be provided by the pro posed amendment would achieve the same 
air quality benefits as  the 10 percent  by weight  VOC limit  because it would require that 
products complying under the alternate compliance option form no more ozone than the 
average 10 percent compliant product.   The mass of VOC for products meeting the 
alternate compliance option would be expected to r emain at current levels .  The propos ed 
amendments would provide  flexibility for manufacturers to continue offer ing products with 
the performance that consumers expect  while meeting the air quality objectives of the 
regulation.  The alternate compliance opt ion does not increase cost over the existing 
requirements and may result in lower compliance costs . 
 
The proposed reactivity limit would not require reductions in total  VOC content, but would 
likely require the use of ingredients with lower reactivity.  This would result in a reduc tion of  
the ozone formed from products choosing the alternate compliance option.  By allowing the 
alternate compliance option, overall reactivity of products wo uld be reduced rather than total 
mass of VOCs.   The proposed r eactivity limit provides equivalent ozone air quality benefits 
to the future effective 10 percent by weight mass based VOC limit and provides more 
reformulation options at  a potentially lower cost.    
 Staff’s Recommendation  
 
Staff recommends that the Board adopt the proposed amendments to the Consumer 
Products Regulation and Method 310.  
  1 
 I. INTRODUCTION AND BACKGROUND  
 
A. Introduction 
 
In this rulemaking, California Air Resources Board ( CARB or Board) staff is proposing 
amendments to t he Consumer Products Regulation and Method 310.   
This report is C ARB staff’s technical justification and analysis of the proposed 
amendments.  It is part of the Initial Statement of Reasons  (ISOR) for the Proposed 
Amendments to the Californ ia Consumer Products Regulation and Method 310.  The 
proposed amendments to the Consumer Products Regulation  and Method 310 are in 
Appendi x A and Appendix B, respectively.  
 
Included in this report is the f ollowing information:  
 
• Background information on the consumer products program;  
• The purpose for proposing the amendments;  
• A description of the public problems, the proposed solutions, and the rationale 
supporting the solutions;  
• A summary of the proposed action in plain language;  
• A summary and rationale for the regulatory proposals;  
• An analysis of the expected environmental impacts;  
• An assessment of how the proposed action aligns with C ARB’s environmental 
justice policies;  
• The economic impacts associated with complying with the proposed 
amendments; and 
• The public process staff used to develop the proposal.   
 
The primary purpose of the proposed amendments to the Consumer Products 
Regulation is to provide reformulation flexibility by establishing an alternate reactivity 
based limit for MPL products .  The purpose for proposing amendments to Test Method 
310 is to make corrections for clarity and consistency and to add several reference test 
methods.  
 
The proposed amendments designed t o fulfill these purposes would be codified in  
title 17, California Code of Regulations, sections 9450 9, 94513, and 94515.  
 
B. Background  
 Consumer products are defined as chemically formulated products used by household 
and institutional consumers.  Examples  include detergents, cleaning products, floor 
finishes, personal care products, lawn and garden products, adhesives, air fresheners, 
disinfectants, automotive maintenance products, paint thinners, insecticides, and aerosol coatings.  
 To date, the Board has  taken numerous actions to fulfill the legislative mandate 
pertaining to the regulation of consumer products.  An overview of the CARB ’s authority 2 
 to regulate consumer products, a synopsis of the regulations adopted to date, and a 
comparison of California and national consumer products regulations follows.  
 
1. Enabling Legislation  
 
The Health and Safety Code sets forth C ARB’s authority to regulate consumer products 
to control VOC emissions and greenhouse gas (GHG) emissions.  Section 41712 specifies require ments to reduce VOC emissions primarily as a ground- level ozone 
control strategy.  Section 38500 et seq. , establishes authority to reduce emissions of 
GHGs from consumer products as part of CARB ’s climate change mitigation strategy.  
Authority to mitigate potential adverse environmental impacts of proposed regulations is 
set forth in Public Resources Code section 21000 et seq.   A summary of each of these 
requirements in State law follows.   
 
a. Health and Safety Code section 41712  
 As part of the State’s ef fort to reduce air pollutants, in 1988 the California Legislature 
(Legislature) added section 41712 to the California Clean Air Act (CCAA or “the Act”) in 
the Health and Safety Code.  Section 41712, along with subsequent amendments, 
requires  CARB to adopt regulations to achieve the maximum feasible reduction in VOC 
emissions from consumer products.  The CCAA specified that attainment of the California State ambient air quality standards is necessary to promote and protect public health, particularly of chil dren, older people, and those with respiratory diseases.  The 
Legislature also directed that these standards be attained by the earliest practicable date.  
 
Prior to adopting regulations, the Board must determine that adequate data exist to 
establish that t he regulations are necessary to attain State and federal ambient air 
quality standards.  Commercial and technological feasibility of the regulations must also be demonstrated.  The Act further stipulates that regulations adopted must not eliminate 
any product form, and that recommendations from health professionals be considered 
when developing VOC control measures for health benefit products.  
 
b. Health and Safety Code section 38500 et seq.  
 
In 2006, Assembly Bill (AB) 32, The California Global Warming Sol utions Act of 2006, 
was signed into law.  This law created a comprehensive, multi -year program to reduce 
GHG emissions in California.  The California Health and Safety Code, commencing with section 38500, contains these provisions.  AB 32 requires CARB  to develop regulations 
and consider market -based compliance mechanisms that will ultimately reduce 
California’s GHG emissions to the 1990 baseline level  by 2020.  In addition to the  
requirements of AB 32, Senate Bill (SB) 32, signed by Governor Brown in 2016,  
requires statewide GHG emissions be reduced to 40 percent below 1990 levels by 2030.  
   3 
 c. Public Resources Code section 21000 et seq.  
 
In addition to requirements set forth in California's Health and Safety Code, the 
California Environmental Quality Act (CEQA) requires that environmental impacts of 
proposed regulations be evaluated.  If significant adverse environmental impacts are 
identi fied, mitigation measures must be put in place, if available, to reduce or eliminate 
such impacts.  The provisions of CEQA are contained in California's Public Resources 
Code, commencing with section 21000 et seq.    
 
2. Existing Consumer Products Regulations  
 For more than twenty years, the Board has taken actions to fulfill California’s  legislative 
mandates pertaining to the regulation of consumer products.  Three regulations adopted 
by CARB have set VOC limits for 130  consumer product categories  (CARB, 2017 b). 
 
The three regulations that set VOC limits for consumer products, by 2020, will reduce VOC emissions by about 50 percent compared to 1990 levels.  Also, limits on the use of 
ingredients with higher global warming potential (GWP) values in 18 consumer products 
categories will provide reductions of approximately 0.23 million metric tons of carbon 
dioxide equivalents (MMT CO
2e) per year  by 2020.   
 Exposure to toxic air contaminants (TAC) has also been reduced by prohibi ting use of 
certain compounds in 83 categories.  Total emissions of TACs have been reduced by 
over 13 tons per day  relative to 1990 levels .   
 In addition, the Alternative Control Plan (ACP) regulation was adopted in 1995 to 
provide compliance flexibility to companies.  The f our consumer product s regulations 
adopted by CARB are codified in title 17, California Code of Regulations, sections 94500 to 94575 as follows:  
 
• Antiperspirants and Deodorants (Article 1, sections 94500- 94506.5);  
• Consumer Products (Article 2, sections 94507 -94517);  
• Aerosol Coating Products (Article 3, sections 94520- 94528);  and 
• Alternative Control Plan (Article 4, sections 94540- 94555) .  
 Tables of MIR Values have also been adopted to implement the Aerosol Coating 
Products Regulation.  These values are codi fied in Subchapter 8.6, Article 1, sections 
94700 and 94701.  
 
3. Consumer Products and State Implementation Plan (SIP)  
 
Federal clean air laws require areas with unhealthy levels of ozone, carbon monoxide, 
nitrogen dioxide, sulfur dioxide and inhalable particulate matter to develop State 
Implementation Plans (SIP) describing how they will attain the national ambient air 
quality standards (NAAQS).   
 4 
 A SIP is a compilation of new and previously submitted plans, programs (such as 
monitoring, modeling, permitting, etc.), local air district rules, and State and federal 
regulations.  The Code of Federal Regulations (CFR) title 40, Chapter I, Part 52, 
Subpart F, section 52.220 sets forth all of the items which are included in the California SIP. 
 
Because VOCs  are ozone precursors, reducing VOC emissions has been necessary to 
work toward attainment of the ambient air quality standar ds for ozone.  In 1988, with the 
enactment  of the CCAA, the importance of controlling emissions from consumer 
products was set forth.  In 1994, emission reductions from consumer products became 
part of the SIP to meet the federal standard for ozone.   
 
The 2007 SIP, the State Strategy for California’s 2007 State Implementation Plan 
(CARB, 2007) , is California’s plan to attain the NAAQS for ozone of 0.08 parts per 
million (ppm) averaged over eight hours.  In the 2007 SIP, CARB  set a target to achieve 
an addi tional statewide VOC reduction of 30 to 40 tons per day from consumer products 
by January 1, 2014.  
 
With respect to the ozone standard, the U.S. EPA set a standard of 0.075 ppm in 2008.  
On April 30, 2012, U.S. EPA issued a final rule that directs key aspe cts of the 
implementation of this standard.   
 U.S. EPA has also issued a proposed rule that will guide implementation of the 2008  
8-hour ozone standard of 0.075 ppm and will address SIP deadlines and other 
implementation issues.  CARB  submit ted new SIPs for the 0.075 ppm ozone standard in 
2016.   The 2016 SIP  (CARB, 2017a)  contains a control measure for consumer products 
and a commitment to achieve an additional  10 tons per day of VOC emission reductions 
statewide by 2031.  CARB staff anticipates presenting the control measure for Board 
consideration in 2020.  
 
Up-to-date information on SIP activities can be found on C ARB’s website at: 
http://www.arb.ca.gov/planning/sip/sip.htm
. 
 
4. Consumer Products and the California Global Warming Solutions Act of 2006 (AB 32)  
 Various consumer products may contain GHGs in their formulations.  Most often, these GHGs are propellants such as hydrofluorocarbons or carbon dioxide (CO
2).  To a lesser 
extent so me GHGs are used as solvents.  A reduction of 0.23 MMT CO 2e has already 
been achieved from existing consumer product regulations .  We continue to evaluate 
whether GHG emission reductions from other consumer product categories are feasible.   
 
  5 
 5. National  Consumer Products Regulation  
 
On September 11, 1998, U.S. EPA promulgated a national consumer products 
regulation, the “National Volatile Organic Compound Emission Standards for Consumer 
Products” (40 CFR Part 59, Subpart C, sections 59.201 et seq.)  (U.S. EPA, 1998) . This 
action set national VOC emission standards for various categories of consumer 
products.  The regulation became effective on September 11, 1998, and the VOC limits 
became effective on December 10, 1998.  There are similarities and di fferences 
between the California and national consumer products regulations.  However, the 
national regulation does not preclude states from adopting more stringent regulations.  
 The national regulation does not regulate a number of product categories that  are 
currently regulated under the CARB  regulation.  Of the categories that are regulated 
under both regulations, many of C ARB’s limits are more stringent than the national 
limits.  Therefore, CARB ’s Consumer Products Regulation has achieved significant 
additional reductions over those that would be achieved by the national rule.   
 The U.S. EPA has also promulgated a national regulation for aerosol coatings : “National 
Volatile Organic Compound Emission Standards for Aerosol Coatings” (40 CFR Part 59, 
Subpart E, sections 59.500 et seq. ) (U.S. EPA, 2008) modeled on CARB ’s Aerosol 
Coating Products Regulation.  This is a reactivity -based regulation.  The N ational 
Aerosol Coatings Regulation was promulgated on March 24, 2008, with a compliance 
date of July  1, 2009.   
 CARB ’s regulation is more effective because it applies to all products sold, supplied, or 
offered for sale in California.  U.S. EPA’s rule exempts from compliance manufacturers 
whose national sales are less than 7,500 kg (16,500 pounds) per year.  CARB ’s 
regulation also applies to commercial application of aerosol coatings.  Additionally, the 
reactivity limits for most of aerosol coating product  categories were lowered further in 
2013.   
 The national regulations for consumer products and aerosol coatings do not prohibit the 
use of certain TACs.  To date, the California Consumer Products Regulation and the 
Aerosol Coating Products Regulation include prohibitions on the use of certain TACs in 
83 categories, resulting in a reduction of toxic compound em issions of over 13 tons per 
day. 
 
C. Regulatory History  
 This section summarizes the history of CARB’s  regulation of consumer products with 
emphasis on the categor y that is the subject of this rulemaking.   
 
  6 
 1. Consumer Products Regulation  
 
CARB’s r egulation of consumer products began in 1989 with adoption of the 
Antiperspirants and Deodorants Regulation.  The “general” Consumer Products Regulation was approved for adoption in 1990 and has been amended numerous times.   
 
Multi -purpose Lubricant products were first regulated in California under “Midterm 
Measures I” of the Consumer Products Regulation approved in July of 1997, and a description of these products is also included in the staff report for that rulemaking 
(CARB , 1997).  At that time, the Bo ard adopted a 50 percent by weight VOC limit for 
these products , which became effective on January 1, 2003.  In 2008, the Board 
approved for adoption a 25  percent  VOC limit and a 10 percent VOC limit that were to 
become effective i n 2013 and 2015,  respecti vely.  The most recent amendments to the 
Consumer Products Regulation were approved for adoption on September 26, 2013.  These amendments extended the compliance date for the  10 percent VOC limit for MPL 
products from December 31 , 2015,  to December  31, 2018, to address commercial and 
technological feasibility .   
 2. Method 310  
 Air Resources Board Method 310, Determination of Volatile Organic Compounds (VOC) in Consumer Products and Reactive Organic Compounds (ROC) in Aerosol Coating Products (Method 310), was first adopted in 1997 and has been amended several times.  This method  sets forth a process to develop analytical methods and standard 
operating procedures to determine compliance with various regulatory provisions . 
 
II. THE PROBLEM THAT THE PROPOSAL IS INTENDED TO ADDRESS  
 
In this chapter , we describe the problem and issues that the proposed amendments are 
intended to address.  
 
A. Description of Public Problem Proposal is Intended to Address  
 
The majority of California residents continue to be exposed to pollutant concentrations 
that exceed health- based ambient air quality standards for ozone and particulate matter.  
Volatile organic compound emissions from consumer products are known to contribute 
to the formation of ground- level ozone and particulate matter.  Despite developing 
regulations that have to date reduced consumer product VOC emissions by over 209 
tons per day, it is estimated that current VOC emissions are still approximately 204 tons 
per day .  This represents about 13 percent of the overall statewide VOC inventory  in 
2018.  Moreover, as California’s population grows, an increase in consumer product 
emissions to approximately 231 tons per day statewide in 2031 is expected if no further 
action is taken.  
 
  7 
 1. Problems Identified with the Provisions for MPLs  
 
Reformulating MPL products to meet the future effective 10 percent by weight VOC limit 
continues to prove challenging to manufacturers .  In some cases, m eeting a 10 percent 
by weight VOC limit may result in products with reduced efficacy and may  result in  
additional costs to  manufacturers . 
 
In 2008, CARB  approved amendments to the Consumer Products Regulation reducing 
the VOC limit for MPL products from 50 percent by weight and establishing two 
technology -forcing limits: a 25 percent by weight VOC limit effective 
December  31, 2013, and a 10 percent by weight VOC limit effective 
December  31, 2015.  Because the limits were technology forcing, staff conduct ed 
Technical Assessment s to determine feasibility of the VOC limits prior to their 
implementation.   Solid or semisolid products (primarily greases) were not considered a 
significant source of VOC emissions and were excluded from the VOC limit . 
 
In 2012 , staff conducted a Technical Assessment for the 25 percent VOC limit.  Staff 
determined that while meet ing the 25 percent VOC limit was technologically feasible, it 
had proven challenging for manufacturers with reformulation requiring  more time and 
resources than anticipated  (CARB, 2012) .  As a result, in a 2013 rulemaking, the Board 
approved a three- year extension to the compliance date for the 10 percent VOC limit for 
MPL products from December 31, 2015 , to December  31, 2018, to allow manufacturers 
additional time to reformulate products to meet the 10 percent by weight VOC limit.  
 In 2017, staff conducted  the Technical Assessment for the 10 percent by weight VOC 
limit (CARB, 2017c).  The results o f the Technical Assessment indicated that th e  
10 percent VOC limit remained  a significant challenge to more than 90 percent of the 
MPL market (see Appendix C).  Staff concluded that additional flexibility could be 
provided to industry to comply while maintaining the ozone air quality benefits of the  
10 percent by weight VOC limit.   This could be achieved by setting a product weighted 
maximum incremental reactivit y (PWMIR) limit of 0.45 
g O 3/g product , and requiring that 
the products not exceed the current 25 percent by weight VOC limit.  
 
The sales weighted PWMIR of products meeting the 10 percent VOC limit and those 
that meet the current 25 percent VOC limit reported in the Technical Assessment  are 
shown in Table 1.   The sales weighted average PWMIR of current MPL products  
(excluding oils)  compliant with the 10 percent VOC limit is 0.49 g O 3/g product .  If that 
group is extended to include the MPL products com pliant with the current 25 percent 
VOC limit, the sales weighted average PWMIR is 0.44  g O 3/g product .  This analysis 
also shows that, on average,  the ozone air quality benefits of reformulation to meet the 
25 percent VOC limit are similar to those achieved, on average, from products 
reformulated to meet the 10 percent VOC limit.   
   
  8 
 Table 1 
Summary of Technical Assessment  of  
Multi -purpose Lubricant Product s (Excluding Oils)  
 
Multi -
purpose 
Lubricant 
VOC 
Range  Sales 
Weighted 
Average 
VOC  
Weight 
Percent  Sales 
Weighted 
Product 
Weighted 
MIR  Number of 
Reported 
MPL 
Formulas  Number of 
Companies 
Reporting 
MPLs  Percent of 
Reported 
MPL Market 
Represented  Group Mass 
(lbs/yr)  
0-10 0.6 0.49  37 10 6.3 257,958  
0-25 22.5 0.44  91 31 97.4 3,976,849  
0-50 23.2 0.44  97 35 100.0  4,084,590  
 
 III. SUMMARY OF THE SPECIFIC PURPOSE AND RATIONALE FOR  EACH 
ADOPTION, AMENDMENT, OR REPEAL  
 The proposed amendments  are needed to provide compliance flexibility to the regulated 
industry to meet the applicable requirements for MPL products .  The information in this 
chapter provides  a summary of the provisions and CARB staff’s determination that each 
provision proposed is: (1) reasonably necessary to carry out the purpose of the regulation; and (2) reasonably necessary to address the problem for which the amendments are proposed.  The proposed amendments to the Consumer Products 
Regulation and CARB Test Method 310 can be found in Appendices A and B, 
respectively.  
 Amendments are being proposed to the following sections in the Consumer Products Regulation:  section 94509,  “Standards for Consumer Products ;” section 94513,  
“Reporting Requirements ;” and section 94515,  “Test Methods.”  
 
