PROPOSEDREGULATIONTOREDUCE 

VOLATILE ORGANIC COMPOUND EMISSIONS 

FROM 

CONSUMER PRODUCTS 

TECHNICAL SUPPORT DOCUMENT 

. STATE OF CALIFORNIA 

AIR. RESOURCES BOARD 

STATIONARY SOURCE DIVISION 

AUGUST 1990 

" 

.... -
State of California 

AIR RESOURCES BOARD 

TECHNICAL SUPPORT DOCUMENT 

FOR 

A PROPOSED REGULATION TO REDUCE 

VOLATILE ORGANIC COMPOUND EMISSIONS FROM 

CONSUMER PRODUCTS 

Prepared by: 

Solvents Control Section 

Criteria Pollutants Branch 

Reviewed by: 

Peter D. Venturini, Chief, Stationary Source Division 

Ronald A. Friesen, Assistant Chief, Stationary Source Division 

Dean C. Simeroth, Chief, Criteria Pollutants Branch 

Peggy l. Vanicek, Manager, Solvents Control ·section 

Stationary Source Division 

Air Resources Board 

August 1990 
PROPOSED REGULATION TO REDUCE VOLATILE ORGANIC 

COMPOUND EMISSIONS FROM CONSUMER PRODUCTS 

Technical Support Document 

Air Resources Board 

P.O. Box 2815 

Sacramento, CA 95812 

This report has been prepared by the staff of the California Air 

Resources Board. Publication does not signify that the contents reflect 

the views and policies of the Air Resources Board, nor does mention of 

trade names or commercial products constitute endorsement or 

recommendation for use. 
ACKNOWLEDGMENTS 

This report and proposed regulation were developed by the Air Resources 

Board Solvent Control Section staff with the participation of industry 

representatives. We would particularly like to thank: 

Air Resources Board Staff 

Ed Wong 

Linda Clark 

Paul Milkey 

Torn Evashenk 

Floyd Vergara 

Mike Jaczola 

The Chemical Specialty Manufacturers Association, the Cosmetic Toiletries 

and Fragrance Association and the Soap and Detergent Association for 

facilitating discussion among industry and governmental representatives. 

(. 
TABLE OF CONTENTS 

Contents 

Acknowledgments 

I. Introduction .............................................. 1 

A. Overview .............................................. 1 

B. Background ............................................ 1 

II. Consumer Product Regulation ............................... 3 

A. Standards ............................................. 3 

B. Innovative Products ................................... 6 

C. Exemptions ............................................ 6 

D. Administrative Requirements ........................... ? 

E. Variances ............................................. 8 

F. Test Methods .......................................... 9 

G. Sever ab i 1 i ty ......................................... 10 

III. Ambient Air Duality and the Need for Emission Reductions.ll 

IV. Emission Estimates for the Regulated Categories .......... 15 

A. Methodology of Estimating Emissions ......•........... 15 

V. Summary of Proposed Standards ............................ 19 

VI. Description of the Categorjes ............................ 23 

A. Air Fresheners ....................................... 23 

B. Dual-Purpose Aerosol Air Freshener/Disinfectant ...... 29 

C. Automotive Windshield Washer Fluid ................... 30 

D. Bathroom and Tile Cleaner ............................ 32 

E. Engine Degreaser ....•................................ 34 

F. Floor Polish ......................................... 36 

G. Furniture Maintenance Products ....................... 39 

H. General Purpose Cleaners ............................. 42 

I. Glass Cleaner ........................................ 45 

J. Hair Spray ..........•................................ 47 

K. Hair Mousse .......................................... 51 

L. Hair Styling Gel ..................................... 53 

M. Insect Repellent. .................................... 55 

N. Laundry Prewash ...................................... 57 

0. Na i 1 Po 1 ish Remover .................................. 60 

P. Oven C 1 eaner ......................................... 63 

Q. Shaving Cream ........................................ 65 
TABLE OF CONTENTS (CON' I) 

Contents ~ 

VI I. Impacts .................................................. 67 

A. Economic Impacts ............................... ; ....... -.. 67' 

B. Env i ronmenta 1 Impacts ................................ 71 

.C. Consumer Impacts ....•...••........................... 75 

VIII. Issues ..................................................... 76 

A. Collection of VOC Survey Data .............. ~ ......... 76 .. B. VOC .Content Verses VOC Emi ss i ens .......... ~;.; ........ 77 

C. Ttme for. .Industry to .camp ly .......................... 79 

D .. Liquid Laundry Detergents ............................ Sl 

E. Dual-Purpose Aerosol Air Freshener/Disinfectants ..... 82 

References ......................................................... .' ....... 95 

Appendices 

A. California Clean Air Act Section 26 

-.B •. Proposed Consumer Product Regulation C. VOC Survey Summary 

o. Workshop Announcements 

E. Cost Analysis Calculations 
LIST OF TABLES 

1 Proposed Consumer Product VOC Standards 

Percent by Weight. ................................... 4 

2 Ozone and PM10 Air Qua 1 i ty Standards ................ 12 

3 Emissions by Product Category ....................... 18 

4 Summary of Complying Products ....................... 20 

5 Proposed Future Effective Standards ................. 22 

6 Air Fresheners Emission Summary ..................... 24 

7 Air Fresheners Standard Summary ..................... 28 

8 Bathroom and Tile Cleaners Emission Summary ......... 33 

9 Bathroom and Tile Cleaners Standard Summary ......... 34 

10 Floor Polish Emission Summary ....................... 37 

11 Floor Polish Standard Summary ....................... 39 

12 Furniture Maintenance Products Emission Summary ..... 40 

13 Furniture Maintenance Products Standard Summary ..... 42 

14 General Purpose Cleaners Emission Summary ........... 43 

15 General Purpose Cleaners Standard Summary ........... 45 

16 Glass Cleaners Emission Summary ..................... 45 

17 Glass Cleaners Standard Summary ..................... 47 

18 Hairspray ·Emissions Summary ......................... 48 

19 Hairspray Standard Summary .......................... 50 

20 Hair Styling Gel Emissions Summary .................. 53 

21 Hair Styling Gel Standard Summary ................... 54 

22 Insect Repellents Emission Surnrnary .................. 55 

23 Insect Repellent Standard Summary ................... 57 
LIST OF TABLES (CON' I) 

24 Laundry Prewash Emission Summary ...............•... :58 

25 Laundry Prewash Standard Summary .................... 60 

26 Oven Cleaners Emissions Summary ..................... 63 

27 Oven Cleaners Standard Summary ...................... 65 

28 Cost Effectiveness Comparison of the Proposed 

Consumer Product Regulation With Other Recently 

Adopted SCM's and Regulations ....................... 70 

29 Summary of Emissions and Emission Reductions ........ 71 

30 Effect of Virucidal Contact Disinfectants ........... 88 

31 Reprocessing for Equipment Used in the 

Prehospital Healthcare Setting ...........•.......... 90 
Figure 

1 

2 

LIST OF FIGURES 

California Ozone Attainment Status ............. 13 

California PMlO Attainment Status .............. 14 
I. 

INTRODUCTION 

A. OVERVIEW 

The California State Legislature, aware of California's serious air 

pollution problems and the inability of many areas to meet the State and 

Federal ambient air quality standards, enacted the California Clean Air Act 

of 1988 (CCAA). The CCAA added Section 41712 (Appendix A) to the California 

Health and Safety Code, which requires the Air Resources Board (ARB) to 

adopt statewide regulations by January 1, 1992, to achieve the maximum 

feasible reduction in volatile organic compounds (VOC) emitted by consumer 

products. It was further stipulated that any regulation adopted by the ARB 

must be necessary, and commercially and technologically feasible. 

As defined in Section 41712, consumer products are any chemically 

formulated product used by household and institutional consumers, including 

but not limited to, detergents; cleaning compounds; polishes; floor 

finishes; cosmetics; personal care products; home, lawn, and garden 

products; disinfectants; sanitizers; and automotive specialty products. The 

definition of consumer products specifically does not include paint, 

furniture coatings, or architectural coatings. 

Consumer products comprise an important source of VOC emissions in 

California. Based on the ARB emissions inventory, consumer product VOC 

emissions were about 200 tons per day (T/D) in 1987. Consumer products are 

the second largest solvent-use category and the only one that is largely 

unregulated. 

B. BACKGROUND 

In July 1989, the ARB approved a Consumer Products Control Plan which 

outlined the regulatory strategy proposed for meeting the CCAA mandate to 

reduce VOC emissions from consumer products. The control plan outlined a 

schedule of projects that would be undertaken to support the regulation 

development process and established a set of priorities for regulation 

development. The schedule includes development of a regulation for 

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deodorants and antiperspirants in the fall of 1989 to be followed by four 

regulations at six month intervals for personal care products, household 

products, automotive and industrial products and pesticide products. The 

schedule also included an evaluation of the feasibility of adopting a 

generic aerosol regulation. 

The ARB approved the regulation for control of VOC emissions from 

antiperspirants and deodorants in November 1989. An emissions reduction of 

4.0 TID is expected when the final compliance date becomes effective in 

1995. In December 1989, staff completed the evaluation of the concept of 

establishing VOC content limits for all aerosol consumer products. Staff 

concluded that, rather than regulate one specific product form, it would be 

feasible and more effective in terms of resources to establish limits for 

consumer products in a comprehensive regulation that would address at least 

some of the individual products in each of the four major product categories 

and address multiple product forms. Subsequently, staff began preparation 

of a draft comprehensive regulation. In January 1990, a Court Order was 

issued to the Bay Area Air Quality Management District (BAAQMD) and/or the 

ARB to adopt, by July 1990, regulations designed to achieve at least a 4 ton 

per day emission reduction from consumer product solvents in the Bay Area. 

The ARB adopted a regulation in June 1990 to comply w1th the court order. 

The regulation set limits for the VOC content of ait fresheners, engine 

degreasers, glass cleaners, hairsprays, oven cleaners, and automotive 

windshield washer fluids. 

This technical support document (TSD) provides the tethrtical informatioh 

staff used in developing the comprehensive regulatory proposal tci reduce 

emissions from consumer products statewide. The majority of the information 

contained in this TSD was obtained from members of the consumer product 

industry through five public workshops, VOC product surveys, individual . meetings with representatives from consumer product compariies and comments 

on distributed drafts of this report and regulation. This document presents 

an overview of the statewide consumer products regulation, a discussion of 

the ambient air quality and the need for emission reductions, solvent 

emissions for the regulated categories, descriptions of the r~gulated 

categories and the strategies to reduce consumer solvent emissions, and a 

discussion of the economic, environmental and lifestyle impacts resulting 

from the proposed regulation. 

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II. 

CONSUMER PRODUCT REGULATION 

A. STANDARDS 

The proposed statewide comprehensive consumer products regulation is a 

regulation that would establish VOC content standards for 16 different 

consumer products. The effective date for six of the product categories is 

January 1, 1993. These products were also regulated under the regulation 

adopted by the Air Resourc~s Board in June 1990 for the Bay Area Air Quality 

Management District. Because the Bay Area Regulation is no longer 

necessary, staff is proposing that it be repealed. The effective date for 

the remaining categories is January 1, 1994 with the exception of FIFRAregistered products which are described below. Future effective standards 

have also been proposed for engine degreasers, hairsprays, nail polish 

removers and single phase aerosol air fresheners. Table 1 lists the 16 

consumer products and the recommended standards. 

The standards prohibit the sale, supply, offer for sale, or manufacture 

for sale in California of any consumer product which, at the time of sale or 

manufacture, contains any VOC in excess of the limits specified. Also, the 

standards are set on the basis of the percentage VOC by weight and apply to 

the product only after the minimum recommended dilution has taken place. An 

exemption has been provided for incidental, "spot" use of a product in 

concentrated form. This will make allowance for infrequent uses of small 

amounts of concentrated products such as general purpose cleaners in cases 

where a higher VOC content is desired. 

-3-
* 

TABLE 1 

Proposed Consumer Product VOC Standards 

Percent by Weight 

Product Category 

Air Fresheners 

Single Phase Aerosols 

Double Phase Aerosols 

Liquids/Pump Sprays 

Solids/Gels 

Dual-Purpose Aerosol Ai~ 

Freshener/Disinfectant 

Automotive Windshield 

Washer Fluids . * Type A Are'as 

All Other Areas 

Bathroom and Tile Cleaners 

Engine Degreasers 

Floor Polishes (Waxes) 

Products for Flexible 

1/1/93 1/1/94 

70 

30 

18 

3 

35 

10 

75 

60 

5 

Flooring Materials· 7 

Products for 

Nonresilient Flooring 10 

Wood F 1 oor Wax 90 

Furniture Maintenance Products 

Aerosols 25 

All Other Forms except solid/paste 7 

General Purpose Cleane~s 10 

Glass Cleaners 6 

Hairsprays 80 

Future 

Effective 

(Date) 

30 (1/1/96) 

50 (1/1/96) 

55 (1/1/98) 

For automotive windshield washer fluids, "Type A" areas include only 

the following areas where winter temperatures between 20°F and -25°F can be 

reasonably expected to occur: Del Norte, Shasta, and Trinity Counties, and 

the Lake Tahoe, Mountain Counties, Great Basin Valleys, and Northeast 

Plateau Air Basins. 

-4-
TABLE 1 (Can't) 

Proposed Consumer Product VOC Standards 

Percent by Weight 

Product Category 1/1/93 1/1/94 

Hair Styling Gels 6 

Hair Mousses 16 

Insect Repellents 

Aerosols 65 

Laundry Prewashes 

Aerosols/Solids 22 

All Other Forms 5 

Nail Polish Removers 85 

Oven Cleaners 

Aerosols/Pump Sprays 8 

Liquids 5 

Shaving Creams 5 

Future 

Effective 

(Date) 

75 (1/1/96) 

A one year sell through period has been provided for retailers and 

suppliers to clear out non-complying products after the effective date of 

the standard. This does not apply to products in the Bay Area that have 

effective standards January 1, 1993 (air fresheners, automotive windshield 

washer fluid, glass cleaners, hairspray, oven cleaners, and engine 

degreasers). Because the court order specified that the emission reductions 

must occur by February 1, 1993 it is necessary to prohibit the sale of any 

non-complying product after the January 1, 1993 effective date. 

1. FIFRA Products: For those consumer products registered under the 

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the effective 

date of the VOC standards is one year after the effective date listed in the 

Table of Standards for the product category which contains the FIFRA 

product. This provision will allow additional time for companies toreregister any of their reformulated FIFRA products with EPA. FIFRA requires 

the registration of pesticide products, and defines ''pest" as any insect, 

rodent, nematode, fungus, weed, or any form of terrestrial or aquatic plant 

or animal life or virus, bacteria, or other micro-organism (except viruses, 

bacteria, or other micro-organisms on or in living man or other living 

animals)(7 U.S.C., Section 136(u)). By virtue of this definition, FIFRAregistered products generally tend to fall under the product categories of 

air fresheners (dual-purpose aerosol air freshener/disinfectants), bathroom 

-5-
and tile cleaners, general purpose cleaners, and insect repellents, based on 

any disinfectant or pesticide claim made by the manufacturer for the 

product. 

2. Ozone-Depleting Compounds: Another provision stipulates that, effective 

January 1, 1993 any consumer product listed in the table of standards that 

is sold or manufactured in California cannot contain any ozone-depleting compound which is regulated by the EPA or with an ozone-depleting potential 

of greater than o.oo: This provision only applies to new product 

formulations introduced to the market after the effective date of the 

regulation and will not apply to any product formulation which is sold, 

supplied, or offered for sale in California prior to the effective date of 

the regulation. In addition, the provision does not apply to any ozonedepleting compounds that may be present as an impurity in a consumer product 

in an amount equal to qr less than 0.011 by weight. This provision was 

established to limit the amount of exempt ozone-depleting compounds used in 

consumer products to ensure that manufacturers do not switch to ozone 

depleting compounds when they are reformulating current products to lower 

VOC content. This is generally the same as a similar provision in the 

antiperspirant and deodorant regulation that the Board adopted in 

November 1989. 

B. INNOVATIVE PRODUCTS 

A consumer product can be exempted from the VOC standards in the 

regulation if it can be classified as innovative. An innovative product is 

a product which may have a VOC content greater than the applicable VOC 

standard, but which emits less VOC emissions than a representative consumer 

product which does meet that standard. To be eligible for this exemption, a 

manufacturer must demonstrate that us~ of the product will result in less 

emissions than a complying product, due to some characteristic of the , product formulation, design, delivery system, or other factors. The 

manufacturer must also identify the VOC content and, if appropriate, test 

methods that can be used to enforce the innovative product exemption. 

C. EXEMPTIONS 

1. Vapor Pressure: The proposed regulation exempts any VOC which either, 

1) has a true vapor pressure of less than 0.1 mm Hg at 20 degrees Centigrade (C) or, 2) consists of more than 12 carbon atoms, if the vapor pressure is 

unknown. Those VOCs with vapor pressures less than 0.1 mm Hg have very low, 

volatility and due to the product formulation characteristics are less 

emissive than higher volatility products .. Examples of the exempt VOCs are 

the high molecular weight resins used in hairsprays and floor polishes, surfactants used in cleaners and the heavy oils used in furniture polishes. 

2. Fragrance and Colorants: The VOC standards do not apply to fragrances 

and colorants up to a combi.ned level of 2 percerit by weight contained in anY 

consumer product. This exemption was established to allow manufacturers a 

-6-
de m1n1mus level of these substances in various products such that the 

products may be marketed in an appealing manner to consumers. 

3. Insect Repellants: The VOC standards do not apply to 2-ethyl-1,3-

hexanediol contained in personal insect repellents. This compound, found in 

small quantities, is considered essential ingredients in a few insect 

repellents. In addition, the market share for products based on 2-ethyl1,3-hexanediol is very small when compared to the dominant repellent 

ingredient, N,N-diethyl-m-toluamide (DEET). DEET is exempt because it has a 

vapor pressure less than 0.1 mm Hg. 

4. FIFRA Products: The labeling requirements for consumer products do not 

apply to those products registered under FIFRA. Section 24(b) of FIFRA 

prevents the state from requiring any labeling or packaging in addition to 

or different than that required under FIFRA. 

5. Air Fresheners: The VOC standards do not apply to air fresheners that 

are comprised entirely of fragrance not including exempt VOCs. This is to 

allow the use of air fresheners such as those used in cars, which consist of 

fragrance impregnated on a cardboard symbol or fragrance oils that are 

impregnated on potpourri. Excluding the weight of the cardboard substrate, 

the VOC content of the fragrance substance would be 100%. The active 

ingredient (e.g. the fragrance) is present in a more concentrated form, 

resulting in less VOC emissions over the life of the product. 

6. Paradichlorobenzene: An exemption is allowed for air fresheners 

comprised of at least 98 percent paradichlorobenzene. Staff are unaware of 

technology currently available to allow for the reduction of VOCs in air 

fresheners formulated at high concentrations of para-dichlorobenzene. 

D. ADMINISTRATIVE REQUIREMENTS 

1. Most Restrictive limit: Many consumer products can serve several 

functions, i.e., a bathroom and tile cleaner can also be used as a general 

purpose cleaner in the kitchen. In cases of such potential overlap between 

product categories, if the product is labeled or advertised as suitable for 

use as a consumer product for which a lower VOC standard is specified, then 

the lowest applicable standard shall apply. This provision does not apply 

to general purpose cleaners that by their very nature have multiple uses. 

2. Code-Dating: No later than three months after the effective date of 

the regulation, consumer products subject to the VOC standards shall display 

the date of manufacture either on the container or on the packaging. If the 

manufacturer uses a code to indicate the date of manufacture, an explanation 

of the code must be filed with the Executive Officer of the ARB no later 

than 3 months after the effective date of the regulation. This will aid in 

enforcement of the regulation by allowing inspectors to verify that only 

complying products are being sold in California after the effective date of 

the regulation. There is, however, a one-year sell-through period allowed 

for non-compliant products manufactured prior to the effective date of the 

standards. 

-7-
3. Registration: Each manufacturer. of consumer products that are sold in 

California, must register such products with the ARB no later than ·· March 1, 1991, and no later than March 1 of every third year thereafter. 

All registration material will be handled in accordance with the 

confidentiality protection procedure~specified in Title 17, California Cod~ 

of Regulations, Sections 91000-91022. Registration items must include the 

following information: 

- the brand name for each consumer product; 

- the owner of the trademark or brand name; 

-the product category to which the consumer product belongs; 

-the product forms (aerosol, liquid,. etc.); 

the California ~nnual sales in pounds per year and the method used to 

calculate it; 

-the total VOC content in percent by weight which (a) has a vapor 

pressure of gr~ater than or equal to 0.1 mm Hg.at 20 degrees 

Centigrade, or (b) consists of 12 or less carbon atoms, if the vapor 

pressure is unknown; 

Products subject to registration include those products listed in the 

·Table of Standards, products exempted under the 100% fragrance exemption, 

and an additional 23 products that are being evaluated and considered for 

future regulation. 

This information will aid staff in developing additional standards for 

consumer products, and will eliminate the need for administering product 

surveys. It will also allow staff to track emissions from consumer products 

and to evaluate the effectiveness of the consumer product regulations. 

E. VARIANCES 

Any person who cannot comply with the requirements set forth in the 

section on standards, because of reasons beyond the person's reasonable 

control may apply in writing for a variance. The variance application shall 

state the specific reasons why a variance is sought, the proposed date(s) by 

which compliance with the standards will be achieved, and the methods by which compliance will be achieved. 

Upon receipt of a variance application, the Executive Officer will hold 

a public hearing to determine whether, under what conditions, and to what 

extent, a variance from the standards is necessary and will be permitted. 

All of the following findings must be made in order to brant the variance: 

1. Compliance with the standards would result in extrao~dinary economic 

hardship, due to rea~ons beyond the reasonable control of the applicant. 

-8-
2. The public interest in mitigating the hardship to the applicant 

outweighs the public interest in avoiding any increased emissions which 

would result from issuance of the variance. 

3. The methods to achieve compliance can reasonably be implemented, and 

will achieve compliance as expeditiously as possible. 

If a variance is granted, the variance order will specify a final 

compliance date by which compliance with the standards will be achieved, and 

the increments of progress necessary to assure timely compliance. The order 

may also contain any other conditions that the Executive Officer deems 

necessary to carry out the purposes of Division 26 of the Health and Safety 

Code. A variance's duration will be determined by the Executive Officer, 

and can also be terminated, upon failure to comply with any condition of the 

variance. Upon application of any person, the Executive Officer may hold a 

public hearing to review a variance, and for good cause may modify or revoke 

a variance. 

F. TEST METHODS 

Testing to determine the VOC content of a consumer product, or to 

determine compliance with the standards, shall be done using one or more of 

the following methods: (1) Method 24-24A, Part 60, Title 40, Code of 

Federal Regulations, Appendix A, July 1, 1988; (2) Method 18, Federal 

Register 48, no. 202, October 18, 1983; (3) Method 1400, NIOSH Manual of 

Analytical Methods, Volume 1, February 1984; or (4) Environmental Protection 

Agency Method 8240 "GC/MS Method for Volatile Organics," September 1986. 

The methods referenced in the regulation are not intended to be used by 

everyone. Their successful use requires someone thoroughly familar with the 

use of the methods. Each method is designed for certain applications. 

Before a product can be tested, an evaluation of the nature and chemical 

properties of the product must be made. Based on the results of this 

evaluation, a method or combination of methods is selected for the use in 

determining the VOC content of the product. In recognition that other 

methods may be available to determine the VOC content, the proposed 

regulation would allow the use of alternative methods which can be shown to 

the satisfaction of the Executive Officer to accurately determine the 

concentration of nonexempt VOCs in a product, upon approval of the Executive 

Officer. 

Staff is working to develop new test methods and improvements to 

existing methods. This work is being done both independent of and in 

cooperation with industry. Also, EPA is beginning to work toward 

development of new test methods for consumer products. Staff will follow 

and take advantage of EPA's efforts. 

Compliance can also be demonstrated through calculation of VOC content 

from records of amounts of constituents making up the product. 

The results of tests conducted to determine the VOC content of consumer 

products shall be subject to verification by the Executive Officer. The 

-9-
results of such tests as conducted by the Exetutive Offiie~ or the . Environmental Protection Agency sh~ll take precederice over results of tests 

conducted by other parties when determining cdmpliarice with th~ regulation. 

G. SEVERABILITY 

Each section of the regulation is deemed ~everabl~. and if any part of 

the regulation is held to be invalid, the remainder of it will continue in 

full force and effect. 

-10-
III. 

AMBIENT AIR QUALITY AND THE NEED FQR EMISSIQN REDUCTIQNS 

To protect the public health and welfare, ambient air quality standards 

have been established on both the national and state level for ozone and 

particulate matter of aerodynamic equivalent diameter less than or equal to 

10 microns (PM-10). These standards are shown in Table 2. The state hourly 

ozone standard is 0.09 parts per million (ppm) and the national hourly ozone 

standard is 0.12 ppm. The state PM-10 standard was established by the ARB 

in August 1983. The standard is 50 micrograms per cubic meter determined 

over a 24-hour period. 

Volatile organic compound (VOC) emissions contribute to the formation of 

both ozone and PM-10. Ozone formation in the lower atmosphere results from 

a series of chemical reactions between VOCs and nitrogen oxides in the 

presence of sunlight. PM-10 levels are the result of both direct and 

indirect emissions. Direct sources include emissions from fuel combustion 

and wind erosion of soil. Indirect sources result via the chemical reaction 

of VOCs, nitrogen oxides, sulfur oxides and other chemicals in the 

atmosphere. 

Ozone is a strong respiratory irritant that can impair the normal 

function of the lungs, especially during vigorous physical activity. This 

health effect is particularly acute in children, the elderly and people with 

respiratory conditions. Ozone levels also damage some types of vegetation, 

reducing the yields from some crops. 

Particulate matter with diameters smaller than or equal to 10 microns 

equivalent aerodynamic diameter (PM-10) have the greatest impact on the 

respiratory system because they can reach deep into the lungs. PM-10 causes 

irritation of the respiratory tract and may contain toxic compounds which 

adhere to the particle surfaces and can enter the lungs. Because it is 

visible in the atmosphere, PM-10 also contributes to reduced visibility. 

-11-
Pollutant 

Ozone 

PM-10 

TABLE 2 

Ambient Air Quality Standards for Ozone and PM-10 

Average Time 

1 hour 

Annual Geometric 

Mean 

24 hour 

Annual Arithmetic 

State Std. 

0.09 ppm 

(180 ug/m3) 

30 ug/m3 

50 ug/m3 

National Std. 

0.12 ppm 

(235 ug/m3) 

150 ug/m3 

50 ug/m3 

Figures 1 and ~show the attaiMment status for C~lifornia air basins and 

counties with regard to the national and state standards for ozone and the 

state standard for PM-10. As shown on the map, most areas of California 

have been designated nonattainment for ozone and PM-10. Over 90 percent of 

California's population live in nonattainment areas for these pollutants. 

To ensure adequate progress toward the state and federal ozone and PM~10 

standards, the California Clean Air Act requires California's nonattainment 

districts to achieve an average 5 percent annual reduction in emissions from 

each nonattainment pollutant and their precursors. 

Volatile organic compound emissions from most consumer products are not 

currently regulated. Although emissions from individual products seem 

small, when taken collectively they are sig~ificant. VOC emissions from the 

solvents and propellants in consumer products are estimated to be over 240 

tons per day based on the 1987 ARB Emissions Inventory. A regulation 

limiting emissions f~om this source is necessa~y to help California meet the 

state and federal ~mbient air quality standards and to help nonattainment 

districts achieve the required 5 percent annual emissions reduction from 

ozone and PM-10 precursors. · 

-12-

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* PURSUANT TO SECTION 39608 OF THE CALIFORNIA CLEAN AIR ACT. 

-14-

+ 

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TSD • 10/89 
IV. 

EMISSIONS ESTIMATES FOR THE REGULATED CATEGORIES 

To quantify emission reductions and monitor the effectiveness of the 

regulations, it is important to determine the VOC emissions that each 

category of consumer products emits. To do this, ARB staff compiled data 

from various sources in an attempt to quantify the magnitude of emissions 

from each product category. Staff initially used ARB's 1983 Emissions 

Inventory to get a first approximation of statewide emissions from consumer 

products. Extrapolated to 1987 levels, this emissions inventory showed that 

approximately 200 tons/day of VOCs were emitted in California. 

Although the existing emission inventory proved valuable in determining 

the magnitude of emissions from the different categories, it nevertheless 

needed improvement. Various changes in the market from 1983 to 1988 may 

have significantly affected the estimated emissions. To alleviate this 

problem, staff designed a comprehensive consumer products VOC survey which 

they distributed to product manufacturers and distributors on February 9, 

1990 (modified on March 6, 1990). 

A. METHODOLOGY FOR ESTIMATING EMISSIONS 

ARB's 1983 Emission Inventory, updated in 1985 and extrapolated to 1987 

levels, generally combined estimated average VOC contents for various 

product categories along with their respective California production figures 

to arrive at an estimated 200 tons/day emissions in 1987. ARB staff used 

California- or regional-specific sales data whenever possible. If these 

were not available, national sales figures were proportioned to California 

levels according to population and geographical use factors. 

The recent consumer products VOC survey, distributed in February 1990, 

was designed to give ARB staff comprehensive data on formulations and 

production figures. The survey was distributed and collected by ARB staff 

and three other firms: (1) Heiden Associates, a law firm contracted by the 

Chemical Specialties Manufacturers Association (CSMA), (2) Baker and 

-15-
Hostetler, a law firm contracted by the Soap and Detergents Association 

(SDA), and (3) the Cosmetics, Toiletries and Fragrances Association (CTFA). 

Data that were submitted by these firms or submitted directly to staff were 

screened for obvious errors. Subsequently, data that were deemed by staff 

to be representative and accurate were used to improve the existing 

inventory; otherwise, the data found in the updated 1983 emission inventory 

were used as default values. 

Survey submissions that did not include VOC content or production data 

were eliminated unless they represented a large fraction of the market. In 

these cases, efforts were made to find the missing data or to take the 

results (e.g. complying market share) from the evaluation of the complete 

data and apply them to the incomplete data. In general, most of the 

incomplete data was found in the survey responses submitted by small 

manufacturers. Since their production figures were generally small, staff 

did not expect the elimination of these incomplete data to significantly 

affect the data analysis. A summary of the VOC Survey data for the products being proposed for regulation is included in Appendix C. · 

Using data that were found to be accurate and representative, ARB staff 

found that the 16 products proposed for regulation are responsible f6r 

approximately 102 tons/day of VOC emissions. This is of the same order of 

magnitude as the existing inventory, which tends to support the accuracy of 

the inventory. However, since the product categories reviewed to date · represent only a fraction of all existing product categories, the existing·· 

inventory of 200 tons VOC/day may be a gross underestimation. 

Table 3 shows the results of the analysis of the survey data submitted td 

ARB on a per-product-category basis. The survey results were compiled to 

report the following values: per-product emissions, the sales-weighted 

average VOC per product category, and the expected emission reduction 

associated with the proposed VOC standards. The emissions from each product 

reported in the survey responses were calculated using the following 

equation: 

where, 

voce = voce * Prod I 2000 1 365 1 100 (1) 

voce = VOC emissions (per product) [=] ton VOC/day 

voce = VOC content of product [=] wt% 

Prod = 1988 California production (except otherwise specified) 

2000 

365 

100 

[=] lb product sold in California/year = conversion factor for lb to tons [=] 2000 lb/ton = conversion factor for year to day [=] 365 day/year 

= conversion factor for wt% to fractional weight, no units · 

-16-
The sales-weighted average VOC content per product category was calculated 

using the following equation: 

where, 

= VOCc 1*Prod 1 

Prod1 

+ VOCcz*Prod 2 + ••• + VOCcn*Prodn 

+ Prod2 + ••• + Prodn 

vocavg 

VOCe, Prod 

1,2, ... ,n 

= sales-weighted average VOC content [=] wt% 

= as defined in Equation (1) 

= total number of products in category 

The emission reductions associated with each proposed standard were 

calculated for each reported product using the following equations: 

where, 

vocer 

voce, voce 

Std 

1,2, ... ,n 

= 

= 

= 

= 

(3) 

VOC emission reductions [=] ton VOC reduced/day 

as defined in Equation (1) 

proposed VOC standard [=] wt% VOC 

individual products, same as above 

-17-

(2) 
TABLE 3 

VOC Emissions by Product Category 

(1989) 

Product Category 

Air Fresheners (including dual-use disinfectants) 

Automotive Wind~hield Washer Fluid 

Bathroom and Tile Cleaner 

Engine Degreaser 

Floor Polish 

Furniture Maintenance 

General Purpose Cleaner 

Glass Cleaner 

Hair Spray 

Hair Styling Gels 

Hair Mousse 

Insect Repellent (aerosols) 

Laundry Prewash 

Oven Cleaner 

Nail Polish Remover 

Shaving Cream 

VOC Emissions 

lbs/Day 

17,300 

48,000 

900 

9,000 

5,200 

5,600 

9,800 

4,600 

92,000 

820 

1,160 

880 

4,000 

2,000 

2,200 

520 

Source: ARB 1990 Constimer·Product Survey 

Total: - 204,000 lbs/Day 

(102 .Tons/Day) 

-18- .. 
v. 

SUMMARY OF PROPOSED STANDARDS 

The proposed statewide consumer product regulation contains VOC 

standards for 16 consumer products. The proposed standards were selected 

after review of the ARB VOC survey responses, numerous meetings with 

industry representatives and after analyzing the technological and 

commercial feasibility of each standard. Based on the survey results, there 

are complying products for each product category currently being sold in 

California that can meet the proposed standard and, in many cases, in each 

product form. 

The proposed windshield washer fluid standard was not based on the VOC 

survey data, but based on the physical need for VOCs used in windshield 

washer fluids to provide a freezing point depression for the fluid. Two 

standards are proposed for windshield washer fluid based on the wintertime 

temperatures found in California. For those areas that experience 

temperatures below freezing, the standard is set at 35 percent VOC which 

will provide anti-freezing protection to -25 degrees Fahrenheit, and for the 

majority of Californians who live in the more temperate regions of the state 

the standard is 10 percent which will provide anti-freezing protection to 20 

degrees Fahrenheit. 

The proposed standards and the number of complying products currently 

being sold in California that comply with the standard are summarized in 

Table 4. The number of complying products being sold in California are 

based on the responses to the ARB VOC survey. 

-19-
TABLE 4 

Summary of Complying Products 

I I Proposed I Number of Complying Product I Product I Standard, I Products Currently CSlt~gQC!l I EQCtD I H:t ~ ~QC I B~jcg Sgld jc CA 

I I I 

Dual-Use Aero so liAeroso 1 I 60 I 1 

Air Freshener/ I I I 

Disinfectants* I I I 

I I I 

Air Fresheners !Aerosol-Single Phase I 70 I 0** II !Aerosol-Double Phase I 30 I 20 II I liquids/Pumps I 18 I 84 II !Solids/Gels I 3 I 33 I 

I I Other I 3 I 9 I 

I I I, I r 

!Automotive lA 11 Forms , I 10 I UTQ*** I 

I Windshield I (A Areas) I 35 I UTQ*** I 

I Washer Fluid I I I r 

I I I I r, 

!Bathroom & Tile IAll Forms I 5 44 I 

I I I I 

!Engine DegreasersiAll Forms I 75 4 I 

I I I I IFloor Polishes lA 11 F.orms I 7 115 I 

I Flexible Floor I I 

I Materials I I . I I I 

I Nonresilient IAll Forms 10 UTQ*** I 

I Floori.ng I I 

I I I 

I Wood Floor Wax lA 11 Forms 90 5 I 

I I I 

I Furniture Main- I Aerosols 25 22 I 

I tenance Product! I 

I II I Solids 87 1 I 

I II IAll Oth.er 7 15 I 

* "Dual-Use" and "Dual-Purpose" are interchangeable 

** The standard proposed for single phase aerosol air freshener is based on a 

recommendation by CSMA. According to CSMA, even though there are 

currently no complying products on the market, the technology is available 

to formulate a single phase aerosol air freshener at the 70% VOC limit. 

*** UTQ - Unable to quantify 

-20-
TABLE 4 (can't) 

Summary of Complying Products 

I I 

I Product I Product 

I Category I Form 

I I 

!General Purpose IAll Forms 

I Cleaners I 

I I 

!Glass Cleaners IAll Forms 

I I 

IHair Mousses IAll Forms 

I I 

IHairsprays IAll Forms 

I I 

IHair Styling GelsiAll Forms 

I I 

!Insect RepellantsiAerosols 

I I 

!Laundry Prewash !Aerosol/Solids 

I " IAll Other Forms 

I I 

INail Polish IAll Forms 

I Remover I 

I I 

lOven Cleaners !Aerosols/Pump Spray 

I " !Liquids 

I I 

!Shaving Creams IAll Forms 

Proposed 

Standard, 

Wt % VOC 

10 

6 

16 

80 

6 

65 

22 

5 

85 

8 

5 

5 

Number of Complying 

Products Currently 

Bejng Sold in CA 

160 

32 

66 

66 

58 

4 

4 

9 

11 

13 

8 

5 

For four product categories~ staff is proposing to have future effective 

standards. Future effective standards are proposed for engine degreasers, 

hairsprays, nail polish remover, and air fresheners ("single phase aerosols"). 

Table 5 below summarizes the product categories with future effective 

standards. Engine degreasers, hairspray and nail polish remover products are· 

currently being sold in California that can meet the proposed future effective 

standards. However, these products do represent newer technologies in the 

market place and in each case the products have a smaller percent of the 

market. To allow for other manufacturers to develop complying products, the 

standard will not become effective until 1996 for nail polish removers and 

engine degreasers, and 1998 for hairsprays. Due to the complexity of 

hairspray resin development, additional time was provided for manufacturers to 

meet the future effective standard for hairspray. Staff is unaware of any 

products for single phase aerosols that are currently being marketed in 

California, however, conversations with industry representatives have 

indicated that the technology is developing in this area that will allow for 

the production of a single phase aerosol at the lower limit. 

-21-
TABLE'S 

Proposed Future Effective Standards 

Product 

Category 

' Air Fresheners, 

Single Phase Aerosol 

Engine Degreasers 

Hairsprays 

Nail Polish Removers 

Future 

Effective Date 

1/1/96 

1/1/96 

1/1/98 

1/1/96 

-22-

Proposed Emission 

Standard Reductions 

(% VOC) (Jbs/day) 

30 620 

50 2,340 

55 24,160 

75 . 220 

TOTAL: 27,340 

(13.7 T/D) 

:: 
VI. 

DESCRIPTION OF THE CATEGORIES 

This section contains a description of the 16 consumer products that 

were chosen for the comprehensive statewide consumer product regulation. 

A. AIR FRESHENERS 

Product Description: The proposed definition for air fresheners 

includes products for the purpose of masking odors, providing a scent, or 

deodorizing. Not included in the definition are personal bodily hygiene 

products, rug deodorizers or products that function primarily as cleaning 

products as indicated on a product label or in any advertising. 

Dual-purpose aerosol air freshener/disinfectants which claim to freshen 

or deodorize air are also included under the air freshener category. 

However, since these products have two purposes, staff has provided a 

separate product description and analysis of health concerns for these 

products. The product description for these dual purpose products follows 

the description for air fresheners and the analysis of these products is 

presented in Issues, Chapter VIII. 

