## PROPOSEDREGULATIONTOREDUCE VOLATILEORGANICCOMPOUNDEMISSIONS FROM CONSUMERPRODUCTS

TECHNICALSUPPORTDOCUMENT

.STATEOFCALIFORNIA AIR.RESOURCESBOARD 

### STATIONARYSOURCEDIVISION AUGUST 1990

" 

# -

....

### StateofCalifornia AIR RESOURCES BOARD

TECHNICAL SUPPORT DOCUMENT FOR APROPOSED REGULATION TO REDUCE VOLATILE ORGANIC COMPOUND EMISSIONS FROM CONSUMER PRODUCTS

Prepared by:

Solvents Control Section CriteriaPollutants Branch

Reviewed by:

PeterD. Venturini, Chief, StationarySource Division Ronald A. Friesen, Assistant Chief, StationarySource Division Dean C. Simeroth, Chief, CriteriaPollutants Branch Peggy l. 

### Vanicek, Manager, Solvents Control·section StationarySource Division Air Resources Board

August 1990PROPOSED 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 CaliforniaAir Resources Board. Publication does not signifythat the contents reflect the views and policies of theAir 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 theAir Resources Board Solvent Control Section staffwith 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 SpecialtyManufacturers Association, the Cosmetic Toiletries and FragranceAssociation and the Soap and DetergentAssociation 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. AdministrativeRequirements

...........................? E. Variances

.............................................8 F. Test Methods

..........................................9 G. Severabi1ity

.........................................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-PurposeAerosol 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. Nai1Po1ish Remover

..................................60 P. Oven C 1

eaner
.........................................63 Q. Shaving Cream

........................................65TABLE OF CONTENTS (CON'I)



### Contents**~** 

### VII. Impacts

..................................................67 A. Economic Impacts

...............................;
.......- ..67' B. Environmenta1Impacts

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

### VIII. Issues

.....................................................76 

### A. Collection of VOC Survey Data

..............**~**

### .........76



### ..B. VOC.Content Verses VOC Emissiens
..........**~;.;**

### ........77



### C. Ttme for..Industryto.camply

..........................79 

### D

.. Liquid Laundry Detergents

............................Sl E. Dual-PurposeAerosol Air Freshener/Disinfectants

.....82 References

..........................................................'

.......95 AppendicesA. CaliforniaClean Air Act Section 26 -.B•. 

### Proposed Consumer Product Regulation

C. VOC Survey Summary 

# o. Workshop Announcements E. Cost Analysis CalculationsLIST OF TABLES

1 Proposed Consumer Product VOC Standards Percent by Weight.

...................................4 2 Ozone and PM10 Air Qua1ity 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 FurnitureMaintenance 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

...................57LIST 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...........•..........90Figure

1
2 LIST OF FIGURES

California Ozone Attainment Status

.............13 California 

### PMlO Attainment Status

..............14I. 

### INTRODUCTION

A. OVERVIEW The California State Legislature, aware of California's serious air pollution problems and the inabilityofmany 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 SafetyCode, which requires theAir 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 theARB must be necessary, and commercially and technologicallyfeasible. 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 specialtyproducts. The definition of consumer products specificallydoes not include paint, furniture coatings, or architectural coatings. Consumer products comprise an important source of VOC emissions in California. Based on theARB 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, theARB 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
-1-deodorants and antiperspirants in thefall 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 establishingVOC 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 adraft comprehensive regulation. In January 1990, a Court Order was issued to the Bay Area Air QualityManagement District (BAAQMD) and/or the ARB to adopt, by July 1990, regulations designed to achieve at least a 4ton per day emission reduction from consumer product solvents in the BayArea. 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 staffused in developing the comprehensive regulatoryproposal tci reduce emissions from consumer products statewide. The majorityof the information contained in this TSD was obtained from members of the consumer product industry through five publicworkshops, 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 overviewof 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.

-2-II. 

### CONSUMER PRODUCTREGULATION

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 theAir**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 theminimum 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 ahigher 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-PurposeAerosol**Ai~** 

### Freshener/Disinfectant Automotive Windshield Washer Fluids



### . * Type AAre'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 F1 

### oor Wax 90 FurnitureMaintenance 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 reasonablyexpected to occur: Del Norte, Shasta, and TrinityCounties, and the Lake Tahoe, Mountain Counties, Great Basin Valleys, and Northeast PlateauAir Basins.

-4-TABLE 1 (Can't)
Proposed Consumer Product VOC Standards Percent byWeight

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)

Aone 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 BayArea 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 necessaryto 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 RodenticideAct (FIFRA), the effective date of the VOC standards is one year after the effective date listed in the Table of Standards for the product categorywhich 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 othermicro-organism (except viruses, bacteria, or othermicro-organisms on or in livingman or other living animals)(7 U.S.C., Section 136(u)). By virtue of this definition, FIFRAregistered products generallytend 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 claimmade by themanufacturer 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 Californiacannot 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 themarket after the effective date ofthe regulation and will not applyto 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 thatmay 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 ofexempt ozone-depleting compounds used in consumer products to ensure thatmanufacturers do not switch to ozone depleting compounds when they are reformulating current products to lower VOC content. This is generallythe same as a similar provision in the antiperspirant and deodorant regulation that the Board adopted in November 1989.

B. INNOVATIVE PRODUCTS Aconsumer product can be exempted from theVOC standards in the regulation if it can be classified as innovative. An innovative product is a product which may have aVOC content greater than the applicable VOC standard, but which emits less VOC emissions than arepresentative consumer product which does meet that standard. To be eligiblefor this exemption, a manufacturer must demonstrate that**us~** 

### ofthe product will result in less emissions than a complying product, due to some characteristic ofthe , product formulation, design, delivery system, or other factors. The manufacturer must also identifythe 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 ofmore than 12 carbon atoms, if the vapor pressure is unknown. Those VOCs with vapor pressures less than 0.1 mm Hg have very low, volatilityand due to the product formulation characteristics are less emissive than higher volatilityproducts

..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 2percerit by weight contained in anY consumer product. This exemption was established to allowmanufacturers 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, themarket 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 entirelyof fragrance not including exempt VOCs. This is to allowthe 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 substancewould be 100%. The active ingredient (e.g. the fragrance) is present in amore 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 allowfor 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 threemonths after the effective date of the regulation, consumer products subject to the VOC standards shall display the date ofmanufacture either on the container or on the packaging. Ifthe manufacturer uses a code to indicate the date ofmanufacture, an explanation of the code must be filed with the Executive Officer of theARB no later than 3months after the effective date ofthe regulation. This will aid in enforcement of the regulation by allowing inspectors to verifythat 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 theARB no laterthan ·· March 1, 1991, 

### and no laterthan March 1

### of everythird year thereafter. All registration material will be handled in accordance with the confidentialityprotection**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 ofthe trademark or brand name; -the product categorytowhich the consumer product belongs; -the product forms (aerosol, liquid,. etc.); the California**~nnual** 

### sales in pounds per year and themethod used to

calculate it; -the total VOC content in percent by weight which (a) has avapor 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, ifthevapor 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 eliminatethe need for administering product surveys. Itwill also allow staffto track emissions from consumer products and to evaluate the effectiveness ofthe 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 avariance. The variance application shall statethe specific reasons why avariance 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 avariance application, the Executive Officer will hold apublic 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 ofthe applicant.

-8-2. The public interest in mitigatingthe 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 afinal compliance date by which compliance with the standards will be achieved, and the increments of progress necessaryto assure timely compliance. The order may also contain any other conditions that the Executive Officer deems necessaryto carryout the purposes of Division 26 of the Health and Safety Code. Avariance'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 themethods. Each method is designed for certain applications. Before a product can be tested, an evaluation of the nature and chemical properties ofthe product must be made. Based on the results of this evaluation, amethod or combination ofmethods 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 alternativemethods 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 testmethods and improvements to existingmethods. 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. Staffwill 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 ProtectionAgency**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 itwill continue in full force and effect.

-10-III. AMBIENTAIR QUALITYAND 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 particulatematter 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 theARB 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, especiallyduring vigorous physical activity. This health effect is particularly acute in children, the elderlyand people with respiratory conditions. Ozone levels also damage some types of vegetation, reducing theyields from some crops. Particulatematter 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 respiratorytract 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

AmbientAir QualityStandards for Ozone and 

### PM-10
Average Time 1hour

Annual Geometric Mean 24 hour Annual Arithmetic StateStd. 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 1and**~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 themap, 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 5percent 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 collectivelythey 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. Aregulation limiting emissions**f~om** 

### this source is**necessa~y** 

### to help Californiameet the state and federal**~mbient** 

### air quality standards and to help nonattainment districts achieve the required 5percent annual emissions reduction from ozone and PM-10 precursors. ·

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### IV. EMISSIONS ESTIMATES FOR THE REGULATED CATEGORIES

To quantifyemission 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 quantifythemagnitude of emissions from each product category. Staff initiallyused ARB's 1983 Emissions Inventoryto get afirst 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 themagnitude of emissions from the different categories, it nevertheless needed improvement. Various changes in the market from 1983 to 1988 may have significantlyaffected the estimated emissions. To alleviate this problem, staff designed a comprehensive consumer products VOC surveywhich 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/dayemissions 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 giveARB staff comprehensive data on formulations and production figures. The surveywas distributed and collected byARB 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 directlyto staffwere screened for obvious errors. Subsequently, data thatwere deemed by staff to be representative and accuratewere 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 themarket. In these cases, efforts were made to find themissing 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 datawas 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. Asummary ofthe VOC Survey data for the products being proposed for regulation is included in Appendix C. · Using data thatwere found to be accurate and representative, ARB staff found that the 16 products proposed for regulation are responsible f6r approximately 102 tons/dayofVOC emissions. This is ofthe same order of magnitude as the existing inventory, which tends to support the accuracy of the inventory. However, sincethe product categories reviewed to date · represent only afraction 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-categorybasis. 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 associatedwith 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 1365 1 100 (1)

=

### VOC emissions (per product) [=] 

### ton VOC/day voce voce 

## =VOC content ofproduct [=] 

### 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 categorywas calculated using the following equation:

where, 

### =VOCc1*Prod1 Prod1 + VOCcz*Prod2 + ••• + 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 theARB 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 majorityof Californians who live in themore 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 Californiathat comply with the standard are summarized in Table 4. The number of complying products being sold in California are based on the responses to theARB VOC survey.

-19-TABLE 4 

### SummaryofComplying Products

I IProposed INumber of Complying Product IProduct IStandard, IProducts Currently**CSlt~gQC!l** 

### I EQCtD 

### I H:t**~ ~QC**  

### I**B~jcg** 

### Sgld jc CA 

### I I I Dual-Use AerosoliAeroso1 

### 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 

### Iliquids/Pumps I 18 I 84
II 

### !Solids/Gels I 3 I 33 I I IOther I 3 I 9 I I I I, I 

## r !Automotive lA11 

### Forms ,I 10 I UTQ*** I I Windshield I (AAreas) 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 lA11 

### 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 lA11 

### Forms 90 5 I I I I IFurnitureMain- I Aerosols 25 22 I I tenance Product! I I II 

### ISolids 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 currentlyno complying products on themarket, 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 ofComplying Products

I I I Product I Product I Category IForm 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 !InsectRepellantsiAerosols 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 5below summarizes the product categories with future effective standards. Engine degreasers, hairspray and nail polish remover products are· currentlybeing 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 allowfor othermanufacturers 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 complexityof 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 currentlybeing marketed in California, however, conversations with industry representatives have indicated that the technology is developing in this area that will allowfor the production of a single phase aerosol at the lower limit. -21- i /

### TABLE'S Proposed FutureEffectiveStandards

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 ofmasking 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 awide 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 claimto 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 8tons per day. Table 6 shows shows the percentage of emissions from each subcategory.

-23-

### Prodyct Form Aerosol-2 phase Aerosol-1 phase Liquids/Pumps Solids 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 ofthe air freshener market at about 50% and contribute about 80% ofthe 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% ofthe air freshener market yet contribute nearly20% ofthe 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 afine "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 airfresheners 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 ahousing that is pushed whenever a "shot" qf the product is desired. According to theARB survey, dual phase aerosol air fresheners make up the majorityof the aitfreshener market at 45% and contribute over 60% of the emissions from air.freshehersj With dual phase aerosol products, the liquid contents ofthe product are present in more than one phase. Generally, awater 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 tomix the phases into a**homog~neous emulsion~**  

### According to theARB survey, 1

### iquid airfres.heners make up about 20% of the air freshener market and contribute about 15% ofthe emissions. Although afew products aremarketed as liquids in containers that are exposed directlyto open air, most are availablewithin specialized packaging to control the release rate (evaporation) ofthe product. Most liquid products use awick, pad, or other barrier between a liquid reservoir and open air to control the evaporation of the fragrance and any solvents. -24-Amore 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, inertmaterial. An example of these products is a fragrance impregnated paper air freshener for use in automobiles. Liquid products delivered by pump spraymake up a very small percentage of the air freshener market. Solid air fresheners include powders, crystals, blocks and gels. According to theARB 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 categoryof 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 contribute4.3 tons per day VOC emissions, making this subcategorythe 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-PurposeAerosol Air Freshener/Disinfectants." Product Content Formulation: The formulations and VOC content used in air fresheners varywidelywith 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 theARB surveythese products have an average VOC content of approximately40%. Dual phase products contain two liquid phases and a propellant. The liquid phases consist of awater 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 generallymade up primarilyof 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 theARB survey
.. These products contain a small amount of fragrance with the balance consistingof 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 varywidely. The average VOC conten't according to theARB survey is20%. Formulations typicallycontain 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 theARB survey. These formulations typicallycontainwater, various solvents, and athickener such as silica. The solid "block" closet fresheners and toilet bowl fresheners often contain 100% paradichlorobenzene and a small amount offragrance. Many other toilet bowl fresheners are**~omposed** 

### primarilyof 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 ofdisinfectant agents may also be added to the formulation. ProductUse: Air fresheners are used in household, automotive, institutional, and commercial settings to treat unpleasant odors. This is accomplished bymasking the odor with apleasant scent or removing the oddr. While most air fresheners mask odors, afew claim to remove the offending odors by chemicallyreactingwith them. Household airfresheners are used to treat bathroom and kitchen odors, pet odors, garbage odors, smoke, and odors caused bymoisture. Common household products include aerosol sprays and solid or liquid products which· evaporate from adispenser. Aerosol air fresheners, which make up the majority ofthemarket, are generally sprayed as needed with the user controllingthe 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 consistmainly of liquids. These products include paper and othermaterials 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 ofthemarket are self-dispensingproducts with the product emissions generally controlled by the chemical and physical characteristics ofthe product as well as the ambient temperature and humidity. These products are described as "maintenance" airfresheners and are designed to maintain a constant scent over a long period oftime. Anumber of products are available including mostly liquid and solid products. Some products are -26-available within an enclosurewith afan 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 sprayproducts) begins with the purchase and storage of chemical ingredients in bulk. The ingredients are generally added to stainless steel vessels where they aremixed. 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 varietyofmethods. Health and SafetyConcerns: 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 highlyflammable 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 7below. 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 aCSMA proposal. According to theARB survey, 20 of the 65 dual phase aerosol products reviewed currently comply with the limit. No single phase product currentlycomplies with the proposed 70% limit, but based on discussions with CSMA and the industry, reformulation to the limit is feasible. Afuture effective standard of 30% has been set for all aerosol air fresheners in 1996. Single phase aerosols contribute adisproportionately high amount of emissions based on their share of themarket. This segment of themarket 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 allowfor 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 So1

### 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 ofthe air freshener products under the "other" categoryactuallyfall under the "solid" category since 84% of themarket comp1

### ies with the 3%. standard. Theref'Ore a3% standard was used to calculatethe emission reduction.

The VOC limits for liquid and solid air fresheners at 18 and 3percent· respectively, are based on the salesweighted 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 onlyfragrance 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 directmeans of ··· reformulation. Staff believes that simpledilution would not lead to**emi~sion** 

### reductions. Since these concentrated products result in aminimum ofemissions of nonfragrance VOCs, staffbelieves 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 2mm Hg at 2d degrees Celsius, the sole purpose ofwhich is to impart an odor or scent, or to counteract a · malodor. According to discussions with the fragrance industry, the· definitionwill include themajorityof availablefragrances while limiting the potential for inclusion of nonfragrance components to fragrances. An exemption has also been provided for air fresheners containing at least98% paradichlorobenzene (PDCB). This exemption was provided for closetfresheners and toilet bowl deodorizers. We are not aware of ameans· of reformulating these products since they are almost entirelycomposed of PDCB, aVOC.