A. Proposed Amendments to the Consumer Products Regulation  
 
Summary of Section 94509(a)  
 CARB staff is  proposing to amend the Table of Standards contained in section 94509(a) 
as well as several other requirements in section 94509.  These proposals  are described 
below.  
 Staff is proposing to amend section 94509(a) of the Consumer Products Regulation to add the alternate compliance option for meeting the 10 percent by weight VOC limit for MPL products.  The purpose of this amendment is to provide com pliance flexibility by 
allowing manufacturers the option to comply using a reactivity -based approach.  
Products subject to the proposed alternate compliance option would be required to meet the currently applicable 25  percent by weight VOC limit and  a reac tivity limit of  
0.45 
g O 3/g product . 9 
  
Staff is also proposing to extend the 10 percent by weight VOC limit effective date from 
Decem ber 31, 2018, to July 1, 2019, to provide Responsible Parties adequate time to 
evaluate their products and decide whether to  comply with the 10 percent by weight 
VOC limit  or use the alternate compliance option.  
 
Rationale for Section 94509(a)  
 
This change is necessary because after many years of working to reformulate MPL products only a relatively  small percentage of the market is meeting the upcoming  
10 percent by weight VOC limit.  The Multi -purpose Lubricant Products Technical 
Assessment of the feasibility of meeting the 10 percent by weight VOC limit by the 
compliance date of  December 31, 2018 , found that the proposed l imit was still proving 
to be a challenge for industry  (Appendix C) .  Additionally, review of the reactivity for 
ingredients used to replace VOCs in MPL products found that some product formulas that met the 10 percent by weight VOC limit had higher potenti al to form ozone than 
some products at the 25 percent by weight VOC limit.   
 The proposed reactivity limit may not necessarily require reductions in total VOC  
content, but likely will require lower reactivity  ingredients  be used to reduce the ozone 
formed from products  choosing the alternate compliance option.  By allowing products 
comply via the alternate compliance option to reduce their overall reactivity, rather than total mass of VOCs, the proposed reactivity limit provides equivalent air quality benefit s 
to the future effective 10 percent by weight mass -based VOC limit, and provide more 
reformulation options at potentially less cost.   
 Staff determined that it is necessary to extend the effective date of the limit in the Table 
of Standards to allow manufacturers adequate time to evaluate their products to determine whether to comply by meeting the 10 percent by weight VOC limit or use the alternate compliance option.  The six month extension provides manufacturers the 
additional necessary time to reformulate products to comply with the 10 percent by 
weight VOC limit or the reactivity limit.  
 
Summary of Section 94509(n)  
 Staff is proposing to amend section 94509(n) to add Multi -purpose Lubricant to Table 
94509(n)(1).  This addition will prohibit use of compounds with Global Warming Potential (GWP) values of 150 or greater in the MPL  product category.   
 
Rationale for Section 94509(n)  
 While high GWP compounds currently are not used in MPL formulations, certain high 
GWP chemicals could be used in reformulated MPL products.  This provision is 
proposed as a mitigation measure against future use of  compounds with GWP values at 
or above 150.  
 10 
 Staff is proposing to add new subsection (r) to section 94509 , including subparts (1), 
(2), (3), (4), and (5).   Section 94509(r)(1) defines the terms specific to the sections being 
added.   
 
Summary of Section 94509(r)(1)(A)  
 
Staff is proposing to define “Base Reactive Organic Gas  Mixture (Base ROG Mixture)” 
as the mixture of reactive organic gases utilized in deriving the maximum incremental 
reactivity scale.  
 
Rationale for Section 94509(r)(1)(A)  
 This definition is being proposed to address the situation  where a MIR value is not 
available for a chemical compound or mixture.  The MIR value for Base ROG Mixture would be the default  value used in such a case.  
 
Summary of Section 94509(r)(1)( B) 
 Staff is proposing to define “Chemical Compound” as  a molecule of definite chemical 
formula and chemical structure.  
 
Rationale for Section 94509(r)(1)(B)  
 The proposed reactivity limit requires that each chemical compound with an MIR value be used in determining the overall reactivity of MPL products.  Thus, it is necessary to define what a chemical compound is for the purposes of the proposed provision.  
 
Summary of Section 94509(r)(1)(C)  
 Staff is proposing to define “Chemical Mixture” as  a substance comprised of two or 
more chemical compounds.  
 
Rationale for Section 94509(r)(1)( C) 
 The proposed reactivity limit requires that each chemical mixture with an MIR value be used in determining the overall reactivity of MPL products.  Thus, it is necessary to define what a chemical mixture is for the purpose of the proposed provision.  
 
Summary of Section 94509(r)(1)(D)  
 Staff is proposing to define “Ingredient” as a chemical compound or a chemical mixture.  
   11 
 Rationale for Section 94509(r)(1)( D) 
 
The proposed definition of ingredient is needed because e ach ingredient in the 
formulation is required to be reported as part of the initial reporting of MPL products that would comply using the alternate compliance option.  
 
Summary of Section 94509(r)(1)( E) 
 Staff is proposing to define “Maximum Incremental Reactivity (MIR)” as the maximum 
change in weight of ozone formed by adding a compound to the Base ROG Mixture per weight of compound added, expressed to hundredths of a gram (g O
3/g ROC).  
 
Rationale for Section 94509(r)(1)( E) 
 The alternate compliance option sets a proposed reactivity limit to ensure that the air 
quality benefits of the upcoming 10 percent VOC limit are maintained.  The reactivity limit is based on the MIR scale.  Thus, we are proposing to define MIR consistent with the science -based definition of MIR .  
 
Summary of Section 94509(r)(1)( F) 
 Staff is proposing to define “Product Formulation” as  the weight fraction of all 
ingredients.  
 
Rationale for Section 94509(r)(1)( F) 
 The definition of product formulation is intended to clarify what will be used in determining a product ’s overall reactivity.  
 
Summary of Section 94509(r)(1)( G) 
 Staff is proposing to define "Production Records" to mean product formulation 
information disclosing the actual quantity of all ingredi ents used to manufacture a MPL 
product on the date of manufacture.  The definition also identifies various types of 
information that would be considered a production record.  
 
Rationale for Section 94509(r)(1)( G) 
 This definition is intended to provide clarity to manufacturers as to what information 
CARB will ac cept for MPL products selected for compliance verification.   The production 
records are intended to assist CARB staff in determining the compliance status of  MPL 
products.  
   12 
 Summary of Section 94509(r)(1)( H) 
 
Staff is proposing to define “Product -Weighted MIR (PWMIR)” to mean the sum of all 
weighted- MIR for all ingredients in a “Multi -purpose Lubricant” product.  The PWMIR is 
the total product reactivity expressed to hundredths of a gram of ozone formed per gram of product  (g O
3/g product), excluding container and packaging.  
 
Rationale for Section 94509(r)(1)( H) 
 The proposed definition of PWMIR is needed to determine the reactivity of MPL 
products that would comply using the alternate compliance option.  
 
Summary of Section 94509(r)(1)( I) 
 Staff is proposing to define “Reactive Organic Compound (ROC)” to mean any 
compound containing at least one atom of carbon and that has the potential, once emitted, to contribute to ozone formation in the troposphere.  
 
Rationale for Section 94509(r)(1)( I) 
 The definition of reactive organic compound is needed to ensure that all chemical compounds with the potential to form ozone are accounted for in calculating the PWMIR  
of MPL products . 
 
Summary  for Section 94509(r)( 2) 
 Section 94509(r)(2) specifies that, in order to qualify for the alternate compliance option, 
Responsible Parties will need to identify which products will be using this option.  The VOC content, not exceeding 25 percent by weight, has to be reported to CARB along 
with the product formulation.  Information that m anufacturers are required to report in 
section 94509(r)(2) must be received by CARB at least 90 days before the 10 percent 
by weight VOC limit comes into effect on July 1, 2019.  A fter July 1, 2019, VOC content 
(not exceeding 25 percent by weight ) and product formulation  must be received by 
CARB at least 30 days before a product , using the alternate compliance option , 
becomes available on the market.   This section also specifies that i f a product is not eligible for the alternate compliance 
option, it will be subject to the 10 percent by weight VOC limit.  To avoid hindering the 
effectiveness of any future VOC limits in related product categories, products making 
claims that would make them subject to the most restrictive VOC limit provision do  not 
qualify for the alternate compliance option.  Products subject to an Alternative Control Plan do not qualify  for th e alternate compliance option.  P roducts that exceed the  
0.45 g O
3/g product  reactivity  limit do not qualify for the alternate compliance option.  
   13 
 Rationale for Section 94509(r)( 2) 
 
Staff is proposing this section to have the Responsible Party provide information that 
would allow staff to track which products are complying using the proposed alternate compliance option.  The notification requirements will provide CARB staff the necessary information to monitor the effectiveness of the proposed provisions.  
 
Summary  for Section 94509(r)( 3) 
 Section 94509(r)(3) states the PWMIR limit for the alternate compliance option.  The 
proposed PWMIR limit is 0.45 
g O 3/g product  and a product must not exceed 25 percent 
by weight VOC.  
 
Rationale for Section 94509(r)( 3) 
 Section 94509 (r)(3) sets a reactivity limit and a VOC limit that would ensure that 
products under the compliance option would provide the same ozone air quality benefits 
as products that would comply with the 10 percent  by weight VOC limit . 
 
Summary  for Section 94509(r)( 4) 
 Section 94509(r)(4) provides  the equation that will be used to calculate the PWMIR for 
products using the alternate compliance option.  A ll ingredients present in the final 
formulation in an amount of  0.1 percent by weight or greater  must be included in the 
calculation of the PWMIR .  This section also states t hat MIR values set forth in 
Subchapter 8.6, Article 1, section 94700 or 94701,  dated October  2, 2010, and the MIR 
values specified in s ection 94509(r)(5) will be used for product ingredients until at least 
July 1, 2021.  
 
Rationale for Section 94509(r)( 4) 
 Section 94509 (r)(4) is intended to provide the methodology to be used to calculate the 
PWMIR of MPL products.  It also specifies the level at which an ingredient does not 
have to be counted in the calculation of PWMIR.   This section allows manufacturers of 
MPL products to ensure that their formulations of MPL products will comply with the 
reactivity limit.  
 
Summary  for Section 94509(r)( 5) 
 Section 94509(r)(5) assigns MIR values for specific ingredients.  I ngredients that are not 
given MIR values in section 94509(r)(5) are assigned MIR values as they appear in sections 94700 or 94701 of the Consumer Products Regulations.  This section also 
specifies criteria for ingredients not listed in eit her section 94700 or 94701.  
   14 
 Rationale for Section 945 09(r)(5) 
 
The purpose of section 94509(r)(5) is to provide the specific MIR values for ingredients 
in MPL products  to implement the new alternate compliance option.   By specifying 
which MIR values are to be used in calculating the PWMIR, this provision provides part of the framework necessary to implement the proposed alternate compliance option.  
 
Summary of Section 9 4513(c)  
 Staff is proposing to amend section 94513 by revising section 94513(c) .  Modification to 
section 94513(c) is proposed to clarify that any information submitted to CARB must contain a signed statement verifying that all information submitted is ac curate, true, and 
complete.  Modifications also clarify that all confidential information received by CARB will be handled in accordance with the confidentiality procedures specified in t itle 17, 
California Code of Regulations, sections 91000- 91022.  
 
Rationale for Section 94513(c)  
 This section is needed to provide Responsible Party accountability for the information 
provided to CARB to ensure that all information submitted is true, accurate, and complete.  The rationale for a dding clarifying language to section 94513(c) is to address 
the need for CARB to acquire complete and accurate information to ensure compliance with the regulatory requirements.  
 
Summary of Section 94513(h) (1) 
 Section 94513(h)(1) states that t he sales of product s using this option  will be required 
by CARB annually, and reports must be submitted by March 31 of each year.   The 
annual reporting would sunset on April 1, 2023.  
 
Rationale for Section 94513(h) (1) 
 Section 94513(h)(1) would require annual reporting i n order for staff  to evaluate the use 
and success of the alternate compliance option over time.  Staff proposes that this 
annual reporting requirement sunset on April 1, 2023.  Staff would use initial reporting of 
product formulation to ensure the reported product formula complies with the qualifying 
factors of the alternate compliance option.  Furthermore, staff would use annually 
reported product sales to determine the effect that the alternate compliance option has on the market.     15 
 Summary of Section 94513(h) (2) 
 
Section 94513(h)(2) sets forth various ingredient  reporting requirements for formulations 
of MPL products using the alternate compliance option.  Section 94513(h)(2) requires 
that certain formulation data be reported.  This section defines the types of ingredients to report and their concentrations.  
  
Rationale for Section 94513(h) (2) 
 Section 94513(h)(2) would ensure that CARB staff have accurate information regarding 
products that would comply via the alternate compliance option. . 
 
Summary of Section 94513(h )(3) 
 Section 94513(h)( 3) states that production records for products using this option must 
be kept by the Responsible Party.  CARB will have the option to obtain up to three years of these records upon request when a product is selected for compli ance verification.  
 
Rationale for Section 94513(h) (3) 
 Section 94513(h)(3) would state that u p to three years of production batch records are 
needed if a product is selected for compliance verification by CARB .  This would provide 
staff with adequate information to determine the VOC content and PWMIR of the 
products using this option.   Staff would use this and other information to verify 
compliance.  
 
Summary of Section 94513(h) (4) 
 Staff is proposing section 94513(h)( 4) to inform Responsible Parties that they must 
provide any other information necessary to determine the PWMIR of the MPL  product to 
be tested including the MIR value for each ingredient used to calculate the PWMIR of 
the product . 
 
Rationale for Section 94513(h) (4) 
 Section 94513(h)(4) woul d allow CARB access to all information needed to accurately 
calculate PWMIR and determine product compliance under the alternate compliance option.  
 
Summary of Section 94513(h) (5) 
 Section 94513(h)( 5) is proposed to specify that if a product is selected for compliance 
verification, the Responsible Party will have 25 working days to provide all requested information to CARB.  
 
Rationale for Section 94513(h) (5) 16 
  
Section 94513(h)(5) would require R esponsible Parties to report information to CARB 
within a reasonable amount of time so that staff could begin compliance determination.  
Staff believes the 25 working days is adequate time for Responsible Parties to provide the required information.  
 
Summary of Sectio n 94513(h) (6) 
 Staff is proposing s ection 94513(h) (6) to stipulate that information  provided by 
Responsible Parties to CARB  would be handled consistent with State law,  as specified 
in title 17, California Code of Regulations, sections 91000- 91022 . 
 
Rationa le for Section 94513(h) (6) 
 Section 94513(h)(6) would allow Responsible Parties to provide their product 
information to CARB knowing that the information is protected and treated appropriately.  
 
Summary of  Section 94515  
 Staff is proposing to amend section 94515 to c orrect a typographical error in section 
94515(a)(2) . 
 
Rationale for Section 94515(a) (2) 
 The purpose of this amendment is to correct a typographical error in the Regulation for Consumer Products to properly reflect text from Method 310, section 3.6.2.  The Regulation for Consumer Products  inadvertently stated a 5 percent distillation cut 
whereas  Method 310 states a 1 percent distillation cut will be used.  
 
Summary of Section 945 15(k)  
 Staff is proposing to add new subsection (k) to section 94515.  Section 94515 (k) 
specifies  the test methods for the alternate compliance option, wherein, section 
94515(k)(1) specifies that Method 310 will be used when testing products using this option.  
 
Rationale for Section 94515(k)  
 Method 310 is the most appropriate test method for the alternate compliance option.   
Method 310 is used to determine compliance with other Consumer Products Regulation provisions, including  the Aerosol Coatings Regulation for determining PWMIR values.  
This precedent made Method 310 the most appropriate option for determining the 
PWMIR of MPL  products using this option.  
  17 
 B. Proposed Amendments to Method 310  
 
Summary of Method 310, Section 1  
 
Staff proposes changes to Sections 1 of Method 310 to delete language that is no longer necessary from a previous version.  Staff also proposes to make grammatical and typographical changes, for consistency.  
 
Rationale for Method 310, Section 1  
 Method 310 sets forth the analytical procedures and processes used to determine the VOC content of consumer products.  Staff is proposing these minor corrections to Section 1 of Method 310 for clarity and consistency.   
 
Summary of Method 310, Section 2  
 Staff proposes changes to Sections 2 of Method 310 to delete language that is no 
longer necessary from a previous version.  Staff also proposes to make grammatical and typographical changes, for consistency.  
 Staff also proposes changes to Sections 2 of Met hod 310 to reflect the addition of 
reference methods .  These methods are: ASTM D6730- 01(2016) , Standard Test 
Method for Determination of Individual Components in Spark Ignition Engine Fuels by 100-Metre Capillary (with Precolumn) Hig h Resolution Gas Chromatography  (ASTM, 
2016a ); ASTM D4057 -12, Standard Practice for Manual Sampling of P etroleum and 
Petroleum Products  (ASTM, 2012); ASTM D4177- 16e1, Standard Practice for 
Autom atic Sampling of Petroleum and Petroleum Products, ( ASTM, 2016b ); ASTM 
D4626- 95(2015) , Standard Practice for Calculation of Gas Chromatographic Response 
Factors (ASTM, 2015); and  ASTM E203 -01, Standard Test Method for Water Using 
Volumetric Karl Fisher Titration  (ASTM, 2001).  
 
Rationale for Method 310, Section 2  
 Method 310 sets forth the analytical procedures and processes used to determine the VOC content of consumer products.  Staff is proposing minor corrections to Section 2 of  Method 310 for clarity and consistency.    Staff is also proposing to incorporate the reference methods listed above as section 
2.36, 2.37, 2.38, 2.39, and 2.40.  These methods are being added to determine compliance with the proposed reactivity -based option for MPL products.    
   18 
 Summary of Method 310, Section 3  
 
Staff proposes changes to Sections 3 of Method 310 to delete language that is no longer necessary from a previous version.  Staff also proposes to make grammatical and typographical changes, for consistency.  
 Staff also proposes changes to Sections 3 of Method 310 to reflect the addition of 
reference methods .  These methods are: ASTM D6730- 01(2016) , Standard Test 
Method for Determination of Individual Components in Spark Ignition Engine Fuels by 100-Metre Capillary (with Precolumn) Hig h Resolution Gas Chromatography  (ASTM, 
2016a ); ASTM D4057 -12, Standard Practice for Manual Sampling of P etroleum and 
Petroleum Products  (ASTM, 2012); ASTM D4177- 16e1, Standard Practice for 
Automatic Sampling of Petroleum and Petroleum Products, ( ASTM, 2016b ); ASTM 
D4626- 95(2015), Standard Practice for Calculation of Gas C hromatographic Response 
Factors (ASTM, 2015); and  ASTM E203 -01, Standard Test Method for Water Using 
Volumetric Karl Fisher Titration  (ASTM, 2001).  
 