Product Forms: Air fresheners are available in a wide variety of forms 

including, but not limited to, aerosol sprays, liquids (alone or within 

absorbing materials such as pads and wicks), gels, powders, crystals and 

blocks. Also included in the air freshener category are dual-purpose 

aerosol air freshener/disinfectants which claim to freshen air. The 

emissions from all forms of air fresheners, excluding dual-purpose aerosol 

air freshener/disinfectants, are estimated at 4.4 tons per day based on the 

ARB survey. Including dual-purpose aerosol air freshner/disinfectant 

sprays, the emissions are estimated at about 8 tons per day. Table 6 shows 

shows the percentage of emissions from each subcategory. 

-23-
Prodyct Form 

Aerosol-2 phase 

Aerosol-1 phase Liquids/Pumps 

Sol ids 

Other 

TABLE 6 

Air Fresheners Emission Summary* 

(Total Emissions 4.35 T/D) 

Percent of Emissions 

Market (TID) 

45 2.72 

4 0. 77 

20 0.64 

29 0.15 

2 0.07 

Percent of 

Emissions 

63 

18 

14 

3 

2 

* Numbers do not include dual-purpose aerosol air freshener/disinfectants 

and may not add up to 100% due to rounding. 

Aerosol air,fresheners (both single and double phase) make up the 

largest segment of the air freshener market at about 50% and contribute 

about 80% of the emissions from air fresheners, not including dual-purpose 

aerosol air freshner/disinfectant sprays. Aerosol sprays include both 

single phase and dual phase aerosol products. Single phase products make up 

less than 5% of the air freshener market yet contribute nearly 20% of the 

emissions from air fresheners. With sihgle phase aerosbl products, the 

liquid components of the product are present in a single, homogeneous phase. These aerosol products have a high VOC content. The VOCs evaporate as the 

product is sprayed, resulting in a fine "dry" mist. According to industry 

representatives, single phase products are preferred when spraying furniture, drapes, or near surfaces where the "wetter" sprays may leave 

moisture spots. Also, single phase aerosol air fresheners do not have to be 

shaken before use. This feature of single phase products is apparent in a 

wall-mounted aerosol air freshener enclosed in a housing that is pushed 

whenever a "shot" qf the product is desired. 

According to the ARB survey, dual phase aerosol air fresheners make up 

the majority of the ait freshener market at 45% and contribute over 60% of 

the emissions from air .freshehersj With dual phase aerosol products, the 

liquid contents of the product are present in more than one phase. Generally, a water based phase and a solvent based phase are present, 

resulting in products with lower VOC content than the single phase aerosol 

products. These products must be shaken before use to mix the phases into a homog~neous emulsion~ 

According to the ARB survey, 1 i quid air fres.heners make up about 20% of 

the air freshener market and contribute about 15% of the emissions. 

Although a few products are marketed as liquids in containers that are 

exposed directly to open air, most are available within specialized 

packaging to control the release rate (evaporation) of the product. Most 

liquid products use a wick, pad, or other barrier between a liquid reservoir 

and open air to control the evaporation of the fragrance and any solvents. 

-24-
A more elaborate example by one marketer consists of a felt soaked material 

enclosed in a plastic bag to control the release rate. The plastic bag is 

held within a plastic housing with a small, battery-operated fan to deliver 

the scented air. 

Other liquid products include pre-soaked materials without a liquid 

reservoir. These products are classified as liquids although they are 

absorbed within a solid, inert material. An example of these products is a 

fragrance impregnated paper air freshener for use in automobiles. 

Liquid products delivered by pump spray make up a very small percentage 

of the air freshener market. 

Solid air fresheners include powders, crystals, blocks and gels. 

According to the ARB survey, these products make up about 30% of the air 

freshener market, but contribute only about 3% of the emissions from air 

fresheners due to their low VOC content. This diverse category of products 

includes such products as a gel in the shape of a cone that is enclosed in a 

plastic enclosure. Another example is the solid "block" products which 

include toilet bowl deodorizers and closet fresheners. Rug deodorizers are 

not included in the air freshener category. 

Dual-purpose aerosol air freshener/disinfectants contribute 4.3 tons 

per day VOC emissions, making this subcategory the largest source of 

emissions under the air freshener category. While these products may be 

used as surface disinfectants, the aerosol forms are often promoted as air 

fresheners to be sprayed into the air rather than on a specific surface. 

This product is discussed under Sections V.B. and VIII.E., which are both 

titled "Dual-Purpose Aerosol Air Freshener/Disinfectants." 

Product Content Formulation: The formulations and VOC content used in 

air fresheners vary widely with the product form. The VOC content ranges 

from an average of 3.5% for solid air fresheners to 96% for single phase 

aerosol products. 

Aerosol air fresheners are the highest VOC product forms. These 

formulations may be single phase or dual phase. The majority of aerosol air 

fresheners are dual phase products. According to the ARB survey these 

products have an average VOC content of approximately 40%. Dual phase 

products contain two liquid phases and a propellant. The liquid phases 

consist of a water phase and a solvent phase which contains a small amount 

of fragrance. The two phases are mixed when the product container is 

shaken, producing an emulsion that is sprayed. The solvent phase is 

generally made up primarily of liquid hydrocarbon propellant although other 

solvents may also be included in the formulation. The propellants are 

typically butanes and propane. As in most other aerosol products, the 

propellants in aerosol air fresheners are present in both a liquid and gas 

state. In the liquid phase the propellant functions as a solvent and 

reservoir to replenish propellant in the gas phase. The gas phase provides 

the pressure that expels the product. 

-25-
Single phase aerosol air freshener formulations average 96% VOC content 

according to the ARB survey .. These products contain a small amount of 

fragrance with the balance consisting of solvents and the propellant .. · Often 

the propellant in liquid form is the primary solvent although other solvents 

may also be included in the formulation. The propellants are typically . hydrocarbons such as butan~s and propane. 

Liquid air freshener formulations vary widely. The average VOC conten't 

according to the ARB survey is 20%. Formulations typically contain water, 

alcohols and other solvents, and fragrance. Some liquid air fresheners 

contain 100% fragrance. 

Solid air fresheners contain an average VOC content of 3% according to 

the ARB survey. These formulations typically contain water, various 

solvents, and a thickener such as silica. The solid "block" closet 

fresheners and toilet bowl fresheners often contain 100% 

paradichlorobenzene and a small amount of fragrance. Many other toilet bowl 

fresheners are ~omposed primarily of surfactants and fragrance. · 

Dual-purpose aer.osol. air freshener/disinfectant sprays are typicaliy" '"' 

composed of a large percentage of ethanol, hydrocarbon Or carbon dioxide 

propellant and water. Small amounts of disinfectant agents may also be 

added to the formulation. 

Product Use: Air fresheners are used in household, automotive, 

institutional, and commercial settings to treat unpleasant odors. This is 

accomplished by masking the odor with a pleasant scent or removing the oddr. 

While most air fresheners mask odors, a few claim to remove the offending odors by chemically reacting with them. 

Household air fresheners are used to treat bathroom and kitchen odors, 

pet odors, garbage odors, smoke, and odors caused by moisture. Common 

household products include aerosol sprays and solid or liquid products which· 

evaporate from a dispenser. Aerosol air fresheners, which make up the 

majority of the market, are generally sprayed as needed with the user 

controlling the amount of product emitted. Aerosol disinfectants that also 

function as air fresheners are either sprayed on specific surfaces such· as 

bathroom fixtures or in the air. ')' · 

Automotive air fresheners consist mainly of liquids. These products 

include paper and other materials soaked with the liquid product and small 

containers with wicks. 

. , '; 

Air fresheners are used in institutional and commercial settings to 

control odors from bathrooms, laundry areas, food preparation areas and 

specific industries such as diaper services. Most air fresheners used in 

this segment of the market are self-dispensing products with the product 

emissions generally controlled by the chemical and physical characteristics 

of the product as well as the ambient temperature and humidity. These 

products are described as "maintenance" air fresheners and are designed to 

maintain a constant scent over a long period of time. A number of products 

are available including mostly liquid and solid products. Some products are 

-26-
available within an enclosure with a fan to distribute the fragrance while 

others are designed to be placed in the ductwork of ventilation systems. 

Another common product is the solid toilet bowl fresheners used to deodorize 

bathrooms. Some specialized liquid products include a product designed to 

be added to cleaning solutions, a product that can be added to sewage 

treatment tanks, and a product designed to be sprayed after extensive fire 

damage to eliminate smoke odors. 

Manufactur;ng Process: The manufacture of air freshener products with 

liquid ingredients (aerosols, liquids and pump spray products) begins with 

the purchase and storage of chemical ingredients in bulk. The ingredients 

are generally added to stainless steel vessels where they are mixed. The 

ingredients are then transferred to individual containers on an automated 

filling line. Propellants are added to aerosol products during filling. 

Solid/gel products may be produced by a variety of methods. 

Health and Safety Concerns: Health and safety considerations include 

the effects of ingestion by infants and the inhalation toxicity of aerosol 

products. The closet fresheners and toilet bowl fresheners composed of 

paradichlorobenzene are of special concern since paradichlorobenzene is 

considered a possible carcinogen by EPA. 

Another concern is the storage and use of highly flammable aerosols 

such as single phase air fresheners. 

Recommended VOC Standard: Five separate VOC content limits have been 

established for air fresheners. Individual limits apply to the following 

categories: (1) single phase aerosols, (2) dual phase aerosols, (3) liquids 

and pump sprays, (4) solids and gels, and (5) disinfectant aerosol sprays. 

The limits are shown along with other information in Table 7 below. 

Two separate limits have been established for aerosol air fresheners. 

The proposed limits of 70% for single phase aerosols and 30% for dual phase 

products are both based on a CSMA proposal. According to the ARB survey, 20 

of the 65 dual phase aerosol products reviewed currently comply with the 

limit. No single phase product currently complies with the proposed 70% 

limit, but based on discussions with CSMA and the industry, reformulation to 

the limit is feasible. 

A future effective standard of 30% has been set for all aerosol air 

fresheners in 1996. Single phase aerosols contribute a disproportionately 

high amount of emissions based on their share of the market. This segment 

of the market could also possibly grow if not regulated. This limit will 

help to phase out the the high VOC single phase aerosol category and force 

technology to be developed that would allow for the production of a single 

phase aerosol at a lower VOC content. Based on discussions with industry 

representatives, technology is developing in this area and may allow for a 

30% single phase product to be marketed in the future. 

-27-
Product 

Form 

Aerosol-2 phase 

Aerosol-1 phase Liquid/Pump 

So 1 id 

Other 

TABLE 7 

Air Fresheners Standard Summary 

Proposed Number. of Percent of 

Standard Complying Market 

% voc Products Complying 

30 20 4 

70 0 0 

18 84 61 

3 33 98 

3* 9 84 

Emission 

Reduction 

TID 

0.38 

0.23 

0.17 

0.10 

0.06 

* It is assumed that most of the air freshener products under the "other" 

category actually fall under the "solid" category since 84% of the market 

comp 1 i es with the 3%. standard. Theref'Ore a 3% standard was used to 

calculate the emission reduction. 

The VOC limits for liquid and solid air fresheners at 18 and 3 percent· 

respectively, are based on the sales weighted average VOC contents from the 

survey. These limits are intended to bring the higher VOC products into 

compliance with the standard. 

An exemption from the VOC limits in the regulation has been provided 

for air fresheners containing 100% fragrance, less non-VOC's such as water. 

Staff is aware of products containing only fragrance both absorbed in inert 

materials and in liquid and pump form. Since the fragrances used generally fall under the VOC definition, dilution is the only direct means of ··· reformulation. Staff believes that simple dilution would not lead to emi~sion reductions. Since these concentrated products result in a minimum 

of emissions of nonfragrance VOCs, staff believes that these products may 

result in low overall emissions per application. Fragrances have been 

defined in the regulation as substances or complex mixtures of aroma 

chemicals, natural essential oils and other functional components with a 

combined vapor pressure not in excess of 2 mm Hg at 2d degrees Celsius, the 

sole purpose of which is to impart an odor or scent, or to counteract a · malodor. According to discussions with the fragrance industry, the· 

definition will include the majority of available fragrances while limiting 

the potential for inclusion of nonfragrance components to fragrances. 

An exemption has also been provided for air fresheners containing at 

least 98% paradichlorobenzene (PDCB). This exemption was provided for 

closet fresheners and toilet bowl deodorizers. We are not aware of a means· 

of reformulating these products since they are almost entirely composed of 

PDCB, a VOC. 

-28-
Compliance with the Standard: The primary method of complying with the 

regulation is expected to be replacement of VOC solvents with water or other 

exempt VOCs. In some cases, this may require other adjustments in the 

formulation. For instance, in the case of single phase aerosols, the 

introduction of water into the formulation may require that the hydrocarbon 

propellant/solvent be replaced by dimethyl ether. The exemption for 100% 

fragrance products may also encourage new designs. Also, the innovative 

products exemption may provide a means for the development of low emitting 

products that cannot meet the VOC content standard. 

B. DUAL-PURPOSE AEROSOL AIR FRESHENER/DISINFE"CTANTS 

Product Description: For the purposes of this regulation, dual-purpose 

aerosol air freshener/disinfectants are aerosol products that are claimed to 

clean, freshen or deodorize air SfiQ disinfect hard surfaces. Since these 

products are designed to kill certain microbes, they are classified by EPA 

under the general category of pesticides and registered under the Federal 

Insecticide, Fungicide and Rodenticide Act (FIFRA). This regulation does 

not apply to either aerosol products that QDly claim to be disinfectants or 

to any liquid products that are claimed to be air fresheners/disinfectants. 

Product Forms: The regulation applies only to the aerosol form of 

products which are claimed to freshen air and disinfect hard surfaces. The 

aerosol form of air freshener/disinfectants account for approximately 4.3 

tons per day of VOC emissions. 

Product Content Formulation: The major ingredient in dual-purpose 

aerosol air freshener/disinfectants is ethanol, comprising approximately 45% 

to 80% by weight of these products. The next largest fraction of the 

product weight is comprised of propellent (either hydrocarbon or compressed 

carbon dioxide), water and fragrances. Other ingredients found in small 

quantities may include certain active ingredients such as phenols (e.g., 

ortho-phenyl phenol) and quaternary ammonium compounds. Dual-purpose 

aerosol air freshener/disinfectants have a sales-weighted average VOC 

content of approximately 80% VOC by weight. 

Product Use: These products are used for their air freshening and 

disinfecting benefits. Ideally, these products should be used only when the 

transmission of health-threatening diseases through contact with hard 

surfaces is a major concern. However, ARB staff believes that consumers may 

be significantly misusing these products as air fresheners, a function for 

which there are many alternative lower-VOC products. It is important to 

note that these products are efficacious only when applied to hard surfaces. 

Spraying into the air does not "clean", "disinfect" or "purify" the air any 

more than regular air fresheners. 

Manufacturing Process: Staff has no specific data on the manufacturing 

process for this product category; however, staff expects the manufacturing 

process to be similar to those used for manufacturing other aerosol 

products. 

-29-
Health and Safety Concerns: The major safety concern with any aerosol 

is the flammability of that product. Therefore, flammability concerns that 

apply to other aerosol products also apply to dual-purpose aerosol air 

freshener/disinfectants. 

Industry representatives have expressed concern that the proposed standard 1 

of 60% VOC by weight would result in a reduced efficacy product. To addres~ 

these concerns, staff has prepared an analysis of the feasibility of .. -- limiting the VOC content of dual-purpose aerosol air freshener/disinfectants 

to 60% (See Issues, Chapter VIII). From this analysis, staff has determined 

that the standard of 60% VOC can be achieved while still allowing 

efficacious disinfectant products to be available to consumers.· 

Product Emhsions: The current estimate for emissions from dual-purpose. 

aerosol air freshener/disinfectants is 4.3 tons VOC per day. 

Recommended VOC Standard: Staff recommends a 60% VOC limit by weight for dual-purpose aerosol air freshener/disinfectants. Compliance with this 

standard will result in 1.1 tons VOC per day emission reductions. ~- ' 

Compliance .with the Standard: ARB staff believes that compliance with 

the standard could be achieved through at least four different options:. (1) 

sell, advertise and market these. products~ as hard surface disinfectants 

and not as air fresheners, in which case the product would not be subject to 

the standard, (2) reformulate the products to reduce the VOC content and us~ 

an exempt VOC or non-VOC propellent, (3) reformulate the products to redOce 

the VOC content and use it in a pump, and (4) redesign the products into an 

innovative package such that it emits fewer emissions. Of these, options 1, 

2 and 3 are believed to be the most cost-effective and easiest options to 

implement. Note that option 1 requires only a labeling and marketing 

change. The timeframe that is proposed in the regulation allows for 

additional time to reformulate and reregister the reformulated product under 

FIFRA. 

C. AUTOMOTIVE WINDSHIELD WASHER FLUIDS 

Product Description: Automotive ~indshield w~she~ fluid _means any 

liquid designed for use in a motor vehicle windshield washer fluid system for the purpose of cleaning, washing; or wetting the windshield(s). This 

definition does not include any fluid found in a new ~dtor ~ehicle at the 

time the vehicle is manufactured. 

Product Forms: Because the washer system is designed to spray the 

fluid onto the windshield(s) through a pump, windshield washer fluids are 

sold exclusively as liquids. 

Product Content Formulation: Methanol comprises the majority of the· 

VOCs found in washer fluids. A small fraction of the market is based on 

isopropanol. The remaining VOCs found in washer flUids ar~ detergents and 

possibly colorants. 

-30-
Windshield washer fluids are generally sold in two types of formulations: 

(1) "ready-to-use" requiring little or no dilution and (2) "concentrated" 

generally requiring some dilution by the consumer, the degree of dilution 

depending on the ambient temperatures to be encountered by the consumer. 

ARB's shelf survey revealed that ready-to-use formulations have VOC contents 

that generally range from 23% to 40% VOC by weight. The sales-weighted VOC 

content of ready-to-use fluids in California is believed to be 35% VOC by 

weight. Concentrated formulations typically range from 35% to 80% methanol 

by weight. 

Product Use: Windshield washer fluids are used to clean, wash, or wet 

windshields. The primary purpose of the methanol and isopropanol in washer 

fluids is to impart a freezing-point depression to the water used in the 

system, thereby preventing the water from freezing when low ambient 

temperatures are encountered. Methanol and isopropanol, like other organic 

materials such as the ethylene glycol found in engine cooling systems, 

provide freezing-point depression and boiling-point elevation to water in 

varying degrees, depending on the amount of organic material added to the 

solution. The methanol and isopropanol also provide some supplementary 

cleaning properties to the detergents to help clean insects and other soils 

from the windshields. 

Manufacturing Process: Methanol or isopropanol, along with the 

appropriate detergents and colorants, are mixed in a relatively simple 

fashion in varying ratios, according to the amount of freezing protection required. 

Health and Safety Concerns: Poisoning may occur from the inhalation or 

ingestion of either methanol or isopropanol. Ingestion of 100-250 

milliliters of either methanol or isopropanol is usually fatal. 

Since the methanol and isopropanol impart a freezing-point depression to 

water, concerns have been raised regarding the possible freezing of 

reformulated washer fluids if the organic content is too low. According to 

staff's analysis, the proposed standards should address these concerns 

adequately. First, the average VOC content of 35% by weight in currently 

available ready-to-use products is 'designed to provide freezing protection 

to -25 °F. This amount of freezing protection appears to be significantly 

greater than what is required in California's generally temperate climate. 

ARB staff's analysis of mean minimum temperature isolines provided by the 

Meteorology Section shows that approximately 97% of the state's population 

encounter mean minimum temperatures in January above 20 °F. Freezing 

protection to 20 °F would only require a 10% methanol by weight washer 

fluid. Thus, if we assume that washer fluid use is proportional to 

population, it appears that approximately 97% of the total volume of washer 

fluid used in California contains more VOC than necessary. This is the 

basis for the proposed 10% by weight VOC standard. 

For those areas where wintertime temperatures can be reasonably expected to 

stay below 20 °F for appreciable lengths of time, staff has proposed a 

-31-
standard of-35% VOC by weight. This standard would apply only to the 

counties in parentheses located within the following air basins: North Coast 

(Trinity, Del Norte), Northeast Plateau (Siskiyou, Modoc, Lassen), Mountain 

Counties (Plumas, Siskiyou, N~vada, Placer, El Dorado, Amador, Calaveras, 

Tuolumne, Mariposa), Great Basin Valleys (Alpine, Mono, Inyo) and the 

Sacramento Valley (Shasta County only). 

The application of the 35% standard only to these areas, which are the 

regions which are most likely to encounter ambient temperatures below 20 °F, 

would allow residents in these areas to maintain the freezing-point protection they currently have while allowing emission reductions elsewhere 

in the state. 

Product Emission*: Survey results from CSMA were not considered by 

staff to be accurate or representative of the windshield washer fluid market 

in California because of the insufficient response to the survey. Since 

these survey responses did not improve ARB's current emission estimates, 

staff assumed the emissions from the 1983 Emission Inventory were still 

correct, updated to 1988 levels. From the inventory, staff estimated that 

24 tons per day of VOC ~ere emitted in 19B8·from windshield washer fluids .. 

Recommended VOC Standard: Staff proposes to limit the VOC content for 

windshield washer fluids to 35% by weight in Type A Counties (listed 

previously) and 10% in all other counties. Theoretically, all windshield '. · washer fluids can comply with the standards either by: (1) using proper and 

clear dilution instructions on the label of the concentrated product and · distributing the fluids properly, or (2) reducing the amount of VOC in the 

ready-to-use products to the specified limits. Appendix C presents staff's. 

complete analysis and justification of the recommended standards for this 

product category. 

Compliance with the Standard: Since no major process modifications are 

involved, the 1/1/93 compliance date should be adequate time for industry to 

comply with the standards. Staff expects that most of the time required to 

comply with the standards will be in redesigning the product labels. 

D. BATHROOM AND TILE CLEANERS 

Product Description: Bathroom and tile cleaners are defined in the 

regulation as cleaners specifically for the bathroom. Included are both 

all-purpose bathroom cleaners and hard surface bathroom cleaners. 

Product Forms: Bathroom and tile cleaners are available in aerosol, 

liquid, pump spray and solid form. Collectively these products contribute 

-32-
0.45 tons per day VOC emissions to the atmosphere. Table 8 below breaks 

down the percentage of emissions from each product form. 

Product 

Form 

Aerosol 

Liquid 

Pumps 

Solids 

TABLE 8 

Bathroom and Tile Cleaners Emission Summary~ 

(Total Emissions 0.45 T/D) 

Percent of Emissions Percent of 

Market (TID) Emissions 

37 0.29 65 

48 0.13 28 

13 0.01 2 

2 0.02 5 

* Numbers may not add up to 100% due to rounding. 

Aerosol product forms such as foaming bathroom cleaners account for 

about 37 percent of the market, yet they contribute about 65% of the 

emissions from the bathroom and tile category. Liquid products including 

toilet bowl cleaners and liquid abrasives account for the majority of the 

market and about 28% of the VOC emissions from this category. Products 

available in pump or trigger spray forms, such as mold and mildew cleaners, 

contribute only about 2% of the emissions from the category due to low VOC 

content. Solid bathroom and tile cleaners make up a small segment of the 

market comprising about 2 percent of the market. 

Product Content Formulation: The bathroom and tile cleaner category 

contains a wide spectrum of products including cleaners containing sodium 

hypochlorite (bleach) for mold and mildew stains, acidic formulations to 

remove stains and scale from water hardness, abrasive formulations for hard 

surfaces and disinfectant cleaners. Many of these products also contain 

surfactants and solvents for general cleaning. 

Product Use: Bathroom and tile cleaners are used on tile, porcelain, 

and other hard surfaces on toilet fixtures, sinks, tubs and shower stalls. 

Aerosol and pump spray products are generally sprayed on, wiped, and rinsed 

away. Liquid products may be applied directly or wiped on. Solid products 

may include cleaning blocks that are placed in toilet tanks and abrasive 

powders that are rubbed on. 

Manufacturing Process: Most bathroom and tile cleaners with liquid 

ingredients are produced by transferring the ingredients in bulk to 

stainless steel vessels for mixing operations. In most cases, the 

ingredients are purchased from chemical companies, although some large 

companies may produce some of their own ingredients. Solid or granular 

-33-
products are produced by various specialized processes. The final product . is geherally introduced into t~e container on an automat~d~filling line. 

Propellants are added to aerosol products after the product "concentrate" is 

added to the container. 

Health and Safety Concerns: Health' and safety concerns include 

accidental ingestion by infants~ inhalation of aerosol or pump spray product ingredients, and eye and skin irritation. These concerns are especially 

important with highly acidic 6r caustic products, products with strong 

solvents, and disinfectant cleaners. 

A specific safety concern whenever cleaning products are used is the 

possibility of forming toxic chlorine gas when products containing chlorine 

bleach come in contact with acidic products or products containing ammonia. 

Recommended VOC Standard: The proposed VOC standard for bathroom and 

tile cleaners in all forms is 5 percent. According to the ARB consumer 

products survey, the average VOC content of bathroom and tile cleaners is 

about 3%. The sales-weighted average VOC content of liquid and pump spray 

bathroom and tile cleaners is well below the proposed 5% limit. According 

to the ARB survey, aerosol and solid forms both have sales-weighted average 

VOC contents of about 6%, just above the proposed limit. Table 9 summarizes 

the standard for bathroom and tile cleaners . 

. TABLE 9 

Bathroom and Tile Cleaners Standard Sllnmary 

Proposed . Number of Percent of Emission 

Product Standard Complying Market Reduction 

Form (% VOC) Products Complying TID 

Aerosol 5 5 7 0.05 

Liquid 5 35 88 0.05 

Pump spray 5 4 98 - 0 

Scil id 5 0 0 0.01 

Compliance with the Standard: The primary method df complyihg with 

the regulation is expected to be ~eplacement of VOC solvent~ with watet and' 

other exempt VOCs. In some cases, this may require other adjustments in the 

formulation. Also, the innovative products exemption may provide a means 

for the development of low emitting products that cannot meet the VOC 

standard. 

E. ENGINE DEGREASER 

Product Description: Engine degreasers are specialty cleaning products designed to remove grease, grime, oil and other contaminants from the 

external surfaces of engines and other mechanical parts. 

-34-
Product Forms: Engine degreasers are manufactured and marketed only in 

the aerosol form, thus, emissions in this category come from the use of the 

aerosol sprays and account for 100 percent of the total market and 100 

percent of the total emissions. Based on the ARB VOC Survey, VOC emissions 

from engine degreasers were 4.5 tons per day. The survey may not have 

reached all companies, therefore, the emissions may be underestimated. 

Product Content Formulation: Engine degreasers contain VOCs which are 

used as propellants and as solvents to dissolve the contaminants before they 

are rinsed away. Based on the survey, the VOC content ranges from 23 to 95 

percent by weight with most being above 80 percent. Engine degreasers may 

contain 1,1,1 trichloroethane, kerosene, petroleum distillates, xylene, 

water, chlorodifluoromethane (HCFC 22), butane, propane, detergents, and 

surfactants. The amount of propellant may be as high as 25 percent. Some 

products use non-hydrocarbon propellants such as carbon dioxide. 

The 1,1,1 trichloroethane, kerosene, xylene, and other petroleum 

distillates are solvents that are used to remove the grease, dirt, and other 

contaminants. HCFC 22, butane, propane, and carbon dioxide are propellants 

used to expel the ingredients from the container. The detergents are used 

as cleansing agents and the surfactants help to emulsify the grease and 

grime and prevent redeposition of the contaminants. 

Product Use: Depending on the product, the spray is applied on either 

hot or cold engines, and may be foamy. A 10 to 15 minute waiting period is 

required to allow the degreasing components to penetrate the contaminants. 

The contaminants are rinsed off with a water jet or hose. The engine is 

then started and allowed to idle for 10 to 15 minutes to assure drying. The 

process may be repeated if the engine is especially dirty. Engine 

degreasers are most commonly used on motor vehicles in a household or 

commercial fleet setting. Other cleaning uses include driveway and garage 

oil spots, charcoal grills, lawn mowers, marine engines and boats, 

industrial machinery, and other items that collect oil, grease and dirt. 

Manufacturing Process: Generally, each ingredient is weighed and added 

into a large vat. After the solution is thoroughly mixed, it is injected 

into aerosol containers by either of two processes, "under the cap" or 

"through the nozzle". 

Health and Safety Concerns: Current formulations contain petroleum 

distillates and aromatic solvents which are highly flammable. Many of these 

products need to be kept away from heat and direct sunlight and are to be 

used in well ventilated areas. In addition, prolonged contact with the skin 

should be avoided. There are some engine degreasers that are water-based 

which would reduce the flammability and health hazards. 

Recommended VOC Standard: The recommended VOC standard for engine 

degreasers is 75 percent beginning in 1/1/93. At least four products listed 

in the survey can meet the 75 percent limit. These products make up 2 

percent of the current market. Staff's contact with industry 

representatives indicate that water-based formulations are currently on the 

market which can meet the proposed limit. The estimated emission reductions 

-35-
are 0.93 tons per day in·1993. A future effective staridard of 5d% VOC is 

also being proposed for 1/1/96. At this VOC content level there are at 

least 3 products currently available that can meet the standard. , Manufacturers who do not have products that can meet the 50% limit have 

almost 6 years to develop and market a ·lower VOC engine degreaser. This 

future effective standard will achieve an additional 1.2 TID emission 

reduction by 1996. 

Compliance with the Standard: Information received by ARB staff 

indicate that reformulation to water-based products and the reduction or 

elimination of propellants is possible within the timeframe proposed in the 

regulation. The market share for complying products may increase as 

compensation for a decrease in the market share for non-complying products. Subsequently, noncomplying products may be reformulated and re-enter the 

market as complying products. In some of the products the VOC propellants 

have been replaced by compressed gases such as carbon dioxide. Alternative 

packaging such as hand pumps and the Airspray system are also available 

because a fine spray is not needed for a great majority of the cleaning 

jobs. In addition, there are a number of all purpose cleaners on the market 

which contain significantly lower amounts of VOC which may perform as well 

or better than the aerosol sprays. Furthermore, steam cleaning an engine is .. still possible. This method was the mbst widely used method before aerosol 

engine degreasers ·were marketed. This alternative is still available at a 

reasonable cost and eliminates the need for aerosol engine degreasers thereby eliminating VOC emissions. 

F. FLOOR POLISH (WAX) 

Product Description: Floor waxes and polishes are defined in the 

regulation as waxes, polishesj finish restorers or any other products fo~ 

the purpose of polishing, protecting or enhancing the surfaces of floors. 

Excluded are products only for the purpose of cleaning floors, sealants 

for unfinished wood floors or other products falling under district 

architectural coating rules, and industrial spray buff products. 

The vast majority of floor waxes ~nd polishes are used on flexible 

flooring materials such as vinyl and vinyl composite. These products 

include both "dry bright" products used mainly in households and products that must be buffed with a buffing machine. Products requiring buffing are 

typically used on flooring in institutions and business with heavy traffic 

such as supermarkets, department stores and hospitals. 

A small number of floor products are available for nonresilient flooring 

such as marble and for wood floors. 

Product Forms: Emissions from the floof polish category total 2.6 tons 

per day. According to the ARB consumer products survey, about 99% of the 

market is made up of products for use on nonwood surfaces, primarily on 

flexible flooring materials. These products contribute about 82~ of the 

emissions from the floor wax/polish category. Product for use on nonwood 

floors are primarily liquids although a few aerosol products are available. 

-36-
Liquids, solids, and other forms for use on wood floors make up less than 2% 

of the market, but contribute about 18% of the emissions due to high VOC 

content. 

Emissions estimates for wood and nonwood (flexible flooring material and 

nonresilient flooring) products were based on product descriptions and VOC 

content information in the ARB survey. Products with VOC contents in the 80 

to 100% range were assumed to be solvent based products for wood floors. No 

information was available to determine the emissions from nonresilient 

flooring. Therefore it was assumed that 10% of the emissions and emission 

reductions from nonwood floor products was contributed by product for 

nonresilient flooring, the remaining 90% from products for flexible 

flooring. Table 10 below summarizes the standards for the floor polish 

subcategories. 

Product 

Form 

Products for 

Flexible Flooring 

Products for 

Nonresilient Flooring 

Wood Floor Wax 

TABLE 10 

Floor Polish Emission Summary 

(Total Emissions 2.60 T/D) 

Percent of Emissions 

Market (TID) 

89 1.9 

10 0.2 

1 0.5 

Percent 

Emissions 

74 

8 

18 

Product Content Formulation: The majority of floor polishes are water 

based products designed for vinyl or other flexible flooring. These 

products contain primarily water with various polymers or waxes that 

form the final hard surface layer. A number of other ingredients are 

typically included such as solvent coalescing agents, plasticizers, 

defoaming agents, and preservatives. Floor polishes and waxes for 

nonresilient flooring such as marble, ceramic tile and terrazzo usually have 

similar formulations with a slightly higher solvent content. Wood floor 

waxes are solvent based formulations containing waxes and solvents such as 

mineral spirits. 

Product Use: The product typically used by the consumer is the "dry 

bright" type emulsion. This product is simply applied with a mop to a clean 

floor and allowed to dry. Commercial and institutional products designed 

-37-
for high traffic areas usually require buffing with a special buffing machin~ that produces a hard, shiny surface. 

Manufacturing Process: The manufacture of liquid floor polishes/waxes includes mixing and homogenization of the water, polymers, waxes, and other 

product ingredients in a stainless steel vessel. Homogeniiation is a 

process by which the solids in the product are broken down into fine . particles that do not separate out from the liquid ingredients, creating a 

stable emulsion. The final product is packaged on an automated filling 

1 i ne. 

Health and Safety Concerns: Little health risk has been 

identified in association with floor polishes or waxes. As with all 

consumer products, ingestion by infants is a potential hazard. 

Recommended VOC Standard: Three limits have been established for floor 

polish/wax, a 7% VOC limit for products used on flexible flooring, a 10% 

limit for products used on nonresilient ,flooring and a 90% limit for wood 

floor waxes. 

Floor polishes for flexible flooring such as vinyl make up the vast 

majority of the floor polish category. These products are almost entirely 

liquids with an average sales-weighted VOC content of about 5% according to 

the ARB survey. Aerosol floor polishes which make up only about 3% 

of the floor polish market, have an average VOC content of about 10%. We 

have not been able to locate any manufacturer of aerosol floor polishes.· 

The 7% standard was based on the 5% average VOC content in the ARB 

survey with some allowance for new technology polymers such as the 

replacements for the conventional zinc cross-linked polymers. According to informatio~ from Rohm and Haas, S.C. Johnson and others, the new technology polymers often require slightly higher concentrations of solvent coalescing 

agents, but have greater durability, allowing longer periods between 

recoating. 

Floor polishes for nonresilient flooring make up a minor segment of the 

market. According to industry contacts, a higher VOC limit is necessary for 

waxes and polishes used on sealed wood floors and nonresilient flooring such 

as brick, marble, ceramic tile, and concrete. Based on discussion with 

industry, a limit of 10% has been set for waxes/pOlishes used on thes~ 

surfaces. 

A limit of 90% has been set for wood floor waxes. These products are 

currently in the 80% to 100% VOC range. These products make up less than 2% 

of the floor polish/wax market. According to industry, these high VOC 

products are used exclusively on wood floors. According to discussions with 

industry, these products are especially important for use on unsealed or 

poorly sealed wood floors which may be damaged by water based products. 

There are currently architectural coating regulations in California that 

have a VOC content limit of 350 grams per liter for general sealers. This 

may indicate the possibility of lower VOC wood floor waxes in the future. 

-38-
However, we are not aware of any technology at the present time. Table 11 

below summarizes the proposed standards and emission reductions. 

TABLE 11 

Floor Polishes Standard Summary 

Proposed Number of Percent of Emission 

Product Standard Complying Marl<et Reduction 

Form (% VOC) Products Complying TID 

Products for 

Flexible Flooring 7 115 78 940* 

Products for 

Nonresilient Flooring 10 ** ** 100* 

Wood Floor Wax 90 5 100 - 0 

* Emission reduction data was not available for nonresilient floor 

products. It was assumed that these products made up 10% of the 

emission reduction from the nonwood floor products. 

**Data not available. 

Compliance with the Standard: The primary method of complying with the 

regulation is expected to be replacement of VOC solvents with water, exempt 

VOCs, and/or increasing the solids content. In some cases, this may require 

other adjustments in the formulation. 

G. FURNITURE MAINTENANCE PRODUCTS 

Product Description: Furniture maintenance products (FMP's) are defined 

in the proposed regulation as waxes, polishes, conditioners, moisturizers 

and other products designed for the purpose of polishing, protecting or 

enhancing finished wood surfaces. Excluded from the definition are floor 

polishes and waxes, which are covered separately by the regulation, and 

products only for the purpose of cleaning. 

Dusting aids make up a category of products similar to FMP's. Dusting 

aids are most often aerosol sprays that are applied to dust rags or floor 

dusting mops to aid in the removal of dust. A VOC standard has not yet been 

set for these products, however a standard may be established during the 

next update of the regulation. 

-39-
Product Forms: Furniture maintenance products are available as 

aerosols, liquids, pump sprays, and in paste form. Collectively, these 

products contribute 2.8 tons per day VOC emissions. Table 12 breaks down 

the market share and emissions from each product form. 

Product 

Form 

Aerosol 

Solid/Paste 

TABLE 12 

Furniture Maintenance Products Emission Summary~ 

(Total Emissions 2.80 T/D) 

Precent of Percent of 

Market Emissions Emissions 

72 2.44 87 

2 0.14 5 

All other forms** 26 0.22 8 

* Numbers include dustin~ aid products. These products could not easily be 

separated from the other FMP's in the survey. Therefore, numbers may be 

slightly off. 

**Products undet the "All other forms" category consist p~imarily of liquid 

and pump spray produ~ts. 

Aerosol spray products make up the majority of the market at about 72% 

and contribute about 87% of the emissions from the category. The "All other 

forms" category is made up primarily of liquids and pump spray products. 

These products make up an estimated 26% of the market. Due to low VOC 

content, these products contribute only about 8% of the emissions from the 

category. The solid or paste products make up only about 21 of the market 

and contribute about 5% of the emissions from the category. 

Product Content Formulation: The liquid contents of aerosol FMP's are 

typically in two phases. One phase contains the solvents, liquified propellants (which also act as solvents), oils, waxes and silicones, while 

the other phas~ ~ontains primarily water. The two phase products are shaken 

before use, producing an emulsion which is sprayed. The VOC content of 

aeroso1 FMP's is contributed by the solvents ind propellants (in_both gas and liquid form) such a~ propane and butanes. A s~all amount of fragrance·· 

and other agents may also contribute slightly to the VOC content. According 

to the ARB consumer products survey, the sales weighted average VOC content 

for aerosol products is about 27%. 

Paste furniture maintenan6e products hold only about a 1% share of the 

market according the ARB consumer products survey. These solvent based 

products contain waxes, with the balance consisting of solvents such as 

mineral spirits. The average VOC content of these products is 87% based on 

ARB survey. 

-40~ 
Liquid and pump spray products make up the "all other forms" subcategory 

in the regulation. These products are generally much lower in VOC content 

than their aerosol and paste counterparts. The ARB is aware of liquid and 

pump formulations in the 5% VOC range. According to the ARB consumer 

products survey, the sales weighted average VOC content is 5.6% for liquids 

and 7.3% for pump sprays. 