-28-Compliance with the Standard: The primarymethod 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 ameans 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 certainmicrobes, they are classified by EPA under the general categoryof pesticides and registered under the Federal Insecticide, Fungicide and RodenticideAct (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 approximately4.3 tons per day of VOC emissions. Product Content Formulation: The major ingredient in dual-purpose aerosol air freshener/disinfectants is ethanol, comprising approximately45% 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 onlywhen the transmission of health-threatening diseases through contact with hard surfaces is amajor concern. However, ARB staff believes that consumers may be significantlymisusing these products as air fresheners, a function for which there aremany alternative lower-VOC products. It is important to note that these products are efficacious onlywhen 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 SafetyConcerns: The major safetyconcernwith any aerosol is the flammability ofthat product. Therefore, flammability concerns that applyto 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 byweight would result inareduced efficacyproduct. To**addres~** 

### these concerns, staff has prepared an analysis ofthe feasibilityof

..-- limiting the VOC content of dual-purpose aerosol air freshener/disinfectants to 60% (See Issues, Chapter VIII). From this analysis, staffhas determined that the standard of 60% VOC can be achieved while still allowing efficacious disinfectant products to be availableto 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: Staffrecommends 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 theStandard: ARB staffbelieves 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 apump, and (4) redesign the products into an innovative package such that it emits fewer emissions. Of these, options 1, 2and 3 are believed to be the most cost-effective and easiest options to implement. Note that option 1requires only a labeling and marketing change. The timeframe that is proposed in the regulation allows for additional time to reformulate and reregisterthe reformulated product under FIFRA.

C. AUTOMOTIVEWINDSHIELD WASHER FLUIDS Product Description: Automotive**~indshield w~she~**  

### fluid_means any liquid designed for use in amotor vehiclewindshield washer fluid system for the purpose of cleaning, washing; or wetting thewindshield(s). This definition does not include any fluidfound in anew**~dtor ~ehicle**  

### at the time the vehicle is manufactured. Product Forms: Because thewasher system is designed to spraythe fluid onto the windshield(s) through apump, windshield washer fluids are sold exclusivelyas liquids. Product Content Formulation: Methanol comprises themajorityofthe· VOCs found in washer fluids. Asmall fraction ofthemarket 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 generallyrange 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 typicallyrange from 35% to 80% methanol by weight. Product Use: Windshield washer fluids are used to clean, wash, or wet windshields. The primary purpose of themethanol and isopropanol in washer fluids is to impart afreezing-point depression to the water used in the system, thereby preventing thewater 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 SafetyConcerns: Poisoning may occur from the inhalation or ingestion of eithermethanol or isopropanol. Ingestion of 100-250 milliliters of eithermethanol or isopropanol is usuallyfatal. Since themethanol and isopropanol impart afreezing-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 greaterthan what is required in California's generallytemperate climate. ARB staff's analysis ofmean 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 onlyrequire a 10% methanol by weight washer fluid. Thus, ifwe assume that washer fluid use is proportional to population, it appears that approximately 97% ofthe 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 standardwould apply onlyto 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 aremost likelyto encounter ambient temperatures below 20 °F, would allow residents in these areas tomaintain thefreezing-point protectionthey currentlyhave while allowing emission reductions elsewhere in the state. Product Emission*: Survey results from CSMAwere not considered by staffto be accurate or representative of thewindshield washer fluid market in California because ofthe insufficient response to the survey. Since these surveyresponses did not improve ARB's currentemission estimates, staff assumed the emissions from the 1983 Emission Inventorywere still correct, updated to 1988 levels. From the inventory, staff estimated that 24 tons per day ofVOC**~ere** 

### emitted in 19B8·fromwindshield washer fluids

.. Recommended VOC Standard: Staffproposes to limit the VOC content for windshield washer fluids to 35% by weight in Type ACounties (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 ofthe concentrated product and · distributingthe fluids properly, or (2) reducing the amount ofVOC in the ready-to-use products to the specified limits. Appendix Cpresents staff's. complete analysis and justificationofthe recommended standards for this product category. Compliance with theStandard: Since no major process modifications are involved, the 1/1/93 compliance date should be adequate time for industryto comply with the standards. Staff expects thatmost ofthe time required to comply with the standards will be in redesigning the product labels.

D. BATHROOMAND TILE CLEANERS Product Description: Bathroom and tile cleaners are defined in the regulation as cleaners specificallyfor 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. Collectivelythese products contribute

-32-0.45 tons per day VOC emissions to the atmosphere. Table 8below breaks down the percentage of emissions from each product form.

Product FormAerosol Liquid Pumps Solids TABLE 8 Bathroom and TileCleaners 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 asfoaming bathroom cleaners account for about 37 percent of themarket, 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 themajorityof 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 categorydue to low VOC content. Solid bathroom and tile cleaners make up a small segment of the market comprising about 2percent of the market. Product Content Formulation: The bathroom and tile cleaner category contains awide 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 directlyor 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 SafetyConcerns: Health'and safetyconcerns 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. Aspecific safetyconcern whenever cleaning products are used is the possibilityofforming 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 5percent. According to theARB 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 theARB 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 TileCleaners 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 

### Scilid 5 0 0 0.01 

### Compliancewith theStandard: The primarymethod 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 ameans for the development of low emitting products that cannot meet the VOC standard. E. ENGINE DEGREASER Product Description: Engine degreasers are specialtycleaning products designed toremove grease, grime, oil and other contaminants from the external surfaces of engines and othermechanical 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 theARB VOC Survey, VOC emissions from engine degreasers were 4.5 tons per day. The surveymay 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. A10 to 15 minute waiting period is required to allow the degreasing components to penetrate the contaminants. The contaminants are rinsed offwith awater jet or hose. The engine is then started and allowed to idle for 10 to 15 minutes to assure drying. The process may berepeated if the engine is especiallydirty. Engine degreasers aremost 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 thoroughlymixed, it is injected into aerosol containers by either of two processes, "under the cap" or "through the nozzle". Health and SafetyConcerns: Current formulations contain petroleum distillates and aromatic solvents which are highlyflammable. 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 contactwith 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 currentlyon the market which can meet the proposed limit. The estimated emission reductions -35-

### are 0.93 tons per day in·1993. Afuture effective staridard of 5d% VOC is also being proposed for 1/1/96. At this VOC content level there are at least 3products currently available that can meet the standard. , Manufacturers who do not have products that can meet the 50% limit have almost 6years to develop and market a·lower VOC engine degreaser. This future effective standard will achieve an additional 1.2

### TID emission reduction by 1996. Compliancewith theStandard: Information received byARB staff indicatethat reformulation towater-based products and the reduction or elimination of propellants is possiblewithin the timeframe proposed in the regulation. The market share for complying products may increase as compensation for adecrease in themarket share for non-complying products. Subsequently, noncomplying products may be reformulated and re-enter the market as complying products. In some ofthe products the VOC propellants have been replaced by compressed gases such as carbon dioxide. Alternative packaging such as hand pumps and theAirspray system are also available because a fine spray is not needed for a greatmajorityof the cleaning jobs. In addition, there are a number of all purpose cleaners on themarket which contain significantly lower amounts ofVOC which may perform as well or better than the aerosol sprays. Furthermore, steam cleaning an engine is

.. still possible. This method was thembst 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 therebyeliminating 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 offloors. Excluded are products onlyfor the purpose of cleaning floors, sealants for unfinished wood floors or other products falling under district architectural coating rules, and industrial spraybuff products. The vast majorityoffloor waxes**~nd** 

### polishes are used on flexible flooringmaterials such as vinyl and vinyl composite. These products include both "dry bright" products used mainly in households and products thatmust be buffed with abuffingmachine. Products requiring buffing are typicallyused on flooring in institutions and business with heavy traffic such as supermarkets, department stores and hospitals. Asmall number offloor products are availablefor nonresilient flooring such as marble and for wood floors. Product Forms: Emissions from the floof polish categorytotal 2.6 tons per day. According to theARB consumer products survey, about 99% ofthe market is made up of products for use on nonwood surfaces, primarilyon flexible flooring materials. These products contribute about**82~** 

### ofthe emissions from the floor wax/polish category. Product for use on nonwood floors are primarily liquids although afew aerosol products are available. -36-Liquids, solids, and other forms for use on wood floors make up less than 2% of themarket, 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 theARB 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 majorityof floor polishes are water based products designed for vinyl or other flexible flooring. These products contain primarilywater with various polymers or waxes that form the final hard surface layer. Anumber 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 usuallyhave similar formulations with a slightlyhigher solvent content. Wood floor waxes are solvent based formulations containing waxes and solvents such as mineral spirits. Product Use: The product typicallyused by the consumer is the "dry bright" type emulsion. This product is simply applied with amop to a clean floor and allowed to dry. Commercial and institutional products designed -37-

### for high traffic areas usuallyrequire buffingwith a special buffing**machin~** 

### that produces ahard, shiny surface. Manufacturing Process: The manufacture of liquid floor polishes/waxes includes mixing and homogenization ofthe 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 1i

### ne. Health and SafetyConcerns: 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% 

### limitfor 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 ofthe floor polish category. These products are almost entirely liquids with an average sales-weighted VOC content of about 5% according to theARB survey. Aerosol floor polishes which make up only about 3% ofthe floor polishmarket, 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 theARB surveywith 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 slightlyhigher concentrations of solvent coalescing agents, but have greater durability, allowing longer periods between recoating. Floor polishes for nonresilient flooring make up aminor segment of the market. According to industrycontacts, a higher VOC limit is necessaryfor waxes and polishes used on sealedwood 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. Alimit 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% ofthefloor polish/wax market. According to industry, these high VOC products are used exclusivelyon wood floors. According to discussions with industry, these products are especially important for use on unsealed or poorly sealedwood floors which may be damaged by water based products. There are currently architectural coating regulations in Californiathat have aVOC content limit of350 grams per literfor general sealers. This may indicatethe possibilityof 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. Itwas assumed that these products made up 10% of the emission reduction from the nonwood floor products. **Data not available.

Compliance with the Standard: The primarymethod 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: Furnituremaintenance 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 separatelyby the regulation, and products onlyfor the purpose of cleaning. Dusting aids make up a categoryof products similar to FMP's. Dusting aids are most often aerosol sprays that are applied to dust rags or floor dustingmops to aid in the removal of dust. AVOC 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: Furnituremaintenance 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 FurnitureMaintenance 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 easilybe separated from the other FMP's in the survey. Therefore, numbers may be slightlyoff. **Products undet the "All other forms" categoryconsist**p~imarily** 

### of liquid and pump spray**produ~ts.**



### Aerosol spray products make up themajorityofthemarket atabout 72% and contribute about 87% ofthe emissions from the category. The "All other forms" category is made up primarilyof liquids and pump sprayproducts. These products make up an estimated 26% 

### of themarket. Due to low VOC content, these products contributeonly about 8% ofthe emissions from the category. The solid or paste products make up only about 21 

### ofthe market and contribute about 5% ofthe 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**  

### primarilywater. 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 slightlyto the VOC content. According to theARB 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 ofthe market according theARB consumer products survey. These solvent based products containwaxes, with the balance consistingof solvents such as mineral spirits. The average VOC content ofthese 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 generallymuch 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 theARB consumer products survey, the sales weighted average VOC content is 5.6% for liquids and 7.3% for pump sprays. Product Use: Furnituremaintenance 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 aremore 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 awood cleaner and preservative. Dusting sprays are used to aid the removal of dust. These products also clean wood surfaces. Furnituremaintenance 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 thewater phase is absorbed by the cloth while the solvent/wax/polish phase remains on the wood surface. The solvents eventuallyevaporate, leaving the wax/polish layer. Manufacturing Process: The manufacture of liquid furniture maintenance products involves themixing of thewater, 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 SafetyConcerns: 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 theARB survey is 27%. A25% limitwas proposed by CSMA for this categorywith the exception of dusting aids. Based on this information, the limitwas 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 theARB 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 furnituremaintenance products subcategories.

TABLE 13 FurnitureMaintenance 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 slightlyhigh. ** Products under the "all other forms" category consist primarilyof liquids and pump sprays. This does not include pastewax.

Compliancewith theStandard: The primarymethod 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 ameans 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. Specialtycleaning products for use in specific situations are not included in this category. Also excluded from the category are bathroom and t i1 

### e c1 

### ea.ners which are regu1 

### ated under a separate category. · ··· Product Forms: The general purpose cleaner categorycovers awide varietyof 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 themajorityofthemarket at nearly**60~** 

### and contribute93% of the emissions from this category. Solid products, primarilypowders, make up over 40% ofthemarket but contribute only about 4% ofthe emissions from the categorydue to low VOC content. Aerosol products make up less than one percent ofthemarket, 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 alkalinematerials, surfactants, solvents and abrasives. Alkalinematerials such as alkaline salts or builders performmany functions in cleaning formulations. They increase the efficiencyof surfactants, prevent water hardness from combining with soils, help disperse and suspend dirt, saponifyfatty 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 oilymatter. Water is the most widely used solvent. Abrasives are generallycomposed of small particles used to smooth, scour, rub, and clean surfaces by mechanical action. From theARB 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 theARB survey. The VOC content of general purpose cleaners is made up primarilyby 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 specialtyapplications. Liquid products are used either "straight" or diluted. These products are applied tomany different surfaces, but especiallyto floors or other large surfaces with amop, sponge or rag. Some scrubbing is usuallyrequired 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 arag or sponge. Few aerosol general purpose cleaners are on themarket. 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 awide 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 generallyrequiremore rubbing than other cleaners sincetheywork primarilyby 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 oftheir 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 SafetyConcerns: Health and safetyconcerns 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 causticproducts, products with strong solvents, and disinfectant cleaners. Aspecific safetyconcern is the posJibilityofforming toxic chlorine gas when products containingchlorine bleach come in contact with acidic products or products containingammonia. Many prOducts have warning labels instructing consumers not tomix these products. Recommended VOC Standard: The proposed 10% VOC level is currentlymet 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 belowthe 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% ofthemarket. Also, halfofthe aerosol general purpose cleaners currentlycomply with the 10% standard. The 10% standardwas 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 primarymethod 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 ameans 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 primarilyfor cleaning surfacesmade of glass. Product Forms: Product forms include aerosol and liquid/pump spray, • with market shares of 6% and 94%, respectively. There is also arelatively· new product availablewhich consists of clothwipes 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% ofthe 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 essentiallyunaffected 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 colorantis less than 0.1%. Glass cleaners typicallydo not use fragrance, sincethe unmasked ammonia odor ofthe product is associated by the consumerwith cleanliness. Blue and green dyes are often used, for color. Glass cleaners typicallyhave ahigh 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 thereforehas 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 afoam. 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 specificmarket shares for these are not currentlyknown. The product can be applied by aerosol, pump, or hand wiping, and is then wiped off. Advantages ofthe aerosol form include better visibilityof the product on the glass, so the consumer can more· easily seewhat remains to be wiped off, and better adhesion ofthe 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 largemixing tanks, adding the ingredients in specificorder, lettingthem dissolve, and then mixing them together. No production changes are foreseen due to the effect of the regulation. Health and SafetyConcerns: 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 surveydata 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. Industryhad requested a 10% standard, stating that the 6% standard would essentiallyban 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 primarilyfor dispensing droplets of resin (filmforming polymer) on and into the hair coiffure (hair style) to enable users keep their hair in position for a period of time, unaffected by theweather 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 qualitymust 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 

### HairsprayEmissions 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 hairsprayformulat,ions currentlyavailable is 94% for aerosols and 70% for pumps. (Heiden Associates) The key ingredients in hairsprayformulations are: resins, solvents, propellants (aerosol only), neutralizers, co-solvents, plasticizers and. other additives. The active ingredient in all hairsprayformulations, which holds the shape of the hair, is the resin (filmforming polymer). There aremany 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 hairfixative resins contain carboxyl groups, neutralizers are amajor component in hairsprayformulations. The neutralizer acts to adjust the solubilityof 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 carrythe film (resin) onto the hair, and then evaporate to leave the film behind. Ethanol is used exclusively in the United States as themajor solvent in hairsprayformulations. 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 ablend 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 caremarket iS dimethyl ether (DME). DME can be used in formulating water-based hairsprays, which are becoming increasinglypopular. The solubilityof hydrocarbon propellants in a hydroalcoholic system limits the amount ofwater that can be used, but DME shows very good solubility in water and alcohol. Co-solvents many uses include: reducing the flammability rating ofthe**produtt~** 

### reduce the vapor pressuraofthe propellant or reduce the cost in some formulations. Examples of co-solvents are: dimethyl ether (DME), methylene chloride and water. Because oftoxicityconcerns, the FDA has -48-prohibited the use ofmethylene chloride in hairsprays. This ban became effectiveAugust 28, 1989. Plasticizers are added tomodify 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 directlyto 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. Atest used by manufacturers to determine the abilityof a hairspray formulation to "hold" a curl is determined by a curl retention test. This test evaluates the abilityof 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 themandrels 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 amixing process while adding the various contents. Health and SafetyConcerns: The solvents, propellants and other ingredients contained in hair spray are skin and eye irritants. Inhalation of hairsprayparticles are of concern. Aparticle**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 hairsprayhave developed respiratory ailments. It is recommended to use hairsprayproducts in well ventilated areas. -49-

### ReconmendedVOC Standard: The standard being recommended for this category is 80 percent VOC content byweight for aerosols and pumps. Based on ARB product surveys and industrycontacts, an 80 percent VOC content by weight is commercially and technologicallyfeasib1 

### e. There are at 1 

### east 666hairsprayformulations currentlyavailable on themarket (pump 

### &aerosol) that have VOC contents below the recommended standard, but these represent·a small percent ofthe hairspraymarket. 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, afuture effective standard of 55% VOC is being proposed for January 1, 1998. According to theARB VOC survey, there are at least 30 hairsprayformulations that are currently availablethat can meet this future standard. This future effective standard will result in an additional 12 T/D emissions reduction by 1998. Asummary of the proposed standard and the complying prodocts is presented in Table 19 below.

