Subject:SOUTH COAST AIR BASIN 2012 PM2.5 AND OZONE STATE IMPLEMENTATION PLANS –

LOW VAPOR PRESSURE VOC DEFINITION and CONSUMER PRODUCTS EXEMPTION

Amway has been a long time participant in the efforts of California regulators to improve 

the air quality 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 participation 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 independent 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 businesses 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 SCAQMD to develop 

and implement strategies that have improved air quality throughout the state.

The 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 

established 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 period 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 further 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. Therefore, 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 always true of 

California rulemaking this should include economic as well as scientific and regulatory 

impacts.

Thank you for receiving these comments.