Product Use: Furniture maintenance products are applied to finished 

wood surfaces such as furniture, paneling, wood trim and cabinetry. Most 

aerosol and pump spray products are described as waxes or polishes and are 

designed to leave a shiny protective coating on wood. Liquid products 

are more often oil based products described as preservatives or 

moisturizers. Solid (paste) forms are rubbed onto the furniture surface, 

then wiped off after the paste dries. Some products are designed to perform 

more than one function. For instance, one product available in aerosol and 

liquid form is described as a wood cleaner and preservative. Dusting sprays 

are used to aid the removal of dust. These products also clean wood 

surfaces. 

Furniture maintenance products are emulsions that are either sprayed on 

the wood surface or applied with a cloth or pad. The product is then rubbed 

into the wood surface. During the wiping process the water phase is 

absorbed by the cloth while the solvent/wax/polish phase remains on the wood 

surface. The solvents eventually evaporate, leaving the wax/polish layer. 

Manufacturing Process: The manufacture of liquid furniture 

maintenance products involves the mixing of the water, silicones, waxes, and 

other product ingredients in a stainless steel vessel. The final product is 

packaged on an automated filling line. Propellants are added to aerosol 

products during filling. 

Health and Safety Concerns: Little health risk has been identified in 

association with furniture maintenance products. As with all consumer 

products, ingestion by infants is a potential hazard. 

Recommended VOC Standard: Volatile organic compound content limits have 

been set for two furniture maintenance product categories: aerosols and all 

other forms (liquids and pumps). Solid/paste products make up a very small 

niche of the market preferred by some consumers. These solvent based, high 

VOC forms have been exempted from the all other forms category. 

The average VOC content for aerosol FMP's based on the ARB survey is 

27%. A 25% limit was proposed by CSMA for this category with the exception 

of dusting aids. Based on this information, the limit was set at 25% for 

aerosol FMP's excluding dusting aids. The 7% limit for all other forms 

covers liquid and pump spray products. The limit is based on the salesweighted average VOC content of about 7% according to the ARB survey. Both 

limits are designed to require reformulation of the higher VOC products in 

-41-
each category. Table 13 below summarizes the proposed standards for the 

furniture maintenance products subcategories. 

TABLE 13 

Furniture Maintenance Products Standard Summary~ 

Proposed Number of Percent of Emission 

Product Standard Complying Market Reduction 

Form (% VOC) Products Complying TID 

Aerosol 25 22 21 0.41 

A 11 other 7 16 70 0.12 

forms** 

* Numbers include dusting aids although this product is exempt. Emission 

reduction figures may be slightly high. 

** Products under the "all other forms" category consist primarily of 

liquids and pump sprays. This does not include paste wax. 

Compliance with the Standard: The primary method of complying with the 

standards is expected to be replacement of VOC solvents with water, exempt 

VOCs, and/or increasing the solids content. In some cases, this may require other adjustments in the formulation. The innovative products exemption may 

provide a means for higher VOC products to comply with the regulation. 

H. GENERAL PURPOSE CLEANERS 

Product Description: General purpose cleaners have been defined in the 

proposed regulation as formulations designed for general, all-purpose 

cleaning. Specialty cleaning products for use in specific situations are 

not included in this category. Also excluded from the category are bathroom 

and t i 1 e c 1 ea.ners which are regu 1 a ted under a separate category. · · · · 

Product Forms: The general purpose cleaner category covers a wide 

variety of products. These products may be tategorized as liqui~s, 

aerosols, pump sprays, dissolvable powders and abrasive products such as 

scouring powders, creams and pads. These products contribute about 4.9 tons 

per day VOC emissions to the atmosphere. Market share and emissions 

information for each product form are provided below in Table 13. Liquid products make up the majority of the market at nearly 60~ and contribute 93% 

of the emissions from this category. Solid products, primarily powders, 

make up over 40% of the market but contribute only about 4% of the emissions 

from the category due to low VOC content. Aerosol products make up less 

than one percent of the market, but contribute about 5% of the emissions 

-42- . 
from general purpose cleaners. Table 14 is a summary of the proposed 

standards and emissions for general purpose cleaners. 

Product 

Form 

Aerosol 

Liquid/Pump 

Solids 

TABLE 14 

General Purpose Cleaner Emissions Summary* 

(Total Emissions 4.90 T/D) 

Percent of 

Market 

< 1 

59 

41 

Emissions 

(TID} 

0.03 

2.87 

2.0 

Percent of 

Emjssjons 

3 

93 

4 

* Numbers may not add up to 100% due to rounding. 

Product Content Formulation: Typical cleaning agents used in general 

purpose cleaners may be categorized as alkaline materials, surfactants, 

solvents and abrasives. Alkaline materials such as alkaline salts or 

builders perform many functions in cleaning formulations. They 

increase the efficiency of surfactants, prevent water hardness from 

combining with soils, help disperse and suspend dirt, saponify fatty or oily 

soils, maintain a desirable alkalinity, and aid in the removal of 

microorganisms. Surfactants (surface active agents) or soaps are used to 

lower water's surface tension, allowing cleaning solutions to penetrate sail 

more quickly. Surfactants also aid in the removal of soils, both fatty and 

particulate, and help keep them suspended so that settling back on the 

surface is minimized. Solvents such as glycol ether and pine oil are often 

included in formulations to dissolve greasy or oily matter. Water is the 

most widely used solvent. Abrasives are generally composed of small 

particles used to smooth, scour, rub, and clean surfaces by mechanical 

action. 

From the ARB consumer products survey, the average VOC content of all 

forms of general purpose cleaners is about 3%. The sales-weighted average 

VOC content for liquids, pumps, and solids is 4.0%, 5.6% and 0.2%, 

respectively. The average VOC content for aerosols is 18%. However, 

aerosols make up less than 1% of the market based on the ARB survey. 

The VOC content of general purpose cleaners is made up primarily by 

nonwater solvents such as petroleum distillates, pine oil and alcohols. 

Other agents such as fragrance may also add to the VOC content. At least 

one product contains a significant level of VOC due to an inorganic acid. 

While most products contain VOC levels below 10%, some products such as some 

pine oil cleaners contain higher VOC levels. 

-43-
Product Use: As the definition suggest~. general purpose cleaners are 

used for general, all-purpose cleaning as opposed to specialty applications. 

Liquid products are used either "straight" or diluted. These products are 

applied to many different surfaces, but especially to floors or other large 

surfaces with a mop, sponge or rag. Some scrubbing is usually required for 

the product to be effective. Rinsing may or may not be required after the 

use of these products. 

Pump sprays are used without dilution on countertops, appliances and 

other small surfaces. Generally, the product is sprayed onto the soiled 

surface and wiped up with a rag or sponge. Few aerosol general purpose 

cleaners are on the market. 

Solid cleaners include dissolvable powders and abrasive cleaners~ 

Powdered cleaners designed to be dissolved in water are usually applied to 

large surfaces such as floors. Abrasive cleaners are used on a wide variety 

of scratch resistant hard surfaces such as ceramic tile, bathroom fixtures, 

kitchen countertops, and some metal surfaces. Most abrasives are in powder form although pads made of soap-impregnated steel wool and oth~r materi~li' 

are also available. Abrasives generally require more rubbing than other 

cleaners since they work primarily by physical means. However, some 

abrasives do contain surfactants or other cleaning agents. 

Manufacturing Process: Most general purpose cleaners with liquid ingredients are produced by transferring the ingredients in bulk to 

stainless steel vessels for mixing operations. In most cases, the 

ingredients are purchased from chemical companies, although some large companies may produce some of their own ingredients. Solid or powder products are produced by various specialized processes. The final produc~ 

is generally introduced into the container on an automated filling line. 

Propellants are added to aerosol products after the product "concentrate" is 

added to the container. 

Health and Safety Concerns: Health and safety concerns include 

accidental ingestion by infants, inhalation of aerosol or pump spray product 

ingredients, and eye and skin irritatiqn. These concerns are especially 

important with highly acidic or caustic products, products with strong 

solvents, and disinfectant cleaners. 

A specific safety concern is the posJibility of forming toxic chlorine 

gas when products containing chlorine bleach come in contact with acidic 

products or products containing ammonia. Many prOducts have warning labels 

instructing consumers not to mix these products. 

Recommended VOC Standard: The proposed 10% VOC level is currently met 

by most general purpose cleaning products. The sales-weighted average VOC 

content levels for the liquid/pump and solid general purpose categories are 

6% and 0.36%, well below the standard. These product forms make up almost 

the entire general purpose category. Aerosol cleaning products have a 

sales-weighted average VOC content of 18%. However, these products make up 

less than 1% of the market. Also, half of the aerosol general purpose 

cleaners currently comply with the 10% standard. The 10% standard was set 

-44-
based on the survey information and CSMA's proposal of a 10% limit. The 

standard is intended to require reformulation of some of the higher VOC 

cleaning products. Table 15 summarizes the proposed standards and emission 

reductions. 

TABLE 15 

General Purpose Cleaners Standard Summary 

Proposed Number of Percent of Emission 

·Product Standard Complying Market Reduction 

Form (% VOC) Products Complying TID 

Aerosol 10 13 20 0.07 

Liquid/Pump 10 139 86 1.6 

Solid 10 8 -100 - 0 

Compliance with the Standard: The primary method of complying with the 

standard is expected to be replacement of VOC solvents with water or other 

exempt solvents. In some cases, this may require other adjustments in the 

formulation. Also, the innovative products exemption may provide a means 

for the development of complying products that cannot meet the VOC standard. 

I. GLASS CLEANERS 

Product Description: Glass cleaners are any specialty cleaning product 

designed primarily for cleaning surfaces made of glass. 

Product Forms: Product forms include aerosol and liquid/pump spray, • 

with market shares of 6% and 94%, respectively. There is also a relatively· 

new product available which consists of cloth wipes impregnated with glass 

cleaner. Table 16 is a summary of the proposed standards and emissions. 

Product 

Form 

Aerosol Sprays 

Liquid/Pumps 

TABLE 16 

Glass Cleaners Emission Summary 

(Total Emissions 2.3 TID) 

Percent of 

Market 

6 

94 

-45-

Emissions 

(TID) 

0.3 

2.0 

Percent of 

Emjssjons 

12 

88 
Total emissions from the product category are 2.3 tons per day. Emissions 

from the respective product forms are 0.3 tons·per day for aerosols and 2.0 

tons. per day for liquid/pumps. The emissions for liquid/pumps include .. concentrated products, representing approximately 2% of the liquid/pumps surveyed. No allowance was made for dilution when reporting the VOC content 

for the survey, however, the sales-weighted average VOC content for this 

product form was essentially unaffected by this due to the small portion 

represented by concentrates. 

Product Content Fomulation: The sales-weighted average VOC product 

content for aerosols is 13% and 6% for liquid/pumps. The typical combined 

VOC content for fragrance and colorant is less than 0.1%. Glass cleaners 

typically do not use fragrance, since the unmasked ammonia odor of the 

product is associated by the consumer with cleanliness. Blue and green dyes 

are often used, for color. 

Glass cleaners typically have a high water content, with short carbon 

chain alcohols such as isopropyl alcohol or ethyl alcohol used to dissolve 

oily soils, and surfactants to loosen soiL Mild alkalies such as ammonia 

are sometimes added as a cleaning booster. There are also acid-based 

formulations containing vinegar as the cleaning agent, which .is not as 

efficacious as ammonia, and therefore has a higher solvent (VOC) content to . boost the efficacy. The propellant in the aerosol form is typically an 

isobutane/propane mixture, and mixes with the product to produce a foam. 

The propellant comprises 3% to 7% of the total VOC content in the product. 

For concentrated liquid glass cleaners, dilution ratios (product to water) 

are usually 1:2 or 1:6. 

Product Use: The primary use is in the household, with some 

institutional and commercial use. The specific market shares for these are 

not currently known. The product can be applied by aerosol, pump, or hand 

wiping, and is then wiped off. Advantages of the aerosol form include 

better visibility of the product on the glass, so the consumer can more· 

easily see what remains to be wiped off, and better adhesion of the product 

to the glass due to the foam produced by the propellant. There are also 

claims that it takes a lesser amount of an aerosol form than a pump form to 

clean the same surface area of glass. 

Manufacturing Process: The product is made using a "wet blending" 

process, with no heat used. The product is blended in large mixing tanks, 

adding the ingredients in specific order, letting them dissolve, and then 

mixing them together. No production changes are foreseen due to the effect 

of the regulation. 

Health and Safety Concerns: The alcohols contained in glass cleaners 

are irritants to the skin and eyes. If using the product with prolonged 

exposure, wear gloves, and if handling in large quantities, wear goggles. 

Recommended VOC Standard: The current proposed standard being recommended for this category is 6%. This standard was selected based on 

the VOC survey data submitted by industry and chosen such that complying 

products in both the aerosol and liquid/pump forms would be available, yet 

-46-
still achieve emission reductions. Industry had requested a 10% standard, 

stating that the 6% standard would essentially ban the aerosol form, 

however, the 6% standard will in fact allow all product forms to remain on 

the market. Estimated emissions reductions for glass cleaners, based on 

this standard, are 0.61 tons per day. Table 17 is a summary of the proposed 

standards and emission reductions. 

TABLE 17 

Glass Cleaners Standard Summary 

Proposed Number of Percent of Emission 

Product Standard Complying Market Reduction 

Form (% VOC) Products Complying T/D 

Aerosol Sprays 6 6 8 0.15 

Liquid/Pumps 6 26 73 0.46 

Compliance with the Standard: Compliance can possibly be achieved 

through lowering the alcohol (solvent) content and modifying the surfactant. 

To avoid streaking problems, other changes to the formulations, such as the 

type of surfactant may need to be made. 

J. HAIRSPRAY 

Product Description: Hairsprays are consumer products designed 

primarily for dispensing droplets of resin (film forming polymer) on and 

into the hair coiffure (hair style) to enable users keep their hair in 

position for a period of time, unaffected by the weather and atmospheric 

humidity. 

The key ingredient in all hairsprays is the resin. The holding of the 

hair is carried out by a spot welding of one hair to another. When the 

product is sprayed on the hair, it collides in the form of droplets. The 

volatile nature of the droplet allows it to dry rapidly, and create an 

invisible bond to the hair and its neighbor. Hence, the resin must have good 

adherent strength. Its adhesive quality must be such that it can be readily 

removed by shampooing, i.e., water soluble. 

Product Forms: Hairspray products are packaged in aerosol or pump form. 

The market shares for aerosol and pumps are 74 percent and 26 percent 

respectively. The current estimate for emissions from aerosol and pump 

hairspray products is 46 Tons/Day. Aerosol hairspray emissions are 36.8 

Tons/Day and pump hairspray emissions are 9.2 Tons/Day. Table 18 summarizes 

the emissions from the various product forms. 

-47-
Product 

Form 

Aerosol 

Pump 

TABLE 18 

Hairspray Emissions Summary 

(Total Emissions 46.0 TID) 

Percent of 

Market 

74 

26 

Emissions 

(TID) 

36.8 

9.2 

Percent of 

Emissions 

80 

20 

Product Content Formulation: The sales weighted average VOC content for 

hairspray formulat,ions currently available is 94% for aerosols and 70% for 

pumps. (Heiden Associates) 

The key ingredients in hairspray formulations are: resins, solvents, 

propellants (aerosol only), neutralizers, co-solvents, plasticizers and. 

other additives. 

The active ingredient in all hairspray formulations, which holds the 

shape of the hair, is the resin (film forming polymer). There are many resins employed in today's hairspray _formulations including 

polyvinylpyrrolidone (PVP), methyl vinyl ether-malate anhydride copolymer· 

(PVM-MA), polyvinylpyrrolidinone-co-vinyl acetate (PVP-VA), Gantres ES · resins, Amphomer and Resyn 28-1310 & 28-2930. Since most hair fixative 

resins contain carboxyl groups, neutralizers are a major component in 

hairspray formulations. The neutralizer acts to adjust the solubility of 

the resin in both the alcohol vehicle and for shampoo removal. Some examples 

of neutralizers are: morpholine, 2-amino-2-methyl-1-propanol (AMP), 2-amino2-ethyl 3-propanediol (AEPD). · 

Solvents are used to carry the film (resin) onto the hair, and then 

evaporate to leave the film behind. Ethanol is used exclusively in the 

United States as the major solvent in hairspray formulations. Other 

solvents include: isopropyl alcohol, propylene glycol, glycol ethers and 

water. · 

Aerosol hairsprays contain propellant. The purpose of .the propellarit is. 

to deliver the active ingredients to the hair. Today's propellants are . generally a blend of butane and propane. The ~ost common blend is an·~o/20 · mix. of isobutane and propane. Another propellant that has found wide 

acceptance in the European hair care market iS dimethyl ether (DME). DME 

can be used in formulating water-based hairsprays, which are becoming 

increasingly popular. The solubility of hydrocarbon propellants in a 

hydroalcoholic system limits the amount of water that can be used, but DME 

shows very good solubility in water and alcohol. 

Co-solvents many uses include: reducing the flammability rating of the produtt~ reduce the vapor pressura of the propellant or reduce the cost in 

some formulations. Examples of co-solvents are: dimethyl ether (DME), 

methylene chloride and water. Because of toxicity concerns, the FDA has 

-48-
prohibited the use of methylene chloride in hairsprays. This ban became 

effective August 28, 1989. 

Plasticizers are added to modify hardness and the degree of flexibility 

of the resin film. Some commonly used plasticizers are: dimethyl phthalate, 

diethyl phthalate and acetyl triethyl citrate. 

Other additives used such as silicons, lanolin derivatives, various 

oils, and protein hydrolyzates improve appearance or feel, ease of combing, 

rewetting properties, water sensitivity and ease of removal. 

Product Use: Hairsprays are for personal use, although they are also 

used in commercial establishments such as hair styling salons. The primary 

reason for using hairspray is to enable users to maintain a desired hair 

style for a period of time. It can be applied by aerosol or pump form 

directly to the hair coiffure. 

There are different formulations for hairspray users. The types range 

from soft to hard to hold formulas. The degree of hold is controlled by the 

amount of resin present in the formula. The resin employed and its level, 

together with the propellant ratio (if aerosol), solvent, valve design and 

other additives determine the performance of the hairspray, and the 

properties it confers to the hair. 

A test used by manufacturers to determine the ability of a hairspray 

formulation to "hold" a curl is determined by a curl retention test. This 

test evaluates the ability of a formulation to hold a curl under conditions 

of high humidity. This procedure uses hair swatches of a consistent length 

and weight which are rinsed with water, uniformly curled on mandrels and 

dried. The curls are removed from the mandrels and treated with a 

formulation. Swatches are then suspended by clamps on vertical, graduated 

boards which are placed in a humidity chamber maintained at constant 

temperature and humidity. Periodic curl length measurements are then 

recorded and percent curl retention values are calculated. Curl retention 

charts give a graphic representation of the percentage of curl retention 

versus time in hours. There is no standard procedure for curl retention 

tests, so procedures will vary. Curl retention tests are one method of 

measuring product efficacy. The swatches are also evaluated in the areas of 

stiffness, compatibility, flaking, gloss and static charging. 

Manufacturing Process: Manufacturing processes vary, but usually 

involve a mixing process while adding the various contents. 

Health and Safety Concerns: The solvents, propellants and other 

ingredients contained in hair spray are skin and eye irritants. Inhalation 

of hairspray particles are of concern. A particle le~s than ten microns in 

diameter is respirable. The percentage of particles which are smaller than 

five microns varies in each product. Pump sprays can have droplets as small 

as aerosols, but the proportion of particles may be less. Some individuals 

who have been repeatedly exposed to hairspray have developed respiratory 

ailments. It is recommended to use hairspray products in well ventilated 

areas. 

-49-
Reconmended VOC Standard: The standard being recommended for this 

category is 80 percent VOC content by weight for aerosols and pumps. Based 

on ARB product surveys and industry contacts, an 80 percent VOC content by 

weight is commercially and techno logically feas i b 1 e. There are at 1 east 

666hairspray formulations currently available on the market (pump & aerosol) 

that have VOC contents below the recommended standard, but these represent ·a 

small percent of the hairspray market. The total estimated emission 

reductions for aerosols and pu~ps ~ith an 80 percent VOC content by weight 

is 7.2 Tons/Day. In addition, a future effective standard of 55% VOC is 

being proposed for January 1, 1998. According to the ARB VOC survey, there 

are at least 30 hairspray formulations that are currently available that can 

meet this future standard. This future effective standard will result in an 

additional 12 T/D emissions reduction by 1998. A summary of the proposed 

standard and the complying prodocts is presented in Table 19 below. 

TABLE 19 

Hairspray Standards Summary 

Proposed Number of Percent of Emission 

Product Standard Complying Market Reduction 

Form (% VOC) Products Complying TID 

Aerosol 80 25 2 6.4 

Pump 80 41 32 0.8 

Aerosol(1998) 55 6 < 1 9.6* 

Pump (1998) 55 24 24 2.5* 

* Represents additional emission reductions in 1998. 

Compliance With The Standard: Information received by the ARB staff 

indicate that compliance with the recommended standard is feasible within 

the time frame proposed in the regulation. The 80% VOC content has been 

suggested by industry as a feasible limit providing the innovative product 

provision is contained in the regulation. Compliance with the standard 

could be achieved through product reformulation or through modifications to 

the hairspry product that would allow for an inMovative product exemption. 

The May, 1990 issue of Aerosol Age, has aerosol hair spray formulations that 

have water content levels ranging from 30 to 68 percent. Increasing the 

water content in the formulation and using DME (Dimethyl ether) as a 

propellant may be one method of complying with the standard. The major advantage of using DME is its high degree of water solvency. This permits 

the formation of aqueous single phase solutions, which are difficult to 

achieve with other propellent systems. In containers constructed of tinplated steel, a corrosion inhibitor and removal of the air from the aerosols 

headspace may be required in aerosols that have a high water content. Many 

pump sprays are constructed of Plastic, and this may be one way bf avoiding 

container corrosion. Other alternatives include: compressed gases 

-50-
(nitrogen, carbon dioxide & nitrous oxide), self generating carbon dioxide 

can and elasticized bag in the can. Valve design will also play an 

important role in the reformulation of aerosol and pump hairspray products. 

Increasing transfer efficiency through valve design will decrease overspray, 

and deliver more product to its intended target (less product is wasted). 

Current market trends would seem to indicate that in the 1990's there 

will be greater use of styling products, and a change in the way we use hair 

care products. Communication with industry representatives have 

revealed that perms are dying out with the younger generation, and styling 

products are becoming more important. Styling will be done using liquid 

styling products, as opposed to blow dryers. Consumers are starting to use 

a mix of products and they prefer the softer not the stiff or crisp look. 

There will likely be more styling gels and fewer finishing sprays. One 

industry representative feels the move will be toward hydroalcoholic systems 

first, with lower and lower levels of alcohol, eventually getting, with 

advances in technology, to water-based products. 

The staff is proposing a 55% VOC future effective standard for 

hairsprays with a compliance date of January 1, 1998. Information received 

by the ARB staff indicate that technology is already being developed to 

comply with the future limit. Also, information supplied by the survey 

indicates that there are 6 aerosol and 24 pump hairsprays currently on the 

market that can comply with the 55% standard. One product recently 

introduced to the California market has a VOC content below 40 percent. 

This product utilizes a water based resin and dimethyl ether propellant. 

Also, in the May and August 1990 issues of Aerosol Age, an industry trade 

journal, several hairspray formulations were listed with VOC contents 

ranging from 32% to 70% VOC. The accompanying descriptions for one of the 

formulations stated that the new resin allows tack free drying even when 

dispensed from a 100% aqueous solution. It can be used with hydrocarbon or 

DME propellants, pentane and water. 

K. HAIR MOUSSE 

Product Description: Hair mousse is a hair styling foam which 

facilitates styling of a coiffure and provides limited holding power. 

Product Forms: Hair mousses are available in aerosol form only. The 

current estimate for emissions from aerosol hair mousse is 0.6 tons per day. 

Product Content Formulation: The sales weighted average VOC content of 

hair mousse is 11.8 percent. The basic components of the aerosol styling 

mousse are: solvent, propellant, emulsifier, conditioner and polymer. 

The solvent base for these products is water containing a certain amount 

of alcohol (hydralcoholic). Typical alcohol contents lie in the range of 

10-15 percent. The solvent can also be water alone. 

-51-
The propellant normally used is a propane/isobutahe mixture at a· level 

of 5-15 percent. The proportions of the blend must be shift~d in favor of 

the more volatile propane, in order to obtain the lighter, l~Ss dense foam.· 

The emulsifier is one of the most critical materials in the mousse. An 

emulsifer must i~sure a g~od dispersion of propellant in the concentrate and 

good foam formation with the valve actuation. It must provid~ initial .. stability upon application of the foam to the p~lm of the hand, and collapse 

when worked into the hair. 

The incorporation of a conditioner, such as Solulan 16 or Glucams 

imparts desirable properties to the hair. These ethoxylates contribute to 

wet and dry comb, luster and feel, reduce flyaway and enhance foam 

stability. The Glucam type derivatives are effective additives for moisture 

retention and foam wetting. 

The polymer can be considered the active ingredient in the mousse 

formulation. The polymer should give the desired hold and yet leave the 

hair with a soft, natural feel. 

Product Use: Hair mousses are for personal use, although they are also 

used in commercial establishments such as hair styling salons. They provid~ 

setting and/or conditioning benefits to the user~ One reason for hair 

mousse popularity is the ease of application. 

A hair mousse is applied by first discharging the foam into the palm of 

the hand an amount indicated by the directions. The stiff foam retains its:. 

shape, making measurement easy and fairly precise. The foam is then spread evenly through the towel dried, shampooed hair before combing and styling by 

any conventional technique (rollers, blow-waving, finger drying, etc.). 

One of the main advantages that aerosol mouss~ offers is that it can be 

applied on dry or wet hair. It also allows the hair to be recombed or 

restyled several times without a repeat application. 

Manufacturing Process: Manufacturing processes vary, but usually involve a mixing process while adding the various ingredients prior to 

filling the ~erosol container. ' ' ' 

Health and Safety Concerns: The solvents and propellants contained in 

hair mousses are skin and eye irritants. Since hair mousse is applied as a 

foam, the risk of inhalation is reduced. 

· Reconrnended Standard: The standard being proposed for this category is 

16 percent VOC content by weight. Based on ARB product surveys and industry 

contacts, a 16 percent VOC content by weight is feasible. There are 66 

products currently available on the market that meet or exceed the 

recommended standard. The total estimated emission reductions for hair 

mousses with a 16 percent VOC content by weight is 0.03 tons per day. 

Compliance With Standard: Information received by the ARB staff 

indicate that compliance with the recommended standard is feasible within 

-52.;. 
the timeframe proposed. Compliance with the standard could be achieved 

through product reformulation. Increasing the water content and eliminating 

the alcohol does have its obvious cost benefits, but may affect the "hold." 

This, however, could be compensated by increasing the resin level or by 

modifying the type of resin used. 

L. HAIR STYLING GEL 

Product Description: Hair styling gel is a high viscosity, (often 

gelatinous) substance containing a fixative that is applied to the hair to 

aid in styling and sculpting of the hair coiffure. 

Product Forms: Hair styling gels are packaged in pump and liquid/gel 

form. The estimated emissions from pump and liquid/gel is 0.02 and 0.38 

Tons/Day respectively. Table 20 is a summary of the emissions from hair 

styling gels. 

Product 

Form 

Pump 

Liquid/gel 

TABLE 20 

Hair Styling Gel Emissions Summary 

(Total Emissions 0.40 T/D) 

Percent of 

Market 

4 

96 

Emissions 

(T/D) 

0.02 

0.38 

Percent of 

Emissjons 

5 

95 

Product Content Formulation: The sales weighted average VOC content for 

hair styling pumps and liquid/gels is 15.9% and 10.5% respectively. 

A basic hair styling gel contains at least nine ingredients: water, hair 

fixative polymer, gelling agent, neutralizing base, nonionic surfactant, 

fragrance, preservative, ultraviolet screen and chelating agent. When the 

solvency power of the water is insufficient, SO alcohol may be added to the 

formulation. 

The hair fixative polymer is a film forming resin which is soluble in 

the gel solvent (usually water or dilute aqueous alcohol). The polymer must 

dry quickly, with no residual tacky feel, to give a cohesive film with 

adequate adhesion to the hair. 

Hair styling gels are almost exclusively thickened by carbomer resins 

(gelling agent). Carbomer 940 is generally preferred for its rheology and 

crystal clarity which it confers on the gel product. Other carbomer resins 

may be used, but they do not offer the same benefits as carbomer 940. 

-53-
Fragrances used in hair styling gel are oils which are insoluble in 

water. If these oils are not .solubilized in the water, the oil droplets 

would separate from the continuous gel phase and this would cause the gel to 

lose clarity. The fragrances may be solubilized by a suitable noni6ni~ 

surfactant. The amount of surfactant required depends on the formulat1on. 1 

Methylparaben, propylparaben, DMDM hydantoin, imidazolidinyl urea, 

quaternium-15, methylchloroisothiozolinone and methylisothiazolinone are 

all found as preservatives in commercial hair styling gels. 

Carbomers are degraded by ultraviolet light, and in the absence of a UV 

screen, the gel would progressively lose viscosity upon storage in day light. To prevent the loss of viscosity, an ultraviolet screen is added to 

the formulation. Trace amounts of transition metal ions, particularly iron, 

also causes a reduction in viscosity. The chelating agent is added to 

stabilize the product from viscosity loss. 

Product Use: Hair styling gels are for personal use, although they are 

also used in commercial establishments such as hair styling salons. This 

product confers hair holding properties and provides some degree of 

conditioning. The hair styling gel is applied by placing a small amount 

onto the hand and then massaging it into the hair. The main advantage of 

hair styling gels is that it allows the user to apply it to wet or dry hair, 

and it allows the hair to be recombed or restyled several times. 

Manufacturing Process: Manufacturing processes vary, but usually 

involve a mixing process while adding the various contents. 

Re.conrnended VOC Standard: The standard being recommended for this 

category is 6 percent VOC content by weight for all forms. Based on ARB 

surveys and industry contacts, the recommended standard i.s feas i b 1 e within 

the timeframe proposed in the regulation. The proposed standard of 6 

percent would eliminate current pump forms, but industry contacts have 

suggested that these forms are really hairspray products that are labeled as 

gels for marketing purposes. The pump forms are modified hairspray 

formulations, not as viscous as hair styling gels, and are intended to be 

used as a hair styling product. There are 58 products in the liquid/gel form currently on the market that meet or exceed the recommended standard. 

The estimated emission reductions for this category with 6 percent VOC 

content by weight is 0.28 tons per day ... A summary of the proposed standard 

and the complying products is presented in Table 21 below. 

TABLE 21 

Hair Styling Gel Summary 

Proposed Number of Percent of Emission 

Product Standard Complying Market Reduction 

Form (% VOC) Products Complying TID 

Pump 6 0 0 0.01 

Liquid/gel 6 58 73 0.26 

-54-
Compliance With The Standard: Information received by the ARB staff 

indicate that compliance with the standard is feasible within the timeframe 

proposed in the regulation. Compliance could be achieved through product 

reformulation. Increasing the water content or using other exempt VOCs in 

the formulation may be one method of complying with the standard. Another 

would be the reduction, substitution or elimination of propellants in 

aerosol formulations. 

M. INSECT REPELLENT 

Product Description: For the purposes of this regulation, "insect 

repellent" shall apply only to those products which are used on humans. 

Insect repellents are classified under the general category of pesticides 

which are registered under the Federal Insecticide, Fungicide and 

Rodenticide Act (FIFRA). Insect repellents do not kill insects; rather, 

they prevent biting insects such as mites, chiggers, deerflies, and 

mosquitos from making contact with human skin or clothing. 

Product Forms: Insect repellents come in a variety of forms: aerosol 

sprays, pump sprays, liquids, creams, lotions, gels, sticks, towlettes and 

foams. Of these, the California market for insect repellents is dominated 

by aerosol and pump sprays. Table 22 is a summary of the emissions from 

insect repellents. 

Product 

Form 

Aerosol 

Liquid/Pump/Cream 

Solid (Stick) 

Other 

* < = less than 

TABLE 22 

Insect Repellents Emissions Summary 

(Total Emissions 0.45 TID) 

Percent of 

MarKet 

91 

8 

< 1 

< 1 

Emissions 

(TID) 

0.45 

< 1* 

< 1 

< 1 

Percent of 

Emjssjons 

99.0 

< 1 

< 1 

< 1 

Product Content Formulation: In the majority of current insect 

repellents, the main active ingredient is N,N-diethyl-m-toluamide. In at 

least one product, the main active ingredient is 2-ethyl-1,3-hexanediol 

(Rutgers 612). However, this ingredient is believed to be less efficacious 

at repelling insects than is DEET and will probably be phased-out gradually. 

Insect repellents based on R-11 (2,3:4,5-Bis (2-butylene) tetrahydro-2-

furaldehyde), were recently pulled off the market because of health ans 

safety concerns. With the decreasing use of Rutgers 612, it is expected 

that the dominant active ingredient for at least the next five years will be 

DEET. Other ingredients found in small quantities in insect repellents 

-55-
include: synergists such as MGK 264~ ~hich help to improve produ~t efficacy; resins such as Carbopol 934 (for use in gels and creams); aMd antioxid.hts 

such as butyl a ted .. hydroxyl to 1 uene. 

For aerosol spray rep~llents, there ~re two types of for~ulations: 

solvent-based and water-based. Solvent-ba~ed formulations contain mostly 

DEET, hydrocarbon solvents and propellents, with various other organics found in small quantities. The hyd~ocarbon solvents are usually some type 

of alcohol or alcohol-like isoparaffinic petroleum distillate (e.g. isopropanol or Isopar E). Hydrocarbon propellents used in repellents are 

usually isobutane or an isobutane/propane mixture. Water-based aerosol 

spray repellents contain the same types of propellents and solvents as in 

solvent-based repellents but in smaller quantities, making up the remainder 

of the formulation with water. As a category, aerosol spray insect . repellents have a sales-weighted average ·voc content of 95% VOC by weight 

for solvent-based formulations and 15% VOC by weight for water-bas~d 

formulations, respectively. .,., 

Liquids, pumps and creams comprise the next largest group of insect .. repellents. These products tend to be highly contentrated products ~f D~El, 

with many products.~omprised entirely of 100% DEET. These concentrated · products usually are marketed for people who spend a great deal of time 

outdoors (e.g~ hunters, lumberjacks). 

Sticks·, gels, towlettes and foams are relatively rare in California. 

These products do not have a significant share of the market and are not 

expected to increase their share in California dramatically within the near 

future. 

Product Use: Insect repellents are for personal use. They contribute 

to the comfort and safety of people who live, work or play outdoors. They 

are used to help prevent the transmission of diseases such as Lyme's 

disease. The produtts are either applied directly to the skin and clothes 

or are applied to the hands and spread onto skin and clothing. 

Manufacturing Process: Staff has no specific data on the manufacturing 

process for this product category; however, staff expects the ma~ufacturing 

process to be similar to those used for manufacturing other aerosol, pump~' 

cream, solid and towlette productS.· 

- Health and Safety Concerns: The- major safety concern with an aeros'ol 

insect repellent is the flammability of the product. Flammability concerns 

that apply to other aerosol products also apply to aerosol inset£ 

repellents. However, there have been only rare cases where aerosol 

repellents caused damage when applied near a flame (e.g., campfire). Staff_ 

expects the water-based aerosol products to have reduced flammability potential because of the water content. 

Insect repellents based on DEET have been used sucessfu1ly for many 

years. Only recently have there been cases where over-application of the 

product has resulted in adverse reactions, especially in children. Because 

of this~ industry representatives have expressed the desire to formulate 

-56- ' 
lower-DEET products to avoid applications of high levels of DEET. From 

discussions with industry representatives, ARB staff believe that the 65% 

limit on VOC in aerosol repellents can be met while satisfying current 

health concerns. 

Product Emissions: The current estimate for emissions from the insect 

repellent category is 0.45 tons/day. Staff has high confidence in this data 

since all of the major insect repellent marketers responded to the survey. 

Recommended VOC Standard: Since aerosol insect repellents account for 

approximately 99% of the emissions from this category, staff elected to set 

a VOC limit only for the aerosol products. Staff recommends a 65% VOC limit 

by weight for aerosol insect repellents. According to the survey responses, 

there are at least four aerosol repellents that currently meet this 

standard. Compliance with these standards will result in 0.13 tons VOC per 

day emission reductions. Table 23 summarizes the proposed standards and 

emissions reductions for various product forms. 

TABLE 23 

Insect Repellents Standard Summary 

Proposed Emission 

Product Standard No. Complying Percent of Reduction 

Form % voc Products Market Complying (TID) 

Aerosol 65 4 32 0.13 

Compliance With The Standard: Compliance with the standard could be 

achieved through product reformulation. The timeframe that is proposed in 

the regulation allows for additional time to reformulate and reregister the 

reformulated product under FIFRA. 

N. LAUNDRY PREWASH 

Product Description: Laundry prewash means a specialty product that is 

applied to a fabric prior to laundering and that supplements and contributes 

to the effectiveness of laundry detergents and/or provides specialized , performance. 

Product Forms: Laundry prewashes are sold in aerosol, pump, liquid, and 

solid product forms. Results from the survey show that emissions for 

laundry prewashes are 2 tons per day. Liquids and pump sprays account for 

most of the market share (85%) and almost half of the total emissions. 

Table 24 below summarizes the market share and percent of total emissions 

for the product forms. 

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Product 

Form 

Aerosols 

Pumps 

Liquids 

Solid Sticks 

TABLE 24 

Laundry Prewash Emissions Summary 

(Total Emissions 2 TID) 

Percent of Emissions 

Mark,et (T/D} 

14 1.04 

55 0.51 

30 0.38 

1 0.07 

Percent of 

Emissions 

52 

26 

19 

4 

Product Content Formulation: Results from the survey showed the VOC 

content for aerosols.ranged from 21% to 74% by weight with a sales weighted 

average of 35%. For liquids, the VOC content ranged from 0.2% to 63% and a 

sales weighted average of 4%. Only one manufacturer submitted data for 

pumps. The sales weighted average is 6%. For solid sticks, the VOC content 

ranged from 5% to 36% with a sales weighted average of 24%. 

Laundry Prewash formulations generally contain surfactants, so~vents, 

whitening agents, propelleants (aerosol forms), proteolytic enzymes and 

fragrances and dyes. 

Nonionic surfactants (e.g. alcohol polyglycol ethers, fatty acid 

ethanolamides, fatty acid esters), as the name implies, contain neither 

positively charged or negatively charged functional groups. Nonionic 

surfactants ha~e favorable detergency properties which are derived largely 

from having low micelle concentration, very good detergency performance, and 

soil antideposition characteristics with synthetic fibers. They are 

particularly effective in removing oily soil and some function as form 

boosters. Anionic surfactants (alkylaryl sulfonates) may also be used to 

solubilize the active ingredients in the liquid. 

Hydrocarbons and halogenated hydrocarbons (e.g. naphtha, . perch 1 oroethyl ene, 1,1, 1-tr i ch 1 oroethane) rnay be used as so 1 vents and aid ·· the surfactant in penetrating the surface of the soil. Water is also 

sometimes used as a solvent. 

Fluorescent whitening agents (FWA), also known as optical brighteners, 

are organic compounds that convert a portion of the invisible ultraviolet 

radiation in sunlight into longer wavelength blue light in the visible 

region. This improves the brightness as well as the shade of white 

articles. Nearly all white fabrics now have been treated with FWAs during 

manufacture, therefore, the function of FWAs in laundry prewashes is to 

maintain or build-up the fluorescent whitening effect. 

Proteolytic (protein cleaving) enzymes help to break down protein stains 

derived from sources such as milk, cocoa, blood, egg yolk, and grass, which 

may normally be resistant to removal by simple detergents. 