Rationale for Method 310, Section 3  
 Method 310 sets forth the analytical procedures and processes used to determine the 
VOC content of consumer products.  Staff is proposing minor corrections to Section 3 of CARB Method 310 for clarity and consistency.   
 Staff is also proposing to incorporate the reference method citations  listed above as 
section 3.3.2 and 3.3.8.  These methods are being added to determine compliance with the proposed reactivity -based option for MPL products.       
 
Summary of Method 310, Section 4  
 Staff proposes changes to Sections 4 of Method 310 to delete language that is no longer necessary from a previous version.  Staff also proposes to make grammatical 
and typographical changes, for consistency.  
 Staff proposes modifying language to Section 4 of Method 310.   
 
Rationale for Method 310, Section 4  
 Method 310 sets forth the analyti cal procedures and processes used to determine the 
VOC content of consumer products.  Staff is proposing minor corrections to Method 310 for clarity and consistency.    Staff proposes modifications to the language in Section 4 of Method 310, which clarify the factors used in the VOC calculations.  
   19 
 Summary of Method 310, Section 5  
 
Staff proposes changes to Sections 5  of Method 310 to delete language that is no 
longer necessary from a previous version.  Staff also proposes to make grammatical and typographical changes, for consistency.  
 Staff also proposes changes to Sections 5 of Method 310 to reflect the addition of 
reference methods .  These methods are: ASTM D6730- 01(2016) , Standard Test 
Method for Determination of Individual Components in Spark Ignition  Engine Fuels by 
100-Metre Capillary (with Precolumn) Hig h Resolution Gas Chromatography  (ASTM, 
2016a ); ASTM D4057 -12, Standard Practice for Manual Sampling of P etroleum and 
Petroleum Products  (ASTM, 2012); ASTM D4177- 16e1, Standard Practice for 
Automatic Sampling of Petroleum and Petroleum Products, ( ASTM, 2016b ); ASTM 
D4626- 95(2015), Standard Practice for Calculation of Gas Chromatographic Response 
Factors (ASTM, 2015); and  ASTM E203 -01, Standard Test Method for Water Using 
Volumetric Karl Fisher Titratio n (ASTM, 2001)  
 
Rationale for Method 310, Section 5  
 Method 310 sets forth the analytical procedures and processes used to determine the VOC content of consumer products.  Staff is proposing minor corrections to Section 5 of  
Method 310 for clarity and consistency.    Staff is also proposing to incorporate the reference method citations  listed above as 
section 5.3.2 and 5.3.9.  These methods are being added to determine compliance with the proposed reactivity -based option for MPL products.   
  
Summary of Method 310, Section 6  
 Staff proposes changes to Sections 6 of Method 310 to delete language that is no longer necessary from a previous version, for consistency.   
Rationale for Method 310, Section 6  
 Method 310 sets forth the analytical procedures and processes used to determine the VOC content of consumer products.  Staff is proposing minor corrections to Section 6 of  Method 310 for clarity and consistency.    
Summary of Method 310, Section 7  
 Staff proposes changes to Sections 7 of Method 310 to make grammatical changes, for 
consistency.  
   20 
 Rationale for Method 310, Section 7  
 
Method 310 sets forth the analytical procedures and processes used to determine the VOC content of consumer products.  Staff is proposing minor corrections to Section 7 of CARB Method 310 for clarity and consistency.   
 
Summary of Me thod 310, Appendix A  
 Staff proposes changes to Appendix A of Method 310 to delete language that is no longer necessary from a previous version.  Staff also proposes to make grammatical 
and typographical changes, for consistency.  
 Staff also proposes to change the term “Tedlar Bag” to “Propellant Collection Bag”.  
 
Rationale for Method 310, Appendix A  
 Method 310 sets forth the analytical procedures and processes used to determine the VOC content of consumer products.  Staff is proposing minor corrections to Appendix A of Method 310 for clarity and consistency.   
 Staff proposes changing  the term “Tedlar Bag” to “Propellant C ollection Bag”  in 
Appendix A  of Method 310, to eliminate the use of a brand name in favor of existing 
laboratory terminology . 
 IV. BENEFITS ANTICIPATED FROM THE REGULATORY ACTION, INCLUDING THE BENEFITS OR GOALS PROVIDED IN THE AUTHORIZING STATUTE  
 The pro posed amendments would enable manufacturers of MPL  products to comply 
with the 10 percent by weight VOC limit by meeting a 25 percent by weight VOC limit 
and a 0.45 
g O 3/g product  reactivity limit .  The amendments would not force 
manufacturers to participate and only those manufacturers that determine it is in their best interest are expected to do so.  These manufacturers would avail themselves of the 
alternate compliance option to achieve compliance.  
 Analysis of the MPL data indicates that a significant number of formulations from several manufacturers already meet the 10 percent VOC limit.  The analysis also shows that these formulations constitute a small percentage of the market.  Staff’s review of the manufacturers’ efforts to reformulate MPL products to comply indicates that significant challenges remain in reformulating over 90 percent of the MPL market.   
CARB identifie d 26 multi -purpose lubricant manufacturers that have products that do 
not meet the upcoming 10 percent by weight VOC limit , four of which are located in 
California . 
 Therefore, staff has concluded that providing a reactivity -based alternate compliance 
option to meet a reactivity limit  while requiring that products also meet the curre nt 
25 percent by weight VOC limit would allow manufacturers additional flexibility to 21 
 formulate products while preserving the ozone air quality benefit s that would be 
achieved by the 10  percent mass- based VOC limit.  
 
Staff’s review of product reactivity re veals that, on a sales -weighted basis, the reactivity 
of MPL products meeting the 10 percent VOC limit closely matches that of product s 
meeting the 25  percent VOC limit.  In view of reactivity considerations, staff believes  
that the air quality benefits of  the 10 percent by weight VOC limit  are being achieved 
ahead of schedule.  
 In order to lock in these benefits while providing additional compliance flexibility to manufacturers, staff is proposing amendments to the Consumer Products Regulation to 
include the alternate compliance option.  
 
Staff is also proposing  a restriction to prevent the use of high GWP compounds in  
MPLs .  We expect this proposal to have overall beneficial impacts on climate change by 
preventing use of compounds with higher GWP values.  
 
In summary, the proposed alternate compliance option maintains the air quality benefits, provides compliance flexibility, and does not increase compliance costs.   No changes in  
public health and safety, and worker safety are expected as a result of this r ulemaking.  
 V. AIR QUALITY  
 The consumer products program has been and continues to be an important part of California’s overall efforts to reduce smog -forming VOCs, TACs, and GHGs that are 
emitted from the use of chemically formulated consumer products.  VOC emissions  
contribute to the formation of ground- level ozone and fine particulate pollution.  The 
consumer products regulation focuses on reducing emissions from consumer products as a ground- level ozone control strategy.  Staff estimates that the Cons umer Products 
program  has reduced VOC emissions from consumer products by about 50 percent 
since its inception.   While the ozone forming potential of consumer product emissions is 
less than some other source categories (for e.g., mobile sources), further r eductions in 
VOC emissions from consumer products and other VOC sources are needed if progress 
toward ozone and fine particulate attainment is to be achieved.  
 
The MPL product category is one of about 130 categories regulated  in the Consumer 
Products Regulation.  MPL products were first regulated under “Midterm Measures I” of 
the Consumer Products Regulation approved in July of 1997, and a description of these 
products is also included in the staff report for that rulemaking ( CARB, 1997).  At that 
time, the Board adopted a 50 percent by weight VOC limit for these products , which 
became effective on January 1, 2003.   Solid or semisolid products (primarily greases) 
were not considered a significant source of VOC emissions, and we re excluded from 
the VOC limit . 
 In 2008, CARB  approved amendments to the Consumer Products Regulation reducing 
the VOC limit for MPL products from 50 percent by weight VOC and establishing two 22 
 technology -forcing limits:  a 25 percent by weight VOC limit effective 
December  31, 2013, and a 10 percent by weight VOC limit effective 
December  31, 2015.  Because the limits were technology forcing, the regulation 
included a provision requiring staff to conduct a Technical Assessment to determine 
feasibility of th e VOC limits prior to their implementation  
 
In subsequent 2013 rulemaking, the Board approved a three- year extension for 
complying with the 10 percent by weight VOC limit for M PL products to 
December  31, 2018, to allow manufacturers additional time to reformulate products.  
The 2013  rulemaking also set a  March  31, 2017, deadline for Responsible Parties to 
report their reformulation and research and development efforts to meet the 10 percent 
by weight VOC limit to CARB for the Multi- purpose Lubricant Technic al Assessment.  
The purpose of the Technical Assessment was to determine the feasibility of the 
10 percent by weight VOC limit.  
 
Staff’s Technical Assessment determined that the 10 percent by weight VOC limit 
continues to prove challenging.  Industry provi ded information on reformulation efforts 
and research and development costs, including the most promising reformulations that had been achieved in the years lea ding up to the Technical A ssessment.  While MPL 
products on the market today meet the 25 percent by weight VOC limit, only about 8 
percent of the market meet s the future effective 10 percent by weight VOC limit.  The 
analysis indicated that the air quality benefits anticipated from the 10 percent reformulation have largely been met by the previous reformulation effort.  After conducting the Technical Assessment and taking all factors into consideration, staff determined additional reformulation flexibility should be given to manufacturers, while 
locking in the sought after air quality benefits already  achieved by the previous 
reformulation efforts.  
 Staff analyzed the PWMIR of product s reported in the Technical A ssessment.  The 
analysis show s that the range in product weighted reactiv ity for products meeting the 
10 percent VOC limit is similar to those  meeting the 25 percent VOC limit .  Staff 
concluded that formulation flexibility could be provided by allowing products to continue 
to have a VOC content not exceeding 25 percent but requir e those products have a 
reactivity level slightly lower than the sa les-weighted average reactivity for 10 percent 
compliant products.  While this proposal would result in higher VOC mass emissions, 
the composition of those emissions would be such that the ozone forming potential 
would be equal or less than the compliant 1 0 percent by weight VOC emissions . 
 
VI. ENVIRONMENTAL ANALYSIS  
 
A. Introduction 
 
This chapter provides an environmental analysis for the proposed amendments to the 
Consumer Products Regulation.  Based on CARB’s review, staff has determined that 
implementing t he proposed amendments would not result in any potentially significant 
adverse impacts on the environment.  This analysis provides the basis for reaching this 23 
 conclusion.  This section of the Staff Report also discusses environmental benefits 
expected from  implementing the proposed amendments to the consumer products 
regulation.  
 
B. Environmental Review Process  
 
CARB is the lead agency for the proposed amendments to the Consumer Products 
Regulation and has prepared this environmental analysis pursuant to its r egulatory 
program certified by the Secretary of the Natural Resources Agency (14 CCR 15251(d); 
17 CCR 60000- 60008).  In accordance with Public Resources Code section 21080.5 of 
the California Environmental Quality Act (CEQA), public agencies with certified  
regulatory programs are exempt from certain CEQA requirements, including but not 
limited to preparing environmental impact reports, negative declarations, and initial 
studies (14 CCR 15250).  CARB has prepared this environmental analysis (EA) to 
assess th e potential for significant adverse and beneficial environmental impacts 
associated with the proposed regulation, as required by CARB’s certified regulatory program ( 17 CCR 60005(b) ).  The resource areas from the CEQA Guidelines  
Environmental Checklist were used as a framework for assessing the potential for significant impacts ( 17 CCR 60005(b) ). 
 If comments received during the public review period raise significant environmental issues, staff will summarize and respond to the comments in the Final Statement of Reasons (FSOR) prepared for the proposed amendments.  The written responses to environmental comments will be approved prior to final action on the proposed amendments  (17 CCR 60007(a)).  If the proposed amendments  are adopted, a Notice 
of Decision will be posted on CARB’s website and filed with the Secretary of the Natural 
Resources Agency f or public inspection ( 17 CCR 60007(b) ). 
 
C. Prior Environmental Analysis  
 
The Consumer Products Regulation was first promulgated in 1990.  The regulation has 
been amended numerous times resulting in adoption of VOC limits for about 130 different categories.  In each rulemaking an environmental analysis was conducted to 
determine whether any adverse environmental impacts would result from the 
amendments.  Overall, these analyses determined that the amendments designed to reduce VOC emissions, along with mitigat ion measures, would have positiv e impacts on 
the environment.  
 
The VOC limit of 50 percent by weight for MPL products became effective in 2003.  In 
2008, the Board approved for adoption a 25% VOC limit and a 10 percent VOC limit that were to become effect ive in 2013 and 2015, respectively.  The environmental analyses 
conducted for the 2008 rulemaking did not identify any adverse impacts and determined 
that consumer product VOC emissions would continue to decline.   
 
 
 24 
  
D. Proposed Amendments to the Consumer P roducts Regulation  
 
Project Description  
 
In this proposed rulemaking, the proposed amendments establish an alternate compliance option for multi -purpose lubricant products to ensure that the air quality 
benefits of VOC emissions expected from meeting the upcoming 10 percent VOC limit 
are maintained while providing flexibility to the affected industry to continue to formulate 
effective products for consumers.  
 CARB staff is also proposing amendments to Test Method 310 to clarify and update 
reference method citations and dates, correct  gramma r for consistency, and include 
several additional reference methods .   Staff is also proposing to add reference 
methods to Method 310 that would facilitate the reactivity analysis for MPL products using the alternate compliance option.  
 As previously described in chapter II of this Staff Report, the proposed amendments include the following changes:   
• add the alternate compliance option for MPL products,  
• prohibits the use of high GWP chemicals in MPL products;  
• adds de finitions ;  
• establishes a reactivity limit for MPL products  adds reporting requirement 
for those manufacturers complying via the option;  and 
• requires recordkeeping . 
 
Methods of Compliance 
 The proposed amendments include provisions that establish an alternate compliance 
option for multi -purpose lubricants.  The amendments contain some provisions that are 
administrative in nature, as well as other provisions that are more extensive than administrative changes.  These are described in more detail below.  
 The regulation currently does not mandate annual reporting.  However, the proposed amendments  will require new annual reporting of sales for products complying under 
the alternate compliance option for the next 5 years .  Manufacturers are also required t o 
keep records of production for products complying through the alternate compliance option.  In order to be eligible to comply via the alternate compliance option the 
proposed amendments  require that certain information be provided to CARB within the 
timeframes outlined in the regulation.  
 To comply via the alternate compliance option, products  would be required to meet a 
reactivity limit of 0.45 grams ozone per gram product, and have a VOC content of 25 percent or less instead of meeting the 10 percent VO C limit .  Manufacturers complying 
under the alternate compliance option may be have to reformulate their products in 25 
 order to meet these requirements.  Staff believes that reformulation under the alternate 
compliance option would be more flexible because c hemicals have different reactivity 
values.  Thus, companies have more options when formulating to meet the reactivity 
limit. 
 
E. Environmental Impacts  
 
Beneficial Impacts  
 The proposed amendments provide an alternate way of complying with the upcoming 10 perc ent VOC limit.  By specifying a reactivity limit, the alternate compliance option 
ensures that the air quality benefits are maintained.  As discussed in Chapter V , VOC 
emissions react in the atmosphere to form ozone.  The reactivity limit defines the maximum ozone forming potential of products complying under the alternate compliance option.  The reactivity limit proposed is based on staff’s assessment of the ozone forming potential of the MPL products already meeting the 10 percent VOC limit.   
To ensure that the alternate compliance option maintains the expected ozone air quality benefits, staff is proposing a reactivity limit slightly lower than the sales -weighted 
average reactivity of the products meeting the 10 percent VOC limit.  Thus, while the mass emissions may be higher under the alternate compliance option, the air quality 
impact will not increase relative to the 10 percent VOC limit.  
 The proposal would also ensure that the use of compounds with GWP values of 150 or 
greater is prohibited in MP L products.  While high GWP compounds currently are not 
used in MPL formulations, certain high GWP chemicals could be used in reformulated MPL products.  This provision is proposed to ensure against future use of compounds with high GWP values, which is beneficial because it would prevent t he potential 
emissions of greenhouse gases from MPL products.  
 
Resource Areas with No Impacts  
 Staff received comments expressing concerns that the propos ed amendments  would 
allow for more hazardous and flammable MPL products.  Staff recognizes that MPL 
products are formulated with hydrocarbon solvents and other chemicals that are flammable and potentially hazardous.  However, staff believes that the proposal would not result in products with significantly increased flammability or hazard profiles  as 
discussed below.  
 To address these concerns, staff reviewed the formulations of the products meeting the 10 percent VOC limit and products that would meet the proposed alternate compliance 
option requirements of a PWMIR below 0.45 
g O 3/g product  and a VOC content not 
exceeding 25 percent.   Staff’s review indicates that these two groups of products are 
formulated using similar ingredients .  Table 2 shows the chemical compounds that 
collectively comprise more than 90 percent of the mass of products that comply  with the  
10 percent by weight VOC limit  and those that comprise over  90 percent of the mass of 
products that would comply with the propose d alternate compliance option.   Staff’s 26 
 review indic ates that these products are formulated using very similar ingredients.    
The main difference expected between 10 percent compliant product and product that 
would comply via  the alternate compliance option is the relative amounts of these 
chemicals.  
 
Table 2 
Comparison of Ingredient  
10 Percent VOC Compliant P roducts vs Alternate Compliance Option Products  
 
Chemical Name  Meet the 10 Percent 
VOC Limit  Meet the Alternate 
Complian ce Option  
Carbon dioxide  x x 
Grouped LVPs  x x 
Heavy Naphthenic Mineral Oil   
x 
Hydrocarbon Solvent, Bin #11  x x 
Hydrocarbon Solvent, Bin #16  x x 
Hydrocarbon Solvent, Bin #19  x  
Hydrocarbon Solvent, Bin #24  x  
Perfluoropolyether  x  
Water  x x 
White mineral oil  x  
 
 As shown in Table 2, h ydrocarbon solvents bin numbers 19 and 24 were not reported in 
the MPL products that would meet the alternate compliance option.  Hydrocarbon 
solvents are categorized into a system of  “bins” to estimate their reactivity  values .  
These bins are described by chemical types (such as  alkane and aromatic fractions ) 
and boiling point range . 
 Both, hydrocarbon solvents bins 19 and 24 meet the low vapor pressure- volatile organic 
compound ( LVP-VOC ) definition and are not counted toward the total product VOC 
content .  Aromatic compound content of hydrocarbon solvent bin number 19, from 2 to  
8 percent,  is higher than that of hydrocarbon solvents  bin numbers 11 and 16 (less than 
2 percent) , which were reported in the products compliant with the option.   Thus, the 
hydrocarbon solvent bin 19 reactivity value is slightly higher than the reactivity value for  
bin 16.  Hydrocarbon solvent bin number 24 contains  predominately aromatic 
compounds .  Its reactivity  value is significantly higher  than the values for bin 11 and bin 
16.  Therefore, the likelihood of either hydrocarbon solvent bin 19 or especially bin 24 
being used in products  that choose to comply via  the proposed alternate compliance 
option is low because they have relatively  high reactivity  values.  Therefore , the main 
difference expected is the relative quantities of these ingredients already in use 
because t he most likely course for reformulation is to substitute hydrocarbon solvents  
with lower reactivity values for those with higher reactivity values.  
 Because the alternate compliance option allows a higher VOC content, it is likely that chemicals that are VOCs would be present in higher amounts  (a 15 percent maximum 27 
 difference)  as compared to 10 percent products .  The composition of products meeting 
the 10 percent VOC limit and those meeting the alternate compliance option employ 
very similar chemistries.  As discussed a bove, hydrocarbon solvent bin 19 and bin 24 
were reported in the 10 percent compliant products.  These solvent have higher 
aromatic content than the hydrocarbon solvents used in the products compliant with the 
option.  In general, aromatic compounds tend t o have higher toxicity  as compared to 
alkanes .  Thus, s taff believes that the  difference in composition between 10 percent 
compliant products and those that would comply via the proposed option would not 
result in MPL products with significantly different hazard or flammability profiles.   
Therefore, staff concludes that there is no significant  potential for an adverse 
environmental impact to the hazards and hazardous materials resource area.  
 