TABLE 19 HairsprayStandards 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 theARB staff indicate that compliance with the recommended standard is feasible within thetime frame proposed in the regulation. The 80% VOC content has been suggested by industry as afeasible 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 hairspryproduct thatwould allowfor an inMovative product exemption. The May, 1990 issue ofAerosol Age, has aerosol hair sprayformulations that have water content levels ranging from 30 to 68 percent. Increasing the water content in theformulation and using DME (Dimethyl ether) as a propellantmay be one method of complying with the standard. The major advantage of using DME is its high degree ofwater solvency. This permits the formation of aqueous single phase solutions, which are difficult to achieve with other propellent systems. In containers constructed oftinplated steel, a corrosion inhibitor and removal ofthe air from the aerosols headspace may be required in aerosols that have ahigh 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 hairsprayproducts. Increasing transfer efficiencythrough 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. Stylingwill be done using liquid styling products, as opposed to blow dryers. Consumers are starting to use amix of products and they prefer the softer not the stiff or crisp look. There will likelybe more styling gels and fewer finishing sprays. One industry representative feels themove will be toward hydroalcoholic systems first, with lower and lower levels of alcohol, eventuallygetting, 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 theARB 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 currentlyon the market that can comply with the 55% standard. One product recently introduced to the Californiamarket has a 

### VOC content below 40 percent. This product utilizes awater based resin and dimethyl ether propellant. Also, in theMay and August 1990 issues ofAerosol Age, an industrytrade journal, several hairsprayformulations 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 estimatefor emissions from aerosol hair mousse is 0.6 tons per day. Product Content Formulation: The salesweighted 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 apropane/isobutahemixture at a·level of 5-15 percent. The proportions of the blend must be**shift~d** 

### in favor of themore volatile propane, in order to obtain the lighter,**l~Ss** 

### dense foam.· The emulsifier isone of the most critical materials in themousse. An emulsifermust**i~sure** 

### a**g~od** 

### dispersion of propellant in the concentrate and good foam formation with the valve actuation. Itmust**provid~** 

### initial

.. stabilityupon application ofthe foam to the**p~lm** 

### ofthe hand, and collapse when worked intothe hair. The incorporation of aconditioner, such as Solulan 16 or Glucams imparts desirable properties to the hair. These ethoxylates contributeto 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 themousse 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. Ahairmousse is applied by first discharging the foam into the palm of the hand an amount indicated by the directions. The stifffoam retains its:. shape, making measurement easy and fairly precise. The foam is then spread evenly through the towel dried, shampooed hair before combing and stylingby any conventional technique (rollers, blow-waving, finger drying, etc.). One ofthemain 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 arepeat application. Manufacturing Process: Manufacturing processes vary, but usually involve amixing process while adding the various ingredients prior to filling the**~erosol** 

### container.
' ' ' 

### Health and SafetyConcerns: The solvents and propellants contained in hair mousses are skin and eye irritants. Since hairmousse 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 byweight is feasible. There are 66 products currentlyavailable on themarket thatmeet 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 theARB 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 afixative 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 StylingGel 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. Abasic 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 afilm forming resin which is soluble in the gel solvent (usuallywater 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 exclusivelythickened by carbomer resins (gelling agent). Carbomer 940 is generallypreferred for its rheology and crystal claritywhich 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 stylinggel are oils which are insoluble in water. Ifthese oils are not .solubilized in the water, the oil droplets would separatefrom the continuous gel phase and this would cause the gel to lose clarity. The fragrances may be solubilized by asuitable**noni6ni~** 

### surfactant. The amount of surfactantrequired 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 viscosityupon storage in day light. To prevent the loss of viscosity, an ultraviolet screen is added to the formulation. Trace amounts oftransitionmetal ions, particularly iron, also causes areduction in viscosity. Thechelating agent is added to stabilizethe product from viscosity loss. Product Use: Hair styling gels are for personal use, although theyare 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 amixing process while adding the various contents. Re.conrnended VOC Standard: The standard being recommended for this category is 6percent VOC 

### content by weight for all forms. Based on ARB surveys and industrycontacts, the recommended standard i.s feasi b1 

### ewithin the timeframe proposed in the regulation. The proposed standard of 6 percent would eliminate current pump forms, but industrycontacts have suggested that these forms are reallyhairsprayproducts that are labeled as gels for marketing purposes. The pump forms aremodified 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 currentlyon themarket thatmeet or exceed the recommended standard. The estimated emission reductions for this categorywith 6 percent VOC 

### content byweight is 0.28 tons per day

...Asummary ofthe proposed standard and the complying products is presented in Table 21 below. TABLE 21 Hair StylingGel 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 theARB 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 RodenticideAct (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 varietyof forms: aerosol sprays, pump sprays, liquids, creams, lotions, gels, sticks, towlettes and foams. Of these, the Californiamarket 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 InsectRepellents 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 themajority of current insect repellents, themain active ingredient is N,N-diethyl-m-toluamide. In at least one product, themain 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 recentlypulled 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 butylated

..hydroxyl to1 

### uene. For aerosol spray**rep~llents,** 

### there**~re** 

### two types of**for~ulations:** 

### solvent-based and water-based.**Solvent-ba~ed** 

### formulations containmostly 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/propanemixture. 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 acategory, 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** 

### entirelyof 100% DEET. These concentrated · products usuallyaremarketed for people who spend a great deal oftime outdoors**(e.g~** 

### hunters, lumberjacks). Sticks·, gels, towlettes and foams are relativelyrare in California. These products do not have a significant share ofthemarket and are not expected to increase their share in Californiadramaticallywithin the near future. Product Use: Insect repellents are for personal use. They contribute to the comfort and safetyof 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 directlyto the skin and clothes or are applied to the hands and spread onto skin and clothing. Manufacturing Process: Staff has no specific data on themanufacturing process for this product category; however, staffexpects the**ma~ufacturing** 

### process tobe similar to those used for manufacturing other aerosol,**pump~'** 

### cream, solid and towlette productS.·

- Health and SafetyConcerns: The-major safetyconcern with an aeros'ol insect repellent is the flammability ofthe product. Flammability concerns that applyto other aerosol products also applyto aerosol inset£ repellents. However, there have been only rare cases where aerosol repellents caused damage when applied near aflame (e.g., campfire). Staff_ expects thewater-based aerosol products to have reduced flammability potential because of the water content. Insect repellents based on DEET have been used sucessfu1lyfor many years. Only recentlyhave there been cases where over-application ofthe product has resulted in adverse reactions, especially in children. Because of**this~** 

### industryrepresentatives have expressed the desireto 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 repellentmarketers 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 aVOC 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 currentlymeet 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 InsectRepellents 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 specialtyproduct 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 2tons 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 themarket share and percent of total emissions for the product forms.

-57-

### Product Form Aerosols Pumps Liquids Solid Sticks TABLE 24 

### LaundryPrewash 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 of4%. Onlyone manufacturer submitted data for pumps. The sales weighted average is 6%. For solid sticks, the VOC content ranged from 5% to36% 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, fattyacid ethanolamides, fatty acid esters), as the name implies, contain neither positivelycharged or negativelycharged functional groups. Nonionic surfactants**ha~e** 

### favorable detergencypropertieswhich are derived largely from having lowmicelle concentration, very good detergency performance, and soil antideposition characteristicswith syntheticfibers. They are particularlyeffective 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,

. perch1 

### oroethylene, 1,1,1-trich1 

### oroethane) rnaybe used as so1 

### vents and aid ·· the surfactant in penetratingthe surface ofthe soil. Water is also sometimes used as a solvent. Fluorescent whitening agents (FWA), also known as optical brighteners, are organic compounds that convert aportion ofthe invisible ultraviolet radiation in sunlight into longer wavelength blue light in the visible region. This improves the brightness as well as the shade ofwhite articles. Nearly all white fabrics now have been treatedwith FWAs during manufacture, therefore, the function of FWAs in laundryprewashes 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 resistantto removal by simple detergents. -58-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 afresh, pleasant lingering scent on the skin or laundry itself. To help make the productmore visuallypleasing 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 directlyonto 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 awater 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 thoroughlymixed. 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 SafetyConcerns: turrent formulations of aerosols contain hydrocarbon prope11ants that are vo1 atile and f1 ammab1 e and needto 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 varywidely 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 ofthe skin. Consequently, the barrier function of the lipids is impaired, leading to increased permeability and loss ofmoisture 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 aremuch 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 contactwith a
-59-

### concentrated surfactant solution and this contact is not followed by immediate and intensiveflushing with water. High doses of surfactants iri the gastrointestinal tract can lead to vomiting and diarrhea. If a surfactant reaches the circulatorysystem, it can cause damage even in very low concentrations because of interactions with erythrocyte cell membranes, ultimatelyresulting in hemolysis ofthe cells.**Enzym~s** 

### are complex nitrogenous substances of proteinaceous type which catalyze various reactions.of abiochemical nature. As with all proteins, human allergenic reactions are possible. In the past, some detergent factoryworkers have had asthmatic reactions to enzymatic dust. Some ofthe problems have been remedied by themanufacture of encapsulated enzyme types rather than powders. Some consumers are allergicto enzymes and may encounter problems from the use ofezymatic powders in the home. Reconmended VOC Standard: The recommended VOC standard for aerosols and solids is 22% 

### by weight, beginning in 1/1/94. 

### Staffexpects the**propos~d** 

### limit to be achievable and that a greater portion ofthe 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 salesweighted 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 

### So1

### ids 22 3 41 0.026 

### A

11 

### Other

Forms 5 9 36 0.19 

### Compliance with theStandard: It is expected that compliance with the regulationwill be acheived by reformulation with water and other exempt VOCs. Staff contactwith industryrepresentatives indicate that reformulation is possiblewithin the timeframe established.

0. NAIL POLISH REMOVER Product Description: Nail Polish Remover means aproduct primarilyused to remove nail polish and coatings from fingernails or toenails.

-60-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 aremanufactured 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 awider 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 generallypopular. 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 varietyof 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% ofwater 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 claimto remove the nail polishwithout smearing the nails or the adjoining skin. These products may consist of amixture ofwater 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. -61-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 surfacefor 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 probablythemost convenient to use because each towelette is individuallywrapped 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 SafetyConcerns: 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 ahighlyflammable liquid that can dissolve fats, oils, resins, rubbers, plastics, and the like. Although acetone is not a primary skin irritant, itmay result in dermatitis in persons who use it frequently. The result is the removal of the normal fatty sebaceous secretion ofthe skin. Removal of this secretion faster ·than it can be formed results in the skin becoming dry and cracked thus

affordingthe 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 1/1/94with afuture effective limit of 75% beginning in 1/1/96. At least 11 products or 13% of themarket listed in the survey can meet the 85% limit. With the sales-weighted average at 91%, staff expects the proposed limitto 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 acetatewith aVOC 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 contactwith industryrepresentatives 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 completelymiscible with water. ASOX solution in water may be used as a nail polish remover. The compound is stated to be non-irritating to the skin. According to industryrepresentatives, there is at least one product currentlyon themarket 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 includemicrowave ovens, which use adifferent cleaning formulation, similar to a glass cleaner. Product Forms: Product forms are aerosol, liquid, and pump. Total emissions from this product category are 1ton 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. ACSMA spokesperson indicated that the low VOC contents for oven cleaners listed in the Heiden datamay be due to those products being microwave cleaners, which are light-duty surface cleaners, more similar in natureto 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 1T/D)

Percentof 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 categoryranges from 10 to 17%. The typical combined VOC content for fragrance and colorant is less than 0.1%.

-63-

### Oven cleaners consist of both caustic and non-causticformulatiohs. Caustic formulations typicallycontain41 to 20% 

### caustic (potassium or sodium hydroxide) as an alkaline agent, with surfactants and solvents suspended in an emulsion. The solvent solubilizesgreasedeposits and allows the causticto penetrate and saponifythe grease to a soap form. Baked-on food deposits are alsodissolved. Caustic formulations can be used without applying any oven heat, and left on overnight, or theycan 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 to475 degrees for 30 minutes. These formulations are lower in VOC content than the causticones. The aerosol form ranges from 5- 8% in total VOC content, with more propellant than the causticformulations, and no grease-cutting solvents. The caustic aerosol formulations range from 7-11% in total VOC content. Propellants are typicallybutane or propane. Oven cleaners aremade 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.--pizzaovens) sectors. The market shares for the institutional and commercial sectors are not specificallyknown, but they are both smaller than the household sector. The product is typicallyapplied in aerosol form; liquid forms are applied by either pump sprayor as apaste. Thickening agents are added to the liquid forms to promote adhesion ofthe cleaner to vertical oven surfaces. Another non-aerosol form is a pad of · synthetic abrasive, which contains areservoir 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 easierto sprayhard-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 ismade using a "wet blending" process, with no heat used. The product is blended in largemixing tanks, adding the ingredients in specificorder, lettingthem dissolve, and then mixing them together. No production changes areforeseen due to the effect ofthe regulation. Health and SafetyConcerns: Gloves and possiblygoggles should be used with the causticformulations. 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 standardwas selected based on the VOC surveydata submitted by industry, and was set to allow complying products in both the aertisol, liquid, and pump forms, yet still achieve.emission reductions. Industryh'd requested a standard of9% for aerosol/pump oven cleaners in order that the -64-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 allowthe 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 theStandard: Compliance can possibly be achieved by lowering the solvent content and raising the surfactant and caustic contents. Formulation datafound in product formularies include several oven cleaners, including those for heavy duty use, that contain no solvents (ie.--0% VOC). The range of causticfor theseformulations, 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 afoam lather intended to be used with a blade, cartridge razor or otherwet 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 themarket. 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 finelytextured foams that dry out quickly. Nonionic surface active agents -65-

### are used toform emulsions and increase thewetting power ofthe product. Polyoxyethylene sorbitan esters, alkyl phenoxypolyethoxy ethanols and polyoxyyethyleneethers are some examples ofthese agents. Molecular complexes areformed with surface active agents and fatty agents or fatty alcohols. The mostconmon 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 stabilityofthe foam. Glycerin is probablythemost popular ofthe polyhydric alcohol humectants. Synthetic and natural.gums are employed to stabilizethe viscosityof the liquid, cream and gel formulations. Gums contribute both lubricityand 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 theformulation. Microbiological screening ofthe effectiveness ofthe bactericide br 

### bacteriostat used ismandatory. Methyl, ethyl, butyl and propyl parahydroxybenzoates are used in many formulations. Propellants are used to expel the product from the container and to create afoam 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, safetyand speed of a shave. Itwets the hair and maintains it in this statethroughout the shave. It also lubricates the skin so therazor and blade glide smoothly over the surface being shaved. The product is appliedby dispensing a small amount ofthe product into the palmof the hand and then distributingthefoam on the skin surface to be shaved. Manufacturing Process: Manufacturing processes vary, but**~sually** 

### ·0 

### involve amixing 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, a5% VOC content byweight is being proposed. There are five products currentlyavailable on themarket thatmeet this standard. The estimated emission reductions for this category is 0.08 tons per day. ComplianceWith 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. Increasingthewater content in the formulation may be one method of complying. Another method may be reducing or substitutingthe propellants currentlybeing used.