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Propellants (e.g. carbon dioxide, butane, propane) are used in the 

aerosol laundry prewashes help to expel the ingredients onto the fabric or 

article. 

Fragrances impart an agreeable odor as well as help to mask unpleasant 

odors arising from the wash liquor during washing. Fragrances are also 

intended to confer a fresh, pleasant lingering scent on the skin or laundry 

itself. To help make the product more visually pleasing and to give a 

distinctive appearance to a particular brand, dyes are often used. 

Product Use: Depending on the product form, the product is sprayed, 

poured, or rubbed directly onto the fabric until the soiled area is 

saturated. After the product is applied, the fabric is rubbed together in 

the treated area by hand. The product is allowed to soak into the fabric 

for one to three minutes. Then the fabric is laundered in the regular 

machine wash cycle at a water temperature recommended for the fabric using 

regular laundry detergent. 

Some laundry prewashes can be used in hot or cold water. In the case of 

solid sticks, the product may be applied on a soiled area up to one week 

prior to laundering. Extra tough stains may require a second treatment and 

rewashing. 

Manufacturing Process: This description is limited to liquids, pump 

sprays, and aerosol sprays since they comprise 99% of the market. Each 

ingredient is weighed and added into a large vat. The solution is 

thoroughly mixed. For liquids and pump sprays, the solution is poured into 

the containers. For aerosol sprays, the solution is pressure injected with 

a propellant into the container. 

Health and Safety Concerns: turrent formulations of aerosols contain 

hydrocarbon prope 11 ants that are vo 1 at il e and f 1 ammab 1 e and need to be kept 

away from an open flame and stored at temperatures below 120° F. Aerosols, 

pumps, and liquids may contain naphtha which is flammable. 

Perchloroethylene is an eye irritant and 1,1,1-trichloroethane is a possible 

carcinogen. 

Allergic skin reactions to surfactants vary widely and vary by 

individual. But surfactants can emulsify lipids, so repeated or prolonged 

exposure to detergents can cause lipid damage to the lipid skin layer of the 

skin. Consequently, the barrier function of the lipids is impaired, leading 

to increased permeability and loss of moisture from the skin, as evidenced 

by dryness, roughness, and flaking of the skin. Very prolonged exposure to 

concentrated surfactants solutions may lead to serious damage and even 

necrosis. 

Mucous membranes are much more sensitive to surfactants then the skin. 

Minor eye irritation to surfactants is sometimes unavoidable because of the 

widespread availability and use of detergents, but is normally reversible. 

However, serious damage can occur if the eye comes in direct contact with a 

-59-
concentrated surfactant solution and this contact is not followed by 

immediate and intensive flushing with water. High doses of surfactants iri 

the gastrointestinal tract can lead to vomiting and diarrhea. If a 

surfactant reaches the circulatory system, it can cause damage even in very 

low concentrations because of interactions with erythrocyte cell membranes, 

ultimately resulting in hemolysis of the cells. 

Enzym~s are complex nitrogenous substances of proteinaceous type which 

catalyze various reactions.of a biochemical nature. As with all proteins, 

human allergenic reactions are possible. In the past, some detergent factory workers have had asthmatic reactions to enzymatic dust. Some of the 

problems have been remedied by the manufacture of encapsulated enzyme types 

rather than powders. Some consumers are allergic to enzymes and may 

encounter problems from the use of ezymatic powders in the home. 

Reconmended VOC Standard: The recommended VOC standard for aerosols and 

solids is 22% by weight, beginning in 1/1/94. Staff expects the propos~d 

limit to be achievable and that a greater portion of the emission reductions 

will come from the aerosols. The recommended VOC standard for all other 

forms (pumps and liquids combined) is 5% by weight, beginning in 1/1/94. 

Because the sales weighted average for pumps and liquids is 6% and 4%, 

respectively, staff also expects the proposed limit to be achievable. Table 

25 below summar1zes the proposed standards and emission reductions. 

TABLE 25 

Laundry Prewash Standards Sunmary 

Proposed Number of Percent of Emission 

Product Standard Complying Market Reduction 

Form (% VOC) Products Complyjng TID 

Aerosols 22 1 45 0.39 

So 1 ids 22 3 41 0.026 

A 11 Other 

Forms 5 9 36 0.19 

Compliance with the Standard: It is expected that compliance with 

the regulation will be acheived by reformulation with water and other exempt 

VOCs. Staff contact with industry representatives indicate that 

reformulation is possible within the timeframe established. 

0. NAIL POLISH REMOVER 

Product Description: Nail Polish Remover means a product primarily used 

to remove nail polish and coatings from fingernails or toenails. 

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Nail polish removers are generally solvents or mixtures of solvents 

which help remove nitrocellulose, a primary constituent in nail polish. 

They are often modified by the inclusion of such constituents as oils, 

emollients, or other agents that are designed to reduce the defatting action 

of the solvents. 

Product Forms: Nail polish removers are manufactured in liquid, cream, 

sponge, and towelette forms. Creams and sponges were not reported in the 

survey and only one company reported the manufacture of towelettes. 

According to the literature, cream nail polish removers afford a wider scope 

of formulation than liquids, but maintenance of the desired consistency is 

not always easy. That is perhaps why cream nail polish removers are not 

generally popular. 

Based on the survey, emissions from nail polish removers are estimated 

to be 1.1 tons per day. Liquid nail polish removers account for nearly 100% 

of the total market share and nearly 100% of the total emissions. 

Currently, staff is unable to assess the contribution of emissions from the 

other product forms, but since liquid nail polish removers make up the 

majority of the sales and emissions, the primary discussion will concern 

this product form. 

Product Content Formulation: Based on the survey, the VOC content for 

liquids range from 76% to 98% by weight with the sales-weighted average at 

91%. The VOC content for the towelettes are also in this range. In 

"addition, information obtained from the shelf survey and literature search 

indicate that the VOC content of sponges and creams is similar to that of 

the liquids. 

Depending on the manufacturer and their particular products, nail polish 

removers contain a wide variety of ingredients. Nail polish removers may 

contain such ingredients as acetone, ethyl acetate, amyl acetate, butyl 

acetate, fragrances and colorants. The fragrances and colorants are added 

to provide a pleasing color and smell during use. Acetone, ethyl acetate, 

amyl acetate, and butyl acetate are primary solvents which help dissolve the 

nitrocellulose in nail polish. Other solvents include diacetone alcohol, 

ethyl lactate, glycols and glycol ethers. 

The lubricant-emollient agents include castor oil, soluble lanolin 

derivatives and butyl stearate. These agents are designed to prevent or 

reduce the drying of the skin and nails which may be due to the oil 

extraction properties of the solvents. Small amounts of humectants may be 

added, up to about 10% of water in certain types of formulation based on 

water-miscible solvents (e.g. methyl ethyl ketone, acetone, gammavaleractone, alcohol and glycol ethers). 

Some types of nail polish removers are so-called "non-smeary" removers 

because they claim to remove the nail polish without smearing the nails or 

the adjoining skin. These products may consist of a mixture of water and 

water-miscible solvents such as ethyl acetate and may have a water content 

of approximately 8-9%. Other types of nail polish removers contain no 

acetone. In these cases, the primary solvent may be ethyl acetate. 

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Product Use: Liquid, sponge, and cream nail polish removers are said in 

plastjc or glass containers. When not in use, the containers need to be' 

closed to prevent evaporative loss~ For liquids and creams, the solutiqn is 

applied by first dipping a cotton. swab or soft tiisue paper into the 

container and then rubbing the swab or tissue paper onto the nail. Removal 

time will depend on the amount of solution used, the time the solution is 

exposed to the environment, and the amount and type of nail polish being 

removed. 

For sponge products, the nail is dipped into the container and swirled 

around the sponge. The sponge is immersed in solution and provides the 

rubbing surface for the nail while the solution helps dissolve the nail 

polish. In this case, removal time should be minimal. Use of this product 

form may be an inconvenience because the toenail must be positioned in an 

awkward position in order to be dipped into the container. 

The towelettes are probably the most convenient to use because each 

towelette is individually wrapped in a sealed foil wrapper. To apply, the. 

wrapper is torn and the towelette is removed and rubbed onto the nail. 

Manufacturing Process: Generally, explosion-proof, grounded equipment' 

is used. Each ingredient is weighed and added into a suitably sized tank 

equipped with an explosion-proof stirrer. After the batch is thoroughly 

mixed, it is filtered directly into appropriately sized containers. 

Health and Safety Concerns: Current formulations contain solvents that· 

are volatile and flammable and need to be kept away from an open flame. Of 

primary concern is the solvent, acetone, which is a highly flammable liquid 

that can dissolve fats, oils, resins, rubbers, plastics, and the like. 

Although acetone is not a primary skin irritant, it may result in dermatitis 

in persons who use it frequently. The result is the removal of the normal 

fatty sebaceous secretion of the skin. Removal of this secretion faster 

·than it can be formed results in the skin becoming dry and cracked thus 

affording the ingress of bacteria and irritants encountered during ordinary 

work. Acetone may also remove oil from the nails so they cannot retain 

moisture. 

Nail polish removers need to be used in ventilated areas since the 

inhalation of acetone (and perhaps other solvents) can cause headachej 

fatigue, or bronchial irritation. 

Recommended VOC Standard: The recommended VOC standard for nail polish 

removers is 85% beginning in 1/1/94 with a future effective limit of 

75% beginning in 1/1/96. At least 11 products or 13% of the market listed 

in the survey can meet the 85% limit. With the sales-weighted average at 

91%, staff expects the proposed limit to be achievable. At least one 

product contains 75% VOC indicating that further reductions are possible. 

Staff is also aware of an achievable formulation that contains no acetone 

and no ethyl acetate with a VOC content of 73-74%. The estimated emission 

reductions for this category are 0.07 TID in 1994 and an additional 0.12 TID 

in 1996. 

-62-
Compliance with the Standard: Compliance with the proposed standard of 

85% may be achieved by replacing VOCs with water and other exempt VOCs. In 

addition, staff contact with industry representatives indicate that the 

future reduction of acetone and ethyl acetate from current formulations and 

the reduction of VOC content to below 75% may be achievable. 

According to the literature, gamma-valeractone has been suggested as a 

possible solvent in nail polish remover. It is colorless, almost odorless, 

and is completely miscible with water. A SOX solution in water may be used 

as a nail polish remover. The compound is stated to be non-irritating to 

the skin. According to industry representatives, there is at least one 

product currently on the market which contains garnma-valeractone. The 

product consists of pads in a container. 

P. OVEN CLEANER 

Product Description: Oven cleaners are any specialty cleaning product 

designed to clean and to remove dried food deposits from interior oven 

surfaces. This does not include microwave ovens, which use a different 

cleaning formulation, similar to a glass cleaner. 

Product Forms: Product forms are aerosol, liquid, and pump. Total 

emissions from this product category are 1 ton per day. The emissions from 

different product forms are 0.6 ton per day for aerosols, 0.1 ton per day 

for liquids, and 0.3 ton per day for pumps. A CSMA spokesperson indicated 

that the low VOC contents for oven cleaners listed in the Heiden data may be 

due to those products being microwave cleaners, which are light-duty surface 

cleaners, more similar in nature to glass cleaners or general-purpose 

cleaners, than actual oven cleaners. Table 26 below is a summary of the 

emissions for the subcategories. 

Product 

Form 

Aerosol Sprays 

Liquids 

Pumps 

TABLE 26 

Oven Cleaners Emissions Summary 

(Total Emissions 1 T/D) 

Percent of Emissions 

Market (J/D) 

55 0.62 

22 0.12 

23 0.25 

Percent of 

Emjssjons 

63 

12 

25 

Product Content Formulation: The sales-weighted average VOC product 

content is 9.8% for aerosols, 4.9% for liquids, and 9.8% for pumps. Typical 

total VOC content for this product category ranges from 10 to 17%. The 

typical combined VOC content for fragrance and colorant is less than 0.1%. 

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Oven cleaners consist of both caustic and non-caustic formulatiohs. 

Caustic formulations typically contain 41 to 20% caustic (potassium or 

sodium hydroxide) as an alkaline agent, with surfactants and solvents 

suspended in an emulsion. The solvent solubilizes grease deposits and 

allows the caustic to penetrate and saponify the grease to a soap form. 

Baked-on food deposits are also dissolved. Caustic formulations can be used 

without applying any oven heat, and left on overnight, or they can be left 

on the oven interior for 10 to 20 minutes after heating the oven to 200 

degrees F. The application of heat speeds up reaction between the caustic 

and the fatty acids contained in grease deposits. 

Non-caustic formulations contain weakly alkaline salts, and are used 

with the oven heated to 475 degrees for 30 minutes. These formulations are 

lower in VOC content than the caustic ones. The aerosol form ranges from 5-

8% in total VOC content, with more propellant than the caustic formulations, 

and no grease-cutting solvents. The caustic aerosol formulations range from 

7-11% in total VOC content. Propellants are typically butane or propane. 

Oven cleaners are made in ready-to-use form, so there is no product 

concentratiqn and required dilution. 

Product Use: Oven cleaners are used in the household sector ~rimarily; 

They are also used in the institutional (ie.--hospital ovens) and commercial 

(ie.--pizza ovens) sectors. The market shares for the institutional and 

commercial sectors are not specifically known, but they are both smaller 

than the household sector. The product is typically applied in aerosol 

form; liquid forms are applied by either pump spray or as a paste. Thickening agents are added to the liquid forms to promote adhesion of the 

cleaner to vertical oven surfaces. Another non-aerosol form is a pad of · synthetic abrasive, which contains a reservoir holding sodium or potassium 

hydroxide .and surfactant. Before use, the reservoir is punctured, releasi~~ 

the formulation, which is then spread over oven surfaces. The aerosbl forffi~ 

is regarded as easier to use, since it is easier to spray hard-to-reach 

areas than hand-wipe them. The non-caustic formulation has less safety 

hazard associated with it, since it contains no caustic. 

Manufacturing Process:. The product is made using a "wet blending" 

process, with no heat used. The product is blended in large mixing tanks, 

adding the ingredients in specific order, letting them dissolve, and then 

mixing them together. No production changes are foreseen due to the effect 

of the regulation. 

Health and Safety Concerns: Gloves and possibly goggles should be used 

with the caustic formulations. Sodium hydroxide is an irritant to the skin 

and eyes, and the cleaner should be used with adequate ventilation to avoid 

inhaling excessive fumes. 

Recommended VOC Standard: The current proposed standard being 

recommended for this category is 8% for aerosols and pumps, and 51 for 

liquids. This standard was selected based on the VOC survey data submitted 

by industry, and was set to allow complying products in both the aertisol, 

liquid, and pump forms, yet still achieve .emission reductions. Industry h'd 

requested a standard of 9% for aerosol/pump oven cleaners in order that the 

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aerosol form not be banned from the market, however, based on the survey 

results, the recommended standard of 8% will allow both the aerosol and pump 

product forms to remain on the market. The 5% standard, as requested by 

industry, will also allow the liquid form to remain on the market. 

Estimated emissions reductions for this category, based on this standard, 

are 0.2 ton per day. Table 27 below summarizes the proposed standards and 

emissions reductions. 

TABLE 27 

Oven Cleaners Standards Summary 

Proposed Number of Percent of Emission 

Product Standard Complying Market Reduction 

Form (% VOC) Products Comolyjng TID 

Aerosol Sprays/ 

Pumps 8 13 13 0.18 

Liquids 5 8 93 0.02 

Compliance with the Standard: Compliance can possibly be achieved by 

lowering the solvent content and raising the surfactant and caustic 

contents. Formulation data found in product formularies include several 

oven cleaners, including those for heavy duty use, that contain no solvents 

(ie.--0% VOC). The range of caustic for these formulations, in % by weight, 

is 10% for sodium hydroxide, and 20% for potassium hydroxide. Surfactant 

content ranges from 1% to 10%, and water content ranges from 15% to 82%. 

Q. SHAVING CREAM 

Product Description: Shaving cream is an aerosol product which 

dispenses a foam lather intended to be used with a blade, cartridge razor or 

other wet shaving system, in the removal of facial or other bodily hair. 

Product Forms: Shaving cream is packaged in aerosol form only. This 

represents 100% of the market. The estimated emissions from this category 

is 0.26 tons per day. 

Product Content Formulation: The sales weighted average VOC content for 

shaving creams is 7.3%. Some of the ingredients used in shaving creams are: 

anionic surface active agents, nonionic surface active agents, molecular 

complexes, humectants, superfatting agents, synthetic and natural gums, 

preservatives, special additives, fragrances, colors and propellants. 

Anionic surface active agents are soaps or salts of fatty acids that are 

found in shaving cream formulations. Animal fats such as tallow is rich in 

stearic acid and commercial stearic acid are used to form soaps which are 

finely textured foams that dry out quickly. Nonionic surface active agents 

-65-
are used to form emulsions and increase the wetting power of the product. 

Polyoxyethylene sorbitan esters, alkyl phenoxypolyethoxy ethanols and 

polyoxyyethylene ethers are some examples of these agents. Molecular 

complexes are formed with surface active agents and fatty agents or fatty 

alcohols. The most conmon molecular complex is the sodium stearate-stearic 

acid complex. 

Humectants are used to impart a smoothness and softness to the shaving 

products. Also, they help prevent water loss by evaporation and contribute 

to the stability of the foam. Glycerin is probably the most popular of the 

polyhydric alcohol humectants. 

Synthetic and natural. gums are employed to stabilize the viscosity of 

the liquid, cream and gel formulations. Gums contribute both lubricity and 

texture to the foam. Salts and derivatives of alginic acid, tragacanth, 

pectins and methylcellulose ~re some examples. 

Preservatives include both microbiological and chemical types. It is 

important that no human pathogens be present in the formulation. 

Microbiological screening of the effectiveness of the bactericide br 

bacteriostat used is mandatory. Methyl, ethyl, butyl and propyl parahydroxybenzoates are used in many formulations. 

Propellants are used to expel the product from the container and to 

create a foam by expanding in the product after it is expelled. They should 

be odorless, low-boiling, compatible and nontoxic. Hydrocarbon compounds such as propane, butane and isobutane can be used. Isobutane is the most 

commonly used propellent in shaving creams today. 

Product Use: Shaving creams are for personal use. Shaving cream 

contributes to the comfort, safety and speed of a shave. It wets the hair 

and maintains it in this state throughout the shave. It also lubricates the 

skin so the razor and blade glide smoothly over the surface being shaved. 

The product is applied by dispensing a small amount of the product into the 

palm of the hand and then distributing the foam on the skin surface to be 

shaved. 

Manufacturing Process: Manufacturing processes vary, but ~sually ·0 

involve a mixing process while adding the various contents. 

Recommended VOC Standard: The standard being recommended for this 

category is 5% VOC content by weight. Based on ARB surveys and industry 

contacts, a 5% VOC content by weight is being proposed. There are five 

products currently available on the market that meet this standard. The 

estimated emission reductions for this category is 0.08 tons per day. 

Compliance With The Standard: Compliance with the standard could be 

achieved through product reformulation using water and other exempt solvents 

and propellents. The timeframe proposed in the regulation is accepted as 

adequate time for reformulation. Increasing the water content in the 

formulation may be one method of complying. Another method may be reducing 

or substituting the propellants currently being used. 

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VII. 

IMPACTS 

A. ECONOMIC IMPACTS 

1. Economic Impact on Industry 

Manufacturers of noncomplying consumer products have several options 

available to them to meet the requirements of the proposed regulation. 

These options include reformulation of existing products, changing product 

forms, development of new technology that allows the products to qualify for 

the innovative products exemption, and withdrawal from the California 

market. Reformulation is the most likely means of meeting the VOC standards 

in the regulation since in most cases there are already complying products available. 

Staff performed an economic analysis to determine the cost impact of the 

regulation. In conducting this analysis, staff assumed that the primary 

impact of the regulation would be on consumer product manufacturers. ARB 

staff believe that, based on the data presented in the New York Pacific 

Environmental Services report, the impact to "upstream" suppliers such as 

chemical companies supplying solvents and propellants should be minimal. It 

was also felt that product distributors, due to their regional and multiproduct nature, should not experience a significant economic impact from the 

regulation. It was further assumed that manufacturers would comply with the 

regulation by reformulating existing products to meet the VOC standards. 

The analysis was a before tax study although there may be tax advantages 

that could significantly reduce the costs associated with reformulation. 

These factors are difficult to estimate and were beyond the scope of this 

analysis. 

Based on the assumptions below, the analysis resulted in an estimate of 

the average annual cost to reformulate a typical product formulation, the 

total annual cost to the consumer products industry, and the cost 

effectiveness of the regulation. 

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Assumptions 

To estimate the cost of reformulation, a number of assumptions were 

necessary. These assumptions are as follows: · 

(1) Reformulation of products will not result in a change from one 

product form to another (e.g. aerosol to a pump spray product 

form). 

(2) No major retooling of manufacturing equipment will be 

necessary. 

(3) No significant change in marketing costs will be required. 

(4) No increase in raw materials cost will occur. 

(5) Reformulated products will be marketed nationally. 

The first assumption was that reformulation will not require a change in 

the product form. While some companies may choose to change product forms, 

the regulation is generally not designed to require a change in product form. 

Since the product form is not expected to change, it is further assumed 

that major retooling of production lines will not be necessary. However, 

industry has pointed out that some equipment may have to be purchased to 

accommodate changes in the formulation. Industry also pointed out that 

training of employees would generally be required if new equipment is 

purchased. These costs are very difficult to estimate since it is not know~ 

what reformulations will result from the regulation or whether equipment 

purchases will be necessary. Some of the cost estimates provided to staff 

by industry considered these elements while most did not. 

It is also assumed that marketing costs will remain unchanged. Some 

industry contacts have noted that consumer acceptance studies will be 

desired for reformulated products. It has also been pointed out that 

modifications to trade show displays will have to be made. These costs were 

not considered since staff cannot quantify these. Also, staff believes that' 

market studies are often ongoing and in many cases would be performed even 

in the absence of the regulation. 

Staff assumed that there will be no increase in the cost of raw 

materials. In general, solvents will be replaced by water, which represents 

a cost savings. Increasing the water content will in some cases require 

changes in the solvents, active ingredients and packaging. These costs are 

difficult to quantify and have not been considered. 

Finally, from discussions with industry, staff found that the majority of consumer product companies market their products nationally. Most of 

these companies plan to market products reformulated for California in the 

rest of the country. 

-68:.. 
Annual Cost 

The first step in the economic analysis was the determination of the 

average annual cost to reformulate a typical consumer product. Due to the 

number of products covered by the regulation, an individual analysis of each 

product category was not possible. This analysis is shown in Appendix E. 

As shown in Appendix E, the analysis determined the annual cost of 

reformulating a typical product to range from a low of about $16,000 to a 

high of over $500,000. The annual cost figures were calculated based on 

four scenarios with total reformulation costs of 100,000 and two million 

dollars and amortization periods of five and ten years. Total reformulation 

cost estimates were based on discussions with industry. According to the 

information gathered, the significant costs associated with reformulating a 

product to meet the requirements of the proposed regulation include research 

and development, efficacy testing, stability testing, safety testing, and 

modifications to labels. An interest rate of 10% was assumed. 

Total cost to industry 

The total annual cost to the consumer products industry to reformulate 

all noncomplying products was estimated. The estimate is based on the range 

of annual costs per product formulation described above and the total 

number of noncomplying products. Based on the estimated 681 noncomplying 

product formulations from the ARB consumer products survey, the total cost 

to the consumer products industry is estimated to be between 11 and 360 

million dollars. The wide range in cost is due to the range in the annual 

cost figures 

Cost effectiveness 

Cost effectiveness ratios are used to compare the cost of a regulation 

to the benefits in terms of reduced emissions. The cost effectiveness 

ratios used for this regulation are expressed in dollars required per pound 

of VOC reduced. These ratios were determined by dividing the total annual 

cost figures by the estimated emission reductions due to the regulation. 

It was assumed that the reformulated products will be marketed nationally, 

resulting in emission reduction benefits throughout the nation. 

In some cases, the regulation may result in a net savings to industry. 

For instance, it is estimated that reformulation of automotive windshield 

washer fluid to the 10% VOC limit could result in an annual cost savings to 

industry of $800,000. This estimate is based on the replacement of methanol 

(at $0.41/gallon) with water to meet the 10% standard. This represents a 

cost savings of 5 cents per pound of VOC reduced. This figure does not 

include any costs associated with relabeling or distribution changes. 

The cost effectiveness ranged from about -$0.05 to $1.70 per pound of 

VOC reduced. This range in the cost effectiveness estimates reflects the 

uncertainty in the cost to reformulate the wide variety of products covered 

under the regulation. The cost effectiveness ratios, summarized in Table 

28, compare favorably with other VOC regulations considered by the ARB. 

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TABLE 28 

Cost-Effectiveness Comparison of the Pr.oposed · Consumer Product Regulation with 

Other Recently Adopted SCM' s, .. and Regulations 

Cost-Effectiveness 

Measure. . $/Jb VOC Reduced 

Consumer Products (1990) -0.05 to 1.70 

Arti-perspirants (1989) 0.50 to 1.20 

Architectural Coatings (1989) -4.30 to 6.40 

Marine Vessel Operations (1984) 0.00 to 18.75 

Sumps, Pits, Ponds (1988) 0.07 to 10.00 

in 0 i 1 Production Operations 

ARB staff believes that the economic burden on industries as determined 

with a cost-effectiveness ratio (e.g. dollars required per pound of VOC 

reduced), would be favorable when compared to ;~pacts on other industries 

from recently approved regulations that cover such categories as antiperspirants and deodorants, architectural coatings, and loading, ballasting and lightering operations on crude oil and gasoline cargo tankers. In som~ 

cases there may even be cost savings to industry due to replacement of .. solvents with water. For most categories listed in the proposed regulation, 

there are products currently in the market which can meet the proposed 

standards for each product form. 

Reformulation costs and cost effectiveness ratios may alJo be lower than 

predicted due to the transfer of research and development costs to other 

products. Many companies have many simi 1 ar products in their product 1 i nes .. In these cases, research and development costs could be applied to several 

products, reducing the cost per product. ;; · 

2. Imoact on Consumers 

A large portion of the costs incurred by industry may be passed on to 

the consumer. However the extent to which this will occur is difficult to 

predict. It is also possible that the cost of the regulation will be passed 

on to products not covered by the regulation. Due to these uncertainties, 

the increase in the cost of consumer products cannot easily be predicted. 

However, staff has developed some estimates based on the the following information: (1) the annual cost figures per product formulation given in 

Appendix E; (2) information on the tota.l number of aero so 1 product formulations; and (3) the total number of aerosol units sold annually. The 

analysis assumes that all reformulation costs are pa~sed on to the.consumer 

and does not consider any other factors such as expected difficulty of 

reformulation. Only aerosol prod~cts were ~xamined Since they are expected 

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to experience the greatest impact. This analysis showed the average 

increase in cost for a typical aerosol product to vary from a low of about 1 

cent per product using the annual cost figures from cases 1 and 2 in 

Appendix E, to a high of 23 cents per product using the annual cost figure 

from case 3. This analysis is also shown in Appendix E. 

B. ENVIRONMENTAL IMPACTS 

The primary environmental impact from the proposed regulation is 

expected to be a decrease in VOC emissions to the atmosphere from consumer 

products. Since VOCs are precursors to ozone, a decrease in VOC emissions 

will result in a decrease in tropospheric ozone. From .the previous 

discussion, emission reductions are estimated to be 45 tons per day by 1998 

in the state of California for the product categories in the proposed 

regulation. Emission reductions are shown in Table 29. 

TABLE 29 

Summary of Emissions and Emission Reductions 

from the Proposed Standards 

Proposed 

Standard Emission 

Product Percent Emissions Reductions 

Category VOC by Wt. lbs/Day lbs/Day 

Air Fresheners 

Aerosol-2 phase 30 5,450 760 

Aerosol-1 phase 70 1,550 460 

(30%-1996) (620-1996) 

Liquid/Pump 18 1,270 340 

Solid/Gels 3 300 200 

Dual Purpose Aerosol 

Air Freshener/ 

Disinfectant 60 8,600 2,200 

Other 3 140 120 

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Percent 

Reduct jon 

14 

30 

40 

27 

67 

26 

86 
TABLE 29 Can't 

Sunmary of Emissions and Emission Reductions 

from the Proposed Standards 

Proposed 

Standard Emission 

Product Percent Emissions Reductions Percent 

Category VOC by Wt. lbs/Day ]bs/Day Reduct jon 

Automotive Windshield 

Washer Fluids 

Type A Areas 35 (1993) 1,600 0 0 

A 11 Other Areas 10 (1993) 46,400 33,200 72 

Bathroom & Tile 

Cleaners 

All Forms 5 900 220 24 

Engine Degreasers 75 (1993) 9,000 1,860 21 

(50 - 1996) (2,340-1996) 26 

Floor Polishes (Waxes) 

Flexible Flooring 

Polishes 7 3,780 940 25 

Nonresilient Floor 

Polishes 10 420 100 24 

Wood Floor Wax 90 1,000 1 -0 

Furniture Maintenance 

Aerosol 25 4,870 820 17 

A 11 Other 7 730 240 33 

General Purpose 

Cleaners 

A 11 Forms 10 9',800 3,320 34 

Glass Cleaners 

A 11 Forms 6 (1993) 4,600 1,220 27 

Hairsprays 

All Forms 80 (1993) 92,000 14,400 16 

(55 - 1998) (24,160 -1998) 26 

Hair Mousse 

A 11 Forms 16 1,160 70 6 

Hair Styling Gel 

All Forms 6 820 550 67 

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TABLE 29 Can't 

Summary of Emissions and Emission Reductions 

from the Proposed Standards 

Product 

Category 

Insect Repellents 

Aerosol Sprays 

Laundry Prewashes 

Aerosols/Solids 

All Other Forms 

Nail Polish Removers 

Oven Cleaners 

Aerosol Sprays/ 

Pumps 

Liquids 

Shaving Creams 

Proposed 

Standard 

Percent 

VOC by Wt. 

65 

22 

4 

85 

(75-1996) 

8 

5 

Emissions 

Jbs/Day 

880 

2,220 

1,780 

2,200 

1,750 

250 

A 11 Forms 5 520 

Total Cumulative Emission Reductions: 

* 

Emission 

Reductions 

Jbs/Day 

260 

830 

380 

140 

Percent 

Reduct jon 

30 

37 

21 

(220 -1996) 

6 

10 

1993 

1994 

1996 

1998 

360 

40 

160 N 53,000 

N 63,000 N 66,000 

N 91,000 

21 

16 

31 

(26 TPD) 

(32 TPD) 

(33 TPD) 

(45 TPD) 

Emission Reduction in parenthesis represent additional emission 

reductions after future effective VOC limits take effect. 

The proposed regulation prohibits any new uses of compounds which have 

an ozone depletion potential (ODP) greater than 0.00. Industry has proposed 

reformulating their products with HCFCs and 1,1,1-trichloroethane to comply 

with the standards. However, new uses of HCFCs and 1,1,1-trichloroethane, 

which have small but definite OOPs, will be prohibited under the regulation. 

As a result, staff anticipates no adverse impacts to stratospheric ozone 

from the regulation. 

The impact on the emission of greenhouse gases is more difficult to 

accurately predict at this time. For instance, industry may use carbon 

dioxide (a greenhouse gas) as a replacement for hydrocarbon propellants in 

some products. There are two types of propellent systems currently 

available which use carbon dioxide: (1) those using compressed carbon 

dioxide in gaseous form, and (2) those employing a chemical reaction 

separate from the product which generates the carbon dioxide as the product 

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is used. The first system uses compressed carbon dioxide which is a byproduct of many petroleum and chemical refining processes. If this byproduct is not condensed .and subsequently used in consumer products, it 

would normally be emitted to the atmosphere. Using by-product carbon 

dioxide from other man-made sources would therefore recycle carbon dioxide 

that otherwise would have been emitted to the atmosphere. 

On the other hand, the second p~opellent system generates its own 

carbon dioxide, which technically would increase the load of greenhouse 

gases to the atmosphere. However, this propellent system has very limited 

and specialized uses and generally does not lend itself to widespread 

applications. Moreover, replacing solvents with carbon dioxide would reduce 

the amount of VOCs in the environment which react with oxides of nitrogen to. 

form ozone. Since ozone itself is a greenhouse gas, a reduction of ozone 

would at least partially negate any unexpected increase of greenhouse gases 

from the use of carbon ~ioxide in this propellent system. 

To assess other potential envjro,nmental impacts resulting from the 

regulation, staff made the following assumptions: 

o Product efficacy before and after the regulation is implemented 

will remain approximately the same 

o Most reformulation will inVolve the use of water-borne and more 

concentrated products 

o Industry will manufacture a greater percentage of products in 

concentrated forms 

A decrease in the amount of VOCs in "down the drain" consumer products 

could reduce VOC emissions to the atmosphere. Industry representatives have 

argued that the VOCs in "down the drain" products are biodegraded in the 

sewer system and not emitted to the atmosphere. However, EPA has estimated 

that between 14 to 25 percent of the organic compounds in the sewer system 

are emitted to the atmosphere before reaching publicly-owned treatment works 

(POTW). Thus, any reduction in VOC content for these consumer products 

would likely decrease the amount of VOCs which normally volatilize to the 

atmosphere before treatment at a POTW. · 

Reformulati~n using water-borne technology may also impact landfill 

space. To prevent corrosion, water-borne products are typically packaged in 

lirted metal containers which can make recycling difficult. New innovative 

delivery forms such as Exxel, which contain no metals, would also be 

difficult to recycle. The potential impact on future recycling programs 'and 

landfill space cannot be accurately predicted. However, since there are no 

programs which currently recycle aerosol containers, lined or unlined, staff 

anticipates no major changes to landfill space as a result of products using water-borne tethnology or new systems. · · 

An increase in concentrated products may reduce the amount of lahdfill 

space needed. Since the concentrated products would be sold in smaller 

containers, the amount of necessary packaging would decrease, reducing the 

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demand on landfill space. In addition, concentrating products will result 

in a decrease in vehicular transport emissions since fewer units per 

required application are necessary. Thus, while the total impact on 

landfill space cannot be predicted at this time, staff anticipates no 

significant negative impact on landfill space and a possible decrease in 

vehicular transport emissions as a result of the regulation. 

C. CONSUMER IMPACTS 

One important consideration regarding the proposed statewide regulation 

is the impact on the consumer. Not only may manufacturers need to change 

formulations, product forms, and product costs, but consumers as well may 

need to change their preferences, purchases, and uses for some products. 

Staff believes, however, that the impact to the consumer will be minimal 

since for each product category there is a product currently available in 

the market place that can meet the proposed standard. Product costs may 

increase as manufacturers seek to recover any costs associated with 

developing a reformulated product that complies with the VOC limits. Staff 

estimates that increased costs for all products will range from 1 to 23 

cents per unit. 

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VIII. 

ISSUES 

A. COLLECTION OF VOC SURVEY DATA 

The ARB consumer products survey was designed to gain information on VOC 

emissions, current preferences for the various product forms available (e.g. 

aerosol sprays, solids, pump sprays), product brand names, and market 

distribution. This survey was intended to be distributed and implemented by 

one agency for the sake of expediency, consistency, and the minimization of 

errors. However, because of concerns regarding the treatment of 

confidential data, many of the product manufacturers who are members of the 

Chemical Specialties Manufacturers Association (CSMA) elected to submit 

their survey data to one of three entities: (1) Heiden Associates, a law 

firm based in Washington, D.C., (2) Baker and Hostetler, another law firm in 

Washington, D.C., and (3) the Cosmetics, Toiletries and Fragrances 

Association (CTFA), a consortium of specialty consumer product 

manufacturers. To maintain confidentiality, the information submitted by 

these entities to ARB did not include company names or brand names 

associated with the data. 

Problems with this approach arose soon after the survey forms were 

submitted. It became apparent that this multi-agency process for collecting 

the survey data introduced several sources of uncertainty into the survey 

data: (1) misinterpretation by the manufacturers of the survey requirements, 

and (2) misinterpretation and miscategorization of submitted survey data by 

the staff of at least one of the law firms, and (3) typographical errors 

made by either the survey respondents or the law firms. ARB staff detected 

at least one example of each error type in the data submitted by both Heiden 

Associates and Baker and Hostetler. Examples of the errors that were found. 

were blanks or obvious discrepancies in the VOC and propellent content data 

fields and miscategorization of various products into inappropriate 

categories. Review of the compiled data submitted by the Heiden Associates 

indicated that these errors were not uncommon. To be fair, Heiden 

Associates corrected and resubmitted data on several occasions. Even with 

this effort, staff had to exclude a portion of the submitted data from the 

survey analysis because the data were incomplete or because the data were 

inconsistent with other known information. In addition, since company names 

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were kept confidential it was difficult for ARB staff to validate the 

information. 

Using various sources of information on the different product 

categories, ARB staff attempted to correct obvious errors in the data. For 

instance, if an entry for the propellent weight percentage (PVOC) was 

greater than the entry for VOC, then the VOC entry was generally modified to 

be at least the same value as the PVOC entry. Exceptions to this would be 

cases where staff had high confidence that the VOC value was greater than 

even the modified value. In these cases, the VOC entry was remodified on a 

case-by-case basis depending on the particular product category. 

In spite of the uncertainties in the survey, the remaining data proved 

worthwhile and revealing. For many of the products in the proposed 

regulation, the sales-weighted average VOC content proved to be less than 

what ARB staff had originally estimated. This resulted in staff's lowering 

of the VOC standards to the levels now shown in the regulation. Moreover, 

over 501 of the available products in some selected categories comply with 

the proposed standards. These complying products, which are often made by 

independent manufacturers, generally do not represent as large a market 

share as that represented by the major manufacturers. Nevertheless, the 

number of complying products within these product categories indicates that 

the technology to make complying products is reasonably available. 

B. VOC CONTENT VERSUS VOC EMISSIONS 

In the consumer products VOC survey, ARB staff requested information on 

the VOC content of the products and not the actual VOC emissions resulting 

from the use of those products. Some industry representatives who attended 

the first three workshops questioned whether VOC content will yield accurate 

estimates of actual VOC emissions. ARB staff's analysis of the numerous 

forms and application techniques associated with the various product categories indicates that actual VOC emissions are very difficult, if not 

impossible, to accurately determine. For example, in order to accurately 

report VOC emissions from consumer products, a manufacturer or distributor 

would need to know the following: 

1) the total amount of VOC in the product (VOC content), 

2) the total annual usage rate (annual sales) of the product, and 

3) the percentage of the total VOC content that volatilizes into the 

atmosphere (indicated by vapor pressure). 

For the purposes of this discussion, the terms "volatile organic compounds (VOC)" and "reactive organic compounds (ROC)" are essential.ly 

equivalent and shall be used interchangeably. A VOC is defined as any 

compound containing at least one atom of carbon, except methane, carbon 

monoxide, carbon dioxide, carbonic acid, metallic carbides, or carbonates, 

ammonium carbonate, 1,1,1-trichloroethane, methylene chloride, 

trichlorofluoromethane {CFC-11), dichlorodifluoromethane (CFC-12), 

chlorodifluoromethane (HCFC-22), trifluoromethane (HFC-23), 

trichlorotrifluoroethane (CFC-113), dichlorotetrafluoroethane (CFC-114), 

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chloropentafluoroethane (CFC-115), dichlorotrifluoroethane (HCFC-123), 

tetrafluoroethane (HFC-134a), dichlorofluoroethane (HCFC-141b) and 

chlorodifluoroethane (HCFC-142b). As written, this definition is consistent 

with the Environmental Protection Agency's (EPA) definition of a VOC, with 

the exception that EPA does not recognize ethane as a VOC. 