In addition, CARB staff has reviewed the proposed regulatory amendments and 
concluded  that the amendments would not result in any significant or potentially 
significant adverse impacts on the environment because compliance with the proposed 
amendments would not result in any physical change to the existing environment.  The amendments establish an alternate compliance option that requires products to meet a 
reactivity limit of 0.45 g O
3/g product  and have no more than 25 percent by weight VOC , 
thus ensuring that the expected ozone air quality benefits are maintained.    
 It is recognized that different types of VOCs are emitted into the atmosphere from the 
use of MPL products.  VOCs  react at different rates and via different reaction 
mechanisms  to form ozone in the atmosphere.   Therefore, VOCs differ significantly in 
their effects on ozone formation.  These differences in effects on ozone formation are 
referred to as the ozone "reactivities" of the VOCs (Carter, 1994).  A more detailed 
discussion on the science of the photochemical reactivity of VOCs is presented in Chapter 2 of the staff report for the Aerosol Coatings Regulation (CARB, 2000).  To set 
the proposed reactivity limit, staff quantified the sales -weighted reactivity  of products 
complying with the mass -based 10 percent by weight VOC limit and calculated react ivity 
limit that would ensure an equivalent  ozone benefit .  While products complying under 
the alternate compliance option would have higher VOC content, because the proposed 
reactivity limit is designed to achieve slightly more ozone benefit than the products compliant with the 10 percent VOC limit, the proposed amendments ensure that the expected ozone air quality benefits claimed in the SIP are maintained.   The expected 
benefit of the 10 percent limit were part of a SIP revision submitted to the U.S. EPA .  
One of the goals of the proposed amendments is to ensure that those benefits are maintained.  
 
Further, compliance with the proposed amendments would not involve any activity that 
would involve or affect aesthetics, agricultural and forestry resources, a ir quality, 
biological resources, cultural resources, geology and soils, greenhouse gases, hydrology and water quality, land use planning, mineral resources, noise, population 
and housing, public services, recreation, or traffic and transportation because they 
would not require any action that could affect these resources.  Staff’s review of 
compositional data for both products meeting the 10 percent VOC limit and products that would meet the alternate compliance option, shows that their formulations are 28 
 similar.  Thus, staff believes that no new manufacturing facilities would need to be 
constructed, and it would not affect existing transportation methods or volumes for these 
products.  No discussion of alternatives or mitigation measures is necessary because no 
significant adverse environmental impacts were identified.  
 
VII. ENVIRONMENTAL JUSTICE   
 State law defines environmental justice as the fair treatment of people of all races, 
cultures, and incomes with respect to the development, adoption, implementati on, and 
enforcement of environmental laws, regulations, and policies ( Government  Code , 
section  65040.12, subdivision (c)) . CARB  is committed to making environmental justice 
an integral part of its activities. The Board approved its Environmental Justice Policies 
and Actions (Policies) on December 13, 2001, to establish a framework for incorporating 
environmental justice into C ARB's programs consistent wit h the directives of State law 
(CARB, 2001). These policies apply to all communities in California, but r ecognize that 
environmental justice issues have been raised more in the context of low -income and 
minority communities . 
 
Staff has determined that the amendments proposed in this rulemaking are consistent with our environmental justice policies.  Among the goals of the proposed amendments 
is to lower the ozone forming potential of MPL products , thereby improving air quality.  
Use of compounds with higher global warming potentials would also be prohibited in this  
product categor y. 
 Consumer products are cons idered area sources and, as such, their use is not focused 
in a particular area leading to a potential “hot spot.”  Generally, use of consumer 
products including MPL products  is fairly uniform across the state, tracking with human 
population , and their emi ssions are spread over the course of a day, rather than 
concentrated at a particular time of day.  For these reasons, we believe that reducing 
emissions from the use of multi- purpose lubricants  would benefit all Californians.  Staff 
does  not expect any com munities, especially those with low -income and minority 
populations, regardless of location, to be dispropor tionately  impacted by adoption of the 
proposed amendments.  
 VIII. ECONOMIC IMPACTS  ASSESSMENT  
 
A. Introduction 
 
This Chapter provides our analysis of the estimated economic and fiscal impacts 
associated with the implementation of the proposed alternate compliance option to the 10 percent VOC limit for MPL products , and the proposed GWP limit.  The proposed 
amendment s are designed to allow flexibility in meeting the requirements for MPL 
products .  The alternate compliance option would allow R esponsible Parties to choose 
whether to meet the upcoming 10 percent by weight limit or remain at the existing 25 
percent by wei ght VOC limit and also meet a reactivity limit of 0.45 
g O 3/g product .  In 
recent years, it has been recognized that when control strategies take into account 29 
 differences among VOCs and their effects on ozone formation, the use of less reactive 
VOCs in pro viding a cost -effective means to achieve ozone reductions is encouraged.  
 
While staff has quantified the economic impacts to the extent feasible, some projections are necessarily qualitative, and based on general observations and facts known about 
the mult i-purpose lubricant products sector.  This analysis, therefore, serves to provide 
a general picture of the economic impacts typical businesses subject to the proposed limits might encounter.  Individual companies may experience different impacts than 
projected.  
 
The alternate compliance option would allow additional reformulation flexibility, since as noted earlier, reformulating products to meet the 10 percent limit has proven 
challenging.  The alternate compliance option maintains the air quality benefits of the 
10 percent by weight VOC limit  while meeting the SIP commitments made for this 
category . 
 
B. Summary of Findings   
 
The proposed amendments allow, but do not require, R esponsible Parties to comply 
using the alternate compliance option.  However, for those that choose to comply via the alternate compliance option, there are reporting, recordkeeping, and in some cases reformulation costs.  
 CARB  staff identified 54 products  from 26 companies  that do not comply  with the 
upcoming  10 percent  by weight  VOC  limit.  These companies  could  choose the 
alternate compliance  option and would be affected  by the proposed  amendments,  four 
of which  are located in California.   Two of the California -based businesses are 
considered to be small  businesses  because  they are independent ly owned and 
operated and have  fewer  than 100 employees.   The four California  companies  have 
eight  products  that do not meet  the 10 percent  VOC  limit.  While  all 26 companies  could  
potentially  benefit  from the alternate compliance option,  the cost analysis  focus  only on 
the four California companies  because  the proposed amendments  are not expected to 
increase product  prices . 
 Table 3, presents staff’s assumption and data used to estimate the compliance cost.  In estimating the cost, staff used the average of the high and low cost estimates from the 2008 analysis.  
 
  30 
 Table 3 
Reformulation Costs for MPL Products * 
 
Annualized costs from 2008 ISOR   
 
  Low High Average   
Aerosol  $1,442.55  $12,911.98  $7,177.26  
Nonaerosol  $1,229.71  $6,290.45  $3,760.08  
Annualized cost (2017 dollars)    
Adjustment factor (convert 2007 dollars to 2018) 1.22  
Aerosol  $1,687.78  $15,107.01  $8,397.40  
Nonaerosol  $1,438.76  $7,359.83  $4,399.29  
* Assumes the reformulation cost to comply under the alternate compliance option is the 
same as to reformulate to comply with 10 percent VOC (2008 ISOR estimated cost of reformulating from 25% VOC to 10% VOC)  (CARB, 2008).  
 One way to estimate the potential change in cost to produce a product is to determine the change in raw materials cost.  The previous analysis conducted as part of the adoption of the 10 percent VOC limit indicates that reformulations from the current  
25 percent VOC limit to the future 10 percent VOC limit results in negligible raw material 
cost (net savings or no cost)  (CARB, 2008 ).  To the extent that the projected cost 
savings or increases are ultimately passed on to the consumer, the actual retail pric e of 
products after the proposed limits become effective may be higher or lower than suggested by this analysis.  
 Staff used the average reformulation cost for both the aerosol and nonaerosol products in estimating the compliance costs.  These cost are fro m the cost analysis conducted 
when the 10 percent limit was adopted (CARB, 2008) .  The costs were adjusted to 201 8 
dollars by multiplying them by a factor of 1.22  (BLS, 2018) .  To estimate the compliance 
cost for the four California companies, staff multiplied the annual average cost per 
product by the number of products and added the annual reporting cost when complying under the proposed option.  
 Staff estimates total compliance costs of $ 217,500  for the four California companies.  
Cost for the four  manufacturers to comply  with the 10 percent by weight VOC limit is  
estimated  to be about $266,880.  If the four companies choose to comply using the 
alternate compliance they would have a slight cost savings  of about $49,380 .  In 
summary, staff believes t hat companies would use the alternate compliance option even 
if there is a small cost increase because of the additional reformulation flexibility it 
provides.  
 Staff believes that the regulation cost methodologies are conservative, and are thus in most ca ses, overestimated.  There are several factors that contribute to the 
overestimation of costs.  The mid- range cost (used to determine the overall cost and 
cost effectiveness of the regulation) is the average of the estimated high and low cost scenarios.  T he low cost scenario assumes that companies would choose the lowest 
cost reformulation pathway, making minor adjustments to a product’s formulation, or 31 
 simply eliminating higher VOC products.  We believe that most manufacturers would 
choose the lowest cost  reformulation option.  For the high cost scenario, it is assumed 
that there is significant research and development, and new equipment is needed to 
reformulate the product.  We believe that few manufacturers would choose to take the 
high cost reformulation approach.  
 
In the 2008 economic analysis  (CARB, 2008) , staff assumed that it would be 
challenging and costly to comply with the VOC limits for multi-purpose lubricants.  Staff 
calculated the estimated costs of reformulation for each of the proposed tiers  (25 
percent VOC and 10 percent VOC) of the Multi -purpose Lubricant proposal.  
Additionally, cost estimates were performed for aerosol and non- aerosol products, 
respectively.  The analysis show ed that greater costs would be incurred during the first 
tier reformulation (50 to 25 percent VOC) than the second tier reformulation (25 to 10 
percent VOC) .  This is because of the assumption that significant high-end costs will be 
incurred in the first tier reformulation, but not all of these costs would necessarily be 
duplicated in the second tier reformulation.  If major plant modifications or new equipment purchases are needed to meet either tier of the VOC limits,  a manufacturer 
would likely choose to make these significant changes during one plant modification, rather than making significant changes more than once.  In fact, certain companies may choose to reformulate only once (i.e. reformulate to meet the second  tier VOC limit 
before 2013) .  Regardless of whether this assumption is correct, we believe that it is 
appropriate to assume that high-end reformulation costs will be incurred during either 
the first tier reformulation or the second tier reformulation, but  not both.  Either 
assumption, that higher costs would be incurred during a given tier relative to the other, would yield the same amount of total costs being incurred to meet both tiers.  
 
C. Economic Impacts Analysis on California Businesses, Consumers, and Employment  
 
Legal Requirements   
 Section 11346.2(b) and 11346.3(b) of the Government Code requires an economic impact analysis (EIA) for non- major regulations.  The EIA assess es the potential for 
adverse economic impacts on California business enterprises and individuals when 
proposing to adopt or amend any administrative regulation.  The assessment must include a consideration of the impact of the proposed regulation on California jobs; business expansion, elimination or creation; and the ability of California business to compete with similar businesses in other states.  
 Also, state agencies are required to estimate the cost or savings to any State or local 
agency and school district in accordance with instructions adopted by the Department of Finance.  The estimate shall include any nondiscretionary cost or savings to local 
agencies and the cost or savings in federal funding to the State.  
   32 
 Evidence Supporting Finding if No Significant Statewide Adverse Impact Directly 
Affecting Business  
 
As discussed in t he summary above, staff expects the proposed amendments will not 
result in a significant adverse economic impact on business .  The amendments would 
require reporting and recordkeeping for MPLs that will comply using the alternate compliance option.  These consist of a one- time reporting of formulation and product 
name (estimated to take 4 hours), annual reporting of sales (estimated to take 4 hours per year), and recordkeeping (estimated to take 52 hours per year).  Thus, reporting and recordkeeping is expected to take 60 hours in the first year and 56 hours in ongoing years.  A weighted wage of $74 for computing cost was estimated using Bureau of Labor Statistics data for 2014 for California (BLS, 2014).   Median wage values for 
individual job classifications that are typically responsible for reporting and implementing new requirements were combined into major functional bins (i.e., managerial, engineer, scientist/technicians).   These primary bins were multiplied by an adjustment factor 
of 1.67 (U.S. EPA, 20 10) to account for labor -related benefits and overhead.   The three 
adjusted bins were then averaged to compute an overall composite average loaded wage rate of $73.82 per hour.   Table 4 summarizes the primary data used to calculate 
the average wage rate us ed for the fiscal analysis; values in Table 4 are rounded for 
simplicity.  
  
Table 4  
Wage Rate Range in California  
  Base Wage 
($/hour)  Loaded 
Wage 
($/hour)  
Staff Avg 
Median  Avg 
Median  
Managerial  56 95 
Engineer  45 76 
Scientist & Technicians 
(combined)  31 51 
Average Wage  44 74 
 Assuming $74 dollars per hour, reporting and recordkeeping would cost each business $4,440 in the first year and $4,144 in ongoing years.  The hourly wage includes an estimate for overhead and benefits, and uses the methods of the 2016  amendments to 
the Regulation for the Mandatory Reporting of Greenhouse Gas E missions (CARB, 
2016) .  If all 4 California businesses opt to use the proposed alternate compliance 
option, the total statewide reporting and recordkeeping cost will be $84,064 over the 5 year lifetime of the regulation.  
 33 
 This does not consider an estimated $133,440 in cost -savings to business as a result of 
the proposed amendments.  Four MPL products that would require reformulation to 
meet the 10 percent by weight VOC lim it would no longer be required to reformulate 
under the proposed amendments.  Staff estimates the average one -time reformulation 
cost is $6,672 per MPL product per year ), resulting in a total cost -savings to business of 
$133,440 ($6,672x5 yearsx4 products) .  Staff used the average reformulation cost for 
aerosol and nonaerosol MPL products from Table VII-5, of the 2008 staff report (CARB , 
2008).  The average cost was adjusted to 2018 dollars by multiplying them by a factor of 1.22 from the Bureau of Labor St atistics Inflation Calculator (BLS , 2018).  Thus the net 
impact of the proposed amendments is a cost -savings to California businesses.  
 
Potential Impact on California Businesses  
 
We believe there would not be any noticeable impact on California businesses because the overall cost of the alternate compliance option is a potential modest cost relative to 
the 10 percent limit.  Further, we do not expect a noticeable change in employme nt; 
business creation, elimination or expansion; and business competitiveness in California.  
 
Return on Owners’ Equity  
 This portion of the economic impacts analysis is based on a comparison of the return on owners’ equity ( ROE ) for affected businesses be fore and after inclusion of the cost to 
comply with the proposed alternative.   Because the proposed amendments have a 
small cost savings in the compliance costs, there would be no impact on the ROE of a typical business.   Additionally, because the alternat e compliance option does not 
capture the potential benefit of increased formulation flexibility, companies would likely 
avail themselves of the alternate compliance option.  
 
Affected Businesses  
 Any business which manufactures or markets multi -purpose lubricant products in 
California subject to the proposed to the 10 percent VOC limit could be directly affected 
by this regulation.  Also potentially affected are businesses that  supply raw materials  or 
equipment to manufacturers or marketers, and those that distribute or sell multi -purpose 
lubricant products in California.  The focus of this analysis, however, will be on manufacturers, marketers, and distributors that are most affected by the proposed measure.  
 Based on the 2016 Technical Assessment Survey , 56 companies manufactured, 
marketed, or distributed MPL  products in 2016 (see Appendix C ).  These companies 
manufacture, market, and distribute a broad range of multi -purpose lubricant products.  
Of the companies manufacturing these products, four firms (mostly medium - or  
small- sized firms) are located in California.   These 56 companies fall primarily into North 
American Industry Classification System code (NAICS) 324191,  Lubricant 
Manufacturing.
 
 34 
 Typical California businesses could be affected by the proposed alternate compliance 
option to the extent that the implementation of this option would change their 
profitability.  As noted, because the proposed amendments would have a minor 
decrease in com pliance cost  for the four California companies , staff does not expect a  
noticeable change on companies’  profitability.  
 
Potential Impact on Business Creation, Elimination or Expansion 
 
The proposed measures would have no noticeable impact on the status of California 
businesses.  This is because the proposed alternate compliance option is similar to the costs that would be incurred to comply with the 10 percent limit, which are not expected to impose a significant impact  on the profitability of businesses in California.  There 
would be no impact on business creation, elimination or expansion (CARB, 2008) . 
 
Potential Impact on Business Competitiveness  
 The proposed alternate compliance option would have no significant impact  on the 
ability of California businesses to compete with businesses in other states.  Because the proposed alternate compliance option would apply to all businesses that manufacture or market MPL products regardless of their location, the staff’s proposal should not present any economic disadvantages  specific to California businesses.   
 
Potential Impact on California Consumers  
 The potential impact of the proposed alternate compliance option on consumers depends upon the ability of affected businesses to pass on the cost increases to consume rs.  Because there is a potential cost savings from the alternate compliance 
option, we do not expect a change in retail prices.  
 The proposed amendments could affect consumers adversely if they result in reduced performance attributes of the products.  However, this scenario is unlikely to occur.  Based on discussions with manufacturers, the alternate compliance option should enable manufacturers to maintain the performance of their products that currently meet the 25 percent by weight VOC limit . 
 
Potentia l Impact on California Employment  
 The proposed amendments are not expected to cause a noticeable change in California employment and payroll.  
 
D. Analysis of Potential Impacts to California State o r Local Agencies  
 Staff did not identify any Local or State agencies that would be directly impacted.  If 
Local and State agencies use MPL products, there would not be a noticeable impact because the price of these products is not expected to change due to the proposed amendments.    35 
  
CARB anticipates the need for one additional Air Pollution Specialist (APS) to assist in 
verification and analysis of laboratory samples in support of the proposed amendments.  
This position would develop reference methods, analyze samples, operate laboratory instruments, review and report results, train other laboratory staff on new methods, and 
perform program maintenance logistics (calibration, instrument maintenance, 
troubleshooting).  The APS position is anticipated to cost $165,000 in the 19/20 fiscal 
year, $164,000 in 20/21 fiscal  year, and $164,000 in the 21/22 fiscal year.   
 
