Subject: S OUTH C OAST A IR B ASIN 2012 PM2.5 AND O ZONE S TATE I MPLEMENTATION P LANS

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L OW V APOR P RESSURE VOC DEFINITION and CONSUMER PRODUCTS EXEMPTION

Amway has been a long time participant in the efforts of California regulators to improve the air q uality by emissions management strategies. As an employer within the SCAQMD, Amway is concerned about the quality of life for our employees and their families as well as the economic impact of control measures. We very much appreciate the opportunity to share our comments on the recommendation of the South Coast Board encouraging study of the LVP

- VOC exemption and its impact on air quality in the region

. Amway supports the intent of the recommendation but would like to provide history of our industry pa rticipation in the Consumer Products Rule with regard to the exemption and to suggest criteria for the path forward.

Amway is a global business with $10.9 billion in sales. The Access Business Group, the operations component that supports Amway independen t business owners (IBOs) with products, is engaged in the development, production and distribution of a wide variety of consumer products. Our company has manufacturing facilities in Buena Park, California and supports tens of thousands of small businesse s selling our products throughout the state. Because of our commitment to California business and to the health and safety of California consumers and environment, we have been pleased to actively engage the California Air Resources Board (CARB) and SCAQM D to develop and implement strategies that have improved air quality throughout the state.

T he long standing LVP VOC exemption has been one of the key elements of the CARB Consumer Products Rule since its inception. This rule and the corresponding US EPA

VOC Emission Standards for Consumer Products have served as a model for air quality management regulatory policy for nearly twenty years. No change in that rule should be made without extremely careful deliberation since that would disrupt the carefully

e stablished consistency among regulations and the invested efforts of countless manufacturers compelled to comply with the existing rule.

These rules have incorporated an understanding of low vapor pressure and reactivity that have focused on the regulatory capability and efficiencies of the enforcing agencies. There were limitations of analytical chemistry and experimental reaction chemistry that had to be considered in the context of practical considerations for the products and the regional conditions. The compromises made in granting both reactivity and vapor pressure exemptions have allowed for a very effective regulatory policy that has demonstrably improved air quality in California and in other regions where it has been implemented.During the perio d from about 1998

– 2005, Bob Hamilton of Amway participated actively

in the rulemaking and research review phases of the above topics. Contributions to CARB’s 310 Method, the RRAC and the US EPA’s RRWG efforts resulted in some clear

recommendations for f urther study in the areas of volatility and availability. Those efforts were summarized in a whitepaper and the proceedings of a workshop which have been cataloged at a NARSTO website:

http://www.narsto .org/voc_reactivity

These studies and the historical justification for the LVP exemption should be the basis for reviews going forward. Amway recognizes that the science underlying air quality regulation is subject to constant review and improvement. T herefore, we commit to participation in any effort for updating the Consumer Product Rule and strongly recommend that CARB Board and staff encourage a robust, stakeholder driven review and advisory process to inform any research going forward. As is alway s true of California rulemaking this should include economic as well as scientific and regulatory impacts.

Thank you for receiving these comments.