The VOC content and annual sales should be readily available to the 

product manufacturers and/or distributors. Thus, a conservative estimate of 

the actual VOC emissions from consumer products would require simply taking 

the VOC content and multiplying it by the usage rate (i.e., the entire VOC 

content of a product evaporates). For a more accurate estimate of actual 

VOC emissions, the percentages of organic compounds that volatilize into the 

atmosphere need to be determined. However, this may fluctuate significantly 

under real world conditions. 

ARB staff realizes that many of the compounds that have low vapor 

pressure or have high polar attraction for water do not volatilize 

immediately when applied. However, these compounds may become volatile 

under certain conditions. For instance, as a result of overspray or during 

the intended application, many of these compounds are deposited onto 

surfaces within the home or in other structures. Over time, these compounds 

offgas and are released into the air. 

Products designed to be applied to people or objects and then washed 

into the sewage system can also be sources of emissions. These compounds, 

which can be semi-volatile or highly polar, may be emitted into the 

atmosphere through at least three possible mechanisms: (1) physiochemicalor bio-degradation into simpler, more volatile compounds, (2) stripping into 

the air during sparging and aeration caused by turbulence in the sewer 

stream, or (3) adsorption onto wastewater solids and subsequent offgassing 

during dewatering and landfilling of those solids. EPA has estimated that 

between 14 and 25 percent of the pollutants discharged to publicly-owned 

treatment works (POTWs) may be emitted into the atmosphere. 

In light of the uncertainties concerning the final fate of so-called 

"nonvolatile" organic compounds from consumer products, the ARB staff has 

taken the position that almost all volatile organic compounds found in 

consumer products can be assumed to eventually volatilize into the 

atmosphere. However, implementing this view in the real world of consumer 

products quickly becomes impractical when all the various VOCs present in 

consumer products are considered for regulation. To streamline the 

regulatory development process and to minimize the impacts on industry, ARB 

staff has limited the applicability of the regulation to those VOCs which 

are thought to contribute the largest portion of the ambient VOC loading. 

This streamlining was accomplished by qualifying a VOC with the provision 

that it either has (a) a vapor pressure greater than 0.1mm Hg at 20 degrees 

Celsius or (b) less than thirteen carbon atoms, if the vapor pressure is 

unknown. ARB staff chose these qualifiers based on the relative 

volatilities of known organic compounds which are found in consumer 

products. Staff believes that these provisions will enable the regulation 

to cover most, if not all, of the major contributors to VOC emissions from 

consumer products. This approach has another practical benefit as most of 

-78-
the active ingredients tend to be low vapor pressure cbmpounds and exempting 

compounds based on vapor pressure avoids the necessity of identifying · individual active ingredients. 

During the regulatory development process, ARB staff indicated they 

would consider on a product-by-product basis any incontrovertible 

documentation that shows negligible volatilization for VOCs found in 

consumer products. Such documentation provided to the ARB needed to address 

the entire.lifespan of th~ organic compounds in question, from its initial 

application to its final destruction or conversion. Without this 

documentation, ARB staff estimated the VOC emissions from consumer products v 

using the VOC content and usage rates for those VOCs which meet the criteria 

described above. 

C. TIME FOR INDUSTRY TO COMPLY 

, lThere have been concerns raised regarding the ability of manufacturers 

to develop complying products by the product standard effective dates. ·The 

predominant objection is that there is not enough time to reformulate , existing products to the VOC levels required by the regulation. Objections 

have also been raised to the future effective dates, which industry says will require them to reformulate more than once, taking more time and money. 

There are five basic steps involved in reformulating a product: 

(1) Product Formulation Development, 

(2) Packaging Development (Can/Valve, Label etc.), 

(3) Safety and Efficacy Testing, 

(4) Consumer Marketing Tests, and 

(5) Production 

Product formulation development includes modifying an existing 

formulation to meet the VOC standard. During this stage of development, 

manufacturers may. conduct numerous laboratory tests to evaluate and adjust the physical attributes of the new formulation such as the odor, viscosity 

and color prior to developing the final formula specifications. Industry 

estimates for formulation development range from 6 to 18 months. 

Package development includes choosing an acceptable packaging system and 

labeling design for the reformulated product. This may include tests to 

determine the compatability ·of the container with the new formulation, 

stability testing to determine that the product will be stable and not 

undergo chemical reaction within the container, and modifications to can and 

valve design for aerosol packages. Package development may take anywhere from 2 to 18 months depending on the changes made to the formulation and the 

choice of package. 

-79-
Safety and efficacy testing generally take 6 to 18 months, depending on 

the product and how extensive the safety testing must be. Safety testing 

consists of toxicity tests of various types, used to determine the subacute, sub-chronic exposure effects of the product. Sub-acute tests 

generally take 3 to 6 months; sub-chronic test take 3 to 12 months; and 

chronic tests take from 6 months to 24 months. Efficacy testing is done to 

determine how well the product performs its intended function, and the 

amount of time and cost to do them varies from product to product. 

Once the safety and efficacy testing is complete, if the product is a 

FIFRA regulated product the necessary government .registration process can 

begin. Products which must be registered with state and federal agencies 

are predominantly those which make a pesticide claim. This includes 

insecticides and disinfectants. The FIFRA registration is initiated first 

with EPA, then the product must also be registered with the California 

Department of Food and Agriculture (CDFA). These registration processes 

cannot be done simultaneously; the FIFRA registration must be done first. 

Staff contacted EPA and CDFA to determine typical timeframes for 

registration. The FIFRA amendments enacted in 1988 require EPA to respond 

to applicants within specified timeframes. For products containing an 

active ingredient that has been previously registered in another product, 

the response time is 90 days. For active ingredients that are new, the 

registration process can take up to one year or longer. Every distinct 

product subject to FIFRA must be registered, even if the formulation is 

identical to another product that is already registered. The CDFA 

registration takes approximately 3 to 5 months. 

Consumer marketing tests may take from 3 to 6 months to complete. 

Time for production startup will also vary from product to product, with a 

range of 9 to 30 months identified given by industry as typical. 

Assuming the development process is sequential, based on the time frames 

indicated by industry, the total time for reformualtion to market ranges 

from 3 to 10 years. However, staff beleives that this is an overestimate. 

In the the Aerosol Handbook, 2nd Edition, an estimate of 1 to 4 years was 

given for introducing a new product to the consumer; and in discussions with 

private consultants to the consumer product industry, for some products it 

may only take from 1 to 2 years to develop and market a new product. Also, 

• many of the above steps can be done concurrently, thus saving time in the 

reformulation process. Much of the laboratory work involved in formulation 

development can be eliminated or reduced through the use of library 

resources, in-house files of previous laboratory experience, and 

manufacturers' product literature. Cosmetic products, jn particular, use 

standard formulations which contain substances that are "generally 

recognized as safe" (GRAS), for which the physical, chemical, and 

compatibility behaviors are well known. One method for formulation 

screening, which is widely used and may provide significant savings in time 

to reformulate, is fractional-order randomized block design. This method is 

used to study different formulation variables, allowing two or more factors 

to be investigated concurrently. This avoids the "one-factor-at-a-time" 

approach, which does not allow the detection of interactions of factors. 

-80-
At the same time that formulation development is being done, container 

and closure systems should be undergoing evaluation under stress conditions 

to eliminate those systems that adversely affect product stability. Many 

companies also begin preliminary or pre-market testing of the proposed 

product's safety and efficacy at this time as well. The various safety 

tests can be done concurrently with each other, as well as concurrently with 

efficacy testing. 

Consumer marketing tests are generally done after safety and effitacy 

testing. However, these can be done concurrently with government agency 

filings, and initial production steps can also be started at this time. 

Many of the production processes inVolve simple blending of ingredients, anfu 

industry in general indicated that they did not anticipate extensive process 

or equipment changes in order to reformulate. ·• •' 

In response to industry's concerns, it must be emphasized that industry 

is not being asked to develop completely new technology or products in order 

to comply. The VOC standards have been set such that there are existing ,,, complying products in every product .category for every product form. It '·"· 

should be possible for industry to utilize technology transfer from these 

existing products in their pursuit of compliance. The extent to which this 

occurs is subject to the extent of industry interaction and cooperation and. 

may be affected by patents and licensing agreements. 

Industry has also indicated that they typically experiment with product 

components and formulations on an ongoing basis. Some companies have begun 

reformulation efforts already, in response to the initiation of regulation 

development in Fall 1989. This essentially provides three years to 

reformulate until the first standards become effective in 1993, four years 

until the 1994 standards, and 1 additional year after the effective date for 

those products registered under FIFRA. Because many 6f the steps involved 

in product reformulation can be overlapped in time, such as various kinds of 

testing, we believe that compliance by the effective date of the standards 

is possible. 

D. LIQUID LAUNDRY DETERGENTS ' I' ~, 

Liquid laundry detergents ("down-the-drain" products) contain VOCs, 

incl,uding ethanol, which may be released into the atmosphere during and 

after use. Ethanol, a low-molecular weight compound, has a high volati.lity 

and high water-sol~bility. It is used as a formulation aid in liquid 

laundry detergents because of its hydrotropic characteristics. The compound 

helps to ensure that other detergent components can b~ combined in a stable 

way in an aqueous environment. Primarily, it helps prevent phase separation 

and precipitation from occurring as a result of shifts in temperature. 

Because liquid laundry detergent is used in a highly agitative wash 

environment (e.g. washing machines), the potential for ethanol release into 

the. atmosphere is great. Aware of this possibility and the possibility that 

-81-
VOC standards may be established for liquid laundry detergent, the Soap and 

Detergent Association (SDA) sponsored two studies. The studies involved two 

central issues: (1) what amount of ethanol is emitted into the atmosphere 

during the wash cycle, and (2) what amount of ethanol is emitted during 

transport to publicly-owned treatment works (POTWs). 

The first study was conducted by the University of California, Berkeley. 

In this study, the release of ethanol to the atmosphere during simulated 

household use of liquid laundry detergent (hand dishwashing detergent was 

also measured but is not relevant to this discussion) was measured. Two 

conditions of wash were established: (1) "typical" laundry (characteristics 

selected to represent the most prevalent use habits), and (2) "high release" 

laundry (characteristics selected to increase the potential for ethanol 

release while remaining within the range of consumer habits). 

The second study was conducted by Engineering-Science of Berkeley, CA. 

The study makes an analysis of the environmental fate of ethanol in downthe-drain household cleaning products. In this study, no measurements or 

experimental work were performed. Instead, the study makes use of existing 

calculations and models taken from the scientific literature. The release 

of ethanol was estimated in six areas: (1) open bottles during use or 

storage of dishwashing product, (2) household kitchen sinks during washing 

of kitchenware, (3) clothes washing machines, (4) sewer lines, (5) publiclyowned treatment works (POTWs), and (6) surface waters. (Areas (1) and (2) 

are not relevant to this discussion.) 

Staff received copies of both studies from SDA representatives. Results 

from the studies indicated that ethanol release during and after the use of 

liquid laundry detergent was very small compared to the total VOC emissions 

from all sources in California. Staff is currently reviewing the methods, 

data, and results given in both studies. Additionally, staff will review 

other studies and literature relevant to ethanol release. Due to the time 

needed to ev~luate both studies, review other literature, and determine t~e 

potential applicability of a VOC standard for liquid laundry detergent, 

staff is withholding any comments regarding ethanol release until a later 

date. 

E. DUAL-PURPOSE AEROSOL AIR FRESHENER/DISINFECTANTS 

ARB staff proposes to limit the VOC content of dual-purpose aerosol 

disinfectants that are also used as air fresheners to 60% by weight. This 

proposed standard is based on staff's analysis of aerosol air fresheners, 

current disinfectant technology, marketing trends, data provided by industry 

representatives, and the use of disenfectants as air fresheners. The 

following will discuss the need for and the feasibility of reducing the VOC 

emissions from these dual-purpose disinfectants. 

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1. What are dual-purpose aerosol air freshener/disinfectants? 

Dua 1-purpose. aero so 1 air fresheners/disinfectants (henceforth "aero so 1 

air freshener/disinfectants" or "dual~purpose products"), as defined in the 

proposed Consumer Products regulation, are pressurized spray disinfectants 

which are also claimed to freshen or deodorize air. Since disinfectants. are 

designed to kill microbes, they are required to be ~egistered as pesticides 

with EPA pursuant to the Federal Insecticide, Fungicide, Rodenticide Act 

(FIFRA). 

The proposed VOC standard does not apply to liquid or pump disinfectants 

since these products have a sufficiently low VOC level after the recommended 

d i 1 uti on to. meet tne proposed standard without requiring reformu 1 at ion~ 

However, the discussion will include liquid ·disinfectants which make·· 

deodorizing claims since these products are viewed by ARB staff as viable 

alternatives to aerosol air freshener/ disinfectants. 

2. Who will be affected by the proposed VOC standard for dual-purpose aerosol air freshener/disinfectants? 

The regulation will affect only aerosol products which are claimed to 

freshen or deodorize air and to disinfect hard surfaces. Note that products· 

that are sold and advertised only as hard surface aerosol disinfectants 

would D.Q1 be affected by the proposed standard. In addition, liquid and 

pump spray disinfectants that are claimed to deodorize would also .D.Q1 be 

affected by the standard. Products sold to the consumer market as well as 

the commercial/institutional markets will be subject to the regulation and 

proposed standard. 

It is interesting to note that the aerosol air freshener/disinfeGtant 

products sold to the consumer market gen~rally have much higher VOC levels 

than the p~oducts sold to the commercial/institutional market. Intuitively; 

one would expect commercial/institutional users to need higher VOC products, 

to inactivate the wider variety and greater concentrations of microbes 

encountered by these users.· This apparent anomaly will be further discussed 

in subsequent sections of this report. · 

Previous studies indicate that one brand of dual-purpose aerosol air 

freshener/disinfectants accounts for ove~ 90% of the consumer retail-mark~t 

and, consequently, over 90% of the emissions from this category . . (Soap/Cosmetics/Chemical Specialties, December 1988). In contrast with the 

consumer market, the commercial/institutional market for disinfectants is 

much more fragmented, with the largest market share for any one company 

probably not exceeding 20%. 

3. Why are we propos j ng to regu 1 ate the VOC content from dua 1 urpcise · ajr freshener/disinfectants? 

The California Clean Air Act of 1988 authorizes the ARB to regulate the 

VOC emissions from consumer products if it is necessary and commercially and 

technologically feasible. This paper will discuss the feasibility of 

regulating dual-purpose aerosol air freshener/disinfectants in subsequent 

-83-
sections. As for the necessity of regulating this product category, ARB 

staff believes that the VOC emissions associated with this product 

(approximately 4.3 tons/day), along with the availability of viable 

alternatives, justify the proposed VOC standard. Compliance with the 60% 

standard will result in 1.1 tons per day of VOC emission reductions. 

Staff proposes regulating the VOC content of these products because, for 

spray disinfectants, the VOC emissions are assumed to be directly 

proportional to the VOC content. Since these products are meant to be 

either sprayed into the air or sprayed onto a hard surface and evaporated, 

essentially all of the VOC contained in the package is eventually released 

into the atmosphere. Thus, for the purposes of this discussion, the terms 

"VOC content" and "VOC emissions" are used interchangeably. 

It is important to note that ARB staff does not question the need for 

disinfectants in the home and in commercial/institutional applications. 

Staff recognizes that current health concerns and consumer preferences 

require disinfectants in the home and commercial/institutional applications 

that are effective and useful. However, given the market and product 

efficacy data currently available on alternatives to current dual-purpose 

spray disinfectants, ARB staff believes that the VOC emissions from these 

products can be reduced while maintaining current levels of anti-microbial 

protection. 

Staff believes that this position can be supported by the following 

reasons. First, the spray disinfectants which are sold mainly in the retail 

(consumer) market are advertised or marketed such that consumers may 

significantly misuse these products as air fresheners. Television 

commercials and other advertisements involving these disinfectants clearly 

place a heavy emphasis on the deodorizing and room-freshening properties 

rather than the hard surface disinfecting properties of these products. ARB 

staff's shelf survey revealed that these air freshener/disinfectants are 

very often sold along with other air fresheners instead of other 

disinfectants. 

Dual-purpose aerosol air freshener/disinfectants have an average VOC 

level of 80% by weight. For comparison, the air freshener category has an 

average VOC content of 25% by weight, excluding dual-purpose products . . Since the dual-purpose products compete directly with other air fresheners, 

ARB staff believes that the standards for all similar air fresheners should 

be roughly equivalent. Staff also believes that many consumers spray these 

products into the air in the mistaken belief that they "disinfect" or 

"purify" the air. However, these products are not registered with EPA as 

"air sanitizers." Thus, spraying the products into the air provides Qn..ly 

air freshening benefits wjthoyt disinfecting benefits. It is important to 

note that the disinfecting benefits can only be achieved when the product is 

used as a hard surface disinfectant. When using these products correctly as 

hard surface disinfectants, the user must spray the product until a liquid 

film forms on the surface in accordance with the label instructions. 

The 1990 CARB Consumer Products VOC survey shows that VOC emissions from 

these dual-purpose products (4.3 tons/day) are approximately equivalent to 

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those from the entire air freshener category (4.5 tons/day). This data 

indicates that dual-purpose spray disinfectants are among the highestemitting product categories in the VOC survey. Because of the reasons cited 

previously and the following .discussion, ARB staff has determined that the 

emissions from this category should be reduced if the redUctions are 

technologically and commercially feasible. 

4. What are. dis j nfectants and what types of d j s j nfectants are 

available? 

The following, in order of ascending potency, are the three types of 

classifications the EPA assigns to microbially-inactivating products: 

sanitizers, disinfectants~ and sterilants. Sanitizers include general. 

housekeeping cleaners which reduce the number of some microbes on surfaces 

but are not rated for killing the prototype microbes used in classifying the 

different levels of disinfection. Sterilizers, on the other hand, must 

inactivate every microorganism on the surface, ihcluding high numbers of 

bacterial spores. Bacterial spores are among the most difficult of 

microorganisms to inactivate or kill. Disinfectants, therefore, fall _, ,, between these two . product extremes in. terms of the microbes which they k i Tl . and the rate of kill provided by the product. 

The efficacy of disinfectants is determined by the use of a set of 

rigidly controlled in vitro tests that are described in the Federal 

Register, the manual of the Association of Official Analytical Chemists 

(AOAC) and various EPA guidelines. Testing is conducted against various 

prototype microorganisms to achieve different disinfection designations. To. 

be registered as a "hospital" disinfectant, complete kill in 10 minutes must 

be demonstrated against Staphylococcus aureys (~. ayreus), Salmonella 

choleraesyjs (~. choleraesyjs), and Pseydonomas aerygjnosa (f. aerygjnosa). 

These tests must also demonstrate that the disinfectant acts in the presence 

of organic matter (5% serum) and that this activity is not diminished in the 

presence of hard water. 

5. Agajnst what types of mjcrobes are hospjtal djsjnfectants active? 

The EPA has chosen a strain of ~- ayreys as the prototype gram-positive 

organism because it is one of th~ more difficult of this group to kill when 

dried on an inanimate surface. Effectiveness against this organism tacitly 

presupposes effectiveness against other gram-positive bacteria, such as. 

streptococi, micrococci, other staphylococci, and coryneform bacilli. 

A strain of ~- choleraesyjs is accepted as the prototype enteric 

bacillus, and activity against it is generally assumed by the infection 

control community to predict effectiveness against members of the genera 

Escherjchja, Proteus, Salmonella, Shigella, Serratia, Enterobacter, 

Citrobacter, Arizona, Providencja; Morganella and other members of the 

family Enterobacteriaceae, i.e., all gram-negative rods that ferment 

glucose, do not produce spores, and are negative in the cytochrome oxidase 

test. 

-85-
A strain of f. aeruginosa is considered as the prototype aerobic 

bacillus. Action against it is assumed by the infection control community 

to predict effectiveness against oxidizing and nonoxidizing members of the 

large group collectively cited as nonfermenting bacilli. These include 

pseudonomads such as f. cepacja, f. pytida, f. stytzeri, f. alcaligenes, f. 

paycimobilis, f. maltophilja, f. pseydoalcaljgenes, as well as members of 

the genera Achromobacter, Flavobacterium, Acjnetobacter, Moraxella and a 

variety of unnamed CDC strains. 

Activity against ~. ayreys, ~. choleraesyjs and f. aerygjnosa satisfies 

the minimum requirements for EPA registration as a hospital disinfectant. 

Additional tests conducted against viruses, pathogenic fungi, and other 

bacteria can be performed to improve the disinfection classification of the 

product or to improve the marketability of the product. For instance, if 

activity against pathogenic fungi is claimed, an additional test against 

Trichophyton mentagrophytes (jnterdigjtale) is required. This microbe 

causes "athletes foot fungus." Furthermore, if activity against the 

tuberculosis bacteria is claimed, additional tests employing the BCG strain 

of Mycobacterium tuberculosis var. ~must be performed. It must be 

noted, however, that activity against M. tuberculosis does not necessarily 

mean that the product will reduce the pbysjcal transmission of tuberculosis. 

The main vector for transmission of tuberculosis in humans is believed by 

the infection control community to be airborne particles breathed into the 

lungs and not through physical contact with a hard surface. Many products 

document activity against M. tybercylosjs because it is regarded as one of 

the difficult-to-kill, benchmark microorganisms and not because they are 

trying to claim a reduction. in the transmission of tuberculosis through hard 

surface contact. 

6. What are the differences between the different brands of 

disinfectants? 

Once a product passes the mandated AOAC tests against ~- aureus, ~­

choleraesyjs, f. aeruginosa, M. tuberculosis and I. mentagrophytes, it is 

tacitly accepted as an effective disinfectant in the hospital environment 

for all pathogenic microorganisms except protozoa and viruses. Therefore, 

the main differences in disinfectants which have claims against these five 

prototype organisms are the types of virucidal activity which the products 

claim. EPA registration requirements allow specific virucidal claims only 

if the activity data is provided for that specific viral strain. For 

instance, the label of an approved disinfectant can claim virucidal action 

against a specific virus or an array of viruses-influenza, herpes, and 

vaccinia, for instance- but cannot make broad claims on the basis of 

predictive tests, as can antibacterial agents. A product with activity 

against rhinovirus will state the exact strain for which data have been 

submitted. In the case of myxoviruses, a manufacturer cannot claim activity 

against the myxovirus influenza 8 if it has submitted data that documents 

activity only against myxovirus influenza A. 

Conversely, because a product does not make a claim against a particular 

strain of virus, it does not necessarily mean that the product has no 

activity for that virus. In these cases, the economics of documenting the 

-86-
assays and test results for activity against certain viruses may not be 

favorable when competing products make these same claims and hold a very 

significant portion of the market. This may be the case for products 

competing with the one dominant product in the consumer retail market. As 

long as this product holds such a commanding and established' share of this 

market, any competing products would not be able to justify the cost of 

documenting activity against additional microbes because any potential 

market gains would probably be insignificant. 

With activity against all five prototype microbes, hospital 

disinfectants with tuberculocidal and fungicidal claims differ mainly by the 

activity claimed against different viruses. Some active ingredients in 

these products ~rovide broad spectrum virucidal activity; others are fairlyspecific in the types of viruses against which they claim activity. The 

different active ingredients available in current formulations inactivate 

viruses through varying mechanisms. Table 30 lists the different 

formulation types, their range of virucidal activity, and the mechanisms by~· 

which they inactivate viruses. 

As shown .in Table 30, the ethjnol (70%), glutaraldehyde, halogen 

(iodophors and hypochlorite) and hydrogen peroxide disinfectants provide the 

broadest-spectrum activity against viruses. Phenolic and quaternary ammonium products (quats) have narrow to moderate range in virucidal 

activity. 

7. What types of disinfectants are recommended for use in hospital. dental. and other healthcare applications? What types of 

disinfectants are recommended for yse on blood spills that may 

contain the hyman immunodeficiency virus (HIV) and hepatitis B virus 

(HBV)? How would the proposed standard affect the efficacy of the 

product in regard to preventing the transmission of these and other 

viruses? 

Given currently available data, ARB staff do not believe that the 

proposed standard will adversely affect the efficacy of disinfectants 

against the viruses that cause AIDS and other diseases. Recent public 

concern bas emphasized the prevention of the transmission of the AIDS virus. 

The human immunodeficiency virus (HIV) which causes AIDS is among the 

easiest of viruses to kill on environmental surfaces. At this time, no case 

of AIDS transmission through contact with environmental surfaces has been 

documented.. Probably of greater concern to health-care officials is the 

transmission of the hepatitis B virus (HBV), which carries a greater 

probability of transmission within the health-care setting. 

To address the public and health-care worker concerns about the 

transmission of these two viruses, the U.S Department of Health and Human 

Services (Centers for Disease Control or CDC) recently published their 

"Guidelines for Prevention of Transmission of Human Immunodeficiency Virus -· and Hepatitis B Virus to Health-Care and Public-Safety Workers" (henceforth 

"CDC Guidelines"). Among other things, these guidelines recommend 

procedures for cleanup of environmental surfaces in the health-care settin~~ 

-87-
Table 30 

Effect of Virucidal Contact Disinfectants After 10 Minutes 

Agent Spectrum 

Alcohol 70% Broad 

(Ethanol~ Isopropanol) 

Formaldehyde Broad 

Glutaraldehydea 

Halogensa 

!2 

Iodophors 

Hypochlorite 

Phenol and 

derivatives 

Quaternary Ammonium 

Compounds (Quats) 

Chlorohexidine 

Broad 

Moderate 

(lipophilic 

viruses) 

Narrow 

(lipophilic 

viruses) 

Hydrogen peroxidea Broad 

or organic peroxides 

aMost effective. 

Use 

Skin antiseptics, 

components of EPA 

disinfectantsb 

Preservatives, 

disinfectants, 

chemosterilizers 

Disinfectants, 

topical antiseptics 

Preservatives, skin 

antiseptics, 

disinfectants 

Skin antiseptics, 

disinfectants, 

preservatives 

Skin antiseptics, 

disinfectants, 

chemosterilizers 

Action 

Denature protein 

React with R-NH 2 

groups, protein 

inactivation 

Oxidizing agents 

Solubilize and 

proteins, 

dissolve lipid 

envelope 

Dissolve lipid 

envelope of 

ether-sensitive 

viruses 

Oxidizing agents 

bDisinfectant claims regulated by EPA, antiseptic claims by FDA. 

(Reprinted from Particulate & Microbial Control, March/April 1983) 

-88-
This document currently serves as the basis for operational guidelines used 

by hospital and dental associations, the Red Cross, and other health-care 

agencies. 

In these guidelines, the CDC classifies disinfectants in terms of 

whether they achieve high-, intermedi~te-, or low-level disinfection, as 

shown in Table 31. As can be seen in Table 31, sterilants and high-level 

di-sinfectants are recommended for use on equipment and tools that are 

invasive to or otherwise used on the human body. Environmental surfaces 

(e.g., counter-tops, sinks, toilet seats), which are found in homes, 

hospitals, dental offices and other areas where infection control is 

important, generally require only low- or intermediate-level disinfection or 

even cleanup with water and detergent, depending on the degree of 

disinfection required and whether any soil is present. r: 

As shown in Table 31, the CDC guidelines specify either low- or 

intermediate-level disinfectants for cleaning environmental surfaces. For 

surfaces where there is no significant amount of blood or blood-contaminated 

fluid, the CDC guidelines specify that low-level disinfection (i.e., 

hospital disinfectant without a tuberculocidal claim) will suffice. In 

those cases where there is a significant amount of blood or bloodcontaminated fluid, the CDC guideline specifies the use of an intermediatelevel disinfectant after precleaning of the visible material: that is, use 

of either a hospital disinfectant with a tuberculocidal claim or a solution 

containing at least 500 ppm free available chlorine (approximately 1/4 cup 

common household bleach per gallon of tap water). Intermediate-level 

disinfection is also recommended by the CDC for dental settings, where 

saliva containg blood may be present on the environmental surfaces.' 

From Table 31, it is apparent that hospital and dental hard surface 

disinfection requires only low- or intermediate-level disinfection. 

Products that perform intermediate-level disinfection are those with 

tuberculocidal claims. In addition tb the 500 ppm chlorine solution noted 

in Table 31, other products are available which will meet the requirements 

for intermediate-level disinfectioni To determine the number of hospital 

disinfectants with tuberculocidal claims (i.e., intermediate-level 

disinfectants), staff conducted searches through EPA's National Pesticides 

Information Retrieval System (NPIRS) and the pesticides database compiled by 

the California Department of Food and Agriculture (CDFA). From these 

searches, staff found 85 tuberculocidal hospital disinfectants registered 

with EPA. In addition, staff also found 101 EPA-registered products that 

claim activity against the HIV virus (AIDS). Note that the products with 

claims against the AIDS virus do not necessarily claim tuberculocidal 

activity, which indicates the relative ease at which the HIV virus is 

inactivated. Although there is some overlap between the results from these 

two searches, it can be clearly shown that there are numerous products which 

can meet the requirements'of the Centers for Disease Control for the 

prevention of transmission of the HIV and HBV viruses. 

-89-
Sterilization: 

High-Level 

Disinfectant: 

TABLE 31 

Reprocessing Methods for Equipment Used in the 

Prehospital 1 Healthcare Setting 

Destroys: All forms of microbial life including high 

numbers of bacterial spores. 

Methods: 

Use: 

Steam under pressure (autoclave), gas 

(ethylene oxide), dry heat, or immersion in 

EPA-approved chemical "sterilant" for 

prolonged period of time, e.g. 6-10 hours or 

according to manufacturers' instructions. 

Note: liquid chemical "sterilants" should be 

used only on those instruments that are 

impossible to sterilize or disinfect with 

heat. 

For those instruments or devices that 

penetrate skin or contact normally sterile 

areas of the body, e.g., scalpels, needles, 

etc. Disposable invasive equipment eliminates 

the need to reprocess these types of items. 

When indicated, however, arrangements should 

be made with a health-care facility for 

reprocessing reusable invasive instruments. 

Destroys: All forms of microbial life except high 

numbers of bacterial spores. 

Methods: Hot water pasteurization (80-100 C, 30 

minutes) or exposure to an EPA-registered 

"sterilant" chemical as above, except for a 

short exposure time (10-45 minutes or as 

directed by the manufacturer). 

Use: For reusable instruments or devices that come 

into contact with mucous membranes (e.g. 

laryngoscope blades, endotracheal tubes, 

etc.). 

Intermediate-Level Destroys: Mycobacterium tybercylosjs, vegetative 

Disinfectant: bacteria, most viruses, and most fungi, does 

not kill bacterial spores. 

-90-
Low-Level 

Disinfection: 

Environmental 

Disinfection 

Methods: 

Use: 

TABLE 31 (Con't) 

EPA-registered "hospital disinfectant" 

chemical germicides that have a label claim 

for tuberculoidal activity; commercially 

available hard-surface germicides or 

solutions containing at least 500 ppm free 

available chlorine (a 1:100 dilution of 

common household bleach-approximately 1/4 cup 

bleach per gallon of tap water). 

For those surfaces that come into contact 

only with intact skin, e.g., stethoscopes, 

blood pressure cuffs, splints, etc., and have 

been visibly contaminated with blood or 

bloody body fluids. Surfaces must be 

precleaned of visible material before the 

germicidal chemical is applied for 

disinfection. 

Destroys: Most bacteria, some viruses, some fungi, but 

not Mycobacterium tybercylosjs or bacterial 

spores. 

Methods: 

Use: 

EPA-registered "hospital disinfectants" (no 

label claim for tuberculosis activity). 

These agents are excellent cleaners and can 

be used for routine houskeeping or removal of 

soiling in the absence of visible blood 

contamination. 

Environmental surfaces which have become 

soiled should be cleaned and disinfected 

using any cleaner or disinfectant agent which 

is intended for environmental use. Such 

surfaces include floors, woodwork, ambulance 

seats, countertops, etc. 

IMPORTANT: To assure the effectiveness of any sterilization or disinfection 

process, equipment· and instruments must first be thoroughly 

cleaned of all visible soil. 

1 Defined as setting where delivery of emergency health-care takes place prior to arrival at hospital or other health-care facility. 

-91-
8. Why was 60% by weight VOC chosen as the standard for spray 

disinfectants? 

ARB staff's analysis of current disinfectant technology indicated that 

60% by weight VOC is adequate for products to meet hospital disinfection 

requirements. Staff has determined that alternative non-air freshener 

products are available which are EPA-registered hospital disinfectants. 

Moreover, these products can meet guidelines issued by the U.S. Department 

of Health and Human Services for the use of disinfectants in health-care and 

dental settings to help prevent the transmission of the AIDS and hepatitis B 

viruses. Because of the way these dual-purpose products are marketed and 

used, they may compete directly with two-phase aerosol air fresheners. Both 

products provide similar air freshening benefits. Therefore, ARB staff 

believes that the standards for these similar-use products should likewise 

be similar. The current standard for two-phase aerosol air fresheners is 

30% VOC by weight. Staff therefore proposed the limit for these dualpurpose products as 60% to reflect the need for additional VOC for 

disinfection. 

Dual-purpose aerosol air freshener/disinfectants, most of which are 

based on high levels of ethanol, contain propellents whose primary purpose 

is to deliver the ethanol and a small amount of other active ingredients in 

a convenient manner for the consumer. The difference between these products 

and a liquid disinfectant which has the same disinfectant classification 

then becomes a matter of convenience to the consumer. Staff set the 

standard at the minimum amount of ethanol required for an aerosol product to 

inactivate the five prototype organisms required for the hospital 

disinfectant classification with tuberculocidal and fungicidal activity. 

Staff expects most, if not all, liquid/pump spray disinfectants with this 

type of activity will easily comply with the standard after proper dilution. 

9. If we limit the VOC content of these products. are we indicating 

that homeowners do not deserve the same antimicrobial protection as 

hospitals? What air freshener/disinfectants do hospitals really 

.u.a? 

As stated previously, the Centers for Disease Control recommends lowor intermediate-level disinfectants for hospital and dental hard surface 

disinfection. Although the ethanol-based aerosol products qualify as 

intermediate-level surface disinfectants, they are by no means the only 

products available that can satisfy the CDC recommendations. ARB staff's 

discussion with hospital personnel indicates that most hospitals and dental 

offices in California use corrmercially-available liquid disinfectants. With 

the help of the California Association of Hospitals and Health Systems 

(CAAHS), ARB staff found that none of the more than twenty-four hospitals 

and health clinics surveyed used aerosol disinfectants. Hospitals surveyed 

include Kaiser Permanente, Sutter Memorial, and various smaller 

establishments. The only aerosol product used by these hospitals was a 

spray lubricant for use on surgical equipment. The hospital personnel 

contacted by the CAAHS staff cited three reasons for not using aerosol spray 

disinfectants: (1) the individually-packaged aerosol disinfectants are not 

economical when compared to liquid disinfectants purchased in bulk, (2) 

-92-
health and environmental concerns regarding sprayihg an aerosol product 

around senstitive patients, (3) the relative ease with which individually 

packaged aerosol products are stolen from health-care facilities. Of these, 

the main reason cited was economic; aerosol sprays cannot compete with bulk 

liquid disinfectants on a per volume basis. 

A frequently overlooked but highly-effective alternative to consumer- ':. 

and commercially-formulated disinfectants is common household bleach. When 

diluted to a 500 ppm solution, it will kill many, if not all, of the 

microbes against which currently available disinfectants claim activity. As. 

previously stated, there. are also numerous liquid disinfectants registered 

with EPA that will accomplish the same level of disinfection as the aerosol' 

products but at a lower VOC content. Again, it should be noted that the 

standard would not apply to products sold or advertised solely as a hard 

surface aerosol disinfectant. Staff therefore believes that there will 

still be efficacious disinfectants available to the consumer. 

10. If liQuid djsjnfectants are ysed in place of spray djsjnfectantsi 

wjll there be safety problems wjth children possjble swallowing the ljgyjd? 

Industry representatives contend that, as alternatives to aerosol 

products, liquid disinfectants present a safety concern from the potential . accidental swallowing by children. Although this is a legitimate concern~ r 

staff believes that properly-designed packaging will eliminate or 

significantly reduce this concern. ARB staff has identified from the NPIRS 

search at least 8 liquid/pump spray disinfectants which employ chi·ldresistant packaging. Moreover, staff believes that the potential for· 

accidental swallowing cannot be completely eliminated from either the spray 

or liquid packaging. Therefore, although the potential for accidental 

swallowing cannot be completely eliminated, ARB staff believes that 

packaging technology is currently available that will significantly reduc~ 

or eliminate this concern. 

11. Will limiting the VOC content jn dyal-pyrpose aerosol ajr 

freshener/disinfectants reduce thejr efficacy agajnst germ-causing 

.QSiQr:.s.? 

As stated previously, spraying into the air provides only air 

freshening benefits and no documented disinfecting benefits. Thus, spraying 

a high~VOC disinfectant into the air to deodorize a room achieves only air 

freshening benefits, which could be similarly achieved with numerous 16W~voc 

air fresheners. In addition, these products are often advertised as being capable of "clearing" the air of noxious cigarette smoke and similar fumes. 

Cigarette smoke, which is composed of minute particles of soot and ash, can 

be removed from the air by contacting the particles with sufficiently-sized. droplets of liquid. This process, known as "scrubbing", forms the basis fof\ 

wet scrubbing in particulate control systems and is the main reason why dirty air is cleaner after a rain storm. In the case of cigarette smoke 

removal in air, the size of the liquid droplet is the controlling factor; 

Thus, any liquid, including plain water, can "clear" a cigarette s~okefilled room if sprayed at the proper droplet size. 

-93-
The germs that cause odors on hard surfaces in the household, such as 

E. coli, are relatively easy to kill when compared to the prototype 

organisms used in EPA disinfectant classifications. Staff believes that at 

60% VOC, spray disinfectants should be able to retain activity against odorcausing germs. As in the previous discussion, there are alternative 

disinfectants that are able to kill the odor-causing organisms at lower VOC 

levels. Of course, these alternatives include properly-diluted common 

household bleach. 

12. ARB staff appears to view household bleach as a viable alternative 

to spray disinfectants. Is a 500 ppm bleach solution corrosive in 

the household environment? 

Because of its oxidizing properties, a 500 ppm bleach solution is 

considered by staff to be an inexpensive but highly effective disinfectant 

for household and institutional uses. A bleach solution at this 

concentration (approximately 1/4 cup household bleach in a gallon of water) 

is recommended by the U.S. Department of Health and Human Services for use 

in health-care and dental settings. A 500 ppm bleach solution is generally 

not considered to be corrosive in the household environment. For 

comparison, staff estimates that a typical load of laundry with bleach 

contains about 3700 ppm of bleach. In addition, the 5% bleach solution as 

sold in the package is rated as non-corrosive under Department of 

Transportation regulations for transport. This indicates that a 500 ppm 

bleach sol~tion should not adversely affect hard surfaces found in the home. 

13. How can an ajr fresbener/djsjnfectant manufacturer comply wjth 

thjs standard? 

There are essentially four ways for a manufacturer to comply with the 

60% standard: (1) sell, advertise and market the product Qfily as a hard 

surface disinfectant and not as an air freshener, in which case the product 

would no longer be subject to the regulation, (2) reformulate the product to 

reduce the VOC content and use an exempt VOC or non-VOC propellent, (3) 

reformulate the product to reduce the VOC content and use it in a pump, (4) 

redesign the product into an innovative package such that it emit~ fewer 

emissions. Of these, options 1, 2 and 3 are believed to be the most costeffective and easiest options to implement. Note that option 1 requires 

only a labeling and marketing change. 