IX. EVALUATION OF REGULATORY ALTERNATIVES  
 Government Code section 11346.2 , subdivision (b)(4) requires CARB  to consider and 
evaluate reasonable alternatives to the proposed regulatory action and provide reasons 
for rejecting those alternatives. This section discusses alternatives evaluated and 
provides reasons why these alternatives were not included in the pro posal.  As 
explained below, no alternative proposed was found to be less burdensome and equally effective in achieving the purposes of the regulation in a manner that  ensures full 
compliance with the authorizing law.  The Board has not identified any reasonable alternatives that would lessen any adverse impact on small business.   
 
Alternative One –  No Action  
 A “No Action” alternative would be to forgo adopting the proposed amendments, making no regulatory changes, thereby allowing the 10 percent by weight VOC limit to become effective on December 31, 2018.  The “No Action” alternative would risk eliminating some  companies  from the market place.  Consumers would be at risk of not having 
access to MPL products that are needed to perform essential, everyday lubricating functions.   As discussed in Chapter VI currently only about eight percent of the market 
meets the 10 percent VOC limit.  
 
Alternative Two –  Extend the Effective Date 
 As discussed in Chapter I , staff previously extended t he effective date from 
December  31, 2015, to December 31, 2018.  Results of the recent 2017 Technical 
Assessment show that for many applications , a viable formulation that addressed 
technological and commercial challenges had yet to emerge . Given that manufacturers  
demonstrated in the technical assessment that they  had been attempting to develop 
potential reformulation options since 2008, staff determined that a further extension would not be war ranted. 
 
Alternative Three –  Rescind the 10 Percent by Weight VOC Limit  
 Staff also e valuated the option to rescind the 10 percent by weight VOC limit and make 
the finding that the 10 percent by weight VOC limit is not technologically or commercially feasible.    This alternative was rejected because staff determined that the 
10 percent by  weight VOC limit is technically feasible .  This alternative could have 36 
 created an apparent  VOC emission reduction SIP shortfall of up to 1.27 tons per day 
statewide (0.5 tons per day in the South Coast air basin).  
 
Alternative Four –  Set a Reactivity Limit without a VOC Limit  
 
At the request of industry, staff has additionally evaluated the option to eliminate VOC limits in the multi- purpose lubricant category and implement only a reactivity limit.  This 
precedent has been set by the reactivity limit c urrently in place for the Aerosol Coatings 
product category. However, that limit was set in place because no further VOC reductions for that category were considered feasible.  At eight percent market 
compliance, staff cannot determine that the 10 percent by weight VOC limit for  MPL 
products is i nfeasible, though staff does acknowledge it is challenging.  Also, staff 
acknowledges the efforts and successes of those manufacturers whose products were able to be reformulated to meet the 10 percent by weight VOC  limit.  Furthermore, 
based on the results of the technical assessment, moving this category entirely to a 
reactivity limit  would even require some companies that reformulated to meet the 10 
percent limit to reformulate once again.  Staff has therefore rul ed out a reactivity only 
limit for this category.  
 
Small Business Alternative  
 The Board has not identified any reasonable alternatives that would lessen any adverse 
impact on small business.  
 
Performance Standards in Place of Prescriptive Standards  
 The proposed regulation does not mandate the use of specific technologies or 
equipment, or prescribe specific actions or procedures . 
 
Health and Safety Code section 57005 Major Regulation Alternatives  
 The proposed regulation will not result in a total economi c impact on state businesses  of 
more than $10 million in one or more years of implementation.  Therefore, this proposal is not  a major regulation as defined by  Health and Safety Code section 57005.  
 X. JUSTIFICATION FOR ADOPTION OF REGULATIONS DIFFERENT FR OM 
FEDERAL REGULATIONS CONTAINED IN THE CODE OF FEDERAL REGULATIONS   
 
A. National Consumer Products Regulation  
 On September 11, 1998, U.S. EPA promulgated a national consumer products regulation, the “National Volatile Organic Compound Emission Standards for  Consumer 
Products” (40 CFR Part 59, Subpart C, sections 59.201 et seq.).   This action set 
national VOC emission standards for various categories of consumer products.  The regulation became effective on September 11, 1998, and the VOC limits became 37 
 effective on December 10, 1998.  There are similarities and differences between the 
California and national consumer products regulations.  However, the national 
regulation does not preclude states from adopting more stringent regulations.  
 
The National Consumer Products Regulation is less effective than the California 
Consumer Products Regulation in reducing VOC emissions from consumer products. 
The national regulation does not regulate a number of product categories that are 
regulated under the CARB regulation , including MPL  products.  Therefore, CARB’s 
Consumer Products Regulation has achieved significant additional reductions over 
those that would be achieved by the national rule.  
 As of the date of this staff report, there are no national consumer products regulations 
related to reducing GHG emissions  or limiting the reactivity of ingredients formulated in 
MPL products.  
 
XI. PUBLIC PROCESS FOR DEVELOPMENT OF THE PROPOSED ACTION  
(PRE-REGULATORY INFORMATION)  
 Consistent with Government Code sections 11346 , subdivision (b),  and 11346.45, 
subdivision (a), and with the Board’s long -standing  practice , CARB  staff held public 
workshops and had other meetings with interested persons during the development of 
the proposed regulation.  These informal pre- rulemaking  discussions provided staff with 
useful information that was considered during development of the regulation that is now being proposed for formal public comment.  
 
Our process for development of these proposed amendments included a number of 
formal and informal opportunities for public participation.  Participation is open to any 
member of the public.   CARB has established an electronic list serve to disseminate 
information regarding the consumer products program , which includes over 4000 
subscribers.   Subscribers to the Consumer Products List Serve received emails alerting 
them of meetings and available materials for review  regarding this proposed 
rulemaking.  Staff posted relevant information to CARB’s public Consumer Products 
Program  website.  
 
On Dece mber 30, 2016, an email list serve notice was sent out announcing  that 
materials regarding the upcoming special reporting requirements (technical assessment) for MPL products  were posted to CARB’s website.  The special reporting 
requirements were for MPL products subject to the 10 percent by weight VOC limit that 
will become effective on December 31, 2018.   The MPL product data was due to CARB 
by March 31, 2017.  
 Results of staff’s technical assessment for Multi -purpose Lubricant products, including 
data an d proposals were discussed at a public workshop held on October 12, 2017.   
Fifty-six companies reported information on their reformulation efforts to meet the 
10 percent by weight VOC limit.  Product information collected in the technical 
assessment inclu ded formulation data, a summary of research and development costs 38 
 for each of those formulas, the MIR value of each ingredient in a formula, and a product 
label for all reported products.  More than 120 unique formulas were reported that were 
subject to the VOC limits.   
 
An additional public workshop was held on January 17, 2018, to discuss the proposed 
amendment to allow flexibility in meeting the 10 percent by weight VOC limit for M PL 
products .  Staff also discussed administrative changes proposed to Met hod 310.   
 
To solicit additional information and comments, staff held individual meetings and 
teleconferences with stakeholders.  At several of these meetings, industry representatives presented technical information related to the reformulation of produc ts 
and technological challenges faced by manufacturers.   
 
XII. REFERENCES  
 
1. ASTM E203 -01.  Standard Test Method for Water Using Volumetric Karl Fisher 
Titration.  October 10, 2001. (ASTM, 2001)  
 
2. ASTM D4057- 12.  Standard Practice for Manual Sampling of Petr oleum and 
Petroleum Products.  December 1, 2012. (ASTM, 2012)  
 
3. ASTM D4626- 95(2015).  Standard Practice for Calculation of Gas Chromatographic 
Response Factors.  April 1, 2015. (ASTM, 2015)  
 
4. ASTM D6730- 01(2016).  Standard Test Method for Determination of I ndividual 
Components in Spark Ignition Engine Fuels by 100- Metre Capillary (with Precolumn) 
High-Resolution Gas Chromatography.  April 1, 2016. (ASTM, 2016a)  
 
5. ASTM D4177- 16e1.  Standard Practice for Autom atic Sampling of Petroleum and 
Petroleum Product s.  October 1, 2016. (ASTM, 2016b)  
 
6. Bureau of Labor Statistics .  Occupational Employment Statistics – May 2014 State 
Occupational Employment and Wage Estimates California.  March 25, 2015.   
(BLS, 2014)  
 
7. Bureau of Labor Statistics .  CPI Inflation Calculator .  March 2, 2018:  
https://data.bls.gov/cgi -bin/cpicalc.pl?cost1=1&year1=200701&year2=20180
1.  
(BLS, 2018)  
 8. California Air Resources Board.  Initial Statement of Reasons f or Proposed 
Rulemaking - Proposed Amendments to the California Consumer Products 
Regulatio n.  June 1997. (CARB, 1997)  
 
9. California Air Resources Board.  Initial Statement of Reasons for the Proposed Amendments to the Regulation for Reducing Volatile Organic  Compound Emissions 
from Aerosol Coating Products and Proposed Tables of Maximum Incremental 39 
 Reactivity (MIR) Values and Proposed Amendments to Method 310, Determination 
of Volatile Organic Compounds in Consumer Products.  May 5, 2000. (CARB, 2000)  
 
10. Califo rnia Air Resources Board.  Policies and Actions for Environmental Justice.  
December 13, 2001: https://www.arb.ca.gov/ch/programs/ej/ejpolicies.pdf . 
(CARB, 2001)  
 
11. California Air Resources  Board.  Attachment A – Technical and Clarifying 
Modifications to April 26, 2007 Revised Draft Air Resources Board’s Proposed State 
Strategy for California’s 2007 Implementation Plan and May 7, 2007 Revised Draft 
Appendices A through G .  Released April 26,  2007.  Adopted by the California Air 
Resources Boar d on September 27, 2007. (CARB, 2007)  
 
12. California Air Resources Board.  Initial Statement of Reasons for Proposed 
Amendments to the California Consumer Products Regulation.  May 9, 2008. 
(CARB, 2008)  
 
13. California Air Resources Board.  Multi -purpose Lubricant and Penetrant Special 
Reporting Requirements for 2011 .  March 28 2012. ( CARB, 2012)  
 
14. California Air Resources Board.  Staff Report: Initial Statement of Reasons for 
Proposed Rulemaking -  Proposed Am endments to the Antiperspirants and 
Deodorants Regulation, the Consumer Products Regulation, the Aerosol Coating Products Regulation,  the Tables of MIR Values,  Test Method 310, and Proposed 
Repeal of the Hairspray Credit Program.   August 7, 2013.  (CARB, 20 13) 
 15. California Air Resources Board.  Staff Report: Initial Statement of Reasons f or 
Rulemaking - Proposed Amendments to the Regulation for the Mandatory Reporting 
of Greenhouse Gas Emissions .  July 19, 2016 (CARB, 2016)  
 16. California Air Resources Board.  Revised Proposed 2016 State Strategy for the State Implementation Plan.  March 7, 2017 (CARB , 2017a)  
 
17. California Air Resources Board.  The California Consumer P roducts Regulations.  
May 2017. ( CARB, 2017b)  
 
18. California Air Resources Board.  2016 Multi -Purpose Lubricant Products Technical 
Assessment and Attachment A - Preliminary Concept for an Alternate Compliance 
Option.  October 11, 2017.  (CARB, 2017c ) 
 
19. Carter W.P.L.  Development of Ozone Reactivity Scales for Volatile Organic Compounds.  Journal of th e Air & Waste Management Association, Volume 44, 881-
899. January 20, 1994.  (Carter, 1994)  
 
20. United States Environmental Protection Agency.   National Volatile Organic 
Compound Emission Standards for Consumer Products. (40 CFR Part 59).  Federal 40 
 Register: Se ptember 11, 1998. Volume 63. Number 176: 48819- 48847.   
(U.S. EPA, 1998)   
 
21. United States Environmental Protection Agency.  National Volatile Organic Compound Emission Standards for Aerosol Coatings  (40 CFR Part 59, Subpart E, 
sections 59.500 et seq.)   Federal Register: March 24, 2008. Volume 73, Number 57: 
15604- 15631  modeled on C ARB’s Aeroso l Coating Products Regulation.  
(U.S. EPA, 2008)  
 
22. United States Environmental Protection Agency.  Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas  Emissions Under Subpart W Final Rule 
(GHG Reporting) Final Report .  November 2010. (U.S. EPA, 2010)  
 
  41 
 XIII. APPENDICES  
 
Appendix A :  Proposed Amendments to the Consumer Products  Regulation  
 
Appendix B:  Proposed Amendments to Method 310 : Determination of Volatile 
Organic Compounds (VOC) in Consumer Products and Reactive 
Organic Compounds (ROC) in Aerosol Coatings  
 Appendix C:  2016 Technical Assessment for Multi -purpose Lubricants   
 
  
Appendix  A 
 
Proposed Amendments to the  
Consumer Products  Regulation 
 
       
Proposed Regulation Order  
           
  
State of California  
Air Resources Board  
            
Release Date April 3, 2018  
   
 
  
 
  
 
 
 
 
 
 
  
 
 
 
 
 
 
 
This Page Intentionally Left Blank  
  
1 
 Proposed  Regulation Order  
Proposed Amendments to the  Consumer Products  Regulation  
 
Note: Amendments are shown in underline to indicate additions and strikeout  to indicate 
deletions from the existing regulatory text. The symbol “*****” means that intervening 
text not proposed for amendment is not shown.  
 
Subchapter 8.5 . Consumer Products  
Amend title 17, California Code of Regulations, sections 94509 , 94513,  and 94515 
to read as follows:  
 Article 2. Consumer Products  
 *****  § 94509.      Standards for Consumer Products.  
 
(a) Except as provided in sections 94510 (Exemptions), 94511 (Innovative Products),  
94514 (Variances), and 94540 through 94555 (Alternative Control Plan), title 17, California Code of Regulations, no person shall  sell, supply, offer for sale, or 
manufacture for sale in California any consumer product which, at the time of sale or manufact ure, contains volatile organic compounds in excess of the limits 
specified in the following Table of Standards after the specified effective dates.  
 
Table of Standards  
Percent Volatile Organic  Compound by Weight  
 
 
Product Category  Effective  
Date 1 VOC  
Standard  2 
***** ***** ***** 
Gear, Chain, or Wire Lubricant**  
   aerosol  
------------------------------------------------------  
   nonaerosol  
------------------------------------------------------  
Multi -purpose Lubricant  
(excluding solid or  
semisolid products)# **   
12/31/2013  
--------------------------------  
12/31/2013  
--------------------------------  
1/1/2003  
12/31/2013  
12/31/2018  7/1/2019   
25 
---------------------------  
3 
---------------------------  
50 
25 
     10 ## 
***** ***** ***** 
 [**See subsection 94509(n) for additional requirements that apply to Anti -Seize 
Lubricant; Cutting or Tapping Oil; Gear, Chain, or Wire Lubricant;
 Multi-purpose 
Lubricant ; or and Rust Preventative or Rust Control Lubricant  products .] 
 *****  
2 
 [##See subsections 94509(r)(1) through 94509( r)(5) for an alternate compliance option 
that applies to  Multi -purpose Lubricant .] 
 
*****  
Table 94509(n)(1)  
Product Categories in which Use of Any Chemical Compound that has a Global  
Warming Potential (GWP) Value of 150 or Greater is Prohibited  
 
Product Category   
Effective Date  Sell-through  
Date  
***** ***** ***** 
Lubricant:  
***** 
• Gear, Chain, or Wire Lubricant  
• Multi -purpose Lubricant (excluding solid or 
semisolid products)  
*****  
***** 
12/31/2013  
7/1/2019  
*****  
***** 
12/31/2016  
7/1/2022  
***** 
***** ***** ***** 
 *****  
(r)     Alternate  compliance o ption for “ Multi -purpose Lubricant ” products . 
 
(1) For the purpose of subsection s 94509(r) , 94513(h),  and 94515(k) , the following 
definitions apply:  
 
(A) “Base Reactive Organic Gas Mixture (Base ROG Mixture) ” means the mixture of 
reactive organic gases utilized in deriving the maximum incremental reactivity  
scale.  
 
(B) “Chemical Compound” means a molecule of definite chemical  formula and 
chemical  structure.  
 
(C) “Chemical Mixture” means a subst ance comprised of two or more chemical 
compounds . 
 
(D) “Ingredient” means a chemical compound  or a chemical mixture . 
 
(E) “Maximum Incremental Reactivity (MIR)”  means the maximum change in weight 
of ozone formed by adding a compound to the Base ROG Mixture per weight of 
compound added, expr essed to hundredths of a gram   (g O 3/g ROC) . 
 
(F) “Product F ormulation” means the wei ght fraction of all i ngredients.  
  
3 
 (G) "Production Records" mean product formulation information disclosing the actual 
quantity of all i ngredients  used to manufacture a “ Multi -purpose Lubricant ” 
product on the date of manufacture.  Such records shall include:  
 
1. Batch production record with  the date of manufacture;  
 
2. Quality control records;  
 
3. Raw materials invoices and physical property data;  
 
4. Production equipment maintenance records;  
  
5. Records of the wei ght fraction of all i ngredients including  the hydrocarbon 
solvent bin number, as listed in section 94701, manufacturer  name, and trade 
name.   For ingredients not listed in sections 94700, 94701, or 94509(r)(5), 
each chemical compound in the mixture must be reported separately;  and 
  
6. Any l aboratory results of testing conducted at the ti me of manufacture to 
establish the VOC content and reactivity of the product . 
 
(H) “Product -Weighted MIR (PWMIR)”  means the sum of all weighted- MIR for all 
ingredients in a “Multi-purpose Lubricant ” product.  The PWMIR is the total 
product reactivity expressed to hundredths of a g ram of ozone formed per gram 
of product  (g O3/g product ), excluding container and packaging.  
 
(I) “Reactive Organic Compound (ROC)” means any compound containing at least 
one atom of carbon and that has the potential, once emitted, to contribute to 
ozone formation in t he troposphere.  
 
(J) “Reactivity Limit” means the maximum ozone forming potential of i ngredients 
(excluding container and packaging) allowed in a “ Multi-purpose Lubricant” 
product , expressed as the PWMIR.  
 
(2) “Multi -purpose Lubricant ” products  subject to the 10 percent by weight VOC 
standard in section 94509(a) may comply by meeting the provisions of this 
subsection.   “Multi -purpose Lubricant ” products subject to the most restrictive limit 
provisions in subsection 94512(a) are ineligible to comply using this subsection.  
“Multi -purpose Lubricant ” products subject to an Alternative Control Plan are 
ineligible to comply using this subsection.  
 