-66-

### VII. IMPACTS
A. ECONOMIC IMPACTS

1. Economic Impact on Industry Manufacturers of noncomplying consumer products have several options available to them tomeet 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 qualifyfor the innovative products exemption, and withdrawal from the California market. Reformulation is the most likelymeans ofmeeting 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 ofthe regulation. In conducting this analysis, staff assumed that the primary impact of the regulation would be on consumer product manufacturers. ARB staffbelieve 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. Itwas further assumed thatmanufacturers would comply with the regulation by reformulating existing products tomeet the VOC standards. The analysis was a before tax study although theremay be tax advantages that could significantlyreduce 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 estimateof the average annual cost to reformulate atypical product formulation, the total annual cost to the consumer products industry, and the cost effectiveness of the regulation.

-67-

### Assumptions To estimatethe cost of reformulation, anumber 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 apump spray product form). (2) No major retooling ofmanufacturing equipment will be necessary. (3) No significant change in marketing costs will be required. (4) No increase in rawmaterials costwill occur. (5) Reformulated products will be marketed nationally.

The first assumption was that reformulationwill not require a change in the product form. While some companies may choose to change product forms, the regulation is generallynot designed to require a change in product form. Since the product form is not expected to change, it is further assumed thatmajor 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 theformulation. Industry also pointed out that training ofemployees would generallybe required ifnew equipment is purchased. These costs are very difficultto estimate since it is not**know~** 

### what reformulations will resultfrom the regulation or whether equipment purchases will be necessary. Some ofthe cost estimates provided to staff by industry considered these elements while most did not. It is also assumed thatmarketing costs will remain unchanged. Some industry contacts have noted that consumer acceptance studieswill be desired for reformulated products. Ithas also been pointed out that modifications totrade show displays will have to be made. These costswere not considered since staffcannot quantifythese. Also, staffbelieves that' market studies are often ongoing and in many cases would be performed even in the absence ofthe regulation. Staff assumed that therewill be no increase in the cost of raw materials. In general, solvents will be replaced by water, which represents acost savings. Increasingthewater contentwill 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, stafffound that themajority of consumer product companies market their products nationally. Most of thesecompanies plan tomarket products reformulated for California in the restof 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 categorywas 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 tomeet the requirements of the proposed regulation include research and development, efficacytesting, stabilitytesting, safetytesting, and modifications to labels. An interest rate of 10% was assumed. Total cost to industry The total annual cost to the consumer products industryto 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 theARB 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 ofreduced 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. Itwas assumed that the reformulated products will be marketed nationally, resulting in emission reduction benefits throughout the nation. In some cases, the regulationmay result in a net savings to industry. For instance, it is estimated that reformulation of automotive windshield washer fluid tothe 10% VOC limit could result in an annual cost savings to industryof $800,000. This estimate is based on the replacement ofmethanol (at $0.41/gallon) with water tomeet the 10% standard. This represents a cost savings of 5cents 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 thewide varietyof products covered under the regulation. The cost effectiveness ratios, summarized in Table 28, compare favorablywith other VOC regulations considered by theARB. -69-

### TABLE 28 Cost-EffectivenessComparison ofthePr.oposed· Consumer Product Regulationwith Other RecentlyAdopted SCM's,

..

### and Regulations Cost-Effectiveness Measure.

.$/JbVOC Reduced Consumer Products (1990) -0.05to 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 0i1

### Production Operations

ARB staffbelieves thatthe 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 recentlyapproved regulations that cover such categories as antiperspirants and deodorants, architectural coatings, and loading, ballasting and lighteringoperations on crude oil and gasoline cargo tankers. In**som~** 

### cases theremay even be cost savings to industrydue to replacement of

.. solvents with water. For most categories listed in the proposed regulation, there areproducts currently in themarket which can meet the proposed standards for each product form. Reformulation costs and cost effectiveness ratios may alJo be lower than predicteddue to the transfer of research and development costs to other products. Many companies have many simi1 

### ar products in their product 1i

### nes
.. In these cases, research and development costs could be applied to several products, reducing the cost per product. ;;· 2. Imoact on Consumers Alarge portion ofthe costs incurred by industrymay be passed on to the consumer. However the extent towhich this will occur is difficult to predict. It is also possiblethat the cost ofthe 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 easilybe predicted. However, staffhas developed some estimates based on the the following information: (1) the annual cost figures per product formulation given in Appendix E; (2) information on thetota.l number of aeroso1

### 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 otherfactors such as expected difficultyof reformulation. Only aerosol**prod~cts** 

### were**~xamined** 

### Sincethey areexpected -70-to experience the greatest impact. This analysis showed the average increase in cost for atypical 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 ofEmissions 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

-71- Percent Reductjon

14 30 40 27 67

26 86

### TABLE 29 

### Can't Sunmary ofEmissions and Emission Reductions fromtheProposed Standards Proposed Standard Emission Product Percent Emissions Reductions Percent Category VOC byWt. lbs/Day ]bs/Day Reductjon Automotive Windshield Washer Fluids Type AAreas 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 

### FurnitureMaintenance 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 StylingGel All Forms 6 820 550 67

-72-TABLE 29 Can't Summary of Emissions and Emission Reductions from theProposed 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 Reductjon

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 effectiveVOC limits take effect.

The proposed regulation prohibits any new uses of compounds which have an ozone depletion potential (ODP) greater than 0.00. Industryhas proposed reformulating their products with HCFCs and 1,1,1-trichloroethaneto 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, industrymay 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
-73-

### is used. The first system uses compressed carbon dioxide which is abyproduct ofmany petroleum and chemical refining processes. Ifthis byproduct is not condensed .and subsequentlyused in consumer products, it would normally be emitted tothe atmosphere. Using by-product carbon dioxide from otherman-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 technicallywould increase the load of greenhouse gases to the atmosphere. However, this propellent system has very limited and specialized uses and generallydoes not lend itselftowidespread applications. Moreover, replacing solvents with carbon dioxide would reduce the amount ofVOCs in the environment which reactwith oxides of nitrogen to. form ozone. Since ozone itself is a greenhouse gas, areduction of ozone would at least partiallynegate any unexpected increase of greenhouse gases from the use of carbon**~ioxide** 

### in this propellent system. To assess other potential envjro,nmental impacts resultingfrom the regulation, staffmade the following assumptions:

o Product efficacybefore and afterthe regulation is implemented will remain approximatelythe same

o Most reformulation will inVolve the use ofwater-borne and more concentrated products

o Industrywill manufacture agreater percentage of products in concentrated forms Adecrease in the amount ofVOCs in "down thedrain" consumer products could reduce VOC emissions to the atmosphere. Industryrepresentatives have argued thatthe 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 ofthe 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 likelydecrease the amount ofVOCs which normally volatilizeto the atmosphere before treatment at aPOTW. ·**Reformulati~n** 

### using water-borne technologymay also impact landfill space. To prevent corrosion, water-borne products are typicallypackaged in lirted metal containerswhich can make recycling difficult. New innovative deliveryforms 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 accuratelypredicted. However, sincethere are no programs which currentlyrecycle aerosol containers, lined or unlined, staff anticipates no major changes to landfill space as aresult of products using water-borne tethnologyor new systems. · · An increase in concentrated products may reduce the amount of lahdfill space needed. Since the concentratedproducts would be sold in smaller containers, the amount of necessary packaging would decrease, reducing the -74-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 ofthe regulation.


### C. CONSUMER IMPACTS One important consideration regarding the proposed statewide regulation is the impact on the consumer. Not onlymay 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 sincefor each product categorythere is a product currently available in themarket 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 1to 23 cents per unit.

-75-VIII. ISSUES

A. COLLECTION OF VOC SURVEY DATA The ARB consumer products surveywas 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 surveywas 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 productmanufacturers who aremembers of the Chemical Specialties Manufacturers Association (CSMA) elected to submit their surveydata 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 specialtyconsumer product manufacturers. To maintain confidentiality, the information submitted by these entities toARB 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 themanufacturers ofthe surveyrequirements, 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 datafrom the survey analysis because the datawere incomplete or because the datawere inconsistentwith other known information. In addition, since company names -76-

### were kept confidential itwas difficult forARB staffto validatethe 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 entryfor the propellentweight percentage (PVOC) was greater than the entryfor VOC, then the VOC entrywas generallymodified to be at least the same value as the PVOC entry. Exceptions to this would be cases where staffhad high confidencethat theVOC value was greater than even themodified value. In these cases, the VOC entrywas remodified on a case-by-case basis depending on the particular product category. In spite ofthe uncertainties in the survey, the remaining data proved worthwhile and revealing. For many ofthe products in the proposed regulation, the sales-weighted average VOC content proved to be less than whatARB staffhad originallyestimated. This resulted in staff's lowering ofthe 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 oftenmade by independent manufacturers, generallydo not represent as large amarket share as that represented bythemajormanufacturers. Nevertheless, the number of complying products within these product categories indicates that the technologytomake complying products is reasonably available.


### B. VOC CONTENTVERSUS VOC EMISSIONS In the consumer products VOC survey, ARB staffrequested information on the VOC content of the products and not the actual VOC emissions resulting from the use ofthose products. Some industryrepresentatives who attended the first threeworkshops questioned whether VOC content will yield accurate estimates of actual VOC emissions. ARB staff's analysis ofthe numerous forms and application techniques associated with the various product categories indicates that actual VOC emissions are very difficult, if not impossible, to accuratelydetermine. For example, in order to accurately report VOC emissions from consumer products, amanufacturer or distributor would need to know the following: 1) thetotal amount of VOC in the product (VOC content), 2) thetotal annual usage rate (annual sales) ofthe product, and 3) the percentage ofthe total VOC content that volatilizes into the atmosphere (indicated by vapor pressure). For the purposes ofthis discussion, the terms "volatileorganic compounds (VOC)" and "reactiveorganic compounds (ROC)" are essential.ly equivalent and shall be used interchangeably. AVOC is defined as any compound containing at least one atom of carbon, exceptmethane, 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), -77-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 ProtectionAgency'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 amore 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 thatmany of the compounds that have low vapor pressure or have high polar attraction for water do not volatilize immediatelywhen applied. However, these compounds may become volatile under certain conditions. For instance, as a result of oversprayor 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 possiblemechanisms: (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, theARB staff has taken the position that almost all volatile organic compounds found in consumer products can be assumed to eventuallyvolatilize into the atmosphere. However, implementing this view in the real world of consumer products quicklybecomes impractical when all the various VOCs present in consumer products are considered for regulation. To streamline the regulatorydevelopment process and tominimize the impacts on industry, ARB staff has limited the applicabilityof the regulation to those VOCs which are thought to contribute the largest portion ofthe ambient VOC loading. This streamliningwas accomplished by qualifying aVOC with the provision that it either has (a) avapor 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 ofknown organic compounds which are found in consumer products. Staff believes that these provisions will enable the regulation to cover most, if not all, of themajor 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 necessityof identifying · individual active ingredients. During the regulatorydevelopment process, ARB staff indicated they would consider on aproduct-by-product basis any incontrovertible documentation that shows negligible volatilizationfor VOCs found in consumer products. Such documentation provided to theARB 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 staffestimated 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 abilityofmanufacturers 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 effectivedates, which industry says will require them to reformulatemore than once, takingmore time and money. There are five basic steps involved in reformulating aproduct: (1) Product Formulation Development, (2) Packaging Development (Can/Valve, Label etc.), (3) Safetyand EfficacyTesting, (4) Consumer Marketing Tests, and (5) Production Product formulation development includes modifying an existing formulation tomeet the VOC standard. During this stage of development, manufacturers may.conduct numerous laboratorytests to evaluate and adjust the physical attributes ofthe new formulation such as the odor, viscosity and color prior to developing the final formula specifications. Industry estimates for formulation development range from 6to 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·ofthe containerwith the new formulation, stabilitytestingto determine that the product will be stable and not undergo chemical reactionwithin the container, and modifications to can and valve design for aerosol packages. Package development may take anywhere from 2to 18 months depending on the changes made to the formulation and the choice of package. -79-Safety and efficacytesting generallytake 6to 18 months, depending on the product and how extensive the safetytestingmust be. Safetytesting consists of toxicitytests of various types, used to determine the subacute, sub-chronic exposure effects of the product. Sub-acute tests generallytake 3 to 6months; sub-chronic test take 3 to 12 months; and chronic tests take from 6months to 24 months. Efficacytesting 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 efficacytesting 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 predominantlythosewhich 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 registrationmust 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 previouslyregistered 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 FIFRAmust be registered, even if the formulation is identical to another product that is alreadyregistered. The CDFA registration takes approximately 3to 5months. Consumer marketing tests may take from 3to 6months to complete. Time for production startupwill also vary from product to product, with a range of 9to 30 months identified given by industry as typical. Assuming the development process is sequential, based on thetime frames indicated by industry, thetotal time for reformualtion to market ranges from 3to 10 years. However, staff beleives that this is an overestimate. In the theAerosol Handbook, 2nd Edition, an estimate of 1to4years 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 takefrom 1to 2years 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 ofthe laboratorywork involved in formulation development can be eliminated or reduced through the use of library resources, in-house files of previous laboratoryexperience, 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 compatibilitybehaviors arewell 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 studydifferent formulation variables, allowing two ormore factors to be investigated concurrently. This avoids the "one-factor-at-a-time" approach, which does not allowthe 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 preliminaryor pre-market testing of the proposed product's safety and efficacy at this time as well. The various safety tests can be done concurrentlywith each other, as well as concurrentlywith efficacytesting. Consumer marketing tests are generallydone after safety and effitacy testing. However, these can be done concurrentlywith 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, itmust 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.categoryfor every product form. It '·"· should be possible for industryto 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. Industryhas also indicated that they typicallyexperiment 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 essentiallyprovides threeyears to reformulate until the first standards become effective in 1993, four years until the 1994 standards, and 1additional year after the effective date for thoseproducts 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 aformulation 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 inan 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 agitativewash environment (e.g. washing machines), the potential for ethanol release into the.atmosphere is great. Aware of this possibilityand the possibilitythat

-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 thewash cycle, and (2) what amount of ethanol is emitted during transport to publicly-owned treatment works (POTWs). The first studywas 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 studywas conducted by Engineering-Science of Berkeley, CA. The studymakes 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 studymakes 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) surfacewaters. (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 themethods, data, and results given in both studies. Additionally, staffwill review other studies and literature relevant to ethanol release. Due to the time needed to**ev~luate** both studies, reviewother 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-PURPOSEAEROSOLAIR 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.

-82-1. 

### What are dual-purpose aerosol air freshener/disinfectants? Dua1-purpose. aeroso1airfresheners/disinfectants (henceforth "aeroso1 air freshener/disinfectants" or**"dual~purpose** 

### products"), as defined in the proposed Consumer Products regulation, are pressurized spray disinfectants which are also claimed tofreshen or deodorize air. Since disinfectants.are designed tokill microbes, they are required to be**~egistered** 

### as pesticides with EPA pursuant to the Federal Insecticide, Fungicide, RodenticideAct (FIFRA). The proposed VOC standard does not apply to liquid or pump disinfectants sincethese products have a sufficiently lowVOC level afterthe recommended d i 1 ution to.meet tne proposed standard without requiringreformu1 at**ion~** 

### However, the discussion will include liquid·disinfectantswhich make·· deodorizing claims since these products are viewed byARB staff as viable alternatives to aerosol airfreshener/ disinfectants. 2. Who will be affected by the proposed VOC standard for dual-purpose aerosol air freshener/disinfectants? The regulationwill 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 spraydisinfectants 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 interestingto note thatthe aerosol airfreshener/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 inactivatethe wider variety and greater concentrations ofmicrobes encountered by these users.· This apparent anomaly will be further discussed in subsequent sections ofthis report. · Previous studies indicatethat one brand ofdual-purpose aerosol air freshener/disinfectants accounts for**ove~** 

### 90% ofthe consumer**retail-mark~t** 

### and, consequently, over 90% oftheemissions from this category

. . (Soap/Cosmetics/Chemical Specialties, December 1988). 