-94-
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Editors of Consumer Reports Books, with Monte Florman, How to Clean 

Practically Anything, New York, Consumers Union, 1986. 

Editors of Time-Life Books, Cleaning, Virginia, Time-Life Books, 1982. 

Federal Register, 6-29-89, vol. 54, no. 124 

"Free Mousses," Aerosol Age, March 1988. 

"Glass Cleaners", Consumer Reports, October 1989, pp. 611-614. 

-95-
Harry, Ralph G., Revised by Myddleton, William M., Cosmetic Materials. 

Their Origin. Characteristics. Uses and Dermatological Action, Vol.ume 

Two, Chemical Publishing Co., Inc., New York 1963. · · 

Jakobi, Ghunter, and Lohr, Albrecht, Detergents ahd Textile Washing. Principles and Practice, VCH ~ublishers, New York 1987~ · 

Johnson, J.C., Emulsifiers and EmulsifYing Techbi~ues, New Jersey, 

Noyes Data Corporation, 1979. 

Life Systems, Inc., "Toxicological Profile for 1,4-Dichlorobenzene", 

prepared under contract for Agency for Toxic Substances and Disease 

Registry. January 1989. 

Maksimoski, Richard C.~ and Hoskins, James J., "Formulation of Alcohol 

. .. MabufattOring Chemist, November 1987. 

Milwidsky, Ben, "Ho.usehold Chemical Specialties", HAPPI, l989, pp. 5-9. 

Milwidsky, Ben, "Hard Surface Cleaners", HAPPI, 1980, pp. 3~34. 

Murphy, E. J,, and Petter, P. J., "Formulating Aerosol Mousse Products 

for Hair Care," Aerosol Age, December 1983. 

Murphy, Edward J., "Hairsprays: Yesterday, Today, and Tomorrow," 

Oteri, Rosaro J., Johnson, Dr. Stephen, and Hollenbach, Roger, "Formulating Gantrez Resin Based Hairspray Without Methylene Chloride," 

Aerosol Age, August 1985. 

Pavlichko, Joseph P., "Making a Mousse .. ~,? Aerosol Age, January 1985. 

Petter, P. J., "Hairsprays- The Role of Resins,d Manufacturing Chemist, November 1982. · · · IL ., 

Pacific Environmental Services, Analysis of Regulatory alternatives for 

Conttolling Volatile.Organic Compound Emissions from Consumer and · Commercial Products i~ New York City Metropolitan Area, Vol. I~. 

Submitted to the New York State Department of Environmental 

Conservation, January 1990. 

Prince, Herbert N., ~Disinfectant Activity Against Bacteria and 

Viruses: A Hospital Guide", Particulate and Microbial Control, 

March/April 1983. 

SanGiovanni, Michael L., "~PA Hunti for VOC Regulatory Options", 

Aerosol Age, February 1990, pp. 24-27. 

Science Applications International Corporation (EPA), Photochemically 

Reactive Organic Compound Emiss.jons From Consumer and Commercial Producfs;'Nove~bet 26; 1986. 

-96-
Speer, Wayne, "The California Challenge", Aerosol Age, June 1990, pp. 

20-33. 

Stoller, Leonard, and Sciarra, John J., The Science and Technology of 

Aerosol Packaging, John Wiley and Sons, N.Y., 1974. 

The Federal Insecticide. Fungicide. and Rodenticide Act. As Amended, 7 

u.s.c. 136-136y. 

The Science Action Committee, Consumer's Guide to Cosmetics, Anchor 

Books, New York 1980. 

The Soap and Detergent Association, A Handbook of Industry Terms, 3rd 

ed., June 1987. 

U.S. Department of Health and Human Services (Centers for Disease 

Control), Guidelines for Prevention of Transmission of Human 

Immunodeficiency Virus and Hepatitis B Virus to Health-Care and Public 

Safety Workers, February 1989. 

U.S. Department of Health and Human Services, Practical Infection 

Control in the Dental Office, December 1989. 

Wells, F.V., and Lubowe, Irwin I., Cosmetics and the Skin, Reinhold 

Publishing Corp., New York 1964 · 

Wilkinson, J.B., and Moore, R.J., Harry's Cosmeticology, Chemical 

Publishing Corp., New York 1982. 

Woollatt, Edgar., The Manufacture of Soaps. Other Detergents and 

Glycerine, John Wiley & Sons, New York 1985. 

-97-
REFERENCES (CON'!) 

. ··' 

WRITTEN COMMENTS ON PROPOSED CHANGES 

TO THE STATEWIDE CONSUMER PRODUCTS RVLE 

Company 

Canberra Corporation 

Ian Gecker & Associates (2 letters) CCL Industries 

JASCO Chemical Corporation 

May Kay Cosmetics, Inc. 

Sprayon Products 

Blue Magic Products, Inc. 

Ecolab Inc. 

The Soap and Detergent Association 

The Procter & Gamble Company 

Chemcial Specialties Manuf. Assoc at'ion 

Halogenated Solvents Industry All ance 

Creative Products Inc. 

Cardinal · Accra Pac, Inc. 

Dupont 

Environmental Protection Agency· Fairfield American Corp. 

May Kay Cosemtics, Inc. 

Cyc 1 o Automat i ve Prod·ucts 

Justice Brothers, Inc. 

BAF Industries 

Major Paint Company 

The Cosmetic, Toiletry, & Fragrance Association 

Dow Corning Corporation 

Chesebrough-Ponds USA 

Cosmosol, Ltd. 

Chemical Specialties Manufacturers Association 

Portion Pac, Chemical Corporation Car-Freshener Corporation 

Dow Corning Corporation Champions Choice, Inc. 

Halogenated Solvents Industry alliance 

The Aerosol Group 

Apollo 

The Procter & Gamble Company Colgate-Palmolive Company 

Paul, Hastings, Janofsky & Walker 

Faultless Starch 

The Soap and Detergent Association 

Claire Manufacturing Company Copper Brite, Inc. 

CCL Industries, Inc. 

-98-

Letter 

2-16-90 

2-23-90 

3-01-90 

3-2-90 

3-2-90 

3-4-90 

3-5-90 

3-5-90 

3-5-90 

3-5-90 

3-5-90 

3-6-90 

2-26-90 

3~12-90 

3-12-90 

3-9-90 

3-15-90 

3-6-90 

3-8-90 

3-15-90 

3-14-90 

3-15-90 

3-14-90 

3-6-90 

3-12-90 

4-2-90 

4-4-90 

. 4-6-90 

4-6-90 

4-2-90 

4-2-90 

4-11-90 

4-12-90 

4-25-90 

4-26-90 

4-27-90 

5-10-90 

5-10-90 

5-17-90 

5-21-90 

5-21-90 

5-22-90 

5-22-90 
Accra Pac Group 

Kirkpatrick & Lockhart 

Cyclo Automotive Products 

Dow Corning, USA 

The Clorox Company 

Montfort A. Johnson & Assoc., LTD · Chemical Specialties Manufacturers Association 

Dow Corning Corporation 

Mary Kay Cosmetics, Inc. 

Halogenated Solvents Industry Alliance 

Creative Products, Inc. 

The Procter & Gamble Company 

The Soap and Detergent Association 

Ecolab Inc. 

The Procter & Gamble Company 

Livingston & Mattesich Law Corporation 

The Cosmetic, Toiletry and Fragrance Association 

Paul, Hastings, Janofsky & Walker 

First Brands Corporation 

The Procter & Gamble Company Accra Pac Group 

Accra Pac Group 

Claire Manufacturing Company 

Radiator Specialty Company 

KMS Research 

Airwick Industries 

Fragrance Materials Association of the United States 

Sprayon Products 

The Soap and Detergent Association 

The Cosmetic, Toiletry and Fragrance Association 

Sprayon Products 

Radiator Specialty Company 

Chemical Specialties Manufacturers Association 

Ecolab Inc. 

The Procter & Gamble Company 

Environmental Protection Agency 

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5-24-90 

5-30-90 

5-31-90 

6-1-90 

6-5-90 

6-7-90 

6-11-90 

6-14-90 

6-19-90 

6-22-90 

6-28-90 

6-29-90 

7-3-90 

7-5-90 

7-6-90 

7-10-90 

7-11-90 

7-12-90 

7-13-90 

7-26-90 

7-30-90 

7-31-90 

7-31-90 

8-1-90 

8-3-90 

8-3-90 

8-3-90 

8-3-90 

8-3-90 

8-6-90 

8-6-90 

8-6-90 

8-6-90 

8-7-90 

8-8-90 

8-10-90 
REFERENCES (CON'!} 

PHONE CONVERSATIONS 

Company 

CTFA 

National Starch & Chemical Corp. BASE 

Cosmosol LTD. 

Ecolab, Inc. 

Unsmoke International 

Amway 

Sani Fresh International 

J. Hubbard, Inc. 

Willert Home Products 

Air-Scent International 

Boyle Midway (A/F) 

Murphy - Phoenix Co. 

Pioneer/Eclipse 

Las - Stick Manufacturing Co. 

Faultless Starch 

Theochem 

Pennzoil 

Whink Products Company 

Natal Industries Inc. 

Colgate-Palmolive Co. 

Sunshine Makers Inc. 

Company 

GAF Chemical Corp. 

Stepan Chemical Company 

Precision Valve Corp. 

Mary Kay Cosmetics, Inc. 

Steiner Co. Inc. 

Car Freshner Corp. 

Big "D" Industries, Inc. 

Stan home 

Drackett Products Co. 

Mil-Du-Gas Co. 

Desca le It 

Blue Coral, Inc. 

SC Johnson & Son, Inc. 

Rohm & Haas 

Scott's Liquid Gold 

Howard Products, Inc. 

Procter & Gamble 

LPS Labs 

Del Laboratories 

Revlon, Inc. 

CCL Industries Inc. 

Summit Chemical 

Chevron Chemical Co. 

)l. 

Mclaughlin Gormley King Co. 

Meteorology Sect., Tech Sup. Div ARB 

California Dept. of Food & Ag. 

Infection Control, Sac. U.C. Med 

Pfizer 

Texas Tech University Health Services 

Environ. ·Protection Agency, FIFRA Reg.· 

Ctr EPA office of Pesticides (Disinf.Br~) 

Miles Inc. 

Mearl Co. 

Scotch Corporation 

Certified Growers 

Firman and Warren 

Fleming Foods 

Southern California Grocers Assoc. 

American Hospital Association 

California Dental Association 

Calif. Assoc. of Health Facilities 

Calif. Assoc. of Rehabilitation Fac. 

Calif. Licensed Voc. Nurses Assoc. 

Sullivan, Roche and Johnson 

Medi-Cal 

Oemert and Dougherty, Inc. 

National Pesticide Info. Retrieval Sys. 

Ohio Envir. Protection Agency 

Dow Brands 

E.I. Dupont De Nemours & Co. 

Market Wholesale Grocery Co. 

Northern California Grocers Assoc. 

Em co 

California Grocers Assoc. 

Calif. Assoc. Hospitals & Health Syst. California Assoc. of AIDS Agencies Calif. Assoc. of Medical Products 

Calif. Hotel and Motel Association 

California Pharmacy Association 

Calif. Assoc. of Catholic Hospitals Aerosol Services Co., Inc. 

Redken Laboratories, Inc. 

John Paul Mitchell Systems 

U.S. Dept. of Health and Human 

Amer. Assoc. for Health Serv. at Home 

Services, Centers for Disease Control 

-100-
REFERENCES (CON'!) 

QAlE. 

08/17/89 

08/31/89 

10/20/89 

01/22/90 

02/13/90 

02/13/90 

02/22/90 

02/22/90 

03/01/90 

03/01/90 

03/01/90 

03/15/90 

03/21/90 

03/23/90 

03/26/90 

03/27/90 

03/27/90 

04/10/90 

04/11/90 

04/12/90 

04/26/90 

05/08/90 

05/16/90 

05/17/90 

05/22/90 

05/22/90 

06/01/90 

06/19/90 

06/20/90 

06/22/90 

06/25/90 

06/27/90 

06/28/90 

06/28/90 

06/28/90 

07/03/90 

07/03/90 

07/11/90 

07/16/90 

07/18/90 

07/25/90 

08/1/90 

08/1/90 

08/7/90 

CONSULTATION MEETINGS 

Descrjptjon 

3M 

Lehn & Fink 

Cosmosol 

Winzer Company 

Procter & Gamble 

Soap & Detergent Assoc. 

Procter & Gamble 

Vidal Sassoon 

Sprayon Products 

PMI 

Johnson Wax 

Johnson Wax 

Sprayon 

Lubrizol 

Chemsicol 

Chesebrough-Ponds 

Gillette 

CTFA 

CSMA 

Alberto Culver 

EPA 

Faultless Starch 

Scotts Liquid Gold 

Colgate-Palmolive 

Procter & Gamble 

Paradichlorobenzene Producers 

CTFA 

Drackett 

Johnson Wax 

Monsanto, Willert 

Soap & Detergent Lehn & Fink 

Mclaughlin Gormley King Co. 

Sprayon 

Chevron Chemical 

Location 

Sacramento 

San Francisco 

II 

Sacramento II 

II 

Fairfield 

Sacramento II 

II 

II 

II 

II 

Ecolab, Airwick, State Chemical Co. 

CSMA - Engine Degreasers 

CTFA - Hairspray Manufacturers 

California Dental Association 

California Association of Hospitals and Health Systems Charcoal Lighter Fluid Industry Representatives 

3M 

CSMA - First Brands 

Lehn and Fink 

-101-

II 

II 

II 

II 
Appendix A 

California Clean Air Act Section 26 
AB 2595 

SEC. 26. Section 41712 is added to the Health and 

Safety Code, to read: 

41712. (a) On or before January. 1, 1992, the state 

board shall adopt regulations to achieve the maximum 

feasible. reduction in reactive organic compounds 

emitted by consumer products, if the state board 

determines that adequate data exists for it to adopt the 

regulations. 

(b) The state board shall not adopt regulations 

pursuant to subdivision (a) unless the regulations are 

technologically and commercially feasible, and necessary 

to carry out this division. 

(c) For purposes of this section, a "consumer product" 

means a chemically formulated product used by 

household and institutional consumers, including, but not 

limited to, detergents; cleaning compounds; polishes; 

floor finishes; cosmetics; personal care products; home, 

lawn, and garden products;· disinfectants; sanitizers; and 

automotive speciality products but do not include paint, 

furniture coatings, or architectural coatings. 

(d) Prior to January l, 1994, a district shall adopt no 

regulation relating to a consumer product which is 

different than any regulation adopted by the state board 

for that purpose. 
Appendix 8 

Proposed Consumer Product Regulation 
PROPOSED 

REGULATION FOR REDUCING VOLATILE ORGANIC COMPOUND 

EMISSIONS FROM CONSUMER PRODUCTS 

Adopt new Article 2, Consumer Products, Sections 94507-94516, Title 17, 

California Code of Regulations, to read as follows: 

SUBCHAPTER 8.5 CONSUMER PRODUCTS 

Article 2. Consumer Products 

94507. Applicability 

Except as provided in Section 94510, this article shall apply to any 

person who sells, supplies, offers for sale, or manufactures consumer 

products in the state of California. 

NOTE: Authority cited: Sections 39600, 39601, and 41712, Health and Safety 

Code. Reference: Sections 39002, 39600, 40000, and 41712, Health and 

Safety Code. 

94508. Definitions 

For the purpose of this article, the following definitions apply: 

( 1) Aerosol Food Product means any food product dispensed from an 

aerosol container. 

( 2) Aerosol Product means a pressurized spray system that dispenses 

product ingredients by means of a propellant or mechanically 

induced force. 

( 3) Air Freshener means any consumer product including, but not 

limited to, sprays, wicks, powders, and crystals, designed for the 

purpose of masking odors, providing a scent, or deodorizing. 

This category includes disinfectant aerosol spray products that 

are sold or advertised for dual use as air fresheners and hard 

surface disinfectants. "Air freshener" does not include products 

that are used on the human body, or products that function 

primarily as cleaning products as indicated on a product label or 

advertisement. 
( 4) Antjperspjrant·means any product including, but not limited to, 

aerosols; roll-ons, stickS, pumps, pads, creams, and squeezebottles, that is intended by the manufacturer to be used to reduce 

perspiration in the .human a xi 11 a bj at 1 east 20 percent in at 

least 50 percent of a target population. 

( 5) Architectural Coating means coatings applied to stationary 

structures and their appurtenances, to mobile homes, to pavements, 

or to curbs. 

( 6) Automotive Bug and Tar Remover means a specialty cleaning product 

used primarily to remove materials such as bugs, road tars, and 

oil which have adhered to a motor vehicle's body. 

( 7) Automotive Chrome Polish means a specialty maintenance product 

used to clean and polish a motor vehicle's chrome components. 

( 8) Automotive Leather/Vinyl Cleaner means a specialt~'cleaning 

product used .to clean the leather or vinyl componi:mts.'of a motor 

vehicles's interior. · · 

( 9) Automotive Tire Dressih~ means ~ ~pecialty prbduct designed to 

provide lustre and/or protect a motor vehicle tire. 

(10) Automotive Wheel Cleaner means a specialty product used to remove 

materials such as dirt and grime from a motor vehicle's wheels. 

(11) Automotive Wjadshjeld Washer Fluid means any liquid designedc"fdr 

use in a motor vehicle windshield washer fluid system for the 

·purpose of cleaning, washing, or wetting the windshield(s). · Automotive windshield washer fluid does not include any fluid 

which is placed in a new motor vehicle at the time the vehicle is 

manufactured. 

(12) Bathroom and TUe Cleaner means a specialty cleaner formulated 

specifically for bathroom and/or tile cleaning. 

(13) Brake-Cleap~r means a 5pecialty cleaning product designed to 

remove oil,: grease, or brake fluid from motor vehicle brakes 

without leaving a residue. ·. 

(14) Carburetor -dChoke Cleaner means a product designed to remove dirt 

and other contaminants. from a carburetor and its components. 

(15) Charcoal Lighter flujd means any combustible organic liquid used 

to ignite charcoal. 

(16) Colorant means any pigment or coloring material used in a consumer 

product for an aesthetic effect, or to dramatize an ingredient. 

-2-
(17) Consumer Product means a chemically formulated product used by 

household and institutional consumers including, but not limited 

to, detergents; cleaning compounds; polishes; floor finishes; 

cosmetics; personal care products; home, lawn, and garden 

products; disinfectants; sanitizers; and automotive specialty 

products but do not include paint, furniture coatings, or 

architectural coatings. 

(18) Deodorant means any product including, but not limited to, 

aerosols, roll-ons, sticks, pumps, pads, creams, and squeezebottles, that is intended by the manufacturer to be used to 

mrnrmrze odor in the human axilla by retarding the growth of 

bacteria which cause the decomposition of perspiration. 

(19) Disinfectant means any product intended to destroy or irreversibly 

inactivate infectious or other undesirable bacteria, pathogenic 

fungi, or viruses on surfaces or inanimate objects and whose label 

is registered under the Federal Insecticide, Fungicide, and 

Rodenticide Act (FIFRA, 7 U.S.C. 136, et seq.) 

(20) Distributor means any person who transports or stores or causes 

the transportation or storage of consumer products at any point 

between any consumer product manufacturing plant and any retail 

outlet or whole-sale-purchaser-consumer's facilities. 

(21) Double Phase Aerosol Air Freshener means an aerosol air freshener 

with the liquid contents in two or more distinct phases and 

requiring that the product container be shaken before use to mix 

the phases, producing an emulsion. 

(22) Dusting Aid means a spray product designed to assist in removing 

dust and other residuals from finished wood surfaces, including 

floors, and which after drying leave behind no film or other 

residuals on such surfaces. 

(23) Engine Degreaser means a specialty cleaning product designed to 

remove grease, grime, oil and other contaminants from the external 

surfaces of engines and other mechanical parts. 

(24) Executive Officer means the Executive Officer of the Air Resources 

Board, or his or her delegate. 

(25) Fabric Protectant means a product specially designed to be applied 

to fabric substrates to protect the surface from soiling from dirt 

and other impurities. 

(26) Flexible Flooring Material means asphalt, cork, linoleum, no-wax, 

rubber, seamless vinyl and vinyl composite flooring. 

-3-
(27) Floor Poljsh (Wax) means waxes, polishes, finiSh restorers o'r any 

other products for the purpose of polishing, prot~cting or 

enhancing the surfaces .. of floors and excluding products only for 

the purpose r;Jt' cleaning floors, products formulated for unfinished 

wood floors, and coatings subject to architettural coatings rules. 

(28) £QQa means (1) articles used for food or drink for man or other 

animals, (2) chewing gum, and (3) articles used for components of 

any such article. · 

(29) Fragrance means a subst~nce or complex mixture of aroma chemicals, 

natural essential oils, and other functional components with 

a combined vapor pres$_ure not in excess of 2 mmHg at 20 C, the 

sole purpose of which is to impart an odor or scent, or to 

counteract a malodor. 

(30) Furniture Maintenance Product means a wax, polish, conditioner, 

moisturizer or any other product designed for the purpose of 

po1ishing, protecting or enhancing finished wood surfaces other 

than floors and excludes products only for the purpose of cleanjn~. Furniture maintenanc~ produtt does not includ~ dusting 

sprays.·· 

(31) Furniture Coating means any paint applied to; room furnishings 

which include cabinets (kitchen, bath and vanity),. tab~~s, chairs, 

beds, and sofas. . " 

(32) General Purpose Cleaner mean; a formulation desigiied for .general 

all-purpose cleaning, in contrast to specialty cleaning ·products 

made to clean in certain situations. 

(33) Glass Cleaner means a specialty cleaning product designed prima~ily for cleaning surfaces made of glass. · 

(34} Hairspray means a consumer product designed primarily for the 

purpose,of.dispensing droplets of a resin on and into a hair coiffur~ Which will impart sufficient rigidity to the. coiffure to 

establish or: re~ain the style for a period of time. 

(35) Hair Mousse means a hairstyling foam which facilitates styling of 

a coiffure and provides limited holding power. 

(36) Hair Styljng Gel means a high viscosity, often gelatiriou;, 

product that contains a resin and is applied to hair to aid in 

styling and sculpting of the hair coiffure. 

(37} Household Adhesive means any substance that is used to bond one 

surface to another by attachment. 

-4-
(38) Household Consumer means any person who uses consumer products in 

his or her daily activities including, but not limited to, 

personal care; cooking; cleaning; laundering; or home and auto 

maintenance. 

(39} Household Pestjcjde means any pesticide product distributed to the 

retail market. 

(40} Household Sealant and Caulking Compound means any product designed 

to fill in cracks, close or secure an object, or to prevent 

seepage of moisture or air. 

(41} Industrial Spray Buff means a liquid or aerosol product mixture of 

polymer, resins, waxes and solvents that is used in conjunction 

with a floor machine and special pad for restoring worn floor 

polishes. 

(42) Insect Repellent means a compound or combination of compounds 

which are applied to human skin, hair or clothing in order to 

prevent contact with or otherwise repel biting insects and pests. 

(43) Institutional Consumer means an organization, business, or 

establishment engaged in either the nonprofit promotion of a 

particular public, educational, or charitable cause, or the 

transfer of commodities or services for profit. Institutional 

consumer includes but is not limited to government agencies, 

schools, hospitals, sanitariums, prisons, restaurants, stores, 

automobile service centers, health clubs, theatres, or 

transportation companies. This does not include private 

residences. 

(44) Laundry Detergent means a product containing a surfactant and 

other ingredients, formulated to clean and care for fabric articles. 

(45) Laundry Prewash means a specialty product that is applied to a 

fabric prior to laundering and that supplements and contributes to 

the effectiveness of laundry detergents and/or provides 

·specialized performance. 

(46) Laundry Starch Product means a product that is applied to a fabric 

after laundering to impart and prolong a crisp, fresh look and 

retain the shape of the garment and that may act as an aid to make 

ironing of the fabric easier. Such products include, but are not 

limited to, fabric finish, sizing, and starch. 

(47) Lubricant means any liquid or solid that reduces friction, heat, 

and wear when applied as a surface coating to a moving part. 

-5-
(48) Manufacturer means any person or business entity that produces, 

packages, repackages, or relabels a consumer product for sale in 

California. 

(49) Nail Polish Remover means a product primarily used to remove nail 

polish and coatings from fingernails or toenails. 

(50) Nail Poljsb means any clear or colored coating applied to the 

fingernails or toenails and includes lacquers, enamels, acrylics, 

base coats and top coats. 

(51) Nonresjlient Flooring means flooring of a mineral content which is 

not fl.exible. Nonresilient flooring includes terrazzo, marble, 

slate, brick, stone, ceramic tile and concrete. 

(52) oven Cleaner means any specialty cleaning product designed to 

clean and to remove dried food deposits from oven walls. 

(53) Paint means any pigmented liquid, liquefiable, or mastic 

composition designed for application to a substrate in a thin . layer which is converted to an opaque solid film after application 

and is used for protection,.decoration or identification, or to 

serve some functional purpose such as the filling or concealing of 

surface irregularities or the modification of light and heat 

radiation characteristics, etc. 

(54) Paint Stripper means any product formulated to strip or remove 

paint from a substrate without markedly affecting the substrate 

itself. 

(55) Percent-Bv-Wejght means the total weight of VOC except those VOCs 

exempted under Section 94510, expressed as a percentage of the 

total net weight of the product exclusive of the container or 

package as calculated according to the following equation: 

.Percent-By-Weight= 

· where, · 

~ * 100 

A 

A = net weight of unit (excluding container and packaging) 

8 =weight of VOCs, as defined in Section 94508, per unit 

C =weight of VOCs, exempted under Section 94510, per unit 

(56) Pesticide means and includes any substrates or mixture of 

substances labeled, designed, or intended for use in preventing, 

destroying, repelling or mitigating any pest, or any substance or 

mixture of substances labeled, designed, or intended for use as a 

defoliant, desiccant, or plant regulator,; provided that the term 

upesticideu will not include any substance or mixture of 

substances which the Environmental Protection Agency does not 

consider to be a pesticide. 

-6-
(57) Prooellant means a liquified or compressed gas that is used in 

whole or in part to expel from the same self-pressurized container 

or from a separate container a liquid or solid material different 

from the propellant. 

(58) Pump Spray Dispenser means a non-pressurized dispenser that 

dispenses product ingredients by means of a mechanical force 

induced by the hand of the operator. 

(59) Retailer means any person who owns, leases, operates, controls, or 

supervises a retail outlet. 

(60) Retail Outlet means any establishment at which consumer products 

are sold, supplied, or offered for sale. 

(61) Rug Deodorizer means any product designed to mask odors, provide a 

specific desired scent, or to deodorize carpets, rugs, or other 

floor coverings. This does not include products that function as 

cleaning products. 

(62) Shaving Cream means an aerosol product which dispenses a foam 

lather intended to be used with a blade or cartridge razor, or 

other wet-shaving system, in the removal of facial or other bodily 

hair. 

(63) Shavjng Gel means an aerosol product which dispenses a gel capable 

of being formed into a foam lather intended to be used with a 

blade or cartridge razor, or other wet-shaving system, in the 

removal of facial or other bodily hair. 

(64) Single Phase Aerosol Air Freshener means an aerosol air freshener 

with the liquid contents in a single homogeneous phase and which 

does not require that the product container be shaken before use. 

(65) Volatile Organic Compound (VOC) means any compound containing at 

least one atom of carbon, except methane, carbon monoxide, carbon 

dioxide, carbonic acid, metallic carbides, or carbonates, ammonium 

carbonate, 1,1,1-trichloroethane, methylene chloride, 

trichlorofluoromethane (CFC-11), dichlorodifluoromethane (CFC-12), 

chlorodifluoromethane (HCFC-22}, trifluoromethane (HFC-23), 

trichlorotrifluoroethane (CFC-113), dichlorotetrafluoroethane 

(CFC-114), chloropentafluoroethane (CFC-115), 

dichlorotrifluoroethane (HCFC-123), tetrafluoroethane (HFC-134a), 

dichlorofluoroethane (HCFC-141b), and chlorodifluoroethane (HCFC142b). 

(66) Water Proofing Products means a product applied to fabric to 

reduce absorption of water. 

(67) Wood Floor Wax means wax-based products for use solely on wood 

floors. 

-7-
NOTE: Authority cited: Sections 39600, 39601, and 41712,· Health and Safety 

Code. Reference: ·Sections 39002, 39600, 40000, and 41712, Health. and 

Safety Code. 

94509. Standards for Consumer Products 

(a) Except as provided in Sections 94510, 94511, and 94514, no p,rson 

shall sen, supply, offer for sale, or manufacture for sale in 

California any consumer product which, at the time of sale or 

manufacture, contains volatile organic compounds in excess of the 

limits specified in the followin~ Table or Standards after the 

specified effective dat"es. 

Table of Standards 

Percent Volatile Organic Compounds by Weight 

<" Future 

Effective 

Product Category 111/93 111/94 (Date) 

Air Fresheners 

Single Phase Aerosbls 70 30 . (1996) 

Double Phase Aerosols 30 

Liquids/Pump Sprays 18 

Sol ids/Gels 3 

0U(l1 Purpose Air Freshener- . Disinfectant Aerosol Sprays 60 

Automotive, Windshield 

Washer F7 ui.ds: 

Type A Areas* 35' · Al 1 Other. Areas . 10 

Bathroom and Tile· Cleaners 5 

Engine Degreasers 75 50 

(1996) 

Floor Polishes/Waxes 

Products for Flexible 

Flooring Materials 7 

Products for Nonresilient 

F7ooring 10 

-8-
Table of Standards 

(continued) 

Percent Volatile Organic Compounds by Weight 

Product Category 111193 111194 

Wood F7 oor Wax 90 

Furniture Maintenance Products 

Aerosols 25 

All Other Forms except 

Solid or Paste Forms 7 

General Purpose Cleaners 10 

Glass Cleaners 6 

Hairs prays 80 

Hair Mousses 16 

Hair Styling Gels 6 

Insect Repellents 

Aerosols 65 

Laundry Prewash 

Aerosols/Solids 22 

Al 1 Other Forms 5 

Nail Polish Removers 85 

Oven Cleaners 

Aerosols/Pump Sprays 8 

Liquids 5 

Shaving Creams 5 

Future 

Effective 

(Date} 

55 

(1998) 

75 

(1996) 

Type A Areas include only the following: Del Norte, Shasta and 

Trinity Counties; the Great Basin Valley, Lake Tahoe, Mountain 

Counties, and Northeast Plateau Air Basins, as defined in Title 

17, California Code of Regu1ations, Sections 60105, 60108, 

60111, and 60113. 

-9-
(b) 

(c) 

(d) 

(e) 

(f) 

For consumer products for which the label, packaging, or 

accompanying literature specifically recommends dilution prior to 

use, the limits specified specified in subsection (a) shall apply 

to the product only after the minimum recommended dilution has 

taken place. For purposes of this subsection (b), "minimum 

recommended dilution~· shall not include recommendations for 

incidental use of a concentrated product to deal with limited 

special application such as hard-to-remove soils or stains. 

Notwithstanding the provisions of Section 94509(a), a. consumer 

product manufactured prior to the earlieit effective date 

specified for that product in the Table of Standards may be sold, 

supplied, or offered for sale for up to one year after the 

earliest specified effective date. This subsection (c) does not 

apply to any product with a specified effective d~te of 1/1/93 

that is sold, supplied, or offered for sale in the Bay Area Air 

Quality Management District. ·· · 

For those consumer products that are registered under th~ Federal 

Insecticide, Fungicide, and Rodenticide Act, (FIFRA; 7 ·u·.s.c. S~ction 136-136y), the effective date of the VOC standards 

specified in subsection (a) is one year after the date specified. 

Effective January 1; 1993, for any consumer product for Which VOC 

standards are specified under subsection (a), no person shall 

sell, supply, offer for sale, or manufacture in California any 

consumer product which contains any ozone-depleting compound 

regulated by the U.S. Environmental Protection Agency (EPA) under 

its final rule "Protection of Stratospheric Ozone" (Published at 

53 Federal Register (FR) 30566-30602 (August 12, 1988) or with an 

ozone-depleting potential of greater than 0.00 as listed in the 

appendix entitled "AFEAS Report" of the United Nation's 

Environmental Panel Integrated Report "Scientific Assessment of 

Stratospheric Ozone: 1989". Before using any halogenated compound 

as a replacement for a VOC in consumer products whose ozonedepleting potential is not addressed in the AFEAS Report,. the 

manufactur:,er or user of that compound must determine the 

compound's ozone-depleting potential using one of the full 

atmospheric models described in the AFEAS Report, or any other 

method determined by the Executive Officer to give equivalent 

results. 

The requirements of subsection (e) shall not apply to: 

1} any existing product formulation that complies with the Table 

of Standards which is sold, supplied, offered for s.ale in 

California prior to the effective date of this article, or any . existing product formulation that is sold supplied, offered for 

sale in California prior to the effective date of this article 

that is reformulated to meet the Table of Standards as long as the 

ozone depleting compound content does not increase; and 

-10-
2) to any ozone-depleting compounds that may be present as·an 

impurity in a consumer product in an amount equal to or less than 

0.01% by weight. 

NOTE: Authority cited: Sections 39600, 39601, and 41712, Health and Safety 

Code. Reference: Sections 39002, 39600, 40000, and 41712, Health and 

Safety Code. 

94510. Exemptions 

(a) This article shall not apply to any consumer products 

manufactured in California for shipment and use outside of 

California. 

(b) The provisions of Section 94509(a) do not apply to a manufacturer 

who sells, supplies, or offers for sale in California a consumer 

product that does not comply with the VOC standards specified in 

Section 94509(a), as long as the manufacturer can demonstrate both 

that the consumer product is intended for shipment and use outside 

of California, and that the manufacturer has taken reasonable 

prudent precautions to assure that the consumer product is not 

distributed to California. 

(c) The requirements of Section 94509(a) shall not apply to fragrances 

and colorants up to a combined level of 2 percent by weight 

contained in any consumer product. 

(d) The requirements of Section 94509 shall not apply to paint, 

furniture coatings, or architectural coatings including aerosol 

(spray) paints. 

(e) The requirements of Section 94509(a) shall not apply to any VOC 

which either: 

{1) has a vapor pressure of less than 0.1 mm Hg at 20 degrees 

Centigrade, or 

(2) consists of more than 12 carbon atoms, if the vapor pressure 

is unknown. 

(f) The requirements of Section 94509(a) shall not apply to the 

following organic compound in insect repellents: 

(1) 2-ethyl-1,3-hexanediol (Rutgers 612). 

(g) The requirements of Section 94512(b) shall not apply to consumer 

products registered under FIFRA. 

(h) The requirements of Section 94509(a) shall not apply to air 

fresheners that are comprised entirely of fragrance, less 

-11-
compounds not deftned as VOCs under Section 9450~ or exempted un~er Section 94510(e). 

(i) The requirements of Section 94509(a) shall not apply to air 

fresheners containing at least 98% paradichlorobenzene. 

' 

NOTE: Authority cited! Sections 39600, 39601, and 41712, Health and Safety 

Code. Reference: Sections 39002, 39600, 40000, and 41712, Health and 

Safety Code. 

94511. Innovatjye Products 

(a) The Executive Officer shall exempt a consumer product from the 

requirements of Section 94509(a) if a manufacturer demonstrates by clear 

and convincing evidence that, due to some characteristic of the prbduct 

formulation, design, delivery systems or other factors, the use of the 

product will result in less VOC emissions as compared to emissions from 

a representative consumer product of,the same product category or, if 

the innovative product is a modification to an existing product, the 

use of the product will result in less VOC emissions as compared to the 

reductions in emissions that would have occurred from that existing 

product had it been reformulated to meet the Table of Standards and 

retained the same product efficacy as the original formulation. 

(b) For the purposes of this section, "representative consumer prodi.(Ct" 

means a consumer product which meets the VOC standards specified in 

Section 94509(a) and, based on tests generally accepted by the consumer 

products industry and concurred with by the Executive Officer, has 

similar efficacy as other complying consumer products in the same 

product category. 

(c) 

(d) 

For the purposes of this section an "existing product" is any 

formulation of the same product category and form sold, supplied 

manufactured, or offered for sale in California prior to the effective 

date of this article. 

A manufacturer shall apply in writing to the Executive Officer .for any 

exemption claimed under this subsection'{a). The application sha17 

include the supporting documentation that demonstrates the reduction of 

emissions from the innovative product, including the actual physical 

test methods used to generate the data ~nd, if necessary, the consumer 

testing undertaken to docume.nt product usage. In addition the applicant 

must provide necessary information to enable the Executive Officer to 

establish enforceable conditions for granting the exemption including, 

but not limited to, the VOC content for the innovative product, test 

methods for determining the VOC content and other parameters identified 

as necessary for the performance of the product. All information 

submitted by a manufacturer pursuant to this section shall be h~ndled in 

accordance with the procedures specified in Title 17, California Code of 

Regulation, Sections 91000-91022. 

-12-
(e) 

(f) 

(g) 

(h) 

(i) 

(j) 

Within 30 days of receipt of the exemption application the Executive 

Officer shall determine whether an application is complete. If the 

Executive Officer determines there are deficiencies in the application, 

the manufacturer shall be notified in writing of the decision, 

specifying the reasons for denial. 

Within 90 days after an application has been deemed complete, the 

Executive Officer shall determine whether, under what conditions, and to 

what extent, an exemption from the requirements of Sections 94509 will 

be permitted. The applicant and the Executive Officer may mutually 

agree to a longer time period for reaching a decision, and additional 

supporting documentation may be submitted by the applicant before a 

decision has been reached. The Executive Officer shall notify the 

applicant of the decision in writing and specify the reasons for 

approving or denying the exemption. An exemption granted by the 

Executive Officer pursuant to this section may specify such terms and 

conditions that are necessary to insure that emissions from the product 

will meet the emissions reductions specified in subsectio~ (a), and that 

such emissions reductions can be enforced. 

In granting an exemption, the Executive Officer shall establish, for the 

product, conditions that are enforceable. These conditions shall 

include the VOC content of the innovative product, dispensing rates, 

application rates or other products deemed necessary. The Executive 

Officer shall also specify the test methods for determining conformance 

to the conditions established. The test methods shall include criteria 

for reproducibility, accuracy, and sampling and laboratory procedures. 

For any product for which an exemption has been granted pursuant to this 

section, the manufacturer shall notify the Executive Officer in writing 

within 30 days of any change in the product formulation or recommended 

product usage directions, and shall also notify the Executive Officer 

within 30 days if the manufacturer learns of any information which would 

alter the emissions estimates submitted to the Executive Officer in 

support of the exemption application. 

If VOC standards are lowered for a product category through any 

subsequent rulemaking, all innovative product exemptions granted for 

products in the product category, except as noted in this subpart, 

shall have no force and effect as of the effective date of the modified 

VOC standard. This subpart shall not include those innovative products 

the VOC emissions of which are less than the appropriate lowered VOC 

standard and for which a written notification of such emissions' status 

versus the lowered VOC standard has been submitted to and approved by 

the Executive Officer at least 60 days before the effective date of such 

standard. 

If the Executive Officer believes that a consumer product for which an 

exemption has been granted no longer meets the criteria for an 

innovative product specified in subsection (a), the Executive Officer 

may hold a public hearing in accordance with the procedures specified in 

Title 17, California Code of Regulations, Part III, Chapter 1, 

-13-
Subchapter 1, Article 4 (commencing with Secti'on 60040), to determine if 

the exemption sho~!d be modi.fi.ffd or ~revoked. - . '· ,' 

NOTE: Authority cited: Sections 39600, 39601, and 41712, Health and Safety 

Code. Reference:· Sections 39002, 39600,.-40000, and 41712, Health and·· 

Safety Code. 