To qualify for this compliance option,  a Responsible Party  must meet the following 
criteria:  
 
(A) The Responsible Party  must identify the product(s) t hat will comply by meeting 
the Reactivity L imit specified in subsection 94509(r)( 3); 
  
4 
 (B) The Responsible Party  must declare the VOC content of the product(s) and the 
VOC content must not exceed 25 percent by weight ; and 
 
(C) The Responsible Party  must provide the Executive Officer with the formulation 
of the product(s) , as specified in subsection 94513(h) . 
 
(D) Until July 1, 2019, the Responsible Party  must provide to the Executive Officer  
the information required in subsection 94509(r)(2 )(A) through (2 )(C) at least 90 
calendar days  before the effective date of the 10 percent by weight VOC 
standard.   
 
(E) On or after July 1, 2019, the Responsible Party must provide to the Executive 
Officer  the information required in subsection 94509(r)(2)(A) through (2)(C) at 
least 30 calendar days before a  new product is made available on the market . 
 
(F) If any criteria of subsect ion 94509(r)(2) are not met, a product will not qualify for 
the alternate compliance option and will be  subject to the 10 percent by weight 
VOC standard specified in subsection 94509(a) for “ Multi -purpose Lubricant ” 
(excluding solid or  semisolid products ). 
 
(G) A Responsible Party using the alternate compliance option for a future product  
must meet the criteria in subsection 94509(r)(2).  
 
(3) “Multi -purpose Lubricant ” products complying under this sub section shall not 
exceed a Reactivity Limit of 0.45 g O 3/g product . 
 
(4) The PWMIR  shall be calculated according to the following equation:  
 
 Product -Weighted MIR = (Wtd -MIR) 1 + (Wtd -MIR) 2 +…+ (Wtd -MIR) n 
 
where:   
 
         MIR          =  ingredient MIR, as specified in subsection 94509(r)(5 ); 
 
         Wtd-MIR  =  MIR of each ingredient in a product multiplied by the weight  
        fraction of that ingredient;  and  
 
         1,2,3,...,n  =  each ingredient in the product up to the total n ingredients in the  
         product.   
 
To calculate the PWMIR of a “Multi -purpose Lubricant ,” the MIR values dated 
October 2, 2010, as set forth in Subchapter 8.6, Article 1, section 94700 or 94701, 
and the MIR values specified in subsection 94509(r)(5) must be used until at least 
July 1, 2021.  All ingredients present i n the formulation in an amount equal to or 
exceeding 0.1 percent by weight must  be used to calculate the PWMIR.  
 
(5) Assignment of Maximum Incremental Reactivity (MIR) Values .  
5 
  
The MIR values of product ingredients are assigned as follows:  
 
(A) Any ingredient whi ch does not contain at least one atom of carbon is assigned 
an MIR value of 0.0;  
 
(B) Carbon dioxide is assigned an  MIR value of 0.0;  
 
(C) Ingredients that are solid are assigned a n MIR value of 0.0;  
 
(D) For aliphatic hydrocarbon solvent “Alkane Mixed –  Minimally 90% C13 and 
higher carbon number ,” the MIR value of 0.60 g O 3/g ROC must be used to 
calculate the PWMIR;  and 
 
(E) For fragrance, as defined in section 94508(a)(54), present in a “ Multi -purpose 
Lubricant ” product, the MIR value for terpinolene, as listed in section 94700, 
must be used to calculate the PWMIR unless detailed fragrance ingredients 
information is available to determine the MIR value of the fragrance.  
 
(F) Any ingredient not covered under subsection s 94509(r) (5)(A), (5)(B), (5)(C), 
(5)(D), or (5)(E ) is assigned the MIR value for that ingredient  as set forth in 
section 94700 or 9470 1. 
 
(G) If a ROC is not listed in section 94700 but an isomer(s) of the ROC is listed, 
then the MIR value for the isomer must  be used.  If more than one isomer is 
listed, the lis ted MIR value for the isomer with the highest MIR value must  be 
used.  
 
(H) If a ROC or its isomer(s) is not listed in section 94700, the MIR value for Base 
ROG M ixture must  be used to determine the weighted MIR of t he ROC to 
calculate the PWMIR.  
 
(I) If a new ingredient is added to section 94700 or 94701, the MIR value for the 
new ingredient must be used instead of the value speci fied in subsection 
94509(r)(5)(G) or (5)(H ) to calculate the PWMIR after the effective date of the 
MIR value.  
 
NOTE:  Authority cited:  Sections 38500, 38501, 38510, 38560, 38560.5, 38562, 38580, 39600, 39601,  
39650, 39658, 39659, 39666 and 41712, Health and Safety Code.  Reference:  Sections 38505, 39002, 
39600,  39650, 39655, 39656, 39658, 39659, 39666, 40000 and 41712, Health and Safety Code.  
   
6 
 § 94513.      Reporting Requirements.  
 
***** (c) All information submitted by any person pursuant to section 94513 shall : be
 
handled in accordance with the procedures specified in Title 17, California Code of 
Regulations, Section 91000- 91022.  
 
(1) Be accompanied by a signed statement declaring under penalty of perjury that the 
information submitted is accurate, true, and complete;  and  
 
(2) Be handled in accordance with the procedures specified in Title 17, California 
Code of Regul ations, sections 91000- 91022.  
 *****  
(h)    Special reporting r equirements for “ Multi -purpose Lubricant ” products using the 
alternate compliance o ption specified  in subsection 94509(r) . 
 
(1) The Responsible Party must report annual sales to the Executive Officer no later 
than March 31.   The annual reporting requirement shall sunset on April  1, 2023.  
 
(2) Product formulation must be reported upon initial qualification to comply using 
94509(r).   Product formulation shall be reported in accordance with subsections 
94513(h)(2)(A) through (2)(G).  
 
(A) Any ingredient  listed in section 94700 must be reported if it is present in an 
amount greater than or equal to 0.1 percent by weight of the final “ Multi -
purpose Lubricant ” product formulation.  
 
(B) Any hydrocarbon solvent listed in section 94701 shall  be reported as an  
ingredient  if it is present in an amount greater than or equal to 0.1 percent by 
weight of the final “ Multi -purpose Lubricant ” product formulation.  The 
hydrocarbon solvent b in number,  manufacturer  name , and trade name must be 
specified.  
 
(C) Any ingredient  assigned an  MIR value in section 94509(r)(5)  shall be reported if 
it is present in an amount greater than or equal to 0.1 percent by weight of the 
final “Multi -purpose Lubricant” product  formulation.  
 
(D) For chemical mixtures  not listed in sections  94700, 94701 , or 94509(r)(5) each 
chemical compound in the mixture must be reported separately . 
 
(E) Propellant mixtures must be reported as separate chemical compounds . 
 
(F) If an MIR value other than t erpinolene is used for fragrance, the Responsible 
Party must provide the fragrance ingredients .  
  
7 
 (G) For the purpose of this subsection, a safety data sheet (SDS) does not 
constitute a pro duct’s formulation.  
 
(3) The Responsible Party will retain a minimum of three years of production records , 
as specified in subsection 94509(r)(1)(G) , and provide them to the Executive 
Officer upon request . 
 
(4) The Responsible Party shall provide a ny other information necessary to determine 
the PWMIR of the “ Multi -purpose Lubricant ” product to be tested including the 
MIR value for each ingredient used to calc ulate the PWMIR . 
 
(5) Upon written notification from the Executive Officer, the Responsible Party will 
have 25 working days from the date of mailing to provide to the Executive Officer 
production records to determine compliance for products complying using the 
alternate c omplianc e option in subsection 94509(r).  
 
(6) Treatment of Confidential Information.  
 
Information submitted by the Responsible Part y pursuant to subsection 94513(h) 
will be handled in accordance with the procedures specified in Title 17, California 
Code of Regulations, sections 91000- 91022.  
 
 
NOTE:  Authority cited:  Sections  39600, 39601, 41511 and 41712,  Health and Safety Code.  
Reference:  Sections 3900 2, 39600, 40000, 41511 and 41712, Health and Safety Code.  
 
§ 94515 .      Test Methods.  
 ***** 
3.6.2 LVP -VOC status of “compounds” or “mixtures.”   The Executive Officer 
will test a sample of the LVP -VOC used in the product formulation to 
determine the boiling  point for a compound or for a mixture.   If the 
boiling point exceeds 216
oC, the compound or mixture is an LVP -VOC. 
If the boiling point is less than 216oC, then the weight percent of the 
mixture which boils above 216oC is an LVP -VOC.  The Executive 
Office r will use the nearest 51 percent distillation cut that is greater than 
216oC as determined under 3.6.1 to determine the percentage of the 
mixture qualifying as an LVP -VOC.  
 *****     
8 
 (k)     Alternate compliance option  verification  for “Multi -purpose Lubricant ” products . 
 
(1) Testing of “ Multi -purpose Lubricant ” products subject to the provisions of 
subsection 94509(r) must  be performed by the procedures set forth in “Air 
Resources Board Method 310, Determination of Volatile Organic Compounds 
(VOC) in Consumer Products and Reactive Organic Compounds (ROC) in 
Aerosol Coating Products,” (Method 310) adopted September 25, 1997,  and as 
last amended on [INSERT DATE OF AMENDMENT]  which is incorporated herein 
by reference.  Only ingredients present in amount equal to or greater than 0.1 
percent by weight will be reported.  
 
NOTE:  Authority cited:  Sections 39600, 39601, 39607, 41511 and 41712, Health and Safety Code.  
Reference:  Sections 39002, 39600, 39607, 40000, 41511 and 41712, Health and Safety Code.  
 
  
Appendix B 
 
       
  
METHOD 310  
 
 
Determination  of Volatile Organic Compounds (VOC) in Consumer 
Products and Reactive Organic Compounds  (ROC)  in Aerosol 
Coating Products  
 
(Including Appendi x A) 
   
Adopted:  September 25, 1997  
Amended:  September 3, 1999  
Amended:  July 18, 2001  
Amended:  May 5, 2005  
Amended:  August 6, 2010  
Amended:  September 29, 2011  
Amended:   August 1, 2014  
Amended:  [INSERT DATE OF AMENDMENT]  
 Intentionally Blank Page   
1 
 [NOTE: Proposed are amendments  shown in bold/underline  and strikeout  
to indicate deletions from existing text.] 
 
 
PROPOSED AMENDMENTS TO METHOD 310, DETERMINATION OF 
VOLATILE ORGANIC COM POUNDS (VOC) IN CONSUMER 
PRODUCTS AND REACTIV E ORGANIC COMPOUNDS (ROC)  IN 
AEROSOL COATING PRODUCTS  
 
(Including Appendix A)  
 
1 APPLICABILITY  
 
1.1 This method (Method 310) applies to the determination of the percent by weight of: 
 
(1) volatile organic compounds (VOC) in consumer products, antiperspirant and  
deodorant products, as those terms are defined in Title 17, California Code of Regulations (CCR), Division 3, Chapter 1, Subchapter  8.5 (Consumer Products), 
commencing  with sections 94500 and 94508, and  
   
(2) low vapor pressure -volatile organic compounds (LVP -VOC) as that term is 
defined in section 94508(a) .
, and  
 1.2 This method ( Method 310 )
 applies to the determination of product weighted 
maximum incremental reactivity (PWMIR) of aerosol coating products, as that term is defined in Title 17, CCR, 
Consumer Products section 94521.  
 1.3 Method 310 determines the total volatile material in a product  and the presence 
of any compounds prohibited by  CARB regulations (“prohibited compounds”). 
Components of the product that do not meet the definition of a VOC or are exempted by  CARB regulations for a specific product category (“exempt 
compounds”) are subt racted from the total volatile material to determine the final 
VOC content for the product. Method 310 is also used to determine the percent by weight of the reactive organic compounds ( ROC)
s contained in aerosol 
coating products, for the purpose of determ ining compliance with the Regulation 
for Reducing the Ozone Formed from Aerosol Coating Product Emissions, Title 
17, CCR, sections 94520 to 94528 (the “Aerosol Coating Products Regulation”) . 
 
1.4 Method 310 does not apply to the determination of the composition or concentration of fragrance components in products.  
 
1.5 The term “Executive Officer” as used in this document means the Executive Officer of the Air Resources Board or his or her authorized representative.   
2 
  
2 REFERENCE TEST  METHODS  
 
Method 310 incorporates by reference the following ASTM International , (ASTM),  
National Institute for Occupational Safety and Health (NIOSH), and United States 
Environmental Protection Agency (US EPA) analytical test methods:  
 2.1 ASTM D2369- 01:
, Standard Test Method for Volatile Content of Coatings 
(January 10, 2001).  
 2.2 ASTM D1426- 98:
, Standard Test Methods for Ammonia Nitrogen in Water  
(December 10, 1998).  
 
2.3 ASTM D4017- 96a:, Standard Test Method for Water in Paints and Paint 
Materials by the Karl Fisher Titration Method (July 10, 1996).  
 
2.4 ASTM D3792- 99:, Standard Test Method for Water Content of Water -Reducible 
Paints Coatings by Direct Injection Into a Gas Chromatograph (May 10, 1999).  
 
2.5 ASTM D859- 00:, Standard Test Method for Silica in Water (determination of 
polymethylsiloxanes after digestion) (June 10, 2000).  
 
2.6 ASTM D3074- 94:, Standard Test Methods for Pressure in Metal Aerosol 
Containers (November 15, 1994) , with the modifications found in Appendix A to 
this Method 310.  
 
2.7 ASTM D3063- 94:, Standard Test Method s for Pressure in Glass Aerosol Bottles 
(November 15, 1994) , with the modifications found in Appendix A to this Method 
310. 
 
2.8 ASTM D3064- 97:, Standard Terminology Relating to Aerosol Products 
(September 10, 1997).  
 
2.9 NIOSH : Method 140 0, Alcoh ols I, (analysis of acetone and ethanol by gas 
chromatography).  NIOSH Manual of Analytical Methods, Volume 1 Fourth 
Edition, (August 1994).  
 
2.10 Gas Chromatography/Mass Spectrometry for Volatile Organics (analysis of 
exempt and prohibited compounds in the product by headspace/gas 
chromatography/mass spectrometry).  
 
2.10 US EPA Method 8240B, Revision 2,  September 1994, Revision 2, Final Update 
IIA to the Third Edition of the Test Methods for Evaluating Solid Waste, 
Physical/Chemical Methods, Volatile Organic Comp ounds by Gas 
Chromatography/Mass Spectrometry (GC/MS),  Test Methods for Evaluating 
Solid Waste, Volume 1 B, Chapter 4, Section 4.3.2: Laboratory Manual 
Physical/Chemical Methods,  EPA publication SW-846, September 1994 .  
3 
  
2.11 US EPA Method 8260B, Revision 2,  December 1996, Revision 2, Final Update 
III to the Third Edition of the Test Methods for Evaluating Solid Waste, 
Physical/Chemical Methods,  Volatile Organic Compounds by Gas 
Chromatography/Mass Spectrometry (GC/MS), Test Methods for Evaluating 
Solid Waste,  Volume 1 B, Chapter 4, Section 4.3.2: Laboratory Manual 
Physical/Chemical Methods, EPA publication SW -846, December 1996 . 
 
2.12 US EPA Reference Method 24, Determination of Volatile Matter Content, Water 
Content, Density, Volume Solids, and Weight Solids of Surface Coatings :, Title  
40 Code of Federal Regulations (CFR) Part 60, Appendix A, as it existed on 
September 11, 1995 (July 1, 1996) . 
 2.13 US EPA Reference 
Method 24A, Determination of Volatile Matter Content and 
Density of Printing Inks and Related Coatings :, Title 40 CFR Part 60, Appendix 
A, as it existed on July 1, 1994 (July 1, 1994) . 
 
2.14 US EPA Reference Method 18, Measurement of Gaseous Organic Compound 
Emissions by Gas Chromatography :, Title 40 CFR Part 60, Appendix A, as it 
existed on September 25, 1996 (July 1, 1996) . 
 
2.15 US EPA Method 300.7, March 1986.  Dissolved Sodium, Ammonium, Potassium,  
Magnesium,  and Calcium in Wet Deposition by Chemically Suppressed Ion 
Chromatography , EPA Report # 600/4- 86-024, (March 1, 1986) . 
 
2.16 ASTM D86 -01:, Standard Test Method s for Distillation of Petroleum Products at 
Atmospheric Pressure (August 10, 2001).  
 
2.17 ASTM D850- 00:, Standard Test Method s for Distillation of Industrial Aromatic 
Hydrocarbons and Related Materials (December 10, 2000).  
 
2.18 ASTM D1078- 01:, Standard Test Method s for Distillation Range of Volatile  
Organic  Liquids (June 10, 2001).  
 
2.19 ASTM D2879- 97:, Standard Test Method for Vapor Pres sure-
Temperature Vapor -Pressure -Temperature  Relationship and Initial 
Decomposition Temperature of Liquids by Isoteniscope (April 10, 1997).  
 
2.20 ASTM D2887- 01:, Standard Test Method for Boiling Range Distribution of 
Petroleum Fractions by Gas Chromatography (May 10, 2001).  
 
2.21 ASTM E1719 -97:, Standard Test Method for Vapor Pressure of Liquids by 
Ebulliometry (March 10, 1997).  
 
2.22 ASTM D3257- 06: , Standard Test Methods for Aromatics in Mineral Spirits by 
Gas Chromatography (April 1, 2006).  
  
4 
 2.23 ASTM D3606- 07: , Standard Test Method for Determination of Benzene and 
Toluene in Finished Motor and Aviation Gasoline by Gas Chromatography 
(Nov ember  1, 2007).  
 
2.24 ASTM D3710- 95(2004)  (Reapproved 2004): , Standard Test Method for Boiling 
Range Distribution of Gasoline and Gasoline Fractions by Gas Chromatography (November 1, 2004).  
 
2.25 ASTM D5443- 04: , Standard Test Method for Paraffin, Naphthene, and Aromatic 
Hydrocarbon Type Analysis in Petroleum Distillates Through 200oC200° C  by 
Multi -Dimensional Gas Chromatography (Nov ember . 1, 2004).  
 
2.26 ASTM D5580- 02(2007)  (Reapproved 2007): , Standard Test Method for 
Determination of Benzene, Toluene, Ethylbenzene, p/m -Xylene, o- Xylene, C9 
and Heavier Aromatics, and Total Aromatics in Finished Gasoline by Gas Chromatography (November 1, 2007).  
 
2.27 ASTM E1782 -08:, Standard Test Method for Determining Vapor Pressure by 
Thermal Analysis (March 1, 2008).  
 
2.28 US EPA Method 602 :, Purg eable Aromatics, Title 40 CFR 136 Appendix A, 
Method for Organic Chemical Analysis of Municipal and Industrial Wastewater (
July 1 , 2007 January 2008 ). 
 
2.29 US EPA Method 625 :, Base/Neutrals and Acids, Title 40 CFR 136 Appendix A, 
Method for Organic Chemical Analysis of Municipal and Industrial Wastewater (
July 1 , 2007 January 2008 ). 
 
2.30 US EPA SW-846 Method 8015B :, Revision 2, December 1996, Final Update III 
to the Third Edition of  the Test Methods for Evaluating Solid Waste, 
Physical/Chemical Methods,  Non-Halogenated Organics Using GC/FID , EPA 
publication SW -846(Rev 2, December 1996) . 
 