### In contrastwith the consumer market, the commercial/institutional market for disinfectants is much more fragmented, with the largestmarket share for any one company probably not exceeding 20%. 3. Why are we proposj

### ng to regu1 ate the VOC contentfrom dua1**urpcise** 

### · ajrfreshener/disinfectants? The CaliforniaClean Air Act of 1988 

### authorizes theARB to regulatethe VOC emissions from consumer products if it is necessary and commercially and technologicallyfeasible. This paper will discuss the feasibilityof regulating dual-purpose aerosol airfreshener/disinfectants in subsequent -83-sections. As for the necessityof regulating this product category, ARB staff believes that the VOC emissions associated with this product (approximately4.3 tons/day), along with the availabilityof viable alternatives, justifythe 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 eventuallyreleased 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 thatARB 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 efficacydata 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 significantlymisuse these products as air fresheners. Television commercials and other advertisements involving these disinfectants clearly place aheavy 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 directlywith other air fresheners,

ARB staff believes that the standards for all similar air fresheners should be roughly equivalent. Staff also believes thatmany consumers spray these products into the air in themistaken belief that they "disinfect" or "purify" the air. However, these products are not registeredwith 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 spraythe 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 -84-

### 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 ofthe reasons cited previously and the following.discussion, ARB staff has determined that the emissions from this category should be reduced ifthe redUctions are technologically and commercially feasible. 4. What are.disjnfectants and what types of d j s jnfectants are available? The following, in order of ascending potency, are the three types of classifications the EPA assigns tomicrobially-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 prototypemicrobes used in classifying the different levels of disinfection. Sterilizers, on the other hand, must inactivateeverymicroorganism on the surface, ihcluding high numbers of bacterial spores. Bacterial spores are among the most difficult of microorganisms to inactivateor kill. Disinfectants, therefore, fall _,,, between these two

. product extremes in.terms of themicrobes which theyk iTl

. and the rate ofkill provided by the product. The efficacyof disinfectants is determined by the use of a set of rigidly controlled in vitrotests that are described in the Federal Register, themanual oftheAssociation of Official Analytical Chemists (AOAC) and various EPA guidelines. Testing is conducted against various prototypemicroorganisms 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 organicmatter (5% serum) and thatthis activity is not diminished in the presence of hard water.

5. Agajnst what types ofmjcrobes 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 ofthis group tokill 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. Astrain of**~-** 

### choleraesyjs is accepted as the prototype enteric bacillus, and activityagainst it is generallyassumed by the infection control community to predicteffectiveness againstmembers ofthe genera Escherjchja, Proteus, Salmonella, Shigella, Serratia, Enterobacter, Citrobacter, Arizona, Providencja; Morganella and othermembers ofthe family Enterobacteriaceae, i.e., all gram-negative rods that ferment glucose, do not produce spores, and are negative in the cytochrome oxidase test.

-85-Astrain 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 varietyof 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 themarketability 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. Itmust 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 contactwith 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 themandated AOAC tests against**~-** aureus,**~­** choleraesyjs,

### f. aeruginosa,

### M. tuberculosis and

### I. mentagrophytes, it is tacitly accepted as an effectivedisinfectant in the hospital environment for all pathogenicmicroorganisms except protozoa and viruses. Therefore, themain differences in disinfectants which have claims against these five prototype organisms are the types of virucidal activitywhich the products claim. EPA registration requirements allow specific virucidal claims only if the activitydata is provided for that specific viral strain. For instance, the label of an approved disinfectant can claim virucidal action against a specificvirus or an arrayof viruses-influenza, herpes, and vaccinia, for instance- but cannot make broad claims on the basis of predictive tests, as can antibacterial agents. Aproduct with activity against rhinovirus will statethe exact strain for which data have been submitted. In the case ofmyxoviruses, amanufacturer cannot claim activity against themyxovirus influenza 8 if it has submitted data that documents activityonly against myxovirus influenzaA. Conversely, because a product does not make a claim against a particular strain of virus, it does not necessarilymean that the product has no activityfor that virus. In these cases, the economics of documenting the -86-

### assays and test results for activityagainst certain viruses may not be favorable when competing products make these same claims and hold avery significant portion ofthemarket. 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 tojustifythe cost of documenting activityagainst additional microbes because any potential market gains would probably be insignificant. With activityagainst all five prototypemicrobes, hospital disinfectants with tuberculocidal and fungicidal claims differmainly by the activity claimed against different viruses. Some active ingredients in theseproducts**~rovide** 

### broad spectrumvirucidal 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 themechanisms**by~·** 

### which they inactivateviruses. As shown .in Table 30, the ethjnol (70%), glutaraldehyde, halogen (iodophors and hypochlorite) and hydrogen peroxide disinfectants provide the broadest-spectrum activityagainst viruses. Phenolic and quaternary ammonium products (quats) have narrow tomoderate 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 Bvirus (HBV)? Howwould the proposed standard affect the efficacyofthe product in regard to preventing the transmission ofthese and other viruses? Given currentlyavailable data, ARB staffdo not believe that the proposed standard will adversely affect the efficacyof disinfectants against the viruses that causeAIDS and other diseases. Recent public concern bas emphasized the prevention ofthe transmission oftheAIDS virus. The human immunodeficiency virus (HIV) which causes AIDS is among the easiest ofviruses to kill on environmental surfaces. At this time, no case ofAIDS transmission through contactwith environmental surfaces has been documented.. Probably of greater concern to health-care officials is the transmission ofthe hepatitis Bvirus (HBV), which carries a greater probabilityoftransmissionwithin the health-care setting. To address the public and health-careworker concerns about the transmission ofthese two viruses, the U.S Department of Health and Human Services (Centers for Disease Control or CDC) recentlypublished their "Guidelines for Prevention ofTransmission ofHuman Immunodeficiency Virus -· and Hepatitis BVirus to Health-Care and Public-SafetyWorkers" (henceforth "CDC Guidelines"). Among otherthings, these guidelines recommend procedures for cleanup ofenvironmental surfaces in the health-care**settin~~** 

### -87-Table 30 Effect ofVirucidal ContactDisinfectantsAfter 10 Minutes
Agent Spectrum Alcohol 70% Broad**(Ethanol~** Isopropanol)

Formaldehyde Broad Glutaraldehydea

Halogensa !2 Iodophors Hypochlorite

Phenol and derivatives

QuaternaryAmmonium 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-NH2 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, generallyrequire 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 specifyeither 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 specifythat low-level disinfection (i.e., hospital disinfectantwithout atuberculocidal 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 ofthe visiblematerial: that is, use ofeither ahospital disinfectantwith atuberculocidal claim or a solution containing at least 500 ppm free available chlorine (approximately 1/4cup common household bleach per gallon oftap water). Intermediate-level disinfection is also recommended by the CDC for dental settings, where saliva containg blood may be present on theenvironmental 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 thosewith tuberculocidal claims. In addition tbthe 500 ppm chlorine solution noted in Table 31, other products are availablewhich will meet the requirements for intermediate-level disinfectioni To determine thenumber 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 CaliforniaDepartment of Food and Agriculture (CDFA). From these searches, stafffound 85 tuberculocidal hospital disinfectants registered with EPA. In addition, staff also found 101 EPA-registered products that claim activityagainst the HIV virus (AIDS). Note that the products with claims against theAIDS virus do not necessarilyclaimtuberculocidal activity, which indicates the relativeease atwhich the HIV virus is inactivated. Although there is some overlap between the results from these two searches, it can be clearlyshown thatthere are numerous products which can meet the requirements'ofthe Centers for Disease Control for the prevention oftransmission ofthe HIV and HBV viruses.

-89-Sterilization:

High-Level Disinfectant: TABLE 31 ReprocessingMethods for Equipment Used in the Prehospital1Healthcare Setting
Destroys: All forms ofmicrobial 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 tomanufacturers' instructions. Note: liquid chemical "sterilants" should be used onlyon those instruments that are impossible to sterilize or disinfectwith 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 ahealth-care facility for reprocessing reusable invasive instruments. Destroys: All forms ofmicrobial 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 themanufacturer). Use: For reusable instruments or devices that come into contactwith 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 onlywith intact skin, e.g., stethoscopes, blood pressure cuffs, splints, etc., and have been visiblycontaminated with blood or bloody body fluids. Surfaces must be precleaned of visiblematerial 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 visibleblood 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 settingwhere deliveryof 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% byweight 

### VOC is adequate for products to meet hospital disinfection requirements. Staff has determined that alternative non-air freshener products are availablewhich 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 theAIDS and hepatitis B viruses. Because of theway these dual-purpose products are marketed and used, theymay compete directlywith 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. Stafftherefore 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 ofwhich 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 aconvenient manner for the consumer. The difference between these products and a liquid disinfectantwhich has the same disinfectant classification then becomes amatter 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 classificationwith tuberculocidal and fungicidal activity. Staff expects most, if not all, liquid/pump spray disinfectants with this type of activitywill easilycomply with the standard after proper dilution. 9. Ifwe 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 satisfythe 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 CaliforniaAssociation of Hospitals and Health Systems (CAAHS), ARB stafffound that none ofthemore than twenty-four hospitals and health clinics surveyed used aerosol disinfectants. Hospitals surveyed include Kaiser Permanente, SutterMemorial, 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 senstitivepatients, (3) the relative ease with which individually packaged aerosol products are stolen from health-care facilities. Of these, themain reason cited was economic; aerosol sprays cannot compete with bulk liquid disinfectants on a per volume basis. Afrequently overlooked but highly-effective alternativeto consumer- ':. and commercially-formulated disinfectants is common household bleach. When diluted to a 500 ppm solution, itwill kill many, if not all, ofthe microbes againstwhich currentlyavailable disinfectants claim activity. As. previously stated, there.are also numerous liquid disinfectants registered with EPA thatwill 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 solelyas ahard surface aerosol disinfectant. Stafftherefore believes that therewill still be efficacious disinfectants availableto the consumer. 10. If 

### liQuid djsjnfectants are ysed in place of spray djsjnfectantsi wjll there be safetyproblems wjth children possjble swallowing the ljgyjd? Industryrepresentatives contend that, as alternatives to aerosol products, liquid disinfectants present a safetyconcern from the potential

. accidental swallowing by children. Although this is 

### a legitimate**concern~** r 

### staffbelieves that properly-designed packaging will eliminate or significantlyreduce this concern. ARB staffhas identified fromthe NPIRS search at least 8 liquid/pump spraydisinfectants which employ chi·ldresistant packaging. Moreover, staffbelieves that the potential for· accidental swallowing cannot be completelyeliminated from eitherthe spray or liquid packaging. Therefore, although the potential for accidental swallowing cannot be completelyeliminated, ARB staffbelieves that packaging technology is currentlyavailablethatwill significantly**reduc~** 

### or eliminate this concern. 11. Will limitingtheVOC content jn dyal-pyrpose aerosol ajr freshener/disinfectants reduce thejr efficacyagajnst germ-causing .QSiQr:.s.? 

### As statedpreviously, 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 aroom achieves only air freshening benefits, which could be similarlyachieved with numerous**16W~voc** 

### air fresheners. In addition, these products are often advertised as being capable of "clearing" the air ofnoxious cigarette smoke and similar fumes. Cigarette smoke, which is composed ofminute 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 dirtyair is cleaner after arain storm. In the case of cigarette smoke removal in air, the size ofthe liquid droplet is the controllingfactor; Thus, any liquid, including plainwater, can "clear" a cigarette**s~oke** 

### filled room if sprayed atthe proper droplet size. -93-The germs that cause odors on hard surfaces in the household, such as E. coli, are relativelyeasy to kill when compared to the prototype organisms used in EPA disinfectant classifications. Staff believes that at 60% VOC, spraydisinfectants 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 spraydisinfectants. Is a 500 ppm bleach solution corrosive in the household environment? Because of its oxidizing properties, a 500 ppm bleach solution is considered by staffto be an inexpensive but highlyeffective disinfectant for household and institutional uses. Ableach solution at this concentration (approximately 1/4 cup household bleach in a gallon ofwater) is recommended by the U.S. Department of Health and Human Services for use in health-care and dental settings. A500 ppm bleach solution is generally not considered to be corrosive in the household environment. For comparison, staff estimates that a typical load of laundrywith 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 adverselyaffect hard surfaces found in the home. 13. How can an ajr fresbener/djsjnfectant manufacturer comply wjth thjs standard? There are essentiallyfour ways for amanufacturer to comply with the 60% standard: (1) sell, advertise and market the product Qfily as a hard surface disinfectant and not as an airfreshener, 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, 2and 3 are believed to be themost costeffective and easiest options to implement. Note that option 1requires only a labeling and marketing change.

-94-REFERENCES Aerosol Age, March 1981. Alliance ofAmerican Insurers, Handbook of Organic Industrial Solvents, Fifth Edition, Technical Guide No. 6, 1980. Alexander, Philip, "Aerosol Hairsprays Formulation and Packaging," Ash, Michael and Irene, Formulary of Detergents and Other Cleaning Agents, New York, Chemical Publishing Co., Inc., 1980. Balsam, M.S., and Sagarin, Edward, Cosmetics. Science and Technology, Volume Two, Second Edition, John Wiley 

### &Sons, Inc., New York 1972. Bartlett, Philip L., "Aerosol Foams and the Role of Propellants", Aerosol Age, February 1986, pp. 32-35. Brown, Nellie J., Health Hazards Manual for Cosmetologists. Hairdressers. Beauticians and Barbers, Cornell University, Chemical Hazard Information Program, Grant #87044. CaliforniaAir Resources Board, The Effects of Oxides of Nitrogen on CaliforniaAir Quality, March 1990. CaliforniaAir Resources Board, Emission Inventory 1987, March 1990. Castaneda, J. Y., Hemker, W.J., and Lochhead, R. Y., "Hair Care Gels," Cosmetics 

### &Toiletries, October 1987. Davidsohn, A., and B. Milwidsky, Synthetic Detergents, 5th ed., London, England, Leonard Hill, 1972. deNavarre, Maison G., The Chemistry andManufacture of Cosmetics, volumes III 

### &IV, Allured Publishing Corporation, Illinois 1988. Dorman, S. and San Giovanni, Michael, "Hair Care in the 1990's", Aerosol Age, May 1990. Volume 35, No. 5, May 1990. DOW Customer Information Center Editors of Consumer Reports Books, with Monte Florman, How to Clean PracticallyAnything, 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, WilliamM., 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 TextileWashing. 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 Profilefor 1,4-Dichlorobenzene", prepared under contract for Agency for Toxic Substances and Disease Registry. January 1989. Maksimoski, Richard**C.~** 

### and Hoskins, James J., "Formulation ofAlcohol

. 