94512. 

(a) 

Mmjnjstratjve. Requjrements 

Most Restrictive Limit If anywhere on the container of any 

consumer product, on any sticker or label affixed thereto, or in 

any sales or advertising literature, any representation is made 

that the produ~t may be used as, or is suitable for use as a 

consumer product for which a lower VOC standard is specified in 

Section 94509(a)~ then the lowest VOC standard shall apply. This 

requirement does pot apply to general purpose cleaners. 

(b) Code-Dating No later than three months after the effective date 

of this article, each manufacturer of a consumer product subject 

to Se~tion 94509 sha11 clearly display on each consumer product 

container'or package, the date on which the product was · manvfactured, or a code indicating such date. If a manufacturer 

uses a code indicating the date of manufacture, an explanation of 

the code must be filed with the Executive Officer of the ARB no 

later thanthree months after the effective date of this article. 

NOTE: Authdrity cited: Sections 39600, 39601, and 41712, Health and Safety 

Code. Reference: Sections 39002 1 39600, 40000, and 41712, Health and 

Safety Code. 

94513. Regjstratjon 

(a) On or before March 1, 1991, and no later than March 1 of every 

third year thereafter, each .manufacturer of consumer products for 

which a VOC standard is specified in Section 94509(a) or approved 

as an innovative product under Sectiori 94511, must register such 

products with the Executive Officer. The registration shall" 

include, but not be limited to, the fo17ow·ing information: 

(1) the brand name for each consumer product; 

(2) the owner of the trademark or brand name; 

(3) the product category to which the consumer product belongs; 

(4) the product forms (aerosol, pump, liquid, solid, etc.); 

(5) the California annual sales in pounds per year and the method 

used to calculate California annual sales; 

-14-
(b) 

(c) 

(6) the total VOC (as defined in Section 94508) content in 

percent by weight which: (a) has a vapor pressure of greater 

than or equal to 0.1 mm Hg at 20 degrees Centigrade, or (b) 

consists of 12 or less carbon atoms, if the vapor pressure is 

unknown; 

Manufacturers shall also provide the registration data specified 

in subsection(a) for the following consumer products: automotive 

cleaners (bug and tar removers, brake cleaners, chrome polishes, 

leather/vinyl cleaners, tire dressings, wheel cleaners), dusting 

sprays, industrial spray buff products, insect repellents (creams, 

pump sprays, solids/sticks), laundry detergents, laundry starch 

products, rug deodorizers, shaving gels, paint strippers, 

household, lawn and garden, pesticides, household adhesives and 

sealants, lubricants, carb and choke cleaners, aerosol food 

products, charcoal lighter fluid, fabric protectants, water 

proofing products and air fresheners comprised of 100~ fragrance. 

Upon 90 days written notice, the Executive Officer may also 

require a manufacturer to supply the registration data listed in 

subsection (a) for any consumer product that the Executive Officer 

may specify. If the Executive Officer determines that the 

registration data is no longer necessary for any consumer product 

in this section, he or she shall notify manufacturers that data 

submission is no longer necessary. 

All information submitted by manufacturers pursuant to Section 

94513 shall 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 39002, 39600, 40000, 41511, and 41712, 

Health and Safety Code. 

94514. Variances 

(a) Any person who cannot comply with the requirements set forth in 

Section 94509, because of extraordinary reasons beyond the 

person's reasonable control may apply in writing to the Executive 

Officer for a variance. The variance application shall set forth: 

(1) the specific grounds upon which the variance is sought; 

(2) the proposed date(s) by which compliance with the provisions 

of Section 94509 will be achieved, and 

(3) a compliance report reasonably detailing the method(s) by 

which compliance will be achieved. 

(b) Upon receipt of a variance application containing the information 

required in subsection (a), the Executive Officer shall hold a 

public hearing to determine whether, under what conditions, and to 

what extent, a variance from the requirements in Section 94509 is 

-15-
necessary and wi 11 be permitted'. A hearing shal 1 be initiated no 

later than 75 days after receipt\Of a variSnce application. 

Notice of the time and place of the hearing shall be sent to the 

applicant by certified mail not less than 30 days prior to the · hearing. Notice of the hearing shall also be submitted for 

publication in the California Regulatory Notice Register and sent 

to every person who requests such notice, not· less than 30 days 

prior'to the hearing. The notice shall state that the parties 

may, but need not, be represented by counsel at the hearing. At 

least 30 days prior to the hearing, the variance applitation shall 

be made available to the public for inspection. Interested 

members .of the public shall be allowed a reasonable opportunity to 

testify at the hearing and their testimony shall be considered. 

(c) No variance shal1 b~ granted unless all of the fo77owihgJindings 

(d) 

. (e) 

(f) 

are made: · · 

( 1) 

(2) 

(3) 

that, because of reasons beyond the reasonable cqntrol of the 

applicant, requiring compliance with S.ection 94509 Wquld 

result in extraordinary econom~c hardship. · 

that the public interest in mitigating the extraordinary 

hardship to the applicant by issuing the variance outweighs 

the public interest in avoiding any increased emissions of 

air contaminants which would result from issuing the 

variance. · 

that the compliance report proposed by the applicant can 

reasonably be implemented, and will achieve compliance as 

expeditiously as possible. 

Any variance order shall specify a final compliance date by which 

the requirements of Section 94509 will be achieved. Any variance 

order shall contain a condition that specifies increments of 

progress necessary to assure timely compliance, and such other 

conditions that the Executi~e Officer, in consideration of the 

testimony received at the hearing,·finds necessary to car/'y out 

the purposes of Division 26 of the Health and Safety Cod~,; 

A variance shall cease to be effective upon failure of the party 

to whom the variance ~as granted to Comply with any term' or 

condition of the variance. 

Upon the application of any person, the Executive Officer may 

review, and for good cause, modify or revoke a variance from 

requirements of Section 94509 after ·holding a public hear{ng in 

accordance with the provisions of subsection (b). 

NOTE: Authority cited: Section~ 39600, 396U1, and 41712, Health and Safety 

Code. Reference: Sections 39002, 39600, 40000, and 41712, Health and 

Safety Code. 

-16- ... 
94515. Test Methods 

(a) Testing to determine compliance with the requirements of this 

article, shall be performed using one or more of the following 

analytical methods: (1) Method 24-24A, Part 60, Title 40, Code of 

Federal Regulations, Appendix A, July 1, 1988; (2} Method 18, 

Federal Register 48, no. 202, October 18, 1983; (3) Method 1400, 

NIOSH Manual of Analytical Methods, Volume 1, February 1984; or 

(4) Environmental Protection Agency Method 8240 "GCIMS Method for 

Volatile Organics," September 1986. Alternative methods which are 

shown to the satisfaction of the Executive Officer to accurately 

determine the concentration of VOCs in a subject product or its 

emissions may be used upon approval of the Executive Officer. 

(b) Compliance may also be demonstrated through calculation of the 

volatile organic compound content form records of the amounts of 

constituents making up the product. If this option is used, daily 

records of the amounts and chemical composition of the 

constituents must be kept f~r at least three years. 

(c) In determining compliance with the requirements of this article, 

the results of tests conducted by the Executive Officer or by the 

Environmental Protection Agency to determine the volatile organic 

compound content of consumer products shall take precedence over 

the results of tests conducted by others to determine that 

volatile organic compound content. The results of tests conducted 

by manufacturers or others to determine the volatile organic 

compound content of consumer products shall be subject to 

verification by the Executive Officer. 

NOTE: Authority cited: Sections 39600, 39601, and 41712, Health and Safety 

Code. Reference: Sections 39002, 39600, 40000, and 41712, Health and 

Safety Code. 

94516. Severabjljtv 

Each part of this article shall be deemed severable, and in the event 

that any part of this article is held to be invalid, the remainder of 

this article shall continue in full force and effect. 

NOTE: Authority cited: Sections 39600, 39601, and 41712, Health and Safety 

Code. Reference: Sections 39002, 39600, 40000, and 41712, Health and 

Safety Code. 

-17-
Appendix C 

VOC Survey Summary 
VOC SURVEY RESPONDENTS 

Company 

3M 

Aerosol Services Co. Inc. 

Air-Shields Vickers 

Alberto-Culver Company Almay Inc. 

American Gas & Chemical Co. 

ARC Chemical Div. of Balchem Co. 

Armor All Products Corporation 

Atlanta Sundries 

Babson Bros. Co. 

Barre-National Inc. 

Berryman Products Inc. 

Block Drug Company 

Bolhringer Ingelheim Animal Health 

Boyle-Midway Household Product 

Caltech Industries Inc. 

Car-Freshner Corporation 

Carmel Chemical Corp. 

Carter-Wallace Inc. 

Celex Corporation 

Cetylite Industries Inc. 

Chemical Corporation 

Chesebrough-Pond's USA Co. 

Church & Dwight 

Colgate-Palmolive Co. 

Compounders Inc. 

Conaga Pet Products 

Connolly- R & D Associates 

Cosmair Inc. 

CPC International Inc. 

Creative Sales Inc. 

Crown Industrial Products Co., Inc. 

D' Spense Inc. 

Degesh America Inc. 

Delcor Laboratories Inc. 

Demert & Dougherty, Inc. 

Desoto, Inc. 

Dial Chemical Corporation 

Dow Corning Corporation 

Eagle One Industries 

EVSCO Pharmaceuticals 

Faultless Starch/Bon Ami Co. 

First Brands Corporation 

Focus 21 International 

Ford's Chemical & Service Inc. 

Company 

Accra Pac Inc. 

Airkem Professional Products 

Airwick Industries 

Allied Block Industries Inc. 

American Cyananird Co. 

Amway Corp. Apollo Industries Inc. 

Arjo Hospital Equipment, Inc. 

Athena Products Corp. 

Avon Products, Inc. 

Bardahl 

Bengal Chemical Inc. 

Black Leaf Products Co. 

Blue Diamond 

Bonat Group Inc. 

Cadie Products Corporation 

Canberra Corporation 

Cardinal Industries Finishes 

Carroll Company 

Caswell Massey Co. Ltd. 

Central Solutions, Inc. 

Champion Choice 

Chemsico 

Chevron Chenical Corporation 

Clairol Incorporated 

Combe Inc. 

Contact Ind. Div. of Safeguard 

Conklin Co., Inc. 

Consumer Power Co. 

Cosmosol Ltd. 

Cramer Products Inc. 

Crescent Resources Inc. 

D-Con Company 

Dana Perfumes Corporation 

Delagar Division, Belcan Inc. 

Del Laboratories Inc. 

Descale - lt. Products Co. 

Dep Corporation 

Dow Brands 

E. Davis, Inc. 

Econetics Inc. 

Farnann Companies Inc. 

Fearing Mfg. Company, Inc. 

Fitzpatrick Bros. Inc. 

Follmer Development, Inc. 

Fosrco, Inc. 

C-1 
Frank Fuhner International Inc. 

Georgette Klinger, Inc. 

Grow Group, Inc. 

H & S Chemicals Division 

Helene Curtis Inc. 

Hercules Chemical Co. 

Huntington Laboratories, Inc. 

I Putnam Inc. 

Jasco Chemical Corporation Johnson Wax, S.C. 

Kingcaid Enterprises, Inc. 

Kiwi Brands Inc. 

Knight Oil Corporation 

Lamplight Farms, Inc. 

Lanman & Kemp-Bardy's Co., Inc. 

Lever Bros. Co. 

Magnumn Research Corp. 

Malco Products, Inc. 

Maril Products, Inc. 

Micro-Gen Equipment Corporation Microgen Inc. 

Mil-Du-Gas & Company 

Mine Safety Appliances Co. 

Mofay Corporation Animal Health Div. 

National Laboratories 

Omnitech International Inc. 

Orchite Chemical Coatings Corp. Parfumes Dinard Inc. 

Penn Champ Inc. 

Penzoil Products Inc. 

Pet Chemicals 

Pioneer/Eclipse Corporation 

Playtex Beauty Care, Inc. 

Plough Inc. 

Portion Pac Chemical Corp. 

Primex Plastics Corporation 

Professional Pet Products Inc. 

Purina Mills Inc. 

Qualis Inc. 

Reedy International Corp. 

Revlon 

Roc Corp. Inc. 

Rockland Chemical Inc. 

Rug Doctor, L.P. 

Schering - Plough 

Scott's Liquid Gold- Inc. 

Service Master 

Sherex Chemical Company Inc. 

Shield Packaging of California 

Shiseido Cosmetics (america) Ltd. 

Speer Products Inc. 

Spartan Chemical Company 

Fuller Industries, Inc. 

Griffin Bros. Inc 

H. Clay ~lover Company Inc. 

Hartz Mountain Corporation 

Henkel Corporation 

Houfigant Inc. 

Hydro so 1, Inc. 

Inserta Inc. 

Johnson & Johnson Medical, Inc. 

Kal-Grad Coating & Mfg., Corporation 

King Research Inc. 

Kirker Chemical Inc. 

Lambert Key (Carter~Wallace) 

Lanosheen Inc. Marine Group 

Lehn & Fink Products 

Linette Cosmetics Inc. 

Makiki Electronics 

Major Paint Company 

Melhor Industries Inc. 

Microban Germicide Co. 

Midco Products Co. Inc. 

Miles Inc. 

Minwax Company 

Mothers 

Norton Performance Plastics 

Orange-Sol, Inc. 

Pace National Corporation 

Pel Associates, Inc. 

Penroy Company 

Permabond International 

Pine 0 Pine Company 

Pitman - Moore Inc. 

Playtex Family Products Corporation 

Poolmaster Inc. 

Prentiso Drug & Chemical Co. Inc .. Proctor & Gamble 

Purex Industrial 

Purdy Products Co. 

Redken Laboratories, Inc. 

Republic Drug Company, Inc. 

Riverdale Chemical Co. 

Rochester Midland 

Ross Daniels, Inc. 

San,; co Inc. 

Schaer Manufacturing Company Scotts Sani-Fresh International 

Shamrock Specialities, Inc. S~erwin Willi~ms/Sprayon Products 

Shirlo, Inc. 

Shulton Group/American Cyanamid Co. 

Sporiciden International · Spray Products Corporation . 

C-2 

.'olt. 

.,,_, ,, 

.. ' . ( .:: j "-~ 
Spurrier Chemical Companies Inc. 

Stanhome Inc. 

Sunnen Products Co. 

Sunshine Makers Inc. 

Surcotech Products 

Tek-Trol Chemicals Inc. 

Thompson & Formby Petrolite 

Tomlyn Products 

The Bramton Company 

The Clorox Co. 

The Drackette Products Co. 

The Larskspur Group Inc. 

The mennen Company 

The Reese Chemical Company 

The Tangle Foot Co. 

Turtle Wax 

USA Group 

Vineland Laboratories 

W.F. Young Inc. 

Walton-March, Inc. 

Waterbury Companies, Inc. 

Wexford Labs, Inc. 

Whitmine Research Laboratories Inc. 

Wesco Manufacturing 

Wynn"Oil Company 

Zema Corporation 

Zimmerman Products 

Zoecon Corporation 

Sta-Lube Inc. 

Sun Laboratories 

Sunshine Chemical Spec. Inc. 

Surco Products, Inc. 

Technical Products Corp. 

Theochem Laboratories Inc. 

Thompson Medical Co.Inc. 

Topiderm Inc. 

The Chas H. Lilly Co. 

The Dial Corporation 

The George Basch Co. Inc. 

The las-Stik Manufacturing 

The Murphy-Phoenix Company 

The Savogram Co. 

The Wardy Corporation 

Unsmoke International 

Vapor Products 

Virbac, Inc. 

W.M. Barr & Company Inc. 

Warner-Lambert Company 

Wesco Manufacturing 

Whink Products Co. 

Willert Home Products 

Wexford Labs, Inc. 

York Chemical Corp. 

Zep Manufacturing Company 

Zoe Chemical Co. Inc. 

C-3 
RESULTS OF CARB CONSUMER PRODUCTS VOC SURVEY 

(INCLUDING HEIDEN ASSOCIATES AND BAKER AND HOSTETLER DATA) 

SALESvoc NUMBER WEIGHTED 

PRODUCT EMISSIONS PRODUCT OF AVERAGE PERCENTAGE SHARE 

CATEGORY lbs/Pay FORM PROPUCTS VOC WT% MARKET EMISSIONS 

Air * 17 '300 Aerosol 65 40 45 63 

Fresheners (2-phase) 

Aerosol 5 96 4 18 

(1-phase) 

Liquid 109 19 20 14 

Other 13 19 2 2 

Pump 27 9 <1 <1 

So 1 id 72 3 29 3 

Dual Purpose 5 80 N/A( 1) N/A( 1) 

Air Freshener/ 

Aerosol Disinfectant 

Automotive 48,000 Liquid N/A (1) 35 100 100 

Windshield 

Washer Fluid 

Bathroom and 900 Aerosol 14 6 37 65 

Tile Cleaner Liquid 53 2 48 28 

Pump 6 <1 13 2 

Solid 2 6 2 5 

Engine 9,000 Aerosol 11 94 100 100 

Degreasers 

Floor 5,200 Products 148 5 89 74 

Polishes For Flexible 

(Wax) Flooring Material 

Products For UTQ UTQ 10 8 

Nonresilient 

Flooring Material 

Wood Floor Wax 6 90 1 18 

Furniture 5,600 Aerosol 43 27 72 87 

Maintenance Solid 2 86 2 5 

(Paste) 

Others 22 7 26 8 

C-4 
PRODUCT 

CATEGORY 

voc 

EMISSIONS PRODUCT 

lbs/Day FORM 

General 9,800 Aerosol 

Purpose Cleaner Liquid/P~m~ 

So 1 id 

Glass Cl~aner 4,600 Aerosol 

Liquid/Pump 

Hair Spray 92,000 Aerosol 

.Pump 

Hair Mousse 1,160 Aerosol 

Hair Styling Gel 820 Liquid 

Pump 

Personal 880 Aerosol 

Insect Repellent 

Laundry 4,000 Aerosol · Prewash Liquid/Pump 

So 1 id 

Nail Polish .2,200 Liquid 

Remover 

Oven Cleaner 2,000 Aerosol 

· Liquid 

Pump 

Shaving Cream 520 Aerosol 

NUMBER 

OF 

PRODUCTS 

26 

159 

9 

29 

59 

186 

96 

88 

86 

6 

11 

6 

14 

4 

25 

23 

11 

9 

17 

SALESWEIGHTED 

AVERAGE 

VOC WT% 

18 

6 . 

<1 

13 

6 

94 

70 

12 

11 

16 

72 

35 

5 

24 

91 

10 

5 

. 10 

7 

PERCENTAGE SHARE 

MARKET EMISSIONS 

<1 

59 

41 

6 

94 

74 

26 

100 

96 

4 

91 

14 

85 

1 

100 

55 

22 

23 

100 

. 12 

88 

80 

20 

100 

95 

5 

9~ 

52 

44 

4 

109 

63 

12 

26 

100 

* This includes approximately 8,600 lbs/Day emissions from dual-use 

aerosol spray disinfectants 

(1) 

(2) 

(3) 

N/A =Not Applicable; Dual Purpose Air Freshener/Air Disinfectant dat~ · not included in Air Freshener data. 

UTQ = Unable to Quantify. It was announced that 10% of the market share and emissions from 

nonwood floor products are due to products for nonresilient floors, the 

remaining 90% being due to products for flexible flooring. 

C-5 
STATE OF CALIFORNIA 

AIR RESOURCES BOARD 

!1 02 Q STREET 

~ 0. BOX 281.S 

SACRAMENTO. CA 9.5812 

Dear Sir or Madam: 

George Oeukmejlan. Gover"or 

Febru3ry 9, 1990 

Consumer Products Yolatjle Or~anjc Comoound Suryey 

With the passage of the California Clean Air Act in 1988, 

the Air Resources Board has been charged with reducing volatile 

organic compound (VOC) emissions from consumer products. To 

assist in this effort, the Air Resources Board staff is 

conducting a survey of companie that manufacture consumer 

products for sale in California. The survey information will 

assist ARB staff in developing standards which are both 

technically and economically feasible and in improving our 

current inventory of VOC emissions from consumer products. 

For the pur·poses of this survey, we will assume that the VOC 

emissions from a product are directly related to the VOC content 

of that product. However, we understand that this assumption may 

not apply to all formulations. Possible cases for which this 

assumption may not apply include products with compounds that are 

highly polar or have a very low vapor pressure, very high boiling 

point and/or carbon number. Please feel free to make note of 

these compounds in the survey form's comment sections. 

Assuredly, we will address the issues associated with emissions 

from these compounds as we proceed in the regulatory development 

process. 

The attached survey form was developed from a draft version 

which was presented to attendees of the first consumer products 

workshop, held on September 6-7, 1989. Based on comments 

received during and after that meeting, the draft survey form was 

revised and the revised draft was sent to workshop attendees for 

comments and the Chemical Specialties Manufacturers Association 

(CSMA) for a pilot study. The attached survey form incorporates 

all comments received to date. 

This request for information is made pursuant to Sections 

39607, 39701, and 41511 of the California Health and Safety Code. 

These sections authorize the Air Resources Board to require the 

submission of information needed by the Board to estimate 

atmospheric emissions and to carry out its dther statutory 

res pons i b i 1 it i e s. 
In accordqnce with the California Code of Regulations, 

Sections 91000 to 91022, and the California Public Records Act 

(Government Code Sections 6250 et seq.), the information whic~, 

you provide may be released (1) to the public upon request, 

except those trade secrets which are not emission data, and (2) 

to the federal Environmental Protection Agency which protects 

trade secrets in,accordance wi,th Section 114(c) of the Cle~n Air 

Act, as amended in 1970 (42 USC 7401 et seq.). Information which 

you deem to be a trade secret should be submitted with a det~il@d 

written justification in, accordance with California Code of , Regulations, Section-912010(b) (S~e Attlchement A). In the p~~~ 

of sales figures for variou~ products marketed in California~~an 

affirmation ~hat this data is co~sidered proprietary and a "trade 

secret" will sufficei ~ 

'"', . 

We ask that you complete the attached survey form in as much 

detai 1 as possible. Please submit the completed survey to the 

ARB by March 31, 1990. For your convenience~ we have enclos~d a 

return mailing label for your reply to the survey. You may 

direct any questions concerning the attached survey to any of, 

the ARB staff listed in the attached survey form. 

It is e~sential that industry be involved in developing 

standards for consumer products which are both technically a~~ 

ecoromically feasible. ·Industry response to the survey.will 

ass i st. the . A i .r. Resources Board i n de v e 1 o p i n g f e as i b 1 e 

regulations.· We appreciate the cooperation we have receive.d. to 

date from members of the consumer products industry and hope to 

continue .. that co .. C?perative spirit in this effort. 

.. ,. 

Enclosures 

, .... \,, 

,·,· ) 

Sincerely, 

;fl .. 1 ?•' ~-; . .. . .· 

. ., (~t!.<u .. ,~-( (_. (~ . .n ~<=' f ~.-------~-- ...... ~--- 0 e an C. Simer o t h. Chief 

(

1 Cr,iteria Pollutants Branch 
Dote: 

Company 

Nome: 

Address: 

CALIFORNIA AIR RESOURCE BOARD 

CONSUMER PRODUCT 

VOLATILE ORGANIC COMPOUND SURVEY 

Contact Person: 

Telephone: 

Confidential Information ) Yes No 

----------------------------------------------------------------------------------------------------------------------------- Please Indicate which of the following beet deecrlbee your company'• operation•: 

( 

( 

) 

) 

DISTRIBUTION ONLY 

BOTH MANUFACTURING AND DISTRIBUTION 

( 

( 

) 

) 

PRIVATE LABEL MANUFACTURING 

NO DISTRIBUTION OR MANUFACTURING OF ANY PRODUCT 

WHOSE TYPE IS LISTED - please check and return for~ 

Pleaee Read The Attached Instruction• Carefully Before Filling Out the Survey ForM 

OWN REGISTERED 

TRADEMARK? 

YES OR NO 

(A) 

I· F 

• NO 

BRAND NAME 

(B) 

---~ ------------

\ BRAN~ NAME 

B) 

I 

PRODUCT INFORMATION 

PRIMARY FUNCTION 

(C) 

-'---

PRODUCT MANUFACTURER 

OH!L 

--------------

-~------ -----~---~--------- ----··----------------- --------- -·- -- ·-

-···- .. 

CALIFORNIA PERCENT BY WEIGHT 

FORM ANNUAL SALES TOTAL > C-14 f voc 

(D}__ (1988) lb/yr voc PROPELLENT . (E) __(£_L_ _ _______{Q_)___ (H) 

Com11ents: 

·------------------ -~---

------------------ ·- --·-

• IF YOU ANSWERED "NO" IN COLUMN (A), PLEASE FILL OUT COLUMNS (B) THROUGH (E) AND COLUMN (BB) 
(PHOTOCOPY AND ATTACH ADDITIONAL COPIES IF NECESSARY) 

~=~~i~~:~!:RED ~------BRAND-NAME ______ plfW!H!Q __ ~~~8~~fr}e~~~:I~~-~-~-:~~:;__: --~~~~=:-~~ ~~~~~~R~:~~~ 

(A} ~} · _ H~) _ _{!H_. (.E._L_} __ 

• IF NO 

\ 

I 

BRAND NAME 

(B)_ 

PRODUCT MANUFACTURER 

(BB) Co•••nta: 

PERCENT BY-w(fciir-- --

T~~~L - ;--c:-1_4_ -r--~~~~~~~-;~T 

_lf_) ___ I_ __ (Q}_ _ (H} __ · _ 

----------- -·--· --------------------------

-~< If YOU AIISWERED "NO" IN COLUMN (A) PI r-A<:I' "'" • niiT r-ru ""''~ '"' ~--------
··l 

DIRECTIONS FOR COMPLETING THE CALIFORNIA CONSUMER PRODUCT VOC SURVEY 

Directions for completing tho VOC Survey are provided below, along with an example of a completed survey. 

Once you have completed the survey, please send to: 

CALIFORNIA AIR RESOURCES BOARD 

STATIONARY SOURCE DIVISION 

P.O. BOX 2615 

SACRAMENTO, CA 95612 

ATTN: FLOYD VERGARA 

If you ahould have any queatlona regarding thla for•, pleaae feel free to contact any of the following 

Solvent• Control Section ataff: 

PEGGY VANICEK (916) 327-1517 

flOYD VERGARA (916) 327-1503 

TOM EVASHENK (916) 327-1504 

ED WONG (916) 327-1507 

PAUL MILKEY (916) 327-1516 

LINDA CLARK (916) 327-1506 

------------------------------------------------------------------------------------------------------------------------- DESCRIPTION Of INFORMATION REQUIRED 

(A) OWN REGISTERED TRADEMARK: If you own or control the registered trademark for the product, please 

enter "Yes" in Column (A). for each product that you enter "Yes" In Column (A), please fi I I in tho 

requested Information in Columns (B) through (H). For each product that you enter "No" in Column 

(A), please enter tho information requested in Columns (B) through (E) and Column (BB). 

(B) BRAND NAME: List the brand nome of each product exactly os it appears on the Iobei. Products with 

the same brand nome or primary function, but with minor differences in formulation (i.e., the only 

difference is in the fragrance or color used) and with no greater than o 5:C: variation in VOC 

content, should be I isted as o single product. If you do I ist products which vary less than 5% in 

VOC content under the some brand nome, please enter the total production (lbsjyr) for oil the 

these products in Section (E). If you do not manufacture the product, please I ist the nome and 

address of the products' manufacturer. I. f you o r e o p r i v o t e I o b e I m on u f ~ t u r e r t h e n om e I i s t e d 

here wi I I not necessori ly be the nome that appears on the Iobei. 
(BB) PRODUCT MANUFACTURER: If you answered "No" in Column (A) for any product, please indicate the owner 

of the registered trademark from whom you obtained the product. 

(C) PRIMARY FUNCTION.·: Indicate the primary function or end use of 'fhe product using the attached list of 

consume·r product types as a guide. for example, for products whose primary function is to clean 

windows, you would enter "Window Cleaner" Into Column (C). 

(D) PRODUCT FORM: Use the following letters to describe the dispensing form. 

dispensing for•• should be listed separately. 

Products with multiple 

A • Pressurized Packog~ (Aerosol, Includes foaMs) S • Solid 0 • Other (Describe) 

P • PuMp Spro~ l ~Liquid (lnc~udea creams, ·gels, and lotions) 

(E) CALIFORNIA SALES: Indicate the sales (pounds/year) for California In 1988. Soles volume 

(pounds/yeai) should be rep6rted as net product weight (i.~., not including weight of container) . 

. for example, only thee weight of the ink In ballpoint pens should be reported. If the 1988 calendar 

years sol•• volume Is not available, any consecutive 12 Month period co••encing no earlier than 

January 1987 Ia acceptable (Please ~pecity the year which you use for your calculation). If 

Col ifornio sales Information is no~ available, sales may be estimated using notional or regional 

soles figures. Please indicate how sales data for California was determined. If you use 

population as a basis for dGtermlning sales, please use th• population estimates provided in the 

attached table of population estl•atea. The sales voluMe reported should include only that portion 

of a product's soles used for typical consumer, Institutional, and commercial purposes. Sales 

vo1ume should specifi~ally ~~~Jude industrial process manufacturing use. However, ~enerol 

industrial moJntenance use should be Included. 

c: r~ :__ 

~:, ' .-
(f) TOTAL VOC: Under total VOC content, report the total VOC content, including VOC propellants, of the 

product as a percentage of the total product weight (do not inlcude container weight). 

purposes of this survey, the following definition apply: 

for the 

VOC: VOC means any compound containing at least one atom of carbon, except methane, carbon monoxide, 

carbon dioxide, carbonic acid, metal I ic carbides, or carbonates, ammonium carbonate, 1,1,1-

trlchloroethone, methylene chloride, trlchlorofluoromethone (CfC-11), dichlorodifluoromethone (CfC12), chlorodifluoromethone (HCFC-22), trlfluoromethone (HCFC-23), trlchlorotrlfluoroethone (CFC113), dichlorotetrofluoroethane (CFC-114), chloropentofluoroethone (CFC-115), 

dlchlorotrlfluoroethone (HCFC-123), tetrofluoroethone (HFC-134o), dlchlorofluoroethone (HCFC-141b), 

and chlorodlfluororethone (HCfC-142b). 

Please note that for the purpose• of thla survey, any organic compound, ~ardless of Its carbon 

number, should be Included In Section (f) unless It Ia one of the compounds I lsted above. 

(G) > C-14: Please enter the total weight percentage for the compound• that hove more than fourteen (14) 

carbon atoms. This weight percentage should be Included In your response to Section (f), Total VOC 

Content. 

(H) VOC Propellant: Propel lont meona a VOC containing liqulfled or compressed gas In a container, where 

the purpose of the I lquifled or compressed gas Is to expel the contents of the container. Non-VOC 

containing propel lonts ore excluded from this definition. 
SAMPLE CALCULATIONS (SEE FILLED SAMPLE FORM) 

COMPANY: Entomol, Inc. 

PRODUCTS: Insect Repellents 

BRANDS: 1 =Shoal (Aerosol}, 2 z Go Away! (Stick), 3 = The Terminator (Towlettes} 

OWNER Of REGISTERED TRADEMARK: (1) EntoMol, Inc. • Brands 1,2 (2) Bug Terminators Co. • Brand 3 (Column BB) 

••••••••••••••••••••••••••••••••••••••••••••••s••••=••••••ac••••••••••••••••••••••••••••=••••••••••••••••••••••• 

U.S Production Rates: Brand 1 • 87,000 pounds/year, Brand 2 • 21,800 pounds/year, Brand 3 • 10,000 pounds/year 

Ratio of CA Population to US Population (Pop. foetor) • 28,~14,000 / 245,807,000 • 0.115 

(1988 US Census Bureau) 

Geographical Usage Factor • Unknown (Assu•e • 1.0) 

General CA Production Rote • US Production Rote* CA Pop: Factor * CA Geographical factor 

CA Production Rates: Brand 1 • 87~000 •.0.115 * 1.0 • 10,000 pou. nds/ye.ar_ {Column E.) 

Brand 2 • 21,800 * 0.115 * 1.0 • 2,500 pounds/year (Column E) 

Brand 3 • 10,000 * 0.1f5 * 1.0 • 1,150 pounds/year (C61umn E) 

------------------------------------------------------------------------------------------------------------E·--

Brand 

Shoal 

Go Away! 

Ingredient 

N,N-diethyl-m-toluamide 

Wafer 

I.sopropane 

Isopropanol 

Total 

N,N-diethyl-m-toluomide 

laopor E 

Water 

Isopropanol 

Beeswax 

Tot a ·I 

Ingredient Wt S 

of Product 

15S 

ss· 

65S 

15S 

100S 

25S 

25S 

5S 

15S 

30S 

100S 

VOC Content, wt S 

Total Product > C-14 

15S 

6.5S 

15S 

95S (F) 

25S 

25S 

15S 

30S --~-------.:..·--

. 95,% (F) 

es (G) 

30S 

30S (G) 

Propellent Only 

65S 

65S (H) 

0% (H) 

The Not Avai lob1e N/A N/A N/A N/A 

Terminator 

Note Although N.N-diethyl-m-1o1uomide is the active ingredient and a Iorge molecule, for the purposes of 

this survey lt would sti I I be counted as a VOC. 

F, G, and H refer to the columns in the su~vey form under, "Percent by Weight". 

Beeswo~ is assumed to be comppsed of·otgo~ic mol'ecules which hove more tho~ fourteen carbon atoms 

(C-14). 
Dote: _______ 1/1/!l~ --~--~ 

Company 

Name: 

Address: 

--~!_omQ_L~!!!5_'--~-----------

10000 Bugs Circle 

San Dleao. CA 93060 

CALIFORNIA AIR RESOURCE BOARD 

CONSUMER PRODUCT 

VOLATILE ORGANIC COMPOUND SURVEY 

Conto< · Person: 

Telephone: 619 ) 

Confidential lnfor11atlon 

Rr.,. ~a.~!1CIL'l'_ ~!!lUh ___ _ 

222-4444 

1 Yea (X 1 No 

----------------------------------------------------------------------------------------------------------------------------- Plea11 Indicate which of the following beat deecrlbea your co•pany'l operation•: 

( 

( 

) 

) 

DISTRIBUTION ONLY 

BOTH MANUFACTURING AND DISTRIB.UTION 

( X ) 

( ) 

PRIVATE LABEL MANUFACTURING 

NO DISTRIBUTION OR MANUFACTURING OF ANY PRODUCT 

WHOSE TYPE IS LISTED - please check and return for• 

plea•• Read The Attached ln1tructlona Carefully Before Filling Out the Survey for• 

OWN REGISTERED 

TRADEMARK? 

YES ~~)NO 

YES 

YES 

NO 

IIF • NO 

\ 

I 

BRAND NAME 

(B) 

Shoo I 

Go Away! 

The Terminator 

BRAND NAME 

(B) 

The Terminator 

---------------------------

--~--~----------------- ------

PRODUCT INFORMATION 

PRIMARY FUNCTION 

(C) 

Peraonal lnaect Repellent 

Personal Insect Repellent 

Personal Insect Repellent 

PRODUCT MANUFACTURER 

(BB) 

Bug Terminators Company 

--------------------------- - -------------- ---- I 

··------------~ - ----- . - __ I 

CALIFORNIA PERCE~T BY WEIGHT 

FORM ANNUAL SALES TOTAL > C-14 voc 

(D) (1988) lb/yr voc PRO~~\LENT (E) (F) (G) 

A 10,000 95~ 0 65~ 

-

s 2,500 95~ 30~ 0 

0 1. 150 

--- -

Co1111ents: 

***************** ---------

• SAMPLE FORM * 

-~----------·--

···············~· 

• If YOU ANSWERED "NO" IN COLUMN (A). PLEASE fiLL OUT COLUMNS (B) THROUGH (E) A~D COLUMN (bB) 
CONSUMER PRODUCT CATEGORIES (Use for answering Column C) 

.E~~TJ-~J ~f _.EBQ!H!~ I~ 

Space Insecticides 

Residual Insecticides (Personal and surface repellents, moth 

proofers) 

HOUSEHOLD PRODUCTS 

Room Deodorants and disinfectants 

Cleaners (glass, oven, rug, fabric, wa~l and tile) 

Laundry Products (starch, fabric finish, pre-wash) 

Waxes and polish•• Othe~ Household Products (shoe pol lshe•, dy•s. leather dressing, 

fuels, drain openers, anti-stat~. caulking and seating co~pound~) 

~ERSONAL CARE PRODUCTS 

ShavIng Lather ~air Care Products (Hair Sprays, Mousse, Gels, Shampoo) 

'Medicinals and Phar11aceutlcals (vaporizer's, fungicides, burn ~reatments, antl•eptlcs, contraceptives) 

Colognes, Perfuaes and After Shave 

Per son a+ .Deodo r an.t s, .Ant I p• r spIrants, P-owders and Deo doran t 

colognes i 

Dther Personal Pr~ducts (suntan preparations, lotions, breath .. fresheners, depllltorlea). · 

ANIMAL PiWDUCTS 

Veterinarian and Pet Products (shampoos, Insecticides, 

repellents) 

AUTOMOTIVE AND INDUSTRIAL 

Refrigerants 

Windshield and Lock Spray De-icer 

Cleaners {automotive upholstery, leather, vinyl, dressing, tire 

cleaners) 

Engine Degreaser 

Lubricant ~nd Sificones (penetrating o11s, d~moisturizers, rust 

proofing, mold releases) 

Spray Undercoa1ing 

Tire Inflator and Sealant 

Carburetor and Choke Cleaner 

Broke Cleaner 

Engine Starting fluid 

Other Automotive and Industrial Products (adhesives) 

fQQQ .ERQDUCJ~-

Pan Sprays 

Aerosol food Products (whipping cream, cheese) 

~~I :,f.f!-[.MJ~9US 
...1 

< % (/) 

0 1-

% 1- w 

:::::E Q :::::E Q 0 

< C,) 
Estimates of the Resident Population ot States: July i, 1988, and Components of Change Since 

1980 

~S:urce: u.s. l:ept. of Camerce 

Eureau of the Census 

Series P-25, No. 1044) 

(1:- tl'lous.anas. Inoue~ Armed Forces resldong ,,., e!ICI Sr.tel 

u....ree Sr.tes 

i'cOI"'u"'eas: .. 1-.ew ~.,~:and 

. MtO~Ie Au;nue 

Moawes: 

Eas: "'o"n Centra. 

West Nor:n Cenua: I .I 

So urn 

Soutn Anannc 

East Soutn Centra1 

West So\.otn Cenr:a1 

West •...... 

...... :.i 

.. I 

Mounr.11, ... j:)ac::hc: .. , . I 

New :"'o:;nc: 

Maone • 

New '"'amosrure 

\lermon: 

i .. ! 

I 

Massac:!'lusens 

FlhOae os~and 

Connee:=Jt . 

... , . : j 

MICidle Aaanac: 

N- YOR....... . ..... · · 

N-J~ ....................... . 

Fennsyrvanoa ...................... . 

Eas: NoM C..ntral. 

On.o ............ . lno~ana ......... . ilioi1QIS ...•....•••.. 

Mier\tgan. . ••....... 

::::: :I 

WISCOriSin ..•.............. · · · · · · · · · 

West NOM Centra~: 

Monnesota ........... · .......... .. 