2.31 US EPA SW-846 Method 8020A : , Revision 1, September 1994, Final Update 
II to the Third Edition of  the Test Methods for Evaluating Solid Waste, 
Physical/Chemical Methods,  Aromatic Volatile Organics by Gas 
Chromatography , EPA publication SW -846 (Rev 1, September 1994) . 
 
2.32 US EPA SW-846 Method 8270D :, Revision 4, January 1998, Final Update IV 
to the Third Edition of the Test Methods for Evaluating Solid Waste, 
Physical/Chemical Methods,  Semivolatile Organic Compounds by Gas 
Chromatography / Mass Spectroscopy (GC/MS) , EPA publication SW -846 
(Rev . 4, January 1998) . 
 
2.33 ASTM D5381- 93(2009), : Standard Guide for X -Ray Fluorescence (XRF) 
Spectroscopy of Pigments and Extenders  (February 1, 2009)  (Reapproved 
2009) .  
5 
 2.34 ASTM D523- 08:, Standard Test Method for Specular Gloss (June 1, 2008).  
 
2.35 ASTM D1613- 06:, Standard Test Method for Acidity in Volatile S olvents and 
Chemical Intermediates Used in Paint, Varnish, Lacquer, and Related Products (April 1, 2006).  
 
2.36 ASTM D6730- 01(2016), Standard Test Method for Determination of 
Individual Components in Spark Ignition Engine Fuels by 100 -Metre 
Capillary (with Prec olumn) High- Resolution Gas Chromatography, ( April 1, 
2016).  
 
2.37 ASTM D4057- 12, Standard Practice for Manual Sampling of Petroleum and 
Petroleum Products, ( December 1, 2012) . 
 
2.38 ASTM D4177- 16e1, Standard Practice for Autom atic Sampling of Petroleum 
and Petroleum Products, ( October 1, 2016).  
 
2.39 ASTM D4626- 95(2015), Standard Practice for Calculation of Gas 
Chromatographic Response Factors, ( April 1, 2015).  
 
2.40 ASTM E203 -01, Standard Test Method for Water Using Volumetric Karl 
Fisher Titration, (October 10, 2001).  
 
3 CONSUMER PRODUCTS  TESTING TO DETERMINE VOC PROCEDURE  
 3.1 The t
esting begins when the Executive Officer selects a product  for analysis by 
Method 310.  The Executive Officer will maintain sample chain of custody throughout the selection and analytical process.  
 3.2 Initial Testing of Aerosol Products  
 
If the sample is an aerosol product, the aerosol propellant is separated from the non-propellant portion of the product by 
using ASTM D3074- 94 (as modified in 
Appendix A for metal aerosol container) or ASTM D3063- 94 (as modified in 
Appendix A for glass aerosol container).  The propellant portion is analyzed for exempt or prohibited compounds by using US EPA 
Reference Method 18.  The 
remaining non- propellant portion of the product is then analyzed as specified in 
section 3.3.  
 
3.3 Initial Testing of Non -Aerosol Products and the Non- Propellant Portion of Aerosol 
Products  
 
The non -aerosol product or non- propellant portion of an aerosol product is 
analyzed to determine the total volatile material present in the sample and to  
6 
 determine the presence of any exempt or prohibited compounds.  This analysis is 
conducted by performing the following tests:1 
 
3.3.1  Gravimetric analysis of samples to determine the weight percent of total volatile material, using US EPA Reference Method s 24/24A
, US EPA Method  
24A, ASTM D2369 -01. 
 3.3.2  Determination of sample water content.  For determination of water content either ASTM D4017 -96a (including ASTM E203 -01)
, or ASTM D3792 -99 
may be used, or results from both procedures may be averaged and that value reported.  
 
3.3.3  Determination of ammonium content using ASTM D1426- 98 or US EPA 
Method 300.7.  
 
3.3.4  Determination of ketones and alcohol content using NIOSH Method 1400.  
 
3.3.5  Analysis of exempt and prohibited compounds, if present (US EPA  Reference  
Method 18, US EPA Method 8240B, US EPA Method 8260B, ASTM D859- 00, 
NIOSH Method 1400).  Effective January 1, 2015, for non- aerosol “Multi -
purpose Solvent” and “Paint Thinner” products sold, supplied, offered for sale, 
or manufactured for sale in the South Coast Air Quality Management District, analysis of exempt and prohibited compounds shall include analysis for methyl esters with 17 or more carbon  atoms, if present.  
 
3.3.6  If LVP -VOC status is claimed or the analysis indicates the presence of an 
LVP- VOC component and the percent VOC is not in compliance, the 
Executive Officer will request formulation data as specified in Section 3. 45.2. 
 
3.3.7  For low level VO C content samples, direct determination using US EPA 
Reference Method 18, US EPA Method 8240B, US EPA Method 8260B, 
ASTM D859- 00, NIOSH Method 1400.  
 3.3.8  For aromatic  hydrocarbon
 compound content determination, US EPA 
Method 602, US EPA SW -846 Method 8020A, US  EPA Modified Method 
8015, US EPA Method 625, US EPA Method SW -846 Method 8270D, ASTM 
D5443- 04, ASTM D 3257- 06, ASTM D3710- 95, ASTM D3606 -07, ASTM 
D5580- 02, ASTM D6730- 01(2016), ASTM D4057- 12, ASTM D4177- 16e1, 
ASTM D4626- 95(2015) . 
 
                                            
1 Alternate test methods may be used, as provided in section 7.0.   
7 
 3.4 Prohibited Compounds  
 
If the sample is found to contain compounds prohibited by ARB regulations (i.e., 
ozone- depleting compounds) at concentrations equal to or exceeding 0.1 percent 
by weight, the Executive Officer will reanalyze the sample for confirmation.  
 
3.4 Initial Determination  of VOC Content  
 
The Executive Officer will determine the VOC content pursuant to sections 3.2 
and 3.3.  Only those components with concentrations equal to or greater than 0.1 
percent by weight will be reported.  
 3.4.1  Using the appropriate formula specified in section 4.0, the Executive Officer will make an initial determination of whether the product meets the applicable VOC standards specified in CARB regulations.  If initial results show that the 
product does not meet the applicable VOC standards, the Executi ve Officer 
may perform additional testing to confirm the initial results.  
 3.4.2  If the results obtained under section 3. 5
4.1 show that the product does not 
meet the applicable VOC standards, the Executive Officer will request the 
product manufacturer or respons ible party to supply product formulation data.  
The manufacturer or  responsible party shall supply the requested information.  
Information submitted to the CARB Executive Officer may be claimed as 
confidential; such information will be handled in accordanc e with the 
confidentiality procedures specified in Title 17, C CR, Division 3, Chapter 1, 
Subchapter 4 (Disclosure of Public Records) alifornia Code of Regulations , 
sections 91000 to 91022.  
 
3.4.3  If the information supplied by the  manufacturer or  responsible part y shows 
that the product does not meet the applicable VOC standards, then the Executive Officer will take appropriate enforcement action.  
 
3.4.4  If the  manufacturer or  responsible party fails to provide formulation data as 
specified in section 3. 45.2, the initia l determination of VOC content under this 
section 3. 45 shall determine if the product is in compliance with the applicable 
VOC standards.  This determination may be used to establish a violation of  
CARB regulations.  
 
3.5 Determination of the LVP -VOC status of compounds and mixtures.  This section 
does not apply to antiperspirants and deodorants or aerosol coating s products.  
Effective January 1, 2015, this section also does not apply to non -aerosol  “Multi -
purpose Solvent” and “Paint Thinner” products sold, supplied, offered for sale, or manufactured for sale in the South Coast Air Quality Management District . There 
is no LVP -VOC exemption for these products.   
 
3.5.1  Formulation data.  If the vapor pressure is unknown, the following ASTM methods may be used to determine the LVP -VOC status of compounds and  
8 
 mixtures: ASTM D86 -01 (August 10, 2001), ASTM D850- 00 (December 10, 
2000), ASTM D1078- 01 (June 10, 2001), ASTM D2879- 97 (April 10, 1997), 
ASTM D2887- 01 (May 10, 2001) , and ASTM E1719- 97 (March 10, 1997).  
 
3.5.2  LVP- VOC status of “compounds” or “mixtures.”  The Executive Officer will test 
a sample of the LVP -VOC used in the product formulation to determine the 
boiling point for a compound or for a mixture.  If the boiling point exceeds 
216oC, the compound or mixture is an LVP -VOC.  If the boiling point is less 
than 216oC, then the weight percent of the mixture which boils above 216oC is 
an LVP -VOC.  The Executive Officer will use the nearest 1 percent distillation 
cut that is greater than 216oC as determined under 3. 56.1 to determine the 
percentage of the mixture qualifying as an LVP -VOC.  
 
3.6 Final Determination of VOC Content  
 
If a product’s compliance status is not satisfactorily resolved under sections 3. 45 
and 3. 56, the Executive Officer will conduct further analyses and testing as 
necessary to verify the formulation data.  
 3.6.1  If the accuracy of the supplied formulation data is verified and the product sample is determined to meet the applicable VOC standards, then no enforcement action for violation of the VOC standards will be taken.  
 3.6.2  If the Executive Officer is unable to verify the accuracy of the supplied formulation data, then the Executive Officer will request the 
product 
manufacturer or responsible party to supply information to explain the 
discrepancy.  
 
3.6.3  If there exists a discrepancy that cannot be resolved between the results of Method 310 and the supplied formulation data, then the results of Method 310 shall take precedence over the supplied formulation data.  The results of 
Method 310 shall then determine if the product is in compliance with the applicable VOC standards, and may be used to establish a violation of  CARB 
regulations.  
 
4 CALCULATION OF VOC CONTENT  
 
This section specifies the procedure for determini ng the final VOC content of a 
product, which is reported as percent by weight of VOC.  Effective January 1, 2015, for non- aerosol “Multi -purpose Solvent” and “Paint Thinner” products sold, supplied, 
offered for sale, or manufactured for sale in the South C oast Air Quality 
Management District (SCAQMD) the final VOC content is reported as grams of VOC per liter of material (g/L) as set forth in section 4.2.4.  
 4.1 Aerosol Products  
  
9 
 4.1.1  For aerosol products, except those containing LVP -VOC, the percent VOC 
content shall be calculated using the following equation:  
 
 
Where2: 
 
WL = weight  in grams  (g), of a non- aerosol sample or  the non-
propellant portion  of an aerosol sample , excluding container 
and packaging.  
 
TV  = weight fraction of  non-propellant  total volatile material  in a non-
aerosol sample or in the non- propellant portion of an aerosol 
sample .  
 A  = weight fraction of ammonia (as NH
4) in a non- aerosol sample 
or in the non- propellant portion  of an aerosol sample .  
 H  = weight fraction of water in a non- aerosol sample or in  
the non-
propellant portion  of an aerosol sample . 
 EL  = weight fraction of exempt compound( s) in 
a non- aerosol sample 
or in the non- propellant portion  of an aerosol sample . 
 WP = weight (g) of propellant.  
 EP  = weight (g) of exempt compounds in propellant.  
 4.1.2  For aerosol products containing LVP -VOC, the percent VOC shall be calculated 
using the following equation:  
 
 
Where:  
 
LVP = weight fraction of LVP -VOC compounds and/or mixtures in the 
non-propellant, non- aqueous portion.  
 
                                            
2 Alternate test methods, as provided in section 7.0, or appropriate approved methods from 
section 2.0 may be used . 100WP WLEP WP)ELHA TV(WLVOC% ×+−+−−−=
) )(([ ] )(100WP WLEP WP EL LVP1 H1WLVOC% ×+−+−−×−= 
10 
 1 – H = weight fraction of the non- propellant portion that does not 
contain water.  
 
1 – LVP=  weight fraction of the non- propellant, non- aqueous portion that 
is volatile.  
 4.2 Non-Aerosol Products  
 4.2.1  For non- aerosol products, except those containing LVP -VOC, the percent VOC 
content shall be calculated using the following equation:  
 
 
4.2.2  For non- aerosol products containing LVP -VOC, the percent VOC shall be 
calculated using the following equation:  
 
 
4.2.3  For Fabric Softener –  Single Use Dryer Product, the grams of VOC per sheet 
shall be calculated as follows:  
 
 
 
Where:  
 
WS = weight (g) of single dryer sheet . 
in grams  
 
4.2.4  Effective January 1, 2015, f or non- aerosol “Multi -purpose Solvent” and “Paint 
Thinner” products sold, supplied, offered for sale, or manufactured for sale for 
use in the SCAQMD, grams of VOC per liter of material (g/L) shall be calculated using the following equation:  
 
 
Where:  
 WM = weight of the material in grams.   
 VM  = volume of the material in liters.  
 
TV  = weight fraction of total volatile material.  VMEL)H (TV WMVOCg/L−−×=100)ELHA TV( VOC% ×−−−=
)( )([ ]100 EL LVP1 H1 VOC% ×−−×−=
WS EL)HA (TV Sheetper VOC Grams Total ×−−−=
)( )([ ]WS EL LVP1 H1 LVP with Sheetper VOC Grams Total ×−−×−= 
11 
  
H  = weight fraction of water.  
 
EL  = weight fraction of exempt compounds  including the weight 
fraction of methyl esters with 17 or more carbon atoms in the total volatile material.   
 4.3 Consumer products subject to low VOC limits (below 5.0%) may have their VOC content characterized by a low level direct determination.  
 4.3.1  For aerosol products the percent VOC content may be calculated using the following equation:  
 
 
  
Where:  
 
V = weight fraction of non- exempted VOCs  in the non- propellant 
portion.  
 n = number of non- exempted VOCs  in the non- propellant portion.  
 
WL = weight (g) of the non- propellant portion, excluding container and 
packaging.  
 
WP = weight (g) of propellant.  
 
EP = weight (g) of exempt compounds in propellant.  
 
 4.3.2  For non- aerosol products the  percent VOC content shall be calculated using 
the following equation:  
 
[]100 V VOC%n× =∑  
 5 TESTING TO DETERMINE REACTIVE ORGANIC COMPOUNDS ( ROC
) IN 
AEROSOL COATING PRODUCTS  
 
This section specifies the procedure for determining the percent by weight of  the 
reactive organic compounds (ROC) contained in aerosol coating products, for the 
purpose of determining compliance with the Aerosol Coating Products 
Regulation.  
 5.1 The t
esting begins when the Executive Officer selects a product for analysis.  
The Executi ve Officer will maintain sample chain of custody throughout the []100WP WLEP WP V WLVOC%n×+−+=∑ 
12 
 selection and analytical process.  When a product is selected for testing, the 
Executive Officer will request the product manufacturer or responsible party to 
supply the product formulation data specified in Title 17, CCR, Consumer 
Products section 94526(b)(1).  The manufacturer or responsible party shall 
supply the requested information within 25 working days.  Information submitted to the Executive Officer may be claimed as confidential; such information will be 
handled in accordance with the confidentiality procedures specified in 
sections 
91000 to 91022, Title 17, CCR , Disclosure of Public Records  sections 91000 
to 91022 . 
 5.2 Initial Testing of the Propellant Portion of Aerosol Coating 
Products  
 
TIf the sample is an aerosol product, t he aerosol propellant is separated from 
the non- propellant portion of the product by using ASTM D3074- 94D 3074- 94 (as 
modified in Appendix A for metal aerosol container) or ASTM D3063 -94D 3063-
94 (as modified in App endix A for glass aerosol container).  The propellant 
portion is analyzed for ROC s and other compounds by using US EPA Reference 
Method 18.  The remaining non- propellant portion of the product is then analyzed 
as specified in section 5.3.  
 5.3 Initial Testing of Non-Aerosol Products or
 the Non- Propellant Portion of 
Aerosol Coating Products  
 
The non- aerosol product or non -propellant portion of the aerosol product 
sample is analyzed to determine the ROC s in the sample, including the presence 
of any prohibited compounds.  This analysis is conducted by performing the following tests:
3 
 5.3.1  Gravimetric analysis of samples to determine the weight percent of total volatile material, using US EPA  Reference Method s 24/24A
, US EPA Method  
24A, ASTM D2369- 01D 2369- 01. 
 5.3.2  Determination of sample water content.  For determination of water content either ASTM D4017- 96aD 4017- 96a (including ASTM E203 -01)
, or ASTM 
D3792- 99D 3792- 99 may be used, or results from both procedures may be 
averaged and that value reported.  
 
 
5.3.3  Determination of ammonium content using ASTM D1426- 98D 1426 -98 or US 
EPA Method 300.7.  
 
5.3.4  Determination of ketones and alcohol content using NIOSH Method 1400.  
 
                                            
3 Alternate test methods may be used, as provided in section 7.0.   
13 
 5.3.5  Direct determination of ROC s and, if present, prohibited compounds (US EPA  
Reference Method 18, US EPA Method 8240B, US EPA Method 8260B, 
ASTM D859- 00, NIOSH Method 1400, and modified ASTM D5443- 04). 
 
5.3.6  Determination of metal content using ASTM D5381- 93 (2009).  
 
5.3.7  Determination of specular gloss using ASTM D523- 08 (2008) . 
 
5.3.8  Determination of acid content using ASTM D1613- 06 (2006) . 
 
5.3.9  For hydrocarbon compound content determination using ASTM D6730-
01(2016), ASTM D4057- 12, ASTM D4177- 16e1, ASTM D4626- 95(2015).  
 
 
5.4 Prohibited Compounds  
 
If the sample is found to contain compounds prohibited by the Aerosol Coating 
Products Regulation (e.g., ozone- depleting compounds) at concentrations equal 
to or exceeding 0.1 percent by weight, the Executive Officer will reanalyze the 
sample f or confirmation.  
 
5.4 Initial Determination and Verification of ROC Content  
 
The Executive Officer will determine the ROC content by verifying formulation data pursuant to sections 5.2 and 5.3.  Only those components with 
concentrations equal to or greater than 0.1 percent by weight will be reported.  
 5.4.1  Based on manufacturer’s 
formulation data and the analysis conducted under 
section 5, the Executive Officer will make an initial determination of whether the product meets the applicable requirements specified i n CARB 
regulations the Aerosol Coating Products Regulation .  If initial results show 
that the product does not meet the applicable requirements, the Executive Officer may perform additional testing to confirm the initial results.  
 5.5 Final Determination of ROC  Content  
 
If a product’s status is not satisfactorily resolved under section 5.1 -  5.45
, the 
Executive Officer may conduct additional analyses and testing as necessary to verify the formulation data.  
 5.5.1  If the Executive Officer is unable to verify the accuracy of the supplied formulation data, then the Executive Officer will request the 
product 
manufacturer or responsible party to supply additional information to explain 
the discrepancy.  
 5.5.2  If the additional information supplied by the manufacturer or 
responsible party 
shows that the product does not meet the applicable requirements, then the Executive Officer will take appropriate enforcement action.   
14 
  
5.5.3  If the manufacturer or responsible party fails to provide additional information 
as specified in section 5. 56.1, the initial determination of ROC content under 
section 5.1 – 5.45 shall determine if the product is in compliance with the 
applicable reactivity limits.  This determination may be used to establish a 
violation of  CARB regulations the Aerosol Coating Products Regulation . 
 