## .. 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., "FormulatingAerosol 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 HairsprayWithout Methylene Chloride," Aerosol Age, August 1985. Pavlichko, Joseph P., "Making aMousse

..**~,?** 

### Aerosol Age, January 1985. Petter, P. J., "Hairsprays- The Role ofResins,d Manufacturing Chemist, November 1982. · ··
IL ., 

### Pacific EnvironmentalServices, Analysis of Regulatory alternatives for Conttolling Volatile.Organic Compound Emissions from Consumer and · Commercial Products**i~** 

### New York CityMetropolitan Area, Vol.**I~.** 

### Submitted to the New York StateDepartment of Environmental Conservation, January 1990. Prince, Herbert N.,**~Disinfectant** 

### ActivityAgainst Bacteria and Viruses: AHospital Guide", Particulate and Microbial Control, March/April 1983. SanGiovanni, Michael L.,**"~PA** 

### Hunti for VOC Regulatory Options", Aerosol Age, February 1990, pp. 24-27. ScienceApplications International Corporation (EPA), Photochemically Reactive Organic Compound Emiss.jons FromConsumer 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 ScienceAction Committee, Consumer's Guide to Cosmetics, Anchor Books, New York 1980. The Soap and DetergentAssociation, AHandbook 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 BVirus to Health-Care and Public SafetyWorkers, 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 STATEWIDECONSUMERPRODUCTS 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 DetergentAssociation The Procter 

### &Gamble Company Chemcial SpecialtiesManuf. Assoc at'ion Halogenated Solvents IndustryAll ance Creative Products Inc. Cardinal · Accra Pac, Inc. Dupont Environmental ProtectionAgency· FairfieldAmerican Corp. May Kay Cosemtics, Inc. Cyc1 oAutomative Prod·ucts Justice Brothers, Inc. BAF Industries Major Paint Company The Cosmetic, Toiletry, 

### &FragranceAssociation Dow Corning Corporation Chesebrough-Ponds USA Cosmosol, Ltd. Chemical SpecialtiesManufacturers Association Portion Pac, Chemical Corporation Car-Freshener Corporation Dow Corning Corporation Champions Choice, Inc. Halogenated Solvents Industryalliance The Aerosol Group Apollo The Procter 

### &Gamble Company Colgate-Palmolive Company Paul, Hastings, Janofsky

### &Walker Faultless Starch The Soap and DetergentAssociation ClaireManufacturing 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 5-22-90Accra 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 IndustryAlliance Creative Products, Inc. The Procter 

### &Gamble Company The Soap and DetergentAssociation Ecolab Inc. The Procter 

### &Gamble Company Livingston 

### &Mattesich Law Corporation The Cosmetic, Toiletry and FragranceAssociation Paul, Hastings, Janofsky

### &Walker First Brands Corporation The Procter 

### &Gamble Company Accra Pac Group Accra Pac Group ClaireManufacturing Company Radiator SpecialtyCompany KMS Research Airwick Industries Fragrance Materials Association of the United States Sprayon Products The Soap and Detergent Association The Cosmetic, Toiletry and FragranceAssociation Sprayon Products Radiator SpecialtyCompany Chemical Specialties Manufacturers Association Ecolab Inc. The Procter

### &Gamble Company Environmental ProtectionAgency

-99- 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

- StickManufacturing 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. Stanhome Drackett Products Co. Mil-Du-Gas Co. Descale 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. DivARB CaliforniaDept. of Food 

### &Ag. Infection Control, Sac. U.C. Med Pfizer Texas Tech University Health Services Environ. ·ProtectionAgency, FIFRAReg.· Ctr EPA officeof Pesticides**(Disinf.Br~)** 

### Miles Inc. Mearl Co. Scotch Corporation Certified Growers Firman and Warren Fleming Foods Southern California Grocers Assoc. American Hospital Association CaliforniaDental Association Calif. Assoc. of Health Facilities Calif. Assoc. ofRehabilitation Fac. Calif. Licensed Voc. Nurses Assoc. Sullivan, Roche and Johnson Medi-Cal Oemert and Dougherty, Inc. National Pesticide Info. Retrieval Sys. Ohio Envir. ProtectionAgency Dow Brands E.I. Dupont De Nemours 

### &Co. Market Wholesale Grocery Co. Northern CaliforniaGrocers Assoc. Emco CaliforniaGrocers Assoc. Calif. Assoc. Hospitals 

### &Health Syst. CaliforniaAssoc. ofAIDS Agencies Calif. Assoc. ofMedical Products Calif. Hotel and Motel Association CaliforniaPharmacyAssociation 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 

### CONSULTATIONMEETINGS Descrjptjon 3M 

### Lehn 

### &Fink Cosmosol Winzer Company Procter 

### &Gamble Soap 

### &DetergentAssoc. 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

- HairsprayManufacturers CaliforniaDental Association CaliforniaAssociation of Hospitals and Health Systems Charcoal Lighter Fluid Industry Representatives 3M 

### CSMA

- FirstBrands Lehn and Fink -101- II

II

II

IIAppendix A

CaliforniaCleanAirAct Section 26AB 2595 SEC.26. Section 41712 is added to the Healthand SafetyCode,toread: 41712. (a) On or beforeJanuary.1, 1992, the state boardshalladoptregulationstoachievethemaximum feasible. reduction in reactive organic compounds emitted by consumer products, if the state board determinesthatadequatedataexistsforittoadoptthe regulations. (b) The state board shall not adopt regulations pursuantto subdivision (a) unless the regulations are technologicallyandcommerciallyfeasible,andnecessary tocarryoutthisdivision. (c) Forpurposesofthissection,a"consumerproduct" means a chemically formulated product used by householdandinstitutionalconsumers,including,butnot limited to, detergents; cleaning compounds; polishes; floor finishes;cosmetics;personalcareproducts;home, lawn,andgardenproducts;·disinfectants;sanitizers;and automotivespecialityproductsbutdonotincludepaint, furniturecoatings,orarchitecturalcoatings. (d) PriortoJanuaryl, 1994,adistrictshalladoptno regulation relating to a consumer product which is differentthananyregulationadoptedbythestateboard forthatpurpose.Appendix 8

Proposed Consumer Product Regulation

### PROPOSED REGULATIONFOR REDUCING VOLATILE ORGANIC COMPOUND EMISSIONSFROMCONSUMERPRODUCTS Adopt newArticle 2, Consumer Products, Sections 94507-94516, Title 17, California Code ofRegulations, to read as follows:



### SUBCHAPTER 8.5 CONSUMERPRODUCTS

Article2. Consumer Products



### 94507. Applicability Except as provided in Section 94510, this article shall apply to any person who sells, supplies, offersfor sale, ormanufactures consumer products in the state ofCalifornia. NOTE: Authoritycited: Sections 39600, 39601, and 41712, Health and Safety Code. Reference: Sections 39002, 39600, 40000, and 41712, Health and Safety Code.



### 94508. Definitions For thepurpose ofthis article, thefollowing definitions apply: ( 1) Aerosol Food Product means anyfood product dispensedfrom an aerosol container. ( 2) Aerosol Product means apressurized spraysystem that dispenses product ingredients bymeans ofapropellant ormechanically inducedforce. ( 3)Air Freshener means any consumerproduct including, but not limited to, sprays, wicks, powders, and crystals, designedfor the purpose ofmasking odors, providing a scent, or deodorizing. This category includes disinfectant aerosol sprayproducts that are sold or advertisedfor dual use as airfresheners and hard surface disinfectants. "Airfreshener" does not includeproducts that are used on the human body, orproducts thatfunction primarilyas cleaningproducts as indicated on aproduct label or advertisement.( 4) Antjperspjrant·means anyproduct 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 xi11abjat 1 east 20 percent in at least 50percent ofa target population. ( 5) Architectural Coating means coatings applied to stationary structures and their appurtenances, tomobile homes, to pavements, or to curbs. ( 6)Automotive Bug and Tar Remover means aspecialtycleaningproduct used primarilyto remove materials such as bugs, road tars, and oil which have adhered to amotor vehicle's body. ( 7) Automotive Chrome Polishmeans aspecialtymaintenanceproduct used to clean andpolish amotor vehicle's chrome components. ( 8) Automotive Leather/Vinyl Cleanermeans a**specialt~'cleaning** product used .to clean the leather or vinyl componi:mts.'ofamotor vehicles's interior. · · ( 9) Automotive Tire**Dressih~** means**~ ~pecialty** prbduct designed to provide lustre and/orprotect amotor vehicle tire. (10) Automotive Wheel Cleaner means a specialtyproduct used to remove materials such as dirt and grimefrom amotor vehicle's wheels. (11) Automotive Wjadshjeld Washer Fluid means any liquiddesignedc"fdr use in amotor vehicle windshieldwasherfluid systemfor the ·purpose ofcleaning, washing, orwetting the windshield(s). ·

Automotive windshieldwasherfluid does not include anyfluid which isplaced in anewmotor vehicle at the time the vehicle is manufactured. (12) Bathroom and TUe Cleanermeans aspecialtycleanerformulated specificallyfor bathroom and/or tile cleaning. (13)**Brake-Cleap~r** means a 5pecialty cleaningproduct designed to remove oil,:grease, or brakefluidfrom motor vehicle brakes without leaving a residue. ·. (14) Carburetor -dChoke Cleanermeans a product designed to remove dirt and other contaminants.from

### acarburetor and its components. (15) Charcoal Lighterflujd means any combustible organic liquid used to ignite charcoal. (16) Colorant means anypigment or coloringmaterial used in a consumer productfor an aesthetic effect, or to dramatize an ingredient.

-2-(17) Consumer Product means a chemicallyformulated product used by household and institutional consumers including, but not limited to, detergents; cleaning compounds; polishes;floorfinishes; cosmetics; personal careproducts; home, lawn, and garden products; disinfectants; sanitizers; and automotive specialty products but do not includepaint,furniture coatings, or architectural coatings. (18) Deodorant means anyproduct including, but not limited to, aerosols, roll-ons, sticks, pumps, pads, creams, and squeezebottles, that is intended by themanufacturer to be used to mrnrmrze odor in the human axilla by retarding the growth of bacteriawhich cause the decomposition ofperspiration. (19) Disinfectantmeans anyproduct intended to destroyor irreversibly inactivate infectious or other undesirable bacteria, pathogenic fungi, or viruses on surfaces or inanimate objects andwhose label is registered under the Federal Insecticide, Fungicide, and RodenticideAct (FIFRA, 7 U.S.C. 136, et seq.) (20) Distributormeans any personwho transports or stores or causes the transportation or storage ofconsumerproducts at anypoint between any consumerproduct manufacturingplant and any retail outlet orwhole-sale-purchaser-consumer'sfacilities. (21) Double Phase Aerosol AirFreshener means an aerosol airfreshener with the liquid contents in two ormore distinct phases and requiring that the product containerbe shaken before use to mix thephases, producing an emulsion. (22) DustingAidmeans a sprayproduct designed to assist in removing dust and other residualsfromfinished wood surfaces, including floors, andwhich afterdrying leave behind no film or other residuals on such surfaces. (23) Engine Degreasermeans a specialtycleaningproduct designed to remove grease, grime, oil and other contaminants from the external surfaces ofengines and othermechanical parts. (24) Executive Officermeans the Executive Officerof theAirResources Board, orhis orherdelegate. (25) Fabric Protectantmeans aproduct speciallydesigned to be applied tofabric substrates to protect the surfacefrom soilingfrom dirt and other impurities. (26) Flexible FlooringMaterial means asphalt, cork, linoleum, no-wax, rubber, seamless vinyl and vinyl compositeflooring.

-3-(27) Floor Poljsh (Wax) means waxes, polishes, finiSh restorers o'r any otherproducts for thepurpose ofpolishing,**prot~cting** or enhancing the surfaces

..offloors and excludingproducts onlyfor thepurpose r;Jt' cleaningfloors, productsformulatedfor unfinished woodfloors, and coatings subject to architettural coatings rules. (28) £QQameans (1) articles used forfood ordrink forman orother animals, (2) chewing gum, and (3) articles used for components of any such article. · (29) Fragrance means a**subst~nce** or complexmixture ofaroma chemicals, natural essential oils, and otherfunctional components with acombined vaporpres$_ure not in excess of2mmHg at 20 C, the solepurpose ofwhich is to impart an odor or scent, or to counteract amalodor. (30) FurnitureMaintenance Product means awax, polish, conditioner, moisturizeror any otherproduct designed for the purpose of po1ishing, protecting orenhancingfinishedwood surfaces other thanfloors and excludes products onlyfor the purpose of**cleanjn~.** Furniture**maintenanc~**produtt does not**includ~**dusting sprays.·· (31) Furniture Coating means anypaint applied to; roomfurnishings which include cabinets (kitchen, bath and vanity),.**tab~~s,** chairs, beds, and sofas.

. " (32) General Purpose Cleanermean; aformulation desigiiedfor.general all-purpose cleaning, in contrast to specialtycleaning·products made to clean in certain situations. (33) Glass Cleanermeans aspecialtycleaningproduct designed**prima~ily** for cleaning surfacesmade ofglass. · (34} Hairspraymeans aconsumerproduct designedprimarilyfor the purpose,of.dispensingdroplets ofaresin on and into ahair**coiffur~** Which will impart sufficient rigidity to the. coiffure to establish

## or:**re~ain** the stylefor aperiod oftime. (35) HairMousse means ahairstylingfoam whichfacilitates styling of acoiffure andprovides limited holdingpower. (36) Hair Styljng Gelmeans ahigh viscosity, oftengelatiriou;, product thatcontains aresin and is applied to hair to aid in stylingand sculptingofthe hair coiffure. (37} HouseholdAdhesivemeans any substance that is used to bond one surface to another by attachment.

-4-(38) Household Consumermeans anyperson who uses consumerproducts in his orherdaily activities including, but not limited to, personal care; cooking; cleaning; laundering; or home and auto maintenance. (39} Household Pestjcjdemeans anypesticideproduct distributed to the retail market. (40} Household Sealant and Caulking Compound means any product designed tofill in cracks, close or secure an object, or to prevent seepage ofmoisture or air. (41} Industrial SprayBuffmeans a liquid or aerosol product mixture of polymer, resins, waxes and solvents that is used in conjunction with afloor machine and special padfor restoringwornfloor polishes. (42) Insect Repellentmeans acompound or combination ofcompounds which are applied to human skin, hair or clothing in order to prevent contact with or otherwise repel biting insects and pests. (43) Institutional Consumermeans an organization, business, or establishment engaged in either the nonprofitpromotion ofa particularpublic, educational, or charitable cause, or the transfer ofcommodities or servicesfor 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 includeprivate residences. (44) Laundry Detergent means aproduct containing asurfactant and other ingredients, formulated to clean and careforfabric articles. (45) Laundry Prewash means aspecialtyproduct that is applied to a fabric prior to laundering and that supplements and contributes to the effectiveness of laundrydetergents and/orprovides ·specializedperformance. (46) Laundry Starch Product means aproduct that is applied to afabric after laundering to impart andprolong a crisp, fresh look and retain the shape ofthe garment and thatmay act as an aid to make ironing ofthefabric easier. Such products include, but are not limited to, fabricfinish, sizing, and starch. (47) Lubricant means any liquid or solid that reducesfriction, heat, and wearwhen applied as asurface coating to amovingpart.

-5-(48) Manufacturer means anyperson or business entity thatproduces, packages, repackages, or relabels aconsumerproductfor sale in California. (49) Nail Polish Removermeans aproduct primarilyused to remove nail polishand coatingsfromfingernails or toenails. (50) Nail Poljsb means any clearor colored coating applied to the fingernails or toenails and includes lacquers, enamels, acrylics, base coatsand top coats. (51) Nonresjlient Flooringmeansflooring ofamineral contentwhich is notfl.exible. Nonresilientflooring includes terrazzo, marble, slate, brick, stone, ceramic tile and concrete. (52) oven Cleanermeans any specialtycleaningproduct designed to clean and to remove driedfood depositsfrom ovenwalls. (53) Paint means anypigmented liquid, liquefiable, ormastic composition designedfor application to a substrate in a thin

. layerwhich is converted to an opaque solidfilm afterapplication and is usedfor protection,.decorationor identification, or to serve somefunctional purpose such as thefilling or concealing of surface irregularities or the modification of light and heat radiation characteristics, etc. (54) Paint Strippermeans anyproductformulated to stripor remove paintfrom a substratewithoutmarkedlyaffecting the substrate itself. (55) Percent-Bv-Wejghtmeans the total weight ofVOC except those VOCs exempted under Section 94510, expressed as 

### apercentage ofthe total netweight oftheproduct exclusive ofthe container or package as calculated according to thefollowing equation: .Percent-By-Weight=

·where,·**~** 

### * 100 A

A

### =netweight ofunit (excluding container andpackaging) 8 =weight ofVOCs, as defined in Section 94508, per unit C=weight ofVOCs, exempted underSection 94510, per unit (56) Pesticidemeans and includes any substrates ormixture of substances labeled, designed, or intendedfor use inpreventing, destroying, repelling ormitigatinganypest, or any substance or mixture ofsubstances labeled, designed, or intendedfor use as a defoliant, desiccant, orplant regulator,; provided that the term upesticideu will not include any substance ormixture of substances which theEnvironmental ProtectionAgencydoes not consider to be apesticide.
-6-(57) Prooellantmeans a liquified or compressed gas that is used in whole or in part to expel from the same self-pressurized container orfrom a separate container a liquid or solidmaterial different from the propellant. (58) Pump Spray Dispensermeans anon-pressurizeddispenser that dispenses product ingredients bymeans ofamechanical force induced by the hand ofthe operator. (59) Retailermeans anypersonwho owns, leases, operates, controls, or supervises a retail outlet. (60) Retail Outletmeans any establishment at which consumerproducts are sold, supplied, or offeredfor sale. (61) Rug Deodorizermeans anyproduct designed to mask odors, provide a specificdesired scent, or to deodorize carpets, rugs, or other floor coverings. This does not includeproducts thatfunction as cleaningproducts. (62) Shaving Cream means an aerosol product which dispenses afoam lather intended to be usedwith ablade or cartridge razor, or otherwet-shaving system, in the removal offacial or other bodily hair. (63) Shavjng Gel means an aerosol product which dispenses agel capable ofbeingformed into afoam lather intended to be used with a blade or cartridge razor, or otherwet-shaving system, in the removal offacial or other bodilyhair. (64) Single Phase Aerosol Air Freshener means an aerosol airfreshener with the liquid contents in asingle homogeneous phase andwhich does not require that theproduct container be shaken before use. (65) Volatile Organic Compound (VOC) means any compound containing at least one atom ofcarbon, exceptmethane, 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 aproduct applied tofabric to reduce absorption ofwater. (67) Wood Floor Wax means wax-basedproductsfor use solelyon wood floors.