Iowa ..•.....•............ ········· 

Missoun .......••.. · · ... · · · · · · · · · · · NOI'Ill Oa~eota . . • . . . . . . . . . . . . · · . · · · · · Scutl'l Ouolll ...................... . 

NeoriiSIIll •.•••.•..•........ · · · • · · • · ~nsas ........................... . 

Scull'l Aaanac 

~ 

Oeta • ., •. ; ..•..................... 

........................ .. OiS~ne~ ot CoiUIIIOia ................. . 

vrvrma ........................... . 

=~~:::::::::::::::::::·:: ~.::::::::::::::::::::::::::: East Soutn C..nns: 

~~::::::::::::::::::::::::: 

~::::::::::::::::::::::::: 

West Soull'l c.mrat .. ~ ......................... . LOUISiana .•••••••.•••.....••.•••••• 

Oklanoma .••..........•......•..... 

Texas ......•..••....•............. 

Moun~a~n: 

Montana ..•..•..•••.....••.....•..•. 

~/ :;:; :: :: 

Facfic:: . 

~astwlqlon . • . . . . . . . . . . . . . . . . . . . . c.'::I.Of'l..... .. .. .. .. .. .. .. . ...... Ales.ot~ ·•·••·• ··••• · · · • · · · · · · · · 

H.awaw '· · · • · · · · · · · · · · · · · · · · · · · · · · ... ······ .............. . 

July t, 1988: 

245.!!0:' ' 

SC.595 

t2.~ 

:l7.6:l' 

ss a:-a 

42 .• 19 

17.:'~9: 

S.oi SSS 

42.426 

~~:i~1 50.679: 

t:l.:J2! . ~7.::!51 

1.205 

1.0!5 

s.s:-: 

S.S19: 

99:l: 

3.:<:~::! i 

17.909; 

7.72~ 1 

12.001 i 

10.855; 

5.556: 

1 1.61"; 

9.2«0! 

~.ass i ~.3071 

2.83-41 s. 1.ol1 

667 1 

7,:JI 

uo2 I 2.~95 

660 

4.622 

St7 

6.015 

1.876 

6.-'891 

3.470 

6.3-421 

12.335 I 

::!.727 

~.895 

4.102 

2.620 

2.395 

4 . .ol08 

::!.2~2 

16.&«, 

805 

1.00::! 

.oi79 

3.::!01 

1.507 

3,.oi89 

1,690 

1.05.ol 

4.5o48 

2.767 

28.::!14 

S2.oi 

1,098 

• Reoresems zero Ot a number tl'lat rounds to z.,o. 
STATE OF CALIFORNIA George Da&JKme;tan. Go~,_-

AIR RESOURCES BOARD 

11 02 Q STREET 

P.O. BOX 2Bl.S 

SACRAMENTO, CA 9.5812 

March 6, 1990 

Dear Sir or Madam: 

Consumer Products Volatile Organic Compound Survey Changes 

The purpose of this letter is to inform you of some 

recent and significant changes to the Consumer Products Volatile 

Organic Compound (VOC) Survey which was mailed to you on February 

9, 1990. Based on discussions at the second consumer products 

workshop held on February 28, 1990 we are limiting, at this time, 

the products subject to the survey and changing the reporting 

requirements for the VOC content in Column (G) of the survey 

form. The specific changes are as follows: 

1) At this time, we are asking tha~ information be 

provided for~ those consumer products listed in 

the Table of Standards in Section 94510 (Standards 

for Consumer Products) of the draft regulation ..Q...DJ1 

for all aerosol spray products. A summary of the 

products that must be reported are listed in 

Attachment A. Information on the other non-aerosol 

consumer products wi 11 be· required at a later dat.e 

and a new survey form will be mailed to you. 

2) The reporting requirements for Colymn G have been 

changed. Instead of reporting the weight 

percentage for the compounds that have more than 

fourteen carbon atoms, please report the weight 

percentage for the compounds that have 12 or Jess 

carbons for whjch the vapor pressyre js unknown or 

that have a yapor pressure of 0.1 mm Hg or greater 

at 20 degrees Centigrade. 

If you have completed and mailed the VOC survey to us, 

we will call you for information regarding the above changes. If 

you have not yet completed the VOC survey, please do so in 

accordance with the changes outlined above. We would like to 

remind you that the due date for the VOC Survey is still March 31, 

1990. 

The issue of confidentiality was raised at the 

Sacramento workshop as it had been previously raised during the 

Los Angeles meetings of September 6-7, 1989. We wish to inform 

you that the Air Resources Board (ARB) has had many years of 

experience in handling confidential information obtained from 

industry. A recent example is the ARB Architectural Coatings 

Survey which began in 1984. To date, we have not encountered any 
-2-

difficulties with the confidential data submitted for the survey. 

Currently, we are conducting a s~cond survey for architectural 

coatings data for the year 1988. 

Enclosed is a brief summary (Attachment B) of how 

confidential information is treated by the ARB in accordance with 

Title 17, California Code of Regulations, Sections 91000 to 

91022, and the California Public Records Act (Government ~ode 

Sections 6250 et seq.). (We apologize for not enclosing this 

attachment with the VOC Survey a~ was originally intended.) 

These legal provisions provide substantial procedural safegu,pds 

against the disclosure of confidential information to third .: 

parties. If you have futther concerns reg'r~ing confidentiality, 

you may wish to call ARB's legal counsel, Robert J.enne, a~;::(916) 

322-2884. ' .. 

To simplify the process of requesting confidentiality p~otection for information submitted by your company, we have 

also enclosed a standard disclosure form. Please have the 

appropriate company representative complete the form and return 

it with the VOC survey or to Dean C. Simeroth, Chief, Criteria 

Pollutants Branch, California Air Resources Board, P.O. Box 2815, 

Sacramento, CA 95812. · 

If you should have any questions regarding the VOC 

Survey or related documents, please feel free to contact any of 

.the Solvents Control Section staff listed in the survey. Again, 

we a p p r e c i a t e t h e c o o p e r a t i o n we h a v e r e c e i v e d f r om Y.O u r c om p a n Y 

and hope that we can continue to receive input in this necessary 

and important process. If you have any questions regarding the 

overall development of the consumer products regulation, please 

do not hesitate to call my Branch Chief, Dean Simeroth, at (916) 

322-6020 or Peggy Vanicek, Manager of the Solvents Control 

Section, at (916) 322-8283. 

Enclosures 

0~-·......-.--··-- Peter Venturin1, Chief 

Stationary Source Division 
ATTACHMENT A. 

Consumer Products Subject to VOC Survey 

Air Fresheners 

Any Aerosol Prodyct 

Autdmotive Bug and Tar Remover 

Automotive Chrome Polish 

Automotive Leather/Vinyl Cleaner 

Automotive Wheel Cleaner 

Automotive Tire Colorant 

Bathroom and Tile Cleaner 

Floor Polish (Wax)· 

Furniture Maintenance Products 

General Purpose Household Cleaners 

Glass Cleaner 

Hairspray 

Hair Styling Gel 

H a i r M o u .s s e 

Insect Repellents 

Laundry Detergents (Liquids and Powders) 

Laundry Prewash 

Oven Cleaner 

Nailpolish Remover 

·Rug Deodorizers 

Windshield Washer Fluid 
ATTAC.HMENT B 

In accordance with Title 17, California Code of 

Regulations {CCR), S~ctions 91000 to 91022, and the California 

Public Records Act (Government Code Sections 6250 et seq.), the 

information that a company provides to the Air Resources Board 

(ARB) may be released (1) to the public upon request, except 

trade secrets which are not emissions data or other information 

which is exempt from disclosure or the disclosure of which i~ 

prohibited by 1 aw, and ( 2) to the Feder a 1 Environment a 1· .. ··· 

Protection Agency (EPA), which protects trade secrets as provided 

in Section 114(c) of the Clean Air Act and a~endments thereto (4? 

USC 7401 et seq.) and in federal regulations, and (3) to other· 

public agencies provided that those agencies preserve· the . protections afforded information which is identified as a trade 

secret, or otherwise exempt from disclolure by law (Section 

91000, Title 17, CCR and Health and Safety Code Section 

39660((e)). 

Trade secrets as defined in Government Code Secftbn 

6254.7 are not public records and therefore will not b~ rel~a~ed · to the public. However, .the California Public Recotds Act 

provides that air pollution emission data are always public 

records, even if the data comes within the definition of trade· 1.: 

secrets. On the other hand, the information used to calculate 

air pollution emissions may be withheld from the public if the 

information is a trade secret. 

If any company believes that any of the information it 

may provide is a trade secret or otherwise exempt from disclosure 

under any other provision of law, it must identify it as such at 

the time of submission to the ARB and must provide the name, 

address, and telephone number of the individual to be consulted 

if the ARB receives a request for disclosure or seeks to disclose 

the data claimed to be confidential. The ARB may ask the company 

to provide documentation of its claim of trade secret or 

exemption at a later date. Data identified as confidential will 

not be disclosed unless the ARB determines, in accordance with 

the above referenced regulations, that t~e data do not qualify 

for a legal exemption from disclosure. The regulations establish 

substantial safeguards before any such disclosure. 
California Atr Resoar~es Soa~d 

PO Box 2115 . - Sacramento, CA 95812 

Attention:_Dean C. Simeroth, Ch~ef, 

Criteria Pollutant~ Branch 

In accordance with the provisions of Title 17, California 

Code of Regulations, Sections 91000 to 91022, and the California 

Public Records Act {Government Code Sections 6250 et seq.), 

declares that all the 

(company name) 

information submitted in response to the California Air Resources 

Board's information request on------------------------------------

is confidential •trade secret• infor~ation, 

and requests that it be protected as such frQm public disclosure. 

All inquiries pertaining to the confidentiality of this 

information should be directed to the following person: 

Date ---------------------------

(signature) 

(printed name) 

(title) 

(telephone number) 

Mailing Address: 
Appendix D 

Workshop Announcements 
Company 

WORKSHOP PARTICIPANTS 

LOS ANGELES, CA 

SEPTEMBER 6-7, 1989. 

Company 

The Soap and Detergent Association 

Procter & Gamble 

The Gillette Company 

Faultless Starch/BonAmi Company 

The Clorox Company S.C. Johnson Wax 

Scott's Liquid Gold 

The Dail Company 

Johnson & Mattesich 

Grow Group, Inc. 

Lehn & Fink 

US EPA 

US EPA/AEERL 

Shield Packaging 

Helen Curits, Inc. 

Amway Corporation 

Image Labs 

DuPont 

Rubon 

Jones, Day, Reauis, & Pogue 

Airwick Industries 

Shulton Group American Cynamid Company 

Sprayon Products 

CSMA 

Lathani & Watkins (Representing 3M) 

Industrial Economics, Inc. 

Exxel 

Clairol-Bristol Myers 

General Electric Co./Silicone Products 

ICF 

Diversified CPC 

DeMert & Dougherty, Inc. 

CTFA 

Chemsico 

D-1 
Company 

Chevron USA 

BMP 

Scott's Liquid Gold 

Follmer Development Chemsico 

PPG, Industries, Inc. 

WORKSHOP PARTICIPANTS 

SACRAMENTO, CA 

F.EBRUARY 28, 1990 . 

Company 

The Dail Corporation 

Clairol Inc. 

CSMA 

Peterson/Purtian 

Revlon Research 

The Soap & Detergent Association 

DEP Corporation. 

American Cynamid Company 

Winzer Corporation 

IFF 

FAC 

Sprayon Products 

Aerosol Service Company Diversified ,CPC, Inc. 

Allen, Matk1~s · Dow Corning Corporation 

Procter & Gamble 

EPA 

Randlett Association 

Scott's Liquid Gold 

Aerospres Corporation US EPA/AEERL 

Duffy & Duffy 

Advanced Mono Bloc 

WD-40 

Sebastian Int. 

Sebastian of Sacramento 

Bentley Mftg. 

DuPont 

PMI Distributors 

The Drackett Company 

Kans Research 

Grow Group, Inc. 

Sharp, Green, & Lankford 

HSIA 

Currel Assoc. 

Ian Gecker & Associates 

Armor All Products 

Precisions Valve Corporation Colgate/Palmolive 

SC Johnson & Son 

Lehn & Fink (Consultant) 

Amway Corporation 

Claire/Sprayon 

The Clorox company 

Airwick Industries 

Sherwin-Williams 

US Can Company CTFA 

Western Aerosol Information Bureau 

Chesebough-Ponds 

DeMert & Doughert 

Uniroyal Chemical 

Calmar, Incorporated 

The Gillette Company 

Major Paint Company 

American Home Products Corporation Helene Curtis 

Image Labs 

Seaquist Valve . Haloengated Solvents Industry Alliance 

Boyle Midway Household Products 

Eagle One 

.'. 

'· 
WORKSHOP PARTICIPANTS 

SAN FRANCISCO, CA 

MARCH 28-29, 1990 

Company 

Advanced Monobloc 

Accur Pac Company 

Claire Mfg. 

CTFA 

US Cellulose 

ICI Amgricas 

Calmar, Inc. 

Clairol Inc. 

The Clorox Co. 

EPA 

Peterson/Puritan 

Sika Corp. 

Alliance Technologies Corp. 

Pennzoil 

Scott's Liquid Gold 

The Soap & Detergent Assoc. 

Shulton Group American Cyanamid Co. 

CFC Alliance 

IKI Mfg. 

WD-40 Company 

Drackett Co. 

Alberto Culver 

Dow Brands Inc 

Revlon 

Piedmont Labs 

Airwick Industries 

Image Labs 

Sprayon Products 

Grow Group, Inc. 

Randlett & Assoc. 

Summit Pkg. 

PM! Distributors 

Crown Curk & Seal 

Claire MFG Co. 

American Home Products Co. 

Precison Valve 

Halogenated Solvent Industry All. 

Citizens For A Better Environment 

Company 

Pillsbury, Madison & Sutro 

Ian Gecker & Assoc. 

Proctor & Gamble 

CSMA 

Holchem Inc. 

Phillips Petroleum 

Dow Corning Corp. 

BASF 

Chesebrough-Pond's USA 

Aeropres Corp. 

The Dail Corp. 

Eagle One 

Bentley Mfg. 

Chemical Spec Mfg. Assoc. 

Monsanto Company 

Diversified CPC 

Colgate-Palmolive Co. 

Bacch & Labs 

FMG/Tsomura 

Aerosol Services Co. 

Faultless Starch Co. 

sc Johnson w·ax 

Lehn and Fink 

DeMert 

Boyle-Midway Household Products 

BAAQMD 

GAF Chemical Corp. 

Chevron Chemical Co. 

Church & Dwight 

Ecolab Inc. 

3M 

Sprayon Products Div. S.W. 

Chemisco 

Gillette Co. 

SEAQUIST 

Helene Curtis 

McKenna, Conner & Cuneo 

D-3 
WORKSHOP PARtiCIPANTS 

LOS ANGELES, CA. 

JUNE 5, 1990 

Company 

Fairfield American, 

Clairol Manufacturing . Turtle Wax 

Mary Kay Cosmetics, Inc. 

Dow Corning Corp. 

State Chemical/Neutron Ind. 

US Can Co. 

Image Labs 

Paul, Hastings, Janofskj~ Walter 

Chemsico 

Redken Laboratories 

Proctor & Gamble 

SEAQUIST 

Creative Products 

Advanced Mono Bloc 

OCS Manufacturing CSMA 

Faultless Starch/Bon Ami 

Cosmair 

Clairol 

Allen, Matkins, Leuk, Gamble & 

Molloy 

Aerosol Age Magazine Revlon 

MGK Company 

Advanced Packaging & Products Inc. 

Aerosol Services Co. Inc. 

BAAQMD 

United Industries 

The Clorox Co. 

WD-40 

Boyle - Midway ., Gillette Co. 

Haight, Brown & Bowesteec 

K & W Products 

P & CSD 

·company 

Chevron Chenical Co. 

Sprayon Products 

Jafra Cosmetics 

Shulton Group 

CSA Limited 

Aeropres Corp. W~A.I.B. Pres./US Can Co. 

Ian Gecker & Associates 

Alberto Culver 

SCAQMD 

National Aerosol Products 

Alberto-Culver Canada 

Precision Valve 

SEAQUIST Valve 

The Dail Corp. HSIA 

MOTHER~ ~-

. Drackett 

McKenna, Connera & Caneo 

Crown Cork & Seal Co. 

Boat Kare Products Inc. 

Nationwide Industries 

Chesebrough-Ponds USA Co. 

Airwick 

Grow Group Eagle One 

Self 

Baker & Hosteller 

McLaughlin, Gormley King Co. 

Diversifield CPC International 

I.K. I. Mfg. 

Helene Curtis Inc. 

Colgate Palmolive Co. 

National Starch & Chemical 

3M 

Duffy & Duffy 

D-4 
INNOVATIVE PRODUCT CONSULTATION MEETING 

JULY 30, 1990 

SACRAMENTO, CA 

Company 

SC Johnson 

Cosmair 

Shulton Group 

The Gillete Company 

CTFA 

Soap & Detergent Association 

Dow Corning Corporation Drackett Company 

Ecolab 

Chesebrough-Ponds USA Company 

DeMert & Dougherty 

US Environmental Protection Agency Advanced Mono Bloc 

Seaquist 

Company 

CSMA 

Clairol 

Creative Products Inc. of Rossville 

Airwick Industries 

Sprayon Products 

The Clorox Company 

Dow Brands 

Alberto Culver 

Procter & Gamble 

Crown Cork & Seal Company 

Revlon 

Precision Valve 

Helene Curtis 

Bay Area Air Quality 

Management District 

D-5 
WORKSHOP PARTICIPANTS 

SACRAMENTO, CA 

JULY 31, 1990 

Company 

Chevron Chemical Company 

DR Thomper 

DeMert & Dougherty 

Peterson/Puritan 

KMS Research Inc. 

Procter & Gamble 

Steiner Company Inc. 

Lehn & Fink Products 

Creative Products Inc. of Rossville 

Seaquist 

A irwi ck 

Shulton Group 

Clairol, Inc. 

Calmar, Inc. 

Dow Brands 

\;' 

Diversified CPC International 

POW! Chemical Company 

First Brands Corporation 

Quantum Chemical Corporation Gillette Company Hydrosol Inc. 

Baker & Hostetler,McCutcher,Black 

FOB, CDHS 

CSMA 

Firmenich Inc. 

Sprayon Products 

WD-40 

The Clorox Company 

Ecolab Inc. 

Redken Laboratories 

Company 

Bay Area Air Quality 

Management District 

Precision Valve 

Dow Corning Corp. 

ARB/MLD/EEB 

Monsanto/Chlorobenzene Producer Assoc~ 

Scott's Liqui~ Gold 

Paul, Hastings, Janofsky & Walker 

Miles Inc. 

Alberto Culver , Revlon 

cosmair 

Chesebrough~Ponds USA Company 

Helene Curtis, Inc. 

US Can Company WAIB 

Aeropres Corporation 

3M 

Dial Corporation Environmental Protection Agency 

Crown Cork & Seal Company Citizens For A Better Environment 

IFF 

Dep Corporation Advanced MonoBloc 

KMS Research 

Radiatur Specialty 

I-K-I Manufacturers 

Livingston & Mattesich for SDA 

PM! Distributors 

D-6 
STATE OF CALIFORNIA GEORGE OEUKMEJIAN. ~ 

AIR RESOURCES BOARD 

1102 Q STREET 

o.o. BOX 281.5 

.ACRAMENTO. CA 95812 

August 14, 1989 

Dear Sir or Madam: 

Personal Care/Household Products - Consultation Meetings 

I am writing to request your company's participation in a 

consultation meeting to explore regulatory approaches to reducing volatile 

organic compound emissions from personal care and household products. 

With passage of the California Clean Air Act of 1988, the Air 

Resources Board (ARB) was given direct authority to adopt statewide 

regulations on or before January 1, 1992 to achieve the maximum feasible 

reduction in volatile organic compound emissions from consumer products. On 

July 13, 1989, the ARB approved a consumer product control plan for 

addressing the requirements of the California Clean Air Act. This plan 

describes the need for regulatory action, the regulatory authority and 

several milestones for meeting the legislative mandate. According to the 

control plan, personal care and household products are the first categories 

to be addressed. Personal care products include, but are not limited to, 

such items as hairsprays and hair products, cosmetics, body lotions and 

creams, breath freshners and mouthwashes, shaving products, colognes, 

medicinal and pharmaceutical products. Deodorants and anti-perspirants are 

also part of the personal care category but are being addressed separately. 

Household products include general purpose cleaners, floor and furniture 

waxes and polishes, air freshners and deodorants, and laundry products. 

As a first step in the development of regulations for these 

categories we will conduct two informal consultation meetings in Los Angeles 

on September 6 and 7, 1989. The meeting on September 6, 1989 will pertain 

to the personal care products category and the September 7th meeting will 

focus on the household product category. The location and time for each 

meeting are as follows: 

Date: September 6, 1~89 (Personal Care) 

September 7, 1989 (Household) 

Time: 10:00 AM 

Place: Los Angeles State Office Building 

107 South Broadway, Room 1122 

Los Angeles, CA 90012 
Each consultation meeting will begin at 10:00 a.m. and conclude at or before 

5:00 p.m. 

Attached are several items that we will be discussing at the 

consultation meetings. We would appreciate your review of these items and 

look forward to your conrnents at the meetings. The first item, "Consumer 

Product Emissions Survey Form," is a form that we are considering using to 

survey consumer products marketed· in California. The information from this 

survey would be used to update and improve our consumer product emissions 

inventory. The second item, "Consumer Product Emissions and Selected 

Personal tare and Household Products," is a listing of products that are . included in the personal care and household products categories. · The third 

item, "A Discussion on Regulatory Approaches for Consumer Products," is a 

brief summary on different types of regulatory options that could be pursued 

in the development of consumer product regulations. The fourth item, 

"Questions," is a list of some of the other topics we would like to discuss 

with you at the meeting. A tentative agenda is ~lso attached. A final· ,~, 

workshop agenda will be available at the consultation meeting: 

:' . 

I would like to emphasize that we have not chosen a regulatory approach to use for these two categories of consumer products. There are 

many ways to achieve emission reductions and we want to explore several 

options before conrnitting to an approach. By examining these approaches 

together we will increase the chance of having a regulation that will 

provide for the maximum feasible reduction yet provide flexibility to the 

industry. I hope you will participate in these consultation meetings ~nd 

the development of consumer product regulations. Your participation, 

particularly in this developmental stage, is important and essential to the 

success of this process. If you have any questions or if you need a copy of 

the Consumer Product Control Plan, please call either Dan Oonohoue, Manager, 

Solvents Control Section at (916) 322-8283 or Peggy Vanicek, Associate A~r . Pollution Specialist, at (916) 327-1517. 

;::~~? ~. Venturini, Chief ·· 

Stationary Source Division 

Enclosures 
STATE OF CALIFORNIA 

AIR RESOURCES BOARD 11 02 Q STREET 

P.O. BOX 2815 

ACRAMENTO. CA 9.5812 

February 9, 1990 

Dear Sir or Madam~ 

Publjc Workshop to Qjscyss Draft Regylatjon 

for Consumer Products 

I am writing to request your company's participation in two 

public workshops to be held by the staff of the Air Resources Board (ARB) 

concerning the regulation of volatile organic compounds (VOC) in consumer 

products. 

With passage of the California Clean Air Act of 1988, the ARB 

was given direct authority to adopt statewide regulations on or before 

January 1, 1992 to achieve the maximum feasible reduction in volatile 

organic compound emissions from consumer products. In July 1989, the Board 

approved a Consumer Products Control Plan. To begin implementing the plan, 

on September 6 and 7, 1989 the ARB held a public consultation meeting to 

discuss the implementation of the CCAA mandate. The workshops announced in 

this notice are a continuation of the process begun last fall. 

follows: 

WORKSHOP II 

The locations and times for the upcoming workshops are as 

Date: February 28, 1989 

Time: 9:30 AM 

Place: Sacramento Community Center 

1100 14th Street El Dorado Room 

Sacramento, CA 95814 

WORKSHOP III 

Date: March 28-29,1989 

T i me : 9 : 3 0 AM 

Place: San Francisco State Office Building 

455 Golden Gate Avenue Room 1158 

San Francisco, CA 94102 
Each workshop will begin at 9:30AM and conclude at or before 

5:00PM. A final agenda will be available at the workshop meeting. 

Enclosed with this notice is a draft regulation entitled 

"Regulation for Reducing Volatile Organic Compound Emissions From Consumer 

Products." This draft regulation will provide the basis for the discussions 

at the workshops. In this regulation we are proposing to establish VOC 

standards for selected products and to require a reduction in VOC content of 

aerosol products equal to or greater than the percent of VOC propellant 

contained in the aerosol product. We are particularly interested in your 

assessment of the proposed standards .and dates for implementation. We have 

also included two attachments for discussion: Attachment 1 - Voluntary 

Labeling Program and Attachment 2- Alternative Compliance Plan (Quota). 

I hope you will be able to attend these workshops. These 

meetings will give you the opportunity to share your cormtents and concerns 

about the proposed regulation and your participation in this regulatory 

development process will help ensure a regulatibn that will achieve 

reductions in consumer product VOC emissions and still provide flexibility 

to industry. Written comments will also be accepted. If you would like to 

offer written comments, please submit them no later than March 5, 1990. 

They should be mailed to Daniel E. Donohoue, Manager Solvents Control 

Section, California Air Resouces Board at P.O. Box 2815, Sacramento, CA 

95812. 

Questions concerning this meeting may be directed to either Dan 

Donohoue, Manager, Solvents Control Section at (916) 322-8283 or Peggy 

Vanicek, Associate Air Pollution Specialist, at (916) 327-1517. 

Enclosures 

Sincerely, . ~·J 

. -'r-h ;. --:? :;:: . ~~ 7-- 1 I .r,_., // ..,.. ~~~.:,., -·· (:' ,_, r', 

Peter D. Venturini, Chief 

Stationary Source Division 
STATE OF CALIFORNIA George Oeukmetlan. Governor 

AIR RESOURCES BOARD 

1102 Q STREET 

P.O. BOX 2815 

SACRAMENTO, CA 95812 

March 22, 1990 

Dear Sir or M~dam: 

Public Workshop to Discuss Changes to 

Draft Regulations for Consumer Products 

Enclosed is a copy of the revised draft to the 

statewide regulation for the control of volatile organic 

compounds (VOC) in consumer products, a summary of the changes 

made to the regulation, and a draft regulation for the Bay Area. 

These draft regulations were discussed at the second public 

workshop held in Sacramento on February 28, 1990. Many of the 

revisions are the result of information given by industry 

representatives at that workshop. 

I would like to remind you of the March 28-29, 1990, 

workshop which will be held at the location given below: 

WORKSHOP III 

Date: March 28-29, 1990 

Time: 9:30AM (Second day will begin at 8:30AM) 

Place: San Francisco State Office Building 

455 Golden Gate Avenue (at Polk Street) 

Room 1158 

San Francisco, CA 94102 

The revisions to the draft statewide regulation will be 

discussed during the first day and may continue into the second 

day, if necessary. During the second day, the draft Bay Area 

consumer product regulation will be discussed. In this 

regulation, we will consider two options. The first option is to 

establish VOC standards for selected products and to require a 

reduction in the VOC content of certain aerosol products. The 

second option is to establish an ·alternative compliance plan that 

will require a 15% reduction in VOC content by February 1, 1993. 

This second option is attached for discussion purposes only. We 

believe this option will need further development before it can 

be considered viable. 
-2-

As before, the workshop will give you the opportunity 

to share your comments and concerns about the proposed 

regulations. I hope you will be able to attend. Written 

comments will also be accepted if you are unable to attend. 

Should you have any questions regarding this workshop, 

please call Peggy Vanicek, Manager, Solvents Control Section, at 

( 9 1 6 ) 3 2 2 - 8 2 8 3 .• 

., 

( 

Enclosures 

·, ., ,; 

l·-' 
STATE OF CALIFORNIA 

AIR RESOURCES BOARD 11 02 Q STREET 

P.O. BOX 2815 

SACRAMENTO, CA 95812 

May 18, 1990 

Dear Sir or Madam: 

Public Workshoo to Djscyss Changes to the 

Draft Regulations for Consumer Products 

George Oeukmejlan. Gov•r"o' 

Enclosed is a copy of the revised draft of the statewide 

regulation for the control of volatile organic compound (VOC) emissions from 

consumer products. Also enclosed is a summary of the revisions made to the 

March 20, 1990 draft regulation that was discussed at the public workshop 

held on March 28 and 29, 1990. 

The revised draft regulation will be discussed at the fourth 

consumer product workshop to be held at the date and time given below: 

WORKSHOP IV 

Date: June 5, 1990 

T i me : 8 : 3 0 AM 

Place: Junipero Sierra State Building 

107 South Broadway (at First Street) 

Auditorium, Room 1138 

Los Angeles, CA 90012 

The primary focus of this workshop will be to discuss the 

revisions to the draft statewide consumer products regulation. However, we 

will also allow time for comments pertaining to the proposed Bay Area 

Regulation that was distributed on April 27, 1990. 

Revisions to the draft statewide regulation include: the addition 

of new terms and definitions; the addition and revision of some product 

category limits based on emission data submitted by industry through Heiden 

Associates; the addition of more exemptions; and the addition of the 

Innovative Products, Registration, and Severability sections. An agenda 

will be provided at the workshop. 

We have received many requests for documentation supporting the 

draft statewide consumer product regulation. It is our intention to provide 

industry with the Technical Support Document and another revision to the 

draft regulation in early July for consideration and discussion at a 

workshop to be held in July of this year. 
-2-

This workshop and the previous workshops are an important 

component of the regulatory development process. As before, the workshop will afford you the opportunity to participate in the development of the 

draft consumer product regulation by shar1ng your comments and concerns 

about the draft regulation. If you are unable to attend, written comments 

will be accepted. 

If you have any questions regarding the draft regulation or 

workshop, please call Peggy Vanicek, Manager~ Solvents Control Section, at 

(916) 322-8283. . 

Enclosure 

Sinc,:;e;t', . . -::/' ~ 

c&~?4~ Peter D. Venturini, Chief 

Stationary Source Division 
George Oeukme}lan. ·Governor -

AIR RESOURCES BOARD 

1102 Q STREET 

P.O. BOX 2815 

SACRAMENTO. C' 95812 

July 5, 1990 

Dear Sir or Madam: 

Public Workshop to Discuss Changes to the 

Draft Statewide Consumer Product Regulation 

The Air Resources Board staff will conduct a public workshop at the 

time and place noted below to discuss revisions to the draft statewide 

consumer product regulation. 

Date: July 31, 1990 

Time: 9am to 5pm 

Place: State Office Building 8 

714 P Street Room 103 

Sacramento, CA 

(Public parking facilities available at 7th and L Streets and 2nd and P 

Streets) 

Proposed revisions to the draft regulation and a draft technical 

support document will be the primary focus of this workshop. These 

documents will be sent to you under separate cover prior to July 31, 1990. 

As stated in our previous consumer product workshop announcements, these 

workshops are an important component of the regulatory development process 

and provide you with the opportunity to participate in the development of 

consumer product regulation for California. If you are unable to attend, 

written comments will also be accepted. If you decide to provide us with 

written comments, please submit them to us by August 2, 1990. 

If you have any question regarding the workshop, please call 

Peggy Vanicek, Manager, Solvents Section, at (916) 322-8283. 

Sincerely, .---1 -"',/' ~_.,.,... 

. / L ,...,.. .,...,.,.,--· . . .....----..., / . ~ . . --;.:;:::7' /r - , c_..- . // /./.. ;,..:.//.· L . . ._A-;? t!:· ··v;,p· _.,;· .::::c~ . 

Peter D. Venturini, Chief 

Stationary. Source Division 
, ; ..>. TE OF CALIFORNIA 

AIR RESOURCES- BOARD 

l J 02 Q STREET 

0. BOX 2815 

:iACRAMENTO. C.:- 95812 

July 10, 1990 

Dear Sir or Madam: 

Consultation Meeting to Discuss the Statewjde 

Consumer Product Regulation Innoyatjye Product Provision 

The Air Resources Board staff will conduct a public consultation 

meeting at the time and place noted below to discuss the draft statewide 

consumer product regulation's innovative product provision and the draft 

alternative control plan. 

Date: 

Time: 

Place: 

July 30, 1990 

1:15 pm to 5:00 pm 

State Office Building 8 

714 P Street Room 103 

Sacramento, CA 

(Public parking facilities available at 7th and L Streets and 2nd 

and P Streets) 

This informal consultation meeting has been scheduled to discuss issues 

pertaining to the draft innovative product provision and the draft 

alternative control plan provision. The current draft of the statewide 

consumer product regulation contains a provision that allows for innovative 

products. An innovative product is presently defined as a product that bas 

a volatile organic compound content higher than the volatile organic 

compound content limit proposed for that product category, but because of 

some feature of the product design, use of the innovative product would 

result in the same emissions of volatile organic compounds as would be 

emitted from the use of a product meeting the specified limit for that 

product. Several issues have been raised concerning the innovative product 

provision including, how to evaluate the innovative product, what criteria 

will be used to approve or disapprove the application for use of an 

innovative product, and the need for "pre-market" clearance. 

Many of the issues that apply to the draft innovative product 

provisions also apply to the draft alternative control plan. In addition, 

since the draft alternative control plan may result in trade-offs in 

emissions reductions between individual products and possibly product 

categories, it is inherently more complex. We are especially concerned 

about the enforceability of any alternative control plans. 
-2-

If you have any questions regarding the consultation meeting, please 

call Peggy Vanicek, Manager, Solvents Section, at (916)322-8283. 

Peter D. Venturint, Chief 

Stationary Source Division 

• 
;,;,.>.TE OF CALIFORNIA George Deukmettan. Gov••"o' 

AIR RESOURCES BOARD 

1102 Q STREET 

P.O. BOX 2815 

SACRAMENTO. C .l. 9.5812 

July 16, 1990 

Dear Sir or Madam: 

Draft Technical Sycport Document and 

Draft Statewjde Consumer Prodyct Regylatjon 

Enclosed is a copy of the draft technjcal support document (ISO) and 

draft consumer product regulation (Appendix B of the ISO). As indicated in 

our letter dated July 5, 1990, proposed changes to the draft ISO and draft 

regulation will be discussed at the public workshop to be held on the d•te 

and time given below. 

Date: 

Time: 

Place: 

July 31, 1990 

9 am to 5 pm 

State Office Building 8 

714 P Street, Room 102 

Sacramento, CA. 

(Parking facilities available at 7th and L Streets and 2nd and 

P Streets) 

Please note that the room number for the workshop was incorrectly 

printed in the July 5th letter. The correct room is shown above. Again, we 

welcome your participation in this important aspect of the regulatory 

development process. If you cannot attend, you may wish to provide us with 

written comments. Please submit your conrnents by August 2, 1990. 

If you have any questions regarding the workshop, draft ISO, or draft 

regulation, please call Peggy Vanicek, Manager, Solvents Control Section, at 

(916) 322-8283. 

Enclosure 

Sincerely, 

~Peter D. Venturini, Chief 

Stationary Source Division 
Appendix E 

Cost Analysis Calculations 
COST ANALYSIS CALCULATIONS 

Annual Cost 

1. Reformulation cost estimates from industry ranged from $2,000.00 to 

$2,000,000.00 per product. Most estimates were between $50,000 and 

$100,000 per product. Cost-effectiveness ratios were determined for 

reformulation costs of $100,000 and $2,000,000 per product. 

Low Cost to Reformulate: $100,000 per product 

High Cost to Reformulate: $2,000,000 per product 

2. The cost to reformulate was amortized over both 5 years and 10 years. 

3. Annual cost to reformulate a product for four cases: 

Cost to reformulate: $100,000 

Amortization: 5 years 

Case 1 

Assume interest rate = 10% 

End of Year payments = principal * i(1+i)n 

where i = interest rate 

n = number of years 

(1+i)n-1 

= $100,000 * 0.1(1+0.1) 5 

(1+0.1) 5-1 

End of Year payments = $26,378 per product 

Cost to reformulate: $100,000 

Amortization: 10 years 

Case 2 

Assume interest rate = 10% 

End of Year payments = principal * i(l+i)n 

where = interest rate 

n = number of years 

(l+i)n-1 

= $100,000 * 0.1(1+0.1) 10 

(1+0.1)1Q1 

End of Year payments = $16,274 

E-1 
Cost to reformulate: $2,000,000 

Amortization: 5 year 

Case 3 

Assume interest rate = 10% 

End of Year, payments = principal * i(l+i)n 

(l+i)n-1 

where = int~rest rate 

n = number of years 

= $2,000,000 * 0.1(1+0.1) 5 .. . 5 

( 1+0 .1) -1 '-•' 

End of Year payments = $527,595 

Cost to reformulate: $2,000,000 

Amortization: 10 year 

Case 4 

Assume interest rate = 10% 

End of Year payments = principal * i(1+i)n 

where = interest rate . n = number of years 

(l+i)n-1 

= $2,000,000 * 0.1(1+0.1) 10 

(1+0.1) 10-1 

End of Year payments = $325,490 

Total Cost to Industry 

1. Total Annual Cost = (Annual cost per productC.feformulatibn~ x (number 

of noncomplying formulations) 

2. Number of noncomplying products from ARB survey estimated at 683. 

3. Total Cost using annual· cost figures above •. 

Case 1: (683)($26,378) = $18,148,064 - 18 miliion 

Case 2: (683)($16,274) = $11,196,512 - 11 million 

Case 3: (683)($527,595)= $362,985,360- 360 million 

Case 4: (683)($325,490)= $223,937,120 - 220 million 

E-2 
Cost Effectiveness 

1. Cost Effectiveness = (Total annual cost of regulation)/(Total emission 

reduction) 

2. Total (national) emission reduction (1994) estimated at 290 TPD. 

3. Cost Effectiveness Ratios in dollars per pound VOC reduced. 

Case 1: ($18 million)/[(290 TPD)(2000 lbs/ton)(365 d/yr)] - $0.08/lb. 

Case 2: ($11 million)/[""] $0.05/lb 

Case 3: ($360 million)/[""] - $1.50/lb. 

Case 4: ($220 million)/[""] - $1.00/lb. 

E-3 
Cost Impact to Consumers 

The cost increase of an average aer~~~l pro~uct was,estim;ted. It is 

assumed that all reformulation costs are passed on to the consumer and that 

products are marketed nationally with the cost of reformulation spread throughout the nation. 

1. Cost increase per unit = (Total cost)/(Total number Of ,aerosol units) 

2. Total cost (in California)=(Cost/formulation)(ho. aerosol formulations) 

Cost/formulation =Annual cost per formulation from the four cases in 

Appendix F scaled down for California by population. California is 

approximately 11% of the nation's population .. 

The number of noncomplying aerosol formulations is estimated at 391 

based on the .ARB survey. 

3. Total number of aerosol units from ARB survey= 97,600,000 

4. 

(An estimate of the total number of aerosol units was calculated using the total sales of noncomplying aerosol products (lbs/year) reported in 

the ARB VOC Survey and assuming an average unit size of 10 oz. by wt.) 

Cost per unit: 

Case 1: ($26,378)(0.11)(391)/97,600,000 = $0.012/unit 

Case 2: ($16,274)(0.11)(391)/97,600,000 = $0.007/unit 

Case 3: ($527,595)(0.11)(391)/97,600,000 = $0.23/unit 

Case 4: ($325,490)(0.11)(391)/97,600,000 = $0.14/unit 

E-4 
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