5.5.4  If there exists a discrepancy that cannot be resolved between the results of Method 310 and the formulation data or additional information supplied by the manufacturer or 
responsible party, then the results of Method 310 shall take 
precedence over the supplied formulation data or additional information.  The results of Method 310 shall then determine if the product is in compliance with the applicable requirements, and may be used to establish a violation of  
CARB 
regulations the Aerosol Co ating Products Regulation . 
 
6 METHOD PRECISION AND ACCURACY  
 6.1 The precision of Method 310 for determining VOC content was evaluated using seven representative products with known volatile organic compound ( VOC
) 
contents ranging from 6.2 to 81.2 percent VOC by  weight.  Each sample was  
divided into six portions, and each portion was separately analyzed to determine the VOC content.  Based on the results of this analysis, the 95 percent confidence interval for Method 310 is 3.0 percent by weight  (Wt/Wt%)
. 
 6.2 For determining the percent by weight of the individual ingredients in aerosol coating products, the precision and accuracy of the determination for each ingredient is governed by the precision and accuracy of the test method used to ascertain the percent by wei ght of each ingredient.   
 7 ALTERNATE TEST METHODS  
 
Alternative test methods which are shown to accurately determine the concentration of VOC s or constituent 
components in antiperspirant/deodorants, consumer 
products, or aerosol coating products (or their emissions) may be used upon written approval of the Executive Officer.  
  
   
   
 Method 310 - Appendix A  
 
PROPELLANT COLLECTION PROCEDURES  
 1 APPLICATION  
 
The procedure applies to modify ASTM D3074- 94 and D3063- 94 to allow 
collection of the propellant for analysis and density measurement for metal 
aerosol containers and glass aerosol containers, respectively.  These 
modified procedures also retain the aerosol standard terminology listed in 
ASTM D3064- 97. 
 
2 LIMITATIONS  
 
Nitrogen analysis: Nitrogen may be used as a component of the propellant system.  Ambient air is 78 percent nitrogen and may be present as a contaminant in the system prior to sample collection.  This is eliminated by sweeping out any connecting lines to the Tedlar propellant  collection
 bag 
with product before starting sample collection.  This procedure will eliminate or reduce nitrogen contamination to less than 0.1
 percent % by weight of the 
sample and the analysis of the propellant gas will be unaffected.  
 3 APPARATUS AND MATERIALS  
 3.1 Propellant Collection System: See Figure 1 (metal containers) and Figure 3 (glass containers).  
 3.2 Tedlar Propellant Collection 
Bags equipped with slip valve and septum . 
 
3.3 Density Measurement  
 
3.3.1  250 mL gas dilution bulb, or  
 3.3.2  Density/Specific gravity meter meeting the following minimum specifications:  
 
3.3.2.1  Measurement Range: 0 – 3 +/- 0.00001 g/cm3 
 3.3.2.2  Measurement Temperature Range: 4
oC ~ 70oC. 
 
3.4 Balance, capable of accurately weighing to 0.1 mg  
 3.5 Sample Venting Platform. See Figure 2 ( metal containers)
1 and Figure 4 
(glass containers)2. 
                                            
1 See SOP SAS05, Figures 3 and 4.  
2 See SOP SAS05, Figure 7.   
   
   
 3.6 Platform Shaker, equivalent to Thermolyne M49125  
 
3.7 Cork Rings, 80 x 32 mm  
 
4 PROCEDURE  
 4.1 Propellant Collection for Metal Aerosol Containers  
 4.1.1  Close valves on Propellant Collection System (see Figure 1).  
 4.1.2  Remove the actuator from valve on the aerosol can and weigh can to the nearest  0.01 g     0.01 g
. 
 
4.1.3  Place the can in an inverted position onto the Sample Venting 
Platform, stabilized by cork rings.  
 
4.1.4  Slowly raise the hydraulic jack until the can is pierced.   Note the 
pressure of the can.  
 
4.1.5  Vent the can until propellant is seen flowing from output 1.  Collect the 
propellant in the Tedlar propellant collection  bag from output 1.  
Density is determined from this same Tedlar propellant collection  
bag, as necessary . 
 
4.1.6  After the propellant is collected, close and remove the Tedlar propellant collection
 bag and vent the remainder of the 
propellant.  
 
4.1.7  After the flow ceases from the can, it is removed from the assembly and allowed to vent overnight on a platform shaker, to vent the remainder of the propellant.  
 
4.1.8  Reweigh the can to the nearest 0.01 g and record weight loss (total grams propellant).  The can may now be opened for analysis of the non-propellant portion of the sample.  
 
4.2 Propellant Collection for Glass Aerosol Containers  
 4.2.1  Remove the actuator from valve of the aerosol glass container and weigh container to the nearest 0.01 g.  
 4.2.2  With container in an inverted position place the valve onto the tapered adaptor.  
 
4.2.3  Pressurize the air cylinder to actuate the sample contai ner valve onto 
the tapered adaptor.   Note the pressure of the sample container.  
  
   
   
 4.2.4  Open the sample valve and collect propellant sample into the Tedlar propellant collection
 bag.  Density is determined from this 
same Tedlar propellant collection  bag, as necessary.  
 
4.2.5  After the propellant is collected, close and remove the Tedlar propellant collection
 bag and vent the remainder of the 
propellant.  
 
4.2.6  Continue to vent the container on the platform assembly until no pressure registers on the sample gauge and there in no visible propellant flowing from the sampling tube.  
 
4.2.7  Remove the container from the platform.  
 
4.2.8  Punch a small hole into the container valve assembly.  
 
4.2.9  Place the container on a platform shaker to vent the remainder of the propellant.  
 
4.2.10  Reweigh the container and valve assembly to the nearest 0.01 g and 
record weight loss (total grams propellant).  The non- propellant portion 
of the sample is ready to be analyzed.  
  
   
   
 FIGURE 1  
PROPELLANT COLLECTION SYSTEM 
METAL AEROSOL CONTAINER  
 
  
 
   
   
 FIGURE 2  
SAMPLE VENTING PLATFORM  
METAL AEROSOL CONTAINER  
    
     
   
   
 FIGURE 3  
PROPELLANT COLLECTION SYSTEM 
GLASS AEROSOL CONTAINER  
 
   
   
 FIGURE 4  
SAMPLE VENTING PLATFORM  
GLASS AEROSOL CONTAINER  
   
 1 
 Appendix C 
 
2016 Multi -Purpose Lubricant Product Technical Assessment  
 
Background  
 
Multi -purpose Lubricant (MPL) products  are defined as lubricants designed or labeled 
for general purpose lubrication, or lubricant s labeled for use in a wide variety of 
applications.  
 In 2008, the California Air Resources Board  (CARB or Board ) approved amendments to 
the Consumer Products Regulation reducing the volatile organic compound ( VOC) limit 
for MPL products from 50 percent VOC and establishi ng two technology forcing limits :  
a 25 percent by weight VOC limit effective December  31, 2013 , and a 10  percent by 
weight VOC limit effective December  31, 2015.   Because the limits were technology 
forcing, the regulation included a provision requiring staff to conduct a Technical Assessment to determine feasibility of the VOC limits prior to their implementation.   
Solid or semisolid products (primarily greases) were not considered a significant  source 
of VOC emissions, and were excluded from the proposed VOC standard.  
 In 2011 , staff conducted a Technical Assessment for the 25  percent VOC limit .  Staff 
determined that while meeting the 25 percent  VOC  limit was feasible, it had proven  
challenging  and the reformulation required more time than expected.   As a result, in a 
2013 rulemaking , the Board approved a three- year extension for the 10 percent VOC 
limit for MPL products to December  31, 2018, to allow manufacturers  additional  time to 
reformulate products once again to meet the 10 percent VOC limit.  
 Staff has now conducted the Technical Assessment for the 10 percent by weight VOC 
limit.  Below are staff’s findings . 
 
Technical Assessment  
 Requirements  
 Companies that sell MPL products in California were required to provide data to ARB as 
part of the Technical Assessment evaluation by M arch 31, 2017.  Data reporting was  
mandatory for all responsible parties that sold MPL products subject to the VOC limit  in 
California during calendar year 2016.  
 Industry was required to report company information, including contact information.   If a 
third party formulator was used, third party formulator and formulator contact information 
was required.  Companies were req uired to report information about  current  MPL 
products sold in California during calendar year 2016 and product data on products  
proposed to meet the future 10 percent VOC limit.   A proposed product  was defined as 
a product  or formulation that was evaluated to meet the upcoming 10 percent by weight 
VOC limit.  2 
  
Reporting companies  were required to indicate if the product was in the research and 
development (R&D) process.  If the product was not in R&D, an explanation was required (such as “already compliant,” “discontinued,” etc…).  Formula information 
including ingredients that comprise at least 0.1 weight percent of the product, and the 
maximum incremental reactivity (MIR) value for each ingredient listed was required. 
Companies  were also required to provide product attribute information and a summary 
of R&D costs  for each product formula in the R&D process.  Label s for each reported 
product  were also required.  
 
Results  
 Fifty-six companies  reported MPL data (see Table I) representing a total of about four 
million pounds of product  sold during calendar year 2016 .  The ten companies with the 
most sales collectively account for over 95  percent  of the MPL market.  Staff identified 
over 120 unique MPL formulas subject to the VOC limit that were reported  as part of the 
Technical Assessment evaluation.  
 Staff analyzed the MPL data to determine the VOC  content and reactivity  of the 
products.  Staff also determined the compliant  market share and evaluated the 
readiness of the rema ining market share to  meet the 10 percent VOC limit.  As part  of 
the assessment , staff considered various options to provide manufacturers more 
flexibility to comply with the VOC requirements.  
 Broad product types in the MPL category include oils, aerosol greases, food- grade 
lubricants, and lubricants intended for multiple uses .  Oils comprise less than two 
percent of the MPLs market; these lubricants have not been impacted by progressive implementation of VOC limits  (see Table II). 
 It appears that some ma nufacturers reformulated their MPL products to comply with 
10 percent VOC limit as part of their reformulation to meet the current 25 percent VOC 
limit.  While the data show a number of formulations below the 10 percent VOC limit, these formulas command a relatively small fraction of the MPL market.  Products 
meeting  the 10  percent VOC limit currently make up about eight percent of MPL sales 
(including products reported as oils).  
 
 
  3 
 Table I  
List of Responding Companies  
Company  Company  
3M Company  NCH Corporation  
Aervoe Industries, Inc  Oatey  
Albatross USA  Permatex  
AMSOIL  Petro -Canada Lubricants Inc.  
Atco International  PJH BRANDS  
BG Products, Inc.  QuestSpecialty Corporation  
Chase Products Co.  Radiator Specialty Company  
CNH Industrial America LLC  Rainbow Technology Corporation  
CPC Aeroscience, Inc.  Rust-Oleum Corporation  
CRC Industries Inc.  Share Corporation  
Cyclo Industries, Inc.  Sherwin -Williams  
Ecolab, Inc.  Slide Products, Inc.  
Finish Line Technologies, Inc.  Sprayway, Inc  
Fiske Brothers Refining Company  Starbrite Inc  
Ford Motor Company  State Industrial Products  
General Motors Customer Care and Aftersales  STIHL Incorporated  
Golden State Supply, LLC  Synco Chemical Corporation  
Husqvarna  The Blaster Corporation  
International Lubricants, Inc. The Chemours Company  
ITW Pro Brands  THE PENRAY COMPANIES, INC.  
John Deere Merchandise, A Div. of John 
Deere Shared Services, Inc.  The Valspar Corporation  
Justice Brothers  Thetford Corporation  
Kimball Midwest  Toyota Motor Sales, USA  
Lawson Products, Inc.  Warren Distribution, Inc.  
LHB Industries  WD-40 Company  
Lucas Oil Products Inc.  Wurth USA Inc.  
Maxima Racing Oils  Yamaha Motor Corporation USA  
MOC Products Company, Inc.  ZEP INC  
 
 Staff analyzed company R&D efforts undertaken to achieve the technology forcing 10 
percent VOC limit and demonstrate their progress toward meeting this limit.   The 
company updates included the results of the testing and the testing protocols in some cases; information about the raw  materials used (using a much more expensive material 
in some cases); evaluations of the performance of the raw materials; MIR values for VOC or LVP -VOC ingredients evaluated or used; as well as the cost of reformulation 
efforts. A significant number of ma nufacturers indicated that despite their best efforts, 
the 10 percent VOC limit remains the most challenging and costly to comply with.  Seventeen new proposed formulas were reported. However, they are still being 
tested, so the results are uncertain.   Several companies expressed their concerns as to 4 
 the feasibility of achieving the 10 percent VOC limit and anticipate discontinuing product 
sales in California.  
 
Staff evaluated the reactivity of MPL products using the formulation information reported 
by manu facturers .  Reactivity refers to the quantification of how different types of 
compounds  contribute to the formation of tropospheric ozone.  Some compounds  are 
considered very “reactive” while others are non- reactive or have negligible reactivity to 
form oz one.  The impacts on ozone formation are quantified using the Maximum 
Incremental Reactivity (MIR) scale. This numeric scale was developed by Dr. William 
Carter at the University of California at Riverside and is based on modeling analyses 
and other data derived from smog chamber studies  (Carter, 2010) . 
 The Board has already adopted regulations of consumer products  based on calculations 
of their relative ground -level ozone impacts.  The Aerosol Coating Products Regulation 
limits the ozone formation potenti al (or reactivity) of all aerosol coating product 
emissions (title 17, CCR, sections 94520- 94528).  Tables of MIR Values have also been 
adopted to implement this Regulation.
1   
 In general, companies are meeting the 10 percent VOC limit by increasing the low vapor 
pressure VOC  (LVP- VOC ) content of these products.  These compounds typically 
displace VOCs.  In general, commonly used LVP -VOCs are slightly less reactive than 
commonly used VOCs in these products.  
 Analysis of the MPL data indicates that a signi ficant number of formulations from 
several manufacturers  already meet the 10 percent VOC limit.  The analysis also shows 
that these formulations constitute a small percent age of the market.  Staff’s review of 
the manufacturers’  efforts to reformulate MPL p roducts to comply  indicates that 
significant challenges remain in refor mulating over 90 percent of the Multi-purpose 
Lubricant market . 
 Therefore, staff  has concluded that providing a reactivity -based alternate compliance 
option to meet a reactivity limit would allow manufacturers additional flexibility to 
formulate products while preserving the air quality benefit already achieved by the 
mass- based VOC limit.  
  
                                            
1 Tables of MIR Values , title 17, CCR, Division 3, Chapter 1, Subchapter 8.6, Article 1, sections 94700-
94701  5 
 Table II  
Market Share of  Multi -purpose Lubricant Product  
 
Multi -
purpose 
Lubricant 
Type  Sales 
Weighted 
Average VOC  
Weight 
Percent  Sales Weighted Product Weighted 
MIR  Number of Repo rted 
MPL 
Formulas  Number of Companies Reporting 
MPLs  Percent of Reported MPL Market 
Represented  Group Mass 
(lbs/yr)  
MPL # 23.2 0.44  97 35 98.1 4,084,590  
Oil 0.0 0.00  32 9 1.9 79,428  
All 22.7  0.43  129 41 100.0  4,164,018  
# excludes oils  
 
Staff calculated the product weighted maximum incremental reactivity (PWMIR) of the MPL products  based on formulation information reported by companies as part of the 
Technical Assessment .  This analysis of the ozone air quality impacts of the emissions 
from MPL products indicated that as a whole the category has a relatively low reactivity.  As show n in Table II , products, which are oils, comprise two percent of the MPL market 
and have not needed to reformulate to meet progressively stringent VOC limits.  Removing the oils, which are zero VOC zero MIR lubricant products provides a more 
complete view of the reformulation effort results.  Once oils are excluded, the sales -
weighted average PWMIR of current MPL products compliant with the 10 percent VOC 
limit is 0.49 grams of ozone per gram of product  (see Table III) .  If that group is 
extended to include the MPL products compliant with the current 25 percent VOC limit, 
the sales -weighted average PWMIR of those products is 0.44 grams of ozone per gram 
of product.  The proposed alternate compliance option would create a path to cap the 
reactivity of product s at a level lower than that of the sales -weighted average reactivity 
of products currently compliant with the 10 percent VOC limit .  Based on these results, 
staff developed the alternate compliance option such that that reformulating product to 
comply under the option would ensure that the ozone air quality benefits are maintained.  
    6 
 Table II I 
Product -Weighted Reactivity of  
Multi -purpose Lubricant Product  (Excluding O ils) 
 
Multi -
purpose 
Lubricant 
VOC 
Range  Sales 
Weighted 
Average VOC  
Weight 
Percent  Sales Weighted Product Weighted 
MIR  Number of Reported MPL 
Formulas  Number of Companies Reporting 
MPLs  Percent of Reported MPL Market 
Represented  Group Mass 
(lbs/yr)  
0-10 0.6 0.49  37 10 6.3%  257,958  
0-25 22.5 0.44  91 31 97.4 3,976,849  
0-50 23.2 0.44  97 35 100.0  4,084,590  
 
Summary  
 When the Board approved the technology forcing VOC limits for MPLs, it was understood that reformulation of products to meet the VOC limits, particularly the 
10 percent VOC limit, would be a challenging undertaking.  This expectation has been 
borne out.  Nine years into implementation of these limits, nearly all MPLs now meet the 25 percent VOC limit; however, only about eight percent of produc t meets the 
10 percent limit.  In fact, many manufacturers hav e yet to develop formulations that 
comply with the 10 percent VOC limit  while maintaining product functionality .  Based on 
staff’s review of the data, it is uncertain whether a significant port ion of the market share 
could meet the 10 percent limit by the December 31, 2018 compliance deadline.  
 Staff’s review of product reactivity reveals that , on a sales -weighted basis, the reactivity 
of MPL products meeting the 10 percent VOC limit is matched by  that of product 
meeting the 25  percent limit.  In view of reactivity considerations, one could say that the 
ozone air quality benefits of this regulation are being achieved ahead of schedule.  
In order to lock in these benefits while providing additional compliance flexibility to manufacturers, staff is considering amendment s to the Consumer Products R egulation 
to include an alternate compliance option.  This option will be  base d on a reactivity limit 
that would ensure air quality benefits equivalent to or better than those achieved by the 
products meeting the 10 percent VOC limit.   Staff is also considering adding a restriction 
to prevent the use of high GWP compounds in multi -purpose lubricants . 
 
Reference  
 Carter , W. P. L. “ Development of the SAPRC -07 Chemical Mechanism and Updated 
Ozone Reactivity Scales.” Report to the California Ai r Resources Board,  Contracts 
No. 03-318, 06- 408, and 07- 730, Revised January 27, 2010 (Carter, 2010)