-7-NOTE: Authoritycited: Sections 39600, 39601, and 41712,· Health and Safety Code. Reference: ·Sections39002, 39600, 40000, and41712, Health.and Safety Code.

94509. Standards for ConsumerProducts (a) Except as provided in Sections 94510, 94511, and 94514, no p,rson shall sen, supply, offerfor sale, ormanufacturefor sale in California any consumerproduct which, at the time ofsale or manufacture, contains volatile organic compounds in excess ofthe limits specified in the**followin~** Table orStandards after the specified effectivedat"es.

Table ofStandards Percent Volatile Organic Compounds byWeight

<" Future Effective Product Category 111/93 111/94 (Date) AirFresheners Single Phase Aerosbls 70 30 

# . (1996) Double Phase Aerosols 30 Liquids/Pump Sprays 18 Solids/Gels 3 0U(l1 PurposeAirFreshener-

.DisinfectantAerosol Sprays 60 Automotive,Windshield Washer F7ui.ds: Type AAreas* 35'

· Al1Other.Areas
. 10 Bathroom and Tile·Cleaners 5 Engine Degreasers 75 50 (1996) Floor Polishes/Waxes Productsfor Flexible Flooring Materials 7 ProductsforNonresilient F7ooring 10

-8-Table ofStandards (continued) Percent Volatile Organic Compounds byWeight

Product Category 111193 111194 Wood F7oorWax 90 Furniture Maintenance Products Aerosols 25 All Other Forms except Solid orPaste Forms 7 General Purpose Cleaners 10 Glass Cleaners 6 Hairsprays 80 Hair Mousses 16 Hair Styling Gels 6 Insect Repellents Aerosols 65 Laundry Prewash Aerosols/Solids 22 Al1Other Forms 5 Nail Polish Removers 85 Oven Cleaners Aerosols/PumpSprays 8 Liquids 5 Shaving Creams 5 Future Effective

(Date}

55 (1998)

75 (1996)

Type AAreas include only thefollowing: Del Norte, Shasta and Trinity Counties; the Great Basin Valley, Lake Tahoe, Mountain Counties, andNortheast PlateauAirBasins, as defined in Title 17, California Code ofRegu1ations, Sections 60105, 60108, 60111, and 60113.

-9-(b)

(c)

(d)

(e)

(f)For consumerproducts forwhich the label, packaging, or accompanying literature specificallyrecommends dilution prior to use, the limits specified specified in subsection (a) shall apply to the product onlyafter the minimum recommended dilution has takenplace. Forpurposes ofthis subsection(b), "minimum recommended**dilution~·** shall not include recommendations for incidental use ofaconcentratedproduct to deal with limited special application such as hard-to-remove soils or stains. Notwithstanding theprovisions ofSection 94509(a), a. consumer product manufacturedprior to the earlieit effectivedate specifiedfor thatproduct in the Table ofStandards may be sold, supplied, orofferedfor salefor up to one year after the earliest specifiedeffectivedate. This subsection (c) does not apply to anyproduct with aspecified effective**d~te** of1/1/93 that is sold, supplied, or offeredfor sale in theBayArea Air QualityManagement District. ·· · For those consumerproducts that are registeredunder**th~** Federal Insecticide, Fungicide, and RodenticideAct, (FIFRA; 7

## ·u·.s.c.**S~ction** 136-136y), the effectivedate ofthe VOC standards specified in subsection (a) is one year after the date specified. EffectiveJanuary 1; 1993, for any consumerproductfor Which VOC standards are specified under subsection (a), no person shall sell, supply, offerfor sale, ormanufacture in California any consumerproduct which contains any ozone-depleting compound regulated by the U.S. Environmental ProtectionAgency (EPA) under itsfinal rule "Protection ofStratospheric Ozone" (Published at 53 Federal Register (FR) 30566-30602 (August 12, 1988) orwith an ozone-depletingpotential ofgreater than 0.00 as listed in the appendix entitled 

### "AFEAS Report" ofthe UnitedNation's Environmental Panel Integrated Report "ScientificAssessment of Stratospheric Ozone: 1989". Before using any halogenated compound as a replacementfor aVOC in consumerproducts whose ozonedepletingpotential is not addressed in the

### AFEAS Report,.the manufactur:,er or userofthat compoundmust determine the compound's ozone-depletingpotential using one ofthefull atmosphericmodels described in the

### AFEAS Report,

# or any other methoddetermined by the Executive Officer to give equivalent results. The requirements ofsubsection (e) shall not apply to:

1} any existingproductformulation that complies with the Table ofStandards which is sold, supplied, offered for s.ale in Californiaprior to the effectivedate ofthis article, or any

.existingproductformulation that is sold supplied, offeredfor

sale in Californiaprior to the effective date ofthis article that is reformulated to meet the Table ofStandards 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 aconsumerproduct in an amount equal to or less than 0.01% byweight.

NOTE: Authoritycited: 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 consumerproducts manufactured in Californiafor shipment and use outside of California. (b) The provisions ofSection 94509(a) do not apply to amanufacturer who sells, supplies, oroffersfor sale in California aconsumer product that does not complywith the VOC standards specified in Section 94509(a), as long as the manufacturer can demonstrate both that the consumerproduct is intendedfor shipment and use outside ofCalifornia, and that themanufacturer has taken reasonable prudent precautions to assure that the consumerproduct is not distributed to California. (c) The requirements ofSection 94509(a) shall not apply tofragrances and colorants up to acombined level of2percent byweight contained in any consumerproduct. (d) The requirements ofSection 94509 shall not apply topaint, furniture coatings, or architectural coatings including aerosol (spray) paints. (e) The requirements ofSection 94509(a) shall not apply to any VOC which either: {1) has a vaporpressure of less than 0.1 mmHg at 20 degrees Centigrade, or (2) consists ofmore than 12 carbon atoms, ifthe vaporpressure is unknown. (f) The requirements ofSection 94509(a) shall not apply to the following organic compound in insect repellents: (1) 2-ethyl-1,3-hexanediol (Rutgers 612). (g) The requirements ofSection 94512(b) shall not apply to consumer products registered under FIFRA. (h) The requirements ofSection 94509(a) shall not apply to air fresheners that are comprised entirelyoffragrance, less

-11-compounds not deftned as VOCs under Section**9450~** or exempted**un~er** Section 94510(e). (i) The requirements ofSection 94509(a) shall not apply to air fresheners containing at least 98% paradichlorobenzene. ' NOTE: Authoritycited! Sections 39600, 39601, and 41712, Health and Safety Code. Reference: Sections 39002, 39600, 40000, and 41712, Health and Safety Code.

94511. InnovatjyeProducts (a) The Executive Officer shall exempt a consumerproductfrom the requirements ofSection 94509(a) ifamanufacturerdemonstrates byclear and convincing evidence that, due to some characteristic ofthe prbduct formulation, design, delivery systems or otherfactors, the use ofthe product will result in less VOC emissions as compared to emissionsfrom arepresentative consumerproduct of,the same product categoryor, if the innovativeproduct is amodification to an existingproduct, the use ofthe product will result in less VOC emissions as compared to the reductions in emissions that would have occurredfrom that existing product had it been reformulated to meet the Table ofStandards and retained the same product efficacyas the originalformulation. (b) For thepurposes ofthis section, "representative consumerprodi.(Ct" means aconsumerproduct whichmeets the VOCstandards specified in Section 94509(a) and, based on tests generallyaccepted by the consumer products industryand concurredwith by the Executive Officer, has similar efficacyas other complying consumerproducts in the same product category. (c)

(d) For thepurposes ofthis sectionan "existingproduct" isany formulation ofthe same product categoryandform sold, supplied manufactured, or offeredfor sale in Californiaprior to the effective date ofthis article. Amanufacturer shall apply inwriting to the Executive Officer.forany exemption claimed under this subsection'{a). The application sha17 include the supportingdocumentation that demonstrates the reduction of emissionsfrom the innovativeproduct, including the actual physical test methods used to generate the data**~nd,** ifnecessary, 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 conditionsfor granting the exemption including, but not limited to, the VOC contentfor the innovativeproduct, test methodsfor determining the VOC content and otherparameters identified as necessaryfor the performance oftheproduct. All information submitted by amanufacturerpursuant to this section shall be**h~ndled** in accordance with theprocedures specified in Title 17, California Code of Regulation, Sections 91000-91022.

-12-(e)

(f)

(g)

(h)

(i)

(j)Within 30 days ofreceipt of the exemption application the Executive Officer shall determine whether an application is complete. Ifthe Executive Officer determines there are deficiencies in the application, the manufacturer shall be notified in writing ofthe decision, specifying the reasonsfor 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 exemptionfrom the requirements ofSections 94509 will be permitted. The applicant and the Executive Officermay mutually agree to a longer time periodfor reaching adecision, and additional supportingdocumentation may be submitted by the applicant before a decision has been reached. The Executive Officer shall notify the applicant ofthe decision inwriting and specify the reasonsfor approving ordenying the exemption. An exemption granted by the Executive Officerpursuant to this sectionmay specify such terms and conditions that are necessary to insure that emissionsfrom theproduct 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 ofthe innovativeproduct, dispensing rates, application rates or otherproducts deemed necessary. The Executive Officer shall also specify the testmethodsfor determining conformance to the conditions established. The testmethods shall include criteria for reproducibility, accuracy, and sampling and laboratoryprocedures. For anyproductfor which an exemption has been granted pursuant to this section, the manufacturer shall notify the Executive Officer in writing within 30 days ofany change in the productformulation or recommended product usage directions, and shall also notify the Executive Officer within30 days ifthemanufacturer learns ofany informationwhich would alter the emissions estimates submitted to the Executive Officer in support ofthe exemption application. IfVOC standards are loweredfor aproduct category through any subsequent rulemaking, all innovative product exemptions grantedfor products in the product category, except as noted in this subpart, shall have no force and effect as ofthe effective date ofthe modified VOC standard. This subpart shall not include those innovative products the VOC emissions ofwhich are less than the appropriate lowered VOC standard andfor which awritten notificationofsuch 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 ofsuch standard. Ifthe Executive Officer believes that a consumerproductfor which an exemption has been granted no longermeets the criteriafor an innovative product specified in subsection (a), the Executive Officer may hold apublic hearing in accordance with the procedures specified in Title 17, California Code ofRegulations, Part III, Chapter 1, -13-Subchapter 1, Article 4 (commencing withSecti'on 60040), to determine if the exemption**sho~!d** be modi.fi.ffd or**~revoked.**

- . '· ,' NOTE: Authoritycited: 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 Ifanywhere on the container ofany consumerproduct, on any stickeror label affixed thereto, or in any sales or advertising literature, any representation is made that the**produ~t** may be used as, or is suitablefor use as a consumerproductfor 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 threemonths after the effectivedate ofthis article, each manufacturer ofaconsumerproduct subject to**Se~tion** 94509 sha11 clearlydisplayon each consumerproduct container'orpackage, the date on which theproduct was · manvfactured, or a code indicating such date. Ifamanufacturer uses a code indicating the date ofmanufacture, an explanation of the code must befiled with the Executive Officer oftheARB no later thanthreemonths after the effectivedate ofthis article. NOTE: Authdritycited: 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 beforeMarch 1, 1991, and no later thanMarch 1ofevery thirdyear thereafter, each.manufacturer ofconsumerproductsfor which a VOC standard is specified in Section 94509(a) or approved as an innovativeproduct under Sectiori94511, must register such products withtheExecutive Officer. The registration shall" include, but not be limited to, thefo17ow·ing information: (1) the brand namefor each consumerproduct; (2) the owner ofthe trademark orbrand name; (3) theproduct category towhich the consumerproduct belongs; (4) theproductforms (aerosol, pump, liquid, solid, etc.); (5) the California annual sales inpounds peryear and themethod used to calculate California annual sales;

-14-(b)

(c) (6) the total VOC (as defined in Section 94508) content in percent byweight which: (a) has a vaporpressure ofgreater than orequal to 0.1 mmHg at 20 degrees Centigrade, or (b) consists of12 or less carbon atoms, ifthe vaporpressure is unknown; Manufacturers shall also provide the registration data specified in subsection(a)for thefollowing consumerproducts: automotive cleaners (bug and tar removers, brake cleaners, chrome polishes, leather/vinyl cleaners, tire dressings, wheel cleaners), dusting sprays, industrial spraybuffproducts, insect repellents (creams, pump sprays, solids/sticks), laundrydetergents, 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 lighterfluid, fabric protectants, water proofingproducts and airfresheners comprised of**100~**fragrance. Upon 90 days written notice, the Executive Officermay also require amanufacturer to supply the registration data listed in subsection (a) for any consumerproduct that the Executive Officer may specify. Ifthe Executive Officerdetermines that the registrationdata is no longer necessaryfor any consumerproduct in this section, he or she shall notifymanufacturers that data submission is no longer necessary. All information submitted bymanufacturerspursuant to Section 94513 shall be handled in accordance with the procedures specified in Title 17, California Code ofRegulations, Sections 91000-91022. NOTE: Authoritycited: Sections 39600, 39601, 41511, and 41712, Health and Sections 39002, 39600, 40000, 41511, and 41712, Safety Code. Reference: Health and Safety Code. 94514. Variances (a) Anyperson who cannot complywith the requirements setforth in Section 94509, because ofextraordinaryreasons beyond the person's reasonable control may apply in writing to the Executive Officerfor avariance. The variance application shall setforth: (1) the specific grounds upon which the variance is sought; (2) theproposed date(s) bywhich compliancewith theprovisions ofSection 94509 will be achieved, and (3) acompliance report reasonablydetailing the method(s) by which compliance will be achieved. (b) Upon receipt of

## avariance application containing the information required in subsection (a), the Executive Officer shall hold a public hearing to determine whether, underwhat conditions, and to what extent, avariancefrom the requirements in Section 94509 is -15-necessaryandwi11 be permitted'. Ahearing shal1be initiated no later than 75 days after receipt\OfavariSnce application. Notice ofthe time andplace ofthe hearing shall be sent to the applicant by certifiedmail not less than 30 days prior to the · hearing. Notice ofthe hearing shall also be submittedfor publication in the California RegulatoryNotice Register and sent to everypersonwho requests such notice, not·less than 30 days prior'to the hearing. The notice shall state that theparties 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 thepublicfor inspection. Interested members.ofthepublic shall be allowed

### areasonable opportunity to testifyat the hearing and their testimonyshall be considered. (c) No variance shal1**b~** granted unless all ofthefo77owihgJindings

(d)

. (e)

(f) are made: · · (1)

(2)

(3) that, because ofreasons beyond the reasonable cqntrol ofthe applicant, requiring compliancewithS.ection 94509Wquld result in extraordinary**econom~c** hardship. · that thepublic interest inmitigating the extraordinary hardship to the applicant by issuing the variance outweighs thepublic interest in avoiding any increased emissions of air contaminants which would resultfrom issuing the variance. · that the compliance reportproposed by the applicant can reasonablybe implemented, andwill achieve compliance as expeditiouslyas possible. Any variance order shall specifyafinal compliance date bywhich the requirements ofSection 94509will be achieved. Anyvariance order shall contain acondition that specifies increments of progress necessary to assure timelycompliance, and such other conditions that the**Executi~e** Officer, in consideration ofthe testimonyreceived at the hearing,·finds necessary to car/'y out thepurposes ofDivision26 oftheHealth and Safety**Cod~,;** Avariance shall cease to be effective uponfailure ofthe party to whom the variance**~as** granted to Complywith any term'or condition ofthe variance. Upon the application ofanyperson, the Executive Officermay review, andfor good cause, modifyor revoke avariancefrom requirements ofSection 94509 after·holding apublic hear{ng in accordance with theprovisions ofsubsection (b). NOTE: Authoritycited:**Section~** 39600, 396U1, and 41712, Health and Safety Code. Reference: Sections 39002, 39600, 40000, and 41712, Health and SafetyCode.

-16-

...94515. TestMethods (a) Testing to determine compliance with the requirements ofthis article, shall be performed using one ormore ofthefollowing analytical methods: (1) Method 24-24A, Part 60, Title 40, Code of Federal Regulations, AppendixA, July 1, 1988; (2} Method 18, Federal Register48, no. 202, October 18, 1983; (3) Method 1400, NIOSHManual ofAnalytical Methods, Volume 1, February 1984; or (4) Environmental ProtectionAgencyMethod 8240 "GCIMSMethod for Volatile Organics," September 1986. Alternativemethods which are shown to the satisfactionofthe Executive Officer to accurately determine the concentrationofVOCs in a subjectproduct or its emissionsmay be used upon approval ofthe Executive Officer. (b) Compliance may also be demonstrated through calculationofthe volatile organic compound contentform records ofthe amounts of constituents making up theproduct. Ifthis option is used, daily records ofthe amounts and chemical composition ofthe constituentsmust be kept**f~r** at least threeyears. (c) In determining compliance with the requirements ofthis article, the results oftests conducted bythe Executive Officeror bythe Environmental ProtectionAgency to determine the volatile organic compound content ofconsumerproducts shall take precedence over the results oftests conducted byothers to determine that volatile organic compound content. The results oftests conducted bymanufacturers orothers to determine the volatile organic compound content ofconsumerproducts shall be subject to verificationby the Executive Officer. NOTE: Authoritycited: Sections 39600, 39601, and 41712, Health and Safety Code. Reference: Sections 39002, 39600, 40000, and 41712, Health and SafetyCode. 94516. Severabjljtv Each part ofthis article shall be deemed severable, and in the event that anypart ofthis article is held to be invalid, the remainder of this article shall continue infull force and effect. NOTE: Authoritycited: Sections 39600, 39601, and 41712, Health and Safety Code. Reference: Sections 39002, 39600, 40000, and 41712, Health and SafetyCode.

-17-Appendix C

VOC SurveySummary

### 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 IngelheimAnimal 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

### &DAssociates 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. FitzpatrickBros. Inc. Follmer Development, Inc. Fosrco, Inc.

C-1

### Frank Fuhner International Inc. Georgette Klinger, Inc. Grow Group, Inc. H

### &SChemicals 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 SafetyAppliances 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 ofCalifornia 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. Hydroso1, 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 0Pine 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. TurtleWax 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. LillyCo. The Dial Corporation The George Basch Co. Inc. The las-StikManufacturing 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-3RESULTS OF CARB CONSUMER PRODUCTS VOC SURVEY (INCLUDING HEIDEN ASSOCIATES AND BAKERAND HOSTETLER DATA)SALES

### voc 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 So1id 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~** 

### So1 id

Glass**Cl~aner** 4,600 

### Aerosol Liquid/Pump

Hair Spray 92,000 

### Aerosol .Pump Hair Mousse 1,160 

### Aerosol

Hair StylingGel 820 

### Liquid Pump

Personal 880 

### Aerosol Insect Repellent Laundry 4,000 

### Aerosol

·Prewash Liquid/Pump So1

### 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 

### PERCENTAGESHARE 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 spraydisinfectants (1) (2) (3) 

### N/A =NotApplicable; Dual PurposeAir Freshener/Air Disinfectant**dat~** 

### · not included in Air Freshener data. UTQ =Unable to Quantify. Itwas announced that 10% 

### ofthemarket share and emissions from nonwood floor products are due to products for nonresilientfloors, the remaining 90% 

### being due toproducts for flexible flooring.



### C-5STATE OF CALIFORNIA AIR RESOURCES BOARD !102 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 responsi b i1iti es.

### 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 detai1 

### 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 assist.the

.A i.r. Resources Board i n dev e 1 o p i n g f easi 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**~.-------~--**

......

## ~--- 0ean C. Simero th. Chief ( 1 

### Cr,iteria Pollutants BranchDote: 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 fiII 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 Iisted as o single product. If you do Iist 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 Iist the nome and address of the products' manufacturer. I.f you o r e o p r i v o t e Io b eI m onu f**~**t u r e r t h e nome Ii ste d here wi II not necessorily 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 theeweight 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 Colifornio 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, metalIic 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 Ilsted 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: Propellont meona a VOC containing liqulfled or compressed gas In a container, where the purpose of the Ilquifled or compressed gas Is to expel the contents of the container. Non-VOC containing propellonts 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 Tota·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 Availob1e 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 stiI 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 1Yea (X 1No



## ----------------------------------------------------------------------------------------------------------------------------- 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) ShooI
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 pollshe•, 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 Persona+.Deodoran.ts, .AntIp•rspIrants, P-owders and Deodorant 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,)Estimatesofthe Resident PopulationotStates:July i, 1988, and ComponentsofChange Since 1980**~S:urce:** 

## u.s. l:ept. ofCamerce Eureau oftheCensus SeriesP-25, No. 1044) (1:- tl'lous.anas.**Inoue~** Armed Forcesresldong ,,., e!ICI Sr.tel

u....ree Sr.tes i'cOI"'u"'eas:

.. 1-.ew**~.,~:and**

.**MtO~Ie** Au;nue Moawes: Eas:"'o"nCentra. WestNor:nCenua: I .I Sourn SoutnAnannc EastSoutnCentra1 WestSo\.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

MICidleAaanac:

N- YOR.......

. .....· ·**N-J~** ........................ Fennsyrvanoa

....................... Eas:NoMC..ntral. On.o

.............**lno~ana**.......... ilioi1QIS...•....•••.. Mier\tgan.

.••....... 

## ::::::I

WISCOriSin..•..............· · · · · · · · · WestNOM**Centra~:**

Monnesota

...........·............ Iowa..•.....•............········· Missoun .......••..·· ...··········· NOI'Ill**Oa~eota** . .•

. . . . . . . . . . . .··.····· Scutl'lOuolll

....................... NeoriiSIIll•.•••.•..•........···•··•·**~nsas**............................ Scull'lAaanac

Oeta•., •.;..•.....................**~**..........................**OiS~ne~**otCoiUIIIOia

.................. vrvrma
............................

# =~~:::::::::::::::::::·::**~.:::::::::::::::::::::::::::** EastSoutnC..nns:

### ~~:::::::::::::::::::::::::

### ~::::::::::::::::::::::::: WestSoull'lc.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' ssa:-a 42.•19**17.:'~9:** S.oiSSS 42.426

### ~~:i~1 50.679: t:l.:J2!

.**~7.::!51**

1.205 1.0!5

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St7 6.015 1.876 6.-'891 3.470 6.3-421 12.335

## I

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2.395 4 ..ol08**::!.2~2** 16.&«,

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4.5o48 2.767 28.::!14 S2.oi 1,098

•Reoresemszero Otanumbertl'latroundstoz.,o.STATE OF CALIFORNIA George Da&JKme;tan.**Go~,_-** AIR RESOURCES BOARD 1102 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 Ghave 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. Arecent 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 rom Y.O

### u r comp a nY 

### 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 Hair M o u.ss e Insect Repellents Laundry Detergents (Liquids and Powders) Laundry Prewash Oven Cleaner Nailpolish Remover ·Rug Deodorizers

Windshield Washer FluidATTAC.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 1aw, and (2) to the Federa1 Environmenta1·

..··· 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 AnnouncementsCompany WORKSHOP PARTICIPANTS LOS ANGELES, CA SEPTEMBER 6-7, 1989.
Company The Soap and DetergentAssociation Procter 

### &Gamble The Gillette Company Faultless Starch/BonAmi Company S.C. Johnson Wax The Clorox Company 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 TheDail 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 BentleyMftg. DuPont PMI Distributors The Drackett Company Kans Research Grow Group, Inc. Sharp, Green, 

### &Lankford HSIA Currel Assoc. Ian Gecker 

### &Associates ArmorAll 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 IndustryAlliance Boyle Midway Household Products Eagle One .'. '·

### WORKSHOP PARTICIPANTS SAN FRANCISCO, CA MARCH 28-29, 1990 Company Advanced Monobloc Accur Pac Company ClaireMfg. 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 

### &DetergentAssoc. 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 ClaireMFG Co. American Home Products Co. Precison Valve Halogenated Solvent IndustryAll. Citizens For ABetter 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 BentleyMfg. 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 GilletteCo. SEAQUIST Helene Curtis McKenna, Conner 

### &Cuneo



### D-3

### WORKSHOP PARtiCIPANTS LOS ANGELES, CA. JUNE 5, 1990 Company FairfieldAmerican, Clairol Manufacturing

. TurtleWax MaryKay Cosmetics, Inc. Dow Corning Corp. StateChemical/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/BonAmi 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 

### &DetergentAssociation Dow Corning Corporation Drackett Company Ecolab Chesebrough-Ponds USA Company DeMert 

### &Dougherty US Environmental ProtectionAgency 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 BayArea 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. ofRossville Seaquist A

irwick Shulton Group Clairol, Inc. Calmar, Inc. Dow Brands \;'



### Diversified CPC International POW! Chemical Company FirstBrands 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 BayAreaAir 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 CompanyWAIB Aeropres Corporation 3M 

### Dial Corporation Environmental ProtectionAgency Crown Cork 

### &Seal Company Citizens ForABetterEnvironment IFF Dep Corporation Advanced MonoBloc KMS Research Radiatur Specialty I-K-I Manufacturers Livingston 

### &Mattesich for SDA PM! Distributors



### D-6STATE OF CALIFORNIA GEORGE OEUKMEJIAN.**~** AIR RESOURCES BOARD 1102 Q STREET o.o. BOX 281.5 .ACRAMENTO. CA 95812

August 14, 1989

Dear Sir orMadam: 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 CaliforniaClean Air Act. This plan describes the need for regulatory action, the regulatory authority and several milestones for meeting the legislativemandate. 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 categorybut are being addressed separately. Household products include general purpose cleaners, floor and furniture waxes and polishes, air freshners and deodorants, and laundry products. As afirst step in the development of regulations for these categories we will conduct two informal consultationmeetings 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 90012Each 

### consultationmeeting 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 consultationmeetings. We would appreciateyour review of these items and look forward to your conrnents at themeetings. The first item, "Consumer Product Emissions Survey Form," is aform that we are considering using to survey consumer products marketed·in California. The information from this surveywould 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 RegulatoryApproaches for Consumer Products," is a brief summary on different types of regulatoryoptions 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 themeeting. Atentative agenda is**~lso** 

### attached. Afinal·**,~,** 

### workshop agenda will be available at the consultationmeeting: :'

. 

### I would like to emphasize that we have not chosenaregulatory 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 thatwill provide for themaximum feasible reduction yet provide flexibility to the industry. I hope you will participate in these consultationmeetings**~nd** 

### the development of consumer product regulations. Your participation, particularly in this developmental stage, is important and essential to the success of this process. Ifyou have any questions or if

### you need acopy 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 ·· 

### StationarySource Division

EnclosuresSTATE OF CALIFORNIA AIR RESOURCES BOARD
1102 Q STREET P.O. BOX 2815 ACRAMENTO. CA 9.5812



### February 9, 1990

Dear Sir or**Madam~** 

### PubljcWorkshop to Qjscyss Draft Regylatjon for Consumer Products I amwriting to request your company's participation in two publicworkshops to be held by the staff of theAir Resources Board (ARB) concerning the regulation of volatileorganic compounds (VOC) in consumer products. With passage of the CaliforniaClean Air Act of 1988, the ARB was given direct authorityto adopt statewide regulations on or before January 1, 1992 to achieve themaximumfeasible reduction in volatile organic compound emissions from consumer products. In July 1989, the Board approved aConsumer Products Control Plan. To begin implementing the plan, on September 6and 7, 1989 theARB held apublic consultationmeeting to discuss the implementation of theCCAAmandate. The workshops announced in this notice are a continuation ofthe process begun last fall.

follows: WORKSHOP IIThe 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 Ti

### me: 9 : 3 0AM 

### Place: San Francisco StateOffice 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. Afinal 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 regulationwe are proposing to establish VOC standards for selected products and to require a reduction in VOC content of aerosol products equal to or greaterthan 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 ableto attend theseworkshops. These meetings will give you the opportunityto share your cormtents and concerns about the proposed regulation and your participation in this regulatory development process will help ensure aregulatibn that will achieve reductions in consumer product VOC emissions and still provide flexibility to industry. Written comments will also be accepted. Ifyou would like to offerwritten comments, please submit them no later than March 5, 1990. They should be mailed to Daniel E. Donohoue, Manager Solvents Control Section, CaliforniaAir Resouces Board at P.O. Box 2815, Sacramento, CA 95812. Questions concerning thismeeting may be directed to eitherDan Donohoue, Manager, Solvents Control Section at (916) 322-8283 or Peggy Vanicek, AssociateAir Pollution Specialist, at (916) 327-1517.

Enclosures Sincerely,

.**~·J**



# .

-'r-h;.--:?:;::

.

# ~~ 7-- 1 I

## .r,_.,//..,..**~~~.:,.,** 

## -·· (:' ,_,r', 

### PeterD. Venturini, Chief StationarySource DivisionSTATE 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 22

-828 3.•

., (
Enclosures

·, ., ,;

l·-'STATE OF CALIFORNIA AIR RESOURCES BOARD
1102 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 GeorgeOeukmejlan. 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 publicworkshop 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 IVDate: June 5, 1990
T ime: 8 : 30AM 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 allowtime for comments pertaining to the proposed BayArea 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 industrythrough Heiden Associates; the addition ofmore 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 industrywith the Technical Support Document and another revision to the draft regulation in earlyJulyfor consideration and discussion at a workshop to be held in July ofthis year.-2-



### This workshop and the previous workshops are an important component of the regulatory development process. As before, theworkshop will afford you the opportunityto participate in the development ofthe draft consumer product regulation by shar1ng your comments and concerns about the draft regulation. Ifyou are unable to attend, written comments will be accepted. Ifyou 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 StationarySource DivisionGeorgeOeukme}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 staffwill 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 PStreet Room 103 Sacramento, CA (Public parking facilities available at 7th and LStreets 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. Ifyou are unable to attend, written comments will also be accepted. Ifyou 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 lJ02 Q STREET

0. BOX 2815 :iACRAMENTO. C.:- 95812

July 10, 1990
Dear Sir or Madam: ConsultationMeeting to Discuss the Statewjde Consumer Product Regulation Innoyatjye Product Provision

The Air Resources Board staffwill 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 PStreet Room 103 Sacramento, CA (Public parking facilities available at 7th and LStreets and 2nd and PStreets) 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 presentlydefined 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 productwould 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 applyto 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 inherentlymore complex. We are especially concerned about the enforceabilityof any alternative control plans.-2-

If you have any questions regarding the consultationmeeting, please call Peggy Vanicek, Manager, Solvents Section, at (916)322-8283.

Peter D. Venturint, Chief StationarySource 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 Bof 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 publicworkshop to be held on the d•te and time given below. Date: Time: Place: July 31, 1990 9am to 5pm State Office Building 8 714 PStreet, Room 102 Sacramento, CA. (Parking facilities available at 7th and LStreets and 2nd and PStreets) Please note that the room number for theworkshop was incorrectly printed in the July5th letter. The correct room is shown above. Again, we welcome your participation in this important aspect of the regulatory development process. Ifyou cannot attend, you may wish to provide us with written comments. Please submit your conrnents byAugust 2, 1990. Ifyou 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 StationarySource DivisionAppendix E CostAnalysis CalculationsCOST ANALYSIS CALCULATIONS

Annual Cost 1. Reformulation cost estimates from industryranged 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 reformulatewas amortized over both 5years and 10 years. 3. Annual cost to reformulate a product for four cases:

Cost to reformulate: $100,000 Amortization: 5years Case 1

Assume interest rate = 10% End of Year payments

## =principal 

### * i(1+i)n
where i 

### =interest rate n

### =number ofyears (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 ofyears (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: 5year 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 ofyears

=$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 ofyears (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 ofnoncomplying formulations) 2. Number of noncomplying products fromARB surveyestimated 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-2Cost 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.

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### 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 aremarketed nationallywith 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 Fscaled down for Californiaby 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 fromARB 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 theARB VOC Survey and assuming an average unit size of 10 oz. bywt.) 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-4r

.